HomeMy WebLinkAbout06-6002Alan D. Flick, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
Laura L. Flick, : NO. Z -k601, CIVIL TERM
Defendant : IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
will proceed without you and a decree of divorce or annulment may be entered against you for
any claim or relief requested in these papers by the Plaintiff. You may lose money or property or
other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County,
Pennsylvania, 17013.
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. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
Phone: (717) 249-3166 or (800) 990-9108
Alan D. Flick,
V.
Laura L. Flick,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 06' G do CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
1. Plaintiff is Alan D. Flick, an adult individual currently residing at 915 Willcliff Drive
Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Laura L. Flick, an adult individual currently residing at 915 Willcliff
Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on September 8, 1973 in Cook County, Illinois.
5. There have been no other prior actions for divorce or annulment between the parties.
6. Neither the Plaintiff nor the Defendant are members of the United States Armed
Forces or its Allies.
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling. Knowing this, Plaintiff does
not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90)
days from the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301 (c) of the Domestic Relations Code.
Respectfully submitted,
,?A tl? b, A A K 4a B, V1,Q ry\ I A? r.
Hannah Herman-Snyder t
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
s
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
DATE:-10/6/10?1 A ?- V"
Alan D. Flick, Pla' f
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ALAN D. FLICK,
Plaintiff
V.
LAURA L. FLICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 06 - 6002 CIVIL TERM
IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
To: Prothonotary
Please enter my appearance as attorney for Laura L. Flick, Defendant, in the above captioned
matter.
SAIDIS, FLOWER & LINDSAY
SAIDIS,
FILOWER &z
LINDSAY
ATIMMIMAT-MW
26 West High Street
Carlisle, PA
Dated: March 11, 2008
Ma ou' atas, Esquire
Attorney l . 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Defendant
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ALAN D. FLICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION - LAW
LAURA L. FLICK, : NO. 06-6002 CIVIL TERM
Defendant : IN DIVORCE
ACCEPTANCE OF SERVICE
I, Marylou Matas, Esquire acknowledge that on Olqkhe' / 74, &-6'? I received a
Complaint in Divorce in the above captioned action and acknowledge that I am authorized to do
so on behalf of the Defendant, Laura L. Flick.
Date: 51 / 31.2-00q
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Mar'l s, Esquire
Attorney efendant
Saidis, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
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ALAN D. FLICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -LAW
LAURA L. FLICK, NO. 06-6002 CIVIL TERM
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER 43301(c) OF THE DIVORCE CODE
I . I consent to the entry of a final decree in 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 THE FOREGOING 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.
(_._ 4/,,
DATE: 5 - ?a - 09 _
ALAN D. FLICK, Plaintiff
34 T
27
Ct;,w-
ALAN D. FLICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -LAW
LAURA L. FLICK, NO. 06-6002 CIVIL TERM
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
October 13, 2006, and service was made on October 17, 2006, as indicated by the
Acceptance of Service.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree of Divorce after service of notice of
intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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.
V"?
DATE: ?` I?,?--
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ALAN D. FL K, aintiff
7?jpy
ALAN D. FLICK,
Plaintiff
VS.
LAURA L. FLICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 06-6002 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 §3301(c)
330!(d)(1) of the Diveree Cede.
(Strike out inapplicable section).
2. Date and manner of service of the Complaint: by Acceptance of Service on October 17,
2006.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce
Code: by Plaintiff. 05/22/09 by Defendant: 05/14/09
(b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: May 27, 2009
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: May 26, 2009
Hannah Herman-Snyder, Esqui
GRIFFIE & ASSOCIATES
Attorney for Plaintiff
Tt??l
2CO9i°a 1C: 2
ALAN W. FLICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - DIVORCE
NO. 06 - 6002 CIVIL TERM
LAURA L. FLICK,
Defendant IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed October
13, 200 .
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
I consent to the entry of a final Decree in Divorce after service of notice of
intention to request entry of the Decree.
verify that the statements made in this Affidavit are true and correct to the best of my
information and belief. 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: QQ 9
LAURA L. FLICK
DECREE UNDERS 3301 (c) OF THE DIVORCE CODE
I consent to the entry of a final Decree of Divorce without notice.
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 understand that I will not be divorced until a Divorce Decree is entered by the
Court arid that a copy of the Decree will be sent to me immediately after it is filed with the
verify that the statements made in this Affidavit are true and correct to the best of my
, information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
I - / Z,
Date: zv- 9
Z?ku?i#AFLICK
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2009 MAY 26 1
CUMI a.
