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HomeMy WebLinkAbout95-04905 . .. ' ... , .:.:. .;.:. -:.;. .:.:. .:.:. .;.:- -:.:. .:+:. .:<<. .:t;, ':.:. -:.:. ':.;, .:.;, ':.:. ':.;, .:.;, ':.;, .:.;, .;+:. ~. .:.;, .:.;. ,:+;. -:.;, .;t.' -:~.,. t.:.:. <t:. .:+:. ';4 ~ " ,-. - - ,- ."......, ~ ',i.', lh ?~ ~ IN THE COURT OF COMMON PLEAS ~l ~! .,( ~l :1 :! :1 . ; ~! - ! ~' M , . . >>: .'#'. ':e' :. . . . . . ~ ~ '," OF CUMBERLAND COUNTY "S' STATE OF ~~! PENNA, W) -"/ ,',/ ,.; : i ~' ~ ~ .,.r ~ Jesse Lee Farling, Jr. ~ ( I. 4905 CIVIL II) 95 ~ Plaintiff ~; . , ,",I ~! \". r,,;, Lisa Anne Farling, ~, i ~~ Defendant ~~ ~ DECREE IN DIVORCE 14~'L-\ ~: ~I )E . r AND NOW, 19 96. " it is ordered and ~i ,,/ decreed that Jelllle c'ee Far:ling, ,Jr:. plaintiff. defendant, ~! sl . ( "'/ ~i and ,Lisa Anne Farling. 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 enlered; Jj~ The attached Marital Settlement Agreement is incorporated. I I;, r.t. ,. (" ~ ') 1(1'-, ' \11,-,' ~. . t. -:; "'-'A.//. / ,I ~,' '....t...~<.'.. .. '-c.~'. ,.-.....,.,~~'.t.... / "- - _..'.., f ;- - -~ { :' ^4'~ / '1', "t 11 II I\l ,I." \ . . . . . .... . ,.. ~.. . . . . . '. . .:. . :~ ~ '.' J , . i~ '. '. ),.' , . ;. I'" I~ ~~ /... I~ i'" , ',', ." , - I~ i- , .~ :~ '~ '" , . ~ ~ '.. '" ':' * ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ . ~ . . . . .. ... MARITAL SETTLEMENT AGREEMENT ) Iv',l J..~, .J- THIS AGREEMENT, is made as of this _ day of ~, 1996, by and between Jesse Lee Farling, Jr. an adult individual residing at 119 E. Dauphin street, Enola, Cumberland County, Pennsylvania 17025 ("Husband"), and Lisa Anne Farling, an adult individual residing at 2 Hillcrest Road, Enola, Cumberland County, Pennsylvania 17025 ("Wife") (herein also referred to individually as a "Party" and cOllectively as "Parties"). Recitals: R.1 The Parties hereto, being Husband and Wife, were married on October 17, 1992, in Enola, Cumberland County, Pennsylvania. There were no children born of this marriage. R.2 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 and including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony, alimony pendente lite and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other 1 ~ . and against their respective estates. NOW THEREFORE, in consideration of the premises and 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. Recitals. The Recitals set forth above are incorporated herein by reference as it set forth in full. 2. Divorce. It is specifically understood and agreed by and between the Parties, and each Party does hereby warrant and represent to the other that, as defined in the pennsylvania Divorce Code, their marriage is irretrievably broken. Husband has filed an action in the Court of Cornmon Pleas, cumberland County, Pennsylvania at Docket No. 4905 Civil 1995 (the "Divorce Action"). The Parties agree to take all legal steps (including the timely and prompt submission of all documents and the taking of all actions) necessary to assure that a divorce pursuant to Section 3301 (c) of the Divorce Code is entered in the Divorce Action as soon as possible. This Agreement shall be incorporated by reference, but not merged into the proposed Divorce Decree presented to the Court. 3. personal Riqhts Husband and Wife shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit. Each party shall be free from 2 . any control, restraint interference or authority direct or indirect, by the other in all respects as fully as if they were unmarried. Each Party may, for his or her separate use or benefit, conduct, carry-on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Neither Party shall molest the other nor endeavor to compel the other to cohabit or dwell with him or her in any manner whatsoever. The foregoing provision shall not be taken to be an admission on the part of either Husband or wife of the lawfulness or unlawfulness of the causes leading to their living apart or of their divorce. 4. Marital PrODertv. (a) Personal PrODertv. Except is herein provided, Husband and Wife acknowledge that they have divided all personal property acquired during the marriage to their mutual satisfaction. Husband agrees to return to Wife, her grandfather's antique dresser. Wife agrees to return to Husband, the deacon's bench and the full set of caphelon pans. Husband hereby relinquishes all right, title and interest in Wife's personal property currently in her possession, and Wife hereby relinquishes all right, title and interest in Husband's personal property currently in his possession, except as provided herein. ) J (b) Real Procertv. During the marriage, Husband and Wife purchased their marital home at 12 East Beale