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.1 IN THE COURT OF COMMON PLEAS ..
8 OF CUMBERLAND COUNTY ~
:1 ;
~' STATE OF PENNA. .
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8 JEB.RY C.MORRISON. .
8 Plaintiff No. .67Q!l.p PP.'P.P. 1994 ,
~ VPJ'~lIS 8
~ HARDEE A. MORRISON, 8
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Defendant
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DECREE IN
DIVORCE
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AND NOW, . . , , . . . p~~:-. . . . ~.f ~ . " 19. ~J:-; " it is ordered and
decreed that ."..,....
JE~~Y.C..MO~~ISON.
. . . . . . . . . . . . . . . ., plaintiff,
. . . . . . . . . . , . ". defendant,
and . , , , . . . . . . . . . . . . . . . , ,. . MARD.F.F; 1\,. Xo.R.R.I.S.O.t{
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which hove
been raised of record in this action for which a final order has not yet
been entered;
." .~vne,. .the.ijttaGheq.P4~t~N4Ptial.Agre~ment.is.i~curpo~~ted.b~.ref~:~~~~
herein. but nut merged intu thls Decree.
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POST-NUPTIAL AGRBEMENT
THIS AGREEMENT made and entered into this ~~ day ot
O~I~ , 1995 by and between:
JERRY C. MORRISON, of 153 Locuet Grove Road,
Dilleburg, Penneylvania, party ot the tiret
part, (hereinatter "Husband"),
AND
HARDEE A. MORRISON, of 205 Beaver Drive,
Mechanicsburg, Pennsylvania, party ot the
eecond part, (hereinatter "Wite").
WITNESSETH:
WHEREAS, Hueband and Wife (collectively reterred to herein
ae "the parties") were married to each other on June 17, 1988,
in Cumberland County, Pennsylvania; and
WHEREAS, prior to the parties' marriage, they entered into
a certain Antenuptial Agreement dated June 16, 1988 whereby they
agreed, inter AliA, to waive and release all rights, claime,
title and interest in and to the property of the other acquired
by rea80n of their marriage. A true and correct copy ot the
Antenuptial Agreement is attached hereto and incorporated by
reference herein as "Exhibit A"; and
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WHEREAS, the parties hereby have accumulated certain a..eta
and property during their marriage;
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WHEREAS, the parties hereto have had no children of their
marriage; and
WHEREAS, certain differences have arisen between the
parties, as a consequence of which they have heretofore
separated and now live separate and apart from each other; and
WHEREAS, on October 31, 1994, Husband commenced an action
in Divorce docketed to No. 94-6208 Civil Term in the Court of
Common Pleas of Cumberland County, Pennsylvania (hereinafter
referred to .s the "Divorce Action"); and
WHEREAS, the partie. agree that their marriage is
irretrievably broken; and
WHEREAS, the parties acknowledge that each has had the full
opportunity to be advised independently and repre.ented by
.eparate counsel concerning their respective rights, duties and
obligations arising out of their marital status; and
WHEREAS, the parties having a full opportunity to be so
advi.ed of their respective rights, duties and obligations
ari.ing out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and
all other aspects of each other's property and their jointly
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owned asset. and liabilitie., have come to an agreement for the
final .ettlement of their property and affair..
NOW THEREFORE, in con.ideration of the.e pre.ent. and the
mutual covenant., promise., terms and conditions hereinafter set
forth and to be kept and performed by each party hereto, and
intending to be legally bound hereby, the partie. mutually agree
a. follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and
paragraphs are incorporated by reference herein in their
entirety.
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2. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION. The
parties declare and agree that they have, prior to the execution
of this Post-Nuptial Agreement, VOluntarily agreed to divide and
have phy.ically divided and distributed between themselves all
a..ets which they acquired during their marriage, whether or not
said property is or would be deemed to be marital property under
penn.ylvania Divorce Code and subject to equitabl~ di.tribution.
The partie. further declare and agree that prior to the
execution hereof, they have voluntarily distributed between
themselves all assets and property which each brought with them
into their marriage. The parties acknowledge and reaffirm their
understanding and agreement respecting the property of the other
a. expressed in the Antenuptial Agreement attached hereto as
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"Exhibit A."
