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HomeMy WebLinkAbout02-3877WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO: : CIVIL ACTION-LAW 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 other daim 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 CONNOT 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 2 Liberty Street Carlisle, PA 17013 (717) 249-3166 WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO: CIVIL ACTION-LAW NOTICE OF AVAILABILITY OF COUNSELING .TO THE WITHIN NAMED DEFENDANT You have been named as a Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with [3302 (c) or (d) of the Divorce Code, 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 professional marriage counselors is available at the Cumberland County Court House, Cumberland County, Pennsylvania. You're advised that this list is kept as a convenience to you and you're 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 desire to pursue counseling, you must take your request for counseling within (20) days twenty of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: CiVIL ACTION-LAW DIVORCE COMPLAINT 1. Plaintiff is William C. Starliper, who currently resides at 2225 Lindsey Lot Road, Shippensburg, Cumberland County, PA. 2. Defendant is Barbara K. Starliper, an adult individual, who currently resides at 1434 Three Square Hollow Road, Newburg, Cumberland County, PA. 3. The Plaintiff has been a bona fide resident(s) in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 25, 1998, in Newburg, Cumberland County, PA. the parties. 6. 7. There have been no prior actions of divorce or for annulment between The Plaintiff in this action is not a member of the Armed forces. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to the divorce decree being handed down by the court. 9. The marriage is irrettievably broken. WHEREFORE: The Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, Aborn & Kutt~lal~, L.L.P. Date: August 14, 2002 Attorney I.D. No. 86914 8 South Hanover Street Suite 204 Carlisle, PA 17013 (717) 249-0900 Attornefi for Plain/iff WILLIAM C. STARLIPER, Plaintiff VS, BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: CIVIL ACTION-LAW VERIFICATION Date: I verify that the statements made in the foregoing complaint and divorce are true and correct. I understand that false statements herein are made subject to the penalties 18 Pa.C.S. ~4904, relating to unsworn falsifications to authorities. WILLIAM C. STAILLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: CIVIL ACTION-LAW CERTIFICATE OF SERVICE I, Kara W. Haggerty, Esquire, hereby certify that on this 14th day of August, 2002, a t_me and correct copy of the with/n DIVORCE COMPLAINT was served upon Defendant by Certified United States Mail, First Class, postage pre-paid, addressed as follows: Barbara K. Starliper 1434 Three Square Hollow Road Newburg, PA 17240 Date: August 14, 2002 Attorney ID #86914 8 South Hanover Street Suite 204 Carlisle, PA 17013 /lttorn~ for Plaintiff WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PA NO: 02-3877 Civil Term CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I, Kara Haggerty, hereby certify that I served a tree and correct copy of the Complaint Under Section 3301(c) of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached receipt card on August 16, 2002. Respectfully submitted, ABOM & KUTULAKIS Date: August 20, 2002 · C°mplete Rems 1, 2, and 3. Also complete item 4 If Restricted Dellve~ is de,ired. · Print your name and address on the reverse so that we can return the carol to you. · Attach this card to the back of the rnailpisce, .r or on the front if space perm,. Kara W. Haggerty, Esquire(J (.J (/ -- Attorney I.D. No: 86914 Suite 204 -.° o ~..+~. u~,,,~r gtreet . Received by Agent WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant · IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO: 02-3877 : CIVIL ACTION-.LAW PETITION FOR LEAVE TO AMEND DI-V'ORCE COMPLAINT AND NOW, this 12th day of March, 2003, comes the plaintiff, William C. Starliper, by and through his attorney, Kara W. Haggerty, Esquire, ofABOM & KUTULAKIS, L.L.P. and files this Petition for Leave to Amend, pursuant to Pa.R.C.P. 1033 as follows: 1. Plaintiff is William C. Starliper who currently resides at 2225 Lindsey Lot Road, Shippensburg, Franklin County, Pennsylvania 17257· 2. Defendant is Barbara K. Starliper, who currently re, sides at 1434 Three Square Hollow Road, Newburg, Cumberland County, Pennsylvania 17240. 3. Plaintiff filed the original Divorce Complaint in this case on August 14, 2002. 4. In January of 2003, the Plaintiff received information about Defendant having adulterous relations with another man during her marriage to the Plaintiff. It is unknown whether these adulterous relations have continued since the Defendant's separation from the Plaintiff. 5. On March 10, 2003, undersigned counsel did receive a written statement from Annette Fickes outlining her knowledge of Defendant's adulterous relationship with her husband, Clyde Fickes, III. 6. On January 7, 2003, Defendant did file a Complaint for Support with the Cumberland County Domestic Relations Office requesting spousal support. 