Avenue, Enola, Cumberland County, Pennsylvania (the "Real Property"), On or about July 21, 1995, the Parties sold the Real Property and placed the net proceeds therefrom in escrow. A portion of said net proceeds has since been used to payoff the joint marital liabilities of the Parties in accordance with the accounting set forth on Exhibit A which is attached hereto and incorporated herein by reference as is set forth in full. Upon signing this Agreement, the Parties agree that the remaining balance of said escrow shall be paid as follows: a.) $500 to Husband in exchange for his release of any rights to Wife's diamond earrings; b.) $1,765.44 to Husband; and c.) $1,765.44 to Wife (payable to Wife's attorney as agent for Wife) (c) Pensions. Husband and Wife agree that each of them shall execute any documents necessary to release and waive forever any right, title or interest Husband or Wife may have in the other's retirement plan (which is defined to mean any Pension Plan or account, Profit Sharing Plan for account, IRA account, 40l(K) account, or any other Plan or account for retirement or deferred income). It is specifically agreed that each Party's rights under his or her respective retirement plans constitutes his or her separate property. ~ . 5. Liabilities. Husband and Wife represent that there are no joint debts or other debts incurred by either of them currently outstanding with respect to which the other Party may incur any liability now or in the future, except as agreed herein, Husband shall be solely responsible for all bills, obligations, and debts which he incurred individually since the date of separation, March 1, 1995. Wife shall be solely responsible for all bills, obligations and debts which she incurred individually since the date of separation, March 1, 1995. Each Party hereby expressly agrees to indemnify and hold harmless the other from any and all liability, direct or indirect, including attorneys' fees and costs, which may arise in connection with any obligation, joint or otherwise, for which the Party has agreed hereunder to bear sole responsibili ty, or which the Party has failed to disclose and provide for herein. 6. Automobiles. Husband and Wife agree that Wife shall retain sole ownership of the 1994 Mustang LX or its proceeds or replacement and Husband hereby waives any right, title or interest he may have in said automobile. Further, Husband and Wife agree that Husband shall retain sole ownership of the 1985 Chevy Truck or its proceeds or replacement and Wife hereby waives any right, title or interest she may have in said automobile. Each Party shall be solely responsible for any loans or liens against their respective vehicles and hereby agrees to indemnify and save harmless the other from any liability which is the such Party's obligation hereunder. 5 . 7. Further Debt. (a) Wife shall not contract or incur any debt or liability for which Husband or his property or estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands, including attorneys' fees and costs, made against him by reason of debts or obligations incurred by her. (b) Husband shall not contract or incur any debt or liability for which Wife or her property or estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands, including attorneys' fees and costs, made against her by reason of debts or obligations incurred by him. 8. Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, for all purposes whatsoever, of and from all rights title and interests, or claims in or against the property (including income and gainful property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against each other, the estate of such other of any part thereof, whether arising out of any former accounts, contracts, engagements or liabilities of such other, or by way of dower or curtesy or widower's or widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take 6 . against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all of the rights of a surviving spouse to participate in a decease spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, Commonwealth or Territory of the United states, or (c) any other Country, or any rights which either Party may have or at any time hereafter have for past or present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs, or expenses, whether arising as a result of the marital relation or otherwise, excepting therefrom, all rights and agreements and obligations of whatsoever nature arising or which may arise in this Agreement or for the breach of any provision hereof. 