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HomeMy WebLinkAbout94-06462 J d E . -7 g I c :s .~\. , f ~ I J 11 -::t' ~ .:+:: .~~ ::.:~ .::~.:... ':~~' ..':~:'..i~:' ..-:~:'.. .::!:'_. '.=!:' 5-!-'. ~~:~ _~:~:_~ ::.:'~':!:'.._~:~ ....:!~ ~:~:'. -:~::. ~:~:'_:'.. .:.:. -:+:': ',:.:. .,'~~~_~!:~:':".:.:'_.'~_ ';~:'. ",4 ~' H ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1:\" STATE OF ~~~~ PENNA. ~'-~~~.~r ~1 * 8 ~ ~ ~ ~ ~ Tarin Arlene Bornman, Plaintiff II) l\ (). 94-6462 ~ ~ '," \' l'r..;ll', Gregory Alan Mathis, * ~ Defendant !!. " ~ ~ DECREE IN IJ o I V 0 R C Eit q..SSr/1 AND NOW, , .,.."."" ., "~,., 1996.,. it is ordered and decreed that,.""", ,T~fi ..'~p~,!39rp~p""""""",."" plaintiff, and. , , . . . , , , , , . , , . , , , , ,~reg,~r,~ ,AI.an .Ma.~i.~ , , , , , . ' , ' , , , . , . , , " defendant, are divorced from the bonds of matrimony. ~ ~I .. ... ~ ., ~ ~ W .:> ,;, ., W .:> The court retains jurisdiction of the following claims which have been raised oi record in this action for which a final order has not yet been entered; ." ~ ~ ~ ~ None ,." ..,...... ,..............,.."....... ...,. ,..".. ,...... ..... ...., ". ~ .. ...,... ....................., ,......,., ,.....,.... ". ,.. ~ ~ ..' ~ ~ ',' V'~,,4/~( f.' /c.k.a:/~.4".~~' ,/1~iK /", ~A-, u7! / / .l'rnlhnlllllarv ." ~ :. .~.~*..*..~..~,.~.~"~..:.:-.~..~..~..~-.~:'.~:..~.,~. w ., ~ ~ ~ ~ ~ ,;, " ~ ~ ~ ... ~ ~ ,;, ., ~ .,. ~ I, ~ ., ~ ~ ,;, " ~ ~ ',' ~ ., ,;, " ~ ~ ~ I: i~ , , ':!. :!. ~ ,~ ~ !\ ~ r,', :!: d.::>,3 , 1'1:, d ..,>3' ~t. {AI. (~1'7 '</f''''..t1;/ Ii d1 ~"~J ;ldtl;,L 1/ulj}~;Z t'~ ' ">- N [I:: ~ \"'":.t W~:~, (.'J , - u- '. J Et~ .~ , 0(:' , j c.' , _1' Cl , LU'... N 1:,' rr:!: , c , ,: . '1.1 ,.:; l1.1 ,'~ l'_ "_ ,.'" ..1 t.:~ c". ~.) "=>- Q-) ;....:.. - .r ,_. i.e -, ", , c -'7 ,~ ~', \ ' .-. , N -:r - , "" , <:> ,', <:: , . ~ SEPARATION AGREEMENT ~GREEMENT made and entered into this ~O~ay of 1992, by and between TARIN ARLINE MATHIS, her nafter referred to as the Wife, and GREGORY ALAN MATHIS, hereinafter referred to as the Husband: WITNESSETH: WHEREAS, the parties hereto were married on the 28th day of August, 1989, in Jacksonville, North carolina, have been and are now Husband and Wife; and WHEREAS, irreconcilable disputes, controversies, and differences have arisen between them, and the relations between the parties are and have been of such a character as to render the separation a matter of necessity for the health, welfare, and happiness of both, on account of which the parties have separated August 28, 1989, and live separate and apart and intend to live separate and apart from each other for the rest of their natural lives; and WHEREAS, it is the desire of both finally and for all time to settle, adjust, compromise, and determine their property rights, all rights of support and maintenance by either party against the other by reason of their marriage, all dower, curtesy, alimony, and homestead rights, and any and all other rights existing between the parties growing out of the marriage relation; and WHEREAS, the parties have agreed to file this stipulation and contract with the pleadings or depositions in any suit for divorce between the parties and in any other proceeding in which the parties may hereafter be involved concerning the matters herein set forth, and without raising objection hereto, to request the, Court therein to affirm, ratify and incorporate in its decree this valid agreement between the parties, and all, provisions hereof, so that this agreement and all the provisions hereof shall be deemed for all purposes to be a term of the decree, and enforceable in the same manner as any provision of such decree: WHEREAS, there are no children, of the parties, and; NOW THEREFORE, in consideration of the promises, and the considerations hereinafter mentioned, the mutual promises herein m~de and of acts to be performed by them, the parties have agr~od and by these presents do agree as follows: 1. SEPARATION OF THE PARTIES: The parties hereby acknowledge that they are now separated, and that each 6hall-b~ / entitled to his or her own privacy and sh~ll be free from the (,N'Il ma~ital control and authority of the other as if he or she wero ol/f ,,' ;//!,- 1/ I') ':/f " ~ ,< ;'7 ,.,~ ' p -L' 1 P , I. _ "ge or" "ges "C.,\..l.. - '-' .