HomeMy WebLinkAbout94-05099
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: IN THE COURT OF COMMON PLEAS :
* OF CUMBERLAND COUNTY *
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: STATE OF ~7'~ PENNA. :
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8 MTHY L. GRI FE'[ E, *
8 Plaintiff 1\1.. 5099 cr.y'.I.~..". IIJltl 8
* \'Pl','.;u.... ,
18 KEITH A. GRrFFIE, 8
18 Defendant .
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8 DECREE IN :
:1 0 I V 0 R C E :
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AND NOW, . . '" .~",. ~"1. . . " 19.~.... It Is or ere an 'l'
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* decreed that ......,....I~t,\or.frx:.~.'.,qr~iF'.l':U;,....".,....,...... plaintiff, 8
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. and..,.........."..." 1<.F:nH. A.r;;IU~FIE.,.,............... defendant. ~
8 are divorced from the bonds of matrimony. 8
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8 The court retains jurisdiction of the following claims which have 8
8 been raised of record In this action for which 0 final order has not yet 8
'" been entered;
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8 Nonp i~
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AGREIMENT made this day of December, 1995, by
llnd between KATHY L. GRIP!i'IE, ("Wife") and KEITH A. GRIFFIE,
("Husband") .
W-I-T-N-E-S-S-T-H
WHEREAS, the parties hereto are Wife and Husband, having
been married on september 25, 1.982, in Huntington Township, Adams
County, Pennsylvania. There were no children born or adopted as
a result of this marriage.
WHEREAS, diverse unhappy differences, disputes and
difficulties have arisen between the parties and the parties have
decided that their marriage is itretriev~bly broken, and it is
the intention of Wife and Husband to lLve separate and apart for
the rest of their natural 1 ives. and the partles hereto are
desirous of settling fully and finally their respective financial
and property rights and obligations as between each other,
incl~ding without limitation: the ownership and equitable
distribution of marital property; the past, present and future
support, alimony, alimony pendente lite and maintenance of Wife
by Husband or of Husband by Wife; and in general, any and all
claims and possiblE' daims by one against the other or
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effect after such time as a final de~ree in divorce may be
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entered with respect to the parties.
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3. AGREEMENT TO BE INCORPORATED aUT NOT MERGED IN DIVORCE DECREE
Upon either of th" partie~l' re",overing a final judgment or.
decree of absolute divorce against the other in a court of
competent jurisdiction, the provisions of this Agreement shall be
incorporated by reference or in substance but shall not be deemed
merged into Buch judgment or decree. This Agreement shall
survive any such flnal judgment or d"cree of absolute divorce,
shall be entirely independent thereof, and the parties intend
that all obligations contained heLein shall retain their
contractual nature in any enforcement proceedings in any
jurisdiction, whether enforcement is sought in an action on the
contract itself or in any enforcement action filed to the divorce
caption.
4. ADVICE OF COUNSEl,
Wife has been represented by W. S. Daniels, Esquire.
Husband has chosen not to retain an attorney notwithstanding the
fact that the attorney for Wife has told him that he has an
absolute right to be represented by an attorney. Husband has
chosen instead to negotiate directly with counsel and with his
Wife. Husband hereby acknowledges that he has done so willingly
and that he fully understands the facts and has been fully
informed and understands that had a Court decided this matter, he
may have received more or less than is provided for in this
Agreement. Husband knowlngly waives his rlght. if any, to
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utiliz~ the lack of hia legal reprHsentation ~s a basis to attack
the validity of this Agre~m9nt. Both partles further acknowledge
and agree that each has Cully di~cloHed their r~spnctive
financial situations to the other, including their assets,
liabilities and income. Each of the parties .3ckr.owledges dnd
agrees that, after havlng received such information and with such
knowledge, this Agreement is fair, reasonable and equitable and
that it i9 being entered lnto frenly, voluntarily and in good
faith and that the eKecution of this Agreement in not the result
of any duress, undue influenc'" coercion, collusi<Jn and/or
improper or illegal agreament.
5. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live
separate and apart. They shall be free from any contract,
restraint, interference or authority, direct or indiroct, by the
other in all respects as fully as if they were unmarried. 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
res~ective families of each other.
