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HomeMy WebLinkAbout95-01832 "j d , ~", ,OJ J <4'>' "lI!:o:. ..llCo:'X-''X-::-llOo:'_~: >OC<)3!O< _>OC< .-:co: ..... '-:CO:.-:C-::~::'llO(~llO( '<<'~X>lC<X'II(_>"-.a(~;.llO(;.llO(_;.llO(~ ~ " ' . . . ~ ~ ' ~ IN THE COURT OF COMMON PLEAS : ~ OF CUMBERLAND COUNTY ~ ~ ~ ~ ~ ~ ~ t STATE OF ~,' .: PENNSYLVANIA I ~ ~ e ..C::.Il~~~I~~l\,..!'I.:,..s,'J:\Jl1'"""""""."""""""" ~ ~...................,............. P..1,a.i,l1.t.HL..".......,..,........ No. ....,....,........n -:...~.~}.?.. 19 95 ~ I Vc~us I ~ ..~,()H..~JI,.....S.I~I.,.. .. ...'....',................,.. ~ 8 .... ,'. ...., ........... ..Pl!fendant......... 8 S ~ ... ~ ~ DECREE IN ~ ~ DIVORCE ~ ~ ~ ~ ANDNOW....tv.~'!~n4~...~.<j........ 19.9.~~.lt 15 ordered and ~ ~ ., ~ decreed that.... .~l:I~f.qnrA .t:I:..q1'IJ!'!,........................ plaintiff, ~ ~ and..... .. ,.,JP}lli. t1....STm1..,..... .. ,.., .... ,.... ....,....... defendant, ~ Ii! ~ are divorced from the bonds of matrimony. The tenns of the Marriage - Sett1erent AgreeIrent entered into by the parties on November 15. 1995. .. are ~"d _in. ~ ~ T e court retains jurisdiction of the following claims which have g ~ been raised of record In this action for which a final order has not yet -, 8 been entered; ~ ~ ~ , . . . . . . . . . . . . . None. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . ~ ff,... :~ w 8,: .... t... ". .t... .......... .......0.. to. .., t. .... Of to' .... ...... '0' ~ ~ ~ ~ Dy The Court: /J . ~ I : ~ A,;;;;,~:,;-{1Yf~1:~t~J: i I .,':I!:~;!,.:.I.-:'. ,6;;tt1... -97\;~~lh~~~:'~y,.. ;. ~ ~ " .e._ ~ /1'30 ,9:{' tJvf'. to/'t d~:.ff'/ it; ,;:zf 6.1} /1' 30 Ps lcl /N.-.:.d/ ~ c.~ MARRIAGE SETILEMENT AGREEMENT TInS AGREEMENT is made and entered into between John M. Stum and Christina M. Slum, hereinafter referred to as Husband and Wife. The parties were married on April 18, 1989 and there is one child born or adopted Dftheir marriage, to wit, Justin J. Stum, bDm April 24, 1989. As a consequence of disputes and unhappy differences, the parties hsve separated, The parties desire to confinn their separation and make arrangements in cDnnectiDn therewith, including the settlement of their property rights, custDdy, SUppDrt, 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 hereafler to live separate and apart from the Dther party at such place or places as he or she may from time to time choose or deem/it, B. Each party shall be free from interference, authority and control, direct or Indirect, by the other, as fully as ifhe or she were single and unmarried, Neither shall bother the other or compel Dr 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, executDrs, administratDrs, and assigns, release and discharge the other of and frDm all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or nDW has against the other, except any or all cause or causes of action for divorce. 4. FULL DISCLOSURE The provisions of this Agreement 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 Df 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 Dfall 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 Df this Agreement. Wife acknDwledges that she was represented by Kathleen Carey Daley, Esquire, in reaching this Agreement, and Husband acknDwledges that he was represented by Murrell R. Walters, III, Esquire, in reaching this Agreement. BDlh parties represent that the tenns of this Agreement have been fully explained to them by their respective counsel. ..., 5. EOUITABLE DIVISION By this Agreement, the parties have intended to eficct an equitable division of their marital property. This divisiDn is not intended by the parties to constitute in any WilY II sale or exchange of assets. 6, SUBSEOUENT DIVORCE A. AGREEMENT NOT 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 tD 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 nDn-prosecution Dr nDn-defense of any action for divorce; provided, however, that nothing cDntained in this Agreement shall prevent Dr 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, Ihatthis 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 3 ~ waives any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole Dr in part. Husband and Wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall fDrever be estDpped 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 prDsecuted by either party and no order, judgment or decree of divorce, temporary, tinal or pennanent, shall affect or modifY the linancialterms of this Agreement. This Agreement shall be incorporated in but shall nDt merge intD any such judgment or decree of tinal divDrce, but shall be incDrporated 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 bDth 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 tile 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 3301(c). Upon request, to the extent penniued 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. 