- unmarried and free from any control, restraint or'interference against one by the other. Neither of the parties shall molest, bother, harass, interfere with, assault, annoy, disturb the peace of or impose any restraint on the personal liberties of the other nor endeavor to compel the other to cohabit or dwell with him or her. Neither party hereto shall call upon or visit the other unless by express clear invitation or if there are children for the purpose of orderly visitation with the minor child at agreed upon or set times. Each party understands that he or she may be prosecu~ed by the other criminally for trespass, burglary, theft, assault, abusive language and other similar crimes and that each is free and competent to testify against the other and to prosecute the other and that the normal marital incidents of confidentiality, inter-spousal immunity and other similar incidents of the marital relationship are hereby released, waived and barred, the intent hereof being that each party shall be free from all marital, fiduciary and confidential relationships and obligations except those expressly assumed hereunder. Each party represents, warrants and guarantees to the other that he or she, as the case may be, has had independent advice on this agreement and that there shall not be deemed to exist any confidential or fiduciary relationship between them, and that he or she is dealing at arm's length with the other in an adversarial relationship. 2. ACCEPTANCE AND MUTUAL RELEASE: Each of the parties receives the property set apart to them and the undertakings hereof in full and complete settlement and release of all claims and demands of every kind, name or nature against the other party hereto, including all liability now or at anytime hereafter existing or accruing on account of support, maintenance,-alimony (temporary or permanent), dower, curtesy, or other allowances, either statutory or arising at common law incident to the marriage relation; and after this settlement the Husband and Wife shall require nothing whatever of the other, except as herein provided, as though the marriage relation between them had never existed. J. WAIVER OF CLAIM AGAINST ESTATE: a. The Wife agrees that the estate of the Husband shall belong to the person or persons who would have become entitled thereto if the \~ife had died during the lifetime of the Husband, and the Wife further agrees that she will not contest any will of the Husband to be probated, and will allow administration upon his personal estate to be taken out by the person or persons who would have been entitled to do so had the Wife died during the lifetime of the Husband. b. The Husband agrees that the estate of the Wife shall belong to the persons who would have become entitled thereto if the Husband had died during the lif~time of the Wife;,andthe, Husband further agrees that he ~ill not contest the will of the /21.t'l \Hfe to be probated, and will allow administration upon her Ij t $,t- II).:; ) ~V fv'lt:t<..;';-'- .- Page "/ of 3 P3ges ~ personal estate to be taken out by the person or persons who would have been entitled to do so had the Husband died during the lifetime of the Wife. Each party releases to the other and to the heirs, executors, administrators and assigns thereof all claims or rights of dower, curtesy, or inheritance, descent, distribution, election, or alimony (except that accruing under provisions of this agreement) in and to all property, real or personal, of the other, whether now owned or hereafter acquired. 