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 or nature, real, personal or mixed, which the other now owns or may hereafter acquire, excepting only all rights and agreements and obligations of whatsoever nature arising or which may arise in this Agreement or for the breach of any provision thereof. 9. Full Disclosure. Each Party asserts that she or he has fully disclosed all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them; of all debts and encumbrances incurred in any manner whatsoever by each of them; of all sources and amounts of income received or receivable by each Party; and of every other fact 7 relating in any way to the subject matter of this Agreement. These disclosures are part of the consideration made by each party for entering into this Agreement. 10. Costs to Enforce. In the event that either Party defaults in the performance of any duties or obligations required by the terms of this Agreement, and legal proceedings are commenced to enforce such duties or obligations, the Party found to be in default shall be liable for all expenses, including reasonable attorneys' fees, incurred as a result of such proceedings. 11. Advise of Counsel. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respecti ve counsel, stephen J. Dzuranin, Esquire, for Husband, and James D. Hughes, Esquire for Wife. The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations. The Parties acknowledge that they have the right to pursue full discovery including interrogatories, etc., but have chosen to rely upon the information which has been furnished to them and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advise and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or 8 agreements. 12. Leaal Fees. Each Party shall pay is or her own attorney fees and costs in connection in connection with this Agreement and the Divorce Action, subject however to the provisions of paragraph 10 hereof (entitled "Costs to Enforce"). 13. Life Insurance. The Parties hereby waive any rights which they may have in any cash value of any life insurance policies on the life of the other to which he or she may be entitled by virtue of having been named beneficiary thereon or by virtue of their marriage to the other. 14. Waiver or Modification To Be In Writina. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both Parties. 15. Mutual CooDeration. Each Party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other Party any and all further instruments and/or documents that the other Party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 16. Law of Pennsvlvania. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 17. Aareement Bindina on Heirs. This Agreement sha 11 be binding and shall inure to the benefit of the Parties hereto and their respective heirs, executors, administrators, successors and assigns. 9 18. Intearation. 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. 19. Other Documentation. Husband and Wife covenant and agree that they will forthwith (and within at least seven (7) days after receipt of written demand therefore) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and/or as their respective counsel shall advise should be so executed in order to carry out fully and effectively the terms of this Agreement. 20. 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 the Agreement shall in on way affect the right of such Party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 21. Severabilitv. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this 10 Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any Party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the Parties. 22. Headinas Not Part Of Aareement. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 23. CounterDarts. This Agreement may be executed in any number of counterparts and by different Parties hereto on separate counterparts, each of which, when so executed and delivered, shall be an original, but all such counterparts shall, together, constitute one and the same instrument IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first above written: HUSBAND: ~ ~&~\ J sse Lee Farling, Jr. WIFE: ~lJn lsa Anne ~.\L ~cW). '~ Fa lng 11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. ...- On this, the df"C\. day Of~~~\:::;- ,1996, before me, a Notary Public for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared Jesse Lee Farling, Jr., known to me to be the person whose name is subscribed to the within Marital Settlement Agreement and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NolanaI5611 Usa R fl<Me. N<~ "'He HarnsbJrg. Oat-4-'hn Cl.'l.r:~ MyCann""""'~JI.