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HomeMy WebLinkAbout94-01555 ~ C> )1 j In l() lc) t. -,--- ~ ~j , . . . .' . .. ~:...,. olCo. ':c- .;c. .:+;-. .:.:. ,:+;-..;c. olCo .;c~ .:c. .:.:' <.:. .:<<, .:.:- .:.:. .~:- .:<<. .:.:.;. .,:c,;":.X;':+;-::':.:-..':<<' .:.:. ':""':C-:o(4C(~ ~ S $ $ ~ 8 ~ ~ ~ ~ ~ ~ . ~ 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF * PENNA. :1 :; N (). 9.4.-,,15.5.5..... ................. 19 i '.' ... .MIC.HAEL.. .J..... DUFF.. " ~ ~ Plaintiff. VerslIs , ;i ,I : ............ -, q :i I ,.~ ~ ~.~ ~ .....SHERIE...L.....DUFF... . ...... Defendant. ,', ~ .~~ w '" ~ ~.' DECREE IN,It- 1)111 D I V 0 R 'i:k~ C(:Ol(rl" I , AND NOW,.. ... , .....~............ 19....... it is ordered and decreed that ......,.....~:. ?,~~~. . . . . . , , . . , . , . , . . . . . . . . . . , . . '. plaintiff, and, .!?II.E.lnJi:. ~'" .J;l9!'.r:...."...........,.,...,..........,..., defendant, are divorced from the bonds of matrimony. i '.~ ~ ',' ~ ,; ~ ~ ~ ~ 8 ~ ~ '.' 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; Ix ) Cf\J ~ .....................,~................................................., ~ ..' i '.' ~ ,.~ ~.'. , , _. ~ ~ .:+:. .:+:. .:.:- .:.:. .:.:- .:+:. .:+:. .:.:. .:+:. .:+:.' ~ ~.' ~ " ......................... .....0...... .0.........0. ...... r01 p ~ .... t t. . ) J/ /J-.v' ~~. .~~~~~~._~ . . - "'<.?- ~4::1 "1 ~~ Prothonotary ," ~ ~ .' ~ ~ ~ ---._.~ .. - /.;t:. .~:. .:.:. .:+:. .:+;. .: .' ~ 8 $ ~ ~ ~ ~ . " ~ I' ~ g i '.' ~ ~ '.' w ~~ ,., ~ ,', ~ !l! ~.. ~ $ ~ ',' i '.' ~ .', ~ ~ ~ '.' ~ * e ~ ~ . I . : , 7/7/~s~ (u, ~Il ~ ~ /1. ~ "1/7/95" Ylnfu/H.~ 7$ ~. ., . '- _. "..~._OA. _... ..~', ....,' 0' '. .. ... . LAW OPPlCES . JOHNSON, DUFRE. STBWART {I WEIDNER . . .' Telepho~1 (111)16104540 Tlle.opt.. (111) 16103015 301 Marktl Stre.t P. O. Box 109 Lcmoync. Pcnruylvonla 1104J.0109 ,. 009'71~\I~r26. .1994/DWDIMHI38367 t~~1f THIS DIVORCE SETTLEMENT AGREEMENT, made this 2!i day of ::;. .1 1994, by and between SHERIE L, DUFF. of Camp Hill. Cumberland County. Pa sylvania (hereinafter called "Wife"I, and MICHAEL J, DUFF, of Lemoyne. Cumberland County. Pennsylvania (hereinafter called "Husband"l. WIT N E SSE T H: WHEREAS, Husband and Wife were lawfully merrled on September 16. 1990; and. WHEREAS. differences have arisen between Husband and Wife the consequence of which they live separate end apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their property rights and obligations growing out of their marital relationship; and WHEREAS. the parties desire to confirm their understanding in writing. NOW, THEREFORE, the parties hereto. intending to be legally bound hereby, agree as follows: 1. SeDaratlon. The parties hereto heve been separated since February 26. 1994 and have not cohabitated since that time. It shall be lawful for each perty at all times hereafter to live separate and apart from each other at such place or places as he or she may from time to time choose or deem fit. 2. Interference. From the date of their signing this Agreement. each party shall be free from Interference. authority and control of the other. as fully as if he or she were single or unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other. or compel the other to cohabitate with the other or in any way harass 00957!'OOOClIiScJllC!"bcr 26, ,t994/DWDIMH/38367 . or malign the other, or in any other way interfere with their peaceful existence, separate and apart from the other. 3. Mutual Release. Subject to the provisions contained in this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, edmlnistrators and assigns, forever 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 a cause or causes of action for divorce, or all causes of action for breach of any provisions of this Agreement. Further, each party, subject to the provisions contained in this Agreement, releases and forever discharges the other from any and all claims one may have against the other arising out of. this matrimonial action, including, but not limited to alimony, alimony pendente lite, spousal support, equitable distribution, counsel fees, costs and expenses. 