Loading...
HomeMy WebLinkAbout95-00411 , , I " ;1,1, i~ i',1 I . ,I: , ,; I d,' , " >) , " I]; , , I , '" " \ i " 'I , -I' 'I, . I , ,I 'I , , , " ,I , I , ~ " ;1 1'1 " i'l , . " I' , " ., ,I I~ " I ' , , , , . " , " " I " " " " I " 'l', " l' ,,' !I 'II , " !I " ',' i . , "I , I , , " ,I " 0), I . I ;,1 ., " i, . i i' 'I , ,'I .1 , , 'I' , , ;'1 , I " , " , !' . , .I , , ~l , " 'I' , , ", ' . :'1 i ' , , }, . . , ., , , ,If 11 II' 'I, , , , 'I , '"I " III I ',I " " ,I' . , i,i Ii ',) ., I " , '/1 I I': '1 " ' , " " , I'i ' ' l' , '>1 \ , , ;,11 , I , , <f" " I , I, ,I , " , "Ii 'I., i I \,1' " . , ' I , " . , " ': , , , , ,II 'I 1\1 I' , " " , . , II, " ", ;, .I, " , , , il , , " " :\.,' , , "l' i,', i'l !, I " " I , ,,' " , 'I' I I " . , , . " , " '" II' " I i, , " i 1,,'11 , I II " , " , " II " i'., " ,I ' , d (I ' , " ,llil " ,11\ :1' , , " , " :i 'I " , " " 'l~ j\,~ '1/ . ~ , MAT8I~OHIAL SETTLEMENT AGREEMENT THIll AGREEMEN'f, made thiB ..3JIuig.ay of fllJF 199'1, petween PATRIOIA ~. 'IRltKIJHIR., hereinafter oalled "Wite" and 8'1'IPKllf J. 'IRItIIIJHIR, hereinafter called "Husband". WI'l'NESSETHI The pllrties hereto, peing Husband and Wife were lawfully married on september 20, 1986 in Cumberland County, Pennsylvania, There wore no children born of this marriage, Differenoes have arisen between Husband and Wife in conssquenoe of which they have begun to live separate and apart from each other, Husband and Wife desire to settle and determine f1nlllly and for all time, their mutual property rights. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings herein oontained, the parties eaoh intending to pe legally bound, agree as follows: 1. SEPARATION Husband and Wife shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such plllce or places as they shall respectively deem fit, free from any control, restraint, or interference. whatsoever by the other. Neither party shall molest tha other or .. endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings, The fore9oing proviBion shllll not be tllken to be an Ildmission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. 2. UAIE OF EXECUTION The "dllte of execution" or "execution date" of this Agr~ement shall be defined as the date upon which it is exeouted by the parties if they have each executed the Agreement on the aame date, Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 3. REAL PROP.J.BTl The parties acknowledge that they are joint owners of property known as 2 Tiffany Drive, carlisle, cumberlllnd county, Pennsylvania. They acknowledge that there is currently a mortgage againet the property held by Fulton Bank in the approximate amount of $158,000.00 with a current monthly mortgage payment on the property of $1470.00. Husband agrees to transfer all of hia right, title and interost in the said property to Wife upon execution of this Agreement. Also, HUsband agree. to sign any and 2 .. all doouments whioh Ilre required by Fulton Bank in order to modify the payment schedule on the ourrent mortqaqe obliqation. wite shall thereafter be responsible for the payment of the mortqaqe in aooordance with its terms and conditions and Bhall indemnify and hold husband harmless from any future liability with reqllrd thereto. Husband Ilqrees that he shllll vacate the property on or ~efore September 2, 1995. Husband agrees to PIlY direotly to Fulton Bank the sum of approximately