7. The Plaintiffs oKginal Divorce Complaint does not contain any averments as to the adulterous relations of the Defendant due to this information not being discovered until after the filing of that pleading. WHEREFORE, the Plaintiff respectfully requests that thi:s Petition for Leave to Amend be granted in order to allow the original Divorce Complaint to reflect: the evidence that has been newly discovered. Respectfully submil~ed, Abora & Kutulalds, L.L.P. Kara W. Haggerty, Esq._t~ 4~ Attorney I.D. No. 86914 8 South Hanover Street, Suite 204 Carlisle, PA 17013 (717) 249-0900 ~Ittome_y for Plaintiff WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant : NO: 02-38777 : CIVIL ACTION-LAW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA VERIFICATION I verify that the statements made in the foregoing PETITION FOR LEAVE TO AMEND DIVORCE COMPLAINT are tree and correct. I understand that false statements herein are made subject to the penalties 18 Pa.C.S. ~4904, relaUn~swom falsifications to authorities. William C. StarlJ.per WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO: 02-3877 : CIVIL ACTION-LAW CERTIFICATE OF SERVICE AND NOW, this 12~ day of March, 2003, I, Kara W. Haggerty, Esquire, of Aborn & Kutulakis, L.L.P., hereby certify that ! did serve a tree and correct copy of the foregoing Petition for Leave to Amend upon H. Anthony Adams, Esquire, Attorney for Defendant, by mail at the following: H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 Respectfully submits:ed, Aborn & Kutnlala~, L.L.P. Kara W. Haggerty, Esqu~(J ~ Attorney I.D. No. 86914 8 South Hanover Street, Suite 204 Carlisle, PA 17013 (717) 249-0900 ~lttome~ for Plaintiff WILLIAM C. STARLIPER, Plaintiff Vo BARBARA K. STARLIPER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3877 CIVIL TERM ORDER OF COURT AND NOW, this 18th day of March, 2003, upon consideration of Plaintiff's Petition for Leave To Amend Divorce Complaint, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Kara W. Haggerty, Esq. 8 South Hanover Street Suite 204 Carlisle, PA 17013 Attorney for Plaintiff Barbara K. Starliper 1434 Three Square Hollow Road Newburg, PA 17240 Defendant, Pro Se J/;esley Ole~J_r~ c..-j. :rc WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO: 02-3877 : CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under [3301(c) of the Divorce Code was filed on August 14, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. / //7 / / ~ ...< WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: 02-3877 CIVIL ACTION-LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRF. I~. UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final 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 filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. [4904 relating to unsworn falsification to aut~ WILLIAM C. STARL~PE~'~ (717) 249 0900 Fax (717) 249 3344 A'I~rOIkNEYS Al' LAW ~-- ...... (717) 232 951 i \'~ ILLIAM C. S 1 ARLIPER, Plaintiff VS. B 5RBAI~5 K. STARLIPER, Defendant : IN THI¢ COURT OF COMMON PLEAS : CUMBiZRI,AND COUNrI5z, PA : NO: 02-3877 : CIVIL ACTION-LAW :lin DJVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce Under [3301(c) of the Divorce Code was Fried on August 14, 2002. 2. The marriage of Plainfff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of f~iing and service of the Complaint. 3. I consent to the entry 6f a final decree of divorce after service of notice o ~ intention to request entry of the decree. I verify that the statements made m this affida,St are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. [4904 relating to unswom falsification to authorities. Date: BARBARA STARLIPER (717) 249 0900 Fax (717) 249-3344 ATTOILNEYS AT LAW ~7t7) 232 95 \ViI,]-J X.M CZ. STARIJPF~R, Plaintiff BARBARA K. STARLIPER, Defendant IN THE (7OURT Ot;: COMMON PLE~\S (TL MBERLAND COUNTY, P \ NC): ()2-38~ / CIVI],,\CTI()N LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce w/thout notice. 2. l understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not daina them before a divorce is granted. 3. I understand that I w/~ not be divorced until a divorce decree is entered by the Coui:t and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affida,dt are true and correct. I understand that false statements hereto are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: BA 1LBARA STARLIPER II WILLIAM C. STARLIPER, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: 02-3877 BARBARA K. STARLIPER, Defendant : CIVIL ACTION-LAW : IN DIVORCE SEPARATION AGREEMENT Cover Sheet intentionally left blank SEPARATION AGREEMENT MADE thi~ day of~-/'~ and between William C. Starliper, of Shippensburg, Pennsylvania, hereinafter referred to as "Husband"; and Barbara K. Starliper, of Newburg, Pennsylvania, hereinafter referred to as "Wife". WHEREAS, the parties hereto are Husband and Wife having been married on April 25, 1998; and WHEREAS, the parties live separate and apart, and WHEREAS, the parties hereto have accumulated certain property throughout their marriage and wish to make a disposition thereof; and WHEREAS, each of the parties herein have been advised by independent legal counsel or have that right to be advised by independent legal counsel as to the nature and effect of a separation agreement and with said advice have determined that the following agreement is fair and reasonable and enter into the same with full knowledge of the extent of the estate of the other and their respective rights. NOW THEREFORE, WITNESSETH, in consideration of the promise and mutual undertakings herein contained, intending to be legally bound hereby, the parties do mutually agree as follows: SEPARATION: The parties may live apart for the rest of their