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HomeMy WebLinkAbout94-01215 t..; " fV. I/) o - dJ \n """"" \'6 ........ . t ,. I -~; . '. " .:+:. .:<<. .:.:- .>>:. .:.;. .:.:. .:.:. .:c. .:c. .:<<. .:.:. .:.;. .:+;. .:+:. .:+:. .:+:. .:+;. .:+:. .:.:. .:+:. :-.:.~.' -:<<<:.:.>: .:.:.....:.> .:+}.:.:- <...._:~~ ~. .~~-~. ----- ~ ~ ..' ~ IN THE COURT OF COMMON PLEAS 8 w '.' OF CUMBERLAND COUNTY ~ STATE OF . PENNA. 8 .'. ~ ,'~ ~ 8 ,', ~ i '.' .. CHARI.ES I'E'TER BLOSER, w '.' '. . Plaintiff N (I.U15....C.rV,I r......l.9.9.!1... ~ '.' Vt~r~t1s $ ..KATHLEEN VELMA ..BLOSER, $ Defendant s .' ~ '.' ~ ',' DECREE IN DIVORCE Av~v~ \- q . 7---'" AND NOW. . .. .. .. . . . . .. .. ... . .. . . . . .. " -:-~. it is ordered and ~ '.' ~l ~ t. .', * decreed that......... .9!-l!\.~r,~? .P.~Tl>.R. .Bt.p.s.I;a................ plaintiff, and.................. KATHLEEN .VELMA. BLOSER............... defendant. ~ i ~.~ ~ are divorced from the bonds of matrimony. The terms of the Marital Settlement Agreement dated June 5. 2000 are incorporated herein, but ~e not mergep wit~ t~i~ decfe~. . Ihe court retains IUTlsdlctlon 0 the follOWing claims which have been raised of record in this action for which a final order has not yet been enter~dl "'-J \)'^-.iL w ',' " ~ $ ~ <:. ,'~ ~ ....?.............. W <:' ........ ....., -,............................. -.......... .... $ .........,.................. '/" / .' M ..' ~ /' ~~ /'.' r". ~~ :'" i~ , i~ ;'.' l~ . . . . .i .:+;. .:.:- -:+;. ':6;' .:.;. .:.;. .:.:. .:.;. .:.:. .:.:.' ~ !="' ny ~ ~ AlIe.l: .~ ~ <i ~I ~! ~~;.- .;.:~ ~:~:- .:.:. -:.;. .:.:- .:.:- -:.:- -:.:. .:.:. .:.:- -:.;.' .:.:. .:.;.' .:.;. .:.;. .:.:. .:.:. .:.;. .:.:- Prothonotary J, ~ $ ~ ,,~ * s ,', * ~ .,; ~ t '.' ~ ..~~ ~ ,'~ ~ i ~~ ~ ;tl ',' !' ~ ..' ~ " ~ ,,~ ~ W '.' w ~.~ ~ ~., w ~.~ i '.' .'. ~ ~ ',' ~ ... ~ '.' ~ '.' * ~ . .~.. .:. ~ . . , . .;. . . . . ~:/t/-aJ U ~ /~ 7i 4. .K)...:# flf"'4') ~~ /#~" ~ ~ . " , . " '. - " MARITAL SETTLEMENT AGREEMENT ;:)000 THIS AGREEMENT. made this S'(k day of ,Ju..~1 fl. -t-8S11. oetween CHARLES PETER BLOSER. hereinafter referred to as "Husband". and KATHLEEN VELMA BLOSER, hereinafter referred to as "Wife". WITNESSETH: WHEREAS. Husband and Wife were lawfully married on May 30. 1981 in White Oak, Pennsylvania; and WHEREAS, one child was born of this marriage, KYLE V. BLOSER. born March 27, 1990, hereinafter referred to as "Child"; and there are no other children born of this marriage; and WHEREAS. the parties have lived separate and apart since May 3D, 1993, and mutually desire to make provisions for the settlement of their property differences; and WHEREAS, disputes and difficulties have arisen between the parties, and it is the present intention of Husband and Wife to live separate and apart. and the parties hereto are desirous of settling their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the past, present. and future support and/or maintenance of Wife and Child by Husband; the settling of all matters between them relating to the equitable division of marital property; and. in general, the settling of any and all claims and possible claims by one against the other or against their respective estates; and WHEREAS. the parties have lived separate and apart since May 30. 1993, and mutually desire to make provisions for the settlement of their property differences; and WHEREAS, there have been no previous proceedings between the parties in any courts pertaining to the marital relationship, the dissolution thereof, and the support and maintenance of either party hereto or the child; however, the parties executed a Separation Agreement on June 24, 1993, which the parties agree shall stand in effect until this Marital Settlement Agreement is fully executed and filed with the Court of Common Pleas of Cumberland County, Pennsylvania; thereafter the parties agree that the Separation Agreement executed on of June 24, 1993 shall be revoked and void; and WHEREAS. Husband and Wife declare that each has had a full and fair opportunity to obtain independent legal advise of counsel of his or her selection; that Husband has been represented by Linda A. Clotfelter, Esquire and that Wife has been represented by Hubert X. Gilroy. Esquire. The parties represent and warrant that they have fully disclosed to each other all assets of any nature owned by each, all debts or obligations for which the other party may be liable in whole or part. and all sources and amounts of income. The parties acknowledge that they fully understand the facts, and they acknowledge and 1 ,. " '. accept that this Agreement, is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, with such knowledge and that 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. NOW THEREFORE, in consideration of the promises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. PERSONAL RIGHTS. It shall be lawful for each Husband and Wife at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The parties shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried, except as may be necessary to carry out the provisions of this Agreement. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign 'each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means in any manner whatsoever with him or her. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. MUTUAL RELEASE. Husband and Wife each do hereby mutually remise. release, quitclaim and forever discharge the other. for all time to come, and for all purposes whatsoever, of and from any and all rights. titles and interests. or claims in or against the property (including income and gains from property hereinafter accruing) of the other or against the estate of such other. of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former act. contracts, engagements or liabilities of such other or by way of dower or curtesy; or claims in the nature of dower or curtesy or widow's or widower's rights, family exception or similar allowance, or under the intestate laws. or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the law of Pennsylvania, any state, commonwealth or territory of the United States. or any other country, or the right to act as personal representative of the estate of the other; or any rights which any party may now have or any time hereafter have for past, present, future support, maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise; except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for breach of any provision hereof. It is the intention of Husband and Wife to give to each other, by the execution of the Agreement, a full, complete and general release with respect to any and all property of any kind of nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except 2 I, . ,. " . - all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of an provision hereof. It is further specifically understood and agreed by and between the parties hereto that each accepts the provisions herein made by the other in lieu of and in full settlement and satisfaction of any and all of their rights against the other or any past, present and future claims on account of support and maintenance; that it is specifically understood and agreed that the payments, transfers and other considerations herein recited so comprehend and discharge any and all such claims by each against the other, and are, inter alia, in full settlement and satisfaction and in lieu of their past, present and future claims against the other on account of maintenance and support, and also alimony, alimony pendente lite, counsel fees, costs and expenses, as well as any and all claims to equitable distribution of property, both real and personal, and any other charge of any nature whatsoever pertaining to any divorce proceedings which may have been or may be instituted in any court in the Commonwealth of Pennsylvania or any other jurisdiction, including any other counsel fees, costs and expenses incurred or to be charged by any counsel arising in any manner whatsoevp.r, except as may be incurred in connection with a breach of the Agreement as set forth hereinafter in paragraph 28. 3. RELEASE OF TESTAMENTARY CLAIMS. Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by last will and testament or otherwise, and each of them agrees that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would have become entitled thereto as if the decedent had been the last to die. Except as set forth herein, this provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's estate whatsoever, and is intended to confer third-party beneficiary rights upon the other heirs and beneficiaries of each. Either party may, however, make such provision for the other as he or she may desire in an by his or her last will and testament; and each of the parties further covenants and agrees that he or she will permit any will of the other to be probated and allowed administration; and that neither Husband nor Wife will claim against or contest the will and estate of the other except as necessary to enforce any breach by the decedent of any provision of this Agreement. Each of the parties hereby releases, relinquishes and waives any and all rights to act as personal representative of the other party's estate. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, for the purpose of enforcing any of the rights relinquished under this Agreement. 4. FINANCIAL DISCLOSURE. The parties waive their rights to require the filing of financial statements by the other, although the parties have been advised that it is their legal right to have these disclosures made prior to entering into this Agreement and by entering into this Agreement without reliance upon financial disclosure, the parties are forever waiving their right to request or use that as a basis to overturn this Agreement or any part thereof. 3 " . 