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Home My WebLink About95-03664 1 lJ.J . -7 l,. J w e ~ J ::r ..:J ~ *-~-*--~~*~~**~**-_.~>-~--*--~*~ ~, ,.-....-,.................._---...._~-.......-............-......---_.............._.. -- ---..........-.....-.-.- ~-......,---..........-...-.._-- ~-.. ...-~.~.-,_.__.,. .__.~-...,._,-,-.......-----.-.__._~..- -..,.......... -'-', ~', "'1 .. i~ ~I ,;, ~ ~ ,", ,', ~i IN THE COURT OF COMMON PLEAS ~ Mi ~I :1 Si v '.' ~~ ~ ,. ," ~ ~ ~ ,.' s ~ e " ~ ,;, ", i '.' 8 s ~ ,.' W f.' ,;, 0;; ,;, " w '.' OF CUMBERLAND ~ STATE OF ~~! PENNA. COUNTY ~ ", ~ ... KIMBERLY S. ETTER, Plaintiff i\: I ),95".3664,....,........ II) ~ '.' ~, VII':,lIS $ DENNIS B. ETTER, Defendant ~ ,', ~ .' ~ s DECREE IN DIVORCE ANDNOW.........t:~"'"*-J.../.I'."...., 19..7'(., it is ordered and decreed that.... .~i!llP.eJ;'ly. .1:1.. E.t.ter........................, plaintiff. and. . . . . . . .. . . . . . ~~.~n~~..~ ~ . ~.t.~~7. . . . . .. . . . . . . . . . . . . . ., . . " defendant. are divorced from the bonds of matrimony, 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 entered; .~~~~~~~~.Se.ttle~e~t.a.nd.s~~~ra~~o~.~~re~~~~~..~~.~~~~~Y.,...,.., . incorpa .not. merged. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . /JY~l.()l4/L ^lIe'~://1 / (at ' ~ ..' ~ ~ ~. - -- , ~.~;. .~:. .:.:. .:.:- -:+:. -:.:. Protl1ol1olnry J. ~ .' ~ ~ ~ S S S ~ .' .. to ~ ... ,', ~ ~ '.' ~ " w ',' ~ '.' S ~ I'. 1~ \~ W '.' ~ ~ ... S ~ )~ (w I.. I: IW '.' I~ i :, I~ i~ .... I :s ~ ~ ~ ~ ~ .:+;. , , -.. '-. " *~.~~.~*~**~ro~.~.~**,~.**ro~.~* .:; If, tfb al. ~~. /J';~ ;t- ?t# KJe4 ell?' ~f? 11'tf~ /I,",'~i" ,<<I ~ PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this ~fJJ -h. day of Ja.n..u~ ,19!@ between KIMBERLY S. ETTER of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Wife, A N D DENNIS B. ETTER of Loysville, Pennsylvania, hereinafter referred to as Husband. WITNESSETH: WHEREAS, in consequence of disputes and unhappy differences, ~he parties have been living separate and apart from each other; WHEREAS, the parties desire to confirm their separation and make arrangements therewith, including the division of their marital property and other rights and obligations growing out of their marriage; WHEREAS, the parties were married on September 5, 1981, - and a Divorce Complaint was filed by Wife on July 10, 1995. NOW THEREFORE, in consideration of the covenants and .AlDIS, GUIDO, SHUFF & MASLAND 26 W. HISh SUed Carlisle. PA promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound it is agreed as follows: (1) It shall 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 from time to time may choose or deem fit. (2) Except as herein otherwisc providcd, cach party hereby rcleases the other from any and all claims, or demands up to the date of cxecution hereof. (3) The parties are the owners of certain real estate with improvements thereon erected known as 506 N. College Street, Carlisle, Pennsylvania. Husband agrees within thirty (30) days to convey the real estate to Husband by quitclaim deed. Wife shall assume full responsibility for all household expenses, including, but not limited to the mortgage to Mellon Bank, as well as the home equity loan, liens of record, utility bills, insurance and real estate taxe~ in connection with said property. With regard to all such expenses, Wife agrees to hold Husband harmless and indemnify him from any loss thereon. In exchange for Husband's equity in the property, Wife will give to Husband $6,000.00 within thirty (30) days of the signing of this Agreement, and an additional payment of $1,500.00 within one year from the date of this Agreement. Wife will be using her best efforts to refinanc~ the property to remove Husband's name from the mortgage and home equity loan. SAlDIS, GUIDO, snUFF & MASLAND 26 W. Hl&h Street Catllsle, PA (4) Husband is now the owner of a piece of real estate located at Box 337A2, Rock Hollow Road, Loysville, Perry County, Pennsylvania. Wife waives any interest she may have in said real estate by reason of her marriage to Husband. (5) In the event that either party contracted or incurred SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carll.le. PA 'any debts since the date of separation on July I, 1995, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. Husband and Wife acknowledge and agree that they have no other outstanding joint debts and obligations except for a Mellon Mastercard bill, which will be paid by Wife. (6) Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportatibn. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. (7) The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree rhat each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto, This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto, SAlOIS, GUIDO, SHUFF & MASLAND 26 W. Iligh 5""", Carlisle, PA Each party hereby interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including but not limited to stocks, bonds, insurance, bank accounts, retirement accounts of Wife at Aqua Specialists, and Husband at Agway. (9) Except as otherwise provided herein, Husband shall not pay to Wife nor Wife to Husband any sum whatsoever as alimony, alimony pendente lite, or for his or her support or maintenance. (10) Each party is now represented by counsel of his and her own choice, and each shall pay his or her own attorney for all legal sJrvices rendered or to be rendered on his or her behalf . (11) Neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. - (12) Each of the parties shall from time to time, at the request of the othp.r, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provision of this Agreement, (13) The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is SAIDIS, GUIDO, SHUFF & MASLAND 26 W. lIIah SU<cI CalU.I<,PA familiar with, the wealth, real property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. (14) Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities I I , , 'c under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (15) It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfactiod of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims which have been raised or may be raised in an action for divorce. (16) Except as may be otherwise specificarly provided in this Agreement, Husband and Wife, for themselves, their heirs, - representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions, expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of curtesy and dower and all claims or rights in the nature of curtesy and dower; D. All widow or widower's rights; E, All rights, title and interest or claims in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision, F. All rights or claims to any accou~ting; - SAlOIS, GUIDO, SHUFF & MASLAND 26 W. Hilh Slre<l Carlisle, PA G, All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the --'''~-_. -'---'p~~nsYlvania Divorce Code, Act 26 of 1980; as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (17) This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the , other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) In the event that either party breaches any provision of this Agreement, and the other party retains eounsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay all attorney's ~ees, court costs and expenses incurred by the other party in enforcing the IAIDlS, GUIDO, snUFF & MASLAND 26 W. IIigh SIlecI Carlisle, PA Agreement. (20) This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature ,AlDIS, GUIDO, snUFF & MASLAND 26 W. HiSh 511<<. Carlisle. .fA whatsoever; other than those herein contained, (21) This Agreement shall bind the parties hereto, their respective heirs, executors and assigns, IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above, ~~J;~_ Witnes Jl,-.Q...~1 &tax, ..~. Klmbery S, tter . iL6~ ' Dennis B, Etter - ,~ ~~J. ., n .a (') !,;; tx> "I , -., ',1 "\1[:; r'T1 01; W .,J.! :t<::, 'ni!J -,.,- ...., . ,S CJi. .' .~(') ...~ .. r._t_; 3! "] l. u :.", -) ') .' ~..! - --"l... ) ....C) ~ i...)rn :J.-.. . ~~. .... c:- 'r. :,;,.; :U -< r~ -< ".._.'. ,.....~..h........