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IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF a~~~t PENNA.
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LAURENE L. 1I0LMES,
Plaintiff
\. l' 95-2732
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(UeIlAHD c. BLUMENS'j'EIN,
Defendant
AND NOW,
DECREE IN
DIVORCE
t) ~k.:' 19 95 it il ordered and
docreed that
Laurene L. Ilolmea
, plaintiff,
defendant,
and Hi"hard c. IlIUl11eI1/ltein
are divorced from tho bonds of matrimony
The court retains jurisdlrllofl of the following c1oill1li which have
been raised of record In this octlon for whirh 0 firlOl order has not yet
been enturod; tJo~V
'11... tenna at the Property ~jetllement Agreement, a copy of which is
/lUnched 11ereta as, I;xhibit A, ate h("eby incotp"rated bill lIot merged it]tQ
,7 /
this Decree
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MAlU TAl, S~n'I'I.I'J4I'Nr AC1li'U'lI'Nr
'11119 AGlEI'J4J'Nl' made this ~.)
day of In,),
If ( "
1995, by and between L^IJIlENE L, II()LMI';~, of Ca"~) 11111, pennsylvllnla
(herelllafter referred to as "\~JFE"). and IUCII^IlD C, /lI.UMlcN5'J'lcIN, of
Wonnleysburg, Penllsylvanla (h,n-elnMlm- referred t.o as "IIIJi'iIl^N/l"),
WI'lWI"S'lBTII:
W11DU'.AS, the part les hereto are lIushand an,l WI fe. hav In') been
married 011 June 16, 1992 ill Willlamsbul"f), Vlr91nlal
W11F2U!AS, there are no minor children born of the marriagel
W111!REAS, the parties hereto are desirous of settling fully and
filially thelr respective finallcisl anll property rights and obligal1ons as
betweell each other. including, without Ilmitstion, the sl!ttlln'J of all
matters between them relating to the ownership of real and personal
property, the support snd mailltenance of one another and, ill general, the
settl1ng of allY and all clslms and possible clsims by one IlIJlllnst the other
or against their respective estates,
t<<:W, 'll1DU'.F<llE, In consideration of Ihese premises, and of Ihe
mutual promises, covellsnts am! undertakings hereinafter set fOIl h, ,m,l for
other good and valuable cOlIsideration, receipt and sufficiency of which Is
hereby acknowledged by each of the parties hereto. Wife Bn,1 lIushar"I, eadl
Intendlllg to be legally bound hereby, covenant and agree as followlll
J. I,MGAI. AIJVICR. Both parties agree 11m! ackn"wlel~Je I hat 1I11lY
have had ample and sufficient time 10 carefnlly and fully review the telm"
snd provisions of this Agreement and to Reek and obtain the advll'e an,!
coulIsel of an attorney wHh respect to th" same, WI i"I': "ull"" I eprellenl R
that ahe has consulted wilh ill"l ohtalned 1'"Jal counsel frc~n Ilawn ~;. :;unday,
"a<Juln" 1I11SIIANIl represent" that he haa "een advi"ed to obtain irlllelx""l"nt
counael but haa elected not to do 50, lIoth partiea alJre" and i1cknow]ecl<Je
that they fu]]y IJl1l]et'stand the facts "lxlll which this Agreement is premised
and based, that they believe Lllis Ayreement to be fair and equi tab]e, that
this Agreement Is being entered into freely and volulltarily by each of
them, and that the execution of this A(Jreelllent is not the result of any
duress or undue influence and that it is not the result of any collusion or
improper or i]legal agreement or agreements.
2. 11lSCl.osuJlli OF ASSETS. ']'he parties warrant that they have
given a full, complete and accurate disclosure of all assets, of any
nature, whether or not the assets were held jointly or in one name alone.
1'he remedies availab]e to either party for breach of violation of this
provision shall be those remedies available pursuant to law and equity
including the right to punitive alld compensatory damages.
3. 1'/lIlllCfiA1. RIGlrra. Wife alld lIusballd may and shall, at all
times hereafter, live separate and apart. Each shall be free from all
control, restraillt, interference and authority, direct or indirect, by the
other. "ach may reside at such place or places as she or he may select.