4. Waiver of Claims Aoalnst the Estate. Except as herein 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 now have or hereafter acquire under the present or future law of any jurisdiction to share In the property or the estate of the other as a result of the marital relationship, including, without limitation, dowry, courtesy, statutory allowance, widow's allowance, homestead rights, right to equitable distribution, rights to take in intestacy, right to elect against the will of the other, and right to act as administrator or executor of the other's estate. Each party will, at the request of the other, execute, acknowledge and deliver any and all Instruments that may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 5. Division of Personal Prooertv. Except as may be set forth herein, each of the parties hereto has divided between themselves, to their mutual satisfaction, all items of tangible and Intangible marital personal property, including household furnishings and other similar property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each egree to sign, upon request, any titles or documents necessary to give effect to this paragraph. The 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 .:. . "..r ";""-~ fl1liIalUI:",". l -,.<~v.~" 009;7I.ooooi/~27..I\l94IDWDIMHl3i367 . the signing of this Agreement, and In the case of Intangible personal property, If any physical or written evidence of ownership, such as a passbook, check book, policy or certificate of insurance or other similar writing is In the possession or control of the party. 6. Division of Real Prooertv. Wife agrees to transfer all of her right, title and Interest In and to the real estate situated at 606 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, now titled In the name of Husband and Wife as tenants by the entireties to Husband. In consideration for this conveyance, and as a complete and final settlement of all claims for equitable distribution between the parties, Husband shall pay to Wife the sum of Five Thousand Six Hundred Dollars ($5,600.00), and remove Wife's name from all liens or mortgage obligations in which she is a party, secured by this real property, within sixty (60) days hereof, or Wife may at her .sole option, elect to declare this Agreement null and void. t..J..f" C.<'''''IJ;uI~Jg'.: ;t*G.ec/' 41 IW;J,t-."....s..."'d rw.t H<-l",c}NcI 'j)r:;/irj.> c...S2,'"o:.J4.tJtI). /f't" kh(c.vrC(; (),..u.d c..:J..4c ~5 'n.,o"u ,,-"'tllL!:....J O"qo l-I""I.rD./'lt2.J jJ"lLc.....~ (1:I'o~.O,'1 Wife has execured a Cuit Claim -Deeer conveYing all o her Intefest in the marital property to Husband, which said Deed shall be held in escrow by Wife's attorney until Wife has been paid Five Thousand Six Hundred Dollars ($5,600.00) and her name removed as an obligor to PNC Mortgage Company. Wife's attorney may release a copy of said Quit Claim Deed to Husband's attorney or PNC Mortgage Company In order for the mortgage company to process the removal of Wife's name from the current mortgage obligation. Husband agrees to take all steps necessary to remove Wife's name from any legal obligation, mortgage, note or other debt secured by her interest in said real property. Upon Wife's receipt of a release executed by PNC Mortgage Company and the removal of her name from any mortgage obligation recorded at the Cumberland County Recorder of Deeds Office to the satisfaction of Wife's attorney, Wife shall direct her attorney to release the original Quit Claim Deed to Husband's attorney. Upon payment of the aforesaid consideration and the complete removal of Wife's name from any obligation encumbering said real property, Wife acknowledges that she shall then have no claim, right, interest or title whatsoever in said real property and agrees never to assert any such claim to said property. 