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HomeMy WebLinkAbout06-3272DAVID E. SORBER, Plaintiff V. CHERYL L. SORBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE/CUSTODY 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 Prothonotary's Office, Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR 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 Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 DAVID E. SORBER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW :NO. CHERYL L. SORBER, Defendant IN DIVORCE/CUSTODY COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, DAVID E. SORBER, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, CHERYL L. SORBER, upon the grounds hereinafter set forth: Plaintiff is DAVID E. SORBER, an adult individual, residing at 1007 Jenkins Grove Road, Enola, Cumberland County, Pennsylvania. 2. Defendant is CHERYL L. SORBER, an adult individual, residing at 141 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 18, 1998 in Steelton, Dauphin County, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. COUNT II CUSTODY 11. Paragraphs 1 and 2 of the within Complaint in Divorce are incorporated herein. 12. Plaintiff seeks custody of the following child: Name Residence Age Jared T. Sorber 141 Hummel Drive 5 Years Lemoyne, Pennsylvania The child was born to Plaintiff and Defendant. The child is presently in the custody of Defendant, CHERYL L. SORBER, who resides at 141 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. The child has resided with Plaintiff and Defendant since birth at 146 North Second Street, Steelton, Dauphin County, Pennsylvania and 141 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. The parties separated on or about May 20, 2006. The mother of the child is CHERYL L. SORBER currently residing at 141 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. She is married. The father of the child is DAVID E. SORBER currently residing at P.O. Box 3208, Harrisburg, Dauphin County, Pennsylvania. He is married. 13. The relationship of Plaintiff to the child is that of the Father. The Plaintiff currently resides with his mother, Rebecca Ensminger. 14. The relationship of Defendant to the child is that of the Mother. The Defendant currently resides with the child and her other two children George Greenwalt and Danielle Greenwalt. 15. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 16. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or in any other jurisdiction. 17. Plaintiff does not know of a person not a parry to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 18. The best interests and permanent welfare of the child will be served by granting the relief requested because Plaintiff has provided and is ready, willing and able to continue providing a stable home environment for the child. 19. Each party whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff, DAVID E. SORBER, respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code and to grant him legal and primary physical custody of the subject minor child. Respectfully submitted, DATED: ?? S• O C Robe B. Lieberman, Esquire 5N. Third Street, 12?h Floor -- Harrisburg, PA 17101 (717) 236-1485 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce with Count for Custody are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. 4G?+ro! ???Q,etL DATED: zoo(. David E. Sorber, Plaintiff N? b yv ? C C? ?I '{4 -? C ? -n DAVID E. SORBER PLAINTIFF V. CHERYL L. SORBER DEFENDANT AND NOW, IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 06-3272 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT Tuesday, June 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Thursday, August 03, 2006 _ at 12:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Melissa P. Greets Esg. 10 Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Awwc for -;z 'Oop?- AOJV ,, io 9Z '17 70 -h1- ? WO hl DAVID E. SORBER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 06-3272 CIVIL TERM CHERYL L. SORBER, Defendant : IN DIVORCE/CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DAUPHIN SS. Personally appeared before me, a Notary Public, in and for said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and says: That on June 9, 2006, a Complaint in Divorce with a Count for Custody was filed on behalf of Plaintiff and against Defendant in the above case. That on June 12, 2006, I forward by certified mail, return receipt requested, a certified copy of the Complaint in Divorce with a Count for Custody to Defendant, CHERYL L. SORBER, at 141 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. That the aforesaid copy of the Complaint in Divorce with a Count for Custody sent to Defendant, CHERYL L. SORBER, was delivered on June 14, 2006, as evidenced by the return receipt card signed by Defendant and attached hereto. 4. That to the best of my information and belief, the signature on the return receipt card is, in fact, the signature of CHERYL L. SWORN AND SUBSCRIBED before me this day of Zv1J E. '2006. 0 -1 Notary P lic My Commission Expires: COIMAONNIEALTH OF PENNSMAMA NOTARIAL SEAL CHERYL L. FEROUSOIV Nobly PubAe My of HwdWxxy, Dauphin Counpr * Canar"on Expk 0 Apra 6, 2006 A Q' A r ru 7 O .q Postage $ Poebmrk Here h p Cedaed Fee O p Retum Receipt Fee (Endmeemem Required) O r Realrleted De l- Fee m (Etslbraeme Required) r 9 O Teal Pesaex A Feow -a G G M1 'e'er ROBERT B. LIEBERMAN, Esquire Attorney for Plaintiff J r A F N S O A Ln O C3 O 0 O A O M1 a a III w If c? ??.