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HomeMy WebLinkAbout06-3882 ... Barry M. Shutt, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. Lauren S. Shutt, Defendant CIVIL ACTION - LAW No.Dl..- 7t?.).. CIVIL IN DIVORCE NOTICE 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 attomey 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 ajudgment 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. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. Barry M. Shutt, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren S. Shutt, Defendant CIVIL ACTION - LAW No. CL.- 3fP~ CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Barry M. Shutt, an adult individual, who resides at 8 Dulles Drive West, Apt H-3, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Lauren S. Shutt, an adult individual, who resides at 335 Hickory Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 13, 1986 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & WHARE Date: q!lO(O(o { Les Ie A. Tomeo, squire 155 South Hanov r Street Carlisle, P A 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff Barry M. Shutt, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren S. Shutt, Defendant CIVIL ACTION - LAW No. CIVIL IN DIVORCE VERIFICATION 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. ~4904, relating to unsworn falsification to authorities. o7;;olo~ I ~4f4P Date: Barry M. Shutt, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren S. Shutt, Defendant CIVIL ACTION - LAW No. CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows; Lauren S. Shutt 335 Hickory Rollli Carlisle, Pa 17013 Oot<d --rfJOb { LeA. Tomeo Esquire 155 South Hano er Street Carlisle, P A 17013 (717) 241-6070 Supreme Court J.D. # 200198 Attomey for Plaintiff y () ~ ,,",' ,~~~ C) <,'" '1 ~ ..,',.... ~q C,_ , ~ i -- -.- - ~ a ~ ~ _c._ -",'-', - ~ ft! sj ., U1 ;n 0 .< J Barry M. Shutt, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren L. Shutt, Defendant CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE PRAECIP~ TO AMEND CAPTION TO THE PROTHONOTARY: Please amend the above caption to Lauren 1. Shutt instead of Lauren S. Shutt. DATE: July 25, 2006 Respectfully Submitted, ROMINGER & WHARE eslie A. Tom , Esquire 155 South H over Street Carlisle, Pa 17013 (717) 241-6070 Supreme Court ID # 200198 Attorney for Plaintiff (""" --I , .1 '.' (. c':) Barry M. Shutt, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren 1. Shutt, Defendant CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE MARITAL SEPARATION AGREEMENT THIS AGREEMENT, made this .J;!}! day Of~ by and between Barry M. Shutt, hereinafter referred to as "HUSBAND", and Lauren L. Shutt, hereinafter referred to as "WIFE. " WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on September 13, 1986; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other 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: 1. 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. 2. The parties have attempted to divide their matrimonial property in a manner that conforms to just and right standards, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and Agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and Agreements of each of the parties to the other. The adequacy of the consideration for all Agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each party to this Agreement acknowledges and declares that he or she, respectively: A. Enters into this Agreement voluntarily after receiving the advice of counsel of his or her own choosing or has voluntarily elected not to obtain counsel; B. Is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this Agreement; D. Has carefully read each provision of this Agreement; and E. Fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all his or her property, interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax retumsfiled by or on half of both parties during the marriage. 7. PERSONAL PROPERTY: WIFE agrees that all the property in the possession of the HUSBAND shall be the sole and separate property of the HUSBAND, and HUSBAND agrees that all the property in the possession of the WIFE shall be the sole and separate property of the WIFE. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. The following property shall be transferred as follows: a. Each party will become the sole and exclusive owner of their IRAs, 401 (K)s, pensions, life insurance, savings, stocks and checking accounts except as follows at b. and c. b. The M & T Market Advantage account balance at separation has been disbursed equitably as follows after payment of real estate taxes of $2,353.78. Husband acknowledges he has already received $8,018.55 in payout of equitable distribution of this account. Wife acknowledges she has already received $8,018.55 in payout of equitable distribution of this account. c. Each party will close their jointly owned M & T checking account within 120 days of the signing of this agreement. d. WIFE will keep and remain responsible for her own vehicle, 2004 Chrysler. HUSBAND will keep and remain responsible for his own vehicles, the 1990 Toyota Truck and the 2003 Kia Van. e. Husband acknowledges that he was waived all right, title and interest to all M & T stock jointly registered and solely registered in Wife's name, and that said stock has been sold prior to signing ofthis agreement. f. Wife retains the dog, Bunnie. 