lives. Each shall be free from interference, direct or indirect, by the other as fully as though unmarried. Each may for his or her separate benefit; engage in any employment, business or profession he or she may chose. MUTUAL ESTATE WAIVER: It is the intention of the parties hereto that from and alter the date of this agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end, both waive, relinquish and forebear their rights of dower or' courtesy, rights to inherit, rights to claim or take a husband or wife's or family exemption or allowance, to be vested with letters of administration or testamentary, and to take against any will of the other. The parties further agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer and/or encumber .or hereafter own or possess, real or personal property and further agree that the recording of this agreement shall be conclusive evidence to all of his or her right to do so. And the said Husband and Wife do hereby irrevocably grant, each to the other should the exercise of this power hereby given become necessary, the right and power to appoint one ,ar more times, any person or persons, whom Husband and Wife shall designate, to be the Attorney- in-Fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quitclaims or satisfactions, under seal or otherwise, to enable either party to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waive any right of election contained in Chapter 22 of the Pennsylvania Probate, Estates and Fiduciaries Code, or such right in this of any other jurisdiction. DIVORCE: At such time as the parties are ready, Husband and Wife shall complete a divorce and each party shall each bear all expenses connected therewith incurred by them 4. ATrORNEY'S FEES: Both of the parties shall bear their own attorney's fees in this matter, and both and each of the parties waive any claim against the other for any attorney's fees in this matter. 5. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, COSTS, AND EXPENSES: The parties, for and in consideration of this agreement, do hereby waive, one from the other and one to the other, any and all rights they may have to alimony, alimony pendente lite, costs, expenses and support for each other. 6. PERSONAL PROPERTY: Each party has in their possession the personal property that he or she claims an interest in, including but not limited to automobiles, firearms and motorcycles and each party, one to the other, waives any and all future interest in the personal property of the other and agrees to complete any and all documents or titles necessary to assure ownership excepting a wedding band which wife possesses and which shall be returned to Husband and be his sole and separate property. 6A.REAL PROPERTY: Husband shall convey to Wife by deed all of his interest in all real property owned by the parties. Wife shall assume liability for all debt secured by the property. PENSION RIGHTS: Each of the parties waive any claims to any pensions that either may have through his or her employment or otherwise, excepting to the extent that pension rights have been transferred to fulfill an alimony duty. 7A.SE'I-I-LEMENT RIGHTS: Each of the parties waives any claims to any settlements that either may be entitled to recover. Specificall~&,Wife waives any and all claims to any settlement that Husband may~"~titled to as a result of the personal injuries Husband suffered in a motor vehicle accident on or about April 10, 2002. EQUITABLE DISTRIBUTION OF PROPERTY: Ry this agreement, the parties have intended to effect an equitable distribution of their marital property. The parties have determined that an equitable distribution of such property conforms to a .lust and right standard with due regard to the rights of Husband and Wife. The distribution of existing marital property is not intended by the parties to constitute, in any way, a sale or exchange of assets, and the distribution is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. 9. DEFAULT: If either party fails in due performance of his or her obligations hereunder, the other party shall have the right, at his or her election, to sue for damages for a breach of this agreement, or to rescind the same and seek such legal remedies as may be available to him or her. Nothing herein contained shall be construed to restrict or impair either party's rights to exercise this election. 10. APPLICABLE LAW: This agreement shall be governed by the laws of the Commonwealth of Pennsylvania. 11. MODIFICATION AND WAIVER: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both of the parties. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent breach or default of the same or similar nature. 12. RECONCIL][A'r~ON: The parties shall only effect a legal reconciliation which supersedes this agreement by a signecJI agreement containing a specific statement that they have reconciled and that this agreement shall be null and void; otherwise, this agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation which action if not consummated by the aforesaid agreement, shall not affect in any way the legal effect of this property and separation agreement or cause any new marital rights or obligations to accrue. 