F..ach may, for her or his separate use or benefit, conduct, carry 011 or
ell9age in any buainess, occupation, professioll or employment Which to her
or him may seem advisable. Wife and lIusband shall 1I0t 100] est , harass,
disturb or mallgl1 each other or the reapective familiea of each other, nor
compel or attempt to compel the other to cohabit or dwell by any mesns or
in allY manner whatsoever with her or him. Neither par-ty will interfere
with the lise, ownership, enjoyment or disposition of any property 1I0W oWlled
by or hereafter acquired by the other.
4. 1~II'I'AIII,R 1II1J'1'!.lIIl1l1'IOO.
A. lIousehold 1IIId I'l!rsollal Property. Other than as set (ot.th
hereunder In this Agreement, the pilt.ties il(Jree that the personal property
of the parties has heen divided to thelt. mutual satisfaction. 'I'he parties
agree that they shall l'etaln all personal property In their respective
possessions and waive all dghts to persollal property III the possession of
the other party as of the date of the execution of this Agreement.
B. Motor Vehicles.
(1) 'I'he parties agree that lIusband shall retaill
possession of any and all lootor vehicles ill his possession, along with all
rights under allY Insurallce policy thereoll, alld the responsibility for
payment of allY outstalldlng indebtedness pertaining thereto and insurance
thereoll, and lIusballd shall indemnify and hold Wife and her property
harmless from allY liability, cost or expense, illcluding attorney's fees,
illcurred 111 conllectioll wlth the vehicle transferred to lIusband by the terms
of this subparagraph.
(2) 'I'he parties agree that Wife shall retain possession
of allY alld all motor vehlcles ln her possession, along with all rights
under allY insurance policy thereon, and the responsibllity for payment of
any outstanding indebtedneas pertaining thereto and illsurance thereon, and
W1fe shall indemll1fy and hold lIusband and his property harmless from any
liability, cost or expense, inclUding attorney's fees, incurred in
connection with the vehicle transferred to W1fe by the terms of this
subparagraph.
C. neal Estate.
(I) Both parties acknowledge that during the marriage
they hold, as tenallts by the entirety, the fee simple interest ln the
marital resldenee lo<:"te<l Ill. ]1 North ;>lIth Htreet, CalliI' 11111, Cllni>et'!lln<l
County, Pennsylvania.
lIuslx1n<l shall trarllllm' "II hia l'ilJht, title and interest
III the marit"l realdence to Wife as her ao1e propel.ty in exchange for a
total paY/l18nt to lIusband of ,.'ourteen 'l'housand I'ollr lIunrlred 'I'hl rty-Nine
75/100 ($14439,75) Dollars. 'I'hla fj'Jum mpreBenta an Initial dlstl"ibutlon
to Ilusband of I'itteen 'I'housand ($15,000.00) Dollara minus Five lIundred
Sixty 25/100 ($560.25) Dollara, which la one-halt (1/2) of all legal
expenaea Incurred by Wife pursuant to paragrapn 15 of this Agreement.
The total amount due to Ilusband shall be paid by Wife ill
the following Inatallmellts: Nine Thousalld I.'our Ilundred 'I'hirty Nille 75/100
($9,439.75) Dollars by cashier's check 011 or before the ellecutioll date of
this Agreemellt and the balance of Five 1'housalld ($5,000,00) Dollars on or
before June 1, 1996.
(2) On or before the execution date of this Agreement,
Husband shall execute and deliver a Deed to Wife trallsferring all his
right, tltle alld Interest in the marital residence to Wife as her sole
property.
(3) Wife shall promptly take all steps neceasary through
Chase Manhattan Bank in order to asaume Bole respellslbill ty for the
exlstlng mortgage 011 the marital residence and to have lIusballd'a lIame
removed therefrom. Wife will assume solely all ellcumbrances 011 the marital
residence and will hold harmleas, release and indenulify lIusband for allY
mortgage obligation, encunnl)rance or llell.
D, Pension/Stock Inveatment Plan. Ilusband ahall retain as
his sole and separate property his Pension alld Stock Investment Plan
through his employment at General MilIa.
l~. Other Ammt:a.
(I) \'ille shall l'f!tilin ,18 her UOlll llnlt 1ll?I'll'ilte prO(xH't y,
free from allY right, title, claim or interest of IllIshand, any and all bank
accoullts, credit union accounts, Insurance Ix,l teie" and 01 her IntalllJtb1e
personal propeL.ty held by W!Ce on the date of executl on hereof.
(2) lIusband shall retain as Ids sole and separate
property, free froo allY right, tille, claim 01' interest of Wife, any and
all bank accoullts, credit ullion accounts, insurance policies and other
illtanglble personal property held by lIusband on the date of execution
hereof.