5. INCOME TAX CONSIDERATIONS. Any transfers of property pursuant to this Agreement are transfers between Husband and Wife incident to their divorce and as such arc nontaxable, with no gain or loss recognized. The transferee's basis in the property shall be the adjusted basis of the transferor immediately before the transfer. The transfers herein arc an equal division of marital property for full and adequate consideration and as such will not result in any gift tax liability. 6. PENSION. PROFIT-SHARING. RETIREMENT. CREDIT UNION OR OTHER EMPLOYMENT-RELATED PLANS. The parties hereby acknowledge that Husband had the possibility of future retirement pay while he served in the military. The parties further acknowledge that Husband has since left the military and, as a consequence is not eligible for military retirement pay. In the event that Husband becomes eligible for military retirement pay in the future, Wife shall be entitled to her distributable share if any, pursuant to the rules and regulations of the armed services and the laws of the Commonwealth of Pennsylvania. The parties acknowledge that the Court of Common Pleas of Cumberland County, Pennsylvania shall retain jurisdiction should a determination of the military retirement issue be required in the future. * The parties hereto expressly waive and relinquish any right. claim, title or interest in any pension, profit-sharing, retirement, credit union or other employment-related plans in which the other has any interest by virtue of his or her past or present employment. whether vested or unvested, matured or unmatured, with the exception of Wife' s potential interest in Husband's future military retirement, if any. 7. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the age, health, station, amount and sources of income. vocational skills, employability, estate. liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for further acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property. including the contribution of each spouse as a homemaker. the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of the property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 4 * In the event Husband qualifies for any military retirement benefit in the future. Wife will be entitled to receive 50% of such benefits. k:it8 c..lb . " '.. 8. MOTOR VEHICLES. The parties agree that Husband shall have full and sole possession of the 1985 Volkswagen Jetta and shall be responsible for any costs related to said vehicle, to include insurance. The Wife shall become full and sole owner of the 1990 Volvo 240 wagon vehicle, except that Husband shall be responsible for the insurance payments for the vehicle until a decree in divorce is granted. On or before the date of the execution of this Agreement, the parties shall execute the titles to the said vehicles, if appropriate, so as to effectuate the transfer as herein provided. 9. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, 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 tangible personal property presently in his or her possession, and 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. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of each party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, and titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to their 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. DISTRIBUTION OF CASH ASSETS, STOCKS AND BONDS. The parties agree that Wife shall retain as her sole and separate property, free from any right, title or interest on the part of Husband, the entire balances in the bank savings and checking accounts titled in her name, and Husband shall retain as his sole and separate property, free from any right, title or interest on the part of Wife, the entire balances in the bank savings and checking accounts titled in his name. 5 c. " '. The parties shall retain as their respective sole and separate property any other depository or brokerage accounts, stocks, or bonds held in their respective individual names. 11. DEBTS. Husband represents and warrants to Wife that since the separation he has not, and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible, and he shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of such debt or obligation incurred by him since the date of said separation, except as otherwise set forth herein. Wife represents and warrants to Husband that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible, and she shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 12. REAL ESTATE. The parties acknowledge that they were the joint owners of the marital residence situate at 1 213 Ashmead Square, Belcamp, Maryland 21017, but that same has been sold. There were no proceeds of said sale as the property was sold at a loss to the parties. The parties acknowledge that Husband has paid the amount of the loss incurred by the parties. 