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Home My WebLink About06-3587 . JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 24 N. 32ND Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attornevs for Plaintiff KIM A. LA TSHA, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA ; NO. 01. - .1S/7 (!,u~L'9l..~ CHRISTOPHER GEORGE LATSHA, Defendant : CIVIL ACTION - LAW : 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 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 irretrievab Ie breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, 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 Bar Association 2 Liberty Avenue Carlisle, P A 17013 1-800-990..9108 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attornevs for Plaintiff KIM A. LA TSHA, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . ". -r;. ; NO. tJl - ..3 Sf 7 CwJ -I-M-' CHRISTOPHER GEORGE LA TSHA, Defendant CIVIL ACTION - LAW IN DIVORCE A VlSO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja 0 compensaction reclamados por el demandante. Usted puede perder dinero, 0 sus propiedades 0 otros derechos importantes para usted. Cuando la base para el divorcio es indignadades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEV AR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDO PAGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 1-800-990-9108 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. ex. - .3S'I'7 a/u~l'-T~ KIM A. LA TSHA, Plaintiff CHRISTOPHER GEORGE LATSHA, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330HC) OR (D) OF THE DIVORCE CODE 1. Plaintiff is Kim A. Latsha, an adult individual who currently resides at 27 Cornell Drive, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Christopher George Latsha, an adult individual who currently resides at 27 Cornell Drive, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 23, 2005 in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there are no minor children born of this marriage. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling and notes the parties recently completed approximately 4 marriage counseling sessions. . 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. In the alternative, Plaintiff will file a 330l(d) Affidavit and provide the appropriate Notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 330l(c) or (d) of the Divorce Code. Respectfully submitted, Date: to~ Zo r- D\c, Joanne Harrison Clough, Esq . e AttorneyIDNo.: 36461 24 N. 32nd Street Camp Hill, P A 17011 (717) 737-5890 Attorney for Plaintiff . VERIFICA nON I, Kim A. Latsha, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein'are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date:~ _-kl ~ a cirrls~ ~ Kim A. Latsha r.J ~ ~ - ~ ..0 0 . ....... ~ ....... ~ ~ CY -J e ~ i ~::; () ,-""C" -11 0-'" -.--1 r-..j c', ',' - (:~; ::::~ -.,.0 -< ".... C"J Q [;1 -'~"1 . 1"1 .. .. KIM A. LATSHA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 010- 3SP1 C/~tC'T'UL~ v. CHRISTOPHER GEORGE LATSHA, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a certified copy of the Divorce Complaint, on Christopher George Latsha the 29th day of June, 2006, by Certified U.S. Mail at the following address. A true and correct certified mail card signed by the Defendant Christopher Latsha is attached as Exhibit A. Christopher Latsha 27 Cornell Drive CampHill,PA 17011 By: Joanne 'son Clough, Attorney No. 36461 24 N. 32nd Street Camp Hill, PA 17011 (717) 737.5890 Attorney for .' .. . CompIeIIt I\en'8 1, 2, ond 3. AIIQ complete 118m 4 If RlIlllrict8d DeIIveIY Is deoInId; . Pmt'your n8III8 ond dlr1loe on the ........ 80 that we """ I8Ium the card to you. , . _ thIa card to the beck 01 the inaJl~ or on , If Ip&ee pennita. ~~~~br ~~~ ';;.:1 cbr tJ€. II b-,(2... ~p ii\ \) f1\ ,70 )) D.Io~_-..t__,? [J If YEs, _do!IIvery _ boIow: [J No 3._lP , [J CortItIo<I_ [J eq"o. Moll [J ~ ~RocoIptlor_ [J _ _ [J 0.0.0. 4., _ DoIIvory? /EdnI "-J 7004 2510 0007 6500 5969 I. _ NuniI>or r---8boO PlI Form 3811. -,2004 ---. ."1140 . 0 ....., c: = C~ -'-- o~ L_ ..