F. Miscellaneous Property, Any and all property not
speciUcally addressed herein shall be hereafter owned by the party to whom
the property is titled: and if ulltitled, the party in possession. 'I'hls
Agreement shall constitute a sufficient bill of sale to evidence a transfer
of any and all rights in such property froo each to the other,
5. PROPmTY ro WIFE. 'I'he parties agree that Wife shall OWII,
possess, and enjoy, free froo allY claim of Husband, the property awarded to
her by the terms of this Agreell1ent. Husballd hereby quitclaims, assigns and
conveys to Wife sll such property, and waives and relinquishes allY alld all
rights thereto, together with any IlIsurance policies coverin\l the property,
and any escrow accoullts relating to that property. 'I'his ArJreeloont shall
constitute a suff1ciellt bill of sale to evidence the transfer of allY and
all rights in such property froo lIusband to Wife.
6. PROPmTY ro IRJSIIAND. 'I'he parties agree that Ih.sballd shall
own, possess, alld enjoy, free frOlll allY claim of Wife, the property awarded
to him by the terms of this Agreemellt. Wife hereby quitclaill'~, IIssigns and
cOllveys to lIusballd all such property, amj waives amt relinquishes any allrl
lO. INllIffiU'ICA'j'IOO ell" IRJSIlANIl. It any claim, action or
proceeding is hereaftet" Initiated seeking to hold Husband liable for the
debts ot" obligations assumed by I~ife undet" this Agreement, \'/If e wil I, at
het" sole expense, defend Husband against any such claim, action or
pmceeding, whethot" or not well-founded, and Indenulify him and his pmplKty
against any damages or loss resul ting therefnlln, including, but not Jimi ted
to, costs of cout"t and actual attomey's fees incurred by Husband in
connection thet"ewith.
11. WARRANi'Y AS 'IU fUIURR OOI.IGATIOOS. Wife and Husband each
t"ept"esent and wat"t"ant to the othet" that she ot" he will not at any time in
the futut"e incut" ot" contract any debt, chat"ge ot" liability fot" which the
othet", the other's legal t"ept"esentatives, pmpet"ty ot" estate may be
t"esponsible. Ft"OOl the date of execution of this Agt"eement, each pat"ty
shall use only those ct"edi t cat"ds and accounts fot" which that pat"ty is
individually liable and the pat"ties agree to coopet"ate in closing any
t"emaining accounts which pmvide fot" joint liabil ity. Each pat"ty hereby
agt"ees to indemnify, save and hold the other and his ot" her pt"opet"ty
harmless from any liability, loss, cost ot" expense whatsoevet" incurred in
the event of breach hereof.
12. TAXES. 1'he pat"ties agree that they will file sepat"ate future
tax returns for all tax obligations, and any tax obligation ahall be the
responsibility of the individual party. Wife and Husband warrant that they
have heretofore paid all taxes on prior returns including the calendar year
ending Decentler 31, 1994: that they do not owe any interest or penalties
thereon; and that no tax deficiency proceeding or audit is pending or
notice thet"eof received. Husband shall give Wife notice of any deficiency
assessment and Wife shall give Husband notice of any deficiency assessment
of which they Individually or colloctlvely hecome aware. 'l'he parties arJree
that should It ultimately ho detonnined that any deficiency and/ot" penalty
exists with respect to any jointly filed retut"lls, the parly res[XJnalble for
lhe en"oneous preparation anel/ot" non-disclosure of infonnation which has
resulted in the deficiency and/or penally, shall be solely t"esponslble fot"
the payment of the amount ultlmalely delennined to he due, togelher with
interest, as well as expenses lhat may be incurred to contest the
assessment. Should said sums become due as a t"esult of individually filed
retums, the party which filed said t"etum shall be solely responsible for
all sums due, and shall indemnify and hold harmless the olher party fot" any
payment thet"eon.
13. SUPPan', AI.DU<<, AI.JKWY PmoDfl'E I.ITE.
A. The parties agree and do hereby waive any t"ight or claim
they may have, both now and in the future, against the other for alimony,
alimony pendente lite and spousal support and maintenance.
14. K1lUAI. CXXFI']{ATICH. Each party shall on demand execute and
deliver to the othet" any deeds, bills of sale, assignments, consents to
change of beneficiary designations, tax returns, and other documents, and
shall do at" cause to be done every othet" act or thing that may be necessary
or desirable to effectuate the provisions and purposes of this Agreement.
