HomeMy WebLinkAbout94-03329
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,.,171 'n.uII
SIPARATI0N AGRBRNRNT
THIS AGRIBHINT, made lhis _"L..~ day of
e-
, A.D.
"
19~ by and belween BDWIN M. LARSBN, hereinafter called Hus and,
and CATIIIRINB A. LARSBN. hereinafter called Wife.
WI'l'NBS8ITIII
WHIRBAS, lIusband and Wife were united in the bonds of
matrimony on the 16lh day ot March. 1974/ and
WHBRBAS, three children were born ot the marriage who are:
Errin M. Larsen, born July 9. 1975/ Derek IJ, Larsen born December
18. 1980; and Edwin J. Larsen, born November 29, 1982/ and
WHBRBA8, Errin M. Larsen as captioned above is an adult and an
emancipated individual; and
WHBRBAS, Derek Il. Larsen and Edwin J. Larsen presently reside
with Wife/ and
WlIIRBAS, lIuaband and Wife acknowledge that said marriaqe is
irretrievably broken. and the only solution thereto lies in
di vorce/ and
WHIRBAS, lIusband and Wife desire to settle and determine their
mutual property rights/ and
WHIRBAS. lIusband and Wife are legally competent/ and
WHIRBAS. lIusband and Wife have informed and advised each other
at lheir mutual properly. eslate and prospects; and
WIIIRIAS. lIusband has been advised by legal counsel of his own
chooainy of hill righls. duties. responsibilities, liabilities and
inullunitiea against and to Wife and children; and
WHIRBAB, Wife is not presently represented by legal counsel,
although Wife has been represented by legal counsel in the past in
this proceeding and will likely be represented by legal counsel in
the future and has and will be advised of her rights, duties,
responsibilities, liabilities and inununities against and to Ilusband
and children.
NOW THBRBFORB, [or and in consideration o[ the Bum of One
Dollar ($1.00) by each of the parties interchangeably in hand paid,
the receipt whereof is hereby acknowledged, in consideration of the
mutual promises contained herein, and in consideration of the other
good and valuable considerations hereinafter set forth, the parties
hereto do mutually promise and agree as follows:
1, All of the wearing apparel and personal ornaments of Wife
which are situate at her residence in Camp Ilill, PA or elsewhere,
shall hereafter belong to Wife as her separate estate,
independently of Ilusband.
2. All of the wearing apparel and personal ornaments of
Husband which are situate at his residence in Flaqstaff, AZ or
elsewhere, shall hereafter belong to Husband as his separate
estate, independently of Wife.
3. Husband and Wife acknowledge that Wife has conunenced an
action in absolute divorce against Husband in Cumberland County,
Pennsylvania, using as a ground the no fault provision as found in
section 3301 of the Pennsylvania Iltatute, Ilusband and Wife
acknowledge that said marriage is irretrievably broken and both
2
partiel state their presunt intent is to execute the consents when
presented to them by their attorneys so that said divorce may be
qunted,
4. Husband and wifo shall have joint leqal custody of the
two minor children, Derek U, Larsen and Edwin J. Larsen. Husband
and Wife aqroe that wite shall be the custodial parent of the said
Derek U. Larsen and Edwin J, Larsen, althouqh Husband and Wife
aqree that said custodial arrangement may chan\le in the future
dependinq upon the residence at Husband, the residence of wife, the
desires or both Husband and Wile, and the desires of the two
children. Husband and Wife acknowledQo that presently, neither
party intends to tile a Petition concernin\l custody or visitaLion.
Husband and Wife acknowledge that so long as wife shall be
custodial parenL, Husband ahall have liberal visitation riqhts with
said children or either at them and, in the future, should husband
be the custodial parent of the said Ilerek U. Larsen and Edwin J.
Larsen, wife shall have liberal visitation riqhts with said
children, or either of them,
5, Husband and Wlfe acknowledqe that Wife owns certain
realty situate in Cumberland County, Pennsylvania, and Husband and
Wife acknowledqe that said realty is and shall hereafter be the
sole and soparate properLy of Wite. Husband and Wife acknowled\le
Lhat Husband owns 110 roal !lBLaLe.
6. Husband and wit e acknowl edqa lha l Lhey own cerLain really
in Lhe BlaLe of Idaho. Hushand and Wife a\lree Lhat they shall, at
3
the execution of this Agreement, or as soon thereafter as possible,
executive an exclusive sales agreement with a reputablp real estate
agent in the State of ldaho to sell said realty. Finally, Husband
and Wife agree that the net proceeds from the sale of said realty
shall be equally divided between them at the time of the closing on
said really.