4. . DEBTS OF THE MARRIAGE: The parties agree that in the event there are any debts and/or obligations of either party, not herein specifically set forth, such debts and/or obligations shall be paid by the party incurring the same and the other party shall be held harmless therefrom. Each party agrees that from this day forward, neither party shall incur any debt or obligation on the credit of the other, and each party shall hold the other harmless from any liability or obligation occasioned by such party incurring any debt thereafter. Husband agrees to remove Wife and Wife agrees to remove Husband from all accounts awarded to him or her and each warrants to the other that he/she has made no charges on these accounts over and above those reflected herein. Husband herein agrees to assume the balance on the fOllowing community, joint, or family debts, specifically: Vehicle payments on 1991 Chevy S-10 His personal credit cards and accounts Wife herein agrees to assume the balance on the following community, joint, or fam~l~, debts, specifically: Her personal credit cards and accounts If any claim, action, or proceedings is hereafter brought seeking to hold either Wife or Husband liable on account for such debt or obligation they have assumed, Wife and Husband shall, at her/his sole expense, defend the other against any such claim, action, or proceeding,' whether or not well founded. Husband and Wife agree to hold each other harmless for all personal debts and . obligations incurred by him or her subsequent to the dates of execution of this agreement. Should the Husband or Wife hereafter be requested to pay any debts of the other or a child for which he or she is not liable under the terms of this agreement, he or she may pay such debts and charge these payments against future liabilities incurred under this agreement. 5. DIVISION OF PERSONAL PROPERTY: All 'items of personal property shall be divided between the parties as provided herein and henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal properL; of every kind, nature and desc7'ption and wheresoever sicuated, which are so divided or whic~ may hereafter belong to the Husband or IHfe, with full power to the Husband or the Wife to dispose of same as fully and effectually, in all (1,(1'1, respects and for all purposes as if he or she were un.narried. &~)~/~ ~/t- .J./ ~ ...-. -'" "t.' '-- ./ u.. _, Page ., ....J of 3 Pages a. AUTOMOBILE: Wife shall have sole ownership and responsibility of the 1987 BMW 3~, Husband shall have sole ownership and responsibility of the 1991 Chevy 5-10. b. PERSONAL EFFECTS: All items of personal effects such as, but not limited to, clothing, jewelry, luggage, sports equipment, hobby collections and books, but not including furniture or any property, personal or otherwise specifically disposed of pursuant to this agreement, shall become the absolute and sole'prope~ty of that party who has had the principal use thereof or to whom the property was given or for whom it was purchased, and each party hereby surrenders any interest he or she may have in any such tangible personal property of the other. c. INTANGIBLE PERSONAL PROPERTY (other than life insurance): All stocks, bonds, and sums on deposit in checking and savings accounts (owned by either or both parties) shall be divided as soon after execution of this agreement as practicable. d. CASH: All cash owned by either or both parties as of the date of the agreement shall be the individual property of the respective parties. e. FURNITURE AND OTHER TANGIBLE PROPERTY: All furniture and other tangible personal property has been disposed of pursuant to other paragraphs of this agreement. 6. LIFE INSURANCE: The Husband may provide life insurance for himself. Wife may provide life insurance for herself. 