4 " 7. DIVISION OF PERSONAL PROPERTY With the exception of a television set which Husband agrees to deliver to Wife within one week of the date of the executiDn of this Agreement, Wife agrees that all of the property in the pDsscssiDn of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties dD 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 prDperty of the Dther. 8. DIVISION OF MOTOR VEHICLES With respect to the motor vehicles owned by one or both of the parties, they agree as follows: A. The 1991 Geo Storm shall be distributed to Wife. B. The 1995 Chevrolet Corsica shall be distributed to Husband. 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 Df either party. 5 " 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 hislher separate property and any property which is in their possession or control pursuant tD this Agreement and may mortgage, sell, grant, conveyor otherwise encumber Dr dispose of such property, whether real or persDnal, whether such property was acquired before, during Dr after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the Dther pertaining to such dispositiDn of property. 10. ivfOBILE HOME Husband and Wife hereby agree and acknowledge that they own a mobile home located at 277 RedwoDd Lane, Carlisle, Pennsylvania, as tenants by the entireties. Wife hereby agrees to convey all her right, title and interest in said mobile home to Husband. Wife agrees to execute the title or Dther instrument of conveyancing necessary to effectuate this transfer at the time of the execution of this document or at any time thereafter at the request of Husband. The parties acknowledge that there is an existing mortgage against this mobile home held by PNC Bank in the approximate amount of$18,500.00. Husband agrees to assume total liability for this mortgage. Husband shall hDld Wife hannless and indemnify her from liability for this obligation and all other obligatiDns arising from this mobile hDme. 6 may now or hereafter have allainst 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 Dther 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 contributiDns by his or her emplDyer. Wife hereby releases any interest that she has in the retirement benefits of Husband accumulated as the result of his emplDyment by Giant Foods and any other additional benefits he may have accrued including his 401(k) plan benefits. Husband hereby releases any interest that he has in the retirement benefits of Wife accumulated as the result of her employment by Delta Dental of Pennsylvania and any Dther additiDnal benefits she may have accrued. This waiver is a full and complete discharge of each parties' marital claim to the assets described herein. [5. M[SCELLANEOUS 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 Df the title holder of said asset. B ~ The parties believe and agree, and have been so advised by their respective allorneys, that the division of property heretDfore made by this Agreement is a nDn-taxable division of property between CQ-Owners rather than a taxable sale Dr exchange of such property. Each party promises not to take any pDsition with respcctto the adjusted basis Df the property assigned to him Dr her or with respect to any other issue which is incDnsistent with the position set fDrth in the preceding sentence on his or her federal Dr state incDme tax returns. Thll parties have heretofore filed joint federal and state tax returns. Both panies agree that in the event any deficiency in federal, state Dr local income tax is prDpDsed, Dr any assessment of any such tax is made against either of them, each will indemnity and hold hannless the other from and against any IDSS or liability for any such tax deficiency Dr 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 Dfhis or her separate income on the aforesaid jDint returns. 16, CHILDREN A, CUSTODY AND VISITATION. The parties shall share legal custody of the child born Df this marriage. The child shall reside with their mother who shall have primary physical custody. Wife shall provide Husband with infonnation concerning the health, education and welfare of Justin on a regular basis and shall encDurage Husband to join in the decision making process as tD ,the child's schooling, medical care and other important issues associated with his life, 9 ~ Husband shall be afforded partial custody under the following schedule: I. Every-other-weekend the child shall be with his father from Friday evening until Sunday evening. In addition, father shall have partial custody up to two evenings per week. The times and locations for pick up and delivery shall be determined by the parents. 