HomeMy WebLinkAbout95-06320
,0:<<0 ... ... ...'...,'.. ........ .".t\ ........ "*"... ... ... ... ... ....1(.__-;:...;.-:... ... __.~
e ' - .- =. $
e 8
: IN THE COURT OF COMMON PLEAS :
$ OF CUMBERLAND COUNTY e
~ . 8
8 ~ ~
$ STATE OF ~_ PENNA. ~
e "7\-" " .
8 8
e ..BARBARA...D....BATEMAN..,..,.......,................... II Nil. ..,6,3,20.......... ......c,....... 1995 8
~..,..,....,.....................,................................, il ~
e Vcrsus I' 8
. ..J,.,llRUC.e..BATEMAN. SR........"............."..... II 8
8 , " .... '........, "" , ...., Ii e
8 ~
!~
8
DECREE IN 8
o '2 ~ ~ R ~ 41 If: : -,0 p jJ. · :
. . , . . . . . . . . . . . . .. 19......, it is ordered and 8
e
8
oj
'='
8
~
^
8
e
~
.
8
~
8
~
,.'
$
8
8
~
"
~
,.'
AND NOW
decreed that . ..llp.t;Qi)~.a.. . llat;em.a.n........................, plaintiff.
and..... ..01,'.. !3F.4q~. ~"t;~{lI.a.rll. :>.t:... . ............,........... 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;
, . .. . . .. . . .. . . . , .. .. . . ,. . . . . . . .. . nONE. ... .... .. .... .. .. . ... . . . ... .. .. .. ..,
8
~
~
~
~--
?...:. <<- ->>:. -:to:. .:+:. ."
." H
~.
*,Olho~OlnrY ,
, ,
______. ...____._.. ...___.-.-..___~-.'-._.__.........-'_ ,'"' ........ ... _,'-.. ________~~,...._~ '.......__~,~, ...,_~ _, I ~
~. . . .:+:. .:.:. .:.:- .:+:. .:.:. .:+:- .:.;. .:<<. .:+:. .:.:. .:.:. .:+:. .:+:. -:.:. .:+:. .:.:. .:+:. .:+:. .:.:. .:.:. .:+:' .:+:.
~
~
~
.'
w
~.'
~
~,
$
,',
~
s
s
~
'.'
~
'.'
*
v
'.'
i~
I~
(',-
I.
,f~
I~
ac;2J'?~ tV-err ~.,j 4~
.;l'Cl3.~ )1~ ~~~
.'~ ..
,..
. .
IN TIlE COURT or COMMON PLEAS or
CllMIlERLAND COIlNT'l, PENNSYLVANIA
NO. 6320
CIVIL
1995
BARBARA D. B'TEMAN
va.
J. SRUCE BATEMAN, SR,
.
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit ths record, together with the following info~tion, to the court
for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 33)1(c))
33rr(~~-f~) of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint: By U,S, Main, on
November 2. 1995: Acknowledamenc of service si~ned 11/8/95
3. (Complete either paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by Section
3:ill(c) of the Divcirce Code: by the plaintiff February 9, \996
.
.
by defendant
February 9, 1996
(b}~~~_Ba~~f-~ion~~he~1~nt~~'~-8E!~!t-~!r~~
Sectttm3361-~- of-etre- >>ivarce- eade:
(-2~ - Blt~ 'flf-s~'Ce-o!- -the-pla'.I:ntH! tg. -eUidaYi-t-IlpGn- -tke-del-eadaa-tr:
4. Related claims pending: Nnne
5, Indicate date and manner of service of the notice of intention to file
praecipe to transmit record, and attach a copy of said notice under section,3301
(d)(I)(i) of the Divorce Code.
N/A _ N~tica of Tn~2n~ under Lnc~l Qtl1PR
waivar attached.
Gr1~~,.,~~
Attorney for (Plaintiff)
fBef-et'ulltftt;-)
f."t.:'
~ ..:r (;
I~ .:r ,"
M el~
0 ::: U$:
ff c... r':l?;:l
0 " ...
