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HomeMy WebLinkAbout06-2449 " FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 600 N. Second Street Penthouse Suite p, 0, Box 984 Harrisburg, PA 17108 Tel.: (717) 236-8000/Fax: (717) 236-8080 Attorney for Plaintiff LEON POWELL, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 ~ - 2.'/(J'j C!. iu 'L T &V'YL COMPLAINT IN DIVORCE LISA A. TAYLOR, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children, 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle PA, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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, P A 17013 1-800-990-9108 717-249-3166 Respectfully submitted, FRIEDMAN ~ KING, P. C. ~,. r I ..,.c;' . '.' : 'j " By: <../ '-'\..\. l John F, King, Eire 600 N. Seconcf St. , 'P. O. Box 984\.. Harrisburg, PA 17108 (717) 236-8000 FIr. ~ v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. Of..., - ,),449 C/utL '--rE/z.-h ! COMPLAINT IN DIVORCE LEON POWELL, Plaintiff LISA A. TAYLOR, Defendant COMPLAINT UNDER SECTION 3301(c) AND SECTION 330Hd) OF THE DIVORCE CODE 1. Plaintiff is Leon Powell, who currently resides at 1409 Eldindean Terrace, Mechanicsburg, Cumberland County, Pennsylvania 17050, 2, Defendant is Lisa A. Taylor, who currently resides at 1409 Eldindean Terrace, Mechanicsburg, Cumberland County, Pennsylvania 17050, 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 2, 1999, in Lancaster, Pennsylvania, 5. Plaintiff avers that there is a child of the parties under the age of eighteen (18), namely: Natalie Powell (date of birth, 1/15/02). 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on October 13,2004. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. .. COUNT I REQUEST FOR EQUITABLE DIVISION OF MARITAL PROPERTY PURSUANT TO 23 Pa.C.S.A. ~ 3502(a) II. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. The Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage, 13. The Plaintiff and Defendant have been unable to agree as to equitable distribution of the said property to the date of the filing of this Complaint. WHEREFORE, the Plaintiff, Leon Powell, requests this Court to equitably divide all marital property, COUNT II REQUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER ~~ 3104(A)(1) AND (3) AND 3323(8) OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15. The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences. 16, While no settlement has been reached as of the date of the filing of this Complaint, the Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant, 17. To the extent that a written settlement agreement might be entered into between the parties prior to the time of hearing on this Complaint, Plaintiff desires that such written agreement be approved by the Court and incorporated in any Divorce Decree which may be entered dissolving the marriage between the parties. . WHEREFORE, if a written settlement agreement is reached between the parties prior to the time of hearing on this Complaint, Plaintiff respectfully requests that, pursuant to ~~ 3104(a)(1) and (3) and 3323(b) of the Divorce Code, the Court approve and incorporate such agreement in the final Divorce Decree. Respectfully submitted, FRIEDMAN & KING, p,c. . ,", Date:~;) 7" JJUo \'.c -.;.r~_ ! ' i " ~. '~''\'' C/ .\....,.~ Jolm F. King, Esquire ' .900 N. Second Street Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 . . VERIFICA nON I, Leon Powell, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorities. 1 ~ ~~+cl~=- lL Leon Powell Dated: ~ ;)'1 dtik \.) -\ ;:; ~ hl - ~ ~ w ~ .-c.. 9.-, C> -D ~ v=>. -IcJ... --- ')u 9.J --0 ~ C C) .Vz c> <n \) ~ C> -u }\- f ::]-,) ( ~I- - + ..~ ,~- '~ r' € C'~_ LEON POWELL, Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 06-2449 CIVIL TERM LISA TAYLOR, Defendant CIVIL ACTION - IN DIVORCE P g 0 -"'-' C"T"\ -n ~f: ~ ~~ ~)...: N ~t3 E~c. N 8s: ::::;.. I..."~,j , -> ,,_ ~ 5- ~-! :: t;' ~ This Agreement, made and entered into this (} j) day of A { )G U f} t: 20$, b~ee~ ...ll.Li ~ '- w -< Leon Powell, residing at 4173 Grouse Court, Apartment 112, Mechanicsburg, Cumberland MARITAL SETTLEMENT AGREEMENT County, Pennsylvania 17050, (hereinafter referred to as "Husband,", and collectively with "Wife" as "the parties") and Lisa Taylor, residing at 1409 Eldindean Terrace, Mechanicsburg, Cumberland County, Pennsylvania 17050, (hereinafter referred to as "Wife", and collectively with "Husband" as "the parties"). WITNESSETH: WHEREAS, the parties were married on October 2, 1999, and remain married; and WHEREAS, presently irreconcilable differences having arisen between the parties, as a result of which they been living separate and apart since January 1,2006 and intend to continue living separate and apart; and WHEREAS, in light of the parties' separation, they hereby desire to enter into an agreement to define their respective financial and property rights, together with all other rights, remedies, privileges and obligations which have arisen