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HomeMy WebLinkAbout95-04437 '~', .'.r 't.:~ < . ;;..,~ ~~:~ g J ., - . :3 . tIJ 7 & E k> -l) -- - 3 - " ~ P::: ~ f. I J I I I I I , ] I r- ;2 :::t- I V) CT ., ~<. ." -,j,:' o Z ?- ~ ~ ~ ~ ------..-- ,...:- ->>:- -:.:. .>>:. .:.:. .- . .:.; l!l 8 $ ~ W fo' ~ M " . DECREE IN DIVORCE AND NOW, . .. .:J: o,!.)) ?..;':. .. .. .. .. .. .. ., 19.9;6..... it is ordered and decreed that.,..,. ,~':':~ .~: ,~~~..... ,..,. .,........".., plaintiff, CANDIE c. WIlDERMAN and. .. . . ., , . .. . . .. ... . .. " . . , , . . .. , . . .. , . , . . .. . . , . . . . .. . ... .. 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; The Decree incorporates, but does not merge, the Marital Settlerrent .. ........ ..... ....... ........ ............ ................................, Agreement dated May 10, 1996. ................ .. .... ........... .... ...... ........... ...... ..... ......... Dy The Court: I} 11 I ":i1'" .,..' u/~k'~~Og,..1r... .' . Alle.t: ~"lbl. ['~. A~-~- J, , . . ..k;.Z ~ -7 ....~..","- ~.~. .' ~'" " 1 Prothonotary ~ ., -- - ......_--~ ~.,... -, ..- ....- ..... ~ _.~......, , ,. ~.',., , ' ' ~ .. ~.' >>:. .:.:. .:.:. .:.t-:. .:.:. .:.:. .:.:- .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .:+:. .:+:. .:+:. .:.:. .:.:. .:.:. .:.:. .:+:. .:+:. .:+:.' $ .', ~ ~ ~ .:. " 8 $ i ',' ~ ,~ i " ~ I'" ~ .', ~ (,'5'~ &;I. "" /J.l~~ 4 ~~ b.Sft >1~ ,A1~ ~ ~~. " toe 'f DAVID H. WILDERMAN Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 95-4437 v. CANDIE C. WILDERMAN Defendant : CIVIL ACTION - LAW : IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ItJ d- day of ~"'f" ' 1996, by and between CANDIE C. WILDERMAN, ("Wife"), of CarliSle, Pennsylvania, and DAVID H. WILDERMAN, ("HuSband"), of Camp Hill, Pennsylvania. WITNESSETH WHEREAS, the parties hereto are Husband and Wife, married on June 11, 1967, in Philadelphia, Pennsylvania. WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other inClUding, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, and the settling of any and all claims and possible claims by one against the other or against their respective estates, as well as any other matters related hereto. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Husband and wife, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of section 3301(c) of the Divorce Code of 1980, as amended February 12, 1988. 2. EFFECT OF DIVORCE DECREE The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement. This Agreement shall be filed with the Court of 2 , .. 'j Common Pleas of Cumberland County and incorporated into the final decree of divorce for enforcement purposes only. 3. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 4. DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement, unless otherwise specified herein. 5. CONSENT OF PARTIES Husband and wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and Wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. 6. FINANCIAL DISCLOSURE 'I'he parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other, except as set forth herein as an inducement to the execution of this Agreement. 3 7. MOTOR VEHICLES AND VEHICLE INSURANCE with respect to the motor vehicles owned by the parties or either of them, the parties hereby agree as follows: A. The 1988 Chevy S-lO shall become the sole and separate property of wife; B. The 1994 Ford Escort shall become the sole and separate property of the parties' child, Jennifer L. Wilderman. Wife shall be responsible for the insurance costs on said vehicle; C. The 1991 Ford Explorer separate property of Husband; D. The 1984 Ford Bronco II, separate property of the parties' Husband will be responsible for the vehicle. shall become the sole and shall become the sole and child, Jesse H. Wilderman. insurance costs on said E. Husband and Wife agree to be solely responsible for any and all insurance coverage for their respective vehiclesr and for the childrens' vehicles, as stated above; and hereby hold harmless and indemnify the other as to said insurance costs, in addition to any other costs or expenses related to said vehicles. 8. PERSONAL PROPERTY Except as set forth hereto, Husband and Wife agree that they have divided all of their personal property to their mutual satisfaction. The parties further agree that Wife shall have the opportunity to make a final walk through of the marital residence, and Husband shall have the opportunity to make a final 4 walk through of the Perry County property/residence, in order to finalize any and all property distribution, within fifteen (15) days of the execution of this Agreement. In the event an additional division of property is required, the parties hereto agree to do so on their own. Thereafter, neither party shall make a claim against the other as to said division of personal property. 