" <=> ~5~")
-~ N _Z
'':~
CO !~ .
F LU
u.. ..,,~
U. \0 ::>
0 en U
. .
';H:t:'.l,~'>"
"
"
BARBARA 0, BATEMAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
v.
J. BRUCE BATEMAN, SR.
Defendant
NO. 95.6320 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following Inforrnatlon, to the
Court for entry of a divorce decree:
1. Ground for divorce: Irretrievable breakdown under Section 3301 (c)
of the Divorce Code.
2. Date and manner of service of the Complaint: Complaint served
on J. Bruce Bateman, Sr. by Certified Mall, with return receipt signed by Barbara
Baternan on November 8, 1996. Acknowledgrnent of Service signed by J. Bruce
Baternan on November 8, 1996.
3. Date of execution of the Affidavit of Consent required by Section
3301 (c) of the Divorce Code:
Plaintiff on February 9. 1996
Defendant on February 9. 1996
4. The Property Settlement Agreement executed by the parties will be
flied with the Court Is to be incorporated but not merged In the Divorce Decree to be
entered herein.
5. Related claims pendIng: None
Respectfully submitted,
@-t ~ Q.___
Peter J. Russo
PA Attorney I.D. 72897
845 Sir Thomas Court
Suite #9
Harrisburg, PA 17109
(717) 541-4400
Date: February Il. . 1996
~ ..:7 ~
..:7
.. =Set'
r M O~
g - (J
c: '':''l~
2: <::> ;';S!l
~ N ,.)..:..
cE~ ~ co mai
I= w, !nU. t"
LA.. ...:-:.
~ .0 3
en
..;,>'
'~.w.;~~....~:~. fllli"f'\ '
BARBARA D. BATEMAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 'If. ~P&IVIL TERM
IN DIVORCE
v.
.
.
JOHN B. BATEMAN
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 following pages, you muJst take prompt action. You are warned
that If you fall to do so, the case may be entered against YOll 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 custody or visitation of your children.
When the ground for the divorce is indignities or Irretrievable breakdown
of the marriage, you may request rnarriage counseling. A list of rnarriage counselors is
available In the Office of the Prothonotary, Cumberland County Court House, Carlisle,
Pennsylvala.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A 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.
Cumberland County Court Administrator
Third Floor
Cumberland County Court House
Carlisle, Pa. 17013
(717) 240.6200
BARBARA D. BATEMAN
PlalnUff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. CIVIL TERM
IN DIVORCE
v.
JOHN B. BATEMAN
Defendant
COMPLAINT IN DIVORCE
UNDER SECTION 3301(cl AND 3301 (d) OF THE DIVORCE CODE
AND NOW comes the above-named Plaintiff by and through her attorney
Peter J. Russo, and seeks to obtain a Decree In Divorce from the above-named
Defendant, upon the grounds hereinafter more fully set forth:
1. Plaintiff Is an adult Individual residing at 508 Ellen Road, Camp Hili,
Cumberland County, Pennsylvania and Is a citizen of the United States.
2. Defendant Is an adult Individual residing at 508 Ellen Road, Camp
Hili, Cumberland County, Pennsylvania and is a citizen of the United States.
3. Plaintiff has been a bona fide resident of the Commonwealth of
Pennsylvania for twenty-six years and has resided continuously therein for at least six
months prior to filing of this Complaint.
4. Defendant has been a resident of the Commonwealth of
Pennsylvania for twenty-six years and has resided continuously therein for at least six
months prior to filing of this Complaint.
5. Plaintiff and Defendant were married on April 16, 1966 In Baltimore,
Maryland.
6. There are no children of the parties under the age of eighteen (18).
COUNT I . DIVORCE
7. Plaintiff hereby Incorporates by reference averments 1 through 6 of
this Complaint as If each averment were set forth fully hereunder.
8. There has been no prior action for divorce by either party against the
other.
9. Neither Plaintiff nor Defendant is In the Armed Forces of the United
States or any of Its allies.
10. Plaintiff avers that the marriage between the parties is Irretrievably
broken.
