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HomeMy WebLinkAbout94-01100 L- ev ~ L- ~ ~ ~~ 'tl c: ~ ~ ~ III ~~ <&l U ~~ ... ... ..: I ... ~ ~ .... e o~~ on !lip,.~ ... 'tl ~ . c: c: Q ~J on o .en Cl'fJ GJ e IE ~ ~f~: .... ~ 0 ~ ~~ Cl~ t-:l ffie '" 0 on > ~ <&l CIl ~ ~ f-08~ m ::l <&l i~i ~ ~~~<&l m u ~ C <&l ~! o uu Q U l>: . CIl ~ 00 ~ ~ <&l 0:> . iS~:::S f:: <&l 0 ~ f"< ~uliil~ u CIl " .' ~..- LAW OFFlCfS MliW'l & .1ACOBSON 81S0 DI!RRV ~'TRI!IIT HARRISBURG. PA 17111.521>0 (717)51>1.1515 .~ Qr . . , .....~' ':C-' <4Co"-:C-"-:C-' ':4Co-:C-"~'.-:C-':.:iC>: -:C-"-:C-. ,;c, .:.;,..,:<<. .~;. ':C-.<4Co' .:4Co ':<<"l()llc<~:<c-:/.<<x;-:C-:;<4lY._-:1! ~ - I' a ~ , !I! ~ IN THE COURT OF COMMON PLEAS ~ ~ ~ ~ ~ ;,; ~ ~ ~ ~ ~ ~ ~ ~ ~ ;,: ~ to" :-. ~ ~ '. $ ~ ~ .' OF CUMBERLAND COUNTY STATE OF '* PENNA. ~ ? S ~ .:; ... ;;,; ~ ~ . ...Plaintiff.... ..................... II ,I 'I II !I Nil. .....H9.O',........ .f<.l.Y.;u..... 19 94 .............. .... ~~()TI.. \01. ...S~RI!FF~ER,..... VCI'SIIS *- ~.. ..........~.!>.~.. ~Hltf;!fnE1.t... ........................... i " ...........Defendant . t '.' .'~ .', , w '.' DECREE IN..A- D , V 0 R ~f,.. IX.. ;~ %P , . ,~ . , , , , , , " 19." ~ .. it is ordered and .', * ,.; ~ ~ ,; ,:. ~ ~ ~ .'~ AND NOW, ' decreed that"" "".. ,SCOTT ,w. ,SHREFFLER.,...."".,..""" plaintiff, and "," , , , , ,NIY, Il., SIIREFFLER. . . , , , . . , , , . , , , , , , , . , , , , , , . . , , " defendant, are divorced from the bonds of matrimony. ri. ..' .'. ~ i ~, 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; ,', ~ '= !="' w ~.' ~~~~:, .~~~,~~~~~~~.~~FF~~~~~F.AgF~~~~~~PA~~~~~,~q~~~~~~~~,qq~eq.~lInullry' 16..1996.. is, hereby. INCORPORA:fro .in.to -tMfi' 'Hna-l, 'Decree.and .bhe .porn:l:ea..' D to comply with its provisions Dy " " i ~.' .. ... .... ....... ....". t L f.'14"U E'.t' ",,I/6t; /~~J. ~: ~~U~. ~6? n7t . .. f/ / '-~~onotnry ~ " .', ~ '.' ~ .~ ~ .' ~ ~.~ i '.' ri. ~. ~ ',' 8 .'. ~ $ ~ ~ .'. ~ I~ ~.. 1,<1 .. ~ /..- ......_._ ~-.__~ ..__~_...__..._...... ~". _ _-.. _._.._..,......______.....__,..~ __._.____....~__._.,..... _....~ ...... .". ~ J ~ ~_~_~~*____~___~~~~ID~~. 1/.)/,95 tet./-t!f/,/lta..V ri. itt ~C(~ I/;}/. 9.{ ~t1-~t ma..d:/ ~ a;~.4HA"'" - .. '. 4 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT is made and entered into between SCOT~ W. SHREFFLER and AMY KYTE SHREFFLER, hereinafter referred to as "Husband" and "Wife". The parties were married on October 17, 1992, and there are no children born or adopted of this marriage. As a consequence of disputes and unhappy differences, the parties have separated. The parties desire to confirm their separation and make arrangements in connection therewith, including the settlement of their property rights, 3upport, and all other rights and obligations arising out of the marriage relationship. It is therefore agreed: 1. CONSIDERATION The consideration for this agreement is the mutual promises and agreements herein contained. 2. SEPARATION AND NON-INTERFERENCE A. It will 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 may from time to time chose or deem fit. B. Each party shall be free from interference, authority and =- control, direct or indirect, by the other as fully as if h~r she were single and unmarried. Neither shall bother .the other or 0:- compel or endeavor to compel the other to cohabit or dwell w~h him . ,..., or her. ~- = 3. MUTUAL RELEASE - c.JCI .."" Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or 1 " . .. herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce. 4. FULL DISCLOSURE The provisions of this Agreement and their legal effect are fully understood by each party to this agreement, and each party acknowledges that the agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, of the sources and the amount of the income of such party of every type whatsoever and of all other facts relating to the subject matter of this agreement. Husband represents that he was represented by M. Peter Harer, Esquire, in reaching this Agreement and Wife represents that she was represented by Charles E. Friedman, Esquire in reaching this Agreement. Both parties represent that the terms of this Agreement have been fully explained to them by their respective counsel. 5. EOUITABLE DIVISION By this Agreement, the parties have intended to effect an equitable division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange 2 " " . of assets. 6. SUBSEOUENT DIVORCE A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense or for the non-prosecution or non-defense of any action or divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto, It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to execute the agreement. Husband and Wife each knowingly and understandingly hereby waives any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever unenforceable in whole or in part. Husband and Wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 3 ; . B. ENTRY AS PART OF DECREE - It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment, or decree of divorcer temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This agreement shall be incorporated into but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. C. MUTUAL CONSENT OF DIVORCE - The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. S3301(c). Accordingly, upon conveyance of the real estate as set forth in Paragraph 10 of this Agreement, and upon satisfaction of all of the conditions set forth therein, both parties agree to concurrently execute such consents, affidavits or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. S330l(c). Upon request, to the extent permitted by law and the applicable rules of civil procedures, the named Defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 7. DIVISION OF PERSONAL PROPERTY Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband~ and 4 "# -- . Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate party of the other. 8. DIVISION OF MOTOR VEHICLES with respect to the motor vehicles owned by one or both of the parties, they agree as follows: Wife - 1990 Pontiac Grand Am Husband - 19BB Nissan Centra traded for a Ford Bronco. The titles to the said motor vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided, on the date of execution of this Agreement. 9. DISPOSITION OF PROPERTY From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, conveyor otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. 10. DIVISION OF REAL PROPERTY Husband and Wife hereby agree and acknowledge that they own 5 .# \ . certain real property located at 423 South Pitt Street, Carlisle, Cumberland County, Pennsylvania, as tenants by the entireties. . Upon execution of this Agreement, Wife shall also execute a Special Warranty Deed transferring all her right, title and interest in said property to Husband. Said Deed shall be held in escrow by Wife's attorney until time of transfer. At the time of transfer, said Deed will be delivered to Husband, at which time Husband shall pay Wife the sum of $5,000.00, which amount includes funds currently being held in escrow by Husband's attorney. At the time of said transfer, Wife's obligation under an existing mortgage in favor of Fleet Mortgage, Inc. in the original principal amount of $75,937.00 and Wife's personal obligation under said Mortgage shall be satisfied in full. In the event that the transfer of the real