9. REAL PROPERTY Husband and Wife agree that the former marital residence located at 202 North 23rd street, camp Hill, Pennsylvania, and the parties' property located in Perry County, are marital property. Husband and Wife further agree that Husband shall have sole title and possession of the former marital residence, located at 202 North 23rd street, Camp Hill, Pennsylvania, and Wife shall have sole title and possession of the parties' Perry County property. Husband and Wife further agree that they shall each be responsible for one-half (1/2) of their joint, second mortgage loan, the present balance of which is approximately $50,000.00. Husband and Wife shall pay their aforesaid share in a lump sum or otherwise continue to be responsible for one-half of the monthly payment: or in the event that one party pays off its one-half share in full, the other party shall be fully responsible for the monthly payment. Except as set forth hereto, each party shall be fully responsible for any and all taxes, insurancesr liens or mortgages 5 against their respective properties, and shall indemnify and hold harmless the other party, from any and all demands or claims which in any way relates to their respective properties. Husband and Wife further agree to execute any and all documents, upon request of the other, for purposes of transfer of title or any other related documents necessary for the execution of the parties' agreement hereto. Husband and Wife further agree, that at any time hereafter, if Husband would list the former marital residence, located at 202 North 23rd street, Camp Hill, Pennsyvlania for sale, or otherwise proposes to sell said property; or if Wife hereafter, would list the Perry County property for sale, or otherwise proposes to sell said property, that each party must advise the other of the listing, offer or proposal of sale of their respective property, and each party shall have the first option to purchase the other's property. 10. FEDERAL TAXES The parties hereto confirm that they will file a joint Federal tax return for tax year 1995, and hereby further agree to evenly divide any tax refund, or be responsible for any tax liability, on a 50-50 basis. The parties anticipate divorcing during 1996 and filing separately in 1996 and thereafter. 11. AFTER ACOUIRED PROPERTY As of August 18, 1993, each of the parties shall own and enjoy, independently of any claims or right of the otherr all items of personal property, tangible or intangible, and/or 6 , . real property, acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried. 12. WIFE'S DEBTS Wife represents and warrants to Husband that since the date of final separation, on or about August 18, 1993" she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and save harmless Husband from any and all claims or demands made against Husband by reason of debts or obligations incurred by Wife. 13. HUSBAND'S DEBTS Husband represents and warrants to Wife that since the date of final separation, on or about August 18, 1993, he has not contracted or incurred any debt or liability for which wife or her estate might be responsible and Husband further represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indemnify and save harmless Wife from any and all claims or demands against Wife by reason of debts or obligations incurred by Husband. 7 14. PENSION AND RETIREMENT BENEFITS Except as set forth hereto, the parties hereby specifically waive their respective rights, title and interest in any and all pension and retirement benefits of any kind of the other party. Said benefits shall become the sole and separate party of the said party in whose name the benefits are currently carriedr free and clear of all claims of the other party. 15. WAIVER OF RIGHTS The parties hereto fully understand their rights under and pursuant to the Divorce Coder Act of 1980, No. 1980-26, as Amended February 12, 1988r particularly the provisions for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital propertYr attorney fees and expenses. 16. PERSONAL RIGHTS Husband and wife may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and 8 engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabitate or dwell by any means or in any manner whatsoever with him or her. 17. MUTUAL RELEASE Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interestsr or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of each other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have; or any rights which either party may have or at any time hereafter have for past, present or future spousal support or maintenance, alimonYr alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and Obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind 9 , . or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 18. WAIVER OR MODIFICATION TO BE IN WRITING A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties and executed with the same formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 19. 