2. Holidays, vacations and other important times shall be spent with both parents under a schedule agreed to by the parties, B. MAKE-UP TIME . The parties recognize that there may be circumstances from time to time which may prevent the exercise of custDdy at the agreed dates and times. To that end, the parties agree that each will give timely and reasonable notice to the other of the existence Df such circumstances and will permit the other a reasonable period in which to enjoy time with the child tD make-up for these lost periDds. C. ll..LNESS OF CHILD - In the event of any seriDus illness of the child at any time, any party then having custody of the said child shall immediately communicate with the other party by telephone or any other means, informing the other party of the nature of the iJlness. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the proper medical care of the said child. The word "illness" as used herein shall mean any disability which confines the child to bed under the direction of a licensed physician for a period in excess of forty-eight (48) hDurs, 10 ~ D. BEST INTEREST OF CHILD. The parties shall exert every reasDnable effort to maintain free access and unhampered contact between the child and cach of the parties, and to foster a feeling of affection between the child and the other party. Neither party shall do anything which may estrange the child from the other party, or injure the child's opiniDn as to his mother Dr father, Dr which may hamper the free and natural development of the child's love and respect fDr the other party. 17. CHILD SUPPORT Child support shall be paid by Husband to Wife at the rate Df$50.00 per week plus one-half (V,) of any day care expense. This payment is currently being made by Husband to Wife directly. The parties acknowledge that either party retains the right to seek the interventiDn of the courts of the CommDnwealth ofPennsylvnnia regarding child support matters. Husband shn11 be entitled to claim Justin as his dependent on his tax return fDr 1995 and for all future odd years, Wife shall be entitled to claim Justin on her tax return for 1996 and all future even years, Wife agrees to execute any and all documents necessary for these dependency deductions under the condition that Husband has paid all child support obligations to date at the time that Husband requests Wife to sign documents to authorize this dependency deduction, 11 ~ 20, GENERAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS - Each party represents that they have not heretDfore incurred or cDntracted for any debt or liability Dr obligation fDr which the estate of the other party may be respDnsible or liable except as may be provided for in this Agreement. Each party agrees to indemnifY Dr hDld the other party harmless frDm and against any and all such debts, liabilities, Dr Dbligations of every kind which may have heretofore b~en incurred by them, including thDse for necessities, except for the DbligatiDns arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at all times hereafter save hannless and keep the Dther indemnified frDm all debts, charges, and liabilities incurred by the Dther after the execution date of this Agreement, except as may be otherwise specifically provided fDr by the tenns of this Agreement and that neither of them shall hereafter incur any liability whatsoever fDr which the estate Dfthe other may be liable. C. SEVERABILITY -If any lenn, condition, clause, or prDvisiDn of this Agreement shall be detennined or declared to be void or invalid in law Dr otherwise, then only that tenn, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full fDrce, effect, and operation. Likewise, the failure of any party to meet his or her DbligatiDns under anyone Dr more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way VDid Dr alter lhe remaining obligations of the parties. 13 D. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all wrillen instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be neceSSllly or desirable for the proper effectuation of this Agreement, and as their respective coWlSel shall mutually agree should be so executed in order to carry out fully and effectively the tenus of this Agreement, E. ENTIRE AGREEMENT - This Agreement contains the entire understanding ofthe 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 mDdificatiDn or waiver of any of the tenus 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 ofthe same or similar nature. G. MUTUAL COOPERATION. Each party shall, at any time and from time tD time hereafter, take any and all steps and execute, acknDwledge. 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. 14 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, J. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and untiltenninated under and pursuant to the temls of this Agreement. The failure of either party to insist upon strict perfonnance Df any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nDr shaH the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nDr shall it be construed as a waiver of strict perfonnance 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 sDlely for cDnvenience or reference and sha11 nDt constitute a part of this Agreement nor shall they affect its meaning, cDnstruction, or effect. L. ADDRESS OF PARTIES. Each party shall at all times keep the other infDnned of his or her place Df residence, and shall promptly nDtity the other of any change, giving the address of the new place of residence until all obligatiDns under this agreement have been satisfied. M. WAIVER OF CLAIMS AGAINST ESTATES. Except as herein otherwise prDvided, 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 Dr another jurisdiction, tD share in the property or the estate of the other as a 15 result of the marital relaliDnship, 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 Dther, 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 intD 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 tenns thereo~ the parties hereby agree that the breaching party will pay all reasDnable aUDmeys' fees, CDurt CDStS, and expenses incurred by the other party in enforcing the Agreement. IN WITNESS WHEREOF, and intending tD be bound hereby, the parties have signed and sealed this Agreement on the J l'l-k. day Df ~ fi\!1!;1111 J.I A , 1995, at Harrisburg, \ Pennsylvania. In the presence of: laLL~ )/1, ~4:iL ~. ~ lD::::- /~'Lt~!;/1 d 77t--1It 1/)) (SEAL) ~RISTINA M. STUM (SEAL) ()Jt( /"1'11 .4 /j,) //"11 I . , I , ' 16 NOTICIA Le han demandadD a usted en la corle. Si usted quiere defenderse de estas demandas expuestas en las paginas siguienles, usted tiene viente (20) dias de plnzD al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abDgadD y archivar en la corle en fonna escrila sus delensas D sus objcciones a Ins demandas en contra de su persona. Sea avisado que si usted no se defiende, la cDrte tomara medidas y puede entrar una orden contra usted sin previo avisD D notificacion y por cualquier queja 0 nlivio que es pedidD en la peticion do demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos imporlanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDlATAMENTE. SI NO T1ENE ABOGADO 0 SI NO T1ENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A D1RECCION SE ENCUENTRA ESCRlTA AllAJO PARA AVERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th FloDr, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 , .~.' .. .,.~ ..... ..-_......1' . r ~'. 1. ".':..t ~....-"'."""" L" _ ...\..' ~ J . ~ ' ,. ..........~ ---. -....~ . ....... . , , , Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION. LAW : NO. C/S.jfJJ- 0..;J-rL<.-'- : IN DIVORCE CHRISTINA M. STUM, Plaintiff v. JOHN M. STUM, COMPLAINT IN DIVORCE COUNT I DIVORCE AND NOW comes the above Plaintiff, Christina M. Sturn, by her attorney, Kathleen Carey Daley, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant upon the grounds hereinafter set forth: I. The Plaintiff, Christins M, Sturn, is an adult individual who resides at 16 Elicker Road, Dillsburg, York County, Pennsylvania 17019. 2. The Defendant, John M. Sturn, is an adult individual who resides at 277 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintilfand Defendant are sui juris, and both have been bona fide residents Dfthe CommDnwealth of Pennsylvania for a period of more than six months immediately preceding the filling of this CDmplainl. 4. The Plaintiff and Defendant were married on April 18, 1989, in Mechanicsburg, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 6. The cause(s) of action and section(s) of the Divorce Code under which Plaintiff is prDceeding are: A. Section 330 I (c). The marriage of the parties is irretrievably broken. 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. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on March 12, 1995. 7. There have been no prior actions in divorce between the parties. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling, 9. The parties may enter into a written agreement with regard to support, custody, visitation of children, alimony and properly division, In the event that such an agreement is executed by the parties, the agreement may be incorporated by the Court into the final Decree of Divorce. WHEREFORE, PlaintilT requests your Honorable Court to enter a Decree in Divorce, divorcing PlaintilT and Defendant. COUNT II EQUITABLE DISTRIBUTION 10. Paragraphs I through 9 of this Complaint are incorpDrated herein by reference as though set forth in full. 11. PlaintilT and Defendant have acquired property, both real and personal during their marriage from the date of their marriage until March 12, 1995, the date oftheir separation. 