7. Additional Instruments, Each of the parties shall, on demand, execute end deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary on insurance policies, tax returns and other documents and do or cause to be done any other act or thing that may be necessary . . . 009~7FOOOOII~17.1994IDWDIMH/38367 . or desirable to effectuate the provisions and purposes of this Agreement. If either party falls, on demand, to comply with this provision. that party shall pay to the other, ell attorneys fees, costs and other expenses reasonably Incurred as a result of such failure. 8. Debts and LIabilities. Husband and Wife hereby represent end warrant to the other that he or she has not Incurred any debts or liabilities or made any contracts for which the other or his or he estate may be liable, except as stated in this Agreement, If either party has Incurred an individual obligation during the term of the marriage, that party shall be responsible to discharge said obligation and hereby agrees to Indemnify, defend and save the other spouse harmless on account of said obligation. 9. Warranty as to Future Obliaatians. Husband and Wife each covenant, warrant, represent end agree that with the exception of the obligetlons set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall Indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the date of execution of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 10, After Acaulred Personal ProDerty, Each of the parties hereto shall hereafter own and enjoy, independent of any claims or right of the other. all items of personal property, tangible or intangible. hereafter ecquired by him or her, with full power in him or her to dispose of the same as fully end effectively, In all respects and for all purposes, as though he or she were unmarried. 11. ReDresentatlon by Counsel, The provisions of this Agreement and their legal affect have been fully explained to the parties by their respective counsel, Wife has employed and had the benefit of David W. DeLuce. Esquire. as her attorney. Husband has employed and had the benefit of NoJfa F. ~\) Blair, Esquire, as his ettorney, Each party acknowledges that he or she has received independent, legal advice from counsel of his or her selection and that each fully understands the facts and has been fully informed as to his or her legal rights and obligations and each party acknowledges and accepts that this Agreement Is. fair end equitable, and that it is being entered into freely and voluntarily. .....l. .:a ,1">" 009571-0000 IISqitcmbcr 26. .1994/DWD/MH/38367 , 12. Divorce. Husband has filed e divorce action under Section 3301 (c) or 3301 (d) of the Pennsylvania Divorce Code In the Cumberland County Court of Common Pleas on March 29, 1994 to docket number 94.1555. The parties agree and acknowledge that their marriage is Irretrievably broken, that they do not desire martial counseling, and that they both consent to the entry of a Decree in Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. Act 26 of 1980, as mey be amended (hereinafter referred to as the "Code"). Accordingly, both parties agree that at the time all obligations or requirements of the parties pursuant to this Agreement have been completed, both shall exacute such consents, effldavlts or other documents and 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 Section 3301(c) of the Code. 13. Effect of the Divorce Decree, The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the parties hereto that this Agreement shall create contractual rights and obligations entirely independent of any Court Order and that this Agreement may be enforced by contract remedies in addition to any other remedies which may be available pursuant to the terms of this Agreement or otherwise under the Pennsylvania divorce laws. The parties egree that the terms end provisions herein may be incorporated and made part of any Divorce Decree entered between them. Said Agreement shall not merge with. but shall survive the Decree in Divorce, and will be incorporated for the purposes of enforcement and confirmation of the legal duties and obligations required herein. 