6. MUTUAL RELEASES
EKcept as otherwise eKpressly provid~d by this Agreement:
A. Each party herehy absolutely and unconditionally
releases and f<ll"vE'r di".,hal''l'''' thE' other and the E'state of the
other for all purposE'S from any and all rights and obligatlon:,
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which either may have or at- any time h..reaft(-r have for past,
p~esent or future support or maintenance, alimony pend.nte lite,
alimony, I'!'luitable distribution, courw,.l fe"", costs, expenses
and any other right or obligation, economic or otherwise, whether
ariminq out of the marital ro!llation'lhip or otherwisl'!, including
all rights and benefits under the Pennsylvania Divorce Code of
1980, its supp lemen t:; and alO.mdment s, as we 11 as under any ot.her
law of any other jurisdiction, except and only except all rights,
agreements and obligations of what.soever nature arising or which
may arise under this ~greement or for the breach of any provision
thli'reof. Nei ther party sh"lll have any obl.iqat i on to the ot.her
not expressly set forth herein,
B, Each party hereby absolutely and unconditionally
releases and forever discharges th. other and his or her heirs,
executors, administrators, assigns, property and estate from any
and all rights, claims, demands or obligations arising out of or
by virtue of the marital relationship of the parties or
otherwi'se, whether now existing 01 hereafter arising, The ab,)ve
release shall be effective regardless of whether such claims
arise out of any former or future acts, contracts, engagements or
liabilities of the other or by way of dower, curtesy, widow's
rights, family exemption or slmilar 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. ;} surviving spouse too
pat"ticipatf~ in a 11el>;:oa~3f~d :';p(1tJ,'~I-:O';1 ,,:',:;I:a!-l.,', \o/hF;")t.h~l- ::itising under
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the lawB of Pennsylvania, any state, CQ~nonwealth or territory of
the United 6tat~B, at any other country. It is exptessly
under/ltood, how'~>Jer, that n.'i.ther the provisi.oll/l of thh1 release
nor the Bubs~quent elltry of a dlvorce decree are intended to
defeat the right of ei~her parly to recelve allY inDurance
proceods at the death of tho Qthet of which she or h. is the
named ben"fi(~i;HY (wh..thel: the ben..flciary designation was madl!l
prior or subsequent to execution hereof), nor to defeat the right
of either party to reeelv.. Hny legacy, be~uest or residuary
portion of the other's estate under his or her will, or to act as
personal repr8sental lve or executor if BO named by the will of
thp. oth'lr, whether such wi II was execllted pl.iar In' subsequent to
this Agreement,.
C. Ex,~.>pt for any callse of act ion far divorc", which
either party may have or claim to have, and except for the
obligations of the parties contained in this Agreement and such
rights as are expr,ssly reserv",d herein, each party gives to the
other by the execution or this Agreement an ab30lute and
unconditional release and discharge from all causes of action,
claims, rights or demands whatsoever, in law or in equity, which
either party ever had or now has against the other.
7. WARRANTY, DISCLOSURE
Each of the parties has been independently advised of and is
fully cognizant of Us at bel. respedive right" to a full and
fair di"c:loon:r,' of th" financial st,at,\lS of t.he other prior to the
execution of thL; A,] r","'II\p.n t . W: re and Hu:shand t'/:preso>nt, 'l~ld
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wlHtnnt that they hllve disclosed to I:'ach other in full their
~esp~ctivl:' alsets. liabiliti~s and Incomo; tha~ they ar~ each
awa!"l' of. the I:'xtcmt of each othli'r'" financial situation; and l.hat
this Agreement was n"got i;ltl:'d and I~ntered into on the basis of
sll(:h Hnancial status. The padi'!s b,)th confirm that each of
the~ is knowingly and intl:'lligently waiviny his or hl:'r respective
rights to any further enumeration or stalem..nt thereot: and that
in executing this Agreement, each fot'ever waives any future right
to set aside the said Agreement. or to defend against its
enforcement or any portion thereof based upon the other's
financial status, or based upon any claim that it Is inequitable.
unconscionable Ill' do.-::: not. make a reason,,,bl.' provision fLlI: one or
the other of them,
8. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall
be valid unless in writing and signed by both parties.
9. LAW AND JURISDICTION APPLICl\B[,E
This Agreement shall be construed in accordance with the
laws of the Cnmmnnwealth of Pennsylvania.
10. AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be
binding and shall inure to the benefit of the parties hereto and
their rE,,,pectl'/(' h.-irs, '~:{"Clltors. administrators, successors and
assigns.
11. TN't'EGRl\?'lON
This IIgrepment consti!\lt~s the entire understanding of the
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parties ~nd super98d~a any onu alJprior agreements and
negotiations between them. Thera arH nq representations or
warranties other than t.ho"" o;;xpressl y '1 I? t. forth herein.