13. INCOME TAX INDEMNIFICATION. The parties acknowledge that they have filed various joint state and federal income tax returns during the course of their marriage. The parties represent and warrant that all payments of taxes, penalties or interest shown as due on the said joint returns have been paid in full. Each party shall be equally liable for any taxes, penalties, interest, counsel fees, auditor's fees or accountant's fees which may hereafter be assessed or incurred in connection with any of the joint tax returns previously field by the parties. The parties agree to file joint federal and state income tax returns for any subsequent year during which they shall be Husband and Wife and entitled under the applicable laws and regulations to file joint returns, provided that such filing results in a lesser combined tax than would result from separate filing. Each party shall pay that proportionate share of the tax due as shall be attributable to his or her respective earnings or income and each shall indemnify and hold harmless the other against any liability for his or her own proportionate share of said tax. Any refund that is realized as a result of a joint return shall be divided proportionately between the parties. 14. DEPENDENCY EXEMPTION. The parties agree that they shall alternate annually the entitlement to the dependency exemption and other tax benefits for the Child, beginning with Husband utilizing same for 1999. Each party shall execute IRS Form 8332 in favor of the other party when necessary. 15. INSURANCE. The parties acknowledge that certain life insurance policies are in force on the lives of the parties with the other as beneficiary. The parties hereby 6 " " agree that the party in possession of a policy or policies may do with such as he or sho in his or her sole discretion deems proper including, but not limited to, the termination of said policies, or the designation of another beneficiary. Husband agrees to pay the premiums and to maintain in full force and effect insurance of the parties until a decree of divorce is granted. 16. CHILD CUSTODY. agree, respecting the custody, (hereinafter "Child") as follows: The parties hereto do hereby severally consent and control and visitation of their child, Kyle V. Bloser a. Wife shall retain primary physical custody of Child. The parties shall share legal custody of Child. The parties agree to consult with each other on such matters as major medical treatment and selection of schools for the Child to promote the best interests of Child. b. Husband shall be entitled to rights of partial custody, including overnight periods, weekend periods, and extended periods of partial custody during child's school holidays and vacation. This partial custody shall be subject to the condition that Child, until the age of sixteen (16), shall not be taken out of state or country unless (1) the Wife accompanies Child or (2) the Wife consents in advance. All other partial custody periods shall be mutually agreed upon between the Husband and Wife, with at least fourteen (14) days advance notice. Further, such exercises of custody privileges by Husband shall not conflict nor interfere with the school schedule of Child nor with bona fide plans previously made for his activities, and all such custody periods shall be exercised with due regard to the health and general welfare of Child. c. Wife understands that Husbands current relocation to Arkansas and any subsequent residence may make full exercise of these custody rights impractical. d. Husband and Wife agree that the failure to exercise any portion of these custody rights shall not constitute a waiver of any future custody rights, but neither shall such unused custody rights accumulate. 17. CHILD SUPPORT. Husband agrees to pay to Wife for the sole support and maintenance of Child the sum of Five Hundred Twenty-Three and 00/100 Dollars ($523.00) per month paid directly to Wife. Said payments shall continue until Child becomes emancipated. With respect to Child, an emancipation event shall occur or be deemed to occur upon the earliest happening of any of the following: 7 " " a. Reaching the age of twenty-one (21) yeors; or b. Marriage by Child; or c. Death of Child; or d. Legal adoption of Child; or e' Entry of Child into the Armed Forces of the Unltod Stotes: or f. Engaging in full time employment before attaining the age of twenty. one (21) years, except and provided that Child's partial omploymont shall not bo deemed an emancipation event and while a student, Child may engage In full-time employment during summer vacations end summer periods without emancipation taking place. Should Child terminate full time employment before the age of twenty-one (21) years, emencipatlon will not be deemed to have taken place, except that the Husband will not be liable for support for the period which Child was so employed; however, g. In the even Child becomes handicapped to the extent of being physlcelly or mentally incapable, as opposed to unwilling, to support himself or herself, Child shall not be considered omonclpated under the provisions of this paragraph. h. However, notwithstanding the procedlng sentence In subparegraph (a), above, and if no other emancipation event has occurred, Husband sholl continue to provide support until Child's twenty-third (23rd) birthday if Child is pursuing a continuous course of college or vocational training as a fully matriculated student at an accredited Institution of higher learning. The parties further acknowledge that Child support required by this Agreement is subject to modification only by 0 court of competent jurisdiction upon 0 showing of a substantial change of circumstances. Upon the death of Husband ell child support peyments shell cease. 