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HomeMy WebLinkAbout94-05462 ~ t], E - o ' :::r: . -j 'tJ €: - o ::r ~ r- , J <0 ~ :::z- lo 'l I ':T cr~ ~ :!. ~ ~ ~ ~' ~ . , ~~ ~ *- ~ ~ :!.. ~ ~;' ...1 ,',: .!-( ~.' i ~i . , ~i . , ~, ~I ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~ " Ii! :0' ..~: :.: -:.;.:.:. :.:-;.:- :.;. .;.:- -:.;, .:.;. :.: '.:- :.~'.: :.: :.: ..: :4: :.; ;.:-:. <.;.:.~ -:.:. <~:. .'.;' -:.;. -:.;. -:.;. .:+;. ';4 ,,,, .., :..; :.. ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY '"{. STATE OF ;r~~~ PENNA, \......J~.~f LAURA R. !lOLHES, Plaint Iff i': (). 5462.. CIVIL (I) 94 \' t'l'.~ll.; KENTON D. !lOLHES, Defendant DECREE IN DIVORCE AND NOW, . .. ,~f1,~.. ~. ~ '. 19 .q~.., it is ordered and decreed thot LAURA R, !lOLHES KENTON D, !lOLHES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., plaintiff, . .. . . . . . ' . . .... . , . .... . " defendant, and I~ I~ i':' I~ ~ I~ ,,, i : ;~ i' )~ ) . It is ordered that the Harital Settl.em.en.t. As.re.em.ent, ,da,te.d, ,J.u,ly. .2.~, 1998, * are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which 0 final order has not yet been entered; NONE. is incorporated herein. but not merged.. il'..'.... I E v ~.r ~','.-ij,(. ~: , Alt",I: d</.-n~ff-.d~1 f1k"'k...d~'L/ - --/;1"lC-- [J\777e-..)']('l....( ,06tj-- ) ('.. Pn)lho,{;'i~ ~::~:.:.:.:':~.:~':.:'~,.:~':.:.~~..~:..~:.~.~..~,~:.:.:..~:,.~: ~ ~ I~ I" l~ .~ ~ ~ ~ ,~ .~ ., * * ~ ~ ~, ~ ~ '.' .;, ~ '.' ~ '.' * ~ '.' '" ,., ~ ~ '~ ~. i',. "~ ~ ~ ~ ~ :~' ~~ .:.;. i'/''I/ci)) - C,,',d . ("1)'/ HI';, ',{fee -Io/')/Iy .Ll.,vSdv &-,/'9/91 - j2't.,.J,c'C'/l~ ,'l..:rC -/0 IH+y U \!Ud.~L ... NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound, covenant, promis~ and agree as follows: 1. Aqreement Not a Bar to Divorce Proceedinqsl A divorce proceeding has been commenced by Wife by Complaint filed to No. 94-5462 in the Court of Common Pleas of Cumberland County. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code. Upon the signing of this Agreement, the parties also agree that they will both sign Affidavits of Consent and Waivers of Notice of Intent to Request Entry of a Divorce Decree Under Section 3301.(c) of the Divorce Code. The, parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as the final Decree in Divorce may be entered with respect to the parties, and shall be fully enforceable by the Court. No Court may change the terms of this Agreement which shall be enforced in accordance with its terms. 2. SeDarationl It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place that he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either 2 . . party of the lawfulness of the causes leading to their living apart. 3. Interferen~el Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt tQ endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 4. Wife's Debtsl 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 shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 5. Husband's 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 shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 3 medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circum- stances of each party at the time the division of 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. A. Distribution of 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. The vehicles owned by each party at the time of their separation were both pre-marital purchases. Therefore, both parties will retain their respective vehicles. 5 The parties hereto have also divided between themselves, to their mutual satisfaction, all items of intangible marital property. Following is an itemization of the intangible personal property to be retained by each separate party: WIFE HUSBAND Mainstay Mutual Funds (Acct. Nos. 79809377 and 79809376) U.S. Savings Bonds Marital Portion of Union Central Life Insurance Company Tax Deferred Annuity Marital portion of Waddell & Reed Mutual Funds Statement Savings Account at Mellon Bank, N.A. (Acct. No. 00126-750131) 1994 Income Tax Refund 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 agree to sign, upon request, clny titles or documents necessary to give effect to this paragraph in order to properly transfer each specific item to the spouse who is to retain the item. The spouse who is to retain a specific item will be responsible for obtaining any required documents in order to effectuate the transfer. 