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HomeMy WebLinkAbout02-2865 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON C. SEAL, VS. GERILYN M. SEAL, Plaintiff De~ndant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002- ~oO/=~C ClVlLTERM : : IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree 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 Cumberland County Court House, Carlisle, Pennsylvania, 17013. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys fo.r?laintiff ,, C~rol~J.-Lindsay, EsqUire 1~#~4~693 ~ 26-West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JASON C. SEAL, VS. GERILYN M. SEAL, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : · ' CIVIL ACTION - LAW : NO. 2002. ~ CIVIL TERM : : IN DIVORCE C__OMPL.AINT JASON C. SEAL, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Jason C. Seal, who currently resides at Carlisle, Cumberland County, Pennsylvania, where he has resided since June 2001. 2. The Defendant is Gerilyn M. Seal, who currently resides at Parkston, South Dakota, where she has resided since June 2001. 3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were marded on August 18, 1995, at Slidell, Louisiana. 5. That there have been no pdor actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff I quire ID # 44693 ~ ~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W, High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA VERI__FICATION I, the undersigned, hereby verify that the statements made herein 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. eal Date: 0/' ~;:~,~ Iz(~'~' SAIDIS SHUFF, FLOWER & LINDSAY ATroRb~YS*AT.LAW 26 W. High Street Carlisle, PA 0 CT 2 200 JASON C. SEAL, VS. GERILYN M. SEAL, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW :NO. 2002- 2865 ClVlL TERM : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODF 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. Gerilyn r~. Seal,-"~efendant Date: !(_~-/~-O~ SAIDIS SHUFF, FLOWER & LINDSAY AITORNE¥$.AT*LAW. 26 W. High Street Carlisle, PA JASON C. SEAL, VS. GERILYN M. SEAL, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .' : CIVIL ACTION - LAW :NO. 2002- 2865 ClVlL TERM : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on June 13, 2002. 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. ~ ~,.~Geri~"[/I Seal, Defendant Date: SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYSoAT.LAW 26 W. High Street Carlisle, PA JASON C. SEAL, VS. GERILYN M. SEAL, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW :NO. 2002- 2865 ClVlL TERM : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S33011c} OF THE DIVORCE CODF 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. Jaso~iff Date: ~ SAIDIS SHUFF, FLOWER & LINDSAY A'I'rORNEySoAT.LAW 26 W. High $1reet Carlisle, PA JASON C. SEAL, Plaintiff VS. GERILYN M. SEAL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002- 2865 CIVIL TERM : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under g 3301(c) of the Divorce Code was filed on June 13, 2002. 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. Jason ~. S~, Plaintiff Date: ~ 'Z30~'[/O ~ SAIDIS SHUFF, FLOWER & LINDSAY ATrOP.~YS.AT*LAW 26 W. High Street Carlisle, PA JASON C. SEAL, VS. GERILYN M. SEAL, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002- 2865 ClVlL TERM : : IN DIVORCE ACCEPTANCE OF SERVlCI= I accept service of the Complaint in Divorce in the above captioned matter filed on June 12, 2002. Date Genlyn ~."~'"~, Defen SAIDIS SHUFF, FLOWER & LINDSAY ATr0P,/~/YS*AT.LAW 26 W. High Street Carlisle, PA JASON C. SEAL, VS. GERILYN M. SEAL, To the Prothonotary: Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002- 2865 ClVlL TERM : · IN DIVORCE PRAEClPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of service signed by Defendant, Gerilyn M. Seal, on June 30, 2002. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff on 10-18-02; by the Defendant on 10 10-23-02. 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 Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: October 31,2002 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: October 31, 2002 arol J. Lindsay, Attorney for PI-i~fiff SAIDIS SHUFF, FLOWER & LINDSAY ATrOP,/~/S.AT*LAW 26 W. High Street Carlisle, PA PROPERTY SETTLEMENT AND SEPARATION AGREEMENT between JASON C. SEAL, of hereinafter referred to as Husband, THIS AGREEMENT made this Carlisle, dayof /~ s-7/--- 2002, Cumberland County, Pennsylvania, A N D GERILYN M. SEAL, of P. O. Box 936, Parkston, South Dakota 57366, hereinafter referred to as Wife. RECITALS: R.I: The parties hereto are husband and wife, having been joined in marriage on August 18, 1995; and R.2: 