2
11. Plaintiff has been advised that counseling Is available and that
Plaintiff may have the right to request that the court require the parties to participate In
counseling, but does not request the same.
12. Plaintiff and Defendant have reached a property settlement
agreement addressing support Issues, which will be filed herein at the appropriate time.
WHEREFORE, Plaintiff, Barbara D. Bateman, prays that a decree be
entered In favor of the Plaintiff and against Defendant as follows:
A. That a decree In divorce be entered dissolving the marriage between
the two parties.
Respectfully submitted,
@cJ.,J~;2, ---
Peter J. Russo, Esquire
Attorney for Plaintiff
PA Supreme Court ID # 72897
845 Sir Thomas Court
Suite #9
Harrisburg, PA 17109
(717) 541-4400
3
BARBARA D. BATEMAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. CIVIL TERM
IN DIVORCE
v.
JOHN B. BATEMAN
Defendant
VERIFICATION OF COMPLAINT BY PLAINTIFF
I, Barbara D. Bateman, verify that the statements made In this Complaint
are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities.
Jt1~ -O.)~
Barbara D. Bateman
DATED: /1-.1.- 'l.r
^ ,- \ ,-,'""" ~ ,,'-
.'\. ~
..."
en
-
:oc
a-
N
'"
-:r
.... \. \'
"'...
~%..
"'Jo~_ (\
iUZDZ l"
;;;:OU,: ,n ~
&..::~.... ..,
9~oC~ ~
QtI:..JZ
UJc...a::Z
.::!I"'~h' \)
....:r_G. "
1--
"
"'u
'"
'"
=-
~
=
'"
~
~
~~
~~
"""~~-
"':"~<->"""''''~'-'''' "
:" ....~
BARBARA D. BATEMAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
v.
J. BRUCE BATEMAN, SR.
Defendant
NO. 95.6320 CIVIL TERM
IN DIVORCE
'P~"",''(3< .\.. (.\"".,,1
AMENDED CAPTION TO DIVORCE ACTION
NOW COMES Attorney for the Plaintiff and requests that the Divorce pleadings
be deemed amended to correctly spell J. Bruce Bateman, Sr.'s name as shown herein.
Respectfully submitted,
~Q--
Peter Russo, Esquire
PA ID # 72897
845 Sir Thomas Court
Suite 9
Harrisburg, PA 17109
(717) 541-4400
Date: November 9. 1995
I
.
BARBARA D. BATEMAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. CIVIL TERM
IN DIVORCE
v.
JOHN B. BATEMAN
Defendant
ACKNOWLEDGEMENT OF SERVICE OF COMPLAINT IN DIVORCE
UNDER SECTION 3301 (el AND 3301 (d) OF THE DIVORCE CODE
NOW COMES Defendant John B. Batemen and does hereby acknowledge that
on the date Indicated below he did receive a verified copy of a Complaint In Divorce flied
against him In the above captioned case.
!fik1l3. ~~...h-.
ohn B. Bateman '
DATED: ''If} 195
I
,,.._,-..j\;;'F"":'''''~
"',',,'..'-'.-~I. Q
II -:l' ~
.:r
M ~....
()~
- ('J~.:.-
r=: t:: ,,:5
c 0 -~:~~
&.: N
~l c:o :Tim
r=: w te,a.
L.... .:.:
LJ.. '0 ::>
0 0-. U
. .
BARBARA D. BATEMAN
Plaintiff
v.
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95-6320 CIVIL TERM
IN DIVORCE
J. BRUCE BATEMAN, SR.
Defendant
CERTIFICATE OF SERVICE
I, Peter Russo, hereby certify that I am on this day serving a copy of the foregoing
document upon the person (s) and In the manner Indicated below:
Service by First-Class Mall, Postage Prepaid, and Addressed as follows:
J. Bruce Bateman, Sr.
508 Ellen Road
Camp Hili, PA 17011
Q:b /;:;dUA_
Peter Russo, Esquire
PA ID # 72897
845 Sir Thomas Court
Suite 9
Harrisburg, PA 17109
(717) 541-4400
Dated: fIlovember 9. 1995
.......