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 G evidence of ownership, such as passbook, checkbook, certificate of insurance or other similar writing possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits, except as stated herein. policy or is in the 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, convey, or 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~ B. Distribution of Real Estate. Husband shall transfer to Wife, and any other co-owners, concurrent with the execution of this Agreement, all of his interest in and to their jointly owned real estate at 500 Haldeman Avenue, New Cumberland, Pennsylvania 17070. Wife shall transfer to 7 . . Husband, concurrent with the execution of this Agreement, all of her interest in and to their jointly owned real estate at 312 Tenth Street, New Cumberland, Pennsylvania 17070. Wife shall be responsible for the preparation and recording of the Deed to 500 Haldeman Avenue; and Husband ahall be responsible for the prepara- tion and recording of the Deed to 312 Tenth Street. In the event a party fails to make two consecutive mortgage payments on the real estate they are to retain, such property will be immediately listed for sale. Within three years from the signing of this Agreement, both parties agree to remove the other party's name from the mortgage obligation attached to the real estate each party retains, either through satisfaction of the current mortgage, refinancing of the current mortgage, or by obtaining a written Release signed by the mortgage company, completely releasing the other spouse from any personal liability or obligation on the debt. Until the time that refinancing or release of both parties takes place, Husband's attorney shall retain custody of the Deed transferring title to Husband alone, and Wife's attorney shall retain custody of the Deed transferring title to Wife alone. Each Deed will be recorded when the necessary names have been removed. From the date this Agreement is signed to the date of satisfaction, refinancing or obtaining of a Release, each party agrees to be responsible for payment of the mortgage, all current and future taxes, insurance and utility bills relative to the real estate retained. Each party agrees to indemnify each other from 8 any loss by reason of his/her default in the payment thereof, and agrees to save each other harmless from any liability with regard to the cost of defense and actual counsel fees incurred to defend against an action brought against him/her by virtue of his/her default. C. Cash Distribution. In consideration for the transfers of the above-referenced two parcels of real estate, Husband shall pay to Wife the sum of $2,000.00. The $2,000.00 shall be paid at the time this Agreement is signed. 8. A1imonv: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them, and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife fu~ther, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indemnify, defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indemnity to include the actual counsel fees of the defendant in any such future action. 9 9, Alimonv Pendente Lite. Counsel Pees and Expensesl Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties is fair, adequate and satisfactory to them. Both parties shall accept the provisions set forth in this Agree- ment in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses, or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. Each party shall be responsible for his or her own counsel fees, and each agrees to indemnify, defend and save the other harmless from any action commenced against the other for alimony pendente lite, counsel fees and/or expenses. 