~',i 1-'17 ~~~ k~ Notary Public - COMMONWEALTH OF PENNSYLVANIA : COUNTY OF DAUPHIN . SS. On this, the !P:.. day of ..J,(J,J , 1996, be~ore me, a Notary Public for the Commonwealth ~~SYlVania, the undersigned officer, personally appeared JeMie Lisa Anne Farling, known to me to be the person whose name is subscribed to the within Marital Settlement Agreement and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my and official seal. ""lt3':.' ~"..i; ~ L. :_'Iawt;dll~h_ ~ml..iry P~llhL ea,.. Bora. CumbCrtd.....j Counly ~) /"',nmmtSSion Ftplr8SAuy 14,199'j 1.ltI<ii.. Po.................. .....<1_ 12 . DEPOSITS: 10/12/95 11/20/95 PAYMENTS: 11/17/95 11/17/95 11/17/95 11/17/95 11/17/95 12/29/95 12/29/95 BXBIBIT ]I. FARLING V. FARLING BSCROW ACCOUNT SALB OF MARITAL PROPBRTY Bank of America, FSB (#861060) Louis Adler (#1512) TOTAL Holy Spirit Hospital Capital One Harrisburg Belco Federal Credit Union Sears Payment Center PNC Bank PNC Bank, National Association Gordons Jewelers TOTAL Balance Remaining 13 697.14 8.681. 02 $9,378.16 268.34 898.43 880.55 698.43 501. 93 1,366.85 732.75 ($5.347.281 $4.030.88 ~ ~ \J" '- C - , ~, Cf, ~ ~~ , '~ :1: :.::..- -.: :.j ~~. cr> .0 Lt.' I 0:'" !- 'cj ~" -: le,- L'~ '- . u ". -...l JESSE LEE FARLING, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 4905 CIVIL 1995 LISA ANN FARLING Defendant CIVIL ACTION - LAW . . IN DIVORCE PRABCIPB TO TRANSMIT RBCORD 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 Section (xl 3301 (c1 ( 1 3301 (d1 Cl1 of the Divorce Code. (Check the appropriate section). 2. Date and manner of service of the complaint: SeDtember 23. 1995 bv certified mail. return receiDt reauested. Affidavit of Service filed on~ 8. 1996. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff August 2, 1996; by defendant August J8L, 1996. 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file praecipe to transmit rec~rd, a copy of which is attached Waiver of Notice or Int~.nti~n tl,l.ed I~- , / \/,) ~ . At~~~~~ fO~: (~) ;ia{~~i~~ ( ) Defendant DAlEO: A....I 2, 1996 ~ ~ ,... - It': '- ~ ~ a; :i< r ) .~" f ::!: )~ <: ,-::j C 0'\ '>= ~. 'it/) to I :J2 ftv C.". l~ r: - ~ ~ U) .J 0-. :J JESSE LEE FARLING, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. NO. '-/(ll'5 CIVIL 1995 LISA ANNE FARLING, CIVIL ACTION - LAW DEFENDANT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If 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 or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim of relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 the Cumberland County courthouse, High and Hanover Streets, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse High and Hanover Streets Fourth Floor Carlisle, PA 17013 (717) 240-6200 JESSE LEE FARLING, JR. , . IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA . PLAINTIFF . . : V. NO. CIVIL 1995 LISA ANNE FARLING, CIVIL ACTION - LAW DEFENDANT IN DIVORCE NOTICB or AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JESSE LEE FARLING, JR., PLAINTIFF : V. NO. CIVIL 1995 LISA ANNE FARLING, CIVIL ACTION - LAW DEFENDANT IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Jesse Lee Farling, Jr., by and through his attorneys, Wix, Wenger & Weidner, and files the within complaint against the Defendant, averring as follows: Count I - Under Sections 3301Ccl and 3301Cdl of the Divorce Code 1. Plaintiff is Jesse Lee Farling, Jr., an adult individual who currently resides at 119 East Dauphin Street, Enola, CUmberland County, Pennsylvania 17025. Plaintiff has lived at said address since April 15, 1995, and has resided in CUmberland County for over ten years. 2. Defendant is Lisa Anne Farling, an adult individual who currently resides at 2 Hillcrest Road, Enola, Cumberland County, Pennsylvania 17025. Defendant has lived at said address since on or about April 15, 1995, and has resided in Cumberland county for over ten years. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 17, 1992, in Enola, Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the united states of America and are not members of the Armed Forces. 6. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 7. This action is not collusive. 8. Plaintiff has been advised of the availability of counseling and understands that he may have the right to request that the Court require the parties to participate in counseling. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce pursuant to sections 3301(c) and/or 3301(d) of the Pennsylvania Divorce Code of 1980, as amended (the "Divorce Code"). Count II - Eauitable Distribution 10. Paragraphs 1 through 9 hereof are incorporated herein by reference. 11. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under sections 3501 through 3508, inclusive, of the Divorce Code. 12. Oefendant may have owned, prior to the marriage, property, real and personal, which property has increased in value during the marriage and/or which has been exchanged for 2 -f' i ~ j ? -l v j d ~ " . u ,.J -r X J Ii. :;j 11 " - .. " r, 0 j } ~ '.I I] 'Ii ....