If either party unreasonably fails on demand to comply with these
provisions, that party shall pay to the other party all attornsy's fees,
costs, and other expenses actually incurred as a result of such failLlre.
15. CIXfiSEI. FEES, cmrs AND El(l'mBES. Husband shall be
responsible fat" one-half (1/2) of all legal fees, costs and expenses
incut"red by Wife in connection with the parties sepat"ation and/or the
dissolution of lheir marriage, and the pt"eparatlon and execution of this
Agt"eement.
The an~)\1I11 owed by IIl1sbilnd 11Il<tel thill I'ilrilgraph /lhall be
deducted fnlln the payment dlle f tc~n l'Ii f" to IIl1sband on the ext!!'ut Ion date of
this /I<Jt"eement lindeI' IkllalJraph 4(1') IIf,rein.
IG. WAlVllnOI'~!f.lUTlINC!~J!IGlrI11: IInlel>s othen,lse specifically
pt"ovlded In Uds /lgreell"'nt. effective ulxlII the exer'utJon date, Wife and
Husband each waives all rlrjhtB of Inheritance in the estate of the other,
any ri<Jht to elect to lake agaillst the Will or any tlcust of the other or in
which the other has an Interest., and each of tile parties wal ves any
additional rights which said party has or may lIave by reason of their
marriage, except the ri<Jhts saved or created by the tenns of this
/lgreement. 'I'hla waiver shall be construed generally and shall include, but
not be limited to, a waiver of all tights provided under the lawa of
Pennsylvania, or any other jurisdiction, and shall Include all rights under
the Pennsylvania IJlvorce Code.
17. WAIVm 01' IImlll'l CI AllY 11I'Jj)(HA'I'ICfl. Unless othet"lllae
specifically set forth In thia /lgreement, each party hereto specifically
waives any and all beneficiary righta In and to any asset, benefit or like
program cat"ryin<J a beneficiary designation which bulon<Js to the other pat"ty
under the terme of thla Agreement, inclll<Un<J' but not limited to, pensions
and retirement plana of any Bart or nature, deferred con.>ensatlon plans,
life Insut"ance policies, annuities, etock arTOIJIll:s, bank accounts, final
pay checks or an)' olher post-death dlalr Ibut Ion scheme, and each party
expressly states that II. la her and his Intention to revoke by the terms of
this /I<Jreement. any henelldary tleal<jnlltlona nallllll<j the other which ate In
effect as of the dllt.e of execut ion of Ihlll ^I,lteelllent. If and in the event
the other [>/lrly continuea to be namell as bonotld/lt"Y /Inti no alternate
beneficiary Is otherwise des hJnrlted , the heneflclary shall be deemed to be
the estate of the de"e""ed I'llcty. Notwl t.IlBt<lllllt ng the [ol""'join'], howev"t",
in the event t1hlt eithel" Iklrty hereto specifically cJesi(JnateB the other
party as a beneficiary after the date of execution of this /lgreement, then
this waiver pt"ovision shall not bar that party fnllll qualifying as such
beneficiary.
10. REf.EllSE OF CI.I\IH.q.
A. Wife and lI11sband acknowled<je and agree that the property
dispositions pmvided for herein constitute an equitable distdbution of
their assets and liabilities pUt"suant to ~3502 of the Divorce Code, and
Wife and lIusband hereby waive any dght to division of their property
except as provided for in this /lgreement. I'urthennore, except as othet"llise
provided for in this Agreement, each of the parties hereby specifically
waives, releases, renounces and forever abandons any claim, right, title or
interest whatsoever she or he may have in property transferred to the other
party pursuant to this /lgreement or identified in this Agreement as
belonging to the other party, and each party agrees never to assert any
claim to said property ot" proceeds in the future. However, neither party
is released or discharged from any obligation under this Agreement or any
instrument or document executed pursuant to this /lgreement. Wife and
lIusband shall hereafter own and enjoy independently of any claim or right
of the other, all items of personal property, tangible or intangible,
acquired by her or him frOlll the date of exscution of this /lgreement with
full power in her or him to dispose of the same fully and effectively for
all purposes.
n. Each party hereby absolutely and unconditionally releases
and forever dischat"<Jes the other and the estate of the other fot" all
pUt"poses from sny and all rights and obligations which either party may
have or at any time het"eafter has for past, present or future support. or
maintenance, alimony pendente li te, alimony, equi table dl/ltr ibutl on,
counsel fees, costs, expenses, and any other right or obI igatlon, economic
or otherwise, whether at"ising out of the mad tal relationship or othet"llise,
including all rights ilnd benfits under the Pennsylvania Divorce Code of
1900, its supplements and amendnllmts, as well as under any other law of any
other jurisdiciton, except and only except all rights and obligations
arising under this /lgreement or for the breach of any of its provisions.
