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HomeMy WebLinkAbout94-00276 , J ~ \.. U N 1 E. .Ii 7 L ; s E- CYNTHIA A. MENTZER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DALLAS L. MENTZER, JR., DEFENDANT 94-0276 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of April, 1995, a Rule Is issued against Dallas L. Mentzer, Jr., to show cause why he shall not be adjudicated in contempt pursuant to the within petition of Cynthia A. Mentzer. The Rule Is returnable at a hearing to be held In Courtroom No.2 of the Cumberland County Courthouse at 10:30 a.m., Tuesday, April 25, 1995. Jeff Foreman, Esquire For Plaintiff Kent H. Paterson, Esquire For Defendant .- ~*.:.v... ~~~'~<l Lf/'o/".s- ...&. (-', :saa ..j;.,,..-"'..,..,.......l'\,,'" ~PR 10 \Ill M\ '9S ; r t;: ~" \)~_:~,. j.]~i':..i..h" r,\Jr'iV: . '" ~,:"( \ . ~ ~; ~i " ',' i ~" .~ " U 1995 .~ CYNTHIA A. MENTZER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 276 CIVIL 1994 DALLAS L. MENTZER, .JR., Defendant : CIVIL ACTION - LAW : IN DIVORCE ORDER AND NOW, Ihis day of . 1995. upon considemtion of the Petition of CYNTHIA A. MENTZER for CONTEMPT. Respondent DALLAS L. MENTZER, .JR.. is hereby ORDERED to pa)' reasonable attorney fces in the amount of Seven Hundred Fifty and 00/100 ($750.00) Dollars and execute all necessary documents 10 tmnsfer ownership of a 1989 Eagle Medallion automobile subject to this Courts Order of June 14. 1994. or show cause why the same should nlJt be done, Rule returnable day from service oflhe samc upon Respondent, BY THE COURT: J. '. . . . , . . '. . . ." CYNTHIA A. MENTZEl{, l'lalntiff : IN TIlE COUI{T OF COMMON PLEAS : CUMIJEI{LANIl COUNTY, PENNSYLVANIA v. : NO. 276 CIVIL 1994 I)ALLAS L. MENTZEI~. .II~., I)cfcndant : CIVIL ACTION - LAW : IN I>IVOI{CE PETITION FOI~ CONTEMPT Petitioner CYNTHIA A. MENTZEl{, by her attorneys. NICHOLAS ANI) FOI{EMAN. hereby moves this Ilonorable Court to enter an OI{I)EI{ OF CONTEMPT against Respondent. I)ALLAS L. MENTZEI~, .m., because of his violation of this Court's Order of June 14. ] 994. In support thereof. Petitioner avers as follows: I. The Petitioner in the above-captioned matter is CYNTHIA A. MENTZEl{ 01'4749 Brian Road. Meehanicsburg. Cumberland County. Pennsylvania. 2. The Respondent is I)ALLAS L. MENTZEI{, ,m., of 7073 Carlisle Pike. Lot 42. New Kingston. Cumberland County. Pennsylvania. 3. Petitioner and Respondent were murried on October 3. 1987. in Shiremunstown. Pennsylvania. 4. Petitioner filed un Action for Divorce before the Court of Common Pleas of Cumberland County on January 24. 1994. 5. A Decree in Divorce was granted to CYNTHIA A. MENTZER and DALLAS I.. MENTZER. JR.. on June 14. ]994. and the Decree in Divorce incorporated the Separation and Property Settlement Agreement executed by the Petitioner and Respondent on May II. ] 994. A tnte and correct copy of the Decree in Divoree is attaehed hereto. labeled Exhibit "A" and made a part hereol: A true and correct copy of . . , . . the Separation and Property SeUlement Agreement. as incorporated in the Decree in Divorce, is aUached hereto. labeled Exhibit "B" and made a part hcreof.. 6. The Separation and Property ScUlement Agrcement entered into by the Petitioner and Respondent and dated May I]. 1994. which was incorporated in the Decree in Divorce, requires at Section 4 on Page 2 thllt the 1989 Engle Medallion automobile, which WIIS a maritlll IIsset of the Petitioner IInd the Respondent in their marrillge, be the sole property of the Petitioner, and thc Pctitioner and Respondent turthcr agreed in the Sepllrntion and Property SeUlement Agreement that was incorporated into the Deeree in Divorce at Section 19 on Pages 7 and 8 that they would execute such documcnts liS may be nccessllry and expedient to carry out and fully implemcntthe tenns of the Separation IInd Property ScUlement Agreement. 7. Petitioner has fully complied with the Separation and Property SeUlement Agreemcnt, IInd has properly executed all documents necessary and expedient to carry out IInd tully implement the tenns of the Agreement. 8. Contrary to the express terms of the Separation lInd Property Seulement incorporated into this Honorable Court's Order of June 14. 1994, Respondent has failed IInd refused to execute a transfer in registnllion of the 1989 Eagle Medallion automobile previously referenced despite repeated requests by Petitioner to do so. 9. Respondent's repeated failure to execute documents to tnmsfer title to the 1989 Eagle Medallion lIutomobile as is required in the Sepllration IInd Property Seulement Agrccment is a willlulllnd deliberatc viollltion of the Ordcr of this Ilonorable Court of June 14. ] 994. Petitioner believcs. on the bllsis of Respondent's repeated reluslll to execute transfer documents for the 1989 Eagle Medallion automobile in viollltion of the Order of this Ilonornblc Court that Respondent intends to continue to refuse to execute such documents and that Respondents violmions are will ful. deliberate, and withoUl just cause or legal excuse. .. . . .' .' 10. Petitioner has incurred reasonable allorneys' Ices IInd Court costs in the amount of Seven Hundred Filly and 00/100 ($750.00) Dollars to date in allempting to enlorce the said Agreement Order of June 14, 1994 IInd these costs lire the responsibility of Respondent set torth in pamgmph _ orthe sllid Agreement. WHEI{EFORE, Petitioner, CYNTIUA A. MENTZER, request that Respondent DALLAS L, MENTZER, ,m.. he held in Civil Contempt for viollltion of the Order of this Honorable Court of June 14, 1994. IInd he Ordered to immediately execute any and all documents necessary to tmnsfer ownership of the 1989 Eagle Medallion automobile that was the subject maller orthe Separation and Property Selllement Agreement between the I'etitioner and Respondent. which Agreement was incorporated in the Decree in Divorce issued by this Honorable Court on June 14. 