Loading...
HomeMy WebLinkAbout06-6272 . F:\User FolderlFinn Docs\Gendocs2006\401 0-1 div.complaint. wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LA W. L-...r- No. 2006- fo~ t.:t Cl va'l 1 U~ SHA WN M. MORROW, 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 may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIllS 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 ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LAW <-..,- No. 2006- I,~ "f~ G"l u'll L ~ SHAWN M. MORROW, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 2tJI..!J day of tkl, lw(2006 comes Plaintiff, Naomi L. Morrow, by and through her attorneys, Knight & Associates, P .C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Naomi L. Morrow, who resides at 222 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Shawn M. Morrow, who resides at 1132 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on April 29, 2000 in Newville, Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. ~ 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. {j~Xff}611:J Naomi L. Morrow p ~ N -- r--3 1 ~ n c:::> 0 t- c,: e.::j II D t;J-'" --I ~. C) ::r: -n , C) n1F --\ -0 rn 8 1'> ~o 1....,..1 .......... '""'- 0'1 <~ :,~ ~;) ~ -.:( -0 -~ ..H ".~Cl ~ --,,- ,",n ~ -U N c ~) :-\ ~ F U1 ~ 1..0 :< ~ ---I: r '. F:\User Folder\Finn DocslGendocs2006\40 1 0-1 cert.service. wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LAW No. 2006-6272 SHAWN M. MORROW, Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this Z,sr day of November, 2006,1, SeanM. Shultz, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Divorce filed in the above-referenced matter. The Complaint was mailed on October 30, 2006, but actual service took place on November 16, 2006, by Defendant signing for a copy of the Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Shawn M. Morrow 1132 Newville Road Carlisle, Pennsylvania 17013 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, T & ASSOC A F:\User FolderlFum DocslGendocs2006\401 0-1 cert.service.wpd ean M. Shultz, Esquire Attorney ill No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff 4D ~ \ ~ ~ - g- o. . ~ .'iO E~GlaE . g_.c"'GI (/)... .c' ~~c:g... . ...... O"O~ CI...If). 1J. 1iI ~'E t')~~o~Q) ~GI"OGI.oo. \i:i~~GI~ .o"OE~t\l C'l "0 c: ::l 0 0. .' ",:&GS~....1Il .a (/)"OGI"''':O; \ E'C:~C:. 1iI"C - ~ -..../.) GI"'iiilil5oo :.-.e::-.;)- :e l c: GI III ~ "0 -::::> - ~ '5~~GI"Q ..;:> _\ ~ (I):O;o......c.~ 4. ~ ~ "'6...r ... ~ 0 c: ~ "-" ~ . ~il~i~ t P) ;::= . .. .;. .-. ~. t'i ~ c:::::::> \' ~- ~ 1j ">- ~~ z.=--= ~ ~ ~ - ~~~ ~ \ .. cO C3 ,.::\ ,.::\ tu C3 C3 C3 C3 J3 ~ ,.::\ U'l g \ t"- ~ '2 -'i \l- ..- -% ~ ~~ 1 \t ~ (/) ~ 0. (') '"I ....t'.". N _J r,) , ' ,--,-' -_J MARRIAGE SETTLEMENT AGREEMENT ;J-1fJ ~ ! THIS AGREEMENT, made thisL,)--- day of ( ,2007,!b and between SHAWN M. MORROW, of 1132 Newville Road, Carlisle, Pennsylv ia, (herei~ er referred to as "Husband") and NAOMI L. MORROW, of222 Walnut Bottom Road, Carlisi Pennsylvania, hereafter referred to as "Wife." . I I WITNESSETH: WHEREAS, Husband and Wife were married on April 29, 200~ Pennsylvania, and one child was born to the parties, namely Taylor Lynne Morr~ 5,2001; and ! in Newville, , born March WHEREAS, it is the intention and purpose of this Agreement to set forthl t e respective rights and duties of the parties while they continue to live apart from each other an to settle all financial and property rights between them; and each other WHEREAS, Husband and Wife have been living separate and apart it since October 20, 2006; and i WHEREAS, the parties are residents of the Commonwealth of Pennsyly been so for at least the past six (6) months; and \ WHEREAS, certain diverse, unhappy differences have arisen between th~ which have made them desirous of living separate and apart from one another; an1 I I WHEREAS, Husband and Wife desire to settle and determine certain 0 I rights and obligations, and make an equitable distribution of their marital property~! i I I WHEREAS, the parties hereto have mutually entered into agreement for~ division of their jointly owned assets, the provisions for the liabilities they owe, and pro i ions for the resolution of their mutual differences, after both have had full and amble opport . to consult with their respective attorneys, and the parties now wish to have that agreem n reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually ~ e and to be kept promises set forth herein and for other good and valuable consideration, i t nding to be legally bound and to legally bind heirs, successors, assigns, and personal repre ntatives, do hereby covenant, promise and agree as follows: I I i ! SMM 5mrr7. Page 