--1 C - ro., CJ -ry -".. , r;-~) :Z -., -< W 0 MARITAL SETTLEMENT AGREEMENT ofl, THIS AGREEMENT, made this L Kim Latsha, (hereinafter " WIFE") and "HUSBAND"); day of ~ 2006, by and between Christopher Latsha, (hereinafter WIT N E SSE T H: WHEREAS, the parties hereto were married on July 23, 2005, in Camp Hill, P A ; and WHEREAS, the parties have no children of this marriage; and WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling completely the economic and other rights and obligations between each other, including, but not limited to: the equitable distribution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. WIFE is represented by Joanne Harrison Clough, Esquire. HUSBAND is represented by Shana Pugh, Esquire of the Law Offices of Patrick Lauer, but has elected to represent himself in the negotiation and execution of this Agreement: and acknowledges that he had the right to receive legal advice and representation but elected to represent himself. The parties further declare that each is executing the Agreement freely and voluntarily having either obtained sufficient knowledge and disclosure of their respective legal rights and obligations, or if counsel has not been consulted, expressly waiving the right to obtain such knowledge. The parties each 1 acknowledge that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. DIVORCE ACTION. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no fault divorce pursuant to ~ 3301(c) of the Divorce Code. A divorce action was filed by WIFE with the Court of Common Pleas of Cumberland County, Pennsylvania at Civil Action No. 06-3587 on June 20, 2006. The parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement or at the refinancing settlement. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Agreement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" and "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each 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. 4. MUTUAL RELEASES. Each party absolutely and unconditionally release the other and the estate of the other from any and all rights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Each party absolutely and unconditionally releases the other and his or her heirs, executors, and estate from any claims arising by virtue of the marital relationship of the parties. The above release shall be effective whether such claims 2 arIse by way of widow's or widower's rights, family exemption, 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 of the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this Agreement an absolute and unconditional release from all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The parties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Each party understands that hel she had the right to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair and equitable, and that the terms adequately provide for his or her interests, and that this Agreement is not a result of fraud, duress or undue influence exercised by either party upon the other or by any person or persons upon either party. 6. SEP ARA TION/NON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were unmarried. 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 harass, disturb, or malign each other or the respective families of each other. 3 7. REAL PROPERTY. The parties are the joint owners of real property located at 27 Cornell Drive Camp Hill, Cumberland County, Pa, 17011. HUSBAND and WIFE agree that in consideration of HUSBAND tendering to WIFE the sum of Forty-Thousand Dollars ($40,000.00) and the other promises set forth in this paragraph 7, WIFE shall transfer any and all right title claim and interest in the marital residence located at 27 Cornell Drive Camp Hill, Pa. to HUSBAND. HUSBAND shall refinance the mortgage and any other liens and remove WIFE as an Obligor there on. The settlement agent for HUSBAND's refinancing settlement shall tender the payment of FORTY THOUSAND DOLLARS and XX/lOO ( $ 40,000.00) to WIFE from the proceeds of HUSBAND's refinancing settlement. HUSBAND agrees to indemnify WIFE and hold her harmless on any liens, taxes, utilities expenses or any other past, present or future liabilities associated with this property. HUSBAND shall sign a Consent to Divorce and a Waiver of Right to Receive Notice of Intent to Seek Entry of Final Divorce Decree contemporaneously with the Deed and other documents at the refinance settlement. 