Four Thou81lnd Three Hundred Fifty-seven Dollars and sixteen Cents ($4,357.16) which represents one-half of the arrearaqes owinq on the mortqaqe 81 ot September 2, 1995 and the sum of Two-Hundred DollllrB ($200.00) 8S reimbursement to Wife for Homeowner's Insuranoe for 1995. said payments to Fulton Bank and to Wife shall be mllde withi~ thirty (30) days of the execution of this Aqreement. Further, Wife agreos that if she qualifies to do so the property shall be refinanced, if it has not been sold, in order to remove HUBband's name within a reasonable amount ot time. Wife agrees to keep Husband informed of the status regarding the retinancinq. Further, Husband agrees that Wife shall therelltter b. solely responsible for the sale of the house which would include the .eleotion of a real estate firm, the terms of a listing agr..ment and the 8iqning of any and all documents necessary tor the aal. 3 .. of the real estate. Upon the sale of the relll estate, Wife shall pay in full the first mortgage to Fulton Bllnk, the debt to PNC Bank referred to in paragraph 5 in the approximate amount of $26,660.00 and the Line of Credit referred to in Pllrllgraph 6 in the approximllte amount of $1,500.00. Any proceeds remaining after the coets of sale (including, but not limited to real estate fee. and closing CQsts), reimbursement to Wife of pllyments mllde on the Fulton Bank mortgage, PNC debt and Line of credit for the time pericd until the house sells, (excluding the Fulton Bank arrearage referred to herein) and payment in full of the Fulton Bllnk mortgage, PNC debt and Line of Credit shall be distributed 2/3 (two-thirds) to Wife and 1/3 (one-third) to Husband. Further, Husband shall be permitted to use the detached shed located at 2 Tiffany Drive for storage purposes for a period of nihety (90) days from the date he vacates the residence unles. it interfers with the sale of the house. If so, Husband Ilgrees to remove .aid property upon ten (10) days notice by Wife to Husband. 4. EID3.e~PERT'i The parties hereto mutually agree that they have divided all furniture, household furnishings, appliances and other household personal property between them, and they mutually agree that each 4 . party ahall from and Ilfter the dllte thereof be the Bole Ilnd .eparate owner of all tangible personal property presently in hia or her possession, except thllt Wife agrees that she shall return to Husband certain photoqrllphs within thirty (30) days of the exeoution of this Agreement. 5.~ With respect to the motor vehicles owned by one or both of the parties, they agree as followSI (a) The 1992 Aoura shall become the sole and exolusive property of Wife. The parties acknowledge that there is currently a lien Ilqllinst this vehicle which is held by PNC Bank in the approximate amount of $26/660.00. The vehicle shall be sold Ilnd the loan refinanced pursuant to the terms of Pllraqraph 6 herein. (b) The 1929 Model A. F~rd shall become the sole and exclusive property of Husband. The parties aoknowledge their are no liens against this vehicle. (0) The 1984 Monte Carlo SS shall beoome the sole and exolusive property of Husband. The parties acknowledge their are no liens against this vehicle. (d) The 1989 Pace Amerioan enolosed trailer shall beoome the aole and exclusive property of Husband. The parties aoknowledge 5 ., their are no lien. agllinst this vehiole, (e) The parties agree that they will exeoute any neoea.4ry dooument. to otteotuate the transter of the automobile., it neoe..ary. 6. D~BTS The partie. acknowledge that in Ilddition to the mort9age reterred to in Pllragraph 3 and the car loan reterred to in Paragraph 5 above, they are also jointly obligated on the following debt81 a. pNC Bu.ine88 Loan Acct. *40-01-0611072396 in the approximate amount ot 21,165.00 held by PNC Bank, b. Fulton Bllnk Line of credit Acct. *251908680 in the approximate amount of $1500.001 c. Colonilll National Acct. *4071296271186926 in tho a~proxlmate amount of $2,470.00, d. Core.tate. Acct. *01-8113067-5 in the approximate amount ot $1,897.00' e. A.T. , T. Acot. *4783800020535855 in the Ilpproximate amount of $451.00, f. Good. Furniture in the approximate amount ot $2,827.00, 9. Medical Bills in the approximate amount of $3,530.00 Wite acknowledges that she is ourrently in the prooea. ot 6 retinancinq the PNC Business Loan Account 1l10ng with the oar/truok loan refs~red to in paragraph ~ herein which will be recorded as a second mortgage against the real estllts. Hu.bllnd agre.s, if neoessllry, to sign any documents to reoord the loan a. a aecond mortgage against the marital residence and wite aqree. therearter to be solely responeible for the payment or the .econd mortgage, to indemnify Huebllnd from any liability by reaaon of her detault in the payment thereof and to save Husband from any tuture lillbility with regard thereto. wite ohall aseume rull and complete responsibility tor the Fulton Bank Line ot credit debt, the A.T. & T. debt, the Good'. Furniture debt and the Mediclll Bill debt and agreee to indemnity Hueband from any liability by reason of her default in the paym.nt thereof and agrees to save Husband from any future liability with regard thereto. Hu.band ahall assume full and oomplete responsibility tor the COlonial Nlltional Aooount and Corestates Aooount and aqree. to indemnify Wife from any liability by reason ot hi. default in the payment thereof and agrees to save Wife from Ilny future liability with regard thereto. 7. BUSINESS (ACADEMV ARTWORKS. I~ Th. parti.. aoknowledge that Wite currently has a thirty 7 . (30') p_rcent intere.t in Academy Artwor~., Ino. wire aqree. that in eH~hange for Husband's relinquishing any and 1111 intere.t he may have in 81lid business under the Pennsylvania Divoroe Code ot 1980, a. amended, she will thereafter be eolely reeponeible tor any and all debts relative to said business and agree. to indemnify Husband from any lose by reason of her detault in any paymenta relating to .aid business and agree. too hold Hu.band harmless from any tuture liability with regard thereto I however, HUlband is not jointly obligated on Ilny existing debt of Aoademy Arwor~., Ino. Husband agrees to sign Ilny and all document. if nece.eary in order to effectuate his relinquishment of any interest he may have in said business pursuant to the Divorce . Code. 8. MEDICA~ PARTNERSHIP LITIGATION The partie. ac~nowledge that they are presently involved in litigation regarding the Paramount Medical Partner.hip. The partie. agree that if a settlement i. reached in thi. matter, they ehall divide equally any prooeeds or liability as a reault of such settlement. Also, if there are any tees or c08ts generated by the litigation, they would agree to share them equally, a8 well 118 any responsibility for. liability. 9 ~ 'I 9. T~X R~fVND/CREDIT The partiea acknowledge that they have filed joint looal, state and federlll income tax returns for 1994. The partie., aoknowledge that after reimbursement to Wife of the amounta ahe paid for tllxing owing and the bookkeeper Ilnd accountant'. bill, the remainder of the funds shall be equally divided between the parties. , I I I 10. LIF~ INSU~ The pllrtiea Ilcknowledge thllt they each own an insurance pOlioy with security Mutual Insurance company. The partie. agree that they shall each retain ownership of their re.pective life insurance policY and each party waive. any olaim. he/ahe may have for any ownership rights in the other's poliCY. 11. BANK ACCOUNTS The partie. agree that they shllll each retain any funda contained in their respective bank accounts and eaoh party waive. any claim he/she may have for the funds in 81lid account.. 12. LEGAL FEES Both partie. .hall be responsible for the payment of the 9 fee. owed to their own attorney. Husbllnd and Wife do hereby wlliv., release and give up any rights whioh they mllY respectively have against the other for payment of oounsel fees. 13. OTHER WRITINGS Ellch ot the Parties hereto agree to execute any and all documents, doeds, bills of Bille or other writings neoee..rytq carry out the intent of this Agreement. 14. FURTHER DEBT Wife ehall not contraot or incur any debt or liability tor which Husband or his property or estate might be re~ponsible and ehall indemnity and save harmless Husband trom any Ilnd all claim. or demllnds made against Husband by reason of debts or obligatione incurred by Wife. 15. FURTHER DEBT Hueband shall not contact or incur any debt or liability for which Wife or her proparty or estate might be responsible and shllll indemnify and save harmless Wife from any and all claima or demands made against Wife by reason of debts or obligation. incurred by Husband. 10 16. MUTUAL RELEASE Except as otherwise provided herein and so long 08 this Agreement is not modified or canoe led by SUbsequent agreement, the parties hereby release and discharge absolutely and forever each other from any and all rights, olaims and demands, past, present and future specifically from the followingl spousal support from the other, alimony, alimony pendente lite, division of property, clllims or rights of dower and right to live in the marital home, right to act as executor or Ildministrator in the other's estate, right~ as devisee or legatee in the Last Will and Te.tament of the other, any claim or right as benefioiary in any life insurance policy of the other, any claim or right in the distributive share or intestate share of the other partie.' estate. 17. ENTRY AS P^RT OF DECREe It is the intention of the pllrties that this Agreement i. predicated on a mutual consent divorce of the partie.. Each party shllll execute an Affidavit of Consent upon the expiration of the ninety (90) day waiting period. This Agreement shall survive any action for divoroe which may be instituted or prosecuted by either party and no order, judgment or decree of divorc. (temporary, interlocutory, final or permanent) shall affect or 11 21. fVL~ DJSCLOSUR~ Eaoh party Il..ert. that she or her has made a full and oompletedi.olo.ure of all the real Ilnd personal property of what.oever nature and wheresoever locllted belonging in any way to .ach of them, of all debt. and encumbrance. incurred in ~ny manner whateoever by eaoh of them, of 1111 souroes and amounte of income reoeived or receivable by each party, and of ever other faot relating in any way to the subjeot matter of thi. Agreement. The.e disclosures are part of the consideration made by eaoh party for entering into this Agreement. 22. QQaTS TO ENFORC~ In the event that either pllrty defaults in the performance of any duties or obligations required by the terms of thi. Agreement and both extra-judioial and judioial proceec11ng. are oommenced to enforce such duty or obligations, the party foun~.to be in default shall be liable for all expenses, including rea.onable attorneys fees, incurred as a result of such proceedings. 23. AGREEMENT VOLUNTARILV AND CLEARLY UNDERSTOOD Eaoh party to this Agreement acknowledges and declare. that he or ehe respectively: 13 (1) I. tUlly and completely informed as to the tacts r~latinq to the subject matter Ilnd their Aqreement as the riqht, and liabilities of both p"rties, (2) Enters into this Agreement voluntarily after receivinq the advice of independent counsel, (3) Has qiven c~r.ful and mature thought to the making of this Aqreement, (4) Hils cllretully read each provision of this Agreement, (5) Fully Ilnd completely understands each provision of thi. Agreement, both as to tho sUbject matter and legal Ilffect. 24. AMENDMENT OR MQPIFICATION This Agreement may be amended O~ modified only by a written instrument signed by both parties. 25. LAW APPLICABLE Thia Agreement shllll be governed, construed and enforced under the statute and case law of the Commonwealth of Pennaylvania, 14, , IN WITNESS WHEREOF, the pllrtiea hereto have exeouted thia A9re.ment the day Ilnd year first written above. WITNISSI ~ ~ ~U-~ +W;.A,~ , I' , if' , , I ' \ .,'1 , , , , , " ,,'I I' " '" , I , , " .""helm.""l."" , ,I '" , , , , I i& I; , ~.R .. ~:~ Ll. :'~ ).. ", ". , I.,!". 1'1 'J '" ., ,,) I.~ . . " ~1 ~l " " itl' , " i \ " I, , I, " , " " " I, I, " 11J "J 'I I, i I \1 " i., ., " ,'i, " " " , , " Ii " ';I 'I, 'i I' I' . I' , " I, ,I 1 , ' , , ,I " " " PA'l'RIClA A, DERl<JIEIMF.R, Plaintiff IN Till CgUr.T or CCltOfON PLYM or CUlI1I\U.AN1) COUNTY, PlNNIl'i"I.VANIA NO, 95-411 CIVIL 19 VI. S'l'ElPIIm J. DEro<H1:lIMER, Deferdant PlAICI'1 TO TftANSMlf "COlD To the 'rothonotary. Tren.-1t the recor~, co,echer wtr.h the follow tn, lnfor=atton, to the court for eDcry of a 41vorce 4ecr~el 1. Ground lor ~lvorcel trretrleveble breakdoWD un~er Sectlon (201(0)) ~ ot the Dtvorca Co~e. (Strtke out lnappllcebla aectlon.) 2. Dete eu _er of .erv1ce of the COlIplatntl Personal Service on February 4, 1995, Amended Complaint-Certified Mail on August 16, 1995 J. (Cosplata.etther parelreph ea) or (b) .) (a) Date of UlIcutlon of the dUdant of IlOn..nt requlred by SecUon 201(0) of the Dlvorce Cod,.. by the pll1Dtlff September 1, 1995 by 4,f,adallt Sept:.enber 17, 1995 (b) (1) Dete of eaecutlo11 of the p1a1Dtlff'a afftdavtt raqutfad by ,,.t1011 201(d) of the D1yorce Codal (2) dace of ""lc, of eM pLa1nUlf'a afficla171t UpOIl the 4afelldllltl 4. Waced cLaw pll1d1nI' l>nlE I~ri K. Serratelll, , (."\/';, l\j"~L' Atcom~ ~or ('1,U.ot1l1) / ~1II.11et I " 'I " " I' ,i " " " ~ N 'f) ..;) , '" ":1 \n'~ ~.j 'X-; ~~.... -....:.. <) ~') - f'\() r'<) .... "':: ",~ ,"'I ,;~') 11'.1 \--.j 11 p C\~ - ~ ~. '" ~ ~ j'-.l ~~.'~ ~ '.(') \,..j I, ,/ !;~~ JI~ lIEi~: i" I;: .... I E , ' II II I ,'I , ' , , I' " I I, 'I' 1 ... . :::.:t~'~~'_"l,'_".nu.'.nut m~I'''' . ... ."" I 'i . . , . . Sa h.l)~lfll lllATllLl, Sclll"MAN ec alU)WN :\um '06 I P.C. ..1.1........... ..... HAUlI'u,".PA 11ll~1I4I1 Io' . . . .. P~TIUC:EA A. 111UOI11MIR, I IN THI COURT 0' CONNON PLIAI or PldnUtf I CUMIERLAND COUNTY, PINNIY~VANIA I No.1j '/1/ o -i.lJ-l(. 0/.)1",,-.- VI I I CIVI~ ACTION - LAW S'1'IPHIN J. IIRICHIIMIR, I Defendant I IN DIVORCI NOTlel TO DI'mfD AND CLAIM RIORTS You have been .ued in eourt. If you w1.h to defend ava1nat the alai.. .et forth in tha fOllow1nq pave., you .u.t take pro.pt action. You are warned that if you tail to do .0, tha ca.. .ay proaeed without you and a decree of divorce or annul.ent .ay be enter.d ava1n.t you by the court. A jUdrent .ay al.o be entered aga1n.t ~ou for any other cla1. or rei1e reque.ted in tha.. paper. by the plaintiff. You .ay lo.e .oney or property or other right. i.portent to you, including cu.tody or vi.1tation of your ahildnn. When the ground for the divorce i. indivn1tie. oZ' irretrievable breakdown of the .arriave, you .ay raqu..t .arriag. aoun..l1ng. A li.t of .arriave eoun.elora 1. ava11abl. in the Office of tha Prothonotary at ~~I~0~~~1~URTH9USI. 1 COURTHOUSI SOUAR., CARLISLI. I' YOU DO NOT WIIH TO rILl A CLAIM rOR ALIMONY, DIVIIION or PROPERTY, LAWYIR'8 rill OR IXPIN818 81roll A DIVORCI OR ANNULNINT IS GRANTID, YOU NAY LOSI THI RIGHT TO CLAIM ANY or THIM. YOUR SHOULD TAlCI THIS PAPIa TO YOUR LAWYlR AT ONCI. xr YOU DO NOT HAVI A LAWYIR OR CANNOT Arroan ONI, GO TO. OR TI~IPHO"I THI orncI SIT rORTH IILOW TO rIND OUT WHIRl YOU CM OIT LIGA~ HILP. COURT ADMINISTRATOR, 4TH FLOOR CUMBIRLAND COUNTY COURTHOUSI 1 COURTHOUSI 8QUAlI CARLIS~', PINNSYLVMIA 17013 TILIPHONII 240-6200 .', PATRICIA A. IUJCJtIIIIIR I IN THI COURT 0' CONNON 'LIlA' 0' 'laintiff I CUIIIIRLAND COUNTY, 'IIfNIYLVANIA I NO. (I'i 'III C. it." VI I .tJ.~ .1 ( .,~~ I CIVIL ACTION - LAW .TIPRIM J. IIRIOIIIIIU, I Defendant I IN DIVORCI COMPLAINT AND NOW COlliS the above-na.ed Plaintiff, by Lori ~. Sarratelli, l.quiZ'e and the law fi~ of .....'ILLI, .all'.... AID 1101I, ..a., and .eek. to obtain a Decra. in Divorc. fro. the above-na.ed Defendant, upon the 9round. h.reinafter aor. fully .et forthl CDDII'I I 1. plaintiff i. patricia A. I.rkhei.er, who curr.ntly re.ide. in New cuaberland, au.berland County, Penn.ylvania .inc. Decellber 1994. 2. Defendant i. stephen J. Berkh.iaer, who curr.ntly re.ide. at 2 Tiffany Drive, carli.le, au.berland county, Pann.ylvania ainc. 19.9. 3. Plaintiff ha. been a bona rida re.ident in the Commonwealth for at lea at .ix .onth. i..ediately previou. to tha filin9 of thi. co.plaint. 4. The Plaintiff and Dafendant were .arried on Septe.ber 20, 19.6 in cuaberland County, Penn.ylvania. ~) 'J . " \ ! 'i\ " , :1 ii' :: r \, I' "-' . \n ''0 ....... ~ '" ;IL:: . - "- 1.-4 ~ ... \;.,.\ le " -t \" c:) ,,, '"'"'"" '~l n h ~ ~ . " - - " ,J") -:.) ....... ," ~F~ -11"-' ~ U'> ~~ -\.. -;:.J ......... .~ - 2r~~ "~,, ft""_~ SlUAnJ.l.l, SCHIJ'MAII " IIlOWtl, "C. au", I. ............ "...,.,.., ..-",,'A I1""MlI . .....u... .0"11..,""11." _put _..OO."''/Wf)''U'f\''''' ' . . . , , ' " " ': I \ ~ . ' . , . l' ~ " \6 ":' :r: ili- a "~ I ~ " 'd, '" , ~ ' . - " I' " " 10 , ,',r, \"" ' , ';,1 .' 'ATaXCIA A. IlallIIx.a, IN THE COURT OF COMMON PLEAS Plaintitf CUMBERI~O COUNTY, PENNSYLVANIA V. NO. 95-411 civil Term ITI'KIN J. l.allIIx.a, CIVIL ACTION - LAW Derendant : IN DIVORCE AM~NDED qOMPLAINT IN DIVORCE AND NOW COMES the Ilbove named Plaintitt by Lori ~. Serratelli and the law firm ot SERRATELLI, SCHIFFMAN , BROWN and s.eks to obtain Il Decree in Divorce from the Ilbove named Oetendant, upon the qrounds hereinatter more eully set forth: COUNT I 1. plllintitt is Patricia A. Berkheimer, who currently reside. in New cumb.rland, cumberland county, Pennsylvllnia .i.,oe December 1994. 2. Oetendant i. Stephen J. Berkheimer, who currently reside. at 2 Tittany Drive, carlisle, Cumberland county, Pennsylvania .ince 1989. 3. Plaintitt has been a bona fide resident in the commonwealth tor at least six months immediately previous to the tilinq of thi. Complaint. 4. The Plllintitt Ilnd Oetendant were marrled on September 20, 1986 in Cumberland county, Pennsylvania. 5. There have been no prior actions ot divoroe or tor annulment between ths parties. 6. The marriaqe is irretrlevobly broken. 7. The Detendant is not a member ot the Armed Servioes ot the united state. or any of it. Allie.. WHEREFORE, the Plaintiff prllYs your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II 10. Paraqraphs one throuqh nine are incorporated by reterence herein. 11. The Plaintiff avers as the qrounds on which this Ilction is based is that the Defendant has offered such indiqnities to the Plllintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 12. This action in divorce is not collusive. WHEREFORE, the Plaintiff prays your Honorable Court to entar a Decree in Divorce from the bonds of matrimony. COUNT III 13. paraqraphs one throuqh nine are incorporated by reterence herein. 14. Plaintift states that the Plaintiff and Defendant po..... various items of both real and personal maritlll property which i. .ubject to equitable distribution by the Court. WHEREFORE, Plaintiff requests that this Courtl (a) Equitably distribute all property, personal and real own.d by the parties, ~ I verity that the statements made in this Amended Complaint are true and correot. I understand that false statements herein are m~de subjeot to the penalties of 18 Po.C.S. Seotion 4904 relatinq to unsworn falsifioation to authorities. Dated I ~~ il , " " , , I , , , !i , , 'I " , I ,I , I I Ii I I , , " I I' ~ I I' " ,I " q II I I I , I, Ii " " , " " I ! I \" I . I \ 'I , I I, :1 I" IfI ;a:: ~~ ......>1- '''1... ..., . 1< q III .. r:1 -:' H.. ,il I " , ! I " , ,iI ''I i,l 'I ::\' <:'1 ~ 'i- I It 'i , , " 'I ,I , I I' , I I, , , , , , I ,I ,,' I , " il ':r ,', ,I , I' I' , II " , d ,I " ' I ," I :1 I' ,I . I ,. I, , PRIO""rv ONI 'AnORNIYI' MIII.NOIR 8ERVltB .I...ph P. .lOhn.on, Own., . lullp..n.. . C....lon. for All Court. . '.,vlll, y.'''' . CMldl , .. II .. Clm.,on 11'''1 '.0. lOll 414 HI"llbU'JI'A 11'01'0414 (71 , 207.1380 PROOF OF ItRVICt 0"01" NO. , SERRATI...LI SCIII FFMAN GOLDBERG AND BROWN 2q40 LINO...ISTOWN ROAD SUln: 10. HARRISBURG, PA ~T110-9483 DATI IlICI1VED DA'U WlIlOlllO SERVllD BY I DOCUMENTS I SUMMONS/COMPLAINT IN DIVORCE ACTION WITNESS rEEl CASE NO. 9~-411 CIVIL ACTION CUMBERLAND GOUNTY 'LAIll'rlFF PATRICIA A BERKHEIMER -VI- DlFaNDAlIT STEPHEN J BERKHEIMER 10 IE SERVED I STEPHEN J BERKHEIMER 2 TIFFANY DRI,'#E CAR...lSLE, PA ACCEPTED BYI STEPHEN J BERKHEIM~R 2 TIFFANY DRIVE CARLISLE, PA I , 'lB. 4, U 10110 AM JOSEPH F. JOHNSON Kala I naok Halr I ~ ..." .... I Under 100 lb,. I I Ml11tary '.rvlc, FI..1I I lro"" Halr I 5' 0.. .'