1 of 8 ~:JSJm ------------~---l .. ARTICLE I: SEPARATION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live sep ate and apart from each other and to reside from time to time at such place or places as they s~a I deem fit free from any control, restrain, or interference, direct or indirect, by each other. Ne't er party shall molest the other or compel or endeavor to compel the other to cohabit or dwell ith him or her by any legal or other proceedings. The foregoing provision shall not be taken to ~ an admission on the part of either Husband or Wife of the lawfulness of the causes leadin~ 0 them living separate and apart. I ARTICLE II: DIVORCE 2.1 .. This Agreement is not predicated on divorce. It is specifically understood and between the parties hereto and each of the said parties does hereby warrant $1 represent to the other that the execution and delivery of this Agreement is not predicated * on nor made subject to any agreement for institution, prosecution, defense, or for the non-pros~ ution or non- defense of any action for divorce; provided, however, that nothing contained in h s Agreement shall prevent or preclude either of the parties hereto from commencing, instituting r prosecuting any action or action for divorce. Husband and Wife do each hereby warrant, cov~ t and agree that, in any possible event he and she are and ever shall be estopped from assertin~ any illegality or unenforceability as to all or any part of this Agreement. ! I 2.2 It is further specifically understood and agreed that the provision of t!i Agreement relating to the equitable distribution of property of the parties are accepted by + h party as a final settlement for all purposes whatsoever. Should either of the parties obt . n a decree, judgment or order of separation or divorce in any other state, county, or jurisdicti~ ' each of the parties to this Agreement hereby consents and agrees that this Agreement and aI' s covenants shall not be effected in any way by any such separation or divorce; and that nothi* in any such decree, judgment, order or further modification or revision thereof shall alter, am~ or vary any term of this Agreement, whether or not either or both of the parties should re , it being understood by and between the parties that this Agreement shall survive and shall t be merged into any decree, judgment or order of divorce or separation. 2.3 It is specifically agreed that a copy of this Agreement may be incorporateq y reference into any divorce judgment or decree if or whenever sought by any of the parties! ereto. It is understood by the parties that a Divorce Complaint has been filed in the Court of Cp on Pleas of Cumberland County at Docket Number 2006-6272. Such incorporation, however, shall not be regarded a merger, it being the intent of the parties to permit Agreement to sun\-i e any such I agreements. ' SMM ..:infYL Page 2 of 8 fY1fl ARTICLE III: E UITABLE DISTRIBUTION OF MARITAL PROP 3.1 The parties have attempted to divide their marital property in a manner . to the criteria set forth in Section 3502 of the Pennsylvania Domestic Relations <+ de, and taking into account the following considerations: the length of the marriage; the prior ~ . ages of the parties; the.age, health, station, amount and sources of income, vocational skills\, mployability, estate, liabilities, and need for each of the parties; the contribution of one party tp he education, training or increased earning power of the other party; the opportunity of each \p y for future acquisition of capital assets and income; the sources of income of both parties, in~l ding, but not limited to medical, retirement, insurance or other benefits; the contribution of dis i ation of each party in the acquisition, preservation, depreciation, or appreciation of marital pro rty, including the contribution of a party as a homemaker; the value of the property set apart to\ ch party; the standard ofliving of the parties established during their marriage. 3.2 The parties shall retain sole and exclusive right, title and possession 0 all personal property currently in their possession. Except as provided for herein, Husband is all make no claim whatsoever for any personal property in Wife's possession. Addition~l y, except as provided for herein, Wife shall make no claim whatsoever for any personal property in Husband's possession. Should it be necessary for either party to execute any \ ocuments to convey title to any such personal property in the other party's possession, they sh~ll do so within thirty (30) days of the execution of this Agreement or within thirty (30) days oft* request from the opposing party. 