property does not occur on or before April 15, 1995, then Husband and Wife agree to list the property for sale. The parties agree to sell the property at a price sufficient to satisfy the mortgage after consideration of settlement costs and the amount being held in escrow by Husband's attorney. If the parties incur a loss on the sale of the real property, they agree to divide the loss in equal shares between the parties. In the event the parties obtain a gain on the sale, they agree to divide equally between them that amount, as well as any of the funds currently held in escrow by Husband's attorney. 11. PAYMENT OF SPECIFIC OBLIGATIONS The parties agree that the following constitute joint marital 6 0, ~ . obligations which shall be paid by the following persons: A. WIFE - Will pay all debts in her name; B. HUSBAND - Will pay all debts in his name; 12. LEGAL FEES Each party shall pay his or her own attorney's fees. 13. ALIMONY Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance, alimony pendente lite or alimony. Husband and Wife further, voluntarily and knowingly, waive and relinquish any right to seek from the other any payment for support, maintenance, alimony pendente lite or alimony. 14. PENSION PROGRAMS Each party hereto shall maintain sole ownership over his or her individual pension plan, profit sharing or similar retirement plan acquired individually or as the result of contributions by his or her employer. Wife hereby releases any interest that she has in the retirement benefits of Husband accumulated as the result of his employment and any other additional benefits he may have accrued. Husband hereby releases any interest that he has in the retirement benefits of Wife accumulated as the result of her employment and any other additional benefits she may have accrued. This wavier is full and complete discharge of each parties' marital claim. 7 ., " . 15. MISCELLANEOUS All assets including, but not limited to, savings accounts, checking accounts, certificates of deposit and life insurance polices shall be the sole and separate property of the title holder of said asset. The parties believe and agree, and have been so advised by the respective attorneys, that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her with respect to any other issue which is inconsistent with the position set forth in the preceding sentence or his or her federal or state income tax returns. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in Federal, State or local income tax is assessed against them for the years in which they filed joint returns, and in the event that said deficiency is the result of a misrepresentation or failure to disclose the nature and extent of separate income by either of the parties, said party responsible for the deficiency shall be solely liable for the assessment and any interest, penalty or expense incurred in connection therewith. If any deficiency is assessed through no fault of either of the parties individually, they shall equally share said obligation. In the event that the parties are entitled to a tax refund for any year during which they filed jointly, said refund shall be equally 8 " divided between them. In the event that the parties file individual tax returns for 1994, Wife shall be entitled to deduct mortgage interest payments for January, February, March and April 1994 and Husband shall be entitled to deduct mortgage interest payments for the remainder of the year. 16. GENERAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS - Each represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as maybe provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as maybe otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. c. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be 9 " void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. D. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. E. ENTIRE AGREEMENT - This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. F. WAIVER OR MODIFICATION TO BE WRITING - No modification or waiver of any of the terms herein shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. G. MUTUAL COOPERATION - Each party shall, at any time and from time to time hereafter, take any and all steps and execute, 10 " acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. I. BINDING EFFECT - Except as otherwise stated herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. J. NO WAIVER OF DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. K. HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. L. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein 11 '. otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, curtesy, their statutory equivalents, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of other, and right to act as administrator or executor of the other's estate, and each party will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. M. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that either party breaches any provision of this Agreement, and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay all reasonable attorney's fees, court costs and expense incurred by the other in enforcing this agreement. 12 " IN WITNESS WHEREOF, and intending to be bound parties have signed ttJnr I (In.) I and sealed this Agreement on the hereby, 1/ rr-- day of the , 1995 at Harrisburg, Pennsylvania. ~dl;b W -n s ~t:~. Witness dt#rt ~~~,~ S tt W. S re ler '~~r~' shreffler.mSA 13 LI"> C"> - ,.) .~~-= ,..-. ." 1..(, ,.r ~,. .. (. - ~6.:..':~ f', '~:" . ::,.' .: :c ..::r N .... CO I ".i .~-' .. ,. t.. : -,<.'''-1 ". .j.. ~. '. ~- ;j '" - - 0: .... '"'" "'=i ~ ~ ~~ .... ... p..> .... c: !-< ~~ 'r4 OJ ~ ... "Cl ilj ~ o!~ on ;l c: - ~ffi~ Ql ~ ~>-~ on o OJ .... IE - 0 o '" Cj.-4 Ql - Up..", ~p.. ol'l "':l ffici '" .... Cj ~ 0 on ~ 0 i=: ~ ~ OO~ ~ i~i - i > u ... !-<U> l<I gj - g';!tJl<I i el ~! o u u U 0<>= . ~ 00 ~ ~l<I:::~ . ~ l<I p.. iSe~iS ~ U '" " . . , .or' -,.,4. " '. lAW OFFICES MIRIN &. JAC9DSON 0/,,- , . 81SO peRRY mEET . , '. , , HARRISBURG. PA 17111.5260 (717) 561.1515 " SCOTT W. SHREFFLER, . IN THE COURT OF COMMON PLEAS . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION - LAW . v. . . . NO. 1100 CIVIL 1994 . AMY E. SHREFFLER, . . Defendant . CIVIL ACTION - LAW . . IN DIVORCE . PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: (1) Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. (2) Date and manner of service of the Complaint on the Defendant: certified mail, return receipt requested dated March 9, 1994. (3) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff, April 4, 19951 by the Defendant, April 6, 1995. (4) Related claims pending: None (5) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A MIRIN & JACOBSON, ~.Q~ M. Peter Harer Attorney for the Plaintiff 1.0. * 65604 8150 Derry Street Harrisburg, PA 17111-5260 (717) 561-1515 DATE: April 10. 1995 ":r en - e;e, ~~ '-Doc ~'-tl i ~'* ~""'& ~~ . ~ ~ ..... <;:),.~ e~ 0 e oC;> It) cdq . '0 -s> - 00 - "fF" :0:::: .."., '" ... ~~ ~;;'- 5~~ ~-' -;~ ~~,,;..,1:1 "- ~.; .~, ;. -,_:'10_ -~ '-'" " ;. _. ~ro = ,.1.. "" .. = :;:::. :::; L' Po< - u ~ p; ~ ~~ ~ ~ fiI.... <:r ~ r:: UCJfiI Z ~ '" III c>:.....A o ~:: I::r- -~ 't:l 0.....0 o :3 - i:3.E r:: >OU e (I) ~;:: '" UA:J -QI HM - ~~ C>:~ AMfiI ~ - :!l ~~ I 'j filQ1 ....U IE o )o~ , ~A Z c>: - u= . '" ~ HOO 0 ~=o '" E-<fiIZ E-<> ~ ~ l!i!5 ,::- ~~~fi1 . ~ t ~ - CI.l :> ~o~ ... o E-<U ~~~ ~;~ ~ UUUC>: . CI.l <00 :3 [Il - >- , ~~E-< CI.l,..:lH_ ~ fiI E-<iJHA o f<. > . 