Loading...
HomeMy WebLinkAbout06-2907MICHELLE JOYNT Plaintiff, vs. JEFFREY M.JOYNT Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(0 -,2407 l:ivL cjn CIVIL ACTION - LAW IN DIVORCE N O T I C E 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 action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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, PA 17013 MICHELLE JOYNT Plaintiff, vs. JEFFREY M.JOYNT Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0G-2907 CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. KOPE & ASSOCIATES BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkopeftomcast.net MICHELLE JOYNT Plaintiff, VS. JEFFREY M.JOYNT Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (N, -c2Q67 l1?L?_ l CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, MICHELLE JOYNT, by and through her attorney, SHANE B. KOPE, ESQ., and makes the following Complaint in Divorce: 1. The Plaintiff is MICHELLE JOYNT, an adult individual who currently resides at 23 Bare Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is JEFFREY JOYNT, an adult individual who currently resides at 930 Cartref Road, Etters, Cumberland County, Pennsylvania, 17319. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 14, 2004 in Phoenix, Arizona. 5. The Parties separated on April 27, 2006 when the Defendant forced the Plaintiff to leave the marital home. 6. Neither the Plaintiff nor Defendant is in the military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 12. The marriage of the parties is irretrievably broken. 13. The parties are living separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two (2) years as Specked in Section 3301 (d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301 (d) of the Divorce Code. COUNT III REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 (a) OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 15. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502 (a) of the Divorce Code. 16. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing of this Complaint. 17. Plaintiff requests that the Court equitably divide, distribute, or assign the marital property between the parties. WHEREFORE, Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to Section 3502 (a) of the Divorce Code. COUNT IV ALIMONY 18. The Defendant has rendered Plaintiff unable to maintain any reasonable standard of living, let alone the standard the parties established during their marriage. 19. The Plaintiff is self-employed in that she owns her own cleaning business. The profits from this cleaning business have decreased since the marriage between the parties. 20. Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff respectfully requests that the Court enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT V ALIMONY PENDENTE LITE 21. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 22. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff respectfully requests that the Court Order Defendant to pay him reasonable alimony pendente lite during the pendency of this action. Respectfully Submitted, IATES Dated: S? 7/0 6 l Shane B. PROM : Premium Appliance/Donmar Dist._ PHONE NO. : 717 766 9694 MAY. 16 2006 01:42PM P1 VERIFICATION I, Michelle Joynt, the Plaintiff in this matter, have read the foregoing Complaint. I verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated: , -rYI hl lle ll ll Joynt. , ' Mich „f M -?. .?. ?? _... 0 ?? -- ^ l ?°a ? '"]? / ?"` ^ N n r? T C.` .? T 'T'? ^C' ? r.D ? i. T .. c Kl f ? .. 5?? ? Ji . ? ..i 5...7 ._... _J.{ W KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope(&-comcast. net MICHELLE JOYNT Plaintiff, VS. JEFFREY M.JOYNT Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2907 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PETITION FOR ALIMONY PENDENTE LITE, INTERIM COUNSEL FEES, COSTS AND EXPENSES Plaintiff, Michelle Joynt by her attorney, Shane B. Kope, Esq., hereby petitions this Court for alimony pendente lite, interim counsel fees, costs and expenses and, in support thereof, respectfully represents: 1. The parties to this action separated on April 26, 2006. 2. Plaintiff retained Shane B. Kope, Esq. to represent her in her domestic relations matters in April, 2006. 3. On May 19, 2006, Plaintiff filed a Complaint in Divorce and Custody with a Count requesting Alimony Pendente Lite. The Complaint was served on the Defendant on June 1, 2006. 4. The Defendant, Jeffrey Joynt is employed and, upon information and belief, has an income of $915.00 weekly. 5. At present, the parties are in litigation. 