7. ALLOWANCES TO THE ~IIFE: ,. a. In consideration of the wutual covenants and undertakings contained or provided for herein, each of the parties does hereby waive now and forever any and all rights to spousal support and/or maintenance both temporary and permanent, and each of the parties does hereby release the other from any and all claims, past, present, and future, for spousal support and/or maintenance. b. The Wife will, so long as eligible, utilize medical and hospital services available to them under the Armed Services Medical Care Program. Wife shall be responsible for all expenses for necessary medical and dental services, hospital care and medicines not available under the Medical Care Program furnished to her. 8. SUBSEQUENT DIVORCE: In the event th~t an action for divorce is instituted at anytime hereafter by either party against the other in this or any other stat'~ or country, the parcies hereto aqree chac they shall be bound by all the terms of this agreement. Each parcy execuces this a~reement freely and . voluntarily intending to be bound forever by it and intending ({/~/J',\ 9t I~!(_~~/ r il<J e L/- 01: 8 P,lq'~s that it should be enforceable by either party by proceedings in the Family Court in the state and county where such proceedings are initiated. Nothing herein shall be construed to prevent the decree or judgment in any such action from incorporating in full or in substance the terms of this agreement. 9. MILITARY PRIVILEGES: The Husband shall assist in arranging for the Wife's use of military facilities and privileges including, but not limited to, the post exchange, militury. hospital, medical care, post laundry, and commissary to the extent whidh she is, by law, entitled to use them. The parties understand that the eligibility of the Wife to use such privileges in her own right terminat~s upon the granting of a final divorce. 10. REMEDIES: If a party fails to comply with a provision of this agreement and/or a provision of a decree incorporating this agreement therein, the obligation of the other party to make payments for support or maintenance or to permit visitation is not suspended, but the other party may move the Court to grant an appropriate order. The intent hereof is to abolish self-help remedies, now all too common in family litigation, whereby one party withholds support or maintenance payments to force the other party to comply with visitation order and vice versa, and to recognize that disputes of this kind should be settled by the court. 11. ADDITIONAL INSTRUMENTS: Each of the parties shall promptly execute and deliver such deeds, title documents, releases, assignments, identity cards, applications for dependent identity cards, or other written instnlments as may be required from time to time to carry into effect fully the terms and conditions of this agreement according to the true intent and meaning thereof. 12. PRIOR AND SUBSEQUENT AGREEMENTS: The parties hereto hereby cancel, annul and invalidate any and all prior property, settlements by them at anytime heretofore made. All modifications of this agreement shall be of no effect unless' expressed in writing and signed by both parties. 13. ENTIRE AGREEMENT:, Both the legal and practical effect of this agreement in each and every respect and the financial status of the parties have been fully explained to both parties by legal counsel of each party's independent choice. Both parties acknowledge that the agreement is fair and is not the result of any fraud, duress or undue influ9nce exercised by either party upon the other or by any other person or persons upon either, and they further agree that this agreement contains the entire understanding or the parties, there being no Lepresentations, promises, warranties. covenants or undertakings other than those expressly set forth herein. (l~ll! f! v: . \t<., -,--.JO,......, 1t~'- - --- ?V Page 5 or a Pages 14. TAXES: The Husband and Wife agree to file a joint tax return for the tax year 1992 and to divide equally any tax refund. 15. may have on active marriage. HUSBAND'S RETIREMENT: Wife waives any entitlement she to Husband's retirement annuities accrued by his service duty with the Armed Forces during the period of this 16., ENFORCEMENT: The Wife agrees that she will not contact either directly or indirectly, the Armed Forces or her Husband's Commanding Officer with respect to the enforcement of this agreement as long as he complies with its provisions. 