1994. and further that this Honomble Court award Petitioner all reasonable counsel Ices and costs incurred by Petitioner in enforcing the Court's Order of June 14. 1994. Respectfully submilled. NICHOLAS AND FOREMAN Dated: .1 /30/9 r , , By: JEE. MAN. Esquire 32 North Front Street Harrisburg, Pennsylvania 17110 (717) 236-9391 Sapreme Court ID # 72657 Allomeys for PlaintilT .' Exhibit A ". .' r:, '';J ,d '.' t' ~ .. ,. . . , ' -----~-------------~~---------~ j. . ., I~"'~ ~ ij - ~ IN THE COURT OF COMMON PLEAS I e 8 ~ OF CUMBERLAND COUNTY ~ ~ * - ~ STATE OF ...,.; . PENNA. i ~ ,\ . ~ ~ . ~ ~ M """Cynthi.a,A."~tzer,,,,,,,,,,,...,,,,,,,,,.,,,,,,.,.,,..,, I 6 3 ~ .".""""..I?~.~~~~"."P""""'''''''''''''''''''''''''''' I N o. .~?"................. .~Y:!-.L. 1994 ~ Ii! Versus I .. ~ ~ ~ ,,,,,.Dallas.,L.,,~tzer,Jr...,,,,,.,,.,,,,,,,,,,,,,,,,,,,. I ~ ~ ~ ~ "". Defendant."."".",,,.,,,,,,,. ;,: ~ ~ ~ t $ ~ . ~ ~ DECREE IN ~ ~ DIVORCE ~ :~ ~ ~ ~ M ?, ~ ~ ?, ~ ~ ..' AND NOW, .. .... ..J.l\I1E: .lA,... .... ... .. " 1994..... It is ordered and decreed that . .GY.r!~~~'~" .~t;~~J;'.....................,......., plaintiff, and .Dallas.L. .~tzer.. Jr........... ........................, defendant, are divorced from the bonds of matrimony. ~ Ii! ,.' 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 .. 'A1~.~~!lj:j..9!l.~. P1=PP!'!F.tY. ~.t.UestM~ J\~n1; .c1qtecl.~Y .11, .1994, .is.. , ..inoorporated.intothi&~....... ..................................... ~ w ~. Dy The Court: ,./6/",oog<l1,"" 13.,.l3,:iy:).!,!'y' Alleat: . . ..... . ......... ".". ....- J. M ij ~ t01.' ,,,,,,,~~,,pK~1; Prothonotary " " ~--: ~ ~ ;;; ~ ~ ~.~ i!i a , ,'~ i!i ,;, ~ ~ .'~ ~ i '.' .', ~ .', ~ v '.' w " ~ ~. ,', i!i n:In'TFJ13Q C02Y. ISSUED JUNE ~4, :1,994 I ~ ._~~___~e_~~~~'~~~.~,~-~~~. Exhibit B ..., lIUI 'I'''. II"",:VO '...' III i"'~ "'" "''''110 @ , . .' . . " I' '. CYNTHIA A. MENTZER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 276 CIVIL 1994 DALLAS L. MENTZER, JR. Defendant IN DIVORCE SEPARATION AND PROPERTY SETTLEMENT AGREEMENT (., ~ ~- , '" .:... N r:;, "-' c ~. ~.. ~" ::.l;:; -';;":"' -< - <.D ..c.. Respectfully submitted, NICHOLAS & FOREMAN By --7--r1' ~A----f/ e>? fi? '/H-"-_ MICHAEL L. ROZMAN.I ESQUIRE 3207 North Front Street Harrisburg, PA 17110 (717) 236-9391 Attorneys for Plaintiff ".*- -...-, " ", AGREEMENT AGREEMgNT made this /Ie 1994, by to as Wife) and between CYNTHIA A. day of ~ MENTZER (hereinafter referred and DALLAS L. MENTZER, JR. (hereinafter referred to as Husband). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 3, 1987; and WHEREAS, differences have arisen between Husband and Wife which have caused them to live separate and apart; and WHEREAS, there is a divorce action pending between the parties in the Court of Common Pleas of Cumberland County, Docketed at No. 276 Civil 1994; and WHEREAS, the parties have reached a resolution conce,t"ning distribution of marital property and other issues. NOW THEREFORE, each party intending to be legally bound hereby does agree as follows: 1. It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they respectfully deem fit, free of any control, restraint or interference, direct or indirect, by each other. Neither party shall molest the other or compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of causes to their living apart. .., . . . . .' .. 2. The parties acknowledge that they have divided between themselves the household goods and furnishings in a manner satisfactory to both of them. The household goods and furnishings now in the possession of each party shall remain the sole' and individual property of that party. 3. Husband and Wife shall continue to own and enjoy, free from any claim or right of the other, all of his or her personal effects, such as clothing, jewelry, books, athletic equipment and the like, wherever located. 4. The 1989 Eagle Medallion automobile shall be the sole property of Wife, and Husband shall transfer all his right, title and interest in said automobile to Wife. Wife shall assume payment of the loan to Mellon Bank on account of purchase of thft autom9bile and Wife shall indemnify and hold harmless Husband from all liability for payment of said loan, including said reasonable attorney's fees and costs. 5. The Astro mobile home jointly owned by the parties and currently situated at Leiby's Mobile Home Park shall be placed for sale and shall be sold for any reasonable price. The following distribution shall be made from the proceeds of the sale: A. All normal settlement costs including sales commissions. B. Payoff of the purchase money loan to Security Pacific Finance Company. -2- " ,,' .. ", " c. Any credits or monies owing to either party. D. The balance thereafter shall be paid to Husband. The parties have already listed the mobile home for sale with Leiby's Mobile Home Sales, and they shall continue to keep' the property for sale with a reputable sales agency. The parties shall cooperate in conducting settlement and delivering possession of the property to a buyer. In the event there are insufficient funds from the sale of the property to pay the purchase money loan to Security Pacific, then the parties shall contribute, in equal shares, sufficient monies to cover any such deficiency so that the loan can be paid in full and title to the mobile home released to the buyer. 