6. To date, Plaintiff has incurred approximately $856.00 in attorney fees representing approximately 5 1/2 hours of time spent by an attorney, a paralegal and disbursements. It is anticipated that by August 31, 2006 a minimum of 10 additional hours of time will be required to review, prepare for and attend the APL hearing in Cumberland County as well as inevitable proceedings in Cumberland County based on Plaintiffs Complaint in Divorce. 7. The Plaintiff makes considerable less money than the Defendant and currently does not have the level of income to maintain a standard of living comparable to the level maintained while married. 8. The Defendant's recent actions towards Plaintiff indicates that he is unwilling to provide her with financial support and to negotiate a property settlement agreement, and protracted litigations is anticipated as a result of Defendant's unwillingness to negotiate the various aspects of this case. WHEREFORE, the Plaintiff respectfully requests this court enter an Order directing Defendant to pay the following: a) Maximum amount of Alimony Pendente Lite allowed by law to sustain the Plaintiff through the duration of this litigation and to pay his/her reasonable expenses; b) Interim counsel fees of $1,700.00 by Defendant to the Plaintiff within twenty days of the Order; and c) Such other relief as the court deems just and proper. Respectfully Submitted, KOPE & ASSOCIATES Date: 0ope Esq. CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, of The Law Offices of Shane B. Kope, hereby certify that on August4, 2006 1 served a copy of the foregoing Petition for Alimony Pendente Lite, Interim Counsel Fees, Costs and Expenses by depositing same in the United States Mail, certified mail first class, postage prepaid in Camp Hill, Pennsylvania, addressed as follows: Jeffrey Joynt 930 Cartref Road Etters, PA 17319 TES, LLC ane B. Kope, sq. 466 d, Suite 201 Camp Hill, PA 17011 (717) 761-7573 I.D. 92207 Attorney for Plaintiff FROM Premium Appliance/Donmar Dist. PHONE NO. a :IVU •i ?•y4•• air 717 766 9694 AUG. 01 2006 04:21PM P1 VERIFICATION I, Michelle Joynt, the Plaintiff in this matter, have read the foregoing Petition for Alimony Pendente Uite, Interim Counsel Fees, Costs and Expenses. I verify that my averments in this Petition are true and correct and based upon my personal .knowledge, I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsifications to authorities. Dated: MicHalle l t. i. TOTPL P.0& C C A4 l7 ar _ W MICHELLE JOYNT, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-2907 CIVIL TERM JEFFREY M. JOYNT, IN DIVORCE Defendant/Respondent PACSES CASE NO: 529108560 ORDER OF COURT AND NOW, this 29th day of August, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on September 1& 2006 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed on August 29, 2006 to: Petitioner Respondent Shane B. Kope, Esq. i Date of Order: August 29, 2006 J. dday onference Officer / I YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND ' REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 n o p ' "., m !Y •f fil N tD i i KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope(ci)_comcast.net MICHELLE JOYNT Plaintiff, vs. JEFFREY M. JOYNT Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2907 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO ENTER APPEARANCE l"O THE PROTHONOTARY: Please enter the appearance of Lesley J. Beam, Esq, of Kope & Associates, LLC of 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011, on behalf of the Plaintiff, Michelle Joynt, in connection with the above-captioned custody action. Respectfully Submitted, BY: Date: 4/0-c Illesley earn, Esquire ID# 9117A 4660 Trindle Road Suite 201 Camp Hill, PA 17011 (717) 761-7573 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope(d-comcast.net Attorney for Plaintiff MICHELLE JOYNT IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-2907 JEFFREY M. JOYNT CIVIL ACTION - LAW Defendant. IN DIVORCE CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire do hereby certify that on this 5t" day of September, 2006, 1 served a true and correct copy of the foregoing Praecipe to Enter Appearance via regular U.S. First Class mail, postage prepaid, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 KOPE & By: TES, LLC ILdsley J Beam, Esq. 1. D. 91 5 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 A ?? f _ ..;j rj- ' ?1 -- =5 ?: MICHELLE JOYNT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-2907 CIVIL TERM JEFFREY M. JOYNT, IN DIVORCE Defendant/Respondent PACSES # 529108560 ORDER OF COURT AND NOW to wit, this 17th day of October 2006, it is hereby Ordered that no monetary amount of Alimony Pendente Lite is awarded pursuant to Pa R.C. P. § 1910.16-5 (b)(2)(3)(5)(8) and Pa R.C. P. § 1910.16-5 (c). The Respondent is to maintain medical insurance coverage for the Petitioner as provided through his employer. BY THE COURT: Edward E. Guid , J. DRO: R.J. Shadday xc: Petitioner Respondent Barbara Sumple-Sullivan, Esq. Leslie J. Beam, Esq. Form OE-001 Service Type: M Worker: 21005 ? ..? Gs i" .?