HomeMy WebLinkAbout06-5428BRENT S. CARPENTER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
2006 - s~f~~ CIVIL TERM
MARY ELIZABETH CARPENTER,
Defendant : 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 prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in 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 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, 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 LO5E 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
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.
BRENT S. CARPENTER,
Plaintiff
v.
MARY ELIZABETH CARPENTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2006 - ~/~ CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301fC) AND ~ OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Brent S. Carpenter, and files this Complaint in Divorce
against the Defendant, Mary Elizabeth Carpenter, representing as follows:
1. The Plaintiff is Brent S. Carpenter, an adult individual with a mailing address at
333 Franklin Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant is Mary Elizabeth Carpenter, an adult individual currently residing
at 333 Franklin Street, Carlisle, Cumberland County, Pennsylvania 17013.
4. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least
six months prior to the filing of this action in divorce.
5. The Plaintiff and the Defendant were married on November 28, 1998 in
Pennsylvania and separated on or about April 1, 2005.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
8. The Plaintiff avers that he has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
9. Neither party is in military service or in any branch of the armed forces of the
United States or its Allies or otherwise within the provisions of the Soldiers' and Sailor's Civil
Relief Act of Congress of 1940, as amended.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
Respectfully submitted,
IRWIN & McKNIGHT
Dated: September 15, 2006 By: ''
Douglas G. 'ller, squire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
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BRENT S. CARPENTER,
Plaintiff
v.
MARY ELIZABETH CARPENTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2006 - 5428 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Mary Elizabeth Carpenter, Defendant in the above-captioned matter, hereby
acknowledge and accept service of the Divorce Complaint which was filed on September 15,
2006.
Date: , 2006
Mary Eliz eth Carp ter
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this o~~day of /- , 2007, by and
between MARY E. CARPENTER, (hereinafter referred to as "WIFE") and BRENT S.
CARPENTER, (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on November 28, 1998, and
separated on or about April 1, 2005; 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, but not
limited to 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 the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent 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 which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
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 the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter 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 benefit 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.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(1) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: at this time both
parties agree to be represented by Douglas G. Miller, Esquire of Irwin &
McKnight for the initiation of the divorce action and preparation of this
Agreement;
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(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counsel or after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to
the other of all of 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
3
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 for inadequate
consideration of Marital Property 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 Returns filed by or on behalf of either or both Parties during
marriage.
7.
REAL ESTATE: HUSBAND agrees to transfer all right, title and interest which he may
have in that marital property located at 333 Franklin Street, Carlisle, Cumberland County,
Pennsylvania, 17013, and any improvements thereon, to WIFE and releases all claims which he
may have regarding said real estate in accordance with this paragraph. WIFE agrees to pay any
outstanding payments on any mortgages on said property, as well as all real estate taxes,
insurance, and any maintenance and repair costs, and hold HUSBAND harmless from any
obligations on said payments and indemnify him if any claim is made against him. In
furtherance of the transfer of all right, title and interest in said real estate, HUSBAND hereby
agrees to execute a Deed conveying his interest in the property to WIFE. Said Deed shall be
held in escrow by the law firm of Irwin & McKnight until such time that WIFE refinances,
assumes, or satisfies the outstanding mortgage liens, in order to remove HUSBAND from the
outstanding mortgages on said property. Upon completion of the refinancing or assumption of
the mortgages against the property by WIFE, the Deed shall be filed of record with the
Cumberland County Recorder of Deeds.
8.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay spousal support, alimony, alimony pendente lite, or any other financial support to WIFE,
4
and that WIFE will not be required to pay spousal support, alimony, alimony pendente lite, or
any other financial support to HUSBAND. The parties thereby waive any rights they have to
receive spousal support, alimony or alimony pendente lite payments from the other either prior to
or following the entry of the Divorce Decree in this matter.
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest
which she may have in any personal property of the HUSBAND. HUSBAND likewise waives
any right, title and interest which he has in the personal property of WIFE. Henceforth, each of
the parties shall own, have and enjoy independently of any claim or right of the other party, all
items of personal property of every kind, nature and description and wherever situated, which are
then owned or held by or which may hereafter belong to HUSBAND or WIFE with full power
to HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all
purposes as if he or she were unmarried.
10.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND currently owns or may own in the future, and specifically waives all right, title and
interest to the 1996 Toyota Tacoma and 1990s BMW 1100 currently used by HUSBAND and
titled in his name. HUSBAND shall hold WIFE harmless for any and all liability associated
with the use and purchase of any vehicle he may own, and shall be solely responsible for all
insurance, loans, and other financial responsibility associated with said vehicles.
Likewise, HUSBAND hereby waives all right, title and interest in any vehicle that WIFE
currently owns or may own in the future, and specifically waives all right, title and interest to the
1995 BMW currently used by WIFE. Within thirty (30) days of this Agreement, HUSBAND
shall sign the vehicle title and any and all other documentation necessary to transfer ownership
5
of the 1995 BMW to WIFE. WIFE shall hold HUSBAND harmless for any and all liability
associated with the use and purchase of any vehicle she may own, and shall be solely responsible
for all insurance, loans, and other financial responsibility associated with said vehicles.
11.
MARITAL DEBTS: It is the understanding of the parties that there are no longer any
loans, debts, credit cards, or similar obligations for which they are jointly responsible.
Nevertheless, HUSBAND hereby agrees to remove WIFE'S name from any and all joint
accounts within sixty (60) days of the execution of this Agreement or upon discovery of any such
joint obligations. WIFE also hereby agrees to remove HUSBAND'S name from any and all
joint accounts within sixty (60) days of the execution of this Agreement or upon discovery of any
such joint obligations. The parties agree to pay any such debts according to the party who
incurred any said obligation and hold harmless the other party from any obligations on said
payments and indemnify the other if any claim is made against him or her.