8. DEBTS. If a party has acquired debt, the parties agree that each shall assume full and complete responsibility for his or her own debts. HUSBAND represents and warrants to WIFE that since the separation he has not, and in the future he will not, contract or incur any debt or liability for which WIFE or her estate might be responsible, and he shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. WIFE represents and warrants to HUSBAND that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which HUSBAND or his estate might be responsible, and he shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 4 9. RETIREMENT BENEFITS. In consideration of the other property transfers set forth in this agreement, HUSBAND hereby waives his right, title and interest to any of WIFE's pension and/ or retirement and any and all other retirement benefits, otherwise disclosed. WIFE hereby waives his right, title and interest to any of HUSBAND's pension and/ or retirement and any and all other retirement benefits, otherwise disclosed. The parties specifically waive any and all other retirement benefits obtained by the parties pre-marriage, during marriage, and post-separation. The individual who holds said benefits shall own the property solely and individually. Each party waives their right to title and interest to the other party's benefit. 10. BANK ACCOUNTS. The parties acknowledge that they have divided the marital bank accounts to their satisfaction. The bank accounts held solely in individual names shall become the sole and separate property of the party in whose name it is registered. Each party does hereby specifically waive and release his/her right, title and interest in the other party's respective accounts. 11. LIFE INSURANCE. HUSBAND hereby waives any right, title, claim or interest he may have in any life insurance policy of WIFE. WIFE hereby waives any right, title, claim or interest she may have in any life insurance policy of HUSBAND. 12. PERSONAL PROPERTY. Except as set forth here below, the parties hereto mutually agree that they have divided all furniture, household furnishings and personal property between them in a manner agreeable to both parties. The parties mutually agree that each party shall from and after the date of this Agreement be the sole and separate owner of all tangible personal property in his or her possession. 13. VEHICLES. The parties did not own any jointly titled vehicles. The Husband waives any right, title claim or interest in the Wife's vehicle which shall remain her sole and 5 separate property and the Wife waives any right, title, or claim of interest in the Husbands vehicle which shall remain his sole and separate property. 14. BANKRUPTCY OR REORGANIZATION PROCEEDINGS. In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney fees and costs incurred in the enforcement of this paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contrary, and each party waives any and all right to assert that obligation hereunder is discharged or dischargeable. The parties mutually agree that in the event of bankruptcy or financial reorganization proceedings by either party in the future, any monies to be paid to the other party, or to a third party, pursuant to the terms of this Agreement shall constitute support and maintenance and shall not be discharged in bankruptcy. 15. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE. The parties hereby expressly waive, release, discharge and give up any and all rights or claims which either may now or hereafter have for spousal support, alimony pendente lite, alimony, or maintenance. The parties further release any rights that they may have to seek modification of the terms of this Agreement in a court of law or equity, with the understanding that this Agreement constitutes a final determination for all time of either party's obligations to contribute to the support or maintenance of the other. 