3.3 The parties agree that the real estate situate at 1132 Newville Ro d, Carlisle, Pennsylvania shall be transferred to Husband. In consideration of this, Husba d agrees to remove Wife as an Obligor on the loan to Wells Fargo on the 2006 Suzuki Forenza itled in both parties' names. Within 90 days of the signing of this Agreement, Husband shaH finance the Wells Fargo loan or pay it in full even if that means taking out an equity loan on ~ above real estate. Wife agrees to transfer to Husband all her right, title and interest in the 006 Suzuki Forenza upon the removal of Wife as an Obligor on the Wells Fargo loan. 3.4 Except as provided herein, Wife waives any right or interest she may have ~ Husband's employment benefits, including any pension benefits, retirement plan, stock opti n purchase plan, or profit sharing plan. Except as provided herein, Husband waives any right \0 interest he may have in Wife's employment benefits, including any pension benefits, retireme~ plan, stock option purchase plan, or profit sharing plan. Page 3 of 8 SMM :5<<1 <<I NLM 3.5 \ Husband and Wife agree to waive and relinquish any and all right that he! she may now have or hereafter acquire in any real or tangible personal property subsequently\a qui red by the other party. Husband and Wife specifically agree to waive and relinquish ~ right in such property that may arise as a result of the marriage relationship. I ARTICLE IV: RELEASE OF SUPPORT FOR HUSBAND AND E 4.1 I The parties herein acknowledge that by this Agreement they have resp~c ively secured and maintained a substantial and adequate fund with which to provide thems~ es sufficient resources to provide for their comfort, maintenance, and support in the station~' life in which they are accustomed. Husband and Wife do hereby waive, release and give u~ y rights they may respectively have against the other for alimony pendente lite, spou a support, or maintenance. Husband and Wife specifically waive, release and give up any rig for alimony that they may be entitled to pursuant to Chapter 37 of the Pennsylvania Do e tic Relations Code. \ I ARTICLE V: DEBTS OF THE PARTIES 5.1 Each party represents to the other that except as otherwise specifically set forth herein, there are no major outstanding obligations of the parties, that since the separatio neither party has contracted for any debts for which the other will be responsible and each p indemnifies and holds harmless the other for all obligations separately incurred or ass1e under this Agreement. i I The parties agree to indemnify and hold each other harmless from any all loss or liability in connection with said marital debts. In the event either party contracted t r or incurred any debts since the date of separation, the party who incurred said debt shall be ~ ponsible for the payment thereof regardless of the name in which the account may have been qh ged except as otherwise specifically set forth herein. Husband agrees to assume sole responsibility for the following marital debt,: i a. Husband's student loans from 1996 which were incurr~d before the marrIage; b. Credit One credit card Account No. ending in 7910 with an' pproximate balance of Three Hundred Dollars ($300.00), as of February, 2007; c. Household Bank credit card ending in 0912 with an approx' ate balance of Three Hundred Dollars ($300.00), as of February, 2007; and ' SMM ..5mq] Page 4 of 8 N~ l/JidJ , d. Until the sale of real estate and payment in full of the Wel~ Fargo loan on the 2006 Suzuki Forenza, pursuant to paragraph 3.3 above, Husband sh~l assume sole responsibility for the Wells Fargo loan on the 2006 Suzuki Forenza. Husband further agrees to indemnify and hold Wife harmless from anqi II liability in connection with same debts. Wife agrees to assume sole responsibility for the following marital debts: , ! i a. Household Bank credit card ending in 0335 with an apprd 'mate balance of One Thousand Two Hundred Dollars ($1,200.00); b. Debt to First Premiere Bank with an approximate bal~ ce of Three Hundred Dollars ($300.00); i c. Credit One credit card ending in 4021 with an approximate ~ lance of One Thousand Dollars ($1,000.00); and I i a. Husband agrees to transfer to Wife all his right, title and ~ terest in the parties' 2000 Mercury Villager presently in Wife's possession. Wife agrees to a~s e any and all responsibility for the loan on said vehicle to Triad Financial with an approximla e balance of Six Thousand Dollars ($6,000.00) and further agrees to indemnify and hold Hus~ d harmless from any and all liability or loss in connection with same. d. Judgment from car accident III 1998 with monthly pa Hundred Dollars ($100.00). 