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HomeMy WebLinkAbout95-01828 . ..~ . . <fl:-' :_lIe_"->>: ....:.*:'-lIC-: ~__>:lIO"-a< >lIC-: -:1<<>:'" ._lIe_:....: >;c.::->>::->>: >:I<<>~.X>>lO(>>IO(laID<>.-.o<>3D(____~ ~ . . j~ ~ ' ~ IN THE COURT OF COMMON PLEAS ~ ~ ~ ~ OF CUMBERLAND COUNTY ~ ~ '* @ ~ ~ , STATE OF ~, . ': PENNSYLVANIA i ~ ~ ~ 8. : ':::~~~:~'::~:~:::~;~~~::,~~~~:~..:::::::..::::::::::::::::.':: N o. ...",~..?,:.~,~,f.,~ ................, 1995 ~ ~ Versus ~ ~ .......................................... ............................. ij ~.:. ~ " ,~.T.EP.I1.EN...J\..~..9.RU.B.J::,.. ... .. ............ . ~ ~ g ~ ;, i DE,c:cJ:c~; ~1l;~C{(\ l:! AND NOW, ..... .....,,"~...., 19"..... It Is ordered and ~ ~ decreed that.. ..CJ:.B, . n...Cilr.ey.l1l:ubl.:!......,....."......" plaintiff, ~ ~ and ,.....Sl:.ephen.A...GL'l.lbe..,....,....,.,......,..,......., defendant, ~ ~ are divorced from the bonds of matrimony. The terms and conditions of ~ ~ the Marriage Settlement Agreement dated August 10, 1995 are ~ l>.',' attached hereto a.nd inc;o~PQrated. heroin. .~,..,. " ~5 !_w. I ,l!'a+t\8 I1Il,r.Jtlffft8flL "" Jtl'ei-te+IBo;:iRg 11.1MB uhl!R ~.V8 PI 8 ..88A fSlitotJ 9f r8tgr~ I", thlct ",..tQ", f?r ..:RiIA a fJ,ul1 er8ef btll. Rat Ylt "; ~~ 10,,:,,:\" Ant~rlS,.I. 1!1 ~ lil .. -. .' ,;j ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~~.~ . . . . . . . . . t . . . . . . . . , . . . . I . . . . . . . . . . . . , ; 8 ...... It It ......., ...... Of t... .... t. ....., ........000.. '.' :.. ~ ~ ~ ~ ~ t ~ 'UI;~,";~;;~~:~~~;J ~ ~ ,...~v~',_o:...~. ~&;,...~4 .........".. : ,/ P'rolhonolary . " ~ ------ -------.....-. ~ ~___~_lIe___lIe___~_lIe_~~~_lIe__lIe_~__~.~_____~ . S' .)5- ~'S t;\(. {J5 ~'J' 'J;;,t~" {~7 /J,r,:tdl;{? ,r?t KIt;; ,./ ",./ " . . .1/-/) . /~ v/{;r (t:'C.~f .;r...i .Plt:'" r~; 4.:.(',,~ . /v I MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT is made and entered into between Grace B. Carey Grube, and Stephen A. Grube, hereinafter referred to as Husband and Wife. The parties were married on September 2, 1989 and there are no children born or adopted of their marriage. As a consequence of disputes and unhappy differences, the parties have separated. The parties desire to confir.m their separation and make arrangements in connection therewith, including the settlement of their property rights, custody, support, and all other rights and obligations arising out of the marriage relationship. It is therefore agreed: 1. CONSIDERATION The consideration for this Agreement is the mutual promises and agreements herein contained. 2. SEPARATION AND NONINTERFERENCE A. It will be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. B. Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 3. MUTUAL RELEASE Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce. 4. FULL DISCLOSURE The provisions of this Agreoment and their legal effect are fully understood by each party to this Agreement, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, of the sources and amount of the income of such party of every type whatsoever, and of all other facts relating to the subject matter of this Agreement. Both parties acknowledge that they have reached this agreement through their independent negotiations and that Kathleen Carey Daley, Esquire, has memoralized their agreement without providing legal counsel to either party. 5. EQUITABLE DIVISION By this Agreement, the parties have intended to effect an equitable division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 6. SUBSEQUENT DIVORCE A. AGREEMENT NQT PREDICATED ON DIVORCE - It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waives any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole or in part. Husband and Wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. B. ENTRY AS PART OF DECREE - It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. C. MUTUAL CONSENT DIVORCE The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section 3301(c). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. section 330l(c). Upon request, to the extent permitted by law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 7. DIVISION OF PERSONAL PROPERTY Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband1 and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. B. DIVISION OF MOTOR VEHICLES with respect to the motor vehicles owned by one or both of the parties, they agree as follows: A. The 1995 Saturn titled in Wife's name shall remain Wife's sole and separate property. Wife shall pay any and all loans and expenses incident to this asset and shall indemnify Husband harmless from any and all liability arising thereunder. The titles to the said motor vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided, on the date of execution of this Agreement or at any time thereafter at the request of either party. 9. DISPOSITION OF PROPERTY From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, conveyor otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. 