,..".,'~"
;,~-;> "."
=
.,";t
<:J
,,.
"2
.-.-,
;,;4
'at<J
%')..
0>
(~~. ,
"'"
r-'l
"""
,..".,
~)
~}o..
....
C>
:<::
..
, . \o....._c
BARBARA D. BATEMAN . IN THE COURT OF COMMON PLEAS ,OF
.
PlalnUff . CUMBERLAND COUNlY, PENNSYLVANIA
.
.
.
v. . CIVIL ACTION. LAW
.
.
.
J. BRUCE BATEMAN, SR. NO. 95-6320 CIVIL TERM
Defendant . IN DIVORCE
.
PLAINTIFF'S AFFIDAVIT OF PLAINTIFF UNDER
SECTION 3301 (l') OF THE DIVORCE CODE
1. A Complaint In Divorce under Section 3301 (c) of the Divorce Code
was flied on November 2,1995.
2. The marriage Is Irretrfevably 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.
4. I understand that I may lose rights concerning alimony, division of
property, lawyers fees or expenses If I do not claim them before a divorce Is granted.
However, I have reached an agreement with the Plaintiff which satisfies all of my
requirements. This agreement is In the form of a Property Settlement Agreement which
I have executed and which I understand Is to be Incorporated but not merged In the
Divorce Decree In this matter.
5. I have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I participate In
counseling.
6. I understand that the court maintains a list of marriage counselors
In the Domestic Relations Office, which list Is available to me on request.
'./
7. Being so advised, I, Barbara D. Bateman, do not request that the
Court require my spouse and me to participate In counseling prior to a divorce decree
being handed down by the Court.
I verify that the statements made In this Affldavlt are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
g 4904 relating to unsworn falsification to Authorities.
~ l/. ,'1ft.,
DATE: '
.;ja4JM_~.J~
Barbara D. Bateman
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF DAUPHIN ) SS:
Subscrfbed and Sworn before
~ undersigned Notsry Public, on
.I1...",....~ f() 19111..
by a person erffled by me to be
Barbara D. Bateman
J,/ViAL~'~ tl ~
Notsry Public
NOlar!i1! Sonl
FlIlncos A. TIledn. Nolo'Y Pubfl
.. Haul.burg. Dauphin COUnly 0
.v Commission Expires March 16. 1998
'-"'."..i
,.>" -
- ".
". ~ ......
>::;~.~:. ~..
'-'.. ..-.~~~"~:~;
'. ,~:lo::!:' \'-'.;~'
. ;:,:-' ",\....,.-'..
" ,
.~ ',.'
"'.
',:
~ .:r ~
-:l'
\-, M <-;
r 8~
~ .- ~
-'-0
u.. c.:l~
~: Cl ./>-
'VJ
h: N '-:1;~
,., -,.
r.;:\' en o-nUJ
r-" U! ~~q u..
u.. _.
,.!~ t}') ::J
(;) 0\ U
.
.
.
,"'''''~~
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95.6320 CIVIL TERM
IN DIVORCE
"/;;
BARBARA D. BATEMAN
Plaintiff
pROOF c)F SERVICE OF PLAINTIFPS AFFIDAVIT
UPON DEFENDA"'T
NOW COMES PETER J. RUSSO, Attorney for Plaintiff, Barbara D. Bateman, and
certifies that on February 9. 1996 he did personally hand deliver to the Defendant,
J. Bruce Bateman, Sr., the Affidavit of Plaintiff Under Section 3301 (c) of the Divorce Code
and the Affidavit of Defendant Under Section 3301 (c) of the Divorce Code requesting his
signature thereon.
J. Bruce Bateman, Sr.
Defendant
Respectfully submitted,
@-.h; .EY._^~
Peter J. Russo
PA Attorney I,D. 72897
845 Sir Thomas Court
Suite #9
Harrisburg, PA 17109
(717) 541-4400
Date: February 9. 1996
If e3
l5 ~
~
~
c;
gfJ
9~
i~
~
.
."\
.'