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 future instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions of this Agreement. 20. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 21. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the 10 benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors and assigns in the interest of the parties. 22. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith and within thirty (30) days after demand or due date, execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreementr and as their respective counsel shall mutually agree, should be so executed in order to carry out fully and effectively the terms of this Agreement. 23. 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 subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 24. BREACH If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall 11 be responsible for payment of attorney fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 25. SEVERABILITY If any term, condition, clause or provisions 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 provisions herein, with the exception of the satisfaction of the conditions precedent, shall in now way avoid or alter the remaining obligations of the parties. 26. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of pennsylvania. 27. HEADINGS NOT PART OF AGREEMENT '1 I I 'I I I I ! Any headings preceding the text of the several paragraphs/provisions 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. DIVORCE The parties hereto agree that their marriage is irretrievably brokenr and both parties agree to enter into a I , I , I '. , , i I 12 . " .' , mutual consent divorce under Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended February 12, 1988. The parties further agree to sign the necessary documents, including the Affidavit of Consent and Waiver of Counseling. The Decree in Divorce entered hereto, shall incorporate, but not merge, this Marital Settlement Agreement. IN WITNESS WHEREOF, the parties hereto, have set their hands and seals the day and year first above written. Witness: t Mk.-(! .lUJJUtA~ CANDIE C. WILDERMAN ~- ~UJ 13 . . . " ,> STATE OF PA COUNTY OF 2>~fN/~ SS: . . On this".Jill.l day of 11114- '7 , 1996, before me, the subscriber, a Notary PUblic, in and for said Commonwealth and County, came the above-named person(s) /:>If/lit::) <# WfLD~I-UA#4.1A... , satisfactorily proven to me to be the person(s) whose name(s) is/are subscribed to the within instrument(s), and acknowledged the above instrument to be his/her/their act and deed, and desired the same might be recorded as such. WITNESS my hand and Notarial seal. ~,--Q..u '(f (j.A"lUt ' '^-^- OTARY PUBLIC MY COMMISSION EXPIRES: Notarial Seal Nal8lIe L Andr .1118 Nata/y PubIc Lower Paxton 'T\!P.. DalJll/lfn County My CommIeeIan EicpIree Dee. 20. Ill99 STATE OF PA . . SS: COUNTY OF . . On this the subscriber, County, came the d- If) day of '-1?7n.r- ' 1996, before me, Notary PUblic, in-dnd for said Commonwealth and above-named person(s) (lttnilu (1.1fJ,frlUMI9N , satisfactorily proven to me to be the name(s) is/are subscribed to the within acknowledged the above instrument to be and deed, and desired the same might be person(s) whose instrument, and hiS/her/their act recorded as such. WITNESS my hand and Notarial seal. i L~J fucvY'~ u t. NOTARY PUBLIC r MY COMMISSION EXPIRES: ~'7'~~~o NOlarial Seal Debra A. Evangellsli. NOlary Public Susquahanna Twp.. Dauphin Caunly My Cammlsslon E.plre. May 7. 2000 -,.- ,..1 ,- l"-; c; , u ,'~:- u - F: :':" ".' C.' , ~:j G" ,') [::. 1;.'" . ..' ,-:; \...~- , : ~i,p I ,-.. .' '- ~ !,..,) '" . <..1 \ .' DAVID H. WILDERMAN . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNA. . . . v. . NO. 95-4437 . CANDIE C. WILDERMAN . CIVIL ACTION - LAW . Defendant . IN DIVORCE . 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. Grounds for divorce: irretrievable breakdown under Section (x) 3301(c) () 3301(d) of the Divorce Code. 2. Auaust 23. AcceDtance Date and manner of 1995 bv certified mail: of Service. service of the Complaint: Qn see attached Affidavit of 3. (Complete Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: by Plaintiff on 5/10/96; and by Defendant on 5/10/96. (b) (1) Date of execution of the Plaintiff's required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiff's Affidavit Defendant: N/A Affidavit upon the . 4. Related claims pending: None/See attached Marital settlement Aareement. 