HomeMy WebLinkAbout06-3312
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHELLY L. RODRIGUEZ, )
Plaintiff, )
vs. )
)
FELIPE RODRIGUEZ, )
Defendant. )
No. tItJ-33/L ~
CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail to do
so, the case 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 requestep 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 divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at:
Office of the Prothonotary
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
, '
In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHELLY L. RODRIGUEZ, )
Plaintiff, )
vs. )
)
FELIPE RODRIGUEZ, )
Defendant. )
No. 0& - 33/2-
CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in 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 that 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. 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.
Michael S, Travis
Attorney at Law
ID No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717) 731-9509
In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHELLY L. RODRIGUEZ, )
Plaintiff, )
vs. )
)
FELIPE RODRIGUEZ, )
Defendant. )
No. tJ~ - 3 3/~
CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 330I(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by her attorney, Michael S. Travis, respectfully represents:
1. Plaintiff is Shelly 1. Rodriguez, who resides at 4706 Courtland Street, Camp Hill,
Cumberland County, Pennsylvania, 170 II, since August, 2000.
2. Defendant is Felipe Rodriguez, who resides at 533 Maple Street, Lebanon,
Lebanon County, Pennsylvania, 17046, since June, 2004.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
at least six months immediately previous to the filing ofthis Complaint.
4. The Plaintiff and Defendant were married on April 23, 1999, in Lebanon County,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, Plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years,
8. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the court require the parties to participate in counseling.
. .
9. Neither party is in the Military Service in the United States.
to. Plaintiff requests the court to enter a decree of divorce.
VERlFICA nON
I verify that the statements made in this Complaint 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: ~/J ;/f)()(P
icliael S. Travis
Attorney for Plaintiff
!.D. # 77399
3904 Trindle Road
Camp Hill, P A 170 II
(717) 731-9502
Fax 731-9511
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHELLY L. RODRIGUEZ, )
Plaintiff, )
vs. )
)
FELIPE RODRIGUEZ, )
Defendant. )
No. 06-3312
CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint.
~ &tJI2/6t1L-z..
Felipe Rodriguez
address:
Date: June 29, 2006
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
FELIPE RODRIGUEZ,
Defendant.
)
)
)
)
)
)
No. 06-3312
SHELLY L. RODRIGUEZ,
Plaintiff,
vs.
CIVIL TERM
IN DIVORCE
MARFUAGESETTLEMENTAGREEMENT
Counsel of record:
Michael S. Travis, Esquire for Plaintiff
1
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this 51'!! day of .)~ ' 2006, by and between
Felipe Rodriguez, (hereinafter referred to as "Husband,") an Shelly L. Rodriguez, (hereinafter
referred to as "Wife").
WITNESSETH:
WHEREAS, the Husband and Wife were lawfully married April 23, 1999; and
WHEREAS, there were no children born of this marriage; the parties do have one
biological child Talia Tarantino, who was adopted by Plaintiff's first husband prior to this
marriage. She is emancipated.
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they intend to live apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and
obligations; and
NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and
agree as follows;
1. DEFINITIONS
(a) Date of Execution of this Agreement. The phrase "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the parties if they
each have executed the Agreement on the same date. Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
(b) Distribution Date. The phrase "distribution date" shall be defined as fourteen
days following the entry of a final decree in divorce and the filing of Waivers of Appeals by each
party. If the fourteenth day falls on a weekend or holiday, the distribution date shall be the next
business date.
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2. ADVICE OF COUNSEL
The parties have had an opportunity to review the provisions of this Agreement
with their respective counsel. Husband is represented by , Esquire. Wife is
represented by Michael S. Travis, Esquire. Husband and Wife acknowledge that this Agreement
is not the result of any duress or undue influence and that it is not the result of any collusion or
improper or illegal agreement or agreements. The parties further acknowledge that they have
each made to the other a full accounting of their respective assets, estate, liabilities, and sources
of income and that they waive any specific enumeration thereoffor the purpose of this
Agreement.
Each party agrees that he or she shall not at any future time raise as a defense or
otherwise the lack of such disclosure in any legal proceeding involving this Agreement with the
exception of disclosure that may have been fraudulently withheld.