+ O C.. -?1 (_` _ ? -? -T.. -Il ?.. ? ? ? N -) IJ .. ?'?'. ?l ? ^? ' ?? . y W ^? DA E. SORBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 06-3272 CIVIL ACTION LAW CHER L. SORBER, Defendant : IN CUSTODY ACCEPTANCE OF SERVICE accept case Dated ALLEN SMITH, ESQUIRE, on behalf of my client, CHERYL L. SORBER, hereby of a copy of the Order of Court scheduling a conciliation conference in the above Thursday, August 3, 2006. tM.?. Z ? Zoo ?' _ Allen Smith, Esquire P.O. Box 7592 Steelton, PA 17113 Attorney for Defendant r-; ` t-> -? - .? _ .? _?, ?_, ,,,_ ;?.? - , ? o? ,?'; - ?.?. ,, .?; ,,,. _. -; fS ? ?A? (".:, I DAVID E. SORBER, Plaintiff V. CHERYL L. SORBER, Defendant X%Zo%, M fl V 1'dL AU13 1 1 Z006 BY: IN THE COURT OF CO MUN rLMAO OF =00= CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3272 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 14day of August, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, David E. Sorber and Cheryl L. Sorber, shall have shared legal custody of the minor child, Jared T. Sorber, born October 31, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody. Mother shall have primary physical custody subject to Father's rights of partial custody which shall be arranged as follows: A. Commencing August 5, 2006, each Saturday from 1:00 p.m. to 8:00 p.m. Father's period of custody may occur on an alternate day, such as Sunday, if pre-arranged by the parties' mutual agreement. B. Effective August 10`h, 2006, each Thursday from 4:15 p.m. to 8:00 p.m. C. At such other times as the parties may agree. 4. Holidays. The parties will share holidays by their mutual agreement. The holiday schedule shall supersede the regular schedule. In the absence of their mutual agreement, the schedule in the attached form shall be the method by which the parties resolve their dispute. N VINVAIAqWd Z 1 : I I wV 91 snv 9001 ,t6'ViOi?KiH1U:?'d 3M1 ?0 ??(??i?Q3ll? NO. 06-3272 CIVIL TERM 5. The parties shall keep each other promptly informed of any changes to their address or telephone numbers. BY THE COURT: 1 P, . Dist: Robert Lieberman, Esquire, 500 N. P St., 12" Fl., Harrisburg, PA 17101 Allen D. Smith, Esquire, 51 S. Front St., P.O. Box 7592, Steelton, PA 1711 g ??O (fir(/ '/?"' NO 06-3272 CIVIL TERM HOLIDAYS AND TIMES ODD EVEN SPECIAL DAYS YEARS YEARS Easter Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Memorial Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Independence Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Labor Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Thanksgiving 1't Half From 6pm the evening before Mother Father Thanksgiving Day to 3pm on Thanksgiving Day Thanksgiving 2nd Half From 3pm on Thanksgiving Day to Father Mother 6pm the day after Thanksgiving Day Christmas Vt Half From 9am on 12/24 to 3pm on 12/25 Father Mother Christmas 2nd Half From 3pm on 12/25 to 3pm on 12/26 Mother Father Mother's Day From 6pm the evening before the Mother Mother holiday to 6pm the day of the holiday Father's Day From 6pm the evening before the Father Father holiday to 6pm the day of the holiday :280968 AUG ] 1 2006 DAVID E. SORBER, Plaintiff IN THE COURT OF CO CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3272 CIVIL TERM V. CHERYL L. SORBER, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Jared T. Sorber October 31, 2001 Mother 2. Father filed a Complaint in Divorce with a count for custody on June gth, 2006. A Custody Conciliation Conference was held on August 3m, 2006. Attending the Conference were: the Father, David E. Sorber, and his counsel, Robert B. Lieberman, Esquire; the Mother, Cheryl L. Sorber, and her counsel, Allen D. Smith, Esquire. s attache J 3. The parties reached an agreement in the forri 6 Da el a Peel Greevy, Esquire Custody Conciliator ead:280963 DAVID E. SORBER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 06-3272 CIVIL TERM CHERYL L. SORBER, Defendant IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 9, 2006. 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 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 unworn falsification to authorities. Dated: (? J • 0 "o'"ti' E , ? DAVID E. SORBER, Plaintiff tt? C9 c? DAVID E. SORBER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 06-3272 CIVIL TERM CHERYL L. SORBER, Defendant IN DIVORCE/CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 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 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. Dated:?- 3- 0' 1 kL? ?, fja"'? DAVID E. SORBER, Plaintiff p DAVID E. SORBER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION LAW NO. 06-3272 CIVIL TERM CHERYL L. SORBER, Defendant IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 9, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.S. Section 4904 relating to unsworn falsification to authorities. Date: Cheryl L. rber, Defendant C :0 r ` Cr - y t ? ri _ •-;4 ?C'-tr ?. ?' ?lr ` T DAVID E. SORBER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION LAW NO. 06-3272 CIVIL TERM CHERYL L. SORBER, Defendant IN DIVORCE/CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS Section 4904 relating to unsworn falsification to authorities. Date: Cheryl L. orber, Defendant ? ? ° _ ? ? ?? ?