13. ENFORCEABIL1-FY AND CONSIDERATION: This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties. An independent legal action may be brought to enforce the terms of this agreement by either Husband or Wife until it shall have been fully satisfied and ped'ormed. Consideration for this contract and agreement is to be found in this mutual benefit to be obtained by both parties hereto and the covenants and agreements of each of the parties to the other. The adequac~ of the consideration for the mutual undertakings herein set forth is stipulated, confessed and admitted by the parties intended to be legally bound hereby. 14. Husband shall have access to review all records, receipts and documents necessary for Husband to complete or have reviewed all tax obligations. The documents shall be identified and if wife has the documents they will be supplied to husband's accountant. 15.WHOLE AGREEMENT: This agreement constitutes the entire understanding of the parties. It supersedes any and all prior agreements between them. There are not representations or warranties other than those expressly herein set forth. AND further the parties hereto covenant and agree that this agreement shall extend to and be binding upon their heirs, devises, executors, administrators and assigns. AND the parties hereto state that he or she, in the procurement and execution of this agreement, has not been subjected to any fraud, concealment, overreaching, imposition, coercion, or other unfair dealing on the part of the other, or on the part of the other's counsel. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year first above written. Witness: (SEAL) ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND.' On this~/day of ~'Z,~~. 2003, before me, a notary public, the undersigned officer, personally appeared, William C., Starliper, known to me, (or satisfaction proven), to be the person whose name is subscribed to the within instrument, and acknowledged the foregoing Agreement to be his act and deed and desired the same to be recorded as such. IN WITNESS WHEREOF, I hereunto set my official hand and seal. My C@mmms~o~r~ I I Rhonda D, Rudy, No~a~ Public {MCarlisl~ Boro Cumberland Counw I ]] y Commis~,ion £xp ro~ Aug. 12, 2006I M~nb~. Penmtyivanla Associatlo~ of Notad~s ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND : On this ~day of .~_~97~, '2003, before me, a notary public, the undersigned officer, personally appeared, Barbara K. Starliper, known to me, (or satisfaction proven), to be the person whose name is subscribed to the within instrument, and acknowledged the foregoing Agreement to be her act and deed and desired the same to be recorded as such. IN WI'TNESS WHEREOF, I hereunto set my official hand and seal. 'Notary P~Jb.-61l~ - My Commission Expires: ~., .1:I, Anthony Adams Notary Public ~ Shig~pensburg Boro, Cumber and County L~ Commission Expires May 15, 2006J Member, Pennsylvania ~soc~on ot Nofafles WILLIAM C. STARLIPER, Plaintiff VS. BARBARA K. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: 02-3877 CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for divorce: irretrievable breakdown under [3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: August 16, 2002, by certified mail. 3. Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code: by Plaintiff December 1, 2003; by Defendant November 29, 2003. 4. Related claims pending: None, all claims settled by agreement dated November 3, 2003. 5. Date Plaintiff's Waiver of Notice in ~3301 (c) Divorce was fried with the Prothonotary: December 3, 2003 Date Defendant's Waiver of Notice in ~3301(c) Divorce was fried with the Prothonotary: December 3, 2003. Respectfully submitted, ABOM & KUTULAKIS, L.L.P Michael T. Traxler, Esquire / " 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff ID #90961 CERTIFICATE OF SERVICE AND NOW, this 9th day of January, 2004, I, Michael T. Traxler, Esquire, hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Transmit Record upon the Defendant by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, addressed as follows: H. Anthony Adam,a 49 West Orange Streets Suite 3 Shippensburg, PA 17257 Respectfully submitted, ABOM & KUTULAKIS, L.L.P DATE ?,/ ~/// La/ Michael T. Trax]Let, Esquire 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff ID #90961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ST/~'I' E OF WILLIAM C. STARLIPER, Plaintiff VERSUS BARBARA 1<2. STARLIPER, Defendant NO. PENNA. 02-3877 CIVIL DECREE IN DIVORCE AND NOW, DECREED THAT AND WILLIAM C. STARLIPER , PLAINTIFF, BARBARA I<2. STARLIPER __, DEFENDANT, 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 A FINAL ORDER HAS NOT YEt BEEN ENTERED; Marital Settlement Agreement dated November 3, 2003 incorporated, but not merged. By The COURT: //~ //~ / PROTHONOTARY IN THE COURT OF COMMON PLEAS OF THE 39TH 3UDICIAL DISTRICT OF PENNSYLVANIA - FRANKLIN COUNTY BRANCH Barbara K. Starliper, : No. <~,~,- Plaintiff : : Civil Action - Law VS. ; : In Divorce William C. Stadiper, : Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 14 day of January,2004, hereby elects to resume the prior surname of Barbara K. Lehman, and gives this written notice pursuant to the provisions of 54 P.S. Section 704. Dar '_e~ -,/O- ()fi" Bar-bara K. S~arliper~ Ba~b~ra K. Lehman ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND : On the I ii rl"tlay of ~t~]t~N-~, , 2004, before me, a Notary Public, personally appeared the above affiant I~wn to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing document for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Public My Commission Expires: Ship[?sburg Boro, Cumber and Court ~Y~Zommis,~iot~ Expires May 15 200~Yl