Furthermore, it is mutually agreed by and between the parties that WIFE shall assume all
liability for and pay and indemnify the HUSBAND against all debts incurred by WIFE after the
date of separation. WIFE represents and warrants to HUSBAND that since the parties' marital
separation she has not contracted or incurred any debt or liability for which HUSBAND or his
estate might be responsible and WIFE further represents and warrants to HUSBAND that she
will not contract or incur any debt or liability after the execution of this Agreement, for which
HUSBAND or his estate might be responsible. WIFE shall indemnify and hold HUSBAND
harmless from any and all claims or demands made against him by reason of debts or obligations
incurred by her.
HUSBAND shall similarly assume all liability for and pay and indemnify WIFE against
all debts incurred by HUSBAND after the date of separation. HUSBAND represents and
warrants to WIFE that since the parties' marital separation he has not contracted or incurred any
debt or liability for which WIFE or her estate might be responsible and HUSBAND further
represents and warrants to WIFE that he will not contract or incur any debt or liability after the
execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND
shall indemnify and hold WIFE harmless from any and all claims or demands made against her
by reason of debts or obligations incurred by him.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE, as well as any employee benefits,
including but not limited to retirement, profit sharing or medical benefits of either party, shall be
their own. WIFE waives all right, title, and claim to HUSBAND'S employee benefits, and
HUSBAND waives all right, title, and claim to any of WIFE'S employee benefits.
13.
BENEFITS AND BANK ACCOUNTS: The parties acknowledge the existence of a
joint savings account with M&T Bank. The parties agree that the funds in said savings account
shall be divided equally between the parties, and the account closed with thirty (30) days of the
signing of this Agreement. WIFE agrees to waive all right, title and interest which she may
have in the savings or checking or any other bank accounts of HUSBAND and likewise
HUSBAND agrees to waive all right, title and interest which he may have in the savings or
checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
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 reasonably required to give full force and effect to the provisions of this
Agreement.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, 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. It is the
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
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include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
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 may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
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, curtesy, statutory allowance, widow's
allowance, right to take in 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,
9
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
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COMMONWEALTH OF PENNSYLVANIA
. SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ~sQ day of
2007, MARY E. CARPENTER, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMIIAONWEALTH OF PENNSYLV C~~
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COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ~ day of ,
2007, BRENT S. CARPENTER, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto
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BRENT S. CARPENTER,
Plaintiff,
v.
MARY E. CARPENTER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
Zoo6- 5yzg
IN DIVORCE
CIVIL TERM
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 15, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
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Date: ~°~ b `~ ~ ~ .1~
BRENT S. CARPE ER
Plaintiff
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BRENT S. CARPENTER,
Plaintiff,
v.
MARY E. CARPENTER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2006- 5U2~ CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 15, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: ~ ' ~ "
MARY .CARP NTER
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BRENT S. CARPENTER,
Plaintiff,
v.
MARY E. CARPENTER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2006-~{Z.~
IN DIVORCE
CIVIL TERM
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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: ("~ "~
BRENT S. CARPE ER
Plaintiff
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BRENT S. CARPENTER,
Plaintiff,
v.
MARY E. CARPENTER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2006- C ~ Zg CIVIL TERM
IN DIVORCE
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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: ~ ~ ~ -
MARY E. PENT
Defendant
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BRENT S. CARPENTER,
Plaintiff
v.
MARY ELIZABETH CARPENTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2006 - 5428 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 Section 3301(c) of the Divorce
Code.
2. Date and manner of service of complaint:: A certified copy of the Complaint in Divorce
was served upon the defendant, Mary Elizabeth Carpenter, by hand delivery on or about September 19,
2006. An Acceptance of Service was filed with the Prothonotary on or about September 19, 2006.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c)
of the Divorce Code: by plaintiff: Apri120, 2007 by defendant: Apri120, 2007
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the
Divorce Code:
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
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 plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed
with the Prothonotary: Apri123, 2007
Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed
with the Prothonotary: Apri123, 2007
Douglas .Miller, Esquire
Attorney for Plaintiff
Date: Apri123, 2007
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IN THE COURT OF COMMON PLEAS OF CUIYIBERLAND COUNTY,
PENNSYLVANIA
Brent S. Carpenter,
Plaintiff
Vs
File No. 2006-5428
IN DIVORCE
Mary Elizabeth Carpenter,
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /defendant in the above matter,
[select one by marking `~"]
g prior to the entry of a Final Decree in Divorce,
or after the entry of a Final Decree in Divorce dated
hereby elects to resume the prior surname of wry Elizabeth Rowe ,and gives this
written notice avowing his /her intention pursuant to the provisions of 54 P.S. 704.
Date: 4/23/07
Signa e
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Signatur of name being resumed
COMMONWEALTH OF PE YLVANIA }
COUNTY OF~
On th~ day of , 200 ~ before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he /she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set m and official
seal. ~~ ,~
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I N THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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BRENT s. CARPENTER
Plaintiff
VERSUS
MARY ELIZABETH. CARPENTER,
Defendant
]~(O . 2006-5428
DECREE I N
DIVORCE
fit" !d ~ j ~'~ .
`' ' ~ , ~~ 1T IS ORDERED AND
AND NOW,
DECREED THAT
BRENT S. CARPENTER
PLAINTIFF,
AND MARY ELIZABETH CARPENTER ,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 Marriage Settlement Agreement dated April 20, 2007, and signed by
the parties is hereby
BY
ATTEST: J '
PROTHONOTARY
ated into t~_Decree but not merged.
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