The parties deolare and aoknowledge that they are
fully aware and familiar with all assets and property that each
have brought into the marriage and that have been obtained or
aoquired separately or jointly by them during the oourse of
their marriage and therefore waive any evaluation thereof. Each
party expressly releases the other of and from any and all right
of equitable distribution or claims to assets and property of
any kind or nature whatever possessed by the other party. The
parties further declare that they have not acquired and
ret~ined, either separately or jointly during their marriage,
any interest in real estate, except that noted in Paragraph 3,
below.
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3. REAL ESTATE INTEREST OWNED BY OR ACOUIRED BY WIFE.
Husband acknOWledges that Wife prior to marriage to Husband
owned a 1/3 interest in a parcel of real estate improved with a
residence ("property") located at 301 loth street, New
Cumberland, Pennsylvania and that during the parties' marriage,
Wife'. ownership interest in said property increased from 1/3
ownership interest to a 1/2 ownership interest. Husband hereby
releases and waives any interest, right or title in and to said
property that he may have by virtue of his marriage to Wife and
acknowledges that Wife shall own and retain all of her interest,
right and title to said property free of any Qlaims, right,
title or interest of Husband.
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4. PENSION. 401K. RETIREMENT PLANS. BENEFITS AND
EMPLOYMENT BENEFITS.
Each party waivos and torever releases the other ot and
from any and all claims which either may have against the
other's pension, 401K retirement plan or any other retirement
plan, benefit or employee benetit or benetits. Wife agree. to
execute all documents necessary to relea.e and/or terminate her
right to be a beneficiary ot survivor's benefits under Husband'.
pension.
5. DIVISION OF LIABILITIES. The parties declare and agree
that they have divided and allocated between them.elves all
d.bts and liabilities, whether or not incurred by them during
the course ot their marriage. Husband agrees to hold harmle..
and indemnify Wife of and trom any and all debts, damages, costs
and expenses which Wife may incur directly or as a result of
Husband's tailure to payor discharge any debt a..umed by him,
allocated to or to be paid by him. Wite agrees to hold harmless
and indemnify Husband of and from any and all debts, damages,
costs and expenses which Husband may incur directly or as a
result ot Wite's tailure to payor discharge any debt assumed by
her, allocated to or to be paid by her.
6. FUTURE OBLIGATIONS. The parties agree that any and all
obligations incurred subsequent to May, 1994, being the time of
.eparation ot the parties, shall be thQ sole and separate
liability and responsibility ot the party incurring the
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obligation and each party agrees that he/she will not incur or
attempt to incur any obligations for or on behalf of the other
party and will indemnity and hold harmle.s the other party ot
and trom any and all liability arising trom such tuture
obligation.
7. COUNSEL FEES. Each party to thi. Post-Nuptial
Agreement shall be responsible tor paying his or her own counsel
tees and related costs associated with the processing ot the
Divorce Action and the negotiation, executlon and consummation
ot the provisions ot this Post-Nuptial Agreement.
8. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE. Each
party waives and torever releases the other party of and from
any and all claims which either may have againat the other for
spousal support and for all claims which either may have against
the other by reason of and pursuant to the Pennsylvania Divorce
Code (and the divorce law of any other jurisdiction) inClUding,
but not limited to, alimony, alimony pendente lite, equitabls
distr.ibution of marital property, counsel fees, costs and
expenses, except that the performance of any obligation created
hereunder may be enforced by any remedies under the Pennsylvania
Divorce Code.
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9. DIVORCE. The parties agree to terminate their marriage
by mutual consont without counselling and each ftgrees to execute
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the necessary affidavits and consents to procure a consensual
divorce under the provisions of the Pennsylvania Divorce Code,
such documents to be tiled in the Divorce Action.
10. GENERAL RELEASE. Husband relinquishes his inchoate
inte.tate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of
the parties hereto by these presents, for himself or herself,
his or her heirs, executors, administrators Qr assigns, does
hereby remise, release, quit-Claim and forever discharge the
other party hereto, his or her heirs, executors, administrators
or assigns, or any of them, ~f any and all claims, demands,
damages, actions, causes of action or suits at law or in equity
of whatsoever kind or nature, for or because of any matter or
thing done, omitted or suffered to be done by such other party
prior to the date hereof, except that this release shall in no
way exonerate or discharge either party from the Obligations and
promises made or imposed by reason of this Agreement.