out of their marriage. The Page 1 of 10 parties agree that their future relations shall be governed and fully prescribed by the terms of this Agreement (hereinafter referred to as "the Agreement"); and WHEREAS, the parties have disclosed to the other's satisfaction the nature and value of all of their presently constituted assets, liabilities and income; and WHEREAS, Husband having been represented by the law firm of Friedman & King, P.C. with offices located in Harrisburg, Pennsylvania, and Wife having been represented by the law firm of Tanner Law Offices, LLC with offices located in Lemoyne, Pennsylvania; and NOW THEREFORE, in consideration of the mutual promIses, covenants, agreements and terms herein contained, the parties hereto intending to be legally bound hereby do mutually agree as follows: ARTICLE I SPOUSAL SUPPORT AND MAINTENANCE 1. Alimony. Husband and Wife release and discharge the other absolutely and forever for the rest fo their lives for all claims and demands, past, present or future for alimony, alimony pendente lite or for any provisions for support and/or maintenance. Page 2 of 10 2. Insurance. Neither party shall have any obligation to provide or maintain any form of insurance for the other's benefit; such insurance to include, without limitation, health, life, automobile, disability, homeowner's, and so forth. ARTICLE II EQUITABLE DISTRIBUTION 3. Except as otherwise provided herein, the parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, and neither party will make any claim to any such items which are now in the possession or under the control of the other. By these presents, each of the parties hereby specifically waives, releases, renounces and forever abandons whatever claims he or she may have with respect to any personal property which is in the possession ofthe other, and which shall become the sole and separate property of the other from the date of execution hereof. 4. Marital Home. The parties acknowledge that during the marriage, they were vested with title, as tenants by the entirety, to premises located at 1409 Eldindean Terrace, Mechanicsburg, Cumberland County, Pennsylvania 17050 (hereinafter refereed to as the "marital residence"). Husband and Wife agree that the marital residence has accrued significant value through increases in market value, improvements on and Page 3 of 10 within the premises and so forth. Said value has resulted in significant equity in the marital residences. Husband and Wife agree that the marital residence shall be sold to the most qualified buyer so as to maximize the benefit to both parties. The proceeds from the sale of the marital residence, after payment of all outstanding mortgages, liens, and closing costs shall be split between the parties such that Wife shall receive sixty percent (60%) of the proceeds and husband shall receive forty percent (40%) of the proceeds. The parties shall execute a listing agreement with a local full-time realtor no later than six (6) months from the date of execution of the within agreement. 4. Automobiles. The parties agree that each shall retain ownership of the automobile presently in their possession. Husband agrees to convey all of his right, title and interest in and to the 1998 Hond Civic to Wife by tendering and fully executing any and all documents necessary to accomplish this conveyance. Wife agrees to convey all of her right, title and interest in and to the 1991 Honda Del Sol and the Ford Aspire to Husband by tendering and fully executing any and all documents necessary to accomplish this conveyance. The parties understand and acknowledge that each shall continue to be responsible for any and all obligations with respect to their respective automobiles including, without limitation, costs of maintenance and repairs, license, registration, insurance and any miscellaneous charges in connection therewith. Page 4 of 10 5. Bank and Financial Accounts. The parties each hereby waive, release and relinquish any and all right, title and interest either may have in and to the other's separately titled bank and financial accounts; including, without limitation, checking, savings, certificates of deposit, money markets and financial investment accounts of whatever kind and nature, and neither shall make any claim against the other's property now or in the future. 6. Retirement plans, 401(k)s, lRAs and Deferred Savings Plans. Husband hereby waives, releases and relinquishes any and all right, title and interest to Wife's 40 I (k) account, or any other such retirement benefit oflike kind and character. Wife hereby waives, releases and relinquishes any and all right, title and interest to Husband's retirement accounts and any other benefit of like kind and character. 7. Stocks and Bonds. The parties agree to mutually waive, release and relinquish any and all right, title and interest either may have to any stocks, stock plans and bonds presently in either party's name. The parties agree to retain possession and ownership of such property as same is presently titled. 