0 ~ UPo<O Z,..:lHZO U ~ HPo<UHZ CI.l , , . , . .. , , LAW OFFICES l\IlRIN & ,JAC()nSO~ 1', C, HI~II11ERRY STREET IIARRISIIURO,I'A 1711I,~2(~1 -(7I'7T~I,I,'~l~ ,. . SCOTT W. SHREFFLER, Plaintiff : IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA v. . . . . CIVIL ACTION - LAW : . . NO. /100 ~ /99t.f IN DIVORCE AMY E. SHREFFLER, Defendant . . NO'l'ICE TO DEFEND AND CLAIM RIGB'l'S 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE 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. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 Telephone 717-240-6200 . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE SCOTT W. SHREFFLER, Plaintiff AMY E. SHREFFLER, Defendant COMPLAINT IN DIVORCE PURSUANT TO SBCTION 330ltcl OF THE DIVORCE CODE The Plaintiff, Scott W. Shreffler, brings this action in divorce against the Defendant, on the following basis: (1) Plaintiff, Scott W. Shreffler, is an adult individual residing at 423 S. Pitt street, Carlisle, Cumberland County, PA 17013. (2) Defendant, Amy E. Shreffler, is an adult individual residing at 423 S. Pitt Street, Carlisle, Cumberland County, PA 17013. (3) Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. (4) Plaintiff and Defendant were married on October 17, 1992 in Dauphin County, Pennsylvania. (5) Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies. (6) There have been no prior actions of divorce or for annulment between the parties. 1'". ",.:'.'"CiI->>f1' (7) The marriage is irretrievably broken. (8) Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. (9) Plaintiff requests this Honorable Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, MIRIN & JACOBSON ."-"" DATED: March 2. 1994 By:I!Je.)~,~ M. eter Harer Attorney I.D.' 65604 Attorney for Plaintiff B150 Derry Street Harrisburg, PA 17111-5260 (717) 561-1515 VERIFICATION I, Scott w. Shreffler, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 1B Pa.C.S. section 4904 relating to unsworn falsification to authorities. CERTIPlCATE OP SERVICE I, M. Peter Harer of the law firm of MIRIN & JACOBSON, do hereby certify that a copy of the foregoing Complaint in Divorce was this day served upon the following person in the manner indicated below: CERTIPIED MAIL. RETURN RECEIPT REOUBSTED Amy E. Shreffler 423 S. pitt Street Carlisle, PA 17013 cz DATED: -;-7- 'tv 'A-Q~nl M. Peter Harer ...., en . ~.... ...;-":.,: 'H;-,:::;.; :: ~ ~;:;: ::;;::C;;:'~l " ,. ~~ ..":, til " .:0::;' , ."",-, . ::,';.14.0 .~ ;fQ., 40..;;1 0(".' 2:: '""" N .... CO - - ... .... .... ~ ~ <II ~~ Z ~ ~ .... ... 8 .... r:: ~~ '" III ... ] '" ~ 0 ~~= sffi Gl 19 III .... ~ o ;:: III .-l Gl .... ~I'<.... I'< I'l ;: ~>-~ III IE .... . , o .", Cl i:l .... u~~ . 0 "" !il ; ~ ~ffi~ III "'~ :- ~ ~ S'ol:l '" f .... i-<ui:; i <II ~I to ~Iu~ i !:: o U U 0<>= . H 00 ~ ~ ~ ::i:< , ~ ~ ~ol'l :s U I'< " ' . .' ., ". " lAWOmCES MIRIN & JACOBSON 8150 DERRY STReET HARRISBURtJ~ PA 17111.5260 (717)561.UI5 ." . I SCOTT W. SHREFFLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1100 CIVIL 1994 IN DIVORCE v. AMY E. SHREFFLER, Defendant PLAIN'l'IFP'S AFFIDAVIT OF CONSBN'l' (1) A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March B, 1994. (2) The marriage of 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 I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made suLject to the penalties of 1B Pa.C.S. Section 4904, relating to unsworn falsification to authorities. :ktrJl. *- SCOTT W. S FFLER DATE: 'I-q-C/S shrefdiv.cpl ..., ~ ~," t.