_.. : KIMBERLY S. ETTER, I N TilE COURT Qt' COHHON "LEAS : Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : VS. . CIVIL DIVISION . DENNIS B. ETTER, NO. 95-3664 CIVIL : TERM 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 under S3301(c) 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Affidavit of service filed 7/13/95 3. Complete either paragraph (a) a. (b). (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by plaintiff 1/26/98 by defendant 1/16/98 (b),(l) Date of execution of the affidavit required by S3JOl(dl of the Divorce Code: : (2) Date of filing and service of the plaintiff's affidavit upon the r~spondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record. a copy of which is attached: (b) Date plaintiff's Waiver of Not;ice in S3301(c) Di'for.::e was fi led with the Prothonctary: _ _'_ Date defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: (P1aintiff)(Defendant) n \.0 0 c: CX) "7, ~--:: .." ., "'0(;; r-., '1:.." [~JtJ.! C'J "F;i "-""-. . "t16 ""'c .J (,2 r ~; f:;;b " ~-" "5-';(") ::I.: (,5:0 '~f-ri ""'~C) N '-, :;'''(: ~ S! c- 15 t-:> -< . KIMBERLY S, ETI'ER, Plaintiff IN THfJ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 9,j'. 3(.t;fCML TERM CML ACTION. LAW IN DIVORCE v. DENNIS D. ETTER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued In Court. If you wish to defend against the claims set forth in the foUowing pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without I you and a decree in divorce or annulment may be entered against you for any other claim or relief requested I In these papers by the Plaintiff. You may lose money or property or other rights Important to you, I , Including custody or visitstion of your children, I 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 at I the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013, I IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 Administrator Cumberland County Courthouse Fourth Floor Carlisle, Pennsylvania 17013 (717) 240.6200 KIMBERLY S, ETTER, PlalntlfT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.9:: Jt. t. Y CML TERM v. DENNIS B, ETTER, Defendant CML ACTION. LAW IN DIVORCE i I I I I 1. PlalntlfT Is Kimberly S. Etter, an adult IndividWll, currently residing at 506 North CoUege I Street, Carliale, Cumberland County, Pennsylvania. i 2, Defendant Is Dennis B. Etter, an adult individWll, formerly residing at 889 GraIuun'& Woods I I Road, Newville, Cumberland County, Pennsylvania. ! 3, PlalntlfT and Defendant are bollllflde resldenta of the Commonwealth of Pennsylvania and I i have been 80 for atle88t six montha immediately previoU8 to the riling of this complaint, i 4, PlalntlfT and Defendant were married on September 5, 1981 In Cumberland County,l I j I The Defendant Is not a member of the Armed Forces of the United Staten of America, or i I I COMPLAINT IN DIVORCE Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Ita Allies. 7. The PlalntlfT has been advised of the avaiJability of counseling and the right to request that the Court require the parties to participate in counseling, Knowing this, the PlalntlfT does not desire that the Court require the parties to participate In counseling. 8. PlalntlfT and Defendant are citizens of the United States of America. 9, The parties'11lIlITiage is irretrievably broken. " , Ii 10, Plaintiff desires a divorce based upon: The foct that Defendant has (In-ered such Indilll1ities to the person of the Plaintur, I the Innocent and Iqjured spouse, as to render her condition Intolerable and life burdensome, and this action I I Is not collusive; a. Or, In the alternative, I I I It Is belleved that Defendant will aner ninety (90) days from the date of the filing I , b. of this Complaint, consent to this divorce, WHEREFORE, Plaintiff requests your Honorable Court to enter a decree In divorce. 7!1t !?-r Date Respectfully Submitted, THE LAW OFFICES OF RON TURO ~;r/l/Jd4y Robert:lf. Mulderig, Esquirf! 32 South Bedford Street Carllale, PA 17013 (717) 245.9688 Attorney for Plaintiff VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DIVORCE COMPLAINT ARE TRUE AND CORREcr. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJEcr TO THE PENALTIES OF PA. C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DAT>> ~'1 'I 19{7~ 0\\'\'\"6. KImberly S, Etter ~-tC~ ~~ l ~~ 'i)"J~ ~~ ~ ~ '- r.: ~ ....... = ~~ - ~ ~ ~ \ ~ -: ~ :"\, ~~ ~ KIMBERLY S. ETTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95.3664 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE v, DENNIS B. ETTER, Defendant DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on July 10, 1995. 2. Defendant acknowledges receipt and accepts service of the Complaint on 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: / //'/f8 I ' ~l ~~ DENNIS B. ETTER n L.O 0 c:: CO -,"I ~ ." =.1 "U(J't ,." ~!. me co ;. .:; _.....- ...-~-~,- VI_:: 0 j:-J(-" ~ '~:B ~~ -. 9~ N ~ .. ~ l:'" ~ N KIMBERLY S. ETTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3664 civil Term v. DENNIS B. ETTER, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 10, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not clai them before a divorce is granted. 5. I understand that I will not be divorced until a divorc decree is entered by the Court and that a copy of the decree wil be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit ar true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsificat~on to authorit'es. DATED:-!'21,,-18" ER,Plaintiff SAIDIS, GUIDO, SHUFF & MASLAND 26 W. H1ah 51=. Carlisi.. PA (") u:> 0 u~ en .,., ...., --1 ,." h~ Ph,' ~ ~...-\< ") ":....-~ t/},~ : .-:) ,-' ;--~(~; .", ".J'j :;-;c. ',.,.1 ::': 1:-)...". r~ .' ';';ol J ::~f! ~ --rn Yt ~i c- :?q -. I" -<; , KIMBERLY S. ETTER IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION IN DIVORCE NO. 95-3664 V. DENNIS B. ETTER .. .. .. ,. .t .. ., .. .. .. .. .. .. .. .. .. .. .. ,. .. .. ANSWER TO COMPLAINT AND STATEMENT OF COUNTERCLAIM NOW COMES, Dennis B. Etter, defendant pro se, and pursuant to Pa. R. Civ. P. Rule 1920.15 submits this Answer to Complaint ond Statement of Counterclaim. D~fcndnnt represents the following to be true and correct: ANSWER TO COMPLAINT 1. Plaintiff's averments as set forth in the Complaint in Divorce as paragraphs one (1) thru nine (9) inclusive, incorporated herein by reference, are admitted. 2. Plaintiff's averment as set forth in the Complaint in Divorce as paragraph ten (a), incorporated herein by reference, is denied. 3. Plaintiff's averment as set forth in the Complaint in Divorce as paragraph ten (b), incorporated herein by reference, requires no responsive pleading. COUNTERCLAIM 1. Defendant herby states a claim to fifty percent (50%) of the net worth of all marital assets to which he is lawfully enti tIed. 2. Defendant hereby states a claim of rights concerning the shared custody and visitation of his children whom were born in wedlock. . 3. Defendant avers the marriage is irretrievably broken. 4. Defendant is aware of the availability of counseling, and does not desire the Court to require counseling for the parties of this action. 5. Defendant request this Honorable Court to appoint a Master to determine the fair distribution of all equitable and marital property. 6. Defendant request the Honorable Court to bifurcate the issues of distribution of marital property and the Divorce Decree. Defendant request this Honorable Court to bifurcate the issues of shared custody and the Divorce Decree. ;,' Defendant request this Honorable Court to enter a Divorce Decree under the no-fault provisions of the Divorce Code. WHEREFORE, Defendant request this Honorable Court to grant the Divorce, and other relief as set forth above concerning the distribution of property and custody/visitation. Dated: n~s.~ Dennis B. Etter, pro se P.O. Box 664 Elizabethville, Penna. 17023 &df5 Respectfully submitted, -_. ..- ~;t--7-: I -....... --.. .-.--' . VERIFICATION I, Dennis B. Etter, verify that the statements made in the foregoing Answer to Compleint and Statement of Counterclaim are true and correct to the best of my knowledge information, and beliefs. I further understand that any false statements made herein are made subject to the penalties of perjury, 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorites. This :;2 8 day of July, 1995 Respectfully submitted, J)d~ ,6. ffl - Dennis B. Etter, pro se P.O. Box 664 Elizabethville, Penna. 