6. Wife shall have the right to exclusively reside at the mobile home until such time as there has been settlement on the sale of the mobile home. In such event, the Wife shall make the loan payment to Security Pacific and the lot rent payment to Leiby's Mobile Home Park for each month or part of the month that she resides in the property. Wife has been residing in the mobile home since the parties separated in January 1994 and shall be responsible for making the aforesaid payments since that time. If wife should vacate the mobile home, then the parties shall each pay one half of the monthly loan payment and lot rent until settlement on the sale of the property. 7. In the event Wife should vacate the mobile home, then -3- '.. , , . ' , , ,. ". I '" " Husband shall have the right (but he shall not be obligated) to exclusively reside in the property. In such event, Husband shall make the Security Pacific loan payment and the lot rent payment for each month or part of the month in which he resides in' the property. If Husband should thereafter vacate the mobile home, then the part~.es shall each pay one half of the monthly loan payment and lot rent until settlement on the sale of the property. 8. Any outstanding real estate taxes for the year 1993 shall be paid equally by Husband and Wife. Any real estate taxes owing on the mobile home beginning with the year 1994 shall be paid equally by Husband and Wife~ provided, however, that the party exclusively residing in the mobile home shall be responsible for payment of all real estate taxes on a pro rata basis for all months or portions of a month that he or she resides in the mobile home. If it is unknown at the time the taxes are due and owing how long either party will reside in the mobile home during the taxable year, then each party shall pay his or her portion of the taxes owing until the date of paYment and shall reimburse the other party at the end of the taxing authority's fiscal year or at the time of settlement on the sale of the mobile home, whichever is earlier. 9. Each party shall retain as his or her sole and individual property any retirement or pension plan or 401K plan at his or her place of employment. -4- ;',fIl'"'.""'''''' !:-:;..,.~;'C..Li:.. >.. ". '., ,I' ..' .. 'l'.. " 10. Each party releases the other party from any claim for alimony or alimony pendente lite. 11. Each party shall assume payment of the charge account that had been issued in their sole names. Wife shall assume payment of the Visa, Master Card, Gordon Jewelers, and Fashion Bug accounts that were issued in her name. Husband shall Assume payment of the Visa account that was issued in his name. Each party shall indemnify and hold harmless the other party from any liability for payment of said charge accounts that have been incurred by each party, including reasonable attorney's fees and costs. 12. Except as otherwise provided herein, Wife hereby warrants and represents that she has not heretofore incurred any deht or obligation for which Husband now or in the future is or may become liable. With respect to any such obligation incurred by Wife, whether solely in her name or jointly, she agrees to pay same and to indemnify and hold Husband harmless therefrom, including costs and reasonable attorney's fees. 13. Except as otherwise provided herein, Husband hereby warrants and represents that he has not heretofore incurred any debt or obligation for which Wife now or in the future is or may become liable. With respect to any such obligation incurred by Husband, whether solely in his name or jointly, he agrees to pay same and to indemnify and hold Wife harmless therefrom, including -5- . . ' 'I"~ 01.. ..' , ,- I' ....... costs and reasonable attorney's fees. 14. Neither party shall, after the date of this Agreement, in any manner incur debts or other obligations obligating the other or incurring any debt in the name of the other, and each party shall indemnify and hold harmless the other party of any such debts or obligations, including costs and reasonable attorney's fees. 15. Wife does hereby release, remise, quitclaim and forever discharge Husband and the estate of Husband from any and every claim that she now has, may hereafter have, or can have at any time against Husband or against his estate, or any par~ thereof, whether arising out of any formal contracts, engagements or liabilities of Husband; arising by way of dower or claim in the nature of dower, widow's rights, or under the intestate law; arising by any rig~t to take against Husband's Will; arising under the Divorce Code including claim for determination and distribution of property, claim for alimony, and claim for attorney's fees, costs and alimony pendente lite; or arising by any other nature whatsoever excepting only those rights accruing to Wife under this Agreement. 16. lIusband does hereby release, remise, quitclaim and forever discharge Wife and the estate of Wife from any and every claim that he now has, may hereafter have, or can have at any time against Wife or against her estate, or any part thereof, whether arising out of any formal contracts, engagements or liabilities of Husband; arising by way of curtesy or claim in the nature of -6- ." 