- ???. ? ? -?cs ? ?.: ? ? ? _ ?? ? ? KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 IbearnAkopelaw.com MICHELLE JOYNT Plaintiff, vs. JEFFREY M. JOYNT Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2907 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT AND RETURN OF SERVICE AND NOW comes Kope & Associates, LLC by LESLEY J. BEAM, attorney for Michelle Joynt, Plaintiff, and states that service of the Divorce Complaint in this matter was made by Kope and Associates upon Defendant, Jeffrey M. Joynt, by posting the same in the U.S. Mail, postage prepaid, at Camp Hill, PA by Certified Mail No. 7004 2510 0007 6450 2278, Return Receipt Requested on June 1, 2006, to his mailing address, at 930 Cartref Road, Etters, PA 17319, which mail was received by Defendant on June 1, 2006, all in accordance with PA.R.C.P. 412 and 403. The mailing receipt and the return receipt or true copies thereof of the acceptance of service bearing the signature of the Defendant are attached hereto and made part hereof, together with the cover letter mailed to Defendant. LEST V J. BEAM, Esq. Atto ey for Plaintiff A. Signature X ? Agent -?- ? Addressee B. Regeiv9d 3y (RhOZ Name) Q Date of Delivery D. Is delivery address different from Item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type ? certified man ? Express Mail ? Registered ? Return Receipt for Merchandise Pat l 7 '31 ? Insured Mail ? C.O.D. 4. Restricted Delivery? Extra Fee) es 2: Article Number 7004 2510 0007 6450 2278 Ps Forrrr 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. 1 ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article AddresseE$??to: i ?v Shane R Kope, Esq. ¦ Jacob M Jividen, Esq. ¦ Lesley J. Beam, Esc K O P E ASSOCIATES LAW OFFICES LLC May 22, 2006 VIA REGULAR AND CERTIFIED MAIL Jeffrey M. Joynt 930 Cartref Road Etters, PA 17319 Re: Joynt v. Joynt No. 06-2907 (in divorce) Dear Mr. Joynt, I represent Michelle Joynt in the above captioned matter for divorce. Enclosed and served upon you is the Divorce Complaint filed with the Cumberland County Court of Common Pleas. I am sending these papers to you directly because I have no information that you are represented by an attorney. I am also enclosing an Acceptance of Service for this Complaint. Please sign and return in the enclosed self-addressed stamped envelope. If you do not either return the Acceptance of Service or sign the receipt for the certified letter, this office will have to officially serve this Complaint by Sheriff at your place of employment. If you have any questions, please feel free to contact me. But, please be aware that I cannot give you legal advice because I represent Mrs. Joynt Thank-you for your kind attention to this matter. Sincerely, Kope & Associates 4anLeB. Kope Enclosure Cc: Michelle Joynt Smart Representation 466o Trindle Road ¦ Suite 201 ¦ Camp Hill, PA i7ou P 717.761.7573 ¦ F 717.761.7572 ¦ kopelaw.com Shane R Kope, Esq. ¦ Jacob M Jividen, Esq. ¦ l esley J. Beam, K O P E ASSOCIATES LAW OFFICES LLC May 22, 2006 VIA REGULAR AND CERTIFIED MAIL Jeffrey M. Joynt 930 Cartref Road Etters, PA 17319 Re: Joynt v. Joynt No. 06-2907 (in divorce) Dear Mr. Joynt, I represent Michelle Joynt in the above captioned matter for divorce. Enclosed and served upon you is the Divorce Complaint filed with the Cumberland County Court of Common Pleas. I am sending these papers to you directly because I have no information that you are represented by an attorney. I am also enclosing an Acceptance of Service for this Complaint Please sign and return in the enclosed self-addressed stamped envelope. If you do not either return the Acceptance of Service or sign the receipt for the certified letter, this office will have to officially serve this Complaint by Sheriff at your place of employment If you have any questions, please feel free to contact me. But, please be aware that I cannot give you legal advice because I represent Mrs. Joynt Thank-you for your kind attention to this matter. Sincerely, Kope & Associates ane B. Kope Enclosure Cc: Michelle Joynt Smart Representation 4660 Trindle Road ¦ Suite 201 ¦ Camp Hill, PA 1701, P 717.761.7573 ¦ F 717.761.7572 ¦ kopelaw.com