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HomeMy WebLinkAbout06-5594L. COYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. L. COYLE, : NO. & -s q4/ CIVIL TERM 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 owing pages, you must take prompt action. You are warned that if you fail to do so, the case proceed without you and a decree of divorce or annulment may be entered against you by Court. A judgment may also be entered against you for any other claim or relief requested in ce papers by the Plaintiff. You may lose money or property or other rights important to you, uding custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, u may request that the court require you and your spouse to attend marriage counseling prior a divorce decree being handed down by the court. A list of marriage counselors is available in Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are vised that this list is kept as a convenience to you and you are not bound to choose a counselor >m the list. All necessary arrangements and the cost of counseling sessions are to be borne by u and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, AWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, OU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE CE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 (717) 249-3166 SNELBAKER & BRENNEMAN, P.C. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. By: Attorneys for Plaintiff kEL L. COYLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA :NO. CIVIL TERM UDRA L. COYLE, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT COUNT I - DIVORCE 1. Plaintiff Michael L. Coyle is an adult individual residing at 391 Crossroad School Newville, Cumberland County, Pennsylvania. 2. Defendant Audra L. Coyle is an adult individual residing at 426 Dogwood Court, Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of vania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on May 4, 1996 in lisle, Cumberland County, Pennsylvania. 5. The prior action in divorce initiated by Plaintiff and docketed to number 2001-4614, County was purged by inactivity on December 30, 2004. 6. Neither party is a member of the armed forces of the United States of America. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have right to request that the Court require the parties to participate in counseling. 9. Plaintiff and Defendant have been separated since September 15, 2006. 10. The Plaintiff requests this Court to enter to enter a decree of divorce. WHEREFORE, Plaintiff Michael L. Coyle requests this Court to enter a Decree of vorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the and Defendant. COUNT II - EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10, inclusive, of this Complaint are incorporated by reference herein. 12. The Plaintiff and Defendant have legally and beneficially acquired property and debts during their marriage from May 4, 1996. 13. The Plaintiff and Defendant have not agreed as to any equitable distribution of the marital property and debts. WHEREFORE, Plaintiff Michael L. Coyle requests this Court to order equitable LAW OFFICES SNELBAKER & BRENNEMAN, P.C. distribution of marital property and debts. -2- WHEREFORE, the Plaintiff requests this Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; (b) order equitable distribution of marital property and debts; and (c) order such other relief as this Court deems just and reasonable. SNELBAKER & BRENNEMAN, P.C. By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Date: September 20, 2006 Attorneys for Plaintiff Michael L. Coyle LAW OFFICES -3- SNELBAKER & BRENNEMAN, P.C. VERIFICATION I verify that the statements made in the foregoing Petition 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: September 20, 2006 LAW OFFICES SNELBAKER & BRENNEMAN. P.C. [ICHAEL L. COYLE, Plaintiff V. UDRA L. COYLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT MICHAEL L. COYLE, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the JProthonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. 1??? 4?-ab Michael September 20, 2006 LAW OFFICES SNELBAKER & BRENNEMAN, P.G. Q n 4 wl n ^, 'TT CrIl .771 j r rn N =C MICHAEL L. COYLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5594 CIVIL TERM AUDRA L. COYLE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF CUMBERLAND ) Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that he is a principal in the law firm of Snelbaker & Brenneman, P. C., being the attorneys for Michael L. Coyle, Plaintiff in the above captioned action in divorce; that on September 26, 2006 he did send to Defendant Audra L. Coyle by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7003 1010 0000 81310944; that the Complaint and cover letter were duly received by an agent of the Defendant herein, as evidenced by the return receipt card for said certified mail dated September 28, 2006; that a copy of the aforementioned cover letter dated September 26, 2006 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached LAW OFFICES SNELBAKER & BRENNEMAN, P.C. hereto and incorporated by reference herein as "Exhibit B"; and that the foregoing facts are true and correct to the best of his knowledge, information and belief. Keith O. Brenneman Sworn to and subscribed before me this 29 h day of September, 2006. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Susan L. Matrazi, Notary Public Mechanicsburg Boro, Cumberland County My Commission Expires Nov. 24, 2007 Member, Pennsylvania Association Of Notaries LAW OFFICES -2- SNELBAKER & BRENNEMAN, P.C. 11 RICHARD C. SNELBAKER KEITH O. BRENNEMAN Audra L. Coyle 426 Dogwood Court Carlisle, PA 17013 SNELBAKER & BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 717.697-8528 September 26, 2006 Re: Coyle v. Coyle No. 2006-5594, Cumberland County Dear Ms. Coyle: P. O. BOX 318 FACSIMILE (717) 697-7681 Enclosed please find a certified copy of a Divorce Complaint, the original of which was filed this date with the Prothonotary of Cumberland County. Yours truly, Keith O. Brenneman KOB/sm Enclosure CC: Michael L. Coyle (w/enclosure) By certified mail, restricted delivery, return receipt requested, parcel No. 7003 1010 0000 8131 0944 EXHIBIT A CERTIFIED MAILT. RECEIF (Domestic Mail Only; No Insurance Cov •a. I vi r9 M f"' 3 9 r CID Postage $ c C3 Certified Fee 2.40 N P k O eLtnar C3 Return Reciept Fee (Endorsement Required) _ 1 85 ! re O O Restricted Delivery Fee (Endorsement Required) 3 . 70 w a Total Postage & Fees M C3 r To C3 Audra L Co--le ?- : -.?itfBBt, Apt. No.;- orPOeoxNo. 426 ---------------------------------------------- Dogwood Court ------- ---- - ---------------------------------------------------------------------------- cty srara,Z/P+4 Carlisle, PA 17013 3800, June 2002 -PS Form See Reverse for Instructions ¦ Complete Items 1, 2, and 3. Also complete A. Si nature Item 4 if Restricted Delivery is desired. , 13 Agent X ¦ Print your name and address on the reverse ? Addressee eo that we can return the card to you. S. Received by (Printed Nears) C. Date of Delivery ¦ Attach this card to the back of the maiipiece, _I . or on the front If space permits. W't•? 13 Yes D. Is delivery address dill 1 1. Article Addressed to: If YES, ento":rd Mfto Audra L. Coyle DELIVERY 426 Dogwood Court Carlisle, PA 17013 3. Service Type Memed man ? Express Mail ? Registered ? Return Receipt for Merchandhe ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) UYes 2. Article Number (rfanefer from sen 7003 1010 0000 8131 0944 PS Form 3811, February 2004 Domestic Return Receipt 10M!55 02-M-11840 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. EXHIBIT B ?? ? O ??_ ? ?. -rt c'°? ?s i -.-, '?C1 - tv ?? ___;i?+ -,-, j?' ?. ..-..? ?.J ""?, ? MICHAEL L. COYLE Plaintiff V. AUDRA L. COYLE DefencIant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 5594 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above-captioned matter, X ? 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 FANUS , and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. § 704. Date: 0 Signature: Audra L. Coyle Signature of name being resumed: Audra L. Fanus COMMONWEALT14 OF PENNSYLVANIA ) COUNTY OF CUMIOERLAND ) On the day of fitt? , 2008, before me, the notary public, personally appeared the above affiant known to me or satisfactorily proven 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 hand and official seal. OF PENNWLVAP" Notary Publ' NOTLIAL SEAL VALER IE F. Notary Pubk Cx%b Boroedand County COMMWion October 9, 2010 C) cm 7_ r CLO --n a n ?; rn -Ti `&.,4 c ,. _M ?J POST-NUPTIAL AGREEMENT THIS AGREEMENT, made and entered into this day of WIV*16oO, , 2008 by and between: MICHAEL L. COYLE, of 703 Sandbank Road, Mount Holly Springs, Cumberland County, Pennsylvania, party of the first part, (hereinafter "Husband") AND AUDRA L. COYLE, of 426 Dogwood Court, Carlisle, Cumberland County, Pennsylvania, party of the second part, (hereinafter "Wife") WITNESSETH: WHEREAS, Husband and Wife (collectively referred to herein as the "parties") were married to each other on May 4, 1996 in Carlisle, Pennsylvania; and WHEREAS, the parties have accumulated certain assets and incurred certain debts during their marriage; and WHEREAS, the parties have three children of their marriage; namely Dylan Michael Coyle, born February 11, 1997; Torey Lynn Coyle, born December 14, 2000; and Erik Scott Coyle, born April 20, 2004; and WHEREAS, certain differences have arisen between the parties, as a consequence of which they have commenced living