18. SPOUSAL SUPPORT. Husbend shall pay to Wife for her support and maintenance the sum of Throe Hundred Twenty-Seven and 00'100 ($327.00) per month. Said payments will continue until the death of the Husband, the death of Wife, or the remarriage of Wife or cohabitation of Wife, whichever shall occur first; or until further order of the Court. Husband agrees to contract for insuronce on the life of Wife. Further, Husband agrees to pay all premiums associated with this policy. The only beneficiary of this policy shall irrevocably be the porties' son. The minimum amount of the policy shall be One 8 . . '. '. Hundred Thousand and 00/100 Dollars ($100,000.00). Husband agrees to provide Wife with a copy of each year of proof of insurance policy being in effect and in force. 19. MEDICAL INSURANCE. Husband agrees to include Child on his medical insurance obtained through his employer. If the medical expenses of Child are not fully covered by Husband's medical insurance, the parties agree to pay one-half the balance of the medical, dental or optical expenses not covered by medical Insurance, upon the Wife's providing to the Husband copies of the medical bills. However, if Husband cannot provide medical insurance through his employer, the parties shall share the costs of insuring Child. Wife shall be responsible for her own medical, dental, hospital and prescription drug expenses. 20. COUNSEL FEES AND COSTS. Husband and Wife each agree to pay and be responsible for their own attorney' s fees and costs incurred with respect to the negotiation of this Agreement and the divorce proceedings related thereto. 21. ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES. Both parties accept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now or hereafter hllve against the other for alimony, alimony pendente lite, counsel fees or expenses, or for any other provisions for support end maintenance before, during and after the commencement of any proceedings for the divorce or annulment between the parties. 22. DIVORCE. A Complaint in Divorce has been filed to No. 94 - 1215 in the Court of Common Pleas of Cumberland County, Pennsylvania, and either party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an affidavit evidencing their consent to the divorce, pursuant to Section 3301 (c) of the Divorce Code. In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees, resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a consent form and that a legal or equitable action may be brought to compel him or her to execute a consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. 23. RECONCILIATION. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. 24. INCORPORATION IN FINAL DIVORCE DECREE. The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties. Any Court having jurisdiction shall enforce the provisions of this Agreement as if it were a Court Order. This Agreement shall survive in its entirety, resolving the spousal support, child support, alimony, equitable distribution and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania, and no 9 '. court asked to enforce or interpret this Agreement shall In any way chango tho terms of this Agreement. This Agreomont may bo onforcod independently of eny support ordor, divorco decreo or judgment and its terms shell toke precedenco over samo, remaining the primary obligation of each party. This Agreemant sholl remain In full forco and effect regardless of any change in the marital status of 1he por1ies. It is warranted, covenantod and reprasented by Husband and Wifo, each 10 the other, that this Agreement is lawful and anforceablo, and this warranty, covenant and representation is made for the specific purposo of inducing the parties to e>:ecu1o tho Agreement. 25. DATE OF EXECUTION. The "dato of execution" or "execution date" of this Agreement sholl be dofined as tho date upon which it is oxecuted by the parties if they have each oxocutod tho Agroement on the some dato. Otharwisa, tho "dato of execution" or "cxecution date" 01 this AgrCOmcnt sholl bo defined es the dote of execution by the party last exccutlng the Agreemont. 26. FULL DISCLOSURE. Each party asserts that he or she has made or shall make a full and cemple1e disclesuro of 011 the roal and personal property of whatsoever nature and whoresoever located belonging in any way to each of them, of all debts and encumbrances incurred In any manner whatsoever by oach of them, and of all s'ources and amounts of incomo received or roceivable by ench party. 