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11. SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Post-Nuptial Agreement shall survive any
action in divorce which may be instituted or prosecuted by
either party, and no order, jUdCJlll.ent or decree of divorce,
temporary, interlocutory, final or permanent, shall affect or
modify the terms of this Agreement, but ~aid Agreement may be
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enforced by any remedy at law or in equity, including
enforcement proceedings under the Pennsylvania Divorce Code.
The partiee agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this
Agreement shall not be merged into said order or decree in
divorce.
12. COOPERATIQU. The parties agreti to cooperate with each
other and to make, execute, acknowledge and deliver such
instruments and take such further action as may hereafter be
determined to be requisite and necessary to effect the purposes
and intention of this Post-Nuptial Agreement.
1J. VQLUNTARY EXECUTION. The parties declare and
acknowledge that they have had the opportunity to have the
provisions of this Post-Nuptial Agreement and their legal effect
fully explained to them by independent counsel of their choosing
and each party acknowledges that this Poet-Nuptial Agreement ie
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 partie.
acknowledge that they have been furnished with all information
relating to the financial affairs of the other to the extent
same has b,en requested by each of them,
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14. ENTIRE AGREEMENT. This Post-Nuptial Agreement
contains the entire understanding of the parties and there are
no representations, warranties, covenants or undertakings other
than thoee expressly set forth herein. The parties acknowledge
and agree that the provisions of this Agreement with re.pect to
the distribution and division of marital and separate property
are fair, equitable and satisfactory to them based on the length
of their m~rriage, their Antenuptial Agreement and other
relevant factors which have been t&ken into consideration by the
partie.. Both parties hereby accept the provisions of this
Agreement with reepect to the division of property in lieu of
and in full and final 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 jurisdiction pursuant to the Pennsylvania Divorce
Code or any amendments thereto. Each party voluntarily and
intelligently waives and relinquishes 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 tor the
purpose of enforcing the provisions of this Agreement.
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15. WAIVER. The waiver of any term, conditions, clause or
provision of this Agreement shall in no way be deemed or
considered a waiver of any other term, condition, clause or
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h.r.of. .nd to conlult wlth f..lly ...b.r.. .nd coua..1 of th.lr ova
choO.1nl' Th.y .cknowl.dl' th.t the cont.nt. of thl. Alr....nc aDd
tha 1'1.1 con..qu.nc.. h.r.of h.v. b..n ..p1.1n.d to ch... .nd ch.c
Ch.y fully und.r.t.nd the .....
VI. J.rry C. Korr1.on do.. h.r.by cov.nanc .nd 'Ir.. wlch Hard.. A.
Toporc.r that h. wlll n.lth.r dur1nl chI 11f.c1.. of Hard.. A. Toporc.r
nor .ft.r h.r d..th t.k.. clai.. d.mand or r.c.1v.. .nd do.. h.r.by
waiv. .nd r.1.... .ll rilht.. c1.1... t1tl.. and lnt.r..c.. .ccu.l.
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lnchoat. or contlna.nt. ln law .nd .qu1ty whlch h. ai.ht. by r...on
of hi. ~rr1al' to Hard.. A. Toporc.r. .cqulr. ln h.r prop.rty or
..t.t.. lnclud1nl. but not 11.1t.d to:
(A) lilht or claim of dow.r or curc..y or .ny .tacutory .ub.t1tut.
th.r.for .. provld.d by the .tatut.. of the .t.t. In which the
p.rtl.. or .1th.r of th.. a11ht dl. doa1c11.d.
(I) Th. r1lht to .ny dl.trlbut1v. .har. In the ..t.c. of Hard.. A.
Toporc.r .hou1d .h. d1. 1nt..tat.;
(C) Th. r11ht to t.k. 'Ialn.~ the will of Hard.. A. Toporc.r. hi.
pro.p.ct1v. .pou..;
(D) Thl rllht to .et .. .d.1nl.tracor of the ..cac. of Hard.. A.
Toporcar, hl. pro.p.cCiv. .pou...
VII. Hard.a A. Toporc.r doa. haraby cov.nant .nd air.. wlch J.rry C.
Horri.on th.c .h. will n.ithar dur1nl the 11facla. of J.rry C.