5.2 Each party relinquishes any right, title and interest he or she may have ~ motor vehicles currently in the possession of the other party. b. If necessary, within thirty (30) days of the date of exe4 ion of this document, each party shall execute the necessary documents to have said ve~i Ie property registered in the other party's name with the Pennsylvania Department of Transportft on. ARTICLE VI: CUSTODY AND SUPPORT OF CHILDREN 6.1 The Parties agree to shared legal custody of the child of the marriage, n I ely, Taylor Lynne Morrow (Taylor), born March 5, 2001. The parties agree that Wife shall ~ ve primary physical custody of Taylor. Husband shall have partial custody of Taylor every ot r weekend from Friday at 5:00 p.m. until Sunday at 7:00 p.m., only in the event that he provide~ safe home with heat, water, electricity, and adequate meals for Taylor. In the event Husb d does not provide a safe home with heat, water, electricity, and adequate meals for Taylor, ~ shall have partial custody of Taylor every other weekend after 9:00 a.m. for up to six hours on ~ turdayand sMM--5mnl Page 5 of 8 Nt ~ Sunday. Both Husband and Wife shall be responsible for the day to day deci i ns when they have custody of the child. Neither Party has the right to make a unilateral~. cision of the following major issues: Education; Medical treatment (other than emergency t eatment); and General welfare. It is agreed between the Parties that any decisions on these issu will be made . . 1 I Jomt y.: ARTICLE VII: MISCELLANEOUS PROVISIONS 7.1 The provisions of this Agreement and their legal effect have been fully x lained to the parties by their respective counselor the parties have waived their right to ha legal advice regarding the meaning and implication of this Agreement. The parties agree an onsent to the fact that Sean M. Shultz, Esquire, of Knight & Associates, P.c., represents Witl. Husband has had the opportunity to retain independent legal counsel. The parties acknowle e and accept that this Agreement is, in the circumstances, fair and equitable, that it is being ent ed into freely and voluntarily, after having received such advice and with such knowledge th t execution of this Agreement is not the result of any duress or undue influence and that it is np the result of any collusion or improper or illegal agreement or agreements. \ : 7.2 Husband and Wife do hereby mutually remise, release, quitclaim, and fo~ er discharge the other and the estate of the other, for all times to come and for all purposes whats ever, of and from any and all legal right, title and interest, or claims in or against the property b the other or against the estate of the other, of whatever nature and wheresoever situate, which \h or she now has or at any time hereafter may have against such other. . 7.3 Each party represents that they have not heretofore incurred or contracted ~ any debt or liability or obligation for which the estate of the other party may be responsible or 1 able, except as may be provided for in this Agreement. Each party agrees to indemnify and ld the other party harmless from and against any and all such debts, liabilities or obligations of!e ch of them, including those for necessities, except for the obligations arising out of thi~ Agreement. Husband and Wife each warrant, covenant, represent and agree that each will, nt and at all times hereafter, save harmless and keep the other indemnified from all debts, arges, and liabilities incurred by the other after the execution date of this Agreement, except ~ s otherwise specifically provided herein. 7.4 No waiver or modification of any of the terms of this Agreement shall be vlll d unless in writing and signed by both parties and no waiver of any breach hereof or default h~ under shall be deemed a waiver of any subsequent default of the same or similar nature. 7.5 This Agreement shall be construed in accordance with the laws of the Conun nwealth of Pennsylvania which are in effect as of the date of this Agreement. i SMM ..5rn IY) Page 6 of 8 7.6 This Agreement shall be binding and shall inure to the benefit of the p I their respective heirs, executors, administrators, successors and assigns. 7.7 This Agreement constitutes the entire understanding of the parties and! s persedes any and all prior agreements and negotiations between them. There are no renr sentations or warranties other than those expressly set forth herein. 