3. SEPARATION
It shall be lawful for each party at all times hereafter to live separate and apart
from the other party at such place or places as he or she may from time to time choose or deem
fit. The foregoing provisions shall not be taken as an admission on the part of either party as to
the lawfulness or unlawfulness of the causes leading to their living apart.
4. INTERFERENCE
Each party shall be free from interference, authority, and contact by the other as
fully as ifhe or she were single and unmarried except as may be necessary to carry out the
provisions of the agreement. Neither party shall molest the other or attempt to endeavor to
molest the other, nor compel the other to cohabit with the other, or in any way harass or malign
the other, follow, stalk, nor in any way interfere with the peaceful existence, separate and apart
from the other.
5. DIVISION OF PERSONAL PROPERTY
The parties hereto have divided between themselves, to their mutual satisfaction,
all items of tangible marital property. Neither party shall make any claim to any other such items
3
of marital property, or to the separate personal property of either party, which are now in the
possession and/or under the control of the other.
Financial Accounts. The parties have equally divided all joint checking, savings
and other non-retirement accounts to their mutual satisfaction. The parties agree to retain their
separate financial accounts.
The parties agree to cooperate in transferring any title or document to accomplish
the above distribution. Neither party will make further claim to any joint financial account
following the distribution date of this Agreement.
6. SPOUSAL SUPPORT/ALIMONY PENDENTE LITE
Neither party shall be entitled to spousal support or APL.
7. ALIMONY
Wife and Husband represent and acknowledge that they each have sufficient property for
her or his reasonable needs and are able to support herself or himself through appropriate
employment and/or assets according to the standard of living which they are accustomed to and
waive the right to receive alimony.
8. AUTOMOBILES
The parties were the owners of two automobiles at separation, a Chevrolet
Corsica, which since separation has been donated to charity, which was driven by Wife. The
Chevrolet is deemed to be property of Wife. Wife has since acquired a 2000 Chevrolet Impala
which is to be the sole and exclusive property of Wife. The parties agree to indemnifY and hold
the other party harmless for any encumbrance on the vehicle(s).
Should any action be required to transfer title or other document of ownership,
the parties will take steps to transfer and reflect ownership as soon as possible after the
distribution date.
Both parties agree to assume all responsibility and hold each other harmless for
any and all liability, including insurance, costs and expenses associated with ownership of the
above. The costs of any title transfers or fees shall be borne equally by the parties.
4
9. DIVISION OF REAL PROPERTY
Wife is the title holder to real estate at 4706 Courtland Street, Camp Hill,
Cumberland County, Pennsylvania, containing a residential dwelling. The property shall be the
sole and exclusive property of Wife. Wife shall indemnity and hold Husband harmless for
mortgage, lien, or cost of ownership incurred since separation. Should any action be required to
retitle the real estate to Wife, she shall bear the cost. Husband agrees to cooperate in executing
the necessary paperwork to effectuate any retitle.
10. PENSION, RETIREMENT ACCOUNTS, INVESTMENT AND SAVINGS
ACCOUNTS
At the time of separation, the parties were titled to the following retirement accounts.
Wife: a 403(b) with TIAA-CREFF with a value of$3,821.07 at the time of separation in
March of 2002.
Husband: None.
The parties agree that they shall each retain their separate pension and or retirement
accounts. Neither party will make further claim to a pension or retirement account of the other
party.
11. MEDICAL INSURANCE
Neither party is required to maintain medical insurance coverage for the benefit of
the other party following the entry of a Decree in Divorce.
12. MARITAL DEBTS
(a) During the course of the marriage, the parties incurred the following
obligations jointly:
No joint obligations,
Wife and Husband represent that they have taken all steps necessary to make sure
that no credit cards or similar accounts exist which provide for joint liability. From the date of
execution of this Agreement, each party shall use only those cards and accounts for which that
party is individually liable.
5
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(b) The parties have accumulated various debts during the marriage. Husband
shall be solely responsible for the payment of any and all debt in his name. Wife shall be
responsible for the payment of any and all debt in her name.
(c) Since separation, neither party has contracted for any debts which the other
will be responsible for and each party indemnifies and holds harmless the other for all obligations
separately incurred or assumed under this Agreement.