Horri.on nor aftar hi. d..th taka, claia. d...nd or r.c.1v.. and do...
h.r.by w.iv. and r.l.... .11 r1lht.. clai... c1tl.. and lnt.r..t..
.ctu.l. inchoat. or contlnl.nc. in lav .nd .qu1ty which" allhc.
by r...on of h.r marri... to J.rry C. Horr1.on. acquir. in hi. prop.rey
or ..eat., inc1udina. but not 11ait.d to:
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(A) Rilhc or cl.im of dow.r or curc..y or .ny .c.cutory lublC1CUCI
th.r.for .1 provid.d by chI ItICUC.I of chi IC.C. iD which the
p.rci.1 or .ich.r of ch.. ailhC die d~cil.d;
(I) Th. rilhc co Iny dilcribuciv. Ih.r. 1ft chi .IC.CI of Jlrry C.
Horrilon Ihould h. di. iDC.IC.C.1
(e) Th. rilhC co c.k. .1.inIC chI will of J.rry C. Korrilon. h.r
prolp.cCiv. .pOUI.;
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(D) Th. riihc to act .1 .dmini.tr.trix of the .Itlt. of J.rry C.
Korrilon, h.r pro.p.ctiv. .pou...
VIII. It il .Ir..d thlt n.ith.r p.rty will .tt..pt co tnltitutionali.. the
oth.r on . loni-t.rm b..il for .ny phYlic.l or mant.l inc.p.city.
without the con..nc of the childr.n of the p.r.on propol.d to b. 10
tn.titution.liz.d. In makinl thi. Air....nt. it il r.coani..d chac
.
n.ith.r p.rty Ihould b. pl.c.d in . pOltcion of h.vini co r.nd.r
nurlinl type c.r. to the och.r b.yond hil .bility co do 10.
IX. J.rry C. Korrilon .lr..1 th.c in the .v.nt of hil d..th prior co the
d..ch of Hard.. A. Toporc.r. the I.id Hard.. A. Toporc.r .hall have
chI riihc to occupy chi r..1 elc.c. .c 1'3 Locu.C Crov. Io.d. Dilllburl,
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P.nnlylv.ni.. .t no co.t co h.r. for I p~riod of thirc..n (13) IDnchl
.ft.r hi. d..ch .nd .ha11 h.v. Chi r...onabl. UI. of luch of hil
furnicur. .nd houl.ho1d .quip..nt durini chI I.id chirtaan (13) IDnChl.
a. ar. n.c....ry to maincain a workinl houa.hold. Durinl chil ~
(13) monch pariod (or chI cim. of h.r Iccual occupacion. which.var
1a ahorCar). Harda. A. toporc.r Ih.ll ba rllponlible for the p.ymenc
only of utility and he.cinl COltl.
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It i. contlmpl.tld th.t thl partil. hlrlto ..y 1av1.t clrtain .-aunt.
To
Toporclr h.. inYI.t.d TwllYI Thou.aDd
($12.000.00) in thl rial I.tltl of Jlrry C. Morri.on
Road. Dillaburl. '.nn.yly.nia.
tnl partiee haye her.unto eec their handl and
1ntlndinl to b. 1"llly bound hlreby.
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ASSETS or JIBY C. HDqIfOl
leal Iltltll
A. 60 Icrl proplrty with taprov...ntl at
153 LoCUlt Grovl load, Dilllbur., 'A.
lubjlCt to York rldlrll Mort.a'l of $34.000
I. 'roplrty in Dlrry Townlhip, Dluphin County.
'A, lubjlCt to York rldlrll Hort.a'l of $18.'00
C. 1969 'arkvood Mobill HO.I, lubject to
Crldit Union l1ln of $4,400.00
UIIencuUlrld 'alulI
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35,000.00
2,'00.00
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A. 1986 Cadillac
I. 1976 Chevr011t
Sedan dlV111a
14,000.00
1,000.00
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flUllhOld furniturl , Iqu1p.ent
rana Iqu1p.lnt
Toola
lical 1nltrualntl
.'28 .harll KYlor Indultrial
IV. s. Slriel 'I' Savin,1 londl
fIlA at Crldit Union
~~avillll account at Credit Union
JCblckin. account It Crldit Union
~rldaral Oovlrnalnt letirl.lnt
~lclllanloul (Iackhol, ItlrlO, ca.plr, laddll.)