'I , ' ..' ..' "" , " . ' " .. " curtesy, widower's rights, or under the intestate law; ar~sing by any right to take against Wife's Will; arising unde~ the Divorce Code including claim for determination and distribution of property, claim for alimony, and claim for attorney's fees, costs and alimony pendente lite; or arising by any oth~r nature whatsoever excepting only those rights accruing to Husband under this Agreement. 17. The parties agree that this Agreement, C!r an~ parts thereof, may be enforced in any court of any jurisdiction. The above waiver of counsel fees and expenses shall not apply to,an action for the enforcement of this Agreement. Husband agrees that he will pay the reasonable counsel fees and costs incurred by Wife in the event Wife shall bring any action against Hus~and ~o en~orce the terms of this Agreement and ip further event that Wife is successful in such action. Wife agrees that she will pay the reasonable counsel fees and costs incurred by Husband in the event Husband shall bring any action against Wife to enforce the ,terms of this Agreement and in the further event that Husband is successful in such action. 18. Each of the parties agree to execute an Affidavit of Consent to a Decree in Divorce pursuant to the Divorce Code, 23 Pa. C.S.A., Section 330l(c). This Agreement shall be incorporated into but not merged with the Divorce Decree. 19. Husband and Wife mutually agree to execute such documents -7- , . . .. , . ... '. , '.... ,. .... 'f'", ..'0 Of, I as may be necessary and expedient to carry out and fully implement the terms of this Agreement. 20. Husband and Wife each represent and warrant that he and she have made a full and complete disclosure to the other of,a1l assets in which each party has an interest. 21. Both Husband and Wife acknowledge that they are fully aware of the assets and income of each other and that they both enter into this Agreement fully understanding their respective rights and responsibilities. Each party has been fully informed as to his or her legal rights and obligations and acknowledges that he or she enters into this Agreement freely and voluntarily without any duress or undue influence. Each party has had the opportunity to receive independent legal advice, and each party acknowledges that this Agreement is fair and equitable under the circumstances. 22. This Agreement shall be binding upon and shall inure to the benefit of the parties' heirs, personal representatives and assigns. IN WITNESS WHEREOF. the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. WITNESS: ~:?v/.../-(' ~~r''''''' /~/7#~ Ct~1L~v Ii /72G-7l tT.:::~ Cy.hthia A. Ment~er J ~~.~e~iA~C? -8- ,.'" ., ,t. I' .' VERIFICATION I verilY that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. Dated: .3/3O/9S- (!rth, ,( fI j) h -," ) .. ""', I .-.-. \ .. . . ~. I .. ., . CERTIFICATE OF SERVICE I hereby certify thaI on the toli. day of March. 1995. I sentn copy of the foregoing document by certilied muil. return receipt requested. to Defendunt, Dallus L. Ment1.cr, Jr:s,uttomey: Kent II. Patterson, Esquire 2211'ine Street lIarrlsburg. Pennsylvania 17101 Respectfully submitted, NICHOLAS AND FOREMAN Dated: 3hd/f> , . By: Jel 32 North Front Street Harrisburg. Pennsylvania 17110 (717) 236-9391 Supreme Court ID # 72657 Attorneys lor PlaintilT _"t'"" ~ ~ -I-I ~~~~~.... .......... ~...., ~~ ~ ~~ ~~ i~ p., , , <l: ...:l II ffi ~M ...:l I /!! H! N ...:l g ~ ... J .., . . . ...;;. ,,' '" .. - NICHOLAS & FOREMAN '" "II. .'. '.' z < ~ ~~ ~j o :z: u Z . . . ,. ~... . . . ! 5 g G . _ ~.' ~H i!! .;: ~r . . -~- " . r-~--~------~~~~--~~---------~ ~ . ~ ~ ~ ~ 7. 8 ~ ~ 8 8 ...~yn~~~il.A.~...M.e.ntz"r.... .......... ............... II ~ ............~~~.i.n.t.i.f.f.. . ..... ................................. II ~ ~ ~ ~ . h 8 i ~ ~ ~ ~ @ * 7. ~ ~ ~ ~ . ~ ..' ~ ~ . ,. ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .. PENNSYLVANIA No. ...i?'!.!\.............. .!;Jl!.U.... 1994 Versus ...Dallas..I.....Mentzer.; .Jr. .... .............................. Defendant DECREE IN DIVORCE AND NOW, ..~.V.~~.~... ......., 19~'t.. .., it Is ordered and d d th t Cynthia A. Mentzer I I t'ff ecree a. . . . . . . . . . . . . . . . . . .. ............................, pan I , and . ..~i;q..J.i,I~.!<,.tl~!l~:"~r:'.,. .41;"................................ defendant, are divorced from the bonds of matrimony, The court retains jurisdiction of the following claims which have been raised of r.l{cq~ in this action for which a final order has not yet been entered; '^-N ~ The Be f-; "..,., . . . . . . . .p'<p;q.'MQI} . ~ ., .,...w+ty . set:U~j;. P. ,. J.9.9.4,. .is . . . fc , ~ , ~ ~ --- _~ .z. ....... AUelt: ..... . J. Prothonotary -~~ ~ :lito ... ... ... ~ ... (Co 111:. ~. .:.:. .It} ....... "',..: ..:.;.... >It;. .-a:. .;,r.. ... .:.;-:-::.;: @ ~ ~ . 8. ~ @ ~ ~ ~ ~ ~ ~ ~ ~ ~ . j ~ , " ',0 ~ ~ ~ ~ ~ a ,. .' ~ ,;, ~ ,;! ~ ~ '.' ~ <;, * .', ~ .~ ~ ~ ,;, r.> ~ ... . ' , -...-- ~-- - . . . Yl#tfee ~~ &#r CYNTHIA A. MENTZER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 276 CIVIL 1994 DALLAS L. MENTZER, JR. Defendant IN DIVORCE SEPARATION AND PROPERTY SETTI,F.MENT AGREEMENT Respectfully submitted, NICHOLAS & FOREMAN By ~ J-P~~/J'_ MIC L L. ROZMAN, SQUIRE 3207 North Front Street Harrisburg, PA 17110 (717) 236-9391 Attorneys for Plaintiff AGREEMENT AGREEMENT made this day of ~ MENTZER (hereinafter referred /If! 1994, by to as Wife) and between CYNTHIA A. and DALLAS L. MENTZER, JR. (hereinafter referred to as Husband). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 3, 1987; and WHEREAS, differences have arisen between Husband and Wife which have caused them to live separate and apart; and WHEREAS, there is a divorce action pending between the parties in the Court of Common Pleas of Cumberland County, Docketed at No. 276 Civil 1994; and WHEREAS, the parties have reached a resolution concerning distribution of marital property and other issues. NOW THEREFORE, each party intending to be legally bound hereby does agree as follows: 1. It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they respectfully deem fit, free of any control, restraint or interference, direct or indirect, by each other. Neither party shall molest the other or compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of causes to their living apart. 2. The parties acknowledge that they have divided between themselves the household goods and furnishings in a manner satisfactory to both of them. The household goods and furnishings now in the possession of each party shall remain the sole' and individual property of that party. 3. Husband and Wife shall continue to own and enjoy, free from any claim or right of the other, all of his or her personal effects, such as clothing, jewelry, books, athletic equipment and the like, wherever located. 4. The 1989 Eagle Medallion automobile shall be the sole property of Wife, and Husband shall transfer all his right, title and interest in said automobile to Wife. Wife shall assume payment of the loan to Mellon Bank on account of purchase of the automobile and Wife shall indemnify and hold harmless Husband from all liability for payment of said loan, including said reasonable attorney's fees and costs. 5. The Astro mobile home jointly owned by the parties and currently situated at Leiby's Mobile Home Park shall be placed for sale and shall be sold for any reasonable price. The following distribution shall be made from the proceeds of the sale: A. All normal settlement costs including sales commissions. B. Payoff of the purchase money loan to Security Pacific Finance Company. -2- c. Any credits or monies owing to either party. D. The balance thereafter shall be paid to Husband. The parties have already listed the mobile home for sale with Leiby's MobUe Home Sales, and they shall continue to keep' the property for sale wi th a reputable sales agency. The parties shall cooperate in conducting settlement and delivering possession of the property to a buyer. In the event there are insufficient funds from the sale of the property to pay the purchase money loan to Security Pacific, then the parties shall contribute, in equal shares, sufficient monies to cover any such deficiency so that the loan can be paid in full and title to the mobile home released to the buyer. 6. Wife shall have the right to exclusively reside at the mobile home until such time as there has been settlement on the sale of the mobile home. In such event, the Wife shall make the loan payment to Security Pacific and the lot rent payment to Leiby's Mobile Home Park for each month or part of the month that she resides in the property. Wife has been residing in the mobile home since the parties separated in January 1994 and shall be responsible for making the aforesaid payments since that time. If wife should vacate the mobile home, then the parties shall each pay one half of the monthly loan payment and lot rent until settlement on the sale of the property. 7. In the event Wife should vacate the mobile home, then -3- - Husband shall have the right (but he shall not be obligated) to exclusively reside in the property. In such event, Husband shall make the Security Pacific loan payment and the lot rent payment for each month or part of the month in which he resides in' the property. If Husband should thereafter vacate the mobile home, then the parties shall each pay one half of the monthly loan payment and lot rent until settlement on the sale of the property. 8. Any outstanding real estate taxes for the year 1993 shall be paid equally by Husband and Wife. Any real estate taxes owing on the mobile home beginning with the y.ar 1994 shall be paid equally by Husband and Wife; provided, however, that the party exclusively residing in the mobile home shall be responsible for payment of all real estate taxes on a pro rata basis for all months or portions of a month that he or she resides in the mobile home. If it is unknown at the time the taxes are due and owing how long either party will reside in the mobile home during the taxable year, then each party shall pay his or her portion of the taxes owing until the date of payment and shall reimburse the other party at the end of the taxing authority's fiscal year or at the time of settlement on the sale of the mobile home, whichever is earlier. 9. Each party shall retain as his or her sole and individual property any retirement or pension plan or 401K plan at his or her place of employment. -4- 10. Each party releases the other party from any claim for alimony or alimony pendente lite. 11. Each party shall assume payment of the charge account that had been issued in their sole names. Wife shall assume payment of the Visa, Master Card, Gordon Jewelers, and Fashion Bug accounts that were issued in her name. Husband shall assume payment of the Visa account that was issued in his name. Each party shall indemnify and hold harmless the other party from any liability for payment of said charge accounts that have been incurred by each party, including reasonable attorney's fees and costs. 