17023 .. PROOF OF SERVICE I, Dennis B. Etter, hereby certify that I am this ;tB day of July, 1995, serving a true and correct copy of the foregoing Answer to Complaint and Statement of Counterclaim to the persons indicated below, by placing same in the U.S. Mail, postage pre- paid. I understand that these statements, and service, are made subject to the penalties provided by 18 Pa. C.S.A. Section 4904 relative to unsworn falsification to authorities. Service to: Robert Mulberig, Esquire Attorney of record for Plaintiff 32 south Bedford Street Carlisle, Penna. 17013 and Kimberly Etter Plaintiff 506 North College Street Carlisle, Penna. 17013 Service By: D- == ~ t#- Dennis B. Etter, pro se P.O. Box 664 Elizabethville, Pa. 17023 '-- = ,- r-,~ ~:...::: e,.) VI .... "'"'" = ...;:,;. u:> .." KIMBERLY s. ETTER, plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 95-3664 CIVIL TERM I CIVIL ACTION - LAW I IN DIVORCE DENNIS B. ETTER, Defendant PRAECIPE TO ENTER APPEARANCB please enter my appearance on behalf of Dennis B. Etter in !1 " \ \ the above referenced matter. 1\ II , Respectfully submitted, 1\ \ Date: ?1I.J-hS- I r;J/i ? - Bri n J .... puhala, Sr., Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID' 52677 Tel. (717) 763-1800 I \' 1\ II I II I, iI I , i I Ii Ii " i; q , )tf 1\ '3 Z3 V~ 19S , '~rf\ct ",'nll(/i~"~ Ci' '. ;Hb C:<i\iH r"l;':' .l.Io'.....,'1\t,. " '~hh': !'..~H t ! PATRICK F. LAUER, JR. Attorney at Law 21011 MlIrkcI SUcci AZICC BlIildillll Camp Hili. PA 171111 (717) 763.IIIUII LAW OPPlCBS SAlOIS, GUIDO, SHUFF" MASLAND 26 W. HlOIl STRBBT t.n;..:....'JI PBNNA.l1013 PilaND (717) 243-622) CERTIFIDD COPY, ~~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3664 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE KIMBERLY S. ETTER, plaintiff DENNIS B. ETTER, Defendant PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of the Plaintiff, Kimberly S, Etter. ~;:":;;'j~/))/dlt - Rober~ J. MUlde~ PRAECIPE TO ENTER APPEARANCE Esquire TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Kimberly S. Etter, SAIDIS, GUIDO, SHUFF & MASLAND 26 W. Iligh 5'.... Carlisle. PA . ., '" ~~ _..._~-.,.. n t,O 0 c: ~ -n ;:~ 0 -l -nlii n 'r- ~~: -I ~i 7-l to:> ~~ r;c '''':0 ~ t. =::- )~ .::;(", -- ,~ ~....c 9 Q ::;:;~, -I "" " '" ~ ::.1 0 f-~-. -._~.-,-- ~. i_ " I i ~ Ii !I KIMBERLY s, ETTER, I! PlaintilT Ii II r II DENNIS B. ETTE~fendant I , I I Ii I' II II captioned case upon Dennis B. Etter, by certified mall, return receipt requested on July 10, 1995 addressed II to: I! I I I! and Dennis B. Etter did thereafter receive same 88 evidenced by the attached Post Office receipt card Ii I i dated July 12, 1995. I Ii II ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,INFORMATION AND BELIEF, I I' ,I 'I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES I. 'i I I OF 18 PA.C,S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. , II II II '1/;J If J-' I' Date II [! Ii II I' II I, II " : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . : NO, 95.3664 CML TERM : CML ACTION. LAW : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Ccmplaint In Divorce ftled In the above Dennis B, Etter 889 Graham's Woods Road Newville, PA 17241 I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE LAW OFFICES OF RON TURO ~!111& 32 South Bedford Street Carlisle, PA 17013 (717) 245.9688 Attorney for PlaintilT " g~;1 I::- ~ r'" .;: - ..r:.. .,'" ;r .,., 'Ilr ,. .+'::' ~". '..... (;) :""' r.~ ,-:..; 0" .f., - ~-I _.,~. ~,.. .., U) .t:' ... ~ :3: c.C <.n i. I' " ii I' Ii !i ! I' ,I II " I I, Ii II I, II I , I I I I I II I II I: 'I Ii Ii !I I ,I II I, Ii Ii Ii II Ii ii Ii " ii ii I, " Ii :i i Ii Ii :i " t' i Ii -, < ," \ Z Ob'! 1\73 7].1 ~ Receipt for . Certified Mail Nil InslIlonc'J COVt!lllllO PIll\ildl~d ~ 00 not Wit! lof Illtornilllonal M"I~ .....,..'01.... 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