16. A TfORNEY FEES, COURT COSTS. Each party hereby agrees to be solely responsible for his or her own counsel fees, costs and expenses. Neither shall seek any contribution thereto from the other except as otherwise expressly provided herein. 17. ATfORNEYS' FEES FOR ENFORCEMENT. 6 In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecting and enforcing his or her rights under this Agreement. 18. WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a.) The right to obtain an inventory and the appraisement of all marital and non-marital property; (b.) The right to obtain an income and expense statement of either party; (c.) The right to have all property identified and appraised; (d.) The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; and (e.) The right to have the court make all determinations regarding marital and non-marital property, equitable distribution, spousal support, alimony pendente lite, alimony, counsel fees and costs and expenses. 19. MUTUAL COOPERATION. WIFE and HUSBAND shall mutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of documents. 20. VOID CLAUSES. If any term, condition, clause or prOVIsIon of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 7 . . 21. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 22. 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. 23. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND acknowledge e ceipt of a duly executed copy hereof. j ~~~~ Kim Latsha /~~~~ 4hristoPher LafSh . 8 . . COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OFtUn; 82.LAN D On the C)\-h day of Ockc:>b2.s- , 200.G, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared KIm. L.n t.S~ , known to me (or satisfactory proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. COivlMON\I\iEAL TH OF PENNSYLVAN1;.\ I - Notarial Seal I fvlary M. Loper, Notary Public I Camp Hill Bora, Cumberland County I My Commission Expires Oct. 27, 2007 ~;'2'~be( P,,~nsvIV8nl? i\ssocialion Of Notaries -=m~m Notary PUD . c My Commission Expires: OcJobt,....~I, ;?CXJ 1 '?:o-pM COMMONWEALTH OF PENNSYLVANIA :55. COUNTY OF I~Urnl3EI2.L4I\,ju On the 9~ day of OcJ.obe.r , 200~ before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared Ch('\~~phDr LCltS~, known to me (or satisfactory proven) to be on of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. f11::11~ -m . ;;(~ Notary Pu 'c . _ My Commission Expires: GeJoD.Q;- :2/, :;L.OO 7 COMMONWEALTH OF PENNSYLVANiA Notarial Seal Mary M. Loper, Notary Public Camp HiR Bora, Cumberland County My Commission Expires Oct 27, 2007 Member. Pennsylvania Association Of Notanes 9 --------- ---- 2 ~jIi" -0 i:r.: rnfn ';;-; :.~~~ "'~. (. . S~~i~, ~\_' )>, '. ~.~ "':-i -< ~ = c,;> cT' o -n ~ :J:.-n In r; '"Ob :n L 00 ::2~ t;;;c") oi\l -=-t ~ ~ o ("') --4 - '-'> :J" ::z C5 .. -i KIM A. LATSHA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3587 Civil Term CHRISTOPHER GEORGE LATSHA, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on June 23, 2006 . 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of 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 or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Section 4904 relating to unsworn falsification to authorities. Date: \0\Q \()~ ~0 .cfccbha. Kim A. Latsha E s: -om t11 F"'. z-r" z~:~ m~_, .;;;./ .I/IL~~ ~Ci j>(-., z.,J ......c; .....c 2; =< I"'.:l = = ;::r. o ("') --f ~ ~ ~~ -:tJ ~ 00 ---If. I-n (.)-" "70 am ~ ~ \D :r:ooo ~ '2 {T\ ---- KIM A. LA TSHA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-3587 Civil Term CHRISTOPHER GEORGE LA TSHA, Defendant : CIVIL ACTION - LA W : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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. ~ 4904 relating to unsworn falsification to authorities. DATE: ~C\.~\,~ Kim A. Latsha 2 ~ ~(JJ T.r.'... .;f~- :z: '-. ~,!;. t2C~' ~;r---' Z(-'\ J7C Z :;;.; -- ~ ~ <:::) S? - "" ~ q G?t ~~ ;!