7, Hunband and Wife acknowledge that each of them have
debts, and further that each of them shall be responsible and
continue to be responsible for the payment of their own debts.
Husband and Wife acknowledQe that they have no joint debts between
them.
8, Husband and Wife acknowledQe that each of them own their
own motor vehicles. and that there are no motor vehicles owned
jointly between them, Husband and Wife acknowledQe that the owner-
ship of said motor vehicll!s shall. in the future. be as it
presently is stated.
9, Husband and Wife agree that the household Qoods have been
equally divided by and between the parties prior to the execution
of this AQreement. Ilusband and Wife further aQree that all bank
accounts have been aindlarly divided by Slid between the parties.
10. Ilusband and Wi f e acknowl edQe tha t each of them own
certain securities and evidences of wealth in their own names which
Include, but are not limited to, l,R.A, 's and United States Savings
Bonds, Ilushand ond Wife aqree that the individual ownership of
said securities and evidencBB of wealth .hall remain as they are
4
presently titled. Husband and Wife further acknowledge that they
are indeed totally knowledgeable concerning these assets, and
Husband and Wife choose not to lisL Lhem here since they both are
aware that this Agreement shall become a maLter of public record,
11, Husband and Wife acknowledge Lhat Wife may, in the
future, conunence a aupport action against Husband for Lha support
of the two younger children, Derek B, Larsen and Edwin J. Larsen,
Husband and Wife acknowledge, however, that Husband has paid and
will continue to pay $250,00 per monLh per child until such time as
Husband finds employment, at which time Wite contemplates that she
may request additional funds for support. In this regard, the
parties acknowledge that Husband has retired from the united States
Air Force, and while he is employed on a temporary basis, he is
seekinQ out employment befitting his education and experience at
the present time. Husband and Wife acknowledge Lhat said support
may increase or decrease, depending upon Husband's earninQ
capacity, Wife's earning capacity, the earninQ capacity, needs, and
ages of said children, as well as the children's desire to continue
their formal education beyond the public school years, Husband and
Wife acknowledge that they have been advised that the matter of
support is a matter of continuing interest to the courts, and that
either party or the children themselves may petition to increase or
decrease support for the two children in the future,
12. Husband and Wife acknowledge that Ilusband presently
receives the sum of $2,400.00 as a retirement pension from his
5
years in the mil ilary, which payment may increase or decrelise in
the future. Husband lind Wife agree that Wife shall receive one-
third (1/3) of the qross retirement pension before any deductions,
which payment to her shall be made on a monthly basis, Each
recipient of the divided retirement annuity shall be solely
responsible for Federal, State and Local taxes due on his or her
partial disbursement. Said payments are to have conunonced on May
I, 1995, and accordinQly, if said payments do not beQin on that
date, Wife shall receive all arrearaQos in a timely fashion.
13. Addilionally, Husband and Wife aQree that Wife shall
continue to be the benof iciary ot Husband I s Survivor Benefit Plan
in an amount equal to ono.third (1/3) of Husband's Qroaa retirement
pension before any deductions. Wife warrants that ahe will execute
any and all necessary documenta to effectuate thia portion of the
AQreement inunediately upon the granting of a Decree in Divorce
between the partiea, Should Wife not execute said documents in a
timely fashion, all payments hereunder shall ceaae until the
necessary documentation haa been properly executed and lodged with
the appropriate department,
14. Huaband and Wite aQree that Huaband shall provide a
CHAMPUS supplemental pol icy that includes dental coveraQe or a
CHAMl'US Bupplemental policy and Beparate dental coveraQe for the
minor children, Derek 8. Larsen and Edwin J, Larsen, Wife shall be
responaible for all deductibleB, non-allowed amounts and non-
covered benefits such as prescription Qlaesee and educational
6
support for learning disabilities or special gifted student
programs.
15. Husband and wif e agree tha t f or the purposes of the
determination of the Wife's eligibility for continuing benefits due
to her status as a former spouse of a retired service person, that
she does Quality as a 20/20/20 spouse, This calculation was made
based upon the fact that the parties were married on March 16, 1974
and anticipate divorcing in 1995, It also takes into account the
Husband's enlistment on March 6, 1973 and his retirement on October
1, 1994,
16. Husband and Wife agree that Husband maintains two ten
thousand ($10,000.00) dollar lite insurance pOlicies with New York
Life Insurance Company wi th Policy Numbers 33 - 649 - 827 and 27 -167-
189. Husband and Wife agree that Husband will maintain life
insurance coverage naming Derek B. I.arsen as the irrevocable
primary beneficiary on Policy #27'167-189 until the said Derek B.