.1
ALAN D. ;LICK, IN THE COURT OF COMMON PLEAS OF
PI intiff CUMBERLAND COUNTY, PENNSYLVANIA
I
V. CIVIL ACTION - DIVORCE
NO. 06 - 6002 CIVIL TERM
LAURA L. FLICK,
De endant IN DIVORCE
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this ova n day of , 2009, between
ALAN D. LICK, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as
Husband, and LAURA L. FLICK, of Mechanicsburg, Cumberland County, Pennsylvania,
referred to as Wife.
RECITALS:
R.1: The parties hereto are husband and wife, having been joined in marriage on
ibe 8, 1973, in Cook County, Illinois, and
A Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County Commonwealth of Pennsylvania, to Number 2006-6002 Civil Term; and
R.3 The parties hereto desire to settle fully and finally their respective financial and
property ri hts and obligations including, but not limited, of all matters between them relating to
the owner, hip of real and personal property, claims for spousal support, alimony, alimony
pendente 1' e.
R4: The parties also desire to settle their issues of counsel fees and costs, and the
settling of any and all claims and possible claims against the other or against their respective
estates.
THEREFORE, in consideration of the covenants and promises hereinafter to be
mutually kept and performed by each party, as well as for other good and valuable consideration
i
and intending to be legally bound, it is agreed as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place or places as he or she from time to time
may choose or deem fit, free from any control, restraint or interference from the other. Neither
party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by
any legal r other proceeding. Each party shall be free of the interference, authority or contact by
the other as if he or she was single and unmarried except as maybe necessary to carry out the
terms of this agreement.
(2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and
that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce
action. Up n the execution of this agreement, the parties shall execute and file an Affidavit of
Consent a rd Waiver of Notice Forms, necessary to finalize said divorce.
If either party fails or refuses to execute and file the foregoing documents or if
Husband f ils to makes the monetary payment to Wife aforesaid, said failure or refusal shall be
considered a material breach of this Agreement and shall entitle the other party at his or her
option to terminate this Agreement.
(3) REAL PROPERTY: The parties are the owners of certain real estate with
improvements thereon erected and known and numbered as 915 Willcliff Drive, Cumberland
County, Mechanicsburg, Pennsylvania. Husband agrees on the date of execution of this
Agreement, he shall convey the real estate with improvements thereon to Wife by special
warranty deed. Said deed shall be recorded by Husband's attorney on the date of execution of
this Agreement, with the recorded deed fumished to Wife within five (5) business days. Husband
shall pay all fees associated with the preparation of and recording of the deed.
Thee was a home equity line of credit encumbering the property due and owing to
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Members irst Credit Union, with an approximate current balance of $33,450. Husband has paid
the total b lance in full of that line of credit on or before the date of execution of this Agreement,
so that th obligation was satisfied. Husband or the bank shall provide proof to Wife of the
satisfied :bligation. Wife shall assume the property in her name free of any liens or
Hu band shall pay the all 2009 real estate taxes, which shall include county/township and
school tax bills for the property, upon presentation to him of these bills from Wife. Wife shall
provide these bills to Husband within the first discount period so that Husband has the opportunity
to make payment immediately, but in no event shall Husband pay the bills any later than
December 31, 2009. Husband shall provide proof of payment of each bill to Wife. Wife shall
claim the ortgage interest and real estate taxes and a deduction on 2009 taxes. For the tax
years 20110 and forward, Wife shall be responsible for paying all tax bills associated with the
property a d shall claim the bill on her tax return.
From the date of execution of this Agreement forward, with the exception of the 2009
property to es, Wife shall pay for all household expenses including, but not limited to, utility bills,
insurance and fees in connection with said property. With regard to all such expenses, Wife
hereby sha I hold Husband harmless and indemnify Husband from any loss thereon.
(4) DEBT:
A. Marital Debt: Husband and Wife acknowledge and agree that there are no
outstanding debts and obligations which are marital or for which the other might be liable incurred
prior to the signing of this Agreement. In the event an outstanding debt is discovered which was
incurred during the marriage and has not been paid or satisfied, the parties shall immediately
close the account and the person listed on the account shall be responsible for the debt.
B: Post Separation Debt: In the event that either party contracted or incurred any
3
debt since the date of separation on October 13, 2006, the party who incurred said debt shall be
responsible for the payment thereof regardless of the name in which the debt may have been
incurred.
C: Future Debt: From the date of this agreement neither party shall contract or incur
any debt o liability for which the other party or his or her property or estate might be responsible
and shall indemnify and save the other party harmless from any and all claims or demands made
against hirr. or her by reason of debts or obligations incurred by the other party.