separate and apart from each other on September 15, 2006; and WHEREAS, on September 26, 2006 Husband commenced an action in divorce docketed to No. 2006-5594 in the Court of Common Pleas of Cumberland County, Pennsylvania (hereinafter the "Divorce Action"); and WHEREAS, the parties agree that their marriage is irretrievably broken; and WHEREAS, the parties acknowledge that each has had the full opportunity to be advised independently and represented by separate counsel concerning their respective rights, duties and obligations arising out of their marital status and with respect to the terms and provisions of this Post-Nuptial Agreement and the meaning and legal effect thereof and have obtained such counsel and advice or have voluntarily and knowingly chosen not to do so; and; WHEREAS, the parties having a full opportunity to be so advised of their respective rights, duties and obligations arising out of their marital status, and each having a full opportunity to investigate and evaluate assets, liabilities and all other aspects of each other's property and their jointly owned assets and liabilities, have come to an agreement for the final settlement of their property and affairs, which they believe to be fair, just and equitable. NOW THEREFORE, in consideration of these presents and the mutual covenants, promises, terms and conditions hereinafter set forth and to be kept and performed by each party hereto, and intending to be legally bound hereby, the parties mutually agree as follows: 1. INCORPORATION OF PREAMBLE. The foregoing preamble and paragraphs are incorporated by reference herein in their entirety. 2. MUTUAL SEPARATION. Husband and Wife shall be free from constraint or control by the other as fully as if he or she were unmarried. Neither shall disturb, trouble nor interfere in any way with the other or with any person for associating with the other. 3. PERSONAL PROPERTY. the parties declare and agree that they have, prior to the execution of the Post-Nuptial Agreement (the "Agreement"), voluntarily agreed to divide and have physically divided and distributed between themselves all of the parties' personal property 2 which they acquired either before or during their marriage, whether or not said property is or would be deemed to be marital property under the Pennsylvania Divorce Code and subject to equitable distribution. The parties declare and acknowledge that they are fully aware and familiar with all assets and real property that each has brought into the marriage and that has been obtained or acquired separately or jointly by them during the course of their marriage and therefore waive any valuation thereof. Each party expressly releases the other of and from any and all right of equitable distribution or claims to assets and property of any kind or nature whatever possessed in accordance with this Agreement by the other party and hereby declares and acknowledges that the voluntary division by them of all property, whether marital or not, is fair and equitable and that either party may sell, dispose of, encumber or transfer any property in his or her possession free of any claim or interest of the other. 4. BANKRUPTCY. The parties acknowledge that in September 2006, they jointly filed a Petition for relief under Chapter 13 of the United States Bankruptcy Code in the United States District Court for the Middle District of Pennsylvania (the "Bankruptcy"). The parties acknowledge that the parties' marital residence at 391 Crossroad School Road, Newville has been sold as part of the parties' Chapter 13 bankruptcy plan, with the proceeds of such sale being disposed of through the parties' bankruptcy estate in accordance with the plan. The parties further acknowledge that the $100.00 monthly payment required to be paid by the parties in accordance with their plan is being paid to the Bankruptcy Trustee by attachment from Husband's wages. Wife agrees to pay one-half of all amounts required to be paid by the parties to the Bankruptcy Trustee until the bankruptcy proceeding is discharged. The parties agree that except as specifically noted in this Agreement, all debt of the parties, whether joint or separate or incurred prior to or during marriage is being discharged or paid, as the case may be, through their Bankruptcy. 5. EQUITABLE DISTRIBUTION. In addition to the division of assets and marital property as set forth in other provisions of this Agreement, Husband agrees that he shall upon the parties' execution of this Agreement, pay Wife concurrently therewith the sum of $3,000.00 as equitable distribution and not as alimony or support. 