Larsen attains age of twenty- live (25) years. and Husband will name
Edwin J. Larsen as irrevocable primary beneficiary on Policy #33-
649-827 until he attains lhe aile of twenty-five (25) years.
Husband and wife agree that said irrevocable beneficiary agreements
shall be executed by Husband and held by Husband's attorney until
said divorce is granled, and thereafter, Husband's attorney, Harry
I" Ilri cker, Jr, , h j nevoeabl y di reeled to re lease said
documentation to the Harrisburg New York Life office and direct
them to proceed to make aaid irrevocable ben~ficiary designations
7
part of their respective policies, Should said divorce not be
granted wi thin one (1) year of the da te of this Aqreement, the said
Harry L. Bricker, Jr. is irrevocably directed by Husband and Wife
to forward said Agreements to his client, lIusband herein,
17. Husband and wife agree that Husband shall receive one-
fourth (1/4) of any military retir~ment pension to which Wife will
be enti tied from her years in the mi Ii tary,
18. Husband and wife agree that each shall pay their own
counsel in this proceeding and that neither Husband nor Wife shall
seek out any reimbursement in this regard from the other.
19. Husband relinquishes any interest he may have by reason
of any written or oral Agreement he may have with wife and his
inchoate intestate rights and statutory right of election in the
estate of Wife, and Wife relinquishes any interest she may have by
reason of any written or oral agreement she may have with Husband
and her inchoate intestate rights and statutory right of election
in the estate of Husband, and each of the parties hereto by these
presence, for himself, herself, his or her heirs, executors,
administrators or assigns or any of them does remise, release,
quitclaim or forever discharge the other party hereto, his or her
heirs, executors, administrators or assigns or any of them of any
and all claims, demands, damages, actions, causes of action or suit
at law or equity, of whatever kind of nature, for or because of any
matter or thing done, omitted or suffered to be done by said other
party, prior to and includinq the date hereof, except that this
release shall in no way affect cause of actio in divorce or related
8
matters which now exist or which may hereafter arise to the other
party.
20, Husband sha 11 nol at any time contract or incur any
liability on behalf of the Wife or obligate or charge her credit in
any manner whatsoever,
21. Wit e sha 11 nol a t any time contract or incur any
liability on behalf of Husband or obligato or charge his credit in
any manner whataoever,
22. Husband and Wi fa shall at all times make, deliver and
execute any and all further instruments as shall be necessary for
the purpose of giving full force and effect to this AQreement.
23. Wife acknowledges that the provisions herein made are
adequate, reasonable and satisfactory to her, and accordinQly she
accepts the same in lieu of and in full and final settlement and
satisfaction at any and all claims and rights that ahe may now or
hereafter have againot Husband for alimony, support and
maintenance, alimony pendente lite, counsel tees and expenses.
24. Husband acknowledges that the provisions herein made for
the transfer of properly are adequate, reasonable and satisfactory
to him, and accordingly, he accepts the same in lieu of and in full
and tinal settlement and satisfaction of any and all claims and
rights that he may now or hereaf ter have aqainst the Wife for
alimony, support and maintenance, alimony pendente lite, counsel
fees and expenses,
,
. '\
MILITARY AETlftfMI!NT ADDENDUM
TO
",OPERTY SEmEMENT AGREIMENT
AI. ,.un 0' Edwin l",tn'. MfVlcl 'n the United St.t.. Air FOIc, during me
cour.. 01 hi. marr'. to Cather'ne, . POIUon of hi. millt.ry retired ..-v ,. mar"1I
prClpffty .ulJject to chl.lon, AI 10 IhI. dlvlalon, the Pn.. Agree .nd Stlpul...
thlr:
1. InfOlmet'on concerning lhe mlllt,ry "'."6..-, hlrtlnt"w r.f.red to II
.'1t.......:
NeR..; Edwtn M, lMaen
.1nCtt 01 hMce: United Stat.. Air Forc.
locIeI8tcurily Number: 2211.14.5174
2, In'Ofmltdan concerning thl non-mflhlfy Ipo".., "elnl"er "'."ed to II
.........;
NImt: C..,...Ine.......