10. DIVISION OF REAL PROPERTY Husband and Wife hereby agree and acknowledge that they own certain real property located at 2570 Rumson Drive, Harrisburg, Pennsylvania, as tenants by the entireties. Wife hereby agrees to convey all her right, title and interest in said property to Defendant. Wife agrees to execute a deed or other instrument of conveyancing necessary to effectuate this transfer at the time of the execution of this document. The parties acknowledge that there is an existing mortgage for which this property is held as security by Northwestern Mortgage of Warren, Pennsylvania, in the approximate amount of $43,230.00. Husband agrees as soon as he is able to do so to obtain financing such that she shall either satisfy said mortgage in total or ahall assume total liability for the mortgage. Husband shall hold Wife harmless and indemnify her from liability for this obligation and other obligations arising from this property. 11. PAYMENT OF SPECIFIED OBLIGATIONS The parties agree that the following constitute joint marital obligations which shall be paid by the following person: A. WIFE - Citibank Visa 4128 0020 4067 8778 Belco Federal Credit Union 409390 B. HUSBAND - Signet Master Card 5291 1512 8029 4149 12. LEGAL FEES Each party shall pay his or her own attorneys fees. 13. ALIMONY Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance, alimony pendente lite or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support, maintenance, alimony pendente lite or alimony. 14. PENSION PROGRAM Each party hereto shall maintain sole ownership over his or her individual pension plan, profit sharing or similar retirement plan acquired individually or as the result of contributions by his or her employer. Wife hereby releases any interest that she has in the retirement benefits of Husband accumulated as the result of his employment by Rolling Green and PennDel and any other additional benefits he may have accrued. Husband hereby releases any interest that he has in the retirement benefits of Wife accumulated as the result of her employment by CDSC, Bell Atlantic and Papyrus, a division of Marcel Schurman, Inc. and any other additional benefits she may have accrued. This waiver is a full and complete discharge of each parties' marital claim. 15. MISCELLANEOUS All assets including, but not limited to, savings accounts, checking accounts, certificates of deposit and life insurance policies shall be the sole and separate property of the title holder of said asset. The parties believe and agree, and have been so advised by their respective attorneys, that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 16. GENERAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities, or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, repreAent, and ~gree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. c. SEVERABILITY If any term, condition, clause, or provision of this Agreement shall be determined 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. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. D. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the term9 of this Agreement. E. 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. F. WAIVER OR MODIFICATION TO BE IN WRITING - No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. G. MUTUAL COOPERATION - Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. I. BINDING EFFECT - Except as otherwise stated herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. K. NO WAIVER OF DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. K. HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction, or effect. L. ADDRESS OF PARTIES - Each party shall at all times keep the other informed of his or her place of residence, and shall promptly notify the other of any change, giving the address of the new place of residence until all obligations under the agreement have been satisfied. M. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, curtesy, their statutory equivalents, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of other, and right to act as administrator or executor of the other's estate, and each party will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. N. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that either party breaches any provision of this Agreement, and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay all reasonable attorneys' fees, court costs, and expenses incurred by the other party in enforcing the Agreement. , '" .,"j .,..,:-, :lti ~. 1~ " T':.., '. '- U) W U u: u.. o ~ t::; ..... ~ B ~ ,.. ~ r~ o~g? ffi~~ Z~.o ~D.;~ ~~D ~a:l ~ ~ ':'~- c= ,.., CA.l I~ no ...", :::c:: - c..o (J"1 Gr.ace B. Carey Grube Plaintiff IN THE COURT OF COMMON PLEAS : CUMB~ COUNTY, PENNSYLVANIA Vs. NO. 95-1828 CIVIL TERM Stephen A. Grube CIVIL ACTION - IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for diVorce: irretrievable breakdown 3301 (c) Id) under Section (x>lX~~XX(X~~X(ili 11) of the Divorce Code. I Check applicable section). 