17. BINDING EFFECT: All covenants, promises, stipulations, agreements and provisions contained herein shall apply to, bind and be obligatory upon, the heirs, executors, administrators, personal representatives and assigns of the parties hereto. 18. VALIDITY OF PROVISIONS: In the event that any of the provisions herein made shall in any form or manner offend any statute of the State of South Carolina, or of any other state in which an action for divorce or legal separation is brought, or if by decision of the supreme Court of South Carolina, or of any other state in which such an action is brought, or of the united States of America, heretofore or hereafter made, any provision of this Separation Agreement shall be inoperative, it is both Wife's and Husband's intention that this instrument shall operate and be of full force and effect insofar as it does not offend such statute, and is not contrary to the decision of the above' mentioned courts and that these provisions shall be carried out as far as may be. This agreement shall be liberally construed and applied to promote its underlying purposes, which are to promote the prompt and amicable resolution and settlement of disputes that have arisen between the parties and to ~itigate the potential harm to the parties'and the children attendant upon their separation and the irretrievable breakdown of their marriage relationship and to allow the parties to plan their future by agreeing upon a disposition of their property and their maintenance. 19. DISCLOSURE: Each party represents, warrants, guarantees and covenants that he or she was provided a fair and reasonable disclosure of the property and financial obligations of the other party and does hereby waive any right to disclosure of the property or financial obligations of the other party beyond the disclosure provided. 20. NOTICES: For the purposes or this agreement, all notices or other communications given or made hereunder shall, until written notice to the contrary, be given or mailed to the Wire at 126c Lincoln St., Marysvilla, Pennsylvania 17053 and the Husband at Spt Bn, MeRD, Parris Island, South Carolina 29905. ~frJ,1 fit: t.lt), , ' ~.\~r- 1:....... " - Page / L' Ot1 p,"\ges STATE OF SOUTH CAROLINA COUNTY OF BEAUFORT PERSONALLY appeared before me WI/all" r;., j/,. /;',,,J.../( 2? first witness, and made oath that he/she saw the within named GREGORY ALAN MATHIS sign, seal and as his act and deed deliver tlul.l within, writ,ten SljIparation Agreement, and that he/she with R;.., -f- ,~ ('Jr..d!::r7 , second witness, witnessed the execution thereof. Sworn to before me this '50 day of y,);-" , 19 fZ. ~~O~ CI. CJJk.".rL.,.~) N ta Public y mmission Expires: '1, ~ n "'J cr'f STATE OF ~...".y/;<t......- COUNTY OF :z;..~~ /_..v' PERSONALLY appeared before me ~iv II fk/llllflA-rJ , first witness, and made oath that he/she saw the within named TARIN ARLINE MATHIS sign, seal and as her act and deed deliver the within written Separation Agreement, and that he/she with E<<"c ./. L./f-"".(I,c;...(J[: , second witness, witnessed the execution thereof. Sworn to before me this It#- day of D<!<. ~...Iur- , 19 "1.... r' ' tJrlal Sell ' . . "1:'1.:1 J. J::.... ~,!," ., . ~ ........ ,", I " . , . 4 . 4. .01. e: ..~~l:;:j ~n :;~"'rt: 1 : _,' _ , l~ rOil E^pil.'e~. . , tt LI- ~ ~ 1 ll. ""R. 0 -=r 0 () I.{) en >;,- - ~- t-o l,() 0 l() ...(-. (~ = , "'- '" , \) r() lI) .~ ' \J'l lI) :r ...1-. 00 \~J rl 1.., r- () .3 - N .. - 0 CO J ~ 1 V:l ," - - , 'blr - " ,.. .. ~ ":\l. C:::a ,,' 6 <;:( -- - 6; r- . N r:': ;:;, (~ ~.) ..-- ~Q ( .)~; ff?,~ c:>:;. u.. !"").'j ~ro: =::~ ~ M I ,'- ..~ fEW -, li~j";J iE _c: !.!~c... -, l:5 "~l ~ en (J v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-6462 CIVIL TERM CIVIL-ACTION/LAW IN DIVORCE TARIN ARLENE BORNMAN, Plaintiff GREGORY ALAN MATHIS, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 330l(c) of the Divorce Code waB filed on November 14, 1994. 