- ?3? ?... .. J?... "-{'f i? __ .! AGREEMENT made this 5`h day of September, 2007 by and between DAVID E. SORBER ("Husband"), and CHERYL, L. SORBER, ("Wife"), at Harrisburg, Pennsylvania. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married April 18, 1998, in Borough of Steelton, Dauphin County, Pennsylvania. WHEREAS, diverse unhappy differences, have arisen between the parties as a result of which they intend to live separate and apart. WHEREAS, the parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. NOW THEREFORE, in consideration of the promises and of the mutual promises, covenants and undertakings hereinafter set forth Husband and Wife each intending to be legally bound hereby covenant and agree as follows: 1. Nothing in this Agreement shall be construed as a relinquishment by either party of the right to prosecute or defend any suit for divorce in any court of proper jurisdiction. Other than upon a showing of substantially changed circumstances, neither party to any such action shall ask alimony or support contrary to the provisions of this Agreement. 2. Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 3. Husband and wife mutually waive any right to their respective estates, either by will or intestate succession, support, maintenance, alimony, alimony pendente lite, equitable distribution and counsel fees. 4. Husband and Wife have attempted to divide their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Divorce Code of 1990, and taking into account those r considerations, voluntarily enter into this Property Settlement and Separation Agreement. 5. This agreement shall survive any action in divorce and decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought to enforce the terms of this Agreement. The considerations of this contract and Agreement are the mutual benefits to be obtained by the parties and the adequacy of the consideration is stipulated, and the parties intend to be legally bound hereby. 6. Husband and Wife agree that the execution of this Agreement is not predicated upon any agreement relating to a divorce proceeding. It is further understood that nothing contained in this Agreement shall prevent either party from commencing any action in divorce. 7. Husband and Wife agree to sell the marital residence at 141 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. As a result of this sale, the mortgage on said property shall be paid in full and Husband shall receive $1,250.00 from the proceeds, which shall be paid to Robert B. Lieberman, Esq., attorney for husband. The balance of the proceeds shall go to wife. 8. Husband and Wife have lived separate and apart for some time. During that time they have satisfactorily divided their personal property and that this Agreement shall operate as a bill of sale to this effect. 9. Husband and Wife represent that with the exception of the mortgage on the marital property there are no outstanding loan obligations of the parties. 10. Husband and Wife represent that each party has made full disclosure of all assets, both real and personal and that all were the subject of this Agreement. These disclosures are part of the considerations made by each party for entering into this agreement. 11. Husband and Wife acknowledge and declare that he or she, respectively: (a) Is fully and completely informed as to the facts relating to the subject matter of this Agreement and as to the rights and liabilities of both parties; (b) Enters into this Agreement voluntarily; (c) Has given careful thought to and carefully read each provision of this Agreement; (d) Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect; and (e) Husband has been advised that Allen D. Smith, Esq. represents Wife and that she has advised him to seek independent counsel. Husband's counsel is Robert B. Lieberman, Esq. 12. No amendment or modification to the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 13. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. /VIA, Witness v Witness ( " / 5M?-- Cheryl V Sorber 015?'d e David E. Sorber 1 ° t 4 ?J DAVID E. SORBER, Plaintiff V. CHERYL L. SORBER, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION NO. 06-3272 CIVIL TERM 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) 3 3 @1 (d) (1) 89 the piver-Ge cede, (Strike out inapplicable section) 2. Date and manner of Complaint: Certified mail delivered on June 14, 2006, as evidenced by an, Affidavit of Service filed in the Prothonotary's Office of Cumberland County on June 21, 2006. 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 September 3, 2007, by defendant September 18, 2007. 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 plaintiff's Waiver of Notice in 3301 (c) was filed with the Prothonotary: September 11, 2007 Date defendant's Waver of Notice in 3301 (c) was filed with the Prothonotary: October 12, 2007 Robert B. Lieberman, Esquire Attorney for Plaintiff ? j?l 'TS ?T CA) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY elk Aft STATE OF PENNA. DAVID E. SORBER,' Plaintiff VERSUS CHERYL L. SORBER, Defendant No. 06-3272 CIVIL TERM DECREE IN DIVORCE AND NOW, Cd,Llr 2,T dal, IT IS ORDERED AND DAVID E. SORBER DECREED THAT AND CHERYL L. SORBER ARE DIVORCED FROM THE BONDS OF MATRIMONY. , 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; The terms of the Agreement dated September 5, 2007, are incorporated, but not merged, into this Decree in Divorce. BY THE CO PROTHONOTARY &? r!?L? t?o, 60.