Iocllllecunty Numbef: 21......113.
3, The court ret/'''''' tN, ....".nl h., lurildlction to modlfV thl. Igreement In
.... Went" I. nOf conal.,... ICcllJnlbfe '01 proc...... bV thl military pay center.
Iuch mMltlclt60n ...... be" to 101m onlV. Ind ItNII not I"ect thl lub"tntlve
.
rlghtt 0' .... PIrtl_,
4, The duration of the marr.... In ,1I"lon 10 the tlma ..... "*~.. per101mld
1IfYtc. crtdlttble 'or retirlld p'Y I. wall in IIlC,,, 0' 10 v..r., That.'ora direct PlY
f,om M.......'. "tlrlld PlV I. authorlled In ICCOIdanc:. with 10 U,6,C. I 14011dl,
.
IS, _AI end 'or her proplnv Intlrelt In Member'l .Polt Mllltery Slrvlcl
Comp.nlltlon" IPMSCI, not "dllpOllbll retlr.d PlY., SpOUl. II IWlfd.d thlny-
ttwH perc.nt 133.,., 0' Illd PMSC. Seld p.ym.ntl will conti nUl until the dllth 0'
littler peny, SPOUII Icknowledg.. thlt thll 33'" Ihl,. II II" thin one-hll' 0' the
merltll Ih.re 0' the retirement end wllvlI her rlghtl to the remelndlf 0' her Interllt
In the retirement.
e, "Polt Mllltlry Service Complnlltlon" mllnl the 'ull monthly longlvlty,bl..d or
dlllblHty bll.d mllltery retired PlY Member II or would be .ntltltd to rectlvI be'ore
eny Itltutory, "guillory, or .Iectlve dlductlonl Ir. epplled .Ilcept 'or the COlt of
the Survivor Benefit pt.n, dllcul..d b.,ow. PMSC Includ.. retired PlY plld or
p'Y.'e for longevity or Ictlve duty .nd/or renrvl component mllltlry "Met Ind
III p.ymenll plld or plylbll under the provlllonl of Chlpter e t 0' TItll 10, United
8t.t.. Code, PM8C 1110 Includll III lInountl 0' retlr.d p,y Member ICtuelly 01
conl"uctlvlly WIlY.. or 'orfelllln Iny mlnner Ind fOl Iny rellon, Including but
not IImltld to Iny wllver midi In order to qUIII'y 'or Vltll.nl' AU"'I blnefltl.
7, M.-nber 'Ieppo/nted .. trUlt.. fOl the benefit 0' &pou.. to thee.tent of her
~ter..' In thl ponton 0' hil PMSC hereby ewerded to her. Member will p.y to
&POUII her elld Int".., no I.tlr thin 10 dlYI e'ter h. IIc.lv'l p.ym.nt 'rom thl
Finlnel Center, Thll plregreph Ihlll bl IPpllclbll until. direct p.yment ..1
efflCt 10 thlt SpOUII will recllve her plymlnt dlllctty flom the Fln.nc. Cent.r end
ehlll be .ff.ctlvI 'or eny month 'or which Ihe dOli not lecllve direct p.ymentl
from ...d Center,
.
8, M.mber will, undel plIlllty 0' contempt, PlY Spou.. her Interllt In hil PMSC
II h.reln provldld, Member II not relllv.d of thll obllptlon 'IlClpt to the e..ent
MllltllY Retirem.nt Addendum
Merltege olllr..n
P," 2
.
thlt ,h. I. notified thlt the jnt.rl.t of Spou.e he. been p.,d dlrectlv to h.r bV the
.ervlclng Flnlflcl Cent....
8, M.mb.r will bl p.r.onIIlV IIlble for anv co.ts. Including .ttornev.' f.... thlt
m.v b. Incurrld bV former IpOUII In enforcing her right. or coHecting .uch benefltl
from Memb.r,
10, Membll will not pur.ue Bnv courle of ectlon thlt would dlf.lt. reduce. or limit
SpOUIt'. right to r.celve the .hlre of hi. PMSC awerded herein, Member shall
v-mnlfv Ind hold hlrmleu Spou.. for Inv br..ch of thl. provl.lon from fund. 0'
whlttyer .ourc., By w,y of IMu.tr.tlon .nd not IImiUltlon. should Member obtlln
V"eran.' Admlnl.trltlon dl.lbnlty plV In lieu 0' mlllerv retired PIV, he .h.1I
IndemnlfV Spou.. for the r..ultlng reduction of hlr p'vm.ntl from the mniterv PlY
cen"r bV fund. 0' whlt.ver lource .0 thlt .he will contlnul to rec.'ve plvm.nt. In
the ,",ount of her aWlrd.d .her. of hi. PMSC,
", So thlt SpOUII c.n verify thl ICCUrlcy of her Plvm.nt.. Member will IX.Cut.