10. Re1easel Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for hlmself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release, indemnify (including actual legal fees) and discharge the other ':If and from all causes of action, claims, rights, or demands, whatsoever in law or equity, including equitable distribution, spousal support, alimony, counsel f€es, alimony pendente lite. and expenses which either of the 10 parties ag~inst the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or under any other statutory or common law, except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling, pursuant to ~3302 of the Divorce Code. 11. Waivers of Claims Aaainst Estatesl 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 laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and any right existing now or in the future under the Pennsylvania Divorce Code, as amended from time to time, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 11 12. Riqhts on Executionl Immediately upon the execution of this Agreement, the rights of each party against the other, despJte their continuing marital status, shall terminate and be as if they were never married. 13. Breachl In the event of breach of any of the terms of this Agreement, the nonbreaching party shall be paid, as part of any award or judgment against the breaching party, all costs, including actual counsel fees paid to his or her attorney. 14. Incorporation in Final Divorcel The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties. This Agreement shall survive in its entirety resolving the spousal support, alimony, prope~ty and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania. This Agreement may be enforced independently of any support order, divorce decree or judgment and its terms shall take precedence over same, remaining the primary obligation of each party. This Agreement shall remain in full force and effect regardless of any change in the marital status of the parties. It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement. 12 15. Additional Instruments I Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party, any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 16. Separability: In case any provision of this Agreement should be held to be contrary to, or invalid under, the law of any country, state or other jurisdiction, such illegality and invalidity shall not in any way affect the other provisions hereof, all of which shall continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate and undisputed covenant and agreement. 17. Entire Aqreement: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants and undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them, based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final 13 settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any Court of competent jurisdic- tion pursuant to Section 3502 of the Divorce code or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a Court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose ot enforcing the provisions of this Agreement. 18. Modification and Waiver: A modification or waiver of any of the proviaions 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 lnsist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 19. Voluntary Execution: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the 14 '. financial affairs of the other which has been requested by each of them or by their respective counsel, 20. Descriotive Headinqsl The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the right& or obligations of the parties. 21. Aqreement Bindinq on Heirsl This Agreement shall be binding and shall inure to the benefit of the parties hereto, and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year first above written. WITNESS: (\ ( )' -1j,L rn )1- kILCk.:.... 'l)bWt- ~ 7~~!)~~ KENTON D. HOLMES M'~. --fl1J~ LAURA R. HOLMES 15 ~ _"l" C (.