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached if the decree is to be entered under section 330l(d)(i) of the Divorce Code: N/A 6. Date and manner of service of Notice of Intention to file Praecipe To Transmit Record, a copy of which is attached, if the decree is to be enterd under section 330l(c) of the Divorce Code ; OR, date of execution of Waiver of Notice of Intention 5/10/96; date of filing Waiver 5/29/96. .~/ James W. Abraham, Esq. Attorney for Plaintiff DAVID H. WILDERMAN . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNA. . v. . NO. y$"- tJ'43? (1;..;i .::r-e.v.-... . CANDIE C. WILDERMAN . CIVIL ACTION - LAW . Defendant . IN DIVORCE . COMPLAINT AND NOW, comes Plaintiff, David H. Wilderman, by and through his attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: COUNT I DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff, David H. Wilderman, is an adult individual who currently resides at 202 North 23rd st., camp Hill, Cumberland County, pennsylvania. 2. Defendant, Candie C. Wilderman, is an adult individual who currently resides at 432 Franklin Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 11, 1967 in Philadelphia, Pennsylvania 5. There have been no prior actions of divorce or for annulment between the parties hereto. 6. The marriage is irretrievably broken. 7. After ninety (90) days from the filing of the Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes Defendant may also file such an affidavit. 8. This action is not collusive as defined by section 3309 of the Divorce Code. 9. Plaintiff and Defendant are not members of the Armed Forces of the United states of America. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce to Plaintiff dissolving the marriage. Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 122 Locust st. Harrisburg, PA 17101 Attorney for Plaintiff (717-232-7825 DATE: .p-((r' 7!: VERIFICATION I, bNUj~,) iJ, Lv I'c..~fv( VvI ki'l the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities. DATE: .p'1 V- ~/:;- ~4/1tJ/d ---- CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, certified mail, return receipt, upon the following person, on the date indicated below: Candie C. Wilderman 432 Franklin st. Carlisle, PA 17013 05- DATE: J.lft-. , ~~~ JAMES W. ABRAHAMr ESQ. ~ +t ~ , ! ~ if: ~ "::r ~ ; CIa - !S - :>.. ""... ~ ~~ ,Jn~.. ~:r:o- . ~ a(.)~ d~Q;} .~J~~;:! 'U '-Ien ::;_/~Q;'~ -..1!:::ec ho:a;t1..1 ~. => CO 'C} I ~ II) l"" - ~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 95-4437 CIVIL ACTION - LAW IN DIVORCE DAVID H. WILDERMAN plaintiff CANDIE C. WILDERMAN Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 18, 1995. 2. The marriage of plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in the Affidavit are true and correct. 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 a thorities. DATE: ~, I~ Iff6 DAVID H. WILDERMAN Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 95-4437 CIVIL ACTION - LAW IN DIVORCE CANDIE C. WILDERMAN Defendant WAIVER OF NOTICE OF INTBNTION TO RBQUBST BNTRY OF A DIVORCE DBCREB UNDER SBCTION 3301(c) OF THE DIVORCE CODB 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 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. I VERIFY THAT THE STATEMENTS MADE IN THIS AFFIDAVIT ARE TRUB AND CORRECT. 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. DATE: (~1.k r!.~ CANDIB C. WILDERMAN '.. ('') L'" .' c:;: I.U~~ :~ (' . . L,: , :~ 1.1. "-._4 L,f ':., , ' ('l"'i r '.f! c:: -, (~ ! .>:: ..--", L': , 'w i '-",,- , , , '-C , (" :':'i\ ',.l DAVID H. WILDERMAN . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNA. . . . v. . NO. 95-4437 . . . CANDIE C. WILDERMAN . CIVIL ACTION - LAW . Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, attorney for Plaintiff hereto, hereby certify that Complaint in the above-captioned action, was served upon Defendant on August 23, 1995, by certified mail, as evidenced by the green return receipt card, from the U.S. Post Office, attached hereto and made part hereof: ,f'~;;~1~~z~~,~,~";'z,:~,'i+~':~e;;O:la~ti;~t~~{i~~~i~~~JI~ lil.~"iq:1,~~.'~,i;'t'"j~":J!,E, MZ:;,:::.' 1~~:.'~q~~4~~;;~id~~'i~ftl;1 h.. ,.,.,.~,ftot',.~'. .,,>.,"'.',",..",J.\.,'.',."~. '," ',,"..,,'..,......, L,'.' .,., , ..". ,." ....,' .,'..""'.,,..'. '....'.'..,.'.'.'.,..'....,....,..,"1.1 f;.~~.\.!;1!~~";,~i~....i~,Oo(Ii!i'..;;uPllco.......................i.ait.. 2./0R..irl~t~' D~i~~;:V;"0j 'I ,!I""~lliili,R_RllCOIpIwIII._.._""'_w.. and,""'.....', " ,,'.'.. ,", "'j,:":', :1 f~~';;;!""~~"._-"'-,.>'""--->.. _0,-..' -,.,''',,_.\> ~---- -.". - Consult o.tmI.t~rforf~.,-,- ,_,ct.,_ ~l rpi~e.~;;C:' (}~t:;;;: ",~ Aj~;m~r1:~."V~~~A>"}J;i ~~f:r"-~I?4~~I:\ E":g~~~~(:~~ t r~~~:' ~~I:~t-' . . 7. Dati orD.liv,~" , ,;:<".:~)~: F'" 'y, '. AUG.' ";'11 ~ W~~'~~~0!~;~~dre 'H8. ,=rl~~1:':~~dr... (Only II r~u"tIlIlI to;tSlgllllurtlAgentl. ", .,....,'.~ 1!1f~;i!::"'f:_bet " " ~OOMnrlC;RmJRN'f!ECEl~"5{ LJ.I!j'i;:.r{:~A;;~D,:~~t::.., . ..~ .~.. ~<:,<';'_;:J , ~fL DATE: 5/29/96 JAMES W. ABRAHAM, ESQ.