- lJ1 J ..J L"' cr- . ... .A .:: J ~~ -:> :s=: I.f1 .J' \.1 ,~ f:._ ':: (p - 0- r- 0 , r- eo 4\ r- g - :::r " ,..... fH. III ;t ~ ) :fI - .I 4l - J <i.. .... r..) ,., -, ' v' ~ . 4t JESSE LEE FARLING, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 4905 CIVIL 1995 LISA ANN FARLING Defendant CIVIL ACTION - LAW WIX, WENG~R & WEIDNER Attorney4f for Plaintiff I By: /"0/1 step en J. D 1. D'/ #52653 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 IN DIVORCE AFFIDAVIT OF SBRVICB Stephen J. Dzuranin, Esquire, being duly sworn according to law, deposes and says that he is an attorney at law duly authorized to practice law in the County of Cumberland, Commonwealth of Pennsylvania; that on September 22, 1995, he sent a true and correct copy of the Complaint in Divorce, properly endorsed, to Defendant, Lisa Ann Farling, by Certified Mail, No. P-654-984-069, postage prepaid, return receipt requested, to Two Hillcrest Road, Enola, PA 17025, the Defendant's last known address; and that the Defendant received the Complaint in Divorce on September 23, 1995, pursuant to the return receipt card, which is attached hereto and marked Exhibit A. Sworn to and ~bscribed before me this~~, day of ,",~~~~ne, 1996. 4~~Q. k,-~ Notary Public My Commission (SEAL) Expires: r' I . ,!.~ If. ""', ~ ! ., '\ :'\ A.' r ~ ~ '-, .' '.A . ,t ',-" :: r....:; . ..1..1l:\"~ -. ~ '. ~.., \ ",-' .f .~ :,,,'." "1."--": ., .' \...... ~ L.. ~~ Ms. Lisa Anne Farling 'l\Io Hillcrest Road Enola, PA 17025 ~ 4. A","", NuIliber P 6114 984 069 ~o , "........ . 0 '- CIIlllIod (J coo o fa...... Mil 0 Afw.,........... of 1M IllL 01_ ..., ~TI DlUvlam, 8, AddreNii'. AcIdreii (OI(lJ' ....... "/Ie /IWiJ lie , DeIiVWY .PI....... 3811. ...... 1118I . u.I.U.O. 1181-212-"8 :r."-.......,....'....~-'rf' i.;;;"i'~ir.4i<ba~u.:l'l;.;_:,..N{'.;..;"..:I'i:. '\','_":_~""'-_'_'...y., '","_,"-_,," DOManc llITUlIN IlIC1JJrr """r"';'";,~,,,,~,J..~;"~' E X Hl/~IT A - " ..'.. ~, ~ 0\ >- ll: - -r. t c5 ') f' - ~f :r.: 2- ... 1 I.; co ~ . ..-.. L I il!I!' ~: f.:.- -, .:./ <oq, "'" l3 \0 ~ en () ..~~ .,.-,. ~ .' JESSE LEE FARLING, JR. plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 4905 CIVIL 1995 LISA ANN FARLING Defendant CIVIL ACTION - LAW . . : IN DIVORCE AFFIDAVIT OF CONSBNT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 14, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce. 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.A. S4904, relating to unsworn falsification to authorities. laintiff t DATE: ! / ~>\ 2 _, 1996 ~ ~ .::r - Lr. I.- -'1: , t iiJ 'j ,~ L.~' :<: ')~ -=:: .,~ " c .. >- f-. C' <.'9 G,. I .-.~~ a!~' - ~;;. 5::: :,.jJ -~ Ci ' u.. ~ U) :s C1' u . .. - JESSE LEE FARLING, JR. Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4905 CIVIL 1995 v. LISA ANN FARLING, Defendant : CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE or INTBNTION TO RBOUBST BNTRY OF A DIVORCB DBCRBB UNDER SBCTION 3301(C) OF TUB DIVORCB 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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsifications to authorities. n . tl k~' .~~,St~ LEE FARLING, JR. ntlff Dated: 6;;.1 .1- , 1996 ~ . ~ ~ 1.0 :- It': , is co " r ;~ '7- C :c .)<~ -, ..:: "~ (:: r f. 0'\ ,'cn 6: I )z a:l<: c:. :iifi -, "tlu. ~ ;:x ~ 1.0 '.:5 CT\ u . " , ._ ta, JESSE LEE FARLING, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4905 CIVIL 1995 Divorce. v. LISA ANN FARLING Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSBNT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on September 14, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in 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.A. 54904, relating to unsworn falsification to authorities. DATE: August ~ ,1996 ~ ~ In :- IS': \ .~ r .. ,,~ co ~) ..--r "; I ~_., , -. :c -)..~ ...: "... 1". ;2 [ . 0' ..~':) c I IZ ~ ~ ,i~ F= - ,g olZ b .0 '5 -::i' 0 .~ . " ~ ., .... .'" " JESSE LEE FARLING, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4905 CIVIL 1995 v. LISA ANN FARLING, Defendant CIVIL ACTION - LAW IN DIVORCE ~IVER OF NOTICB OF INTBHTION TO RBOUBST BII'l'Ry OF A DIVORCIII DBCRBB UlmER SIIICTIOIf 3301(C) OF TRill DIVORCB 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 div~ce 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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsifications to authorities. rJ,1/~Yl LISA ANN kttt ~.~ F NG, Defenda Dated: AugUst~, 1996 ~ ~ .0 -= It': ' . .. ,- :>~ r o::l ,) <" x: ):;0 c. i!: ...: ':'~ C 0'\ " L '17 u- , ,;111 U" C; F!: ~ ,'",0- e 2 ~ ..0 ;:) (1'\ U .. " .