7.8 If any term, condition, clause, section, or provIsIOn of this Agre~ ent shall be determined or declared to be void or invalid in law or otherwise, then only that ~e , condition, I clause, or provision shall be stricken from this Agreement, and in all othel espects, this Agreement shall be valid and continue in full force, effect, and operation. Like i e, the failure of any party to meet his or her obligation under anyone or more of the articl and sections herein shall in no way void or alter the remaining obligations of the parties. I 7.9 The parties warrant and represent that they have made full disclosure of al~ ssets prior to the execution of this Agreement. Each party represents and warrants that he or $h has made a full and fair disclosure to the other of all of his or her personal property interests\ f any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, ot estriction to which any property is subject. Each party further represents that he or she has ~ e a full and fair disclosure of all debts and obligations of any nature for which he or she is cmt tly liable or may become liable. Each further represents and warrants that he or she has not m~d any gifts or transfers for inadequate consideration of Marital Property without the prior conse*t of the other. Each further warrants, represents, and declares that each is and has been fully apl completely informed of and is familiar with and is cognizant of the wealth, real and/or persia al property, estate and assets, earnings and income of the other and that each has made a full I d complete disclosure to the other of his and her entire assets and liabilities and any further ep. meration or statement thereof in this Agreement is specifically waived. ' Each party acknowledges that, to the extent desired, he or she has had acces to all joint \ and separate State and Federal Tax Returns (including supporting documentation) Ifi ed by or on behalf of either or both Parties during marriage. 7.10 In the event either party to this Agreement shall breach any term, covep t or other obligation herein, the non-breaching party shall be entitled, in addition to all oth r remedies available at law or in equity, to recover from the breaching party all costs w$ h the non- breaching party may incur, including but not limited to filing fees and attomey'~ ees, in any action or proceeding to enforce the terms of this Agreement. SMM 6nfY( Page 7 of 8 7.11 This Agreement shall survive any action for divorce and decree of dtv rce and shall forever be binding and conclusive on the parties; and any independent action III1 y be brought, either at law or in equity, to enforce the terms of this Agreement by either HusbatI or Wife until it shall have been fully satisfied and performed. The consideration for this eement is the mutual benefits to be obtained by both of the parties hereto and the covenants an~ agreements of I each of the parties to the other. The adequacy of the consideration for all agt ments herein contained is stipulated, confessed, and admitted by the parties, and the parti~ intend to be legally bound hereby. 7.12 The parties both agree to cooperate with each other in obtaining a final!. marriage. It is agreed that the parties will execute and file the consents necess divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all th~ fees, including attorney's fees, of the party who is seeking the divorce. ivorce of the to obtain the osts and legal IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first above written. WITNESSED BY: Naomi L. Morrow SMM 5nrn Page 8 of 8 NL Y1/JJI n ~ C c:? ..:,:,_ ---.J, -r'l r, 0:l f"..) 0'> ._, .~ o 11 ~ in f.D C0 , (;..-) .., .....~: -J'.. --~~ ~j ~?~ r~,.) ~1J .< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWN M. MORROW, Defendant IN DIVORCE NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LAW No. 2006-6272 AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 26, 2006. I 2. The marriage of Plaintiff and Defendant is irretrievably broken and niln ty days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ofa final Decree of Divorce after service of no tic of intention to request entry of the Decree. 4. I have been advised ofthe availability of marriage counseling and und rstand that I may request that the Court require that my spouse and I participate in counseling prior 0 a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I unders~ d that false statements herein are made subject to the penalties of 18 Pa. C. S., Section 4904 relati~ to unsworn falsification to authorities. Date: J:;h(/lA/Y 23,2007 ;tmcJ7A F:\User F olderIFinn DocslGendocslGendocs2006140 1 0-1 atfconsenr wpd COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dolly M. Housel, Notary Public Middlesex Twp., Cumber1and County My Commission Expires Sept. 24, 2010 Member, Pennsvfvanl", AS$Ocialion of Notaries (") s; r-..;) (:--.;1 (::::> -...J .,., rr1 c::; N 0::> o -n :::! ~~~ .