14. Bank Accounts. Certificates. Insurance Policies. Pension Funds and other Assets. Each party shall retain any individual retirement account In his or her name, Each party shall retain es his or her own property. any pension. stock, savings or other plan through his or her piece of employment, or otherwise, whether vested or non vested. Each party shall be and remain the sole owner of any other asset in his or her control not specifically covered by other provisions in this Agreement. Should it become necessary. each party agrees to sign any other titles or documents necessary to give effect to this section upon request of the other party. Each party shall be and remain the sole owner of any other asset in his or her control or name not specifically covered by the provisions in this Agreement. 009571-OOooIlScpicmbcr26. 1994/DWD/MH/31361 15, Breach. If either party breaches any provision of this Agreement, the other perty shall have the right, at his or her election, to sue for damages for such breach. The party breaching this Agreement shall be responsible for the payment of all legal fees and costs Incurred by the other In enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 16. Modification and Waiver, Modification or waiver of any provision of this Agreement shall be effective only If made In writing and executed with the same formality as this Agreement, The failure of either party to Insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 17. Severabilltv. If any provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 18. DescrlDtlve Headlnas. The descriptive headings used herein are for convenience only, They shall heve no effect whatsoever in determining the rights or obligations of the parties. 19. Successors and Asslans, This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators. assigns and successors in Interest of the parties, 20. Governlno Law, This Agreement shall be governed by and shall be construed In accordance with the laws of the Commonwealth of Pennsylvania. 21, Entire Aareement. This Agreement contains the entire understending of the parties and there are no representations, warrentles, covenants or undertekings other than those expressly set forth herein. t.:..-,,~._..,. . . 009"I-Ocioot~r26. 19904/DWDIMHI31367 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. j j", -/ '~~_ISEALI Sherie L. Duff 2Zf(hpBU/fSEALI Michael, ff (-. ''''''~;-.e,o~.'~i''4:l'!"/~ 009511-OOool/scPicmbcr 26, 'l994/DWD/MHI31367 . . COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~,v..\ I - Q :85: On this, the ;;) ",'~y of ~~",,-,-,.L\.. , 1994. before me the undersigned officer. personally appeared SHERIE L. DUFF, known to me or satisfactorily proven to be the person whose neme Is subscribed to the foregoing Instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~' ~ IJ..\..,~ Notary ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF NOTARIAL SEAL OIANNE lENIG,I:' I~ry Public Lemoyne Borough Cumbeflallll Co. My Commission expires Dee. 21,1991 :5S: On this. th~t1eey Of..f1tiJJJJ-b.I!\'-(1994. before me the undersigned officer, personally appeared MICHAEL J. DUFF. known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF. I hereunto set my hand and official seal. ~y!,;~ , NOTARIAL SEAL ROBiN M. BOMGARDNER. Nolary Public City of HarrllbDrg, Dauphin County M Commission EJcires ADril 15. 1996 on crt - iE C) ... !::::! (.0 ....... :r. -=: , . )>0- "'~ ~!;; L','t::)"r !?:a:Q:r ,...I;)U.,. ....':!::Q:- '? ~~:::;;! ...: .j ~., ...U;~ l.' i "f ~ "': ..';;'1' , 1-":'.:." . :'.J UC..:. , v. I IH THB COURT 01' COMMOH PLEAS I CUMBBRLlUID COtJH'1'Y, PBHHSYLVAHIA I I HO. '4- 1555 CIVIL TBRK I I I CIVIL ACTIOH - DIVORCB MICHABL J. DUI'I', plaintiff SHRRIB L. DUI'I', Defenclant 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 1, 1994, Certified Mail. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the plaintiff: June 5, 1995; by the defendant: June 9, 1995. (b) (1) Date of execution of the plaintiff's affidavit required by section 3301(d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None U"> c:n - >-.. ~- I..ll~:; ~.1 ~2L'~ .....O'-..:i ....T.O')o r.lI_~_J . .?...t.~ .~ -' Vl . Q;Z ._I'J~ ,,-_.1... .: .1.0 ~'" C:. '-~ :c: "- .... .-l !:::! t"O r-./ Z; => -, . NICBABL J. DUPP. . IN THB COURT OP CONNON PLEAS . Plaintiff . CUMBBRLAND COUNTY. PENNSYLVANIA . . q~- / SS.5- ~~L -.J Vt/W'..J . VS. . NO. . . . SHERIE L. DUPP. . . Defendant . CIVIL ACTION - DIVORCE . NOTICE TO DEPEND 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 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 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 Courthouse, One Courthouse Square. Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S PEES 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 County Courthouse, 4th Floor One Courthouse Square Carlisle, PA 17013 (717) 240-6200 , MICHAEL J. DUPP, . IN THE COURT OP COMNON PLBAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. . . SHBRI! L. DUPP, Defendant . CIVIL ACTION - DIVORCB . COMPLAINT UNDER SECTION 3301(c) or 3301(4) OF THE DIVORCE CODE 1, Plaint I ff Is Michael J. Duff, who resides at 606 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043, 2. Defendant is Sherie L, Duff, who resides at 231 Winding Way, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six months immediately previous to the filing of this Complaint, 4, Plaintiff and Defendant were married on October 18, 1990, in Cumberland County, Pennsylvania. 5, The parties have been living separate and apart since on or about February 19, 1994, a date prior to the filing of this complaint. 6, There have been no prior actions of divorce or for annulment between the parties. 7, Neither of the parties In this action is presently a member of the Armed Forces on active duty. 8, Plaintiff and Defendant are both citizens of the United States. . 9. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to part icipate in such counsel ing. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court, 10. Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHBRBFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, --c ~' -c ~ Road 17112-0216 . < . VERIFICATION I verify that the atatementa made in the foregoing document are true and correct to the best of my knowledge, information and . . .. belief. I understand that the atatements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~c;O~ en ""-I ... ... :or::: '" "I:'" .i U, WoJ:.r '-.:~~ '" ~U {?~ ~ 'Qi ~ .. ~ ~ Q-H I' f"- -- - ~ r{) >:~ ". c:,,; ~ ~j~,':':~ (..)Z"'~ in ;;: cjU..( m ..,'X".c.,)." ~., ,.. :.r. :~J '.1 -- "n ~ ~ .~ t I:: h ~ 1<) -a I.') C6~) '- "'" p-, ,,"), .,. en - ~ u.-.. -'.J .......... N ~ ~~~ '" N " 0 a: 0( :!! oj _ON_ ~ It 10 - CO I " ... N " - ~ III ID 0( -: . ... D. ;; 11. U,,, <~~~~ 0:: ... 0::> ;:: 00 Iii m - Z; 0 !!! " .. II: II: 0( J: . . . -. ..-.. MICHAEL J. DUFF, Plaint iff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . va. NO. 94-1555 Civil Term SHERIE L. DUFF, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF SERVICE I, Nora F. Blair, Esquire, hereby certify that a true and correct copy of the Complaint in Divorce was served on the Defendant by certified mail, restricted delivery, return receipt requested, on April I, 1994 at the Defendant's last known address of: Sherie L. Duff 231 Winding Way Camp Hill, PA 17011 The return receipt "A", ~ a F. Blair, Esquire orney for Plaintiff :- ;.., (.... ,-:'l,~ ,a; - -,:"",,~ ' 1~~E""tTl:'-~.r"_\S'i<"-~'" . -- L" " ,. >.,,,' ~:\<~""''"'''''''~>'''''''''Jo:"' -'~-"""'~\{N'Y-~*~'.;;~"..~,~.;;;",,~' I~. :;~'t~:e:~:.:(A,~,;..: -,-':" ,-"'0-" ~':""$~':'&.'~\'~-;\~ ,.;,r<ljj'1;~2,;\;~~~~.~ """,li1d1oi2foi_poMoio. ",'" ."...,z.",bi (" """!"~;I::'!f!ftO~. ' ~~IIMI4I.b.'.,t;':: tV;>'~6l" ~.1"~ ,! ~;:~ fOI~" "'"'''. Of ~ I, Iti~A ~:-:"::R-r~';b'M;~ :::':.;"'1' f~:~~ci:~"'. ! ~'*~ ~ 1IU'~rJ:U' . ~ .. -'.' ':{"'_ ~,,<"'~l:f\:~'~ ~ . !..'i.lW....'llOIumIlaoo/pl!'Aft''II1~lIlo__ . . . ~ .".,.",.,. ....t,. '''I' ~.f',,,,,,,,,,,,,Ilaoo/pl"',,,,,,,,,,'I'_ondlllo_ . 