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, 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: SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEY$~AT.LAW 26 W. High Street Carlisle, PA ('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 decree in the above-captioned divorce action, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and the moving party shall move for the entry of the divorce decree at that time. Husband will pay the cost of the filing of a Divorce Complaint in the Court of Common Pleas of Cumberland County, Pennsylvania upon execution of this Agreement. Nevertheless, the parties will not finalize their divorce until June 1,2002. (3) DEBT: A. Martial Debt: Husband and Wife acknowledge and agree that there are no outstanding debts and obligations which are martial or for which the other might be liable incurred pdor to the signing of this Agreement. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on June 20, 2001, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the SAIDIS SHUFF, FLOWER & LINDSAY A'I'I'ORN~¥$*AT*LAW 26 W. High Street Carlisle, PA 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 (4) 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, and 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. (5) 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, 401K plans and the like. Husband shall retain his Invesco account. Nevertheless, Husband will pay to Wife 10% of his military pension, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA including the marital and non-marital portions of the pension, and after 30 days subsequent to the entry of a Decree in Divorce, he will cause to be forwarded to the Defense Finance and Accounting Service a Domestic Relations Order, together with other required documents, authorizing a direct payment, upon retirement, to Wife of her 10% of the pension. During the course of the marriage, the parties made certain investments in an American Express and Aim accounts. Subsequent to their separation on or about July 1, 2001, Husband continued to make payments into those accounts. The intention of the parties is that Wife receive a share of the American Express and Aim accounts as more completely set out below, as of the date of the parties' separation, and not including any post-separation contributions by Husband while permitting the parties to also share any earnings on the marital portion or loss thereon. As of the end of April, 2002, Husband had contributed, subsequent to separation, $8,100.00 ($810.00 per month) which contribution is not divisible. The parties will divide their investment account with American Express (0722 0971 1 001) and with AIM (5009495614) so that Wife receives 2/5 of the value of the combined accounts, less Husband's post-separation contribution, and Husband receives 3/5 of the marital value of the combined accounts. The American Express account is devised of mutual funds, a variable Universal Life Insurance Policy, and IRAs. The AIM account is a brokerage account. The parties acknowledge that the combined value of both accounts fluctuates day to day, but they acknowledge that on March 25, 2002, the value of both accounts totaled $78,345.00 (less $8,100.00 in SAIDIS SHUFF, FLOWER & LINDSAY ATrOP, NL~YS*AT*LAW 26 W. High Street Carlisle, PA post-separation contributions). Husband would receive his 3/5 share of the combined accounts by receiving 100% of the variable Universal Life Policy, one-half of his Individual Retirement Accounts, including his Roth account, $7,000.00 from the AIM account, and the balance of his 3/5 interest from the American Express Mutual Funds. Wife will receive her 2/5 share of the combined accounts by receiving one- half of the Individual Retirement Accounts in Husband's name, approximately $10,100.00 from the AIM account, and the balance of her 2/5 share from the American Express Mutual Funds. The parties acknowledge William R. Norton, their investment consultant, to make the division on the date on which he receives a copy of this Property Settlement and Separation Agreement in accordance with its terms, and each party will execute any and all document required by William R. Norton to make the division, understanding that their dollar share of the combined accounts increase or decrease depending on market activity on the date of the division. The parties will execute any and all documents required by AIM and American Express to give effect to the terms of this Section. (6) ALIMONY: Husband shall pay to Wife as alimony the sum of $350.00 per month commencing the month following the date upon which this Agreement is executed and continuing