12. Except as otherwise provided herein, Wife hereby warrants and represents that she has not heretofore incurred any debt or obligation for which Husband now or in the future is or may become liable. With respect to any such obligation incurred by Wife, whether solely in her name or jointly, she agrees to pay same and to indemnify and hold Husband harmless therefrom, including costs and reasonable attorney's fees. 13. Except as otherwise provided herein, Husband hereby warrants and represents that he has not heretofore incurred any debt or obligation for which Wife now or in the future is or may become liable. With respect to any such obligation incurred by Husband, whether solely in his name or jointly, he agrees to pay same and to indemnify and hold Wife harmless therefrom, including -5- cOltl and realonable attorney's fees. 14. Neither party shall, after the date of this Agreement, in any manner incur debts or other obligations obligating the other or incurring any debt in the name of the other, and each party shall indemnify and hold harmless the other party of any such debts or obligations, including costs and reasonable attorney's fees. 15. Wife does hereby release, remise, quitclaim and forever discharge Husband and the estate of Husband from any and every claim that she now has, may hereafter have, or can have at any time against Husband or against his estate, or any part thereof, whether ariling out of any formal contracts, engagements or liabilities of Husband; arising by way of dower or claim in the nature of dower, widow's rights, or under the intestate law; arising by any right to take against Husband's Will; arising under the Divorce Code including claim for determination and distribution of property, claim for alimony, and claim for attorney's fees, costs and alimony pendente lite; or arising by any other nature whatsoever excepting only those rights accruing to Wife under this Agreement. 16. Husband does hereby release, remise, quitClaim and forever discharge Wife and the estate of Wife from any and every claim that he now has, may hereafter have, or can have at any time against Wife or against her estate, or any part thereof, whether arising out of any formal contracts, engagements or liabilities of Husband; arising by way of curtesy or claim in the nature of -6- - -~. curtesy, widower's rights, or under the intestate law, ariling by any right to take against Wife's Will, arising under the Divorce Code including claim for determination and distribution of property, claim for alimony, and claim for attorney's fees, costs and alimony pendente lite; or arising by any other nature whatsoever excepting only those rights accruing to Husband under this Agreement. 17. The parties agree that this Agreement, or any parts thereof, may be enforced in any court of any jurisdiction. The above waiver of counsel fees and expenses shall not apply to an action for the enforcement of this Agreement. Husband agrees that he will pay the reasonable counsel fees and costs incurred by Wife in the event Wife shall bring any action against Husband to enforce the terms of this Agreement and in further event that Wife is successful in such action. Wife agrees that she will pay the reasonable counsel fees and costs incurred by Husband in the event Husband shall bring any action against Wife to enforce the terms of this Agreement and in the further event that Husband is successful in such action. 18. Each of the parties agree to execute an Affidavit of Consent to a Decree in Divorce pursuant to the Divorce Code, 23 Pa. C. S .A., Section 3301 (c) . This Agreement shall be incorporated into but not merged with the Divorce Decree. 19. Husband and Wife mutually agree to execute such documents -7- . . as may be necessary and expedient to carry out and fully implement the terms of this Agreement. 20. Husband and Wife each represent and warrant that he and she have made a full and complete disclosure to the other of all assets in which each party has an interest. 21. Both Husband and Wife acknowledge that they are fully aware of the assets and income of each other and that they both enter into this Agreement fully understanding their respective rights and responsibilities. Each party has been fully informed as to his or her legal rights and obligations and acknowledges that he or she enters into this Agreement freely and voluntarily without any duress or undue influence. Each party has had the opportunity to receive independent legal advice, and each party acknowledges that this Agreement is fair and equitable under the circumstances. 22. This Agreement shall be binding upon and shall inure to the benefit of the parties' heirs, personal representatives and assigns. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. WITNESS: /:h-/ -/-I:--V;f)-.,,,,,,, /~r;b~ ., C(~1LL. ,~ Cy thia A. /i 77. I II / l:!>tJ'llK~ Ment.zer ) J941!41-.E. 0'~.i!i ~ Dallas L. Mentze~cr . -8- ~~ C'l i f:j z < ! ::0 5 ~ Ul l:l . . 3 I; ~ ~~ = . . i ~ Cl . ... . , ~ '" f:j~ Q~ ; ~ i '" ~j i i ~ ..... ; J ll< ..... ~ 0 ~ . :P <oil Ii :c . . u < : . .~ > II :Z ~ . u ~ ~ ~ 21 '" ~ l' ~ N . ~~ S , - - . . NICHOLAS & FOREMAN . . CYNTHIA A. MENTZER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW v. DALLAS L. MENTZER, JR., Defendant : NO. 276 CIVIL 1994 : 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: I. Ground for Divorce: Irreconcilable Differences under Section 330 I (a) (I) of the Divorce Code. 2. Date and manner of service of the complaint: January 25, 1994 by personal service. 