Neither party shall have any obligation to the other not expressly set
forth herein.
c. Except as set forth in this /lgt"eement, each party hereby
absolutely and unconditionally releases and forever dischar<jes the other
and her or his heirs, executors, administrators, assigns, property and
estate frOlll any and all rights, claims, demands or obligations arising out
of or by virtue of the marital relationship of the parties whether now
existing or hereafter arising. 1'he above rslease shall be effective
regardless of whether such claims arise out of any former or future acts,
contracts, engagements or liabilities of the other or by way of dower,
curtesy, widow's or widower's rights, family exemption or similar
allowance, or under the intestate laws or the ri<Jht to take against the
spouse's will, or the right to treat a lifetime conveyance by the other as
testamentary or all other rights of a surviving spouse to participate in a
deceased spouse's estate, whether arising under the laws of Pennsylvania,
any state, commonwealth or terri tory of the uni ted states, or any other
country.
D. Except for the obligations of the pat"ties contained in
this /lgreement and such rights as are expressly reserved herein, each party
<Jives to the other hy t.he execution o[ tlda /I<JreenlOnt an absolute and
unconditional release and discha.'<Je [rolll all cauaes of action, claims,
rJyhts or denll\nda whataoever in law or In equity, which either party ever
had ot" now has a<Ja I nat. t.he othet".
19. ..nf:s~tVAT)(.tl OF Itro:IUl..'i. (,ach 11Bt"ty will keep and preserve
for a period of four (4) years (rom the date of theiL" divorce decree all
financial records relating to the marital estate, and each party will allow
the other (1Brty acceaa to those records In the event of tax audits.
20. 1<<Xl1l'ICATIOO. No modification, rescission, or- amendment to
this Agreement shall be effective unless In wdtlng signed by each of the
parties hereto.
21. BEVmAIllI.I1'Y ~ If any (It"ovlsion of this /lgreement is held by
a court of competent jurisdiction to be void, invalid ot" unenforceable, the
remaining pt"ovislons hereof ahall nevertheless survive and continue in full
force and effect without being impait"ed or invalidated in any way.
22.
IlRPJlClI.
If ei ther party her-eta breaches any provision
hereof, the other party shall have the ri<Jht, at her at" his election, to
sue for damages for such breach, or seek such other remedies or relief as
may be available to her or him. 'I'he non-breaching party shall be entitled
to recover ft"om the breachin9 party all costs, expenses and le<Jal fees
actually Incurr-ed in the enforcement of the rights of the non-breaching
party.
n. WAIV~t Ol' IlRP.AC.'I. 1'he waivet" by one party of any breach of
this Agreement by tho other party will not be deemed a waiver of any other
breach 01 any provision of tlois /lqreement..
24.
A....f.ICAIII.K lAW.
_______...............-----o.--~
/Ill acts contemplated by this Agreement
",hall be conatrlled ami l!nforced under the laws of the Coomonwealth of
Pennsylvania in effect .18 01 the d"te of execution 01 this /I<Jreement.
25. IlI\1'~ 01" l'.xrorl'IOO. 'l'hc "date of execution" or "execution
date" 01 this /I{Jreemcnt shall be defined as the date upon which the parties
signed the A<Jreel1lOnt if they do so on the same date, or if not on tho same
date, then the date on which the Agreement was signed by the last party to
execute this /I<Jreel1K!nt. 'rhls /lgreement shall become effective and binding
upon both pat"tles on the execution date.
26. 1'.F1'fX:T 01" RJDH:II.IATICH, CDWlITA'I'ICH (]I nrVmCE. 1'hls
Agreement shall remain in full force and effect and shall not be abrogated
even if the parties effect a reconciliation, cohabit as husband and wife or
attempt to effect a reconciliation. This /lgreement also shall continue in
full force and effect in the event of the parties I di vorce. 1'here shall be
no modification or waiver of any of the tet"mB hereof unless the parties in
writing execute a statement declaring this Agreement or any term of this
Agreement to be null and void.