~~~; '~_._._:.2 c::S. :~rn ~ ::D -< -0 ~ ('.) 1'....) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LA W No. 2006-6272 SHAWN M. MORROW, Defendant IN DIVORCE 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 pr9P rty, 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 enter~ by the Court and that a copy of the decree will be sent to me immediately after it is filed with the! rothonotary. i I verify that the statements made in this Affidavit are true and correct. I under+t d that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relati~g to unsworn I falsification to authorities. : I I 1; Date: ZJ23JD"1 F:\User FolderlFinn Docs\Gendocs2007\4010-1 waiver. notice. wpd ~ = S -n r'i 'CP N co -;:'1 .-;,'" ~ ~ ..-\ :J:-n niE -0 r;::'\ -,.-j'1 ,.~~~~ t~~l ??1 i::::?\ 20 :.<. f'V ., r" ----------- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LAW No. 2006-6272 SHAWN M. MORROW, Defendant IN DIVORCE AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 26, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and n~n ty 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 notic of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling and und rstand that I may request that the Court require that my spouse and I participate in counseling priQr 0 a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I unders statements herein are made subject to the penalties of 18 Pa. C. S., Section 4904 relatih falsification to authorities. Date: tif(Llafy l3, 2007 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dolly M. House!. Notary Public Middlesex Twp., Cumber1and County My Commission Expires Sept. 24, 2010 Member, Pennsv!vMi~ A.,,;,:1c1fllion of Notaries o c: -.7" ....::~. r-' = ..:.? --' -n ,<"1 c;o 1') CO -n o "11 ::;1 ~:~:n 1\','- :Bt? ':i~~~ ';~,~'~ ~ ~~ ~- r:? 1',) ,----- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW No. 2006-6272 NAOMI L. MORROW, Plaintiff SHAWN M. MORROW, Defendant IN DIVORCE 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 prop rty, 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 enter9d by the Court and that a copy of the decree will be sent to me immediately after it is filed with the!1 rothonotary. I verify that the statements made in this Affidavit are true and correct. I under~ I I statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relati~ to unsworn falsification to authorities. Date: ;(~J3-07 r--.:) = = -..I ...., rr1 co "" co o ." --{ -r :~s -;-~(? ::"'~() --,- --,.- f:~~ --I :1>- :-.0 -< ~ N .. r"v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NAOMI L. MORROW, Plaintiff v. CIVIL ACTION - LA W NO. 2006-6272 SHAWN M. MORROW, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Co for entry of I , a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) the Divorce Code. 2. Date and manner of service of the Complaint: served on Defendant by nited States Certified, Return Receipt Requested, Restricted Delivery Mail on November 16,2006. 3. Date of execution of the Plaintiff's Affidavit of Consent required by S~ ion 3301 (c) ofthe Divorce Code; February 23,2007; by the Defendant; February 23, 2007. 4. Related claims pending: None. 5. Date Plaintiff's WaiverofNotice in S3301(c) Divorce was filed with the othonotary: February 28, 2007. Date Defendant's Waiver of Notice m S3301(c) Divorce was fi1 d with the Prothonotary: February 28, 2007. Date: February 27, 2007 Sean M. Shultz, Esquire Attorney J.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff F:\User Folder\Firm Docs\Gendocs2007\401 0-1 praecipe. wpd C) G --. r-.:> C? = --' ..... jll c::; N Q:) ~ .-\ :J;-t1 f11P-, .,-,.-,-tf', :~t~:: -r: ::;~, ~f:~ <r"," :0 ~ """' ::.;. ~ N :f. ff. ff. :f.:f. ff. IN THE COURT OF COMMON PLEAS ill !Il !Il OF CUMBERLAND COUNTY STATE OF '" NM:MI L. MOR'RCM, '" '" !Ii ff. !Il Plaintiff !Ii VERSUS !Il !f. !Il SHAWN M. MORRCM, !f. !Ii !f. !f. Defendant !f. !f. !f. !f. !Il !Ii !Ii !Il !Ii !Il !Il '" :f. :f. !Il AND NOW, !f. !f. !f. !f. !f. DECREED THAT PENNA. No. 2006-6272 DECREE IN DIVORCE f(I,~ ~ e:A~,''lkI' ,.. 2007 , IT IS ORDERED AND NAa.IT L. MORRCM , PLAINTIFF, !f. !f. !f. AND SHAWN M. MORRCM , DEFENDANT, !f. ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE SEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; !f. !f. !Il !Il !Il !Il !Il !Il 'me Marriage Settlement Agreement dated February 23, 2007, is incorporated !f. by reference. !f. !f. !f. !f. !f. !f. '" !Il !Il !Il By H r ,,/ ATTEST: PROTHONOTARY '" J. '" '" '" '" '" '" '" '" '" '" '" !f. '" :f. :f. '" !f. '" :f. :f. :f. !Il !Il '" '" '" '" '" '" !f. :f. '" :f. ,.-In? ~ ~ ~ {J7 ?7->: -/,'1 ~ ~ r7? (.fl- 1;-[' ~ flY 't-''fI , ... . . .. . . '" ',. . . .' "