(5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she
may have any and all motor vehicles currently in possession of the other party. Within five (5)
of the date of this agreement each party shall execute any documents necessary to have said
vehicles p perly registered in the other party's name with the Pennsylvania Department of
Transporta ion. The party receiving title shall be responsible for the transfer of ownership, if
necessary. Wife shall retain possession of the 2004 Honda. This vehicle was encumbered with a
loan, with an approximate balance due at the time of execution of this Agreement of $2,600.00.
Husband has paid this loan in full on or before the date of execution of this Agreement. If he has
not already done so, Husband shall provide proof of satisfaction of this loan to Wife at the time of
execution o this Agreement. Husband shall retain possession of the 2003 Ford Taurus.
(6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they
have effected a satisfactory division of the furniture, household furnishings, appliances, tools and
other hous hold personal property between them, and they mutually agree that each party shall
from and a er the date hereof be the sole and separate owner of all such property presently in his
or her poss ssion whether said property was heretofore owned jointly or individually by the parties
hereto. This agreement shall have the effect of an assignment or bill of sale from each party to
the other for such property as may be in the individual possession of each of the parties hereto.
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PENSION AND RETIREMENT INTERESTS: Husband hereby waives,
relinquish s and transfers any and all of his right, title and interest he has or may have in Wife's
401(k), pension or retirement account, as well as other accounts that Wife may have in her
individual name or may have secured through her present or prior employment. This
specificall includes all retirement benefits Wife owns or has an interest in through her savings
with an In ividual Retirement Account (IRA). Wife maintains that she does not own or have an
interest in ny other retirement, pension, investment account or the like through any employer.
Husband owns or has an interest in an account with American Funds, with an approximate
current balance of $47,995.00. Wife hereby waives, relinquishes and transfers any and all of
her right, ti le and interest she has or may have in this account.
Hu band owns or has an interest in an account with Fidelity account, with an approximate
current bal nce of $27,190.00. Wife hereby waives, relinquishes and transfers any and all of
her right, ti le and interest she has or may have in this account.
owns or has an interest in an account with Wells Fargo account, with an
current balance of $2,000.00. Wife hereby waives, relinquishes and transfers any
and all of her right, title and interest she has or may have in this account.
Hu band owns or has an interest in an account with Transport Corp account, with an
approximat current balance of $12,923.00. Wife hereby waives, relinquishes and transfers any
and all of h r right, title and interest she has or may have in this account.
Eac party hereby relinquishes any right, title or interest he or she may have in or to any
intangible personal property currently titled in the name of or in the possession of the other party,
including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement
accounts, a ployment benefits including retirement accounts, savings plans, pension plans, stock
plans, 401 plans and the like.
(8) BANK ACCOUNTS: For the mutual promises and covenants contained in this
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and the a ecution of this agreement is not the result of any duress or undue influence, and that it
is not the result of any improper or illegal agreement or agreements. Each party shall pay his or
her own attorney for all legal services rendered or to be rendered on his or her behalf.
agrees to pay $500 towards Wife's legal fees.
(1 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
instrument that may be reasonably required to give full force and effect to the provisions of this
Agreement.
(13) INCOME TAX:
A: The parties have heretofore filed joint Federal and State Tax returns. Both
parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or
assessme t of any such tax is made against either of them, each will indemnify and hold harmless
the other fr m and against any loss or liability for any such tax deficiency or assessment and any
interest, Penalty and expense incurred in connection therewith. Such tax, interest, penalty or
expenses all be paid solely and entirely by the individual who is finally determined to be the
cause of the misrepresentations or failures to disclose the nature and extent of his or her separate
income on he aforesaid joint returns.
B: The parties shall file individual returns for the 2008 tax year and all
years. Husband shall pay $418.00 to Wife upon execution of this Agreement for her
2008 tax return.
(14) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement
shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations
contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a
discharge o any obligations assumed hereunder, the other party shall have the right to declare
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this Agree ent to be null and void and to terminate this Agreement in which event the division of
the parties' marital assets and all other rights determined by this Agreement including alimony
shall be s bject to court determination the same as if this Agreement had never been entered
into.
(15 COMPLETE DISCLOSURE: The parties do hereby warrant, represent,
acknowledge and agree that each is fully and completely informed of, and is familiar with, the
wealth, real and personal property, estate and assets, earnings and income of the other and has
made any nquiry he or she desires into the income or estate of the other and received any such
information requested. Each has made a full and complete disclosure to the other of his and her
entire assets, liabilities, income and expenses and any further enumeration or statement thereof in
this Agree ent is specifically waived.
(16 RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of
them has read and understand his and her rights and responsibilities under this Agreement and
that they have executed this Agreement under no compulsion to do so but as a voluntary act.