~.4'~'_
i.". ;h.;I;::rr'.,....l'.""~1'.~,.,,..... ,". 'y;.'I'!~
\
.
BARBARA D. BATEMAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95-8320 CIVIL TERM
IN DIVORCE
v.
J. BRUCE BATEMAN, SR.
Defendant
DEFENDANT'S AFFIDAVIT OF DEFENDANT UHQEB
SECTION 3301 (Q) OF THE DIVORCE CODE
1. A Complaint In Divorce under Section 3301 (c) of the Divorce Code
was filed on November 2,1995.
2. The marriage Is Irretrfevably 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.
4. I understand that I may lose rights concerning alimony, division of
property, lawyers fees or expenses If I do not claim them before a divorce Is granted.
However, I have reached an agreement with the Plaintiff which satisfies all of my
requirements. This agreement Is in the form of a Property Settlement Agreement which
I have executed and which I understand Is to be Incorporated but not merged in the
Divorce Decree In this matter.
5. I have been advised of the availability of marriage counseling and
understand that I may request that the cou:t require that my spouse and I participate In
counseling.
6. I understand that the court maintains a list of marriage counselors
In the Domestic Relations Office, which list Is available to me on request.
,..
7. Being so advised, I, J. Bruce Bateman,Sr., do not request that the
Court require my spouse and me to participate In counseling prior to a divorce decree
being handed down by the Court.
I verify that the statements made In this Affidavit are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~ 4904 relating to unsworn falsification to Authorities.
Z/q/96
D~:/
9~~A
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF DAUPHIN ) SS:
Subscrfbed and Sworn before
e undersigned Notsry Public, on
by a pers verified by me to be
J. Bruce Bateman, Sr.
~a.~
Notary Public
Nolor!.1 Soal
Frances A. Thodo. Nola'Y Publlo
HarrisbUrg. D.uphln Counly
My Commission Expires March 16.1998
of) "
, ., .,....,/'
',' \ ~l '::., "'-Q .
., ....
...-~\ ''?
)"- 1,.",!i
\. ,,;. .~l.J....
=--- ~,.:'tB
,"1~'- ::;
,.,~f. \' ,"'" n~::,
" ., .;;.,.......,.,?::~
'.~ '.:-.u..:.....~ *'.
~'-'>.:'0,.~1. .~
',"-"+ ,\\'\
"hl"""!,{\\\
;.\<:;
"
-'-','--
~..
!~r.o.~.
~:
d:"
II'
~
U.
o
<Ll~:~~:, })'_~'
;~(;,';:,}r'~~;
r;
gf
,~~
5)~'
...
::5
(.)
":.if.'
.0.;1:
&;~,
::r:
Q,.
o
N
~
~
0\
\
c
y,,\ I
\1,}
~ \
AP
-.,~. -',
~. ",.'.
.-, "-" '~""",~",-,,-_......-'-'
-.., ,"'c. ",-".,~:",~;:.,oM:~~"'~~':""'~
BARBARA D. BATEMAN
PlalnUff
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95-8320 CIVIL TERM
IN DIVORCE
.
.
v.
J. BRUCE BATEMAN, SR.
Defendant
.
.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 13301(g) OF THE DIVORCE CODE
1. I consent to the entry of a Final Decree of Divorce.
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 Pat C.S. Me04,
relating to unsworn falsification to authorities.
Date: --.,fL.....(f ''11991..
.J~ ), J~
--""'","_"""'~",",,~~..-,_T~'_"'""__
"
1'1:
;..:
I ..:r ~
.:r f".
" :)~
M g.
\l ..- ~
- P,~
C-
O :::;,.,iii!~,.. ;"';
';I.'
N ./-
~..,
c:: {I..lia """., .,"
W 'G9D- ' . ,',,-' "
F . u.. a
~ u:>
cr>
'-"",:,', ,',
~. '-, ,
, .
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95-6320 CIVIL TERM
IN DIVORCE
BARBARA D. BATEMAN
PlalnUff
J. BRUCE BATEMAN. SR.
Defendant
.