8. REAL PROPERTY: It is further mutually agreed by and between the parties that the marital residence at 335 Hickory Road, Carlisle, Pa 17013 shall be retained by WIFE in exchange for $85,800.00 and HUSBAND shall relinquish all right, title and interest to the marital property; $30,000.00 of which is to be paid within 10 days of the signing of this agreement. HUSBAND agrees not to enter the marital residence without the express and specific consent of Wife. The remaining $55,800.00 will be paid to HUSBAND within 120 days of the signi.ng of this agreement. HUSBAND shall relinquish all right, title, and interest to the marital property at 335 Hickory Road, Carlisle, Pa 17013 and before or upon the date of WIFE'S refinance of the loan secured by the marital property, shall deliver deed giving WIFE sole and exclusive possession and ownership of the marital property. 9. DEBTS & LIABILITIES: Each party shall be responsible for their own credit card debt, and that any debts incurred by the parties after the execution of this Agreement shall be the sole responsibility of the party incurring that obligation. 10. INCOME TAX RETURNS: The parties may file ajoint tax return for the tax year and 2006, and may divide equally any refund or payment due therefrom. All future income tax refunds will be filed separately and the parties will each retain any refund due to them. 11. ALIMONY. ALIMONY PENDENTE LITE and LEGAL FEES: Each party hereby waives any right to spousal support, alimony or alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. WIFE and HUSBAND do hereby waive, release, and give up any rights they may respectively have against the other for alimony, support or maintenance. It shall be, from the execution of this Agreement, the sole rf;lsponsibility of each of the respective parties to sustain themselves without seeking support from the other party. 12. OTHER LEGAL EXPECTANCY INTERESTS: Nothing in this instrument shall be construed to affect either party's legal interest or entitlement to any settlement proceeds arising out of any current pending litigation. 13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, 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, curtesy, statutory allowance, widow's allowance, right to take the intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waive and relinquishment of all such interest, rights and claims. 14. BREACH: In the event of the breach of this Agreement by either party, the non- breaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek specific performance of the terms of this Agreement, where such damages are not ascertainable. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain monetary damages and/or specific performance of this Agreement shall be recoverable as part of the judgment entered by the Court. 15. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonable required to give full force and effect to the provisions of this Agreement. 16. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties and its provisions are fully understood. Both parties agree that they are executing this Agreement freely and voluntarily. Husband's legal counsel is Leslie A. Tomeo, Esquire. Both parties acknowledge that it has been suggested to them that they review this Agreement with independent legal counsel and has either done so or has voluntarily chosen not to do so. 17. HEADINGS: Any Headings proceeding the text of the several paragraphs and subparagraphs hereof are inserted solely for the convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, constructions or affect. 18. 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. 19. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 20. PRIOR AGREEMENTS: It is understood and agreed that any and all Property Settlement Agreements which mayor have been executed or verbally discussed prior to the date and time of this Agreement are null and void and of no effect. 20. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any court into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contract. 21. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 22. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of 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. 23. Unless otherwise stated herein, this Agreement shall become effective immediately upon its execution by both parties. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and Barry M. -ro~ ~ A ~att-- Lauren L. Shutt COMMONWEALTH OF PENNSYLVANIA COUNTYOF ~U If\l~rt()t\Ql SS: Personally appeared before me, a notary public for Cumberland County, Pennsylvania, this ~ay of , 2006, Barry M. Shutt, known to me (or satisfactorily proven) to be the p son whose name is subscribed to the within Agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I h~ve hereunto et my hand and OffiCial. seal. COMMONWEALTH OF PENNSYLVANIA .~. JJ A ~ Notarial Seal fJ!~ T3':'lmie L Peters, Notary PubliC Notary Public South Middleton Twp.. Cumbettana County My CommissIOn Expires Sept. 9, 2001 Member. PennsylvllnlQ AuOelallon Of Nol."