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HomeMy WebLinkAbout06-6517i~ ROSALIE THOMPSON, IN THE COURT OF COMMON PLEAS Plaintiff DAUPHIN COUNTY, PENNSYLVANIA v, CIVIL ACTION -LAW NO. (Xo _ l~s/ 7 G~ DOUGLAS THOMPSON, Defendant IN DIVORCE NOTICE TO DEFEND 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 in the Office of the Prothonotary at the Dauphin County Court House, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 SAIDIS, FLOWER & LINDhSAY SAIDIS, F7AWER Sz LINDSAY nrton~xs.,v:uw 26 West High Street Carlisle, PA Carol y"."Linds Attorney Id. 44 93 26 West High Carlisle, PA 17013 (717) 243-6222 ~i ROSALIE THOMPSON, Plaintiff v. DOUGLAS THOMPSON, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ©4~ 4S'r'7 IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Rosalie Thompson, an adult individual residing at 520 East Nelson Avenue, Alexandria, Virginia. 2. The Defendant is Douglas Thompson, an adult individual residing at 400 Chambers Street, Steelton, Dauphin County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 5, 1984 in Dauphin SAIDIS, FIAWER ~ LINDSAY nrrow~vs•xnuw 26 West High Street Carlisle, PA County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDI , FLOWN ~~~ ii Dated: ~ ~~~~ CarohJ.1:(rt8say, E'a Attorney Id. 44693 , 26 West High Stree Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 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. §4904, relating to unsworn falsifications to authorities. n ~ ~_ .. C~7d~~-~ Rosalie Thompson Date: ~~ ~ • a SAIDIS, FTAWER SZ LINDSAY ertontvexs~.-~ uw 26 West High Street Carlisle, PA y\w\\! W V l 0 `~ 4 r-, c= r_., ~ ..~ I~ , ~.*.. ,....~ -; > C'. G1 F,~,;i r ~•~ 1~ .~ ~~, ` _J ~.{ ~ f ~ ~',' _t {~ C~ .`' ' ~a- ROSALIE THOMPSON, Plaintiff v. DOUGLAS THOMPSON, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.06-6517 IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on November 14, 2006, she served a true and correct copy of the Divorce Complaint upon Defendant, by mailing those documents to the his address at 400 Chambers Street, Steelton, PA 17113-2803, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Douglas Thompson. Respectfully submitted, SAIDIS, FLOWER I SAY 1 l ~ _ _ ~' Carol J. Linds quire Attorney Id. 4 6 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS, FIAWER SZ LINDSAY aruw 2G West High Street Cazlisle, PA ~ "'' SAIDIS, N~OWER SZ LINDSAY 26 West High Street Carlisle, PA ^ Complete Rams 1, 2, and 3. Also complete ~ item 4 ff ResMcted Delivery is desired. X ~ ^ Agent ^ Print your name and address on the reverse ~~.- ~ ao that vre can return the card to you. ^ Attach this card to the bade of the mailpiece B. Received by Printed Nears) C. Date of Dell , or on the front H space permks. , u 1. Artkk~e Addressed to: . D. b dM-ererrt from item 1? ^ Yes h YE3, enter delivery address t~elow: Pp No ~~9 I ors I ho ~~j so ~ ~fo v C hare- begs ~~'~~ J~f ree rt Jfeel~~n I~~ f'7l-a'~8~o 3. Service Type CatMed Mail ^ Exproas Mall ^ Registered ~ Return Recdpt for Mert;harrdes ^ hewed AAall ^ c.o.D. a. Resatcted Delivery? t~ rree~ ~, Yes 2' Art'`"""i4°r 7DD4 1350 DDD3 7285 89D6 I~+~M Ilan arMae 1ebeQ !~ Fergs 1,.Wbnrlry 2004 Dorrreellc Rearm Rew4rt taeutiae-~tseo ~'? ,-., ~-~ ~. _. - ~-:.; ~ ~ ' r_ ~ ~ .. _ _r<1 T 1 ~ L: ~~ 1~.~' ^"~ i ~ ~ ROSALIE THOMPSON, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-6517 DOUGLAS THOMPSON, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 8, 2006. 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. 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. DATED: 7 ~/~ /v / DOUG ~S THOMP ON DEFENDANT ~ ca c~ -r~ ° ~~: ~ ~~ :. , _ ~ m~ _~~~ ~ ~ q ~ ~ _" m ` ~' ~-- ~ ~ ~-~i -~ ~ ~- ROSALIE THOMPSON, Plaintiff vs. DOUGLAS THOMPSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6517 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. DATED: ~ I2? ~O~ ~~ ~ ~~ ~ ~ DOUG S TROMPS DEFENDANT r~ r~ ~. ~ -n -; !'... ''- ~ ~ 5; ~ `~yi,~ ~ ~-`-; . ~ C 3 " t i ~5'l i f~,~ '~? ROSALIE THOMPSON, Plaintiff v. DOUGLAS THOMPSON, Defendant !N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.06-6517 IN DIVORCE AGREEMENT PURSUANT TO PA. R.C.P. 1920.2(2) The parties hereto agree the venue in the present action may be had in SAIDIS, FIAWER ~ LIlVDSAY erroxr~ts.,vuw 2G West High Street Carlisle, PA Cumberland County. y ~-o~ Date y-2~-m~ Date ~~ Rosalie Thompson Douglas hompson ra r .. ~ ` ~ ~, -r't ~~ya _ t' ~ - ~ ~' r -`~? ~' W '°~ ' _, C~ ~ ~~ i 7"1 ..