12. PlaintilT and Defendant have been unable to agree as tD an equitable division of said property. WHEREFORE, Plaintiff requests YDur Honorable Court to equitably divide all marital property. COUNT III ALIMONY 13. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full, 14. PlaintilTlacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 15. Plaintitl'requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiffrequesls your Honorable Court to enter an award of alimony in her favDr. COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 16. Paragraphs I through 9 of the Complaint are incorporated herein by reference as though set forth in full. 17. Delendant earns in excess of$35,OOO.OO gross per year and has assets which have not yet been ascertained. 18. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attDmey's fees for said cDunsel. 19. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintiff requests your Honorable Court tD enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. 1 verilY that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S,A. ~4904 relating to unsworn falsification to authorities, By: (JJU;/1;'Aai/J}/)!tI/J) Christina M. Sturn, Plaintiff Date:, ~ ~.qC; By: Uctd&u~ K hleen Carey Daley, Attorney No, 30078 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff . , ~ c ~ > ~~ r- ~~~ ~ 5:"~ ~!2!2 ~ ~ti~ ...~ 0 ~)>c ." zCS! ." )i:;ii (; ~ m ... en ~ .,... ...... CHRISTINA M. STUM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v, : NO. 95-1832 CIVIL TERM JOHN M. STUM, Defendant : IN DIVORCE AFFIDAVIT Christina M. Stum, Plaintiff, being duly SWDm accDrding tD law, deposes and says: I. 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 DDmestic Relations Office, which list is available tD me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling priDr to a divorce decree being handed down by the Court. I understand that false statements herein are made subject tD the penalties of 18 Pa.C.S.A, ~4904 relating to unsworn falsification to authorities. Date: /I,tT.1)" By: ~Li/)/;;1dJn.Jo:l/Y} HRISTINA M. STUM, Plaintiff ~ 2;/ ~ lll~ r- ~~~ ~ ~. ~ ~~z ~ ~~m 0 CSl~Cl "'" sJ ~ ~ m .... en ~ ,'- - .,.~.... ., ~_"rT".'.'..' ... . ".. ," - "',', -'_"'- . <-',:-'., ...,--- --.." ~:.~ ." . 'q , ....,...........''",... - " -- ~ ~~ ~ Q~~ ~ 8;'~ ~~~ ~ e;g~ 0 ~~~ =R )>~ (; m en ~ ..... ~ . , . , .....,.. _J ~ ~ rl"'.n;I:!~-:-]!trU~~$ - .' ~ii-- iiiii ~ ""J,~"'r~"""\' -.... . ....._..........~ On .. 1 ,'~i';. LD~,~L.m~1"~~Dt 2'fonddlI5on'h.fYk..;-,V'~'.- - .... I ,I F 8110 wIth to rocelvl' tho r .,' Cornptl,.lttmt 3.- and 4. . b. '" , . . . \ . following lorvlces (for 8n eKtrll 1) .:. Print Your'nlme and addl... on the ,.veri, of thl',form 10 thlt wi tan feel: . , __,rttumW.canltoVOU.-,: .'_ _' ,- --', ,- _ _ ,- . _.~ _,',"" I,' l :, :i~.~.h':::::":I':""_~~ .... "~nl of 1~~"'I>l.C'. '" on ,... bock II .p". (j' 1~' . ~eQ~.t"A~;,)' ". ..' I ,.,. ~ - Wrh. ~'R.tum R.ctlpl R~It.d" ~ tht"fMftpltce below the ittlcl. numbt, 2.' ,a"letid Oellverv'. '; I ,',-e, TfMiR,tumRlcllptF..wldptOYidl.,outhtl.IQn,tureoft.hePlr.cnd.1v1 " '. < c", _' - _' t. :,to,,~thed.t'ofd'h .-. , ..'~' Consult. altmaster.fOl.f. . ; ;>,,;3.-;Artlclo Addre...d to: " , _' 48. Artl 1.;"V:::6d~~,~. S~~'" ";':;. lil.:~(~~~~~f'.~'. .:. ).. h~':' ,. t"" ."~ ,',; I ',I'i; II, flllii r 1990 oU.a.OPO;III8I-2I1-l1OO DOMESTIC RETURN RECEIPT .-; . .", \ " , I ,'.,' '( , ,..'\ " I ':1 . .~ .I I " ' . " ., ,.. . . . B ~ .... ~ II) w U ~~ u:: 0:: ~ I() II- 0>00 o ffi~~ 3;3 Zz-o UJw", ua..... rn .~ ~ ~~D ..... ~CD < rn Q 0:: ~ . CHRISTINA M. STUM, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW v. : NO. 95-1832 JOHN M. STUM, Defendant : IN DIVORCE ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff, in the above matter, having been granted a Final Decree in Divorce on the 29th day of November, 1995, hereby elected to retake and hereafter use her maiden name of Liddick, and gives this written notice avowing her intention in accordance with the prDvision of 54 Pa.C.S.A. ~704(a). Date: /-.;;~/- 9~ t/!.. t ///L/ /1.:1 . )17. __Iill m Christina M. Stum TO BE KNOWN AS: (~'iI~(T/(tl..-})7. L/ddlij./ Christina M. Liddick ..... Ir; ;.~ ~l~f~ cl-( 1 Ll: I~' ~ t;'(: @"': rdl' (" .. h_ (..> f' '--.:j- ~ .~ ~ - -. o ," ,,-; (oJ (t"J -. ::-, ~ ..- l ).' ~ \ ):': I'. ~ 7'! .' ~.! (.'" . d\(l ~;~C__ '12 1.1.. <n N 0"- -'j lfJ 0' ::i u ~ C ~~ ~ '=:)~~ !:;! ~. ~ ~~Z i e~~ 0 tSlf' .,., ,J ?i m en .. - ,.... -; ~ .... ~ !a 0, -..., ~.8' "-.), -- , ~. . . . DALEY LAW OFFICES 1029 SCENERY DRIVE HARRISBURG . PENNSYLVANIA 17109 (717) 657,4795 ... . ..