~ r"=: " , \. " I ~: .~ ~~. j \':1 I ~~ , , .. 'J ,.'..... l. , .... r.:: ,.. ~, ':J U .. , C', ~ LU ( :. ; - ,.. ~ ~: .-:'1 I , , , i... , C' /. -..: I (~: ";;'; I C. , U IBt;;~ a:~~;;!il ~o(~~~ .,~~a.,... a:~~;;!E: ~o4:;J:t:. ~ I:: - ... a: 0( l:l ::Ii 5 ....KI.e. .'J.",.'~.(lI"....r'... UO<nltO, O~.".",..... 'l'otJ111oul ny REAGER , ADLER, PC BYI DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 127 state street Harrisburg, PA 17101-1025 Telephone: (717) 234-1383 Attorneys for Plaintiff LAURA R. HOLMES, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO . 'i 4 - ') LI<..> ',J.. KENTON D. HOLMES, Deftlndant DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in th~ 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. 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, Room 101, Dauphin County Courthouse, Front and Market streets, Harrisburg, 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. Cumberland county Lawyer Referral Service Cumberland County Courthouse Court Administrator 4th Floor Carlisle, PA 17013 (717) 240-6200 '. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to section 3301 Cc) or Cd) of the Divorce Code. Respectfully submitted, REAGER , ADLER, PC Datel September 23, 1994 By: 3 VIlRIJ'ICATION I, Laura Holmes, verify that the statements made in this Complaint 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. ~Q.UML- .Jdl-0Yl~ Laura Holmes Date: September 21, 1994 4 ---- ...., i , l-l t; . , lit ~ -...,; ...... ~ . " . ~ ---J. c:n - \~ I ,...., 0 I~ .', I.~ Ii') r() en h~) ,...... ':t' r ~ r "" - '. I .-~ ':tl ~ U, VI ::J ".I.. cJ .. s ~~m~ Hi .. ~ r.: iii ~ o(i I!! ::. ~ . c c.:J _ ! Iii!!i r.: I;; 01 r:: 1= ~ ll1 0( ~ . PI.linliff : IN THE COURT OF COMMON PLEAS :CUMBERLf\ND COUNTY, PENNSYLVANIA LAURA R. 1I0LMES, v. NO. 94-5462 CIVIL TERM KENTON D. 1I0LMES, Defendunt DIVORCE AFFIU,\ VIT OF CONSENT I. A Compluint in divorce under section 330 I (c) of the Divorce Code was tiled on April 6,19911. 2. The marriage of Plaintiff and Defendunt is irretrievably broken und ninety (90) days have elapsed from the date of tiling the Complaint. 3. I consent to the entry of a !inul decree of divorce ufter service of notice of inlentionto request entry of the decree. 4. I understand thutl may lose rights concerning alimony. division of property, lawyer's fees or expenses if I do not c1aimthem before u divorce is grunted. I verify thut the stutemenls made in this affidavit arc true and correct. I understand that fulse statemenls herein arc made subject to the penalties of III Pa.C.S. * 4904 relating tll unsworn falsi!ication tll authorities. Dated: 7/23/.-/6 ~AJ1' 7f /J~f Laura R. Holmes ?;; ct. ;- ... -'J U.J("j (~~ ". ~.., , d I_f,' .:r: '.)c', , :10', (!),. ~ " 6/ ,) ~ !:/ ...... ...;:} '" ..':,') crill 1,' eJ -;."'-; ~, ., Ll =1 .;. ~, l; ::.~ '-.10.. <0 ", ~~!d ~!;(~~~ ~!:!~~~ :~$;1~ l!J ~ ~ J:... ~Sfi~- ............ .'~ .",,,. 'lJ II., _II' Iii ~~'_' l," "'''''f ~,.,. .......'.. .....jl' J...i '1"f .... a) f: ,r -~ ~ ~ Co M :.j....... II)..;. '5" ~f,.J .~ ,: :--= tl: .~ ~'. r"J:"'J l..' r- . r.i t. u:,( ~. N I>: . j -' 'c~: c.cl,l_) :IIIU f::" ::.J "Jo. .., ". ~ a:> S 0' u ~~!tl ~ ~~~ :; lil ... ~~ ~ ~ ~ :~i:i ... wO: _ !:: CIa :x: !:: i:\ I: - C1. o:<(a~ "\0 !KI." <'0 "1.1I.1Q ('!~....II t,,,, OI'9mtO. OJ'ld.o/'\ tftlll Ij,n n, .. ______0 ..._......-.~._..._"_.__ .__ LAURA It HOLMES, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 94.5462 CIVIL TERM KENTON D. HOLMES, Defendant DIVOI{CE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330llCl OF THE DIVORCE CODE I. I consent to the elllry of a Iinal 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 tiled with the Prothonotary. I verify that the statements made in this aflidavit are true and correct. I understand that false statements herein are made subject to the penalties of I H Pa.C.S. * 4904 relating to unsworn falsilication to authorities. ~lJML -R ~ Dated: 7/23/1t Laura R. Holmes ,,' '.. ?i: '..: IJ-. .'