(17) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby
releases th other from any and all claims, or demands up to the date of execution hereof. It is
further specifically understood and agreed by and between the parties hereto that each party
accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all
of said party's rights against the other for past, present and future claims on account of support,
maintenan , alimony, alimony pendente lite, counsel fees, costs and expenses, equitable
distribution of marital property and any other claims of the party, including all claims which have
been raised or may be raised in an action for divorce.
(18) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in
this Agreem nt, Husband and Wife, for themselves, their heirs, representatives and assigns, each
8
I
hereby fo ver releases, remises, discharges and quitclaims the other, and such other's heirs,
representatives, assigns and estate, from and with respect to the following:
A. All liability, claims, causes of action, damages, costs, contributions and
expenses or demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other, whether
real, perso al or mixed and whether now owned or hereafter acquired;
C. All rights of courtesy and dower and all claims or rights in the nature of
courtesy arid dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance;
and
(4) all other rights or authority to participate or intervene in a deceased
spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country,
territory, state or political subdivision.
F. All rights or claims to any accounting; the parties shall not waive any right,
title or interest they may have earned or be entitled to claim pursuant to any state or federal law
statue including, but not limited to, Social Security benefits of the other.
G. All rights, claims, demands, liabilities and obligations arising out of or in
connection with the marital relationship or the joint ownership of property, whether real, personal
or mixed;
H. All rights, claims, demands, liabilities and obligations arising under the
9
provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time,
and under the provisions of any similar statute enacted by any other country, state, territory or
political subdivision;
1. All rights, claims, demands, liabilities and obligations each party now has, or
may hereafter have, against or with respect to the other.
(19 GOVERNING LAW: This Agreement shall be construed under the law of the
nw alth of Pennsylvania. If any provision of this Agreement is determined to be invalid or
'ce ble, all other provisions shall continue in full force and effect.
(20 INCORPORATION INTO DECREE: In the event that either of the parties shall
recover final judgment or decree of absolute divorce against the other in a court of competent
jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance
but shall not be merged into such judgment or decree and this Agreement shall survive any such
final judgm nt or decree of absolute divorce and shall be entirely independent thereof.
(21) BREACH: In the event that either party breaches any provision of this Agreement,
he or she s all be responsible for any and all costs incurred to enforce the Agreement, including,
but not limited to, court cost and counsel fees of the other party. In the event of breach, the other
party shall ave the right, at his or her election; to sue for damages for such breach or to seek
such other and additional remedies as may be available to him or her.
(22) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions, representations, or agreements, oral
or written, o any nature whatsoever, other than those herein contained.
(23) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind
the parties hereto, their respective heirs, executors and assigns.
10
S
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
d
On this, " day of 2009, before me, the undersigned
officer, personally appeared Alan D. Nick, known to me (or satisfactory proven) to be the
person whose name is subscribed to the within Agreement and acknowledged that he executed
the same or the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NO?IIL AAt ? /
Raft Notary Pu '
TH OF PENNSYLVANIA
C??b? c ?.•?
COUNTY OF
On this [44-'?'\ day of I'll- 2009, before me, the undersigned
officer, personally appeared Laura Flick, known to me (or satisfactory proven) to be the
person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
12
EL' ".r
_
OF
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Alan D. Flick
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Laura L. Flick NO 2006-6002
DIVORCE DECREE
AND NOW, 7,jn C Z I Ibbq , it is ordered and decreed that
Alan D. Flick plaintiff, and
Laura L. Flick , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None. The parties' Property and Separation Agreement entered into May 22,12009 is
incorporated herein, but not merged.
By the Court,
Attest: J.
Prothonotary
!a •:3.09 L?iUf • C? Mxa,aad t 4 y„ - ?.d?i
6. 3 - eF ?" Z? 4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION—LAW
•
Ploo D FLrci� :
Plaintiff . /
: FILE NO.00C,��p—(0 co A 0 ;
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VS. IN DIVORCE o
•
1._puep aiCL a° a�'
Defendant •
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NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the above matter, having
been granted a Final Decree in Divorce on the at,d day of b h e_
hereby elects to resume the prior surname of 1_hU�A L T e 2 P A eA ,
and gives this written notice pursuant to the provisions of 54 P.S. 704.
DATE: / 2D?J,e /02� 08 _ /...Li. .
Signature
Signature of name being resumed
COMMONWEALTH OF PENNSYLVANIA .
: SS.
COUNTY OF CUMBERLAND
On the /<, day of , 20 73 , before me, a
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 and official seal.
Notary'Public +
I- "C t4. ti~A(
Prothonotary,Cumberland County,Carlisle,PA
w Commission Expires the First Mondayot)an.2014