~ ROSALIE THOMPSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 06-6517 DOUGLAS THOMPSON, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301 (c) of the Divorce Code was filed November 8, 2006. 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. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, 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: ,~ S-D~ Rosalie Thomps n PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DI\ DECREE UNDER>~ 3301 (cl OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, 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: Jam' ~ ~ Rosalie Thompso C7 ~ c... ca r;-4 r' ' ~ R1 f '`~=- ~' =~ L-_ c~ m - gy c,a t„~ ROSALIE THOMPSON, Plaintiff v. DOUGLAS THOMPSON, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-6517 IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this ~i~ day of jyl~ I 2007, between DOUGLAS THOMPSON, of 400 Chambers Street, Steelton, Dauphin County, Pennsylvania, hereinafter referred to as Husband, and ROSALIE THOMSPON, of 520 East Nelson Avenue, Alexandria, Virginia, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on February 5, 1984 in Dauphin County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Dauphin, Commonwealth of Pennsylvania, to Number 06-6517 Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs, and any and all claims and possible claims against the other or against their respective estates. NOW 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 and intending to be legally bound, it is agreed as follows: i (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 or 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. Upon execution of this Agreement, the parties shalt execute and file Affidavits of Consent and Waivers of Notice and Wife will finalize the divorce. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 400 Chambers Street, Steelton, Dauphin County, Pennsylvania, the marital home. Within forty-five (45) days of the date of this Agreement, Husband will refinance the marital home so that Wife is no liable thereon. Husband will present to Wife a special warranty deed which Wife shall sign and which Wife's counsel should hold in escrow pending the refinance. On the date of refinance or at the close of the rescission period, Husband will pay to wife $31,387.00. (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: i. Americhoice credit card number-4922; ii. Americhoice credit card number -0259; 2 iii. Capital One credit card number-6580. 1: Husband shall pay the obligation to Americhoice for credit card number -0259 and the Capital One for credit card number -6580 making timely monthly payments in at least the minimum amount required by the creditors, but Husband shall refinance the obligation so that Wife is no longer liable thereon within 10 days of the refinance of the marital home and payment to Wife pursuant to paragraph 3 above. 2: Wife shall pay the obligations to Americhoice for credit card number -4922, by making timely monthly payments in at least the minimum amount required by the creditor, but Wife shall refinance the obligation so that Husband is no longer liable thereon within 10 days of the refinance of the marital home and payment to Wife pursuant to paragraph 3 above. The parties each warrant that there is no marital debt for which the other might be liable other than that debt set out herein. The parties shall pay the outstanding debts as set forth herein and shall indemnify and save harmless the other from any and all claims and demands made against either of them by reason of any such debts or obligations. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation in March 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 or 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 him 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 to any and all motor vehicles currently in possession of the other party. Within ten (10) 3 days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Husband shall retain the Dodge Ram, the Chevrolet S-10 and the Kawasaki 400 motorcycle. Husband shall also retain all of his landscaping equipment. Wife will retain the Honda Rebel and the 1998 Mitsubishi Montero. Both parties agree to refinance or pay off any debt encumbering a vehicle he or she is retaining within sixty (60) days of the date of