. o<l. f,,"';: . 1,,- ... ; )~'.. Cl uj.'~ r: \._1:1. [.ll') " ~? U- " ~ "'_.j .'. ;~O <' r- . ~ t t.' f},\.\ N ,"-' _I ~tlG) - n. -;:J ,\~l',l.. flO ..., ~ ~ al :J 0'1 (.) N .~ ~ W; ~~~~~ ~~~~~ a:~$;!~ WO:E:I:t:. ~~a~ -~. ~'~ .........~ .-.. ~- ....~,......''o\,...'.I.'...''ll'". ........."..'))..........',..."1'1"."1.. , . REAGER , ADLER, PC BYI DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 127 state street Harrisburg, PA 17101-1025 Telephone: (717) 234-1383 Attorneys for Plaintiff LAURA R. HOLMES, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA plaintiff v. NO. 94-5462 CIVIL TERM KENTON D. HOLMES, Defendant DIVORCE AFFIDAVIT OF SERVICE Debra A. Denison, Esquire, being duly sworn according to law, deposes and states that service of the Complaint in Divorce in the above-captioned matter was served on Defendant's attorney, Jill M. Wineka, on September 29, 1994. A copy of an Acceptance of Service is attached hereto as Exhibit "A". Respectfully submitted, REAGER , ADLER, PC Datel October 3, 1994 BYII HI'"tTcKOUIH Exhibit A . . No. 6303 . . I . . . . . REAGER , ADLER, PC BY' DEBRA A. D!NlSON, ESQUIRE Attorney I.D. No. 66378 127 state street Harrisburg, PA 17101-1025 Telephone: (717) 234-1383 Attorneys for Plaintiff LAURA R. HOLMES, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYI,vANIA Plaintiff v. NO. 94-5462 CIVIL TERM KENTON D. HOLMES, Defendant DIVORCE ACCEPTANCE OF SERVICE On behalf of my client, Kenton D. Holmes, I hereby accept service and acknowledge receipt of the above captioned Complaint in Divorce, having received at the offices of Purcell, Krug & Haller at 1719 North Front street, HarriSburg, Pennsylvania, 17102, on the IA. 7fi day of September, 1994. J ~ ~ :r.: --. 3 .'" => -:r 0- .g - l[ I ~ a!~$; ~ ~ ~ ~ ~ · i I!! ... :I _ ;c CJ ... - Iii '" - ~ I: !:; il g ill <( ~ ll! ~ .. . . . . . . . / - ..) L L_ . .'_.. . ~-_.__. ....._.._...._--_._"~.._-_....<-.. LAURA R. HOLMES. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA PllIintiff NO. tJ4 -- jUl.. 1/. KENTON D. HOLMES. Dcfcndllnt DIVORCE PRAECIPE TOTHE PROTHONOTARY: The Sodlll Security numberoflhe PluintilT. Luura R. Holmes, is IllO-56-9611. The Sodul Security numher of the Defendunt.Kcnlon D. Holmcs. is 175-411-70119. Rcspectfully Submitted, REMiER & ADLER, PC , DlIle: July 28, 1998 By: 2331 MlIrket Street Camp Hill. PA 17011-4642 Telephone No. 1717) 763-13113 Attorneys for Pluintiff " .,,, ( r~ ;::: " , " I! tOJ i..... I , --,.'., t '~ . ,I ~ '.- ( I' c.. ~:. .i..i " ;J , Cr, 'r l. hJ ;: ;/1 .. -.1 I .~ , ..." '.liO :'';'j 1.1'1. " "., :lj I.) f;n [.) ~~~i ;~~~~ oIl~~~~ ffi~i~f: ..,0 Xc ~~a~ .-y ...... .....- ~._>--.... .... <K,.." '!l..,.,~. 'II ~.....," ,0 t..."t l.'fo"IiO. O'.l.kJ'-"YlJJllluS 11. ----,' '~""'"'-""."'>,~c."'_~,,"";_....o-...+,-",:..., "',.o..,.,..:~""",->-""". LAURA R. HOLMES, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 9~-5~62 CIVIL TERM KENTON D. HOLMES. Dcf~ndant DIVORCE NOTICE OF EI.ECTION TO RETAKE MAIDEN NAME Notice is hereby giv~n thatth~ Plaintiff In th~ abuv~ mall~r. having been granted a Final ~'th Decree in divorce from the bonds of matrimony un th~ I () of (\lI~lld- 1998, hereby elects to retake and her~after us~ her previous nam~ of Lau~Reim~r.to.-il ~@M- 1< ~ Laura R. Holmes TO BE KNOWN AS: J. __ . A d'~ CIAvtv ~y \n. Laura"Rcimer COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF JI'Ih ~ On the I.. day ofU C \ l: , 1998. before me a Notary Public personally appeared Laura R. Holm~s tlb/k/a Lau Reim~r, known to me to be the person whose name is subscribed to the within document and acknowledg~d th.lt she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereuntu set my hand and official seal. j'jj'l'C( (L. 7/), 1-/{7/>),.JL ~ ~ Notary Public Nolal\lll Seal " Unde M. HaIIwnon. Nol8ly Pl&blic ~.. eo.o. c:..1lbo....'" CcuIIlv Mp ClOnmsIon EJpiIoo Fob. 26. 20ltl 1Iiimtlor. . Aisoclaticn 01 Nt1""..~ "'_.'. ,,;-;.;. .:-. ...". ..r_ ... ,.'~"'l!h..,.. '."....-.. .li..' OlIINO, O'l''-'tIl1'tlJllnU ,...