2: .,R~trk.!8C!.D~",..> . ;gl'~' : . ConaUlt _ for faa. ,: .,; : ~1.*~':4~,~Add~rauacltO: 4a.'A Number \.f;l<",,}jlJ. f'fi: :t - ~~r~1 ~ " - I;} . , ;.' 4b. SatVIoaTypa . '."". 11;,' ria-ol !J)I~rad D IMurad . '_ :.,.,." l-.,t... :-.,!~:'d . J!'Clllllflacl Dcoo, 'J /'i i i!. . RRalpt for , . ~~ i~i~~'?< . . . .': : 'r ."....... ,. , .(, !f ~4;~~' dd i~,.:'~.l; f!,I.'.j,~ .lalJ8!UraCAlIfInll. ,;.,,\;:},i;E.; fl:fi, ;;-J."'i<(;.,',{1!'t-.~:"'" '",_~',/:.<;.'.;t;':;;,~Uk' ,.'L., oc,' ~r;.,~,~..;" ,,"'. ,..'...-'""'....,..".1'~..;:r"'."..;;a'.- j:t'., --.... -- '. -....".., . .. ......_~. _"". '''..' , .".",.$, ~~~'l~;Wjid,j f~~~~rn~'1 ..~ UF't."._- },E8T1C ~~~~'~~. -'.;r.'c'>S.::-*,",,,,-,,;,,,,,,,,,:::,:,,_,,,,-,,,,'..,.._.__ '-'" . - ;_:;;'~,,,,,:,"_;-':;',_:;",;,,,'_i. EXHIBIT "A" ):~--~":C-...-n-oy1 I 1 ~ ( ( f I ~ ~ .... N ~ ...... ~~ ._ ;.e t",('):>_, u <.0- _::11:.....:1:' u..o-..t ;.'%0> n,,":":.t:C ;~: ;~! ~~ ~~ "IIh.:r. ,,'.'l4J ,: :r41.. ...~ '" co a:: ... .... " - "~''''..'._.T'''~' _;....-... .__'.., MICHAEL J. DUPP, I IN THE COURT OP COMMON PLBAS Plaintiff I CUMBBRLAND COUNTY, PENNSYLVANIA I va. I NO. 94- 1555 CIVIL TBRK I SHBRIE L. DUJ'P, I Defendant . CIVIL ACTION - DIVORC! . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 3301(c) of the Divorce Code was filed on March 29, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing of the complaint. 3. I consent to the entry of a final decree of divorce. 4. . I understand that if a claim of 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. DATED: & -..r. 9.F ?J1;.~./C L2 4- MI~HAEL J. ' Dg ? Plaintiff U"S en - =c c:r.- .... ~ ~ LO r-.I z :::> --. ( :.-... .c., ~~"f aJc.'.'.'_ UZf.;.';% -0<".<1 ~""t::a-"', r.)"-:.r: ..;. . ~...r\l') !'1 .," .Iz:. .~~ ~i :~~ ,.1. ::> 0...... ':,H"U-',''''; :'f'''':d':Y''li, . 0095714lOOOIIlunc 5, 19951DWO/MH/44300 . . . MICHAEL J. DUFF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94.1555 Plaintiff vs. SHERIE L. DUFF, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIOA VlT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 29, 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 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. 5. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and ~hat I mAY request the COllrt require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidevit 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: t/'l;/9S" . I ~{;[/u~rJ: ~ Sherie L. Duff, Defenda t U~ ....... ... => --. ~.. .-! ~- ....'. ~~ ",_,.;.-,4J ~.:.t;;j; "'"-' ot..'....~ ......:::1.'"):;.. <:;')t....r..-..l .~~ ~~~~ . ';JU":C _r.ro~ ,. X'" h.~ 0-' Ln en - :::c 0.- ..... ..... ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1555 MICHAEL J. DUFF, v. CIVIL ACTION - LAW SHERIE L. DUFF, IN DIVORCE Defendant NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that a final Decree in Divorce having been granted on the 6th day of July, 1995, Defendant hereby intends to resume and hereafter use the previous name of SHERIE L. MILLER and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309 No. 295, ~702; 54 Pa.C.S.A. 704, as amended. .$L- 'L ~~ Sherie L. Duff TO BE KNOWN AS: ~rJ:cmL , Sherie L. Miller COMMONWEALTH OF PENNSYLVANIA COUNTY OF CumtJp;e.~fJIJD : ss: On this, the 51# day of _F""b,..lUVL.~ ' 2007, before me, a notary public, personally appeared SHERIE L. DUFF, known to me to be the pe son whose name IS subscnbed to the within document and acknowledged that she executed the foregoing for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. COMMONWEAlTH OF PENNSYLVANIA ~ /L -IJ~ ~ NOTARIAL SEAL ~ GAIL J. MAHONEY, Notary Publ~ .' ~ry Public . lemoyne Bora" Cumberland County My Commission Expires Feb, 19. 2010 :291227 r-> .-) c:;> ~ ~ C,.;) --J ~ -r; ::;:! ~ rn rn~ ~ co -DeJ \ - ~') '>....,..i ~ co :) 1 >..-~ \ -i':=-:; <:>Q ~ ~: :~~};~ - ""'" 0 ~ - ....... 0 _._i "\. \/J N }~ :~ '- -- t: