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HomeMy WebLinkAbout95-00442 fJ- .::t- I, , tJ '" . . ~:*'*'-~*:~~"*.~~,**_~~ro*'~*'~'~~~:'~:~ro-~'~"~:~~ ;', -- ------ -- '.' ~ M ~l ... ~ ~ '.' ~ " ~ ~.' IN THE COURT OF COMMON PLEAS ~ ;.~ ~ ~.: ,'. ~ ~ OF CUMBERLAND t'Jt COUNTY STATE OF PENNA. ?- w ',' ~ ',' !I Ii N (), ....,......9,5.:-:,4.~~ ................' 19 95 ~ ',' ....JACK..L. .~A~t!ER,. ~ ~.~ l'la~lltH.f ~ ~.' ,,~ ~ ~ ',' ;.; ~ Vel'SlIS ....HAIlItEEN.A,.. ~ARNER, .. ,I :j ii Defendallt ," .', ~ ~ ~.J DECREE IN DIVORCE AND NOW, .. ..~.... ,"}!. .... .." 19.. ~L. it is ordered and ~ '.~ ~ '.~ tt! " f: ~ ~.~ i ~.~ ~ .'~ ~ ~.~ .' ~ i ~ ~ ~., ~ .,' decreed that.""" ,," ", ~~q<, k.. !'IM~il,E)t""."" , , '.,. ,", , .. plaintiff, and, , .. , .. .. , .. . .. .. , .. . .. .. ..~~Il~IlIl~ '~'''I'!~~~~IL. , , , .. , .. .. ., defendant, are divorced from the bonds of matrimony. The Marital Settlement Agreement dated May 23. 1995 is incorporated herein, but not merged, 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 enteWM $ ~~ ~ .. .... .... ...... ...... .... ..... ..... ... ". ...... ..... ..,. ...... .... .... "', -J / ."' ~ '....... ..... ....... .., .., .......j.. .......... ... ...... '" '1 I Il y -k he /C.'-" ./. 1'1 :. '~I'.->' ... ... .\rl ^lIe.I.:.>t)<<.Lt.e1It<'~ (!, t~r ~' ~~:r.'L f ~~: ~.~~..o. f~-:, ~'a~'" '.' "">;'" . :,:. . ;.....: ':'.--- ' ~- - '..~' ~ "; ~ p ,'. ~ ,"' r: ~ ~ ~ ;!l M ~..>.w..,;::- ::.:' ':... , '. '...-,':'" .~ #'~1%...,~~" AJ.~./.2' 7 T-P~lonOlnrY . ,. ~...' '- " ~ ..;.;'~ ...; .. '. . , ,~ ~ I " -4---~ ......--.... , ..,. - o.,,~ _, . ,0 , "_~. ,', ) ~ ~~~*~--*~**~..~~*.~*~.**~.**** . ," , . . - '... ....._~;':".~...':'."...~. ~ ',' ~ '.~ ~ '.' ~ '.~ ~ ~.~ ,'. ~ ~ '.' ~ ',' .'. ~ ~ ~.~ i ~.' ~ '.' ~ ?; ~ ~.~ ~ '.' ;i i '.' ~ ~ s '. ~ :.~ '. ~ ~.~ ,', ~ ~ ~.' ~ ~ ~.' ~ ',' ~ ',' ~ '.' ~ ',' ~ * * J. ~ ~ ~ -6/3/i;s M 61~ ~f~.h.l~ (~ D,U4~ .5/.31 lIs '?1t:J~ /4~ ~ ,;.111. , MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made, executed and delivered on this .J3M, day of May, 1995, by and between JAC'!( L. WARNER of Mechanicsburg, Pennsylvania, hereinafter referred to as "HUSBAND", and MAUREEN A. WARNER of Mechanicsburg, Pennsylvania, hereinafter referred to as = b - "WIFE". /'.) (...., N WIT N E SSE T H: l~ '" -,., = .~ c...o WHEREAS, the parties hereto were married on June 28, Y974 in Hartford, connecticut; and WHEREAS, two children were born of this marriage, namely ALLISON MAUREEN WARNER born on February 9, 1981 and MATTHEW WILLIAM WARNER born on May 17, 1984; and WHEREAS, diverse unhappy differences, disputes, and difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and to settle fully and finally their financial and property rights and obligations between each other; and WHEREAS, both HUSBAND and WIFE fully understand all of the terms, conditions and provisions of this agreement and believe it to be fair, just, adequate and reasonable as to each of them and . both HUSBAND and WIFE both freely and voluntarily accept such terms/ conditions and provisions; NOW THEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL Both parties acknowledge that they have been afforded the opportunity to consult with an attorney of their choice prior to signing this Agreement. HUSBAND is represented by Debra A. Denison, Esquire. WIFE is represented by Gerald Shekletski, Esquire. Each party acknowledges that this Agreement is being entered into freely and voluntarily and that it is not the result of duress, undue influence or collusion. 2. SUBSE~UENT DIVORCE An action seeking the dissolution of the marriage is pending in the Cumberland County Court of common Pleas and bears docket number 95-442. HUSBAND and WIFE agree to execute affidavits of consent to this divorce at the time of settlement. 2 . 3. EFFECTIVE DATE This Agreement shall be effective on the date above first written if both parties sign on the same date: otherwise, it shall become effective upon the signing by the last party to do so. 4. WARRANTY OF DISCLOSURE The parties acknowledge that they are aware of their respective rights pursuant to the pennsylvania Divorce Code to obtain full disclosure of all marital and non-marital assets, as defined by the Pennsylvania Divorce Code. Both par.-ties hereby waive their right to receive full and complete disclosure and having freely and voluntarily waived such disclosure, acknowledge that this Agreement is fair and equitable and is not the result of , any fraud, coercion, duress, undue influence of collusion. Such a waiver of disclosure is made by both parties in order to expedite this matter. 5. DEBTS AND OBLIGATIONS Each of the parties hereto covenants and agrees that he or she has not in the past and will not at any time in the future incur or contract any debt, charge or liability for which their legal representatives or other property or estate may become liable. Each of them further covenants at all times to keep the other free, 3 harmless and indemnified of and from all debts, charges and liabilities hereafter or heretofore contracted by them except as hereinafter provided. WIFE is a personal guarantor on a Note held by John H. Myers for Lot 12 on the Peninsula in Silver Spring Township. At the time of settlement, HUSBAND shall deliver a release of WIFE from her guarantor status. In exchange for full ownership of the 1994 Chevrolet custom mini-van, WIFE hereby agrees to assume the outstanding loan at Dauphin Deposit Bank. Said loan is a second mortgage which is the , sole responsibility of WIFE. HUSBAND shall make, execute and deliver all documents necessary to transfer title in the van to WIFE prior to the issuance of a divorce decree. HUSBAND and WIFE have a joint debt with PNC..of Ohio for the purchase of a 1994 S10 Chevrolet Truck. The approximate loan amount is $11,000.00. ItUSBAND shall assume the loan and retain sole right to said truck. In addition, both parties agree to hold harmless and indemnify the other in the event they are unable to fulfill the above outlined obligations. 4 6. REAL PROPERTY It is understood and agreed that the parties are the joint owners of certain real estate located at 3811 Claverton Road, Mechanicsburg, Cumberland County , Pennsylvania, 17055. The HUSBAND hereby agrees to transfer his interest in said property to WIFE. HUSBAND hereby agrees to execute all documents necessary to transfer title to WIFE. The WIFE agrees that she will be solely responsible to preserve and maintain the house and ground and to pay all mortgage payments, taxes, utilities, insurance, repairs and all other costs associated with the property as they fall due. yurther, WIFE hereby agrees to indemnify and hold harmless HUSBAND for any and all payments due and any and all decrease in the value of the property attributable to WIFE's failure to make timely and COl1'plete payments and/or her failure to repair, maintain and preserve the property. In addition, WIFE hereby agrees to make all reasonable efforts to remove HUSBAND from the mortgage. WIFE hereby agrees to remove HUSBAND from the mortgage within a period of five (5) years. 7. PERSONAL PROPERTY The parties acknowledge that they have heretofore effected an equitable division of all their personal property and it is understood and agreed that each party shall retain as his or her 5 sole and separate property, free and clear of any claim of the other, all those items of personality which each now has in his or her possession and control respectivelY without the necessity of any documents or further assurance except as otherwise provided herein. HUSBAND hereby agrees to remove any and all personal items from the home no later than June 1, 1995. 8. ATTORNEY FEES, COURT COSTS Each party shall be responsible for any attol:ney fees and costs that he or she incurs, and both do hereby waive any and all rights to recover such expenses from the other party. 9. PENSION. RETIREMENT AND OTHER EMPLOYEE BENEFITS HUSBAND and WIFE acknowledge that the marital property of the parties includes HUSBAND's 401K plan with Warner Homes and WIFE's 401K plan with Health America. HUSBAND and WIFE acknowledge that they have been informed of their right to obtain an independent appraisal of each other's pension and interest, and notwithstanding the same, they hereby forever waive and relinquish any right, interest or claim that they might have otherwise in each other's pension interest. 6 10. WARNER HOMES INCORPORATED ,I ,I '( t WIFE hereby acknowledges her right under the Pennsylvania Divorce Code to obtain a formal valuation and appraisal of HUSBAND I s business. However, the parties have determined that they will not undertake this expense and that HUSBAND shall retain as his sole and separate property the business known as Warner Homes Incorporated without the necessity of any documents or further assurance. 11. CHILD CUSTODY The parties acknowledge that it is in the best interest of their minor children that they associate with both parents as often as possible. The parties agree to jointly share their parental responsibilities and duties until as far as it is practical to do so. The parties agree to consult with each other concerning their children's education, health and general welfare and the parties further agree that they shall encourage their children to maintain a close and meaningful relationship with the other parent. The parties hereby agree that legal custody of both minor children shall be joint in nature. Primary physical custody of both children shall be with the WIFE. HUSBAND shall have liberal periods of partial custody as agreed upon by the parties. 7 12. CHILD SUPPORT HUSBAND shall pay to WIFE a sum of $800.00 per month for the maintenance and support of the parties minor children. Said payments are to be made on or before the 5th day of each month. It is understood and agreed that said payments shall be adjusted upward or downward in accordance with changes in the respected income of the parties and the needs of their children. WIFE hereby agrees to contribute no less than 25% of the post- settlement equity from the sale of the marital home or $35,000, whichever is less, to the secondary education of the children. Said funds will be divided equally between the two (2) children and should a child decide not to pursue a secondary education, the funds will be released for his or her benefit at the age of 21. These funds shall be applied to the payment of educational costs prior to the division of the costs among the parties. Thereafter, the parties agree to contribute to the costs of their children's secondary education within the framework of their respective financial situations or as required by law. Notwithstanding the above, the parties agree to provide appropriate education~l opportunities for their children, inclUding private school, undergraduate, college education, extracurricular lessons and activities. HUSBAND specificallY agrees to pay one-half (~) of yearly private educational expenses within five (5) days of receipt of a billing statement. 8 ., 'il I j 16. INSURANCE HUSBAND and WIFE agree to assume full responsibility for their own individual medical and dental expenses and each agrees to indemnify the other and hold him or her harmless for any liability therefore. WIFE shall provide major medical and hospital insurance coverage for the children unless the parties shall mutually agree to the contrary. The parties further agree that they will each be responsible for fifty percent (50%) of all uninsured or unreimbursed medical and dental or orthodontic expenses, including any deductible portion. 17. MUTUAL RELEASE HUSBAND and WIFE do hereby release each other from any other claims with respect to the marital and non-marital assets of the parties. Additionally, each party hereby releases any interest that he or she may have in the estate of the other. 18. MUTUAL COOPERATION HUSBAND and WIFE shall mutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of documents. 10 19. AGREEMENT BINDING ON HEIRS This Agreement constitutes the final agreement of the parties and is binding upon their heirs, assigns and successors in interest. 20. VOID CLAUSES If any term, condition, clause or provision of this Agreement shall be detennined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects , this Agreement shall be valid and continue in full force, effect and operation. 21, APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 22. ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 11 IN WITNESS WHEREOP, the parties hereto have set their hands and seals on the day first above written. This Agreement is executed in duplicate, and in counterparts. HUSBAND and WIFE acknowledge the receipt of a duly executed copy hereof. ~~~ 12 . COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAfJPtll~(J.b}lher/(J'lcf SS. On the J?3'~ day of May, 1995, before me, a Notary public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared JACK L. WARNER, known to me (or satiSfactorily proven) to be one of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. fJ.G ic NotarlalSoal Kathy 0, Endors. NotalY Publlo Camp HIR Boro. Cumberllind Cour,ly MyCommlsslon Explma Fab,ll.1999 Moo'l>er. AssodalIon 01 Nctlr\OS COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAfJFlIIlI tt,,~ " . . ,.: :SS. On the ~3~ day of May, 1995, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared MAUREEN A. WARNER, known to me (or satisfactorily proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. ~SeU NlNtC~~~ My CotlrroIssbl E>pios Ma'tt127. ~ 13 REAGER , ADLER, PC BY: DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66J78 2331 Market street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff I plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : JACK L. WARNER, v. NO. 95-442 Civil Term MAUREEN A. WARNER, Defendant DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the fOllowing information, to the court for entry of an appropriate divorce decree: 1. Ground for divorce: Irretrievable breakdown under seotion 3301(C) of the Divorue Code. 2. Date and manner of service of complaint: The Complaint was filed on January 27, 1995 and was served on Gerald J. Shekletski, counsel for Maureen A. Warner, on January 31, 1995. The Affidavit of Service is attached. 3. Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by Plaintiff May 24, 19951 by Defendant May 23, 1995. 4. Related Economic Claims Pending: There are no economio olaims pending as the distribution of all personal and real property has been settled by agreement of the parties. Respectfully submitted, REAGER , ADLER, PC Date: May 24, 1995 ~~ Q: -- ED EN ON, ESQUIRE REAGER , ADLER, PC BYl DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for plaintiff JACK WARNER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. ,,<; - Y 'I <.., Cu.~ -r;.-.. MAUREEN WARNER, : . . Defendant : 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 other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the prothonotary, Room 101, Dauphin County Courthouse, Front and Market streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER I S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Courthouse Court Administrator 4th Floor Carlisle, PA 17013 (717) 240-6200 REAGER , ADLER, ,PC BYI DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 2331 Market street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff JACK WARNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY I PENNSYLVANIA , . v. , /J."A- NO. 'I ~. 'I '/;L L-4/t-< 1-'.<--..... MAUREEN WARNER, . . Defendant DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301CC) OR CD) OF THE DIVORCE CODE 1. Plaintiff io Jack Warner who currently resides at P.O. Box 951, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Maureen Warner who currently resides at 3811 Claverton Road, Mechanicsburq, Cumberland County, Pennsyl vania, 17055, 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 28, 1974 in Hartford, connecticut. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United states or its allies within the provisions of the Soldiers' & sailors' civil Relief Act of the congress of 1940 and its amendments. ,7. The marriage is irretrievably broken. 8. Plaintiff and Defendant have been advised that counseling is available and that they may have the right to request that the court require the parties to participate in counseling. 9. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. ;j 10. In the alternative, after the parties have lived separate and apart for a period of two (2) years, Plaintiff will file an affidavit consenting to divorce. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. COUNT I EOOITABLE DISTRIBUTION 10. Paragraph one (1) through nine (9) are incorporated herein as if fully set forth. 11. Plaintiff and Defl;mdant have acquired both real and personal property during the course of their marriage. 12. Plaintiff and Defendant acquired non-marital property which has increased in value during the course of the marriage. 13. Plaintiff and Defendant have acquired marital debt during the course of this marriage. 3 .' ^ ,'. ..,. ., ' " " "~I f , . .' '.-- I' '. ' '. I . . ' . ., , ' , . '.' I"" . 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property and debt as of the date of the filing of the complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debt. Respectfully submitted, REAGER Ii ADLER, PC ~- .- Datel January 27, 1995 BYI ESQUIRE 4 VERIFICl\TION I, Jack Warner, verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.e,S. section 4904, relating to unsworn falsification to authorities. Date: January 25, 1995 5 l'" !( ;1 , .'1: . ~ ! , I d ., \ I " , , '. HI" -I '\ , I oJ " 'J....:J :1 \ I ' ,. ,'II ,;'.v. 7j, 'it " " f! " ,I ') '-" \~1 '-, I V' ;t ,! " ,,'1 'l'..' I., " , " ,. I V' (:/ ,:(. \-f.~ , , Yi l,ef:) .....~.> __..._ __~..L'_~'~"""""'__<_"___" ...._.._ .-.----~- -".-_..-,",," --.-.....,..,-....-.~ .., .-. ..... ",,_..."'.- ......<. '-,...--.".~~.~..<'..."'_-..-~.,~.._......__-.- It'~U1~ ~~rnH8 ~ VI i t p. rn~I,;~fl ~ " ~ IS _....-...,....;_. ...~.O';h.-i-..;,,;..__.'...;.....................~.....'"""'-...."'" - ~ REAGER & ADLER, PC BY: DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 2331 Market street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff JACK WARNER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : Plaintiff v. NO. 95-442 civil Term : MAUREEN WARNER, Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) or (d) of the Divorce Code was filed on January 27, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint, 3. I consent to the entry of a final decree of divorce. 4. 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. U"'l t:n ~ - a:: Cl rl N tn ,...., >- .::!:. .- , . . 1 I \' I I' " , REAGER , ADLER, PC BY: DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 2331 Market street camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff " Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . JACK ~IARNER, v. NO. 95-442 civil Term MAUREEN WARNER, Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) or (d) of the Divorce Code was filed on January 27, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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, I I . , I: 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 authorities. Dated: 5"/;3/9.5' ,a~bu:.&f(__a'/~l.AwJ ureen Warner, a/k/n Maureen A. Warner j " I I: I I lr) ~ = '"- .,., ~. N L"~ "" >- -r :>= .' . Ii .. .. . . ., , .-, . . . u.. _'<~' ~.....,"H-. -..~&,.._-._ - -~ -.-- , I I REAGER , ADLER, PC BY: DEBRA A. DENISON, ESQUIRE Attorney 1.0. No. 66378 2331 Market street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff " i " , i I 'i L. JACI<IWARNEn, : III THE COURT OF COMMON PLEAS : ctw.BERU,ND COUNTY, PENNSYLVANIA " plaintiff v. NO. 95-442 civil Term /I. MAUREEN/WARNER, Defendant DIVORCE ACCEPTANCE OF SERVICE : A. On behalf of my client, Maureen /Warner, I hereby accept service and acknowledge receipt of the above captioned Complaint in Divorce, having received said Complaint at the offices of stone La Faver & stone, 414 Bridge street, New Cumberland, Pennsylvania, ~tU'-).. 17070, on the .51Jf" day of ~o,,_.,~, 1995. L{y4 /~<~ ~ Gerald Shekletsk, Esquire Supreme Court 1.0. No. 40486 Lr> en ..- , '" ,--) ,,,., ,u ,~ ... ~~t;; ~~~~~ ~~~~~ ffia:~;::!E ClQ xc: ~~a~ ..-- ""'" ~~ .-:0. .., . . . " .