this Agreement, so that the other party is no longer liable for the obligation on a vehicle the other is retaining. (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 household personal property between them, as set out on Exhibit "A" attached hereto. They mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession 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. (7) INTANGIBLE PERSONAL PROPERTY: Each 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, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. Husband will retain the Morgan Stanley IRA. The parties have already equally divided the 4 contents of their joint bank accounts at Americhoice, M&T and Mid Penn. (8) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Wife is represented by Carol J. Lindsay, Esquire and Husband is represented by Diane Sommers Baker, Esquire. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution 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. (10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) INCOME TAX: The parties have heretofore filed joint Federal and State Income Tax returns from the date of their marriage up through tax year 2005. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty 5 and expense incurred in connection therewith. Such tax, interest, penalty or expense shall 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 the aforesaid joint returns. (12) 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 of any obligations assumed hereunder, the other party shall have the right to declare this Agreement 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 subject to court determination the same as if this Agreement had never been entered into. (13) 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 inquiry 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 Agreement is specifically waived. (14) 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. (15) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is 6 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, maintenance, alimony, alimony pendente life, 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. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever 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, personal 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 and 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; 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 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; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (17) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a 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 judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall 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 have 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. a (20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: Rosalie Thompson Doug i nompson 9 N C"'1 CJ -F'. -~ .-_ j;;;~ ...1 , r .) ,. _ „-- -; C ~ ~'rt t xJ =1 _--- ROSALIE THOMPSON, Plaintiff v. DOUGLAS THOMPSON, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant was served with the Divorce Complaint on November 14, 2006, via certified mail. Proof of service was filed with the Court on November 21, 2006. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: May 5, 2007 and filed with Prothonotary on May 8, 2007. By Defendant: April 27, 2007 and filed with Prothonotary on May 2, 2007. FLOWER Sz LINDSAY nrromvexs~.u uw 26 West High Street Carlisle, PA 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated April 27, 2007 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-6517 IN DIVORCE By Plaintiff: May 5, 2007 and filed with Prothonotary on May 8, 2007. By Defendant: April 27, 2007 and filed with Prothonotary on May 2, 2007. SAIDIS~F ER & LIN Y 1Yi,.i ~ c Carol`: Linds uire Supreme Co rt ID o. 44693 26 West High reet Carlisle, PA 17013 717-243-6222 ~ ~ _.~ C7 ~ ~ , ~ =-~ .. ~ ~ . :-;~ ? ..,~ ... t'. ~ s~ ,e ; t1 '~ i., C ~ G- '^'"' 1 N 7"H E COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROSALIE THOMPSON -y'' ~ '`~ VERSUS DOUGLAS THOMPSON No. 06-6517 DECREE IN DIVORCE AND NOW, /~'~~ -~3 X07, IT IS ORDERED AND ROSALIE THOMPSON DECREED THAT AN D PLAINTIFF, DOUGLAS THOMPSON DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement, dated Apri127, 2007, are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: ATT E .r J . PROTHONOTARY