13, FILING AND PAYMENT OF TAXES
The parties agree to file separate income tax returns for the year a decree in
divorce is entered. The parties represent that they have filed all income taxes for each year up to
the year a Decree in Divorce is entered. The parties agree to indemnify and hold the other party
harmless for any unfiled or due taxes individually.
14. DIVORCE
The parties agree to cooperate with each other in obtaining a final divorce of the
marriage. It is agreed that the parties will execute and allow to be filed the necessary documents
to obtain a divorce under Section 3301(c) or 3301(d) of the Divorce Code.
15. DEATH PRIOR TO DIVORCE
If either Husband or Wife dies before the entry of a final decree in divorce
between the parties, this Agreement is deemed to survive the death, and the parties, heirs or
assigns shall enter into the same status as after the Agreement was entered into.
16. INCORPORATION
This agreement is to be incorporated for the purposes of enforcement, but not
merged into any subsequent Decree in Divorce.
17. CONTINUED COOPERATION
The parties agree that they will, after the execution of this Agreement, execute any
6
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and all written instruments, assignments, releases, deeds or notes or other such writings as may
be necessary or desirable for the proper effectuation of this Agreement.
18. COUNSEL FEES
Except as otherwise provided for in this Agreement, each party shall be
responsible for his or her own legal fees and expenses.
19. 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, and the party breaching this
contract shall be responsible for the payment of legal fees and costs incurred by the other in
enforcing their rights under this Agreement or for seeking such other remedies or relief as may be
available to him or her.
20. VOLUNTARY AGREEMENT
The provisions of this Agreement are fully understood by both parties and each
party acknowledges that the Agreement is fair and equitable; that it is being entered into
voluntarily; and that it is not the result of any duress or undue influence.
21. WAIVER OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may dispose of his or her
property in any way, and each party hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or future laws of any jurisdiction to share in
the property or the estate of the other as a result of the marital relationship, including without
limitation, dower, curtsey, statutory allowance, widow's allowance, right to take in intestacy,
right to take against the will of the other and the right to act as administrator or executor of the
other's estate.
22. BINDING EFFECT
This Agreement shall be binding upon the parties' heirs, successors and assigns.
7
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23. MODIFICATION AND WAIVER
Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing and executed with the same formalities as this Agreement. The
failure of either party to insist upon strict performance of any of the provisions of this Agreement
shall not be construed as a waiver of any subsequent default of the same or similar nature.
24. PRIOR AGREEMENTS
It is understood and agreed that any and all prior agreements which may have been
made or executed or verbally discussed prior to the date and time of this Agreement are null and
void and of no effect.
25. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the parties, and there are no
representations, warranties, covenants or undertakings other than those expressly set forth herein.
26. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience only. They shall not
have any binding effect whatsoever in determining the rights or obligations of the parties.
27. APPLICABLE LAW
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
IN WITNESS WHEREOF, the parties set their hands and seals the day and the
year first written above.
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Commonwealth of Pennsylvania:
County of L e hQneY)
PERSONALLY APPEARED BEFORE ME, this $~y of 0 \,l \ Y , 2006, a
notary public, in and for the Commonwealth of Pennsylvania, Felipe Rodriguez, known to me (or
satisfactorily proven to be) the person whose name is subscribed to the within agreement and
acknowledged that he executed the same for the purposes herein contained.
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IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
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Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal ,
Paula E. Kissinger, Notary PubliC
City Of Lebanon, Lebanon County
My Commission Expires Dec. 19. 2009
Membe" PennsylvanIa Assoclatlon of Notarlll
Commonwealth of Pennsylvania:
County of Cu""l,crI..."q
ss
PERSONALLY APPEARED BEFORE ME, this 1.L. day of J..J') , 2006, a
notary public, in and for the Commonwealth of Pennsylvania, Shelly L. Rodriguez, known to me
(or satisfactorily proven to be) the person whose name is subscribed to the within agreement and
acknowledged that she executed the same for the purposes herein contained.
r:f~ <I J;.1
Notary Public
COMMONwEALTH OF PENNSYLVANIA
Nol8It8I SeeI
Uoa p, Snyder. NclIIIy I'ltllIc
Upper AIen,..",., Clmleo""'od COII'1Iy
MyCo....w." Elcplr8II Mar. 12, alO9
Member, Pennsylvania AllOCIatton of Notarie.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
SHELL Y L. RODRIGUEZ,
Plaintiff,
)
)
)
)
)
)
No. 2006-3312
CIVIL TERM
IN DIVORCE
vs.