through June 2005 in equal amounts. The alimony shall not be modifiable and shall terminate upon the occurrence of one of the following: 1. The death of Wife SAIDIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS*AT.LAW 26 W. High Street Carlisle, PA 2. The death of Husband The parties acknowledge that they know one another's Social Security Number. Alimony payments shall be deductible from Husband's gross in come for the purpose of filing federal income tax returns and includible in Wife's gross income for the same purpose. (7) 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. Husband is represented by Carol J. Lindsay, Esquire, and Wife has been advised that he or she may be represented by counsel of choice. 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. (8) 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. (9) INCOME TAX: The parties have heretofore filed joint Federal and State SAIDIS SHUFF, FLOWER & LINDSAY ATI1)RNEYS,AT*LAW 26 W. High Street Carlisle, PA Tax returns. 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 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. (10) 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' martial 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. (11) 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 SAIDIS SHUFF, FLOWER & LINDSAY A~fORNEYS,AT.LAW' 26 W. High Street Carlisle, PA expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (12) 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. (13) 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 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 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. (14) 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; SAIDIS SHUFF, FLOWER & LINDSAY A~I'OR~OYS.AT.LAW 26 W. High Street Carlisle, PA 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 madtal 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; SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS.AT*LAW 26 W. High Street Carlisle, PA I. All dghts, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (15) 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. (16) 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. (17) 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. (18) 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. 10 SAIDIS SHUFF, FLOWER & LINDSAY ATrORI~iYS.AT.LAW 26 W. High Street Carlisle, PA (19) 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. WITNL'~~ SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEYS.AT.LAW 26W. High Street Carlisle, PA COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : ON this, the day of ,2002, before me, the undersigned officer, personally appeared JASON C. SEAL whose name subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN witness whereof, I hereunto set my hand and official seal. Notary Public STATE OF ~tod,4.c, IN~ COUNTY OF ~:~t'[:l,,ll,~O0~')-~ : : SS. .- ON this, the I ~')'rt~ day of .J~l lc,,'[-' ,2002, before me, the undersigned officer, personally appeared GERILYN M. SEAL whose name subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN witness whereof, I hereunto set my hand and official seal. 3.2 JASON C. SEAL, Plaintiff VERSUS GERILYN M. SEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STA. FE OF ,~~,, PENNA. NO. 2002 - 2865 CIVIL TERM IN DIVORCE DECREE IN DIVORCE AND NOW, , 2C~Z iT IS ORDERED AND DECREED THAT JASON C. SEAL _, PLAINTIFF, AND GERILYN M. SEAL , 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 terms of the Property Settlement and Separation Agreement dated August 18, 2002 are incorporated but not merged into this Decree in Divorce. 11/26/2002 10;13 FA~ 7177612286 La~sha,Davl$&¥ohe %000022/002 ~.~/~;~/&uu~ ±o:uu ,~,~.,& 'tJ_'l '1~1 ~Ui§ JDS&~ B~UCE ¥. Plain~f KNAUB ENTI--RPR[$E$, INC. ti/Wa UCF MACHINE[ SHOP, I::~endant IN THE CO1JET OF OoMMON pLEAS OF (3UIL~I_~p. LAND cOUNTY, PE-NN-.~YLVANIA NO. 02.2865 CIVIL TEPJV] CIVIl. Ac~ON .-. OATH Wa do solemnly swear (or affirm) t~at we will sLtpporl, =bey and defen .c1 t:he Cel3stitut~on of the Ulltted ~es a~d the Cc)ns'~utlon of this Commom~ealth and tho[ we will dtsohar[le the duties o': our ~ce w~th We, ih~ follo~n9 awaY: unde~sicfllact arbitrators, havinl~ been duly al~l~,.inted ~d .,,'warn (or affirmed), make (Naba: If c~a~ages for delay ~re awarded, thay shall be aepa~'a~ely S~tert,) We, the undersigned, h~r;by fi,nd in favor of lhe_~lel~lJ_ff in th,e amount ~f $742,00~. piu,.; costs. D.~ta of He. rig: Date of Award: November 22, 2002 . Arbitrator. di~ents. (Insert narn,~- ir applE;able.) NOTICE OF E~RY OF AWARD ~ an~rad upon ~e do.et and no~ ~e~of g~en by ~ll~e pa~es or th~,~m~