., (SEAL) COMMONWEAL TH OF PENNSYL VANIA COUNTY OFC\ ) i,'"' b..uJa 11r\ SS: Personally appeared before me, a notary public for Cumberland County, Pennsylvania, this / -) day of aLr.J I , 2006, Lauren L. Shutt, known to me (or satisfactorily proven) to be the person whose name IS sl.'bscnbed to the WIthm Agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. .. ~ ritc, I) Jr CO fJ/"L- Notary Public ;,uMfvlUNWlAUH OF PENNSYLVANIA NOTARIAL SEAL LINDA McCLELLAN Notary Public ~~ro of qar!isle, Cumberland Count \ r."mmlsslon EXl'lires Oct. 26, 200~ ..'-~ ,,.. ...:";--.~~ (SEAL) " , (l ;-;.. r--.) .c~ L.._,) c::....... o -n :~-n rl1p __.-j III .:jl:J , "'\ .J- ~-':\'i? ~~':). (~S C) ;\\ :-\ ~ :;... ~ o r'-",", .:...:i c.,' -u c,) C,.) Barry M. Shutt, Plainti ff v. Lauren L. Shutt, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE PROOF OF SERVICE SENDER. COMPLETE THIS SECTION . Complete items 1, 2, a~d 3. .Also ~omplete item 4 if Restricted Delivery IS desired. . Print your name and address on the reverse so that we can return the card to you.. , . Attach this card to the back of the mall piece, or on the front if space permits. 1. Article Addressed to: . ,\' \Vllltt Lou(c Vl 2'r- \ \ .') >'-:> ., \" C L G'( '-1 1\., ./) I (, 'I \I \ \ ,"\l Q... I . ,''( '-..lJ... \ . -, \ ,,'-, , /"\I~ :~'l t. 'J ',- \ ') C. \ $ 2. Article Number (Transfer from service label) PS Form 3811, February 2004 . Date of Delive~ U~ L 7-jY-tJ~, D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: ,!3:No 3. Service Type J!:'certified Mail 0 Express Mail o Registered J2I'I'leturn Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) JitYes 7005 2570 0000 3795 5016 Domestic Return Receipt 102595-02.M.1S40 "") e'" ~:) e.:"> (' ( .' ~ >- S)~~ .') ;.'":-,. ~~~~ ~, ':~~ C) ");? c: ~ --"-~', c_",) ~) ,...-.'- .....- ( .:...'\ (.,.>." Barry M. Shutt, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren L. Shutt, Defendant CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 10, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: 10 [2'd Qio G -or~--: rr-;'l ~ '~.-~/ 7~r o (- -':.,,'" ..~~.. r..,:) = C";J c:r" (:) <J --I W o .....=,.. -" ~;:; '.r:-"-, ~~.{ /" ~-:;. :::~ .,"", -0 ~ -' -r:-n r-ni':::C ,,-; :qC ~~~ --\ J~ ~ .t:"" r Barry M. Shutt, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren L. Shutt, Defendant CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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. S4904, relating to unsworn falsification to authorities. Date:~{?<>( cb ~~ It Jdc4;{j- Barry M. Shutt, P-fuintiff o c: :~: -ofC CQL: ' J:;.... ~{~ ~ ,..., = c::> 0--' o " -l W o o --n .-4 ::I:... n1r'= -nrn -;:19 l_)('") ---1::-"'F -0 ;tfS .~.'__ rn '..J -I ?O =-< .r:.- .r:.- Barry M. Shutt, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren L. Shutt, Defendant CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 10, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: ~ t1 vtuxrr Lauren L. Shutt/Defendant (") ~ ~~ 4:10' ~?\! ?:/} .',. c: 1,- :- ; s;~; <'-, ~ 'C5 c:> c:r CJ c-> -4 vJ o -0 - ...z.-- - ~ ::?~ n;~ -aSD .c1~~~ c~(') --r11 ';3 "" :J.:! .::;,,:: &:"' .;.. Barry M. Shutt, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Lauren L. Shutt, Defendaflt CIVIL ACTION - LAW No. 06-3882 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 understafld 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 graflted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court afld 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 afld correct. I understafld that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification to authorities. Date:~ 0S-( 0(/ ~1-.~ Lauren L. Shutt, Defendant () s vt~..: lT1 f -/' ' ?;, ," ~~-.. ~"')-~ .....- :?: ;-._-~. 5;,,::'c~ -7 ::"3 ..--..... ~ c....,? = <:;;1" o ~ -. o -n ~ X-n n1p'" -om ""CJ ..~~~ (~?(~ 1='jr, . ~ ""{> ~ w o ::? ~'" - .. .r:- .r:- Barry M. Shutt, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Lauren L. Shutt, Defendant CIVIL ACTION - LAW No. 06-3882 CIVIL 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. Grounds for divorce: irretrievable breakdown under 9 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: July 10,2006, was served on Defendant by Certified Mail and the green card was signed on July 14,2006 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by 9 3301 (c) or The Divorce Code: by the Plaintiff: October 20,2006; by the Defendant: October 25, 2006. 4. Related claims pending: None. 5. (b) Date Plaintiffs Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: October 30, 2006 Prothonotary: October 30, 2006 Date Defendant's Waiver of Notice in 933 Date: October 31, 2006 Le . e A. Tomeo, squire 155 South Hanov r Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID No. 200198 Q ~,; ~ c~ 0'" o (') ~ (,..) - ~ :i-n (l' ~~ -DC? -\} , -:~:9; /?:~ b --' "-\:;0- ~.9.. -q ::v - CO u:> ~ ;+;'+0 ;Ii;li ;Ii ;Ii '+0 ;Ii 0+; ;Ii 0+; ;Ii 0+; ;Ii 0+; 0+; ;f. ;Ii 0+; ;f. <Ii <Ii ;Ii<li!!; !!;!!; Of; ~ <li0f;~~0f;~;f.~;f.O+;~;f. ;Ii ;f.;Ii;li;f.;lio+; ~;Ii;li;li ~;Ii;li IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. R.::Irry M _ Shutt No. 2006- 3882 Plnintiff VERSUS L;:mrpn L Shutt Defendant DECREE IN DIVORCE AND NOW, NDV , 2f)Ob, IT IS ORDERED AND 4 DECREED THAT Barry M. Shutt , PLAI NTI FF, AN D Lauren L. Shutt , 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; Mari tal Separation Agreement is incorporated but not merged into the decree. ATT PROTHONOTARY ;Ii ;f.~O+;",'" ;Ii"'~~;Ii;li;li"';Ii ~~~~ o+;~~~~~ !!;;f.~~O+; ~~o+;o+;o+;o+;~ ~~~o+;~o+; ~ '" ;f. '" ;f. '" '+' '+' '" '" '+' J. _~ z nr:- ry"lA tJO /( -1/ ~ ~ ~~4b; P9 ~.5II! .~ ".. . .