27. ENTIRE AGREEMENT. This Agreomont contains tho entire understanding of the parties, and thero ero no reprasontotlons, worrantlos, covonants or undertakings other than those oxprossly sot ferth heroin. 2B. BREACH. If olthor party broochos any provision of this Agreement, the other party sholl havo the right, at his or hor oloctlon, olthor to sue for specific performance or for damagos for such broach, and tho porty broaching this Agreoment shall be responsible for legal foos and costs incurrod by 1ho othor in onforcing his or her rights under this Agreemant. 29. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shell be valid unless mode in writing and signed by both of the parties. 30. ADDITIONAL INSTRUMENTS. Each of tho parties shall from time to time, at the request of the ether, oxecute, acknowledgo, and deliver to the other party any and all further instruments, titles, or other documents that may be reasonably required to give full force and offect to the provisions of this Agreement. 31. SEVERABILITY. If any term, condition, clause or provision of this Agreement sholl be determined or doclared to be void or invalid in law or otherwise, then only that term, condition, clause or provision sholl be stricken from this Agreement, and in all other respects this Agreement sholl be valid and continue in full force, effect and operation. 10 '. " -. 32. WARRANTY. Husband and Wife again acknowledge that they have each read and understand this Agreement, and each warrants and represents that it Is fair and equitable to each of them. 33. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 34. PENNSYLVANIA LAW. The parties agree that the terms of this Agreement and any interpretation and/or enforcement thereof shall forever by governed by the laws of Pennsylvania. IN WITNESS WHEREOF, and intending to be legally bound hereby, the parties hereto have hereunto set their hands and seals the day and year first above written. This agreement is executed in duplicate, and each party hereto acknowledges receipt of a duly executed copy thereof. WITNESS: ~ ~~ LES PETER BLaSER ,Ifh?fh /}) /rljl, }/rMll ~fJ)') KATHLEEN VELMA LOSER 1 1 '. " " STATE OF VI~I\lM.s'lLl/A,J IA COUNTY OF CUMREI2I..A,Ji"I SS. On this tf+'" day of ~ob~r ,1999, before me, the undersigned officer, personally appeared CHARLES PETER BLaSER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL HElm E. RASMUSSEN, NotaIy N111c CalT(I Hill Borough, Cumberland County My Conrnlsslon Expires Aug. 2, 2003 dJJ4/2 Notary Public - . STATE OF ~~l.}IU(l A.A 1. Or.., COUNTY OF C J.J.' W o~ .......J SS. 0" ,h;, ~ d., of {.. r? '. ~ b.fo," m.. tho uod''';Oood offl.". personally appeared KATHLEEN VELMA BLaSER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. uzJ~ 12 Notarial Seal Bridget Ann Corcornn, Notary Public Cailisle BarD, Cumberland County My Commission e'pires June 10, 2002 , , " '. SOCIAL SECURITY INFOR:\IA nON SHEET PURSUANT TO 23 Pa.C.S.A. SECTlO:-l430.l, I (3) (3) ALL DIVORCES :\IUST INCLUDE THE PARTIES SOCIAL SECURITY i\l):\IBER PLEASE FILL l:-l THE APPROPRIATE INFOR:--lA TlO~ AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: June 14. 2000 DOCKET NUMBER: 1215 CIVIL 1994 PLAINTIFF/PETITIONER SS# 205-52-8600 NAME: Charles P. Blaser DEFENDANT/RESPONDENTSS # 211-46-9138 NAME: Kathleen V. Bloser '. '. - CHARLES PETER BLOSER, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 1215 CIVIL 1994 I I I CIVIL ACTION - LAW IN DIVORCE VB. KATHLEEN VELMA BLOSER, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint was filed on March 11, 1994. 3. Date and manner of Service of the Complaint: March 21, 1994, by Certified Mail, Restricted Delivery as evdienced by the Affidavit of Service filed on June 13, 1994. 4. The Plaintiff's Affidavit of Consent was executed by the Plaintiff on June 14, 2000, and filed on J..I'lt. l~ , 2000. The Defendant's Affidavit of Consent was executed on J\l1'i A~ , 2000, and filed on Al.1.~ It S t I , 2000. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on Jl.Lr'I!. 1'4 , 2000, and said waiver was filed on ..,JIUH III , 2000. Defendant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on Jul", J. 3 , 2000, and said waiver was filed on ~III~-t:' I , 2000. 6. There are no related claims pending. The parties have resolved all related issues by written agreement. . ,. I,'. :~:_. . j. '.'f _,,":1;t,.., _: ~ '. .. .. .: Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: 0./,,1 n n ..., , nda A. torney I. 0 . No. 64 Trindle Road amp Hill, PA 17011 (717) 763-7613 .