3. Date of Execution of the PlaintilT's Affidavit required by Section 3301 (a) (I) of the Divorce Code: May 31, 1994 of Execution the Defendant's Affidavit required by Section 330 I (a) (I) of the Divorce Code: May II, 1994. 4. Related claims pending: None Respectfully Submiued, , /?'?~/.. ~ ~~ MICHAEL L:ROZMAN, E'SQUIRE "- NICHOLAS & FOREMAN 3207 North Front Street Harrisburg, Pennsylvania 17110 (717) 236-9391 , ~:'~ ~~ .. -::r ~. )0"- CT) ..r.~ :c 0- r- In N ',:"'. ,.. :~ 0'"> :z: ::> -, --t.' ;:':' : CIVIL ACTION - LAW Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. .2 7t. C~ 6'1</ CYNTHIA A. MENTZER, v. DALLAS L. MENTZER, JR. 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 make 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, Domestic Relations Section, Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOST THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOU 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. Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 NICHOLAS & FOREMAN Bt:2..0'~ MICHAE L. ROZMAN, ES UIRE 3207 North Front Street Harrisburg, PA 17110 (717) 236-9391 Attorneys lor PlaintHr : CIVIL ACTION - LAW CYNTHIA A. MENTZER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. v. DALLAS L. MENTZER, JR. Defendant : IN DIVORCE NOTICIA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestns en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notilicacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensns 0 sus objeciones a Ins demandns en contra de su personal. Sea avisado que si usted no se deliende, la corte tomara medidns y puede entrar una orden contra usted sin previo aviso 0 notilicacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDATAMENTE. SI NO THlENE ABOGADO 0 SI NO TIENNE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DlRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 NICHOLAS & FOREMAN By P14'1~~-;;f~~ MICHAEL L. ROZMAN. ES IRE 3207 North Front Street Harrisburg. PA 17110 (717) 236-9391 Attorneys for Plaintiff .._~;., CYNTHIA A. MENTZER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVILA ACTION - LAW NO. .nt. CW /1'; '/ IN DIVORCE DALLAS L. MENTZER, JR. Defendant WAIVRR OF COlmSELING 1. 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. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. Dated: ~. n I-hA t1 ~ It C HIA A. MENTZER 1f10d11J- CYNTHIA A. MENTZER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. .2 7i e..~ / 1 <1 'f v. : CIVIL ACTION - LAW DALLAS L. MENTZER, JR. Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff. CYNTHIA A. MENTZER, by her attomeys, NICHOLAS & FOREMAN. and respectfully presents the following: I. Plaintiff is CYNTHIA A. MENTZER. an adult individual, mi .iYris. presently residing at 7073 Carlisle Pike, Lot 42. Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is DALLAS L. MENTZER, JR., an adult individual, mi.iYris, presently residing at 7073 Carlisle Pike Lot 64, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona tide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 3, 1987 in Shiremanstown, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. PlaintilTand Defendant are both eitizens ofthe United States of America. 7. Plaintiff and Defendant are not members of the armed services of the United States. 8. The Plaintiff has been advised of the availability of counseling and she understands that he may request that the Court require the parties to participate in counseling, but avers that she does not require marriage counseling. 9. The Plaintiff avers that the grounds on which the action is based are: (a) That the marriage is irretrievably broken; 10. Plaintiff requests the Court to enter a Decree in Divorce. . , Wherefore, Plaintiff prays your Honorable Court to enter an Order dissolving the marriage between the parties. Respectfully submitted, NICHOLAS & FOREMAN B~~~~~ MICHA L L. ROZMAN, ES UlRE 3207 North Front Street Harrisburg, PA 17110 (717) 236-9391 , . VERIFICATION I verify that the statements made in this Pleading 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. ~tk~ tL f&~ C RIA A. MENTZER DATED: I o ~ " -,r en - ."..... \ - .i ~ I ~! "' '1 \"i ~.~ - .1"/ ::J ;:::; :J o coa '" v- ..., or ..... .. t,,~ .) .. u'C\l ~ J = .1: 00 :;<' " ,. .a:. ~.. ;.:. ~.t .'-~ , ..~. . ~ ::~~-7i '- ..\ P"'l '::1 '~ ',..., '.., , :) \... Q " I. " - " .. .J 1:- .,., ~ N :r. .... .., . - .' Il" ~ ~ OH :.: ~g ...:1>< P<t/l - . z S~ . < ! .... I!;~ ~ ;jP< .... g~ ..... III o . ll:oI.I ''0 ~ ~c2 u>< r><s:: ~; H t.. 0<:1.... oc1d ~S t.. III 0<:1.... /: ~ ~~ . ~~ I ~~ ; Ii 0 > E-oU :.: 0 Ii I ll: 0 :c OQ , 1-1 ~ U ~ 0:': ~ . E-oU Z U:S ...:I Ull: ~ <0 ~ll: 1-1 t/l > =~ =:: ~ ...:I 1-1 Eo<~ Eo< I-1Q :.:C ~ i:;:.: HU U UH . - .. . . NICHOLAS & FOREMAN . , . . . CYNTHIA A. MENTZER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYI.V ANIA vs. : CIVIL ACTION-LAW DALLAS L. MENTZER, JR., Defendant : NO. 276 CIVIL 1994 : IN DIVORCE ACCEPTANCE OF SERVICE This will certify that I, Dallas L. Mentzer, Jr., did accept service of the Divorce Complaint filed against me to the above-captioned term and number, on January 25, 1994. ~U!D.L (' /1J~Jr-- DALLAS L. MENTZER, JR. 0 . " _..:.... Dated: June 6, 1994 . -- "'.:~. ~.:::~~",,,, ~ :c 0- {;; N ~~ ~ ~~~ '~k"~:::--~ -:-. :: ;~::. ~ '.,-", . s -, "::~ '.'=, 1...(,.."\ "" 0'"> . .. . ~ . CYNTHIA A. MENTZER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 276 CIVIL 1994 DALLAS L. MENTZER, JR. Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 24. 1994. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 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: MAY 31, (':- .ntit I~ tl () 212 JL1 ,,_, yYTHIA A. MENTZER 1994 -:r en >->- ~C: ~,.. ~ J, ~~:; ::c: o_ N ':;> N ';" ,. ,~':.) ., 5 ~.~~ ~ -, . . -. . - . CYNTHIA A. MENTZER Plaintiff : IN THE COURT OF COMMON PLEAS OF CUHBERLANDCOUNTY, PENNSYLVANIA : NO. 276 CIVIL 1994 : CIVIL ACTION - LAW : IN DIVORCE v. DALLAS L. MENTZER, JR. Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 24, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint, 3. I consent to the entry of a final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 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. S 4904 relating to unsworn falsification to authorities. Date: 57;//'11-/ . Dallas L. .",.. ~ >->- :.';>- ...: ~e L.,l..,_...., '...l". ::_ ~. ~ '::-~ ~.:-:; .,. -:.:,,::,> ::c: Q.. N r.:> N '-0 .:,.(:;.r".. , _~/t: ~":) '~(..... ::I: -=l - . CYNTHIA A. MENTZER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DALLAS L. MENTZER, JR., DEFENDANT 94-0276 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of April, 1995, the petition to hold the defendant In contempt, IS DENIED. Jeff Foreman, Esquire For Plaintiff I Kent H. Paterson, Esquire For Defendant c-<f-~ r-~L '1-1..1.1&- /'Is 0 ~.P. :saa ~?\\ t~ B j(, ~\\ I~S ',;i -.' ('/Jv, \,; ,\ ~ \ ; \' \; ;' I,,"~ ~,,}'\ , ;': J.-' ',I 'I , CYNTHIA A. MENTZER Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 276 CIVIL 1994 CIVIL ACTION - LAW v. DALLAS L. MENTZER, JR. Defendant IN DIVORCE ANSWER TO PETITION FOR CONTEMPT AND NOW comes Defendant/Respondent, Dallas L. Mentzer, Jr. by his attorney, Kent H. Patterson and files this Answer to Plaintiff/Petitioner's Petition for Contempt, as follows: 1- Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admi tted. 6. Admitted. 7. Denied. It is denied that Petitioner has fully complied with the terms of the Property Settlement Agreement for the reasons set forth in New Matter below. 8. Admi tted in part and denied in part. It is admitted that Respondent has not executed a transfer in the registration for the 1989 Eagle Medallion automobile but it is denied that Respondent has refused to execute a transfer and it is denied that Petitioner has made any request for Respondent to do so. 9. It is denied that Respondent has refused to transfer title to the automobile to Petitioner. It is denied that Respondent has violated the Order of Court or intends to violate the Order of Court or do anything willful, deliberate and without just cause or legal excuse. 10. Respondent is wi thout knowledge or information sufficient to form a belief as to the truth of the averment that Petitioner has incurred attorney's fees in the amount of $750 in filing her Petition for Contempt. It is denied that Respondent is responsible for Petitioner's counsel fees in this matter and it is denied that counsel fees of $750 are reasonable. WHEREFORE, Respondent requests Your Honorable Court to dismiss Petitioner's Petition for Contempt. NEW MATTER 11. At the time the Property Settlement Agreement was executed on May 11, 1994, the title to the 1989 Medallion automobile was held by the bank which financ&d the automobile and said title could not be transferred at that time. 12. Sometime subsequent to the entry of the Divorce Decree, Petitioner obtained the title to the automobile from the bank after the loan had been paid off. 13. After Petitioner obtained ti Ue to the mobile home, Petitioner did not make any request to Respondent that Respondent execute the title or other documents to transfer title to the mobile home to Petitioner. 14. Petitioner exclusively resided in the mobile home from January 1994 through July 16, 1994 and under the terms of -2- -, paragraphs 6 and 8 of the Property Settlement Agreement, Petitioner was responsible for payment of the loan and real estate taxes for the mobile home. 15. After Petitioner vacated the mobile home, neither party resided in it from July 16, 1994 until January 1995 when Respondent moved into the mobile home and under the terms of paragraphs 6 and 8 of the Property Settlement Agreement, Petitioner was responsible for payment of one-half of the loan and the real estate taxes for the mobile home. 16. Petitioner failed to pay real estate taxes and make loan payments during the time she exclusively resided in the mobile home and failed to pay her share of the loan payments and real estate taxes from the period July 16, 1994 to January 1995 after she vacated the mobile home. 17. Petitioner's conduct in filing the Petition for Contempt was arbitrary, vexatious and in bad faith. WHEREFORE, Respondent requests Your Honorable Court to dismiss the Petition for Contempt and to assess costs against Petitioner including Respondent's reasonable counsel fees. L f-/~_ ~nt H. P~t{({s~n Attorney for Defendant 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 -3- CYNTHIA A. MENTZER Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 276 CIVIL 1994 CIVIL ACTION - LAW IN DIVORCE DALLAS L. MENTZER, JR. Defendant CERTIFICATE OF SERVICE I, Kent H. Patterson, attorney for Defendant in the case captioned above, hereby certify that on April 25, 1995, I served Plaintiff with the foregoing Answer to Petition for Contempt by handing her attorney of record, Jeffrey Foreman, Esquire a true and correct copy of same at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013. ~~/(~ ent H. Patterson Attorney for Defendant 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 +r"- Lr> C7'> - = ""'" .." "J , O-J .l..: "~-.