27. IIJ!ADINGS NOr PART OF A~. /lny headings preceding the
text of the several paragraphs and subparagraphs hereof are inserted solely
for convenience of reference and shall not constitute a part of this
Agreement nor shall they affect its meaning, construction or effect.
28. A~ BINDING CH PARTIES AND IIEIRS. 'rhis /lgreement shall
bind the parties hereto and their respective heirs, executors,
administrators, le<Jal representatives, assigns, and successors in any
interest of tho parties.
29. mrlRE A~. Each party acknowled<Jes that she or he has
cat"efully read this /lgreement, including all schedules attached hereto:
that she or he has discussed or has had ample opportunity to discllss its
provisions with an attorney of her or his own choice, and has executed it
iBm Vl ~
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LAUHENE I" 1I01,Mfo;S,
I'laintltt
IN 'I'IIE COUH'!' OF CXX>1MON I'LEI\S OF
CllMBEHL/lND L'OUN'I'Y, I'I':NNSYLV/lNIA
vs.
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CIVIL 'fEI~
IHCIIAllD C. IILUMJ:N5'I'EIN,
Defendant
IN DIVOHCE
OO'!'ICll 'IU flEl->>n> ANI) CIJIIM IUGlrI'Il
You have been sued in Cout"t. H 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 ot" 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 cuatody or visitation of your
children.
When the ground for the divot"ce is indignities or it"retrievable
breakdown of the marriage, you lIIay request marria<Je counseling. /I list of
marriage counaelot"s is available in the Office of the Prothonotary atl
lll'lIlmIJ\N() CXIIf1'Y CDJn'IDJ8E, CARLISLE, PmfiSYLVANJA 17013.
H' yO.! 00 Nor ~'ILE A CLAIM FOH /lLIMOOY, lJIVISION OF PHOPER1'Y, LAWYER'S
FEES OR EXPENSES IlEFOHE A UlVORCE OH ANNUI.MEN'f IS GR/lN1'ED, YOU MAY LOSE TilE
HIGII'I' 'IU CLAIM ANY O~' '1'IlEM.
yO.! SIlOULD 1'/lKE 1'lllS P/lPEH 'JD YOUH I,AI'/YEll /1'1' ONCE. IF YOU 00 N<J1' IIAVE
A LAWYEH OR CIINNCJI' M'FOfU> ONE, (',0 'IU OH 'I'ELEPIIONE 'I'IlE OFFICE SE'I' FORTIl
IlEL~ '1'0 FIND 01.1'1' WIlERE YOU CAN GE'!, LEGAL IlELP.
CCXJH'I' /lDMINISTH/I'I'OH, I'OUH'l'1I F'LooH
CUMlmRLAND COUN'I'Y OJUH1' IlOUSE
CAHLISLE, PI';NNSYLV/lNI/I 17013
TELEPIIONEl (717) 240-6200
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LAUI~ENE L. 1I0LMES,
plaintiff
IN 'I'IlE COURT OF CCI'lMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
RICHARD C. BLUMENSTEIN,
lJefendant
No. 95-2732
IN DIVORCE
CIVIL TERM
AFFIDAVIT OF smWICE OF <DlPLAINl'
I, Dawn S. Sunday, certify that I served a true and correct copy
of the Complaint in the above-captioned matter on the Defendant on
May 27, 1995
by Certified mail, Return Receipt Requested,
Restricted to the Addressee, at the following address: 22 N. Front Street,
WormlevsburQ, P/I 17043
The Return Receipt card
signed by the Defendant and Postal Receipt arl! attached hereto.
The Complaint contained a Notice of Availability of Counseling, a
Notice to Defend and Claim Rights pursuant to Pa. R.C.P. No. 1920.71 and a
Nptice.advising the Defendant that if he did not have a lawyer or could not
afford one, to go to, or telephone the Court Administrator, Cumberlsnd
county Courthouse, Carlisle, PA 17013, telephone number (717) 697-0371, for
the purpose of finding out where he could get legal help.
The statements made in this Affidavit are subject to the
penalties of 16 Pa. C.S. ~4904, relating to unsworn falsification to
authorities.
DATEr
1Jcveml:u'l 3u, /9'15-
{)L.~,.7Y'2~~4
Dawn S. Sunday {/
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