8. Assets Not Specifically Mentioned Herein. To the extent any asset(s) acquired during the parties' marriage is not specifically mentioned or distributed herein, the parties agree to divide and distribute same at a future date. Page 5 of 10 9. Assets Acquired Subsequent to the Execution of this Agreement. The parties agree that any asset of whatever kind and nature acquired by any possible means and titled in their individual name or in the name of another shall forever hereafter remain their separate property and shall not be subject to distribution, equitable or otherwise, in any possible future proceeding concerning the status of the parties' marriage. ARTICLE III MARITAL DEBT 12. Credit Accounts. To the extent that either party may presently have in their possession credit cards or credit/financial account access cards, which credit was obtained in the name ofthe other, each agrees to immediately refrain from using such cards at any time now or in the future, and to this end each further agrees to surrender same to the appropriate titled party forthwith. ARTICLE IV TAXES 13. Tax Returns. The parties agree to file income tax returns for the year 2006 based upon the most beneficial tax consequences to both of them. Any refunds which may be received in the future by either party and any liabilities, including underpayment oftax, penalties, interest, etc., incurred in connection with any joint income tax return Page 6 of 10 previously filed or to be filed by the parties shall be shared and/or borne equally by the parties. ARTICLE V INDEPENDENT LEGAL REPRESENTATION 14. Independent Legal Representation. The parties acknowledge that each has had the opportunity to be represented by independent counsel with respect to the negotiation, drafting and execution ofthis Agreement. Wife has been represented by Tanner Law Offices, LLC, with offices in Lemoyne, Pennsylvania and Husband has been represented by Friedman & King, P.C., with offices located in Harrisburg, Pennsylvania. The parties represent and acknowledge that each understands all of the legal and practical effects ofthis Agreement, and with this understanding, each signs voluntarily, of their own free will, and without any undue influence, fraud, coercion or duress of any kind whatsoever exercised upon either of them by any person. ARTICLE VI MISCELLANEOUS PROVISIONS 15. No molestation and Interference. The parties agree that neither will molest, malign, disturb, or interfere with the other or the other's relatives in any manner whatsoever during the period of their separation. Each shall be free from interference, direct or Page 7 of 10 indirect, by the other, and be entitled to live their life as if single and unmarried to the other. 16. No Bar to Divorce. Nothing in this Agreement shall be construed as a relinquishment by either party of their right to prosecute or defend any suit to dissolve the instant marriage in any court of proper jurisdiction. It is further specifically understood and agreed that the provisions of this Agreement relating to equitable distribution of the parties' property are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgement or order of separation or dissolution of marriage in any other state, county or jurisdiction, each ofthe parties to this Agreement hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or dissolution of marriage and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term ofthis Agreement, whether or not either or both of the parties should remarry, it being understood by and between the parties that his Agreement shall remain in full force and effect. 17. Entire Understanding. The parties acknowledge and agree that this Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. Page 8 of 10 18. Modification of this Agreement. The modification or waiver of any of the provisions of this Agreement shall be effective only ifmade in writing and executed with the same formality as this Agreement. 19. Breach. In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of a breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 20. Applicable Law and Execution. The parties hereto agree that this Agreement shall be construed under the laws ofthe Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. 21. Review of Agreement. The parties acknowledge that each has read and reviewed this Agreement in its entirety and has had the opportunity to obtain advice of separate legal counsel, prior to signing. Page 9 of 10 . ... IN WITNESS WHEREOF, and intending to be legally bound, the parties have set their hands and seals the day and year written below their respective names. :12 ~-;LL Date: D~ /2<3 Ix / I Date: ~ - 9 - 0 ~ 1a.6dk.. /1. ~~ Signature of Witness '-6~'f -4~ Signature of Witness {L~ fE fA1-m e: (L Printed Name of Witness 7;.hl'lIto. J1. hfln# Printed Name of Witness Page 10 of 10 ,.