12. OTHER DOCUMENTATION
Wi fe and l!llsbanu '~O'J8n;.lnt and ,.gro!J8 that t,hey wi 11 forthwi th
and within at most ten (10) days after uemand therefor execute
a,ny and all written i.nstrum,.nts, assignments, releases,
satisfactions, deads, noteD or such other writings as may be
necessary or desirahle for the proper implementation of this
Agreement.
13. NO WAIVER OF DEFAULT
This Agrepment shell 1 remain in full force and .'ffect unless
and until terminated under and pursuant to the terms of this
Agreement. The failure ,)f either party to insist upon strict
performance of any of the provisions of this Agreement shall
neither affect in any way the right of su~h party hereafter to
enforce the same, nor shall the waiver of any breach of any
provision hereof be construed as a waiver of any subsequent
default of tho same or similar n~ture, nor shall the waiver o~
any breach of any provision heleof be construed as a waiver of
strict performance of any other obligations herein.
14. SElVER!\BII. ITY AND INDF.PENDENT AND SEPARATE COVENANT::;
The parties agree that each separate oblig~tion contained in
this Agreem0nt shall b~ deemed to be a separat~ ~nd independent
covenant and agreement.. If any term, condition, cla'.l:'3e or
provision of this Agre~m~nt ;~hall be ,1eter~~ne(1 or ~prlal'pd to be
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void or invalid in Jawor otherwise, th~n only that term,
condition, claus,> or proviuion shall b~ :It dcken horn thifl
Agreement, and in all other respects this Agreement shall be
valid and cor.tinUf! in full forcEl, effect an,1 operation.
Likewise, the failur~ of ~ny party to meet his or her obligations
under anyone or more of the paragraphs herein, with the
eKception of the satisfaction of any conditions precedent, shall
in no way avoid or alter the rernainin9 obligations of the
parties.
15. CONTRACT INTERPRETATION; COSTS AND ATTORNEYS' FEES
For purpose~ of contract interpretation and for the purpose
of resolving any ambiguity herein, Wife and Husband agree that
this Agreement was prepared jOlntly by their respective counsel.
Costs of drafting this Agreement and for no-fault divorce in
C~mberland County, Pennsylvania, contemplated following execution
of this Ag~eement shall be borne by Wife. Attorneys' fees for
individual counsel of parties' selection shall be respectively
bo{ne by Wife and Husband independently.
16. ALIMONY
Wife and Husband do hereby waive, release and give up any
rights which either may have agai~8t the other ,to ~eceivealimony
or other post-divorce maintenance or support. It shall be, from
the execution dat", of this Agreement, the :;;ole respon,sibility of
each of the respective parties to maintain himself o~ hernelf
without seeking any support from the other party.
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17. T~ANBFE~ or REAL ESTATE
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Wifp, hall milde, executed and delivered all documentll in the
usual form conv~ying, transferring and granting to Husband all of
her right" Uti", and jnt.~rel3t in and to the real estate situate
at and known as 60 Victory ~hurch ~oad, Gardners, South Middleton
Townflhip, cumberland County, Pennsylvania 17324 (Tax Parcel No.
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40-40-2656-018) by deed dated October 7, 1994 and recorded on
octob",r 25, 1994.
~8. CONSIDE~ATION FOR TRANSFER OF REAL ESTATE
In t~nsideration for the conveyance set forth in Paragraph
17 above. Husband lias paid to Wife the Dum of Twelve Thousand and
No/I00 ($12,000.00) Dollars. the receipt of which is hereby
acknowledged by Wife.
19. RELEASE OF MORTGAGE LIABILITY
In return for Wife's conveyance of the marital real estate
described in Paragraph 17 above, and Husband's consideration for
said conveyance aD set fort!. in Paragraph 18 above. Husband
hereby releases Wif@ from any liability or obligation on the
mortgage note with respect to said premises. From the date of
transfer of pr~mises, Husbaud arJrees to assume as his sole
obligation any and all mortgage payments, taxes, claims, damages
or other expens,'s inClined in connection with said premises. and
Husband further covenacts and agrees to hold Wife harmless from
any such liability or obligation.
20. TANGlflLE PERSONAl, PROPERTY
wi f,:! .1:-:(1 HI.::';:ld~11: rr,":~',.,ll ~ i' l{J~ ~.~l that t.he1 ha,,~ fo:"lffel.':,t(lc1 a
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satisfactory division of their furniture, household furnishings,
appliance~, and other hous~hold Bnd personal property between
them, including any ilnd all motor vehicl<ls owned by them; they
mutually agr~e that each party shall, from and af.ter the date
hereof, be the sols and separate owner of all such tangible
personal property presently in his or her possession, whether
said pro~erty WilS heretofore owned jointly or individually by the
parties hereto; and this Agreement shall have the effect of an
assignment or receipt from each party to the other for such
property as may be in the indiVidual possession of each of the
parties hereto, with the effective date of said bill of sale
being the date of actual transfer and in no case later than the
date of this Agreement.