· document .uthorirlng the plV clnter to r.,.... to Spou.. .nv mll/tlry rltlr.d plV
InfOfmltlon .he rlqU'''',
12, Mlmber Icknowl.dg.. th.t h. con..nt. to thl. Ictton, Ind ther.fore I. .ubject
to th.jurl.dictlan 0' thl court. 0' the Stlte 0' Penn.ytvanl. for the PUlp 0.. 0'
,"'.ty;ng the requlrem.nt. of 10 U,S,C, S.ction 14081cl(41,
'3. Congre.. h.. P....d the Uniformed Servlc.. Former .pou.... Protection Act,
Codlfl.d It 10 U,S,C, 11408. Ind .Iid Act luthorlz.. I former Ipou" 0' I retired
mUttlry member to obtlln I court IWlrdld portion of I memb.r'l retired PlY
directly from thl member'. ..,vlcl fln.nce center,
MIlItlll'y ...lIrem.nt Addendum
Merrll" of La"ln
P'lI' 3
\
14. ,In order to e"eet lervlce on the lervice Ilnence cen..r 10 thet direct pIyment.
eln be lint to former Ipouse, certlln informetlon mUlt be provided to the finance
center, In order to Inltllte luch plymentl, lormer Ipouse Ihall proce.. In
~plleetlon thlt II In conlormlty with the Act, II 101l0wI:
The following Inlormetlon Ihln be ..nt to DFAS-CL/GL, Clevel.nd, Ohio by
per.onll IIrvlce, or certllled or regl.tefed m.1l return rtctlpt requnted:
I. A certified copy 01 the order implementing thll Igreement that h.. blln
certified within 90 dlya of the dlte the Cent.r recelptl lor the eppllcltloni
b, A .tltement algned by 'orm.r 'POUII requlltlng direct plyment thlt
Includn the lollowlng IlngUlge:
"I ,.qullt direct plyment 'rom the retired PlY 0' Edwin L"I," wholl 10Clll
.ecurtty Iccount numblr II 225.84.5874, In Iccordlnce with the Incloltd court
order, I certify thlt the court order la I tlnll decr.. Ind hll not blln emlnded.
aup.,.tdId or lit ..Ide, A. I condition preced.nt to p.yment, 1 Igr.. thlt Iny
overplymentl I,. recoverlb.. Ind .ubltct to Involuntlry collec:tlon 'rom me or my
..tit., Ind that I will notify the Unl'ormed Service If the Op.ltiv. court order, upon
which payment II blltd, II VIClted, modlrled or lit Illdl. I .110 Igr.. to notl,y the
Uniformed Servlcl 0' I chlnge of eligibility for plymentl, Thlllncludll notlcl 0'
my rem.,I"" If und.r thl tenna of the court order or law. 01 the jurl.dictlon
where It WII Illued, remlrrllg. caul" thl p.ym.ntl to b. reduced; or notlc. of I
chlnlllln IIlg1blNtV 'or child .upport Plym.ntl by r..aon 0' thl death,
emlnclpltlon, .doptlon or 1".lnm.nt 0' mljorlty of I child who.. lupport II
provldtd through direct plymlntl from retired PlY,"
c, The 1_''', or Iccount Ind blnk routing Infonnltlon, to which thl
p.ymentl .. to be mIdt,
15, Member will coop.,et. with SpOUIt by signing Iny Ind III do cum en.. II mlY
b. necl..WV to e",ure thet Ihe II provided In mllltlry prlvll'Uel to which the II
.ntltled, .
1 e. Plyment. of Member'l retired PlY will termlnltt upon hi. delth, Ind thert'ore,
plyment. to SPOUII of her IWlrd would 1'10 termlnlte, How.ver, the government
hll e.tlblllhed the Survivor Benefit Plln (SBPI by which plyment. to . ...ted
MIIt.ry Rttlrement Addendum
Mlrriege 0' Llr..n
Plge 4
. .
beneficllry of I portion of Member's retired PlY will continue after hll delth. Appllceble
atltuel IlIow a lonner Ipouleto be nlmed el beneliclary 01 under the SSP.