.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 13301 (G) OF THE DIVORCE CODE
1. I consent to the entry of a Anal Decree of Divorce.
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 Pat C.S. ~,
relating to unsworn falsification to authorities.
Date:~l1f /.4-.q{,
./
f)~~ ~/Ju
:":';"~O"''';':''~''''''~ ..
..~.._..,,'..,... .........'
.... t. 0"
, ~..I .. . ". .,.'
i. ~
~ -:l' ~
-
~~ Co; i3~
U;:e '",""
i! .... "'J'"
Q.. '.'::l~ .
-7
0 3!n
N frj~
CO
u.; fn
L... a~
~ ..0
en
,":~
t.',.
....
,
-~~..:....-.---~
'~-.
,....,.-..,-..
,_f.<
. ,,~"-'
"-'l;"
,
t;
~ -:l' ~
.:J'
~~ M S~
-
fE~ ii: U<
>. 'Ji..L. ~
~s ~~
0.: 0
0- N
"~.:;.o"
~ CC b:Jm
w ",~a..
L.... ac
~ 0..0
0\'
.'."
r
MAR 1 1 20~0~
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BARBARA D. BATEMAN ~? ~'
Plaintiff No. 95-6320 CIVIL TERM .,,`== `~' --+
,- M":, -~- -n
- ;-~ ~n ~::.~
VS. ~ - ^_ -rs -
~ ,,-,
- , ~_
J. BRUCE BATEMAN, SR. :CIVIL ACTION -LAW -' ` :.: ~ ,
Defendant IN DIVORCE ~~~~~_- «-, `-+`
~d- .. :~
-~ C.'_.~ °.C
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW, THIS day of U ~, ~_~, Z D l ~ , it appears to the
r
Court as follows:
WITNESSETH:
1. Plaintiff, Barbara D. Bateman n/k/a Barbara D. Scheuren hereinafter referred
to as "Wife/Alternate Payee"
2. Defendant, J. Bruce Bateman, Sr., hereinafter "Husband/Annuitant" is a
participant, through his employment, in Teachers Insurance and Annuity
Association-College Retirement Equities Fund (TIAA-CREF)
3. Husband's current and last known mailing address is 168 Flug Aye,
Indialantic, Florida 32903
4. Wife's current and last known mailing address is 4 Gale Road, Camp Hill,
Pennsylvania 17011.
5. Wife's date of birth is October 4, 1945 and social security number is 218-46-
1452.
6. Wife and Husband were married on April 16, 1966; and
7. A complaint in Divorce was filed in the Court of Common Pleas for
Cumberland County, Pennsylvania, docketed at 95-6320.
8. Wife and Husband entered into a Property Distribution Agreement on March
20, 1996
9. Wife and Husband have settled all issues of real and personal property rights
and the past and future support and maintenance of Plaintiff other than issues
relating to the parties' interest in TIAA-CREF.
10. Husband and Wife wish to settle all issues relating to their interests in TIAA-
CREF.
11. Annuitant had irrevocably elected (income option selected) for Formally TIAA
no. P414430-4 and CREF No. A414430-7 which has been converted to TIAA
Contract No. GA32552-6. This option for monthly payments for life, the last
payment to be made at the death of the Survivor. If both Husband and Wife
die before the end of the guaranteed period, John Bateman, Jr. and Charles
Bateman are Designated Beneficiaries for any death benefits due under these
contracts.
12. Effective the date of the Order, Annuitant seeks to have Wife substituted as
Alternate Payee for 50% of the Immediate Annuity benefits paid to him during
life under the Immediate Annuity Contract Formally TIAA no. P414430-4 and
CREF No. A414430-7 which has been converted to TIAA Contract No.
GA32552-6. Should Alternate Payee survive the Annuitant, then the Alternate
Payee would be entitled to 100% of the dieath benefit available at that time.
Should the Alternate Payee predecease the Annuitant, then payment of all
benefits would revert to the Annuitant.
WHEREFORE, it is hereby ordered:
1. That Barbara D. Bateman n/k/a Barbara D. Scheuren as Alternate
Payee is entitled to the benefits due under the subject annuity contract.