21. INTANGIBLE PERSONAL PROPERTY
Intangible personal property has baen exchanged to the
mutual satisfaction of both Wife and Husband.
22. SEPARATE ASSETS
A. Rel,>a"e: The padies hsreby agree that as to each
of their separate assets, as that term is defined herein, the
party not having title to or possession of any particular
separate asset hereby walve9, rel@ase", relinquishes and forever
abandons any and all clai'11 therein, and acknowledges t.hat
heFeaft@r the party havicg title to or pos~ession of a s@parate'
asSet is the sole and exclusive owner thereof.
B. Definitio)t~: ".'h,~ toOrm "sep,lrate asset" is defined
for purposes of thim AgreAment. ~3 designating any a~Ret of ~ny
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kind (whether rmal, personal or ,mixed, tangible or intangil;lle)
which is presently titled either in th~ Dole name of a party
hereto or jointly with one of the parti.~ hereto and a third
party or parties. The term also includes any untitled asset
which is preneotly In the solo possession of one of the parties
hereto. The term shall further include aoy business interests
owned by either party, whether individually or together with a
third party or parties.
C. Indemnifi(,atioll a,s to Expenses: Each of the
parties hereby guarantees to indemnify and hold the other
harmless from any liability, co~t or expense, including
attorneys I fees and l.nterest, WhlCh ei ther may he in the future
or has been previouuly inclIl.r,?r! ',Iith reilpec( to the pal.ties'
separate assets as defined herein.
23. AFTER-ACQUIRED PROPERTY
Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other, all items of
property, be they t'~al, personal or mixed, tangible or
intangible, which Bre 3cquirpd by him or her after October 13,
1995, with full power in him or her to dispose of the same as
fully and effectiv,oly. in all resp"cts and for all purposes, as
though h~ or she were unmarried.
24.. EXI STING AND r'UTURF: PERSONAL OBLIGATIONS
The partie~ hereby agree that all existing personal
liabilities, debts and obligations of every description which
have been inclIrred by eith"r of them shall be paid in a timely
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COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CUMBER1,ANI>
T/~
On this, th,' 13 - day of n"",,'>rnbpr, 1'lCJ5, b..fore me, the
llOdersignf.!d off l""I', t''''t>H1I1C;i l y app..ared KATHY L. GRIFl"IE, )mown
lo me (01 RatI9(a~tollly prov"n) t,) b" th.. person whoge namp is
subscribHd to th. within Agr....ment, and arknowlHdged that she
e:(ecut..,l sal1l" for th.. P"I'PtJSHS th"'I.'11l '~olltained.
IN WITNESS WHEREOF, I
selll,
h..lPWlto set illY handual l fficlal
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c'/~/~.e.~L.___':.~"~( SEAL)
Notal' y punll"
COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CUMBERLAND
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On this, the /,r- day of De"emb.." 1995, h"fore me,
the undersigned offlcer, personally appeared KEITH A. GRIFFIE,
known to me (or 9ati.f~ctorilr proven) to be the person whose
name is subscribed to the within Agreement, and acknowledged that
he p:(p.cuted :'lame for th.~ pllrposes t'h'-;l'<lin cOllt,ained.
IN WITNESS WHEREOF, I
I sea l.
her,,"nto set. ,lilY r:a/jd O~ficial
~~;~_.L-MZ2"'~ .lSEAL)
Notary Punlic
[ NoIMBI SeeI
Wi~~m 5, D.,,~~ NotaIy NlIo
CM,e Bora, CUll'Il8rland C<llI1IlI
, My r.;o.r'nlillslon Expirue 01:1. 19. 1.
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KATHY L. GRIFFIE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
crvrL ACTrON - I.AW
KEITH A. GRIFFIE,
Defendant
NO. 5099 CIVIL 1994
rN DIVORCE
pM)!;cIf' E TO'j.'RMPiML'L RECQJlD.
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
Sectlon 3301(c) of the DivorcD Code.
2. Date and manner of servicD of the complaint:
Service by certified Mail (personal service), under Rule 403
[402(a)] on Occober 7, 1994.