2. Date and manner of servi~e of the 80~1aA8~4ptance On April 14, 1995, Defend~nt s~gne e nf ~prv;ce which was filed on Apr~l 24, 1995 . 3. I~omplete either paragraph la) or Ib). la) Date of execution of the affidavit of consent 3301 required by Section ~ Ic) of the Divorce Code: by I'laintiff " '""..' Auaust 1, 1995 Auaust 10 , 1995 Ib) (1) Date of execution of the plaintiff's : by defendant affidavit required by Section 201 (d) of the Divorce Code: (2) date of service of the Plaintiff'B affidavit upon the Defendant: 4. Related claims pending: None ), Date and mann",' of 5ervice of the notice of llll"nLioll to Ii l" pL":Jecipe to tL'ansrnil l:ecorrJ. a copy of \;hich b '1lt'-lo.:/1.:." t)T~ON 4t GRACE B. CAREY GRUBE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION. LAW ~ NO. 95- 1'D.7? (I (V-~L- 01.-01~' v, STEPHEN A. GRUBE, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT, If you wish 10 defend against the claims set forth in the following pages, you must take prompt action, You are wamed 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, including custody or visitation of your children. 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Adminislrator Cumberland County CourthQuse I .-' 4th Floor, (( 'lLLI' L "-II It) ( ')'.'1" Carlisle, PA 17013 - {./ 1II,.)JI','fr.)eci NOTICIA Le han demand ado a ustcd cn la corte. SI uslcd quicrc dcfcndcrsc dc cstas dcmandas expuestas en las paginas siguientcs, ustcd ticne viente (20) dias de plazo al partir de la fccha de la demanda y la notificacion, Usted debe prescntar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte cn forma escrita sus defensas 0 sus objccioncs a las dcmandas en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede cntrar una orden contra ustcd sin previo aviso 0 notificacion y por cualquier qucja 0 alivio que cs pcdido cn la peticion do demanda. USled puede pcrder dlnero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO T1ENE ABOGADO 0 Sl NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELFONO A LA OFIClNA CUY A DlRECCION SE ENCUENTRA ESCRlTA ABAJO PARA AVERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 5. The Plaintiff and Defendant are both citizens oflhe United Slates of America. 6. There have been no prior actions in divorce bel ween lhe panies, 7. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies, 8, Plaintiff avers that there are no children of the panies, 9. Plaintiff has been advised of the availability of counseling and that shc may have the right to request that the Court require the parties to participate in counseling. 10, The cause of action and section of the Divorce Code under which Plaintiff is proceeding is: A, Section 3301(c), The marriage of the panics is irrelricvably broken. After ninety (90) days have elapsed from the dale of the ming of lhis Complaint, Plaintiff intends to file an Affidavit consenting to a divorce, PlalntUT believes that Defendant may also file such an Aflidavit. WHEREFORE, the Plaintiff prays your Honorable Counlo enter n Decree in Divorce from the bonds of matrimony. I 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.C.S,A. ~4904 relating to unsworn falsification to authorities, ~. 7. ../ Date: "'..) 'Jf j.J , By: il!ldtttLii thleen Carey Daley, Attorney No. 30078 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff Ln r:n ~ ~ '" '-'J -- ~ C. ~l rt: ", ... ~ [- t. ~ ~~~ ~ $9)~ ~ ); ~~! ~ :E "" ~< () :(l~o rn 0 O1;g;o "'" -'" "'" j;m _ o m ..... :::l! ~ , . , .. ..-oC"'".. r-. ,...... I , I i I I I i I ~ >- ",>- ..t!= ",,'-- . or:,:'-o., _.:Z:";~ 1.4l..-'(';:;..; '...;r .' Ct,,"-~,~ ~ i ;.: .., ... "I~_..,l" ..J o:..r; ._".1Jt~;Z: "':r,lllW 1'_ ,:J:U. ~f3 iE Q] ..-j C") -:r - <.3 => - , .' . GRACE B. CAREY GRUBE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 95-1828 CIVIL TERM STEPHEN A. GRUBE, Defendant IN DIVORCE AFFIDAVIT I, Grace B. Carey Grube, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. (-.~ , 1"'/ Date: .f. / I' ':.. I , ..' .1' . ) ./.} {r" .' . ' ( By: . . 1-),:/ ,(.(;.A ( ..(,11' (~~< I ( /:;j_' (-Grade B..Carey Grube,:Plaintiff -.-.. . (~ U"I CTl - :0-). <1': ~_ ., . too: 01 ~" I ~:;:_..:.. 1....1. .' h '1"1- I l~;;- .# :lC <>- a:I ~ (Y) ;.. "'.,., , . -:r ,J. "0 LI.~. " ',j.,- :::t L' oc:x I, i ti , , I , , I , I i I " t: GRACE B. CAREY GRUBE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO, 95-1828 CIVIL TERM STEPHEN A. GRUBE, Defendant : IN DIVORCE ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plainliff, in the above maller, having been granted a Final Decree in Divorce on the 23rd day of August, 1995, hereby elected to retake and hereafter use her maiden name of Grace B. Carey, and gives this wrillen notice avowing her intention in accordance wilh the provision of 54 Pa.C.S,A, ~704(a), D..., Lifr/rb G TO BE KNOWN AS: i "7 \0 J (kl 11.. Q r ',. \0 cr- t<) ii' '-- G I, ,-, 8 ~ 1=1 lit ~ ' " . ..)! 'X (I: ~, c.: 1'-. V l~; , i." (': (,1 If!. l't.. , Hj i_' , I , . \", I t"i '.,1 ~ 0 ~~ ~ ~~~ ~ 5;'~ ~ ()o~Z ::e ~~~ "<0 0 -0)>;0 "Y1 C11Z_ "Y1 ;;~ Q ::i en ~ !i3 . ,. .