2. TIAA-CREF is hereby directed to issued checks to the Alternate
Payee, if it receives the appropriate releases from the parties.
3. This Order:
1. Does not require any Plan to provide any type or form of benefit, or
any option, not otherwise provided under the Plan, and
2. Does not require TIAA-CREF to provide increased benefits, and
3. Does not require the payment of benefits to an Alternate Payee
which are required to be paid to another Alternate payee under
another Order previously determined to be Qualified Domestic
Relations Order.
BY THE COURT:
d.
/,
Distribution List:
~w Offices of Peter J. Russo
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
.,/.Bruce Bateman, Sr.
168 Flug Ave
Indialantic, FL 32903
~'
..
LAW OFFICES OF PETER J. RUSSO, P.C.
Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
-~,~~c
Gl~~-_E~;-r ~~~._ ~Y
,,c Trt~. P,~~.~1, ;.
,~,
2oio t~-~ ~ a ~-; ~~ ~9
,.,~ ~..i
CiV~ ~ ~~._ ,_. .y~,v i
r:..i~, ,. ...
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA D. BATEMAN
Plaintiff
vs.
J. BRUCE BATEMAN, SR.
Defendant
No. 95-6320 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
MOTION TO DISTRIBUTE ASSETS
AND NOW, COMES, Plaintiff, Barbara D. Bateman, by and through her counsel, Peter
J. Russo, Esquire, ,and aver the following in support of this motion to distribute assets:
1. Plaintiff and Defendant were married on April 16, 1966.
2. A complaint in Divorce was filed in the Court of Common Pleas for Cumberland County,
Pennsylvania, docketed at 95-6320.
3. Plaintiff and Defendant entered into a Property Distribution Agreement on March 20, 1996.
4. The parties have agreed to an addendum to their Property Distribution Agreement from
March 20, 1996. Attached as Exhibit A is a true and correct copy of the aforementioned
addendum jointly executed and notarized
.t
5. As a result of the addendum of the Property Distribution Agreement from March 20, 1996, a
new Qualified Domestic Relations Order must be signed in the form agreed upon by the
parties and TIAA-CREF and as attached to Exhibit A.
WHEREFORE, Plaintiff, Barbara D. Bateman and Defendant, J. Bruce Bateman,
respectfully request that this Honorable Court enter the .attached Qualified Domestic Relations
Order as agreed.
Respectfully submitted,
LAW OFFICES OF PETER J. RUSSO, P.C
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
Date: J7 ~~ ~ ~~
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717} 591-1756
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BARBARA D. BATEMAN
Plaintiff
vs.
J. BRUCE BATEMAN, SR
Defendant
No. 95-630 CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
ADDENDUM TO MARCH 20, 1996 PROPERTY SETTLEMENT AGREEMENT
THIS ADDENDUM to the March 20, 1996 Property Settlement Agreement is
made this ~ day of ~.~Yl~~.~009 by and between Barbara D. Bateman n/k/a
Barbara D. Scheuren (hereinafter referred to as "Wife", and J. Bruce Bateman, Sr.,
hereinafter "Husband."
WITNESSETH:
WHERAS, the Wife and Husband were married on April 16, 1966; and
WHERAS, a complaint in Divorce was filed in the Court of Common Pleas for
Cumberland County, Pennsylvania, docketed at 95-6320.
WHERAS, Wife and Husband entered into a Property Distribution Agreement on
March 20, 1996
NOW, THEREFORE, the parties intending to le~~ally bound hereby do covenant
and agree to the following:
1. TIAA CREF ACCOUNT
Husband and Wife agreed that the TIAA CREF'' AACCOUNT, Account Number
GA32552-6 shall be changed according to the Qualified Domestic Relations Order
which is attached hereto as Exhibit A.
IN TESTIOMY WHEREOF, witness the signature of the parties hereto and their
respective counsel this ~_ day of ~Q~c~~h~2009.
,_,._
.,
._
~_..