N C5 O Fri co G 0-11 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam ankopelaw.com MICHELLE JOYNT Plaintiff, VS. JEFFREY M. JOYNT Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2907 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT AND RETURN OF SERVICE AND NOW comes Kope & Associates, LLC by LESLEY J. BEAM, attorney for Michelle Joynt, Plaintiff, and states that service of the Divorce Complaint in this matter was made by Kope and Associates upon Defendant, Jeffrey M. Joynt, by posting the same in the U.S. Mail, postage prepaid, at Camp Hill, PA by Certified Mail No. 7004 2510 0007 6450 2278, Return Receipt Requested on June 1, 2006, to his mailing address, at 930 Cartref Road, Etters, PA 17319, which mail was received by Defendant on June 1, 2006, all in accordance with PA.R.C.P. 412 and 403. The mailing receipt and the return receipt or true copies thereof of the acceptance of service bearing the signature of the Defendant are attached hereto and made part hereof, together with the cover letter mailed to Defendant. UESI,Ct,)? J. BEAM, Esq. Atto ev for Plaintiff • Comp it, . Item 4 if ems 1.2, l f that YoUr name lDelay?, is a jcOmPlete • f Attach we can address o led ,4 . • or on this cant' e m the O o the revel ?"?" • t the %nuifspace back of thyou' X ' Article q ce PermitsMailpiel B d?elo: Agent D if d C Dt O A M ?- from 0 as' address beloi r? r? r, Yes /Vo ,1 , ? 9 v n'k? Type de Number ??/ ? IR Mp Mail `-_ a. red )Well R elm nsu lei for C 1 PS Fob. .?/ a Remitted D? D.D. Me?andise ?, s . 3817. Febrtra?, 2004 7?? 4 25 y left Fee) °o?'?Rehrm 0 0??7 6450 .? lecall 22 78 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this Aay of N-tffiL d- , 2007, by and between JEFFREY M. JOYNT, hereinafter referred to as "HUSBAND", and MICHELLE JOYNT, hereinafter referred to as "WIFE". WITNESSETH, That: WHEREAS, the parties hereto are husband and wife, having been lawfully joined in marriage on February 14, 2004, in Phoenix, Arizona; WHEREAS, it is the intention of the parties to settle fully and finally their respective financial and property rights and obligations as between each other arising out of the marriage relationship or otherwise, including without limitation (1) the settling of all matters between them relating to the ownership of real and personal property, (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of HUSBAND and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles and interests, claims and possible claims in or against the estate of the other. NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed an essential part hereof in consideration of the foregoing recitals, the mutual promises, covenants and undertakings herein set forth, and for good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as follows: 8/13/2007 SECTION I GENERAL PROVISIONS 1. ADVICE OF COUNSEL HUSBAND and WIFE declare that they have each had a full and fair opportunity to obtain independent legal advice of counsel of their selection. HUSBAND has been independently represented by Barbara Sumple-Sullivan, Esquire. WIFE has been independently represented by Lesley J. Beam, Esquire. Each party further declares that they are executing this Agreement freely and voluntarily, having obtained such knowledge and disclosure of their legal rights and obligations. Each party acknowledges that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. Both parties further acknowledge and agree that each has fully disclosed their respective financial situations to the other, including their assets, liabilities and income. Each of the parties acknowledge and agree that, after having received such information and with such knowledge, this Agreement is fair, reasonable and equitable and that it is being entered into freely, voluntarily and in good faith and that the execution of this Agreement is not the result of any duress, undue influence, coercion, collusion and/or improper or illegal Agreement. 2. PERSONAL RIGHTS HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as if she or he were unmarried, except as may be necessary to carry out the provisions 8/13/2007 2 i of this Agreement. Each may reside at such place or places as she or he may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. This provision shall not be taken, however, to be an admission on the part of either HUSBAND or WIFE of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. HUSBAND and WIFE shall not molest, harass, or malign the other or the respective families of each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with the peaceful existence, separate from each other. 