6. AUTOMOBILES. The parties represent and acknowledge that each is in possession of a motor vehicle: Husband being in possession of a 2004 Ford F150 titled in his name alone and Wife in possession of a 2005 Chevrolet Impala titled in her name alone. The parties agree both shall retain sole ownership, use and possession of the vehicle titled in his or her name and be solely responsible for paying the loan secured by said vehicle. The parties agree to indemnify and hold the other harmless of and from any and all liability and claims of any nature with respect to his or her failure to pay the loan on his or her vehicle. 7. PENSION 401 K RETIREMENT PLANS, EMPLOYMENT BENEFITS. The parties acknowledge that Husband has a 401 K account with his employer, Ahlstrom, Inc. having a vested balance as of August 2006 of $49,749.72 and an outstanding loan balance against that account of $19,957.97. The parties agree Husband shall possess as his sole property and retain, free of any claim or interest of Wife, the balance of funds in the 401 K account together with the outstanding loan balance. Husband will indemnify and hold Wife harmless of and from any and all liability and claims of any nature with respect to the outstanding loan balance of Husband's 401 K account, including, but not limited to, any payments, principal and/or interest due therefrom. 4 The parties agree that Husband shall possess and retain, free of any claim or interest of Wife, all of Husband's pension with Ahlstrom, Inc. 8. DEBTS AND FUTURE.DEBTS. Each party agrees that he or she shall indemnify and hold the other harmless of any from any and all liability arising from any debts that each party is obligated to pay as identified in this Agreement. The parties further agree that any and all loans, debts and/or obligations incurred subsequent to the date of their separation shall be the sole and separate liability and responsibility of the party incurring the obligation and each party agrees that he/she will not incur or attempt to incur any obligations for or on behalf of the other party and will indemnify and hold harmless the other party of and from any and all liability arising from any debt or obligation that either party has presently or will later incur in his or her name and is or will be solely obligated to pay. 9. BANK ACCOUNTS. The parties represent that there are no joint bank accounts and that any bank accounts held by the parties up to the time of the their separation have been divided by mutual agreement to their satisfaction. 10. CUSTODY. The parties acknowledge that matters of custody concerning their three children have been or will be resolved through the custody proceeding initiated by Wife in Cumberland County docketed to No. 08-1146. 11. TAX IMPLICATIONS AND MATTERS. Husband and Wife agree that Wife shall be able to claim their children as dependents for federal income tax purposes. In the event it is determined that there is any future tax liability of the parties, which liability relates to any year the parties were married and filed jointly, then in such event, the parties will contribute to the payment of such liability in proportion to their respective incomes for the year to which such liability pertains. The parties hereto agree to retain all tax returns pertaining to the years of their marriage for a period of five (5) years after the date of this Agreement. 12. CHILD SUPPORT. The parties acknowledge and agree that the matter of the support of their three (3) children has been resolved through the Cumberland County Domestic Relations Section through an action initiated by Wife docketed to No. 138 S 2007. 13. COUNSEL FEES. Each party to this Post-Nuptial Agreement shall be responsible for paying his or her own counsel fees and related costs associated with the initiation and processing of the Divorce Action and the negotiation, execution and consummation of the provisions of this Post-Nuptial Agreement. 14. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE. Each party waives and forever releases the other party of and from any and all claims which either may have against the other for spousal support and for claims which either may have against the other by reason of and pursuant to the Pennsylvania Divorce Code (and the divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, cost and expenses, except that the performance of any obligation created hereunder may be enforced by any remedies under the Pennsylvania Divorce Code. 15. DIVORCE. The parties agree to terminate their marriage by mutual consent without counseling and each agrees to execute the necessary affidavits, waivers and consents to procure a consensual divorce under the provisions of the Pennsylvania Divorce Code, such documents to be filed in the Divorce Action. 6 16. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such other party prior to the date hereof, except that this release shall in no way exonerate or discharge either party from the obligations and promises made or imposed by reason of this Agreement. 17. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post- Nuptial'Agreement shall survive any action in divorce which may be instituted or prosecuted by either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or permanent, shall affect or modify the terms of this Agreement, but said Agreement may be enforced by any remedy at law or in equity, including enforcement proceedings under the Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate order of court to be entered in the Divorce Action, but this Agreement shall not be merged into said order or decree in divorce. 18. COOPERATION. The parties agree to cooperate with each other and to make, execute, acknowledge and deliver such instruments and take such further action as may hereafter be determined to be requisite and necessary to effect the purposes and intention of this Post- Nuptial Agreement. 19. BREACH; INDEMNIFICATION. If either party hereto breaches any provision hereof, then the nonbreaching party shall have the right, at his or her election, to sue for damages for said breach, or seek such other remedies or relief as may be available to him or her, and the 7 defaulting party shall be responsible for payment of all reasonable legal fees and costs incurred by the other party in enforcing his or her rights under this Agreement. Each party agrees and covenants to indemnify and hold harmless the other party from any and all liability and/or claims and/or damages and/or expenses (including attorneys' fees and expenses of litigation) that the indemnitee may sustain or may become liable or answerable in any way whatsoever, or shall pay upon, or in the consequence of, the indemnitor's breach of any obligation, term or covenant of indemnitor under this Agreement, including, but not limited to, indemnitor's obligation to make any payment provided for herein. 20. VOLUNTARY EXECUTION. The parties declare and acknowledge that they have had the opportunity to have the provisions of this Post-Nuptial Agreement and their legal effect explained to them by independent counsel of their choosing and each party acknowledges that this Post-Nuptial Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other to the extent same has been requested by each of them. 21. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. The parties acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to the Pennsylvania Divorce Code or any amendments thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 22. WAIVER/MODIFICATION. The waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. This Agreement can only be modified in writing executed by both parties hereto. 23. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced according to the laws of the Commonwealth of Pennsylvania. 24. HEADINGS. The headings or titles of the numbered paragraphs of this Agreement have been used only for the purpose of convenience and shall not be resorted to for the purposes of interpretation or construction of the text of this Agreement. 25. EFFECTIVE DATE. This Agreement shall be dated and become effective on the date when executed by the latter of the two parties. IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals intending to legally bind themselves and their respective heirs, personal representatives and 9 assigns. WITNESSED BY: On"-, ichael L. Coy Date: -tIzlot(SEAL) CAAACJ:?t .l1 (SEAL) Audra L. Coyle Date: 10 ., MICHAEL L. COYLE Plaintiff V. AUDRA L. COYLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 5594 CIVIL ACTION IN DIVORCE CIVIL TERM LAW NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above-captioned matter, X 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 FANUS , and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. § 704. Date: '_6 - i - CJ % Signature: Audra L. Coyle Signature of name being resumed: Audra L. Fanus COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND On the day of , 2008, before me, the notary public, personally appeared the above affiant known to me or satisfactorily proven 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 hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notary P61 NOTARIAL SEAL i : iiit-folly whe , i here aia0 o (fly ta: VALERIE F. GSELL, Notary Public 'i ;d? Im sW of said COU Cat;+'. L. Pa. Carlisle Boro., Cumberland County , . iA a# ?D"0k -day M Commission Expires October 9, 2010 u+r!`' Pro Mwl ?-? ? ?, ?? --`?' c ?^> _? - i - ,-r; ?-`; C.?) "? -- - a4,? ;?.. .., ? .r L. COYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5594 CIVIL TERM L. COYLE, Defendant CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on 26, 2006. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) 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 uest entry of the decree. 4. I verify that the statements made in this Affidavit are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to falsification to authorities. : S&l'c`ri(3eA 2, 2 ov 8 LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. Ci ?:;? '? l_??.. t..?A?' `? L.e"?? ?? ?? ?, w 'A `.-Y MICHAEL L. COYLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5594 CIVIL TERM AUDRA L. COYLE, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S 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. 4. 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: SCPt2A ham. r 2ovd LAW OFFICES SNELBAKER & BRENNEMAN, P.C. CD ?? 40 , s? MICHAEL L. COYLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5594 CIVIL TERM AUDRA L. COYLE, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on 5ee-k'40 - 24 Roo(, 2 The marriage of the Plaintiff and the 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. 4. 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 `a _cf6 d - %"7'? Audra L. Coyle LAW OFFICES SNELBAKER & BRENNEMAN, P.C. lip - MICHAEL L. COYLE Plaintiff v. AUDRA L. COYLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 5594 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above-captioned matter, X 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 FANUS , and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. § 704. Date: `_6 ` It ^ 0 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND Signature: Audra L. Coyle Signature of name being resumed: Audra L. Fanus On the day of , 2008, before me, the notary public, personally appeared the above affiant known to me or satisfactorily proven 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 hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notary Putil NOTARIAL SEAL `;;r r1iM01ty WhEt t, I here U,1111D *1 my rig: VALERIE F. GSELL, Notary Public ,i:d the No of Said GIOU ? Cafti ` C, ?2• Carlisle rland Cumb Cou M Commissiof n ,Expi eseOct ber 9,2010 Y Q# -.?0O? r ? , ' ` Pro MUM ?_ ?? ???? '1 ?1 ?) ?_. . ~......u ? I . . r'"?4 C?? "3 f/, N MICHAEL L. COYLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5594 CIVIL TERM AUDRA L. COYLE, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S 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. 4. 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: 00 ' a-% -0-6 ta--i, Audra L. Coyle LAW OFFICES SNELBAKER & BRENNEMAN, P.C. MICHAEL L. COYLE Plaintiff V. AUDRA L. COYLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06 - 5594 CIVIL ACTION IN DIVORCE CIVIL TERM LAW NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above-captioned matter, X 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 FANUS , and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. § 704. Date: % ` j ^ tJ C? Signature: Audra L. Coy ye c-- 4 Signature of name being resumed: Audra L. Fanus COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND On the ( day of , 2008, before me, the notary public, personally appeared the above affiant known to me or satisfactorily proven 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 hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notary Putil NOTARIAL SEAL ? r, tittirlity iiYherwit, I dare U1110 tki (fly ht: VALERIE F. GSELL, Notary Public ? i.d the 56 1 of said Cou at ?,{i' 0. Pa. Carlisle Soto., Cumberland County M Commission Expires October 9, 2010 ..? y ot- P l?ial c z:) -71 ril PN) rt . L. COYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-5594 CIVIL TERM L. COYLE, Defendant CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of Complaint: on Defendant by certified mail, restricted on September 28, 2006 (see Acceptance of Service filed October 2, 2006 herein). 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the ivorce Code: by the Plaintiff. September 2, 2008; by the Defendant: August 28, 2008. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: 2, 2008; by the Defendant: August 28, 2008. 5. Related pending claims: None. : September 2, 2008 SNELBAKER & BRENNEMAN, P. C. By Attorneys for Plaintiff ???"l ?, .% ?.- ? W ;? .. `t ;?1? E.. ,. t ?.. C.r?j `, ?,. ,. "? s `; "'? 'j? ?'"? :?. C. ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MICHAEL L. COYLE. Plaintiff VERSUS AUDRA L. COYLE Defendant N O. 2006-5594 CIVIL DECREE IN DIVORCE AND NOW, t?/'G,.. aQOB IT IS ORDERED AND DECREED THAT MICHAEL L. COYLE , PLAI NTI FF, AND AUDRA L. COYLE, now known as AUDRA L. FANUS -,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; None. The parties;' Post-Nuptial Agreement dated September 2, 2008 is incorporated but not merged into this Decree. BY THE COURT: ATT E J . ,tw PROTHONOTARY ?4