~~~;..r E~~;~ 0.:- 1": .,;..l - . ~ ....1'-" _~_;.: -r. :! :;:;;: ,::._,t'..... '" ~c :0:: -co: '" ... CO - - :: oq ~ Ii ~~ tIl ~ ~ ..... ... ~ ..... ~ tJ ...:l>l oM I'< ~tIl ... "0 ~!~ zffi c: ~ 0 oM ~ on III ..... I:l ~ ~~~ ..... III U ~ on o~ A ~ IE ~ >0:: ~ , o 0'" !:l ~ tJ~~ 0 ":l ffici '" ~ !:l 0 on ~~...:l > ~ ~ F:' ~ i~~ ~ OH ~ t. HtJ> ~~tJbl ~ tIl ~! o tJ ~ tJ OR: , tIl 00 ~ bl .... > , [!1 ....::: ~ bl ~e ~ ~ tJ ~ ~ tIl ., ..... , .. . " . , , ", lAW OFFICES MIRIN & JACOBSON 815lUlERRY STREET IlARRIEBURO,i'A 17111-5260 (717) 561-1515 ,. . (I ./ . . . " , ., , SCOTT W. SHREFFLER, Plaintiff . . . . . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW . . AMY E. SHREFFLER, Defendant : NO. 1100 CIVIL 1994 : IN DIVORCE DBPENDANT'S AFFIDAVIT OP CONSENT (1) A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March B, 1994. (2) The marriage of 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 I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. I 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 1B Pa.C.S. S 4904, relating to unsworn falsification to authorities. DATE: ~~~~. AMY . SHREFFL . .,,- J I o() t /tJ91/ CERTIFICATE OF SERVICE I, Beryl Millsr-Eckrich, a paralegal with the firm of Mirin and Jacobson, do hereby certify that the original Complaint in Divorce was served by Unitsd States Mail, certified, retLlrn receipt requested on March 9, 1994, Mrs, Amy E, Shreffler 423 So Lith Pitt Street Carlisle, PA 17013 RETURN RECEIPT ATTACHED Date: April 10, 1995 . ."' . ..-U .,";- -~~J~~YJ:i 18110 wlah to ~.1IM!j.~'::1 following I.rvlc.. (for .n extra I '. f..l:. 1, 0 Addr......a Addr... I 4a, i 4b, S.rvlce Typ. II: '. o R.gl.t.red 0 In.ured l'b.. C.rtlfled 0 COD!' . 6 Expr.l. MIll 0 R.tum Rec.lpt for 1 7, Dat. 01 D.llv.ry .! . '/-1 I. B, Addr.....'a Addr..1 (Only II raquOIted 1 and fa. II paldl ~ ,.. .. -,:'~-'--"::'<.';-,::1<E'":- :-:>-~/>:. .. 'CGlIIlllIIO io.mo 1 IlllIIO<lfor.-............., .. .C........._3,1Ild....b;.". .' ..... .. . I . PrInt your ",me end Iddrn. on the rlVltfII af tN. form sa that w. can i lltum thIt ani to you. !P! . AnKh this form to thI front of thI mallP'fC8. or on the b.ck If SP,CI " z: doll not pmnIt. , E . Writl ''Retum Receipt RlQUlltldof an the maIIpieca below the.rtIdt "","bel . t1 . The Rltlm Rtctlpt wit ahaw to whom thell1icll Wit dllivtrtd and the de'l . g -.... I 3, Artlcl. Addr...ed 10: AMY E. SHREFFLER e 423 SOUTH PITT STREET . S CARLISLE, PA 17013 ,D~ 1881 eII.I._lI. __ DOMESTIC RETURN RECEIPT ,-..........-.,..., APR II 8 12 AH '9~ ('; , ~, ' Lt.!': ;,1;';' i Aft)' r:~:,~ ~ . I, ",'" J _~1 i '( ,'or:' .', .. I :~ . : '1'.1 .' "." Form. DV\Maid. Name SCOTT W. SHREFFLER, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . . AMY E, SHREFFLER, Defendant . . NO, 1100 CIVIL 1994 IN DIVORCE NOTICE OP INTENT TO RETAKE PRIOR NAME Notice is hereby given that the Defendant in the above matter, having been granted the Final Decree in Divorce (or annulment) on the~ 20th day of Apr~l , 19~, hereby elects to retake and use her previous name of Amy E. Kyte and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, Pa, Cons. Stat. 5704, ~~~. ~,~(y. E. Shref er To Be Known As: 4~'~' Amy Kyt COMMONWEALTH OF PENNSYLVANIA . . SS: COUNTY OF Dauohin On the 24th day of April I. 1!! 95, before me, a Notary pUblic, personally appeared L!m;; G ',;)j,rpr/l1l? known to me to be the person whose name is subscrlbed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. IN WITNESS, I have hereunto set my hand and seal. 6~~~ 1tf~__ Notarial Soal Linda A. DoAngelo, Notary pubnc Harrilburg. Dauphin County My Commission F.Jpire!'i Sopt. 11, 1998 :c a.- N o (Y) ''', 7.1' ~>-- ~3~ -~ :t: r--: Lr> en - ,-':r. ~ t ~ <".:0 '" <>: a... oe:: " . ., ~:...:. ~ - ~~ t:" \ i:::J ,""" "-J