3. Date of execution of plaintiff's Affidavit required by ~
3301(c) of the Divorce Code:
By pi a i nti f f :_pecet)lp.~r_13.L1995; By De ftmdant :peG.eml:1er..l!;i..._1.9,9.5
4. (a) No related claims are pending.
(b) A true and correct copy of the fully executed
Marital Settlement Agreement is attached and is to be
incorporated in the Decree by Supplemental Decree.
(c) No request for
counseling has been made by either
--"
h:/c::. ~~.LavA
William S. Daniels
Attorney Eor Plaintiff
party.
Date: /). -/9 d)S-
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in this or allY l.lUllH juosdictLQll.
7. ~laintiff has baen advised that counseling is available
and thllt pluntiff 1M I' hav" Lh_ right to l.;;quest thdt th.1 cour:t
r~quire the parties tQ partiGlpatB in counseling,
COUNT r
8, The prior paragraphs at thLs complaint are incorporated
her~in by lefer"nc" theretu.
9. The marnage is irretrievably broken,
WHEREFORE, plaintiff rospectfully requests the Court to
enter a decree of divorce pursuant to ~ 3301(c) of the Divorce
Code.
COUNT II
10. 'l'he pricll.' ,paragraphs of this Campi aint are inco,porated
herein by reference thareto.
It. Thp. publir. policy of the Commonwealth of Pennsylvania
encourages parti~s to a marital dispute to negotiate a gettl~m8nt
of th~ir differences,
12. While no settlement has bean reached as of the date of
the filing of this ComplaLnt. Plaintiff is and has always been
willing to negotiate a fall and reasonable settlement of all
matters with Defendant.
13. To i'.h€t e:(ten~ that a written sett,lement agreement mlght
be enter'ed into between tho? partLes prio!: to the Ltl~\.. of a
hearing on thi:; '~'Jmplaint, Plaintif:f desin's that such written
3gteemerlt ~~ approved by tht~ CUlint a:llj locorporated in any
dL'JotCt~ fl,,,,'_'r~2'f.' '.lhil:h llhl'f ;)8 !?ntpl:f.~r.i'(i:,;:)l)iv"i.l-lg tb1;~ :nat'riaye
b~~twe~~-. t.h~! palLle.s,
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KATHY L. GRIFFIE,
Plaintiff
IN THE COURT OF COHMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
t, CIVIL ACTION.. LAW
KEITH A. GRIFFIE,
Oefendant
No. 5099 CIVIL 1994
IN DIVORCE
M':.V.P.lWJ 'l'_Q.F~S:.Q!'! I'lRl'!.T..
1. A Complaint in Divorce under 53301(c) of the Divorce
Code was filed on September 9, 1994.
2. The mardage
irretrievabl:,t, broken.'
of the Complaint.
of the Plaintiff and Defendant is
Ninety days have elapsed since the filing
3. I consent to t~e entry of 3 final decree of divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if r do not claim
them before a divorce is granted.
5. I verify tHat the statements made in this Affidavit ,are
true and correct. r understand that false statements herein are
made subject to the penalties of 18 Pa.C.8. 5 4904 relating to
unsworn falsification to authorities.
Date: December 13, 1995
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KATHY L. GRIPPIE, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I CIVIL ACTION - LAW
I NO. 94-5099
lIITH A. GRIFFIE, I
Defendant I IN DIVORCE
NOTICB OP IN'rBNTION TO RBSUJIB PRIOR HAIIB
Notice is hereby given that the Defendant in the above
matter, having been granted a final decree in divorce on the 29th
day of December, 1995, hereby intends to resume and hereafter use
her previous name of KATHY L. YOST and gives this written notice
avowing her intention in accordance with the provisions of the
Act of April 2, 1980, P.L. 63, No. 26, 23 P.S. section 702
(effective July 1, 1980).
f
r
M
STATE OF PENNSYLVANIA I
I S8.
COUNTY OF CUMBERLAND I
On the ~ \ S:>r- day of -s:lr...; ~'=1. , 1996, before me, a
notary public, personally appeared Kathy L. Yost (formerly known
as Kathy L. Griffie), known to me to be the person whose name i.
subscribed to the within document and acknowledged that she
executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and
~~"
tl a- blic
seal.
~-_...
NOIARIAL SEAl
SHlLl.V O. SEXTON. NOTARY PUBLIC
CARLISLE BORO, CUMBERLANO COUNlY
MY COMMISSION E~'IRES APRil 2&. 1991
MttMtr. "nnayNtnIIAuoc~1I0n ot Notifies
---