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6,77'.00
11,23'.00
2,0".00
1,150.00
10,000.00
6,'00.00
2,1'0.00
6,880.00
2,000.00
4',000.00
6.150.00
$ 353,095.00
. 61,000.00
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SCHEDULE 'A'
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AlSITS or HAlDII A. fOPOICl1 - CONTllUID (.... 2)
C. with Hare Toporclr
DArCU Accouat
D. with Taaya Jlakia.
ridllity ~couatl
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ridllity Account.
5,260.43
2,'73.43
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~troPolitaa Lifl Inlur.nCI
"'dlr'l Govlrnalnt Lifl laaur'DCI
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1,000.00
106,000.00
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C\MB~IQ C()lJnY
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JERRY C. MORRISON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q'l-~2oB CIVIL TERM
HARDEE A. MORRISON,
Defendant
IN DIVORCE
NOTICE TO DEFEND 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 oth~r claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request that the court require
you and your spouse to attend marriage counseling prior to a
divorce decree being handed down by the court. A list of
marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Court House, Carlisle, You
are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to
be borne by you and your spouse.
IF YOU DO NOT rILE 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 WHERE YOU CAN GET LEGAL HELP.
Court Administrator
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6285
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By
JERRY C. MORRISON,
Plaintift
: IN THE COURT OF COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
VB.
NO.
CIVIL TERM
HARDEE A. MORRISON,
Detendant
IN DIVORCE
COMPLAINT
1.
The Plaintitf in this action is JERRY C. MORRISON, an adult
individual, who reside. at 153 Locust Grove Road, Dillsburg, York
County, Pennsylvania 17019.
2.
The Defendant in this action is MARDEE A. MORRISON, an adult
individual, who resides at 205 Beaver Drive, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
3.
Both the Plaintift and Defendant have been bona tide
residents of the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this complaint.
4.
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The Plaintiff and Defendant were lawfully joined in marriage
on June 17, 1988 in CarliSle, Cumberland County, Pennsylvania.
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IN THE COURT OF COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6208 CIVIL TERM
JERRY C. MORRISON,
Plaintiff
HARDEE A. MORRISON,
Defendant
IN DIVORCE
AFFIDAVIT
HARDEE A. MORRISON, being duly sworn accordinq to law,
deposes and says:
1. I have been advised of the availability of marriage
counseling and understand that I may request that the court
require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage
counselors in the Office of the Prothonotary, which list is
available to me upon request.
3. Being so aqvised, I do HQr request that the court
require my spouse and I participate in counseling prior to a
divorce decree being handed down by the court.
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.
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SNILBAKIER
a
.ltINNIlMAN
Date: / :;.)! /95
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- Mar ee A. M6rr son .....
(Defendant)
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JERRY C. MORRISON,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6208 CIVIL TERM
v.
HARDEE A. MORRISON,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
SS.
COUNTY
OF
CUMBERLAND)
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SNf.\.E:1AKIEFI
Q
SfltlNNI:MAN
Keith O. Brenneman, Esquire, being duly sworn
according to law deposes and says: that he is a principal in
the law firm of Snelbaker & Brenneman, P. C., being the
attorneys for Jerry C. Morrison, the Plaintiff in the above
captioned action in divorce; that on November 1, 1994, he did
send to Defendant Mardee A. Morrison by certified mail, return
receipt requested, restricted delivery, a duly certified copy of
the Complaint in Divorce which was filed in the above captioned
action as evidenced by the attached cover letter of the same
date and Receipt for Certified Mail No. P 290 633 729; that both
the Complaint and cover letter were duly received by Mardee A.
Morrison, the Defendant herein, as evidenced by the return
receipt card for said certified mail dated November 5, 1994;
that a copy of the aforementioned cover letter dated November 1,
1994 is attached hereto and incorporated by reference herein as
"Exhibit A" and that the original Receipt for Certified Mail and
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the Dome.tic Return Receipt are attached hereto and incorporated
by reference herein as "Exhibit B"; and that the foregoing facta
are true and correct to the be.t of
hi. knowledge, information
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Viti j ,//1~ftltfl{(tLr-
~o. Brenneman
and belief.
Sworn to and aubacribed before
me thie / /"L day of November, 1994
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