FELIPE RODROGUEZ,
Defendant.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on June 12,
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 Pa.C.S. S 4904 relating to unsworn
falsification to authorities.
DATED: !O/:J/Oh
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FELIPE RODROGUEZ,
Defendant.
)
)
)
)
)
)
No. 2006-3312
CIVIL TERM
IN DIVORCE
SHELLY L. RODRIGUEZ,
Plaintiff,
vs.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on June 12,
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 Pa.C.S. 94904 relating to unsworn
falsification to authorities.
DATED: /tJ- /-zu?
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/Ji//e ?/i7dJ6z~
Felipe Rodriguez, Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
SHELLY L. RODRIGUEZ,
Plaintiff,
)
)
)
)
)
)
No. 2006-3312
CIVIL TERM
IN DIVORCE
VS.
FELIPE RODROGUEZ,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER ~ 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 Pa.C.S. 94904 relating to unsworn
falsification to authorities.
Date: jo!o/Oh
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FELIPE RODROGUEZ,
Defendant.
)
)
)
)
)
)
No. 2006-3312
CIVIL TERM
IN DIVORCE
SHELLY L. RODRIGUEZ,
Plaintiff,
vs.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER 6 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 Pa.C.S. ~ 4904 relating to unsworn
falsification to authorities.
Date: /?~ /- Z/?
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Felipe Rodriguez, Defendant
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Michael S. Travis
ID No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717) 731-9502
SHELLY L. RODRIGUEZ,
Plaintiff,
In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
No. 2006-3312
vs.
FELIPE RODRIGUEZ,
Defendant.
CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under S 3301(c)(1) of the Divorce
Code.
2. Date and manner of service of the complaint: Complaint was accepted for service
by the Defendant on June 29, 2006, a copy of which was filed with the Court on July 3, 2006.
3. Date of execution of the affidavit of consent required by S 3301(c) of the Divorce
Code: by Plaintiff on Oc.....f..2. , 2006; by Defendant on oct. I , 2006.
4. Related claims pending: Economic claims were resolved by Marriage Settlement
Agreement dated July 31, 2006.
5.
prothonotary:
Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the
OC-""t. \~ ,2006.
Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed with the
prothonotary: (?l'_~ l l.o , 2006.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
SHELLY L. RODRIGUEZ,
Plaintiff,
VERSUS
FELIPE RODRIGUEZ,
Defendant.
No.
2006-3312
DECREE IN
DIVORCE
AND NOW,
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, 1. CCfo, I TIS 0 ROE RED AND
DECREED THAT Shelly L. ReXlriguez
, PLAINTIFF,
AN 0 Felipe Rodriguez
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The Marital Settlement Agreement dated July 31 , 2006 is incorporated
but not merged into this Decree.
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PROTHONOTARY
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHELLY L. RODRIGUEZ,
Plaintiff,
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No. 06-3312
CIVIL TERM
IN DIVORCE
vs.
FELIPE RODRIGUEZ,
Defendant.
AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a Final
Decree in Divorce on October 18 , 2006, hereby elects to resume the prior surname of Shelly
Lynn Hostetter, and gives this written notice pursuant to the provisions of 54 P.S. ~ 704.
DATE: JO/J'f/OftJ
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Signature
~Ynt&u
Signature 0 nam eing resumed
COMMONWEALTH OF PENNSYLVANIA:
/I I I : SS.
COUNTY OF L./.LttI ~44 A./ld
On the ~ day of M1be.e1l.. ,200(", before me, a Notary Public, personally
appeared the above affiant known to me to be the person whose name is subscribed t the within
document and acknowledged that she executed the foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand and official seal.
~ ~Jr-
Notary Pu ic
COMMONWEALTH OF PENNSYLVANIA
NotarIal Seal
Usa P. Snyder, NotaJy Public
Upper Allen Twp., Cumberland County
My Commission Expires Mar. 12, 2009
Member, Pennsylvania Association of Notaries
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