3. FINANCIAL DISCLOSURE The parties have fully disclosed to each other the extent of each other's income, assets, liabilities, holdings and estate. Each party warrants that the information provided has fully and accurately described the extent of his or her holdings. Each of the parties acknowledge that he or she is aware of his or her right to seek discovery including, but not limited to, written interrogatories, motions for document production, depositions, and other means of discovery available through the Pennsylvania Rules of Civil Procedure. The parties acknowledge that they have had the right to have property fully appraised. Each party is fully satisfied that no additional information is necessary for the execution of this Agreement. 4. MUTUAL CONSENT DIVORCE The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of Section 3341(c) of the Divorce Code of 1980, as amended and will execute the documents 8/13/2007 3 necessary to effectuate a divorce under those provisions concurrently with the execution of this Agreement. The parties agree that the Affidavits of Consent and the Waivers of Notice shall be signed simultaneously with the execution of this Agreement. 5. SUBSEQUENT DIVORCE A decree in divorce, entered by the court of Cumberland County, shall not suspend, supersede or affect the terms of this Agreement. This Agreement, and the terms and conditions contained herein, as well as the enforcement of said terms and conditions, shall not be contingent upon the granting of a Divorce Decree to either party by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as HUSBAND and WIFE, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shall not be a modification or waiver of any of the terms hereof unless the parties, in a writing signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. Both parties hereto agree that this Agreement may be incorporated by reference but shall not be deemed merged into any judgment or decree for divorce obtained by either party. 6. OTHER DOCUMENTATION HUSBAND and WIFE covenant and agree that upon request of the other party, they will 8/13/2007 4 forthwith execute and deliver to the other party, any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 7. MUTUAL RELEASES Except as otherwise expressly provided by this Agreement, A. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either may have or at any time hereafter have for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights, agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the other not expressly set forth herein. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties or otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities or the other or by way of dower, curtesy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other country. It is expressly understood, however, that neither the provisions of this release nor the subsequent entry of a divorce decree are intended to defeat the right of either party to receive any insurance proceeds at the death of the other of which she or he is the named beneficiary (whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest or residuary portion of the other's estate under his or her will, or to act as personal representative or executor if so named by the will of the other, whether such will was executed prior or subsequent to this Agreement. C. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an 8/13/2007 5 absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. 8. SUCCESSOR'S RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 9. SEVERABILITY If any provision in this Agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired or invalidated in any way. 10. ENTIRE AGREEMENT HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all of the representations, promises and Agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto. 11. BINDING EFFECT OF AGREEMENT/WAIVER This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. 8/13/2007 6 The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, nor shall such failure be construed as a waiver of any other term, condition, clause or provision of this Agreement. 