~ I ,,.',0 :;:; ...,-, ,J._11 9~ ~ ~ ::< - CP KIM A. LATSHA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3587 Civil Term CHRISTOPHER GEORGE LATSHA, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 23,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of 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 or upon filing of my Waiver of the Notice ofIntention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Section 4904 relating to unsworn falsification to authorities. Date: /tJ-//- 06 ~/A" ~ / ~toPher Georg~a~ n f"...) c:::;) ~ c: c:::;) s:: ~ -at1:l 0 ~21 tDrn n z:r' -of r- zr -09 -<.., O? ,E,: \.0 ;U 2('" '--)0 !<:~ -If' ~C: :tlO> :+:d :J: ~(") ""C' ....-m >c cs 9 z ~ ~ en KIM A. LA TSHA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-3587 Civil Term CHRISTOPHER GEORGE LATSHA, Defendant : CIVIL ACTION - LAW : IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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. ~ 4904 relating to unsworn falsification to authorities. DATE: /0 - /1--c1~ ~4~/~ > ~- Christopher Ge~~ha ~ <;~ "'O~C2. , . t~...: ..J~.' 0!~;' l.d:c ~Q .....l..; $-c: z :.2 g C'" ~ \.t:> :J"- ::lC o .. ~ --' if.:n \Ti :9,0 6' '_:10. _', -1". ~..k---n ":)- Z?^ 9 ~ C" .' --------- .... KIM A. LA TSHA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. (Jt - 3S-g 7 C 1/1// 7?,rrYl : CIVIL ACTION - LAW : IN DIVORCE CHRISTOPHER GEORGE LA TSHA, Defendant PRAECIPE TO TRANSMIT RECORD UNDER ~ 3301 (c) OF THE DIVORCE CODE To the Prothonotary: Transmit the record, together with the following infonnation, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: (a) Date of service: June 29,2006 (b) Manner of service: Certified United States Mail. Affidavit of Service filed: July, 20,2006 3. Date of execution of the Affidavit of Consent required by S 3301 (c) of the Divorce Code: (a) By the Plaintiff: signed October 9,2006 and filed simultaneously with this document. (b) By the Defendant: signed October 11, 2006 and filed simultaneously with this document. (c) Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (d) By the Plaintiff: signed October 9,2006 and filed simultaneously with this document. . . (e) By the Defendant: signed October 11,2006 and filed simultaneously with this document. 4. Related claims pending: NONE DA TED/~ 2-/ tJ ~ Joanne arrison Clough, Attorney lD No. 36461 24 N. 32nd Street Camp Hill, P A 17011 (717) 737-5890 Attorney for PIll ,NT'PF J (') c ~ ij] ~~~~ Zt; UJ"'> ~;-- ~"--" ~c_; ~L) PC: Z =< ~ = c:::J er- e::> n --t ~ ~F1 ;Q9 '-'0 ~:H ".)- :~~ o ~ =< \.0 ::I> :3: <:? CF"t ~~ ~ ~ ~~ ~ ~ ~~~ ~ ~ ~ ~ ~ ~ ~~~ ~~~~~ ~~~~~~~~ ~~~~~~~~ ~ IN THE COURT OF COMMON PLEAS : OFCUMBERLANDCOUNTY PENNA. STATE OF KIM A. LATSHA, Plaintiff No. 06 - 3587 CIVIL TERM VERSUS ~ ~ ~ CHRISTOPHER GEORGE LATSHA, Defendant DECREE IN DIVORCE AND NOW, o ,,{ . 2006 ,IT IS ORDERED AND .... 2.~ KIM A. LATSHA , PLAI NTI FF, DECREED THAT AND CHRISTOPHER GEORGE LATSHA , 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; AND, it is further ordered, adiudqed and decreed, that the terms of the parties' Marital Settlement Aqreement, dated September 1, 2006, and attached hereto are incorporated herein but not merged herewi th. By TH E Cou RT: ATTEST ~~~~~~~~ ~~~~~~~~~ ~ ~~~~~~~~~~~~~~+.~~ ~~~~ ~ ~ J. - ~ :2 ~'" ~k, ?177(:- 01 ~ .fiv p ~ ~ -r;; '717-'11:'- (7/ , . . " ! . Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA KIM A. LA TSHA, v. : NO. 06-3587 CIVIL TERM CHRISTOPHER GEORGE LA TSHA, Defendant : CIVIL ACTION - LA W : IN DIVORCE NOTICE OF ELECTION TO RESUME PREVIOUS NAME Notice is hereby given that a final decree in divorce being granted, KIM A. LA TSHA hereby elects to resume her prior name of KIM A. CRAWFORD, and gives this written notice of her intention in accordance with the provisions of 54 Pa.C.S. Section 704. .E~().~a KIMA. LATSHA to be known as: ~~ 0 .C^C1l1)lr~ . KIM A. CRA WFORD 0''-'''- COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF Q,UI'l1B~R.LA-NiJ On the IS~ day of NO\JtrY\blr ,2006, before me, a Notary Public, personally appeared KIM A. LA TSHA tIb/k/a KIM A. CRA WFoR9 known to me to be the person whose name is subscribed to 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. Notary 2r1cnca -m - 2>f~ CQMMONWEALTH OF PENNSYLYANIA Notarial Seal Mary M. 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