- ," (") ...... ',- .. .. ...;-~ 0'. ; . . , .J ;,) , . ;.i . , <._' l".) ,. ~ '. .... Iii ~ ili ~ ~ ~ ~ ~ ~ ~ CJ i"" :;~~E.I u '" a: U. :: lls o F:' ffi c _ E. uo(- 1S Ii: li! ~ !:! it ~ i ~ ~ ... _ :i ~ ~ i i [ .' .... - '. " CHARLES PETER BLOSER, plaintiff VB. I IN THE COURT OF COHKON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I I I I I CIVIL ACTION - KATHLEEN VELMA BLOSER, Defendant NO. / dlb LAW IN DIVORCB Q~/'74- Divorce-3301(c) - gO Day No-Fault NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BBEN 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, Cumberland County Court House, Carlisle, 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 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 CUMBERLAND CO COURTHOUSE 4th FLOOR 1 COURTHOUSE SQUARE CARLISLE PA 17013 3387 (717) 240 6200 '. '. . CHARLBS PBTBR BLOSBR, I IN THB COURT 01' COMKON PLBAS 01' plaintiff I CUKBBRLAHD COUNTY, PBNNSYLVANIA I va. I CIVIL ACTION - LAW IN DIVORCB I KATHLBBN VBLMA BLOSBR, I NO. Defendant I I Divoroe-3301 (0) - 90 Day No-Pault AVISO PARA DBPBNDER Y RECL~ DBRECHOS USTED SA SIDO DEHANDADO EN LA CORTE. si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud. Se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por las Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja 0 compensacion eclamados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimonialas esta disponible en la oficina del Prothonotary, en la Cumberland county Court of Common Pleas, 3 South Hanover Street, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIKENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO PINAL DB DIVORCIO 0 ANULAKIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECL~ CUALQUIERA DE ELLOS. USTED PEBE LEVAR ESTE PAPEL A UN ABOGADO DE INKEDIATO. SO NO TIBNE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAKE A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY COURT ADMINISTRATOR Cumberland county Courthouse Third Floor Carlisle, PA 17013 (717)249-1133 or (717)697-0371 .'--_....~......~..,.. -- _..'_.~-'''' '. .-. '. . . . va. I IN THE COURT OF COMKON PLBAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW IN DIVORCE I I NO. I I Divorce-3301(C) - 90 Day No-Fault CHARLES PETBR BLOSER, plaintiff KATHLEEN VELMA BLOSER, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is CHARLES PETER BLOSER, who currently maintains his residence at 206 N. Enola Drive, Enola, PA 17025. 2. Defendant is KATHLEEN VELMA BLOSER, who currently resides at 2812 Grover Avenue, McKeesport, Allegheny County, Pennsylvania 15132. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and the Defendant were married on May 30, 1981. 5. There have been no prior actions of divorce or for annulment between the parties. COUNT I No-Fault - Section 3301(0) Plaintiff v. Defendant 6. The marriage is irretrievably broken. . . . ., '. 7. The plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. plaintiff requests your Honorable Court to enter a Decree of Divorce. WHERBFORB, Plaintiff prays this Honorable Court to grant the relief requested. Respectfully submitted, Dated: March 7, 1994 9 , LAW OFFICES 3464 Trindle Ro Camp Hill, PA 17 11 Atty. 10 No. 52987 , -.. .~...~_. . ~ '. '. . ,. CHARLES PETER BLOSER, plaintiff IN THE COURT 01' COMMON PLEAS 01' CUHBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE va. KATHLEEN VELMA BLOSER, Defendant NO. Divorce-3301(C) - 90 Day No-Fault VERIFICATION I, the undersigned, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: :2~ rd> 9y (J~~ CHARLES PETER BLOSER ~ --- ...... I'- "':2"" :,... ~ :."~~ :::I:: I.., - ~ a.- oJ. 'f:. "1"\' -.... ~ ~ ~ :c: ~ ,e\ ~~\c-). "~ ~ C\J) S? lr) ~ -....;:. ......-. } ~ = -, = .~' ~ ~ ..,~ ~ A", <::; ~. ;$ '~' ') '-J C\..J C-J~ --- - r<'\ ~ r{) Ii) ~-Iw ~vf;; c:.J ~ ,~ ," '. .. , . .. CHARLES PETER BLOSER, plaintiff vs. KATHLEEN VELMA BLOSER, Defendant .' I I I I I I I I " '. ,. ... IN THE COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1215 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT 01' SERVICE I, John D. Briggs, Esquire, counsel for the Plaintiff, Charles Peter Bloser, do hereby affirm that a true and correct copy of the return receipt of the Complaint in Divorce sent by certified Mail, Restricted Delivery, Return Receipt Requested, which return rec~ipt appears to contain the signature of Kathleen Velma Bloser, is set forth below. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. I ~ SENDER: I. ~ . Complett I1lma 1 tN:t/or 2 fa,. 4EIdition.lltrvlclI. J ~ . Complete Itlm, 3. end 4. & b. . .\.... r: . P,ln1 your Mme end addl'" on tht"'vi;,. of thl. 'orm 10 thlt WI Cln II filum thl. Clrd to you. . .' '1 . >I!! . Anlth thl. 101m 10 Ihe front of t~ mlifpl,c:..t. 0; on the back If 'PIC' dotl not permit. " ",.;" t')o" .. " .' .. .s . Wrl,,"Retum R,cllpt A'~'.'"4!' on tl)~ ~Wpl.C1I below the .ttlclt number . The R'turn R'cllpt win thow ,!\<Whom \ht It1lcle w.. dellv.red and tht dill a d,Uv."d. ,..,' ," . . II 3~~~I~~d;~~d Vel..m{f BwseR IE c9'6/Q lnRDlJeR (:)uewe I ~ (fle.~I?E5PD~ PA /6/'1;2 a: c c cC I ii 5 . I a: 6. Slgnalura IAganll ~ 1 ii 1\ I III . 1111 \1 \\1 Ii lili \ I ,; PS Forin . D.c.mb1jEtl\JlR~" DOMESTIC RETURN RECEIPT , - .... ~. ..' ....-- .'~ . ('J Dated: 6/2'/Q1 I also wish to receive the following servlcBI (for an extra W f..l: .~ ,. 0 AddrOlsaa's Addrass j 2. )(R.Slrlctad D.llvary Consult oltmllster for fee. 48. Article Number "- ~ a. 'ii .. a:. E a 4b. S.rvice Typa &! o R.glstarad - 0 Insur.d CD C.nlflad 0 COD .s o Expr all 0 R.lurn R.c.lpl for !I M r hi.. 7. Oal. of Oallva"t., (. ~ .2 . . ... "3'-.