2. The Marriage of Plaintiff and Defendant iB irretrievably broken and ninety (90) days have elapBed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree of DivorCE. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouBe and I participate in counseling, and that the Court maintains a list of marriage counBelors in the Prothonotary's Office, which liBt iB available to me upon requeBt. Being so advised, I decline to requeat that t.he Court require that my spouBe and I participate in counBeling. 5. I understand that I may lOBe rights concerning alimony, division of property, lawyer's feeB or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO TilE PENALTIES OF 18 PA. C.S. SECTION 4904 R~~~~NG T~~NSWORN FALSIFICATIO~ TO AU~1I0RI:~ESI t: J /1 (I 1'/'1') {l<" ,I, I' (, ,\ I. . Date Gre? r Alan Math B Defendant ~ co ~ :<'. N b M __J.,_' 0.... ~-: -. (J;-:' 8:& a: -,' (_l;~i ~f.! c" ~~~ ~~ -u. I '-1:;.--:; [tll! ." Illl'J ar.; ~:~ n.. \ F: ..., U. <0 ::; 0 en u TARIN ARLENE BORNMAN, Plaintiff v. I~ THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-6462 CIVIL TERM CIVIL-ACTION/LAW IN DIVORCE GREGORY ALAN MATHIS, Defendant AFFIDAVIT OF CONSENT 1. J\ l:ompla~nt:. in invorce under Section ,j.30qC) ot the Divorce Code was filed on November 14, 1994. 2. The Marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES 'OF 18 PA. C.S. SECTION 4904 RE ING TO UNSWORN FALSIFICATION 0 AQTHOR TIE . /~ YY~)'I/' ~ _ ~-;.. -- Tarin Arlene Bo nmail, Plaintiff .... M ~ b:; -, (.- ~~ ::i ~.... l.u(! sa (-, -,- ~ Eft' '.:)::, x "'-4: (1 ~~~ ~:c co ' If) (I: ~li.~ OJ. t t..< fEll I ~.. : t1tU i},: ~. :l~LL _. - U. \.':1 ::3 0 c." U TARIN ARLENE BORNMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. q,-/ _ (vLI G<J CIVIL ACTION - LAW IN DIVORCE GREGORY ALAN MATHIS, Defendant DEFENDANT'S RESPONSE TO COMPLAINT 1. Defendant, Gregory Alan Mathis, has been sel:'ved the notice and complaint by certified mail. 2. Defendant hereby concedes all eleven (11) points outlined in the Complaint. 3. Defendant hereby elects not to request marriage counseling, and waives any right tl -equest mandatory counseling. 4. Defendant voluntarily grants personal jurisdiction over this matter to the Court of Common Pleas of Cumberland County Pennsylvania. 5. Defendant amicably and voluntarily elects not to defend against the Complaint, and hereby authorizes the Court to decree divorce against him ex parte, so long as Plaintiff requests no expenses or provisions other than a decree of divorce. WHEREFORE, Defendant prays this Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant. Respectfully Submitted, GREGORY^ MATHIS, Pro Se J 1 I ,J;1/'L L--rX)tr>7 II. (t., 7 Dated: ( , , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-6462 CIVIL TERM CIVIL-ACTION/LAW IN DIVORCE TARIN ARLENE BORNMAN, plaintiff GREGORY ALAN MATHIS, defendant NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TOI Gregory Alan Mathis You have been sued in an action for divorce. You have failed to answer the complaint or file a counter affidavit to the plaintiff's affidavit. Therefore, on or after February 29, 1996, the Plaintiff can request the uourt to enter a final decree of divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counteraffidavit by the above date, the court can enter a final decree in divorce. Unless you have alre6dy filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A GOUNTERAF'FIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240-2600 ., . . . , VERIFICATION I verify that the statements made in this Counteraffidavit are true and correct. I understand that falee statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 ~elating to unsworn falsification to authorities. Date: /'- ~~. 1/ /fl16 1')' / (' -.- C"\ i ~. u . i: , - t1..l~ ' '".> I. J ~~ .. (" ....', ,,- c.5 ~ ~ .-) (I...., t..!' , " " I... " I '- I' , ,., L_ "