- \, LEON POWELL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2449 Civil Term LISA A. TAYLOR, Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEAL TH OF PENNSYL VANIA : SS: COUNTY OF DAUPillN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, John F. King, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Lisa A. Taylor, by Certified Mail, Restricted Delivery, as evidenced by the attached Certifi . d. Sworn and subscribed to before m>J'jil { .5 {- day of _, 2006. ~AY~ J Notary Publ llIONlnl _ ~O..... NDIaIy NIle It ~ _ClW~~ ... CIJIUII II ........ JuI" 20'0 r \. LEON POWELL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-2449 Civil Term LISA A. TAYLOR, Defendant COMPLAINT IN DIVORCE ',f '" ER .... _ 7 . Complete items 1, 2. and 3. Also complete Item 4 If Restricted Delivery is desired. . Prtnt your name and address on the reverse SC'-that we can return the card to you. . Attach this card to the back of the mailplece. or on the front If space permits. 1. AI1IcIe Addressed to: x o Agent Addl8ll88 of DelIvely -g~ Dyes DNa B. Recetved bY.!e.rlntetj N L. .. I... ~ {~ D. Is delivery address different from Item 17 If YES, enter delivery address below: !vB. Lisa A. Taylor 1409 Eldindean Terrace ~chan' - - ... -! - fI' -~ 0<'1 2. Article Number DM (ThInsfer from ...1Itbef PS Form 3811, February 2004 17050 3. ServIce 'JYpe ncertmed Mall [] Express Mall o Registered ~ Retum ReceIpt for MerchandIIe o Delivery? (Extra Fee) Xl!JYes 0750 0002 8071 9275 DomeItIc IWum Receipt , 02596-02-M-1540 ~,~ rrnIJt .. c~ ,....:J = () L. C::''2 -n ;, 0'" "'t3( (/) -t ~~ rq ::r: -V rn ::1J ..- Z~ N -om ~~ N :09 :.::::c ~~~1 c:) ~c ~ --r-- ,..~, ,'':,:7. -.....~ ...",. ::5~~ C - ~c Z -\ :f:;-... -<. ~-D (.,) -< v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2449 Civil Term LEON POWELL, Plaintiff LISA A. TAYLOR, Defendant COMPLAINT IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 2, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. / / DATED: 6cfft' ~~~ Leon Powell, Plaintiff o C ~:" ""Ou', li'l,,:, ~~S- ~ ~;. <-, :;;;::::. t,,_.; ~,);~ {:: -':;- =1 -<. ......, = = cr- (/) fTi -0 N N :l> ::I: ~ ~:D -oh1 ;56 ::;:l.,., (:s :'.J :Z?rl r'J ~ ~ .< (.,0 LEON POWELL, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2449 Civil Term LISA A. TAYLOR, Defendant COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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 . 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. 1 ~ \,~ --t6~.5. LL [eon Powell, Plaintiff Datey\ /0 'tUb I (") s; ~~~ "lJ CC 0.)\,,;.' ~?i ~,: ....';. .~ -- ~... ~~.k:: ~:2, =< ~ c::::> t::r' c.n rr1 -0 N N o .,., ~-n :~ :fJ Ou :::1..1'. -':--n 0(') Zrn ~ 35 ;;;<:, :x:- :x - - w LEON POWELL, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2449 Civil Term LISA A. TAYLOR, Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 2, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. DATED: '\- \ I("' - 04 ~, Lisa A. Taylor, Defendant ~ c:::> = 0"> (/) M -0 N N o -n -4 :C:n ~hi ::D9 qo .~, -r) ~:D ';;~~ ~'j :~ 1> ~ J:> :zr: (,..J LEON POWELL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2449 Civil Term LISA A. TAYLOR, Defendant COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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 . 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: k r, Defendant r--:I c:;;:> = <:T'> (/) fTl -0 N N :r.- :J'l: o -n -l ::I::!) ~Fn :SS9 l.::~~ -r .: (j:I.1 z~ ~~ "J::>. ~;[) < (",.1 LEON POWELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-2449 Civil Term LISA A. TAYLOR, Defendant COMPLAINT 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) of the Divorce Code. 2. Date and manner of service of the complaint: certified mail, restricted delivery, on May 8, 2006. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff 9/1/06; by Defendant 9/15/06. 4. Related claims pending: There are no related claims pending. S. (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 Plaintiffs Waiver of Notice was filed with the Prothonotary: 9/22/06 Date Defendant's Waiver of Notice was filed . ~~ ;!;;!; ;!;;!; ;!; ;!; ;!; ;!; ;!; ;!;;!; ;!; ;!; ;!;;!;;!; ;!; ;!; ;!;;!;;!;;!;;!; ~ ;!; ;!;;!; ~ ;!; ;!; ~ ;!; ~ ~~ ~~~~~~~~~~ ~~~~~~~~ ;!' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ :+. ~ ~ :+. :+. :+. :+. :+. :+. STATE OF LEON POWELL :+. :+. :+. ~ :+. :+. :+. :+. VERSUS LISA A. TAYLOR :+. :+. :+. :+. :+. :+. :+. AND NOW, PENNA. No. 06-2449 Civil Term DECREE IN DIVORCE ~~ ~ t . l TJ , 2..60b, IT IS ORDERED AND Leon Powell , PLAI NTI FF, DECREED THAT Lisa A. Taylor , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. The attached Marital Settlement Agreement is incorporated into, but not merged with, this Decree. :+.ff.:+.ff.:+. :+.:+.:+.;!;:+. :+. :+.ff.:+.;!;:+. :+.:+.:+.:+.;!; :+.;!':+. ;!;:+.:+.;!;:+. ;!;;!;;!;;!;;!;;!;;!;ff.;!; :+.;!;:+. ;!;;!;:+.:+.:+.:+. +.:+.:+. :+.;!;:+. ~~ PROTHONOTARY J. ~ :+. +. :+. ;!' :+. :+. :+. ~ +. +. :+. +. :+. +. +. +. +. +. '" :+. +. +. +. / ~ ~ f ~ r I}rJ,Jt'p 4t ftP # ~-~.p; v-Kb .. . , ~'" . , . ':t<.. ...