-L. - ( !: 6. Addras....s Addr... (Only f r.quOlI.d 1 and fa. I. paid I ~ ...- / ~ L. ;fa D. B ~ W OFFICES OF Atty. 10 No. 3464 Trindle t Camp Hill, PA 17011 (717) 763-7613 . DIEHL . . " '. " .' . . .' v.. I I I I I I I IN THill COURT 01' CODON PLIIA8 01' CUKBIIRLAHD COUNTY, PIIHHSYLVAIlIA NO. 94-1215 CIVIL TBRK CBARLIIS PIITBR BLOSBR, plaintiff IATBLIIIIN VIILHA BLOSBR, Defendant CIVIL ACTION - LAW IN DIVORCII CBRTII'ICATB 01' SBRVICB AND NOW, this 8th day of June, 1994, the undersigned hereby certifies that a true and correct copy of the foregoing AFFIDAVIT OF SERVICE was served upon the opposing party by way of united States First Class mail addressed as follows: Kathleen Velma Bloser 2812 Grover Avenue McKeesport, PA 15132 cli-rC~ Helen E. Rasmussen, Legal Secretary LAW OFFICES OF CRAIG A.. DIEHL 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 ..".. c:n - - .J. '->,- -, 'J "J rT) '" .." .-) I~!m ~iU! fiB! .. l!i g B~~..~ ~ll~~ :t~g!: ~l~e " . ..- - .' , . . :. . .' '. '. " . . '. .. '. . .. -' ..... ~. CHARLES PETER BLOSER, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 1215 CIVIL 1994 I I I CIVIL ACTION - LAW I IN DIVORCE va. KATHLEEN VELMA BLOSER, Defendant APFIDAVIT OP CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 11, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and 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 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: N "]Vuo.:) C~~ BLO~~ Plaintiff - .... , , " ',-" t.., ..... b .:;.\ ! --: ,- P, .. .,- .; .~ :".-: ,', " t:; ~l -- ..l .":~ 'f.') ~J :< -;.:. '.C. .:,~ ," " - - , . . :::- <:':) t.".J .~) CJ oJ !!~ i51u1~ is ~ ~ C /I! ~ t!J "~~ ~ ~ ~ 1:0. to) : 115 I&. ~ o E. e~~~~ IE ~if:e o ~::I ~ :r; ~;: ~ :5 i~E. - ...,. ...... .' . . " , . -.. 'It '. . . ._.,-~ ~ ..... . CHARLBS PETBR BLOSBR, Plaintiff I IN THE COURT OP COMMON PLEAS OP I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO, 1215 CIVIL 1994 I I I CIVIL ACTION - LAW I IN DIVORCB V8. KATHLEEN VELMA BLOSER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER I 3301 (C) OP THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: lc.jJU IJ cD l~ ------=:;>- CHARLES P. BLOSER, Plaintiff l::'~"_,~ .." .~~. u~ .... ..: ...~ (-- .. ~-.-:: u co . ..-r- \ -') -) :-'- " ,. 1 -. r w~ . ~~: j ~~ \~ In , ! . , "'-.. -,< . , Itl.i _.1 -j I '"" ,. " . (? :5 .. CJ U ---~. ...- - , . " , .J Iii ~ i5 ~f~ ~ m ~ ~ Cl~ClJ::" ~~~E.! U .. a: - Q. II. - III o ~ 130- E. u<- ~ lElil~t!u; o ~if~ 3; z ::i ..... :5 ii[ ,- ""-' ~ ....0 .. , . va. I IN THE COURT 01" COMMON PLEAS 01" I CUMBERLAND COUNTY, PENNSYLVANJ:A I I I NO. 1215 CIVIL 1994 I I I CIVIL ACTION - LAW IN DIVORCE CHARLES PETER BLOSER, Plaintiff KATHLEEN VELMA BLOSER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 11, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and 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 18 Pat C.S. Section 4904, relating to unsworn falsification to authorities. Date: $3 /ill ~I (/ ,- '.il ..... i..-'-: ('~ .. - .' ~; <) \ ~.. :j ~ ,""- _..1 '- '..) -,:~P ! ..... ... . ,. CHARLES PETER BLOSER, Plaintiff I IN THE COURT OP COMMON PLEAS OP I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 1215 CIVIL 1994 I I I CIVIL ACTION - LAW I IN DIVORCE V8. KATHLEEN VELMA BLOSER, Defendant WAIVER OP NOTICE OF INTENTION TO REQUEST ENTRY OP A DIVORCE DECREE ~ER S 3301 ecl OP THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pat C.S. ~ 4904 relating to unsworn falsification to authorities. Date: 23 kJ IJZJ J Ni/ziI.L4;/ ( l;}zi-u u KATHLEEN V. BLOSER, Defendant '-=) \ . ~ \ " ... -":-:..' . , e.&.:' ;tJ:: .~ '~ '.' .:' '.J . . .. IN THE COURT 01" COMMON PLEAS 01" CUMBERLAND COUNTY, PENNSYLVANIA CHARLES PETER BLOSER, I Plaintiff I I NO. 94-1215 CIVIL TERM VB. I I KATHLEEN VELMA BLOSER, I CIVIL ACTION - LAW Defendant I IN DIVORCE NOTICE OF ENTRY OF APPEARANCE TO THE COURT: Please enter my appearance on behalf of Plaintiff, Charles Peter Bloser, in the above-captioned matter. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: ---.l}UblJ<':'T /q I crq7 , \ ~ef re C. Go , Esquire Atto ey I.D. No. 78732 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Dated Auov", \9. ,0,'19- s C. Goss, Esquire or ey ID No. 78732 34 Trindle Road Camp Hill, PA 17011 (717) 763-7613 .- IN THB COURT OF COMMON PLEAS OF CUMBBRLAND COUNTY, PENNSYLVANIA CHARLBS PBTBR BLOSBR, Plaintiff VB. I I I I I I I NO. 94-1215 CIVIL TBRM KATHLBEN VELMA BLOSBR, Defendant CIVIL ACTION - LAW IN DIVORCB CERTIFICATB OF SERVICB AND NOW, the undersigned hereby certifies that on the date hereof, a copy of the foregoing NOTICE OF ENTRY OF APPEARANCE was served upon the opposing parties by United States First Class mail, postage prepaid, addressed as follows: Hubert X. Gilroy Broujos, Gilroy & Houston, P.C. 4 North Hanover Street Carlisle, PA 17013 LAW OFFICES OF CRAIG A. DIEHL L:,..~: ~ C) i; ,..: 1-- .. ... w0 .3 ?5-1: 01".. ( -/ liS :0:.: ';..;;r -r ,~. (.~ ;;j 9f- Cl :'.;~) 0:. wL. ('I ....... -..... ~H <.~ > I(a i~ ::::; ~~u.. '"" ,. H. I- :.:l C .;;- f..)