12. BREACH If either party breaches any provision 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 shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 13. CONTROLLING LAW This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. SF,CTION II EQUITABLE DISTRIBUTION During the marriage, the parties have accumulated various assets and liabilities, the disposition of which is intended as follows: 8/13/2007 7 1. ASSETS A. PERSONAL and HOUSEHOLD PROPERTY HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non- marital and marital personal and household property, including but without limitation, jewelry, clothes, furniture, and other assets. HUSBAND agrees that all assets in the possession of WIFE shall be the sole and separate property of WIFE. With the exception of those items listed on Exhibit "A," WIFE agrees that all assets in the possession of HUSBAND shall be the sole and separate property of HUSBAND. WIFE shall retrieve those items listed on Exhibit "A" no later than September 1, 2007 or she forfeits her right of receipt and HUSBAND is free to dispose of said property as he sees fit. Each of the parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to any of the above said items which are the sole and separate property of the other. This document shall constitute a bill of sale for said sole property transferred to either party pursuant to this Agreement. B. REAL ESTATE HUSBAND owned real estate located at 930 Cartref Road, Etters, York County, Pennsylvania prior to marriage. This real estate has increased in value during the parties' marriage. This real estate shall continue to be the sole property of HUSBAND. In consideration of the terms of this Agreement, WIFE does hereby waive, relinquish and quit claim any and all rights and claims to said real property, including any claim to share in the increase in value of the 8/13/2007 8 real estate. Simultaneously with the execution of this Agreement, WIFE shall return to HUSBAND all keys to the house and the garage door opener. C. MOTOR VEHICLES The parties acknowledge that neither party purchased or acquired any vehicle during the term of the marriage. D. DISPOSITION OF FINANCIAL ASSETS AND ACCOUNTS a. JOYNT INVESTMENT CLUB: At the time of marriage, HUSBAND had a one-seventh (1/7 h) interest in an investment club with certain of his family members, designated as the "Joynt Investment Club." The value of this ownership in the Club increased during the term of the marriage. Said interest shall remain the sole and separate property of HUSBAND. WIFE hereby waives, relinquishes and quit claims any and all rights and claims in said Club, including any claim to the increase in the value of the interest. b. Sovereign Account: The parties had a marital savings account with Sovereign Bank Account No. 1661234496 with a date of separation value of approximately $49,000.00. WIFE has made two withdrawals at the time of separation. The first was $25,000 on April 26, 2006 and a second withdrawal of $13,000.00 as of April 28, 2006. WIFE shall retain the proceeds of those withdrawals and any and all interest earned thereon since the date of separation. HUSBAND hereby waives any claim thereto. The remainder of the account shall be the sole and separate property of HUSBAND and WIFE waives any claim thereto. This account shall be the sole property of HUSBAND and WIFE agrees to execute any and all documents necessary to make said account HUSBAND's sole property. C. Pension and Retirement: No retirement benefits were acquired during the marriage by either party. However, certain of the parties' pre-marital IRAs increased in value. These accounts are as follows: HUSBAND: i. Charles Schwab IRA Account No. 4865-5898 which became Smith Barney Account No. 724-64001-18-181. This account shall remain 8/13/2007 9 the sole property of HUSBAND and WIFE waives any claims thereto, including any increase in value. ii. For the sake of completeness, it is also noted that HUSBAND has a Smith Barney IRA Account No. 724-60098-10 181. This decreased in value during the marriage. The account shall be HUSBAND's sole property and WIFE waives any claims thereto. WIFE: i. WIFE had a pre-marital IRA during the marriage. HUSBAND waives any and all claims to said IRA and any increase in value thereof. d. Receivables due the Parties: During the marriage, approximately $5,000.00 was loaned to WIFE's sons. HUSBAND hereby assigns the right to collect said sums to WIFE and relinquishes any right to collect said sums from WIFE's sons. E. BUSINESS INTEREST During the marriage, WIFE had ownership of a business known as Homemakers Express. This business has a "cash" receipts component. HUSBAND waives any and all claims to WIFE's business. WIFE agrees to indemnify and hold HUSBAND harmless from any and all claims which might arise against him as a result of WIFE's failure to declare income arising from said business during the marriage. F. CASH PAYMENT TO WIFE In consideration of the terms of this settlement, HUSBAND agrees to pay to WIFE the sum of Four Thousand Five Hundred Dollars ($4,500.00) in cash. The sum of Two Thousand Dollars ($2,000.00) shall be paid upon execution of this Agreement and Two Thousand Five Hundred Dollars ($2,500.00) shall be made to WIFE upon entry of the Decree in Divorce. 