. I 100.nO Ib,. [ i1F1I:1Cbl I 110ndl Halr I ---f'4. .d1i I 1 .160 lb.. O~blr Xdlntlfy1nl I o 1'1 Halr I 5'... '1.0. I 61.200 lb.. - r,,~ural t [ eard I Id Hallt I OVer 6'0. r OVer 200 Ibl. [ 011.... I Wbh. Halr I laldlnl Wblcl 'kln MON..ElVXel I"FO [ VIUO" 'kln I . .)5 Yu. - I I Kovld I I Mo~ Known [ I Ir.wn Ikln I )6.50 Yr.. I No Lonl,r "ploy.d I IvIIUn~ "rvlce [ II. 'kin I 51.65 Yr.. - I M,vlr in I~c A.drl.. I 140 'uc Addu.. I OVer 65 Yu. H.I II.n V,rlfl.d - 'IOCIII .avu'. UroaT IWO~O and .ub.cr1t,4 before .. thl. ((,1- day of ~i.JLJoUAA_'1 . 19 . . ..-J I," " " II I 'II I' 'I', 'I " I, " 'i" I" ii' . I' I, 11'1,1, ,I " i' 'I , .. . . . .. 'I Z 044 LOb I43 2 Receipt '0' . Certlfl.d M II Nt) Illsurnncl) CI'....UFl11l1t P'o....IIJud .:!.II 'm On nol UII' "11 1I\1IJl'llItlml,11 MillI ISen A.vmllu) "77~~;:-, '~~~~:;',-;j\",\ ,'V, ltf , 1~-1 .r~~;\~ --- h.,., "., 'j', II:", II.) u.l"\""",~ ~ ) '\/.-\ '--'- "\\) '''~','I .11;", ' , ,,',~)., I' ~. . ,- f"' I O'~._~':.L1._1_ I',,~I,I'I'I . .. ') I , ...1 '.<1"""1"'" '111>"- .1" th'I...., "'1' 11"..,,, I",. L"I",.,~ "'11 . IIMU,I" 1l"""IJI ","11""'''1 , 1,}~II",,,o\l),lh,IJ."""""1 I I ! K' I ' \, \ ""1111" ""I''''P' ""'J"""'I )0' ~\,t",,,, IMI., .,.,,1 /l,l"'"'~''''' A.I.II"" Tl)! /II P"~hlll" " t .~~ . .), I', PI1,tl""r~ "~I !l,lh' 1)'.'<) ,f.,\ .) '11.\ , . , . I, ',, , " , I I, 'II':C =~l~"""'.,":.""lIooI""IYIcH' ',' I . _. It\d ....... III .., .."". of tIlIo _ ...... .. '11I """,,1Illo ..~, . " . AlllOh lIlI. ,."" Ie.... ...~, of .... ...... Of .. lIlI"" " _,... I """'''liMnftll, , ' . Wr/ti ".IlIWn......_'..lIlI.........._lIlI__ . I'Ilo """"'....... ~........_.... _ .............. ""_ . 0 to. ~1I, ~ C;~:'''''e.\\'{, ~~t" E~,~ C""".,e.\\'11 ~\~ . ~,.J..A,t.. \f.)'il-\\~ ~........\ :::s\......~ ~ e ~I)". C\~:!, \~<.,., ~,....I.l ~A lI\o.t-O'l~ I _ ..._ ..........,::. -WIllI... ~_ ,..II ' ',1 .,' " O~JII....~~'~,. 1.0 IlMlrielltl D,~' S!RVICE OF AMENDED COMPLAINT IN DIVORCE I' " , , , , i' I '1 , ,I \1 , , _II , . II , , , I' rI I I , I I I " '1,1 " \1 " I " . ' 1'1 " III . . )) 'I I II I I I' 'i " I' ij, , , I I . . . '.. " ' ,I I 'AT.IOIA A. .I.KKIIN.., Plaintiff vs. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I I NO. 95-411 Civil Term I I CIVIL ACTION - LAW I I IN DIVORCE .TI'HIH ~. BI.IHIINI., I verity that the statements made in this affidavit are oorreot. I understand that false statemin s herein are subject to the penalti~a of 18 Pa. C.S. S . 4904 reln unsworn falsification to authorities. ! 2" q , -7 ' 'LC; / DATED 8 (l) (2) <U (4) Defendant AFFIDAVIT OF CQNSENT A Complaint in Divoroe under Seotion 3301(0) of the Divoroe Code was filed 011 January 25, 1995. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed trom the date of filing the complaint. I oonsent to the entry of a final decree of divoroe. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel tees or expense. has not been filed with the Court before the entry of a final deoree in divoroe, the right to claim any of them will be lost. rue and ade q to '.' ; 1 .'ji I', I I !lR re g \'Y) -.:r - ~ I " .... '~, .'. . , II' ~ ) ., ''>.ilt I... ';>\' ,,\.~ I . _._ " l. .~ ' ,"; j:J It ,,' :.\ ~ ,'j r"J P' "I 1"1,1 " ,j 1'1 " I' II " 'I I' ',i " 'I I I ", , " 1'1 " " ,II III I " I , " " II I I I , 'I I' I, 'I " I 'I " " , " " , I .', . , . . II I I , "