17, When he retired, he elected to plrtlciplteln the government Survivor Benefit Plln Ind
nlmed Spoule al hll benelicllry.
18 Spoule should continue althe 60le beneficiary under Illd plln, but that her coverlg. will
tennlnlte by operation olllw upon the finality olthll decree of divorce. Therefore, letlon must
betaken by Member to change Ipoule to a "fonner Ipoule beneficiery".
19. II pennltled by Itatute and regulation, the level 01 SBP coverage Ihall ba reduced and a
bill amount leleeted thlt will provide Spouse an annuity equal to 33% of Member'1 gm..
retired pay. Member will, within 10 days of the date thll order hu been Ilgned take the ItepI
nece..lry to convert SPOUII to hll "fonner spouse" beneficllry Ind reduce the level of
coverlge.
20. Each plrty will PlY IlIlpplicable income tlXes on the Ihare of the retirement thlt elch
ahlll receive.
The foregoing MILITARY RETIREMENT ADDENDUM TO PROPERTY SETTLEMENT
AO~ME T il gre to by
~:.)I )
-:.:::, ~ " \ - --.\vJ C{ S
olte
On thl n l,~ day 01 November, In Iha yeal nineteen hundf8d and nlnllly flvl, bllor. ml,
Mu~ ':..:.. \" . \, "....' a Notary Public, Stete 01 ArIZona, duly oommlnloned end l\VOIn, plr.onlUy
app..rlio Edwin M larlln,who plOVed 10 me on the balll of lalllfllC10ry .vidlnc. 10 bl Ihl PI"on whOl. nlm. II
IUblcllbed 10 wllhln Ihll Ilipulation and who acknowladgad to ml al having Ikeculed Ihll R.lelll 0I1l!' 1JlIl n
My oommllllon I.pllll .Mu., 4-1\...l-.L_Ll_ '.t....l ~'\ "\..
)' , ~rt Publi, .01 Arllonl _~..
('IN. . /1/,1111'" 1/,,1)//(,' OfflClAlSlAl (
C.therine A I.arlln 0.18 . MARY JO STERLING
~~ ~~~~~
IXXXlNlMllnlNTY
Mllitery Retirement Addendum ~ It, _
Mlnilge of Llrlln
Page 5
CATHERINE A. LARSEN,
Plslnll"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTY.. PENNSYLVANIA
VB.
No, 94.3329 Civil Term
EDWIN M, LARSEN,
Delendant
CIVIL ACTION - LAW
AFFIDA~I..Qf-.CONSENI
1, A Complaint In Divorce under Section 3301 (c) 01 the Divorce Code was liIed
on June 20, 1994,
2. The marriage 01 plaintiff and dolendant is irretrievably broken and ninety
days have elapsed Irom tho dato ot IiIlng tho Complaint.
3. I consent to the entry of a final decree 01 divorce after service 01 nollce 01
Intention to request entry of the decroe.
I verify thattl10 statements made in this affidavit are true and correct. I understand
that falBe statements herein are made subject 10 the penaltios 01 1 B Pa. C,S. 4904
relallng to unsworn lalsification to authorities.
blulc of ^J:lwnu
Cuunly of Cll~\lJ
\cr I . .'JJ
'2~,
Edwin M Larsen
lln Ihlli 17th ullY of Aj1rlJ, 1 \J\Jb , JAII.ln M, I.lIr~I'Il, whll i~ pl'l'~llllilll)' ~IlOlvn 10 me
III ho Ill\' MlllllOI' of Iho Illx1VO IUlilnullclll, 111\11 II\' ndll\l\,Il~I~I~1 Ihlll lit' I'xl'\:ullctl It.
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Catherine A. Larsen,
Plaintiff
IN 'rHE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, l'ENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-3329
VS.
Edwin M. Larsen,
Defendant
IN DIVORCE
PRABCIPB
TO THE PROTHONOTARY I Please enter my appearance for the
Defendant in the above captioned matter.
Datel
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Harry L. Bricket, Jl".,..!squire
1.0. 07049 ""
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407 North Front Street~
HarrisburQ, PA 17101 ',_
717-233-2555
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CCI Edwin M. Larsen
Lester J. Hayt, Esquire
Keith a. DeArmond, Esquire
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