8/13/2007 10 Further, HUSBAND agrees to effectuate a rollover to WIFE of the sum of Nine Thousand Dollars ($9,000.00) from his Smith Barney IRA. This transfer shall be made pursuant to a directive or a Domestic Relations Order as Smith Barney shall require. This rollover shall only occur in such a fashion to not create any tax liability to HUSBAND. WIFE agrees to indemnify and hold HUSBAND harmless against any tax liability arising out of this transfer. W1FE shall be responsible in obtaining whatever form or order is required to effectuate the transfer. G. INSURANCE Each party shall retain as his or her sole property any insurance policy owned by them. 2. DEBTS Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable except as otherwise provided herein, and that except only for the rights arising out of this Agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party will be liable. Each party agrees to indemnify and hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. Further, the parties confirm that all joint credit cards have been terminated. Each party shall be individually responsible for any debt which exists in his or her name alone. 8/13/2007 11 SECTION III SPOUSAL SUPPORT, APL and ALIMONY ALIMONY, ALIMONY PENDENTE LITE, SUPPORT, MAINTENANCE AND COUNSEL FEES Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance, alimony, alimony pendente lite or counsel fees. HUSBAND and WIFE further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for spousal support, alimony, alimony pendente lite, maintenance or counsel fees. SECTION IV HEALTH INSURANCE As of the divorce, WIFE acknowledges that HUSBAND shall not have the ability to continue WIFE'S health insurance coverage. WIFE shall secure her own coverage. This space intentionally left blank. 8/13/2007 12 a SECTION V 1. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS The parties acknowledge that this Agreement shall become effective when actually signed by both parties. 8/13/2007 13 MI HELLE JOYN COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF Cu M ??? L? ® ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared JEFFREY M. JOYNT, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of his knowledge, information and belief and subscribed to before me this NO'?LR PUBLIC My mmission expires: ok,q COMMONWEALTH OF PENNSYLVANIA COUNTY OF &IL4,kod day of A dfl&;1 O4 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumberland County My Co f$Fts &o Expires Aug. 20, 2009 ) SS. Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared MICHELLE JOYNT, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of her knowledge, information and belief. and subscribed to before me this 13 day of /??r??. NOT UBLIC My c fission expires: ,5f A/02007 (SEAL) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Aug. 20, 2009 8/13/2007 14 Boxes of items located underneath the stairs that belong to WIFE's two sons; Kitchen console; Oak dining room table and four (4) chairs; Matching oak hutch; Queen size bed frame and mattress; Bar table with two matching chairs; Kitchen items (glasses and pates); Antique sewing machine with chair; Master bedroom set (king size sleigh bed, rails, head and foot boards); Two marble topped night stands; Marble topped dresser, mirror and chest; Living room furniture; Couch; Love seat; Coffee table and end table; and Fake plant in living room Exhibit "A" 8/13/2007 ? v d Cam" "_? .-t ?, C:? T -rt c'"• `?? ?. ;`? ?_i ?' __ .... a? ??? 1 r'_.- ?.- '"y/ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 MICHELLE JOYNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLNAND COUNTY, PENNSYLVANIA V. JEFFREY M. JOYNT, Defendant : NO. 06 - 2907 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 19, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the 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. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. DATE: -//// 3 , 2007 _ - C'J F T T C: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 MICHELLE JOYNT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLNAND COUNTY, PENNSYLVANIA V. JEFFREY M. JOYNT, Defendant NO. 06 - 2907 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33301(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 statement herein are made subject to the penalties of 18 Pa.C.S. 34904 relating to unsworn falsification to authorities. DATE: , 2007 C c,._a?- ?;. ?:::' !'. w r- , rz? ? _ ? -,,;. " ? __ , ..: J R .,.' i.`f.1 _ .. -? . r=j r " '? ,? a Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 MICHELLE JOYNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLNAND COUNTY, PENNSYLVANIA V. JEFFREY M. JOYNT, Defendant NO. 06 - 2907 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 19, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the 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. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: I I I i J le'?'-T -M I - MIC ELLE JOYNT ft COMMONWEALTH OF PENNSYLVANIA ) ) SS. } COUNTY OF u4alah4 Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared MICHELLE JOYNT, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing AFFIDAVIT OF CONSENT are true and correct to the best of her knowledge, information and,, belief. Affirmed and subscribed to before me this day of 6 L'P-A 2007. NOTAR PUBLIC My EEo?ission Expires: (SEAL) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Soro, Cumberland County My Commission Expires Aug. 20, 2009 rv --f C.il i` -# =IT) 7 \ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 MICHELLE JOYNT, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLNAND COUNTY, PENNSYLVANIA V. JEFFREY M. JOYNT, Defendant : NO. 06 - 2907 : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33301(c) OF THE DIVORCE CODE 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 statement herein are made subject to the penalties of 18 Pa.C.S. 34904 relating to unsworn falsification to authorities. DATE: MIC ELLE JOYNT Ji I COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF 6 tjrnb2r1 a 0 } Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared MICHELLE JOYNT, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33301(c) OF THE DIVORCE CODE are true and correct to the best of her knowledge, information and belief. and subscribed to before me this day of ; 2007. NOTAIZ PUBLIC q My o ission Expires: Owe S tADlo co (SEAL) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Aug. 20, 2009 ?.-•.1 f1S c- <._? -Ti a& Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Counsel for Petitioner MICHELLE JOYNT, Plaintiff V. JEFFREY M. JOYNT, Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLNAND COUNTY, PENNSYLVANIA : NO. 06 - 2907 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail Restricted Delivery on June 1, 2006. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: November 13, 2007; by Defendant: November 13, 2007. 4. Related claims pending: All matters have been resolved pursuant to the Marital Settlement Agreement reached by the parties dated November 13, 2007 and incorporated, but not merged, into the Decree. See paragraph 5, page 4 of the Agreement. 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with Prothonotary: December 5, 2007. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with Prothonotary: December 5, 2007. Dated: December 4, 2007 I Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Defendant Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Counsel for Petitioner MICHELLE JOYNT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLNAND COUNTY, PENNSYLVANIA V. : NO. 06 - 2907 JEFFREY M. JOYNT, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Lesley J. Beam, Esquire Kope & Associates, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 Ms. Michelle Joynt 23 Bare Road Mechanicsburg, PA 17055 DATED: December 4, 2007 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Defendant r CJ rc? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MICHELLE JOYNT, - '' Plaintiff VERSUS JEFFREY M. JOYNT, Defendant DECREE IN DIVORCE AND NOW, Michelle Joynt DECREED THAT Jeffrey M. Joynt AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. x--11: 17?.,?t . 2007 , IT IS ORDERED AND , PLAINTIFF, ,DEFENDANT, 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; All matters have been resolved pursuant to the Marital Settlement Agreement reached by the parties dated November 13, 2007 and incorporated, but not merged, into the Decree. 06 - 2907 No. PROTHONOTARY r;-4.10X In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION MICHELLE M. JOYNT ) Docket Number 06-2907 CIVIL Plaintiff ) vs. ) PACSES Case Number 529108560 JEFFREY M. JOYNT ) Defendant ) Other State ID Number Order AND NOW to wit, this DECEMBER 15, 2010 it is hereby Ordered that: THE ORDER OF OCTOBER 17, 2006 TERMINATED, PURSUANT TO THE PARTIES' DIVORCE DECREE OF DECEMBER 11, 2007. O rV1 --{ f '*1 Z v tV C) M y BY THE COURT: C JUDGE Form OE-520 Service Type M Worker ID 21005