Pefer .Russo
For Barbara D. Bateman nik/a
Barbara D. Scheuren
Barbara D. Bateman n/k/a
Barbara D. Scheuren
/~_ ~ _..
. Bruce Bateman, Sr.,
K
COMMONWEALTH OF PENNSYLVANIA
:SS.
COUNTY OF ~~ ~ ;~~ ~~ L
On this, the ~ day of `1~~~~ 2009, before me, a Notary Public,
personally appeared Barbara D. Bateman n/k/a Barbara D Scheuren and in due
form of law acknowledged the foregoing Agreement td be her act and deed, and desired
that the same might be recorded as such.
Sworn to and subscribed
before me this ~ day
of~,~ ~,, ~~ , 2009.
t/OMIVIONWEALT~fi OF PENNSYLVANIA
No~ariad Seed
~ ~~ ^ ~ Ashley Silpe, Notary Public
ien Twp, Cumberiarxi C~ _- ` ,
::tmissiorr E~ires ocL ''~ _ .
No ary P lic _.. _ . _ .. ~ ...
hr;,,,_ , ,-annsylvania Association, _; ,,,,__.,,_;
~j
' t
COMMONWEALTH OF PENNSYLVANIA
i~ ~ :SS.
COUNTY OF ~~1~"~;~ ~'
~~ 1 ~ f'
On this, the ` day of ~~~!' ;~,', 2r)~9, Mef~re me, a Notary public,
personally appeared J. Bruce Bateman, Sr. Viand in due form of law
acknowledged the foregoing Agreement to be his act arhd deed, and desired that the same
might be recorded as such.
Sworn to ands scribed
bef a me this day
of ~. ~ ~ ,, ~ . , 2009.
~~ -~
I '~
Notary Public
.~ o~' fiats
~~
~• ~
.. ~- -T.o.w,,..,?.. A,.,~.,~% .
M N~~nq
~, ,
EXHIBIT .
• .
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIAI
BARBARA D. BATEMAN .
Plaintiff No. 95-63~t0 CIVIL TERM
vs. .
J. BRUCE BATEMAN, SR. :CIVIL ACTION -LAW
Defendant IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW, THIS day of , it appears to the
Court as follows:
WITNESSETH:
1. Plaintiff, Barbara D. Bateman n/k/a Barbara D. Scheuren hereinafter referred
to as "Wife/Alternate Payee"
2. Defendant, J. Bruce Bateman, Sr., hereinafter "Husband/Annuitant" is a
participant, through his employment, in Teachers Insurance and Annuity
Association-College Retirement Equities Fwnd (TIAA-CREF)
3. Husband's current and last known mailing address is 168 Flug Ave,
Indialantic, Florida 32903
4. Wife's current and last known mailing address is 4 Gale Road, Camp Hill,
Pennsylvania 17011.
5. Wife's date of birth is October 4, 1945 and asocial security number is 218-46-
1452.
6. Wife and Husband were married on April ~6, 1966; and
7. A complaint in Divorce was filed in the Covert of Common Pleas for
Cumberland County, Pennsylvania, docketed at 95-6320.
8. Wife and Husband entered into a Property!...., Distribution Agreement on March
20, 1996
9. Wife and Husband have settled all issues of real and personal property rights
and the past and future support and maintenance of Plaintiff other than issues
relating to the parties' interest in TIAA-CREF.
10. Husband and Wife wish to settle all issues relating to their interests in TIAA-
CREF.
11. Annuitant had irrevocably elected (income option selected) for Formally TIAA
no. P414430-4 and CREF No. A414430-7 which has been converted to TIAA
Contract No. GA32552-6. This option for mpnthly payments for life, the last
payment to be made at the death of the Survivor. If both Husband and Wife
die before the end of the guaranteed period',, John Bateman, Jr. and Charles
Bateman are Designated Beneficiaries for any death benefits due under these
contracts.
12. Effective the date of the Order, Annuitant seeks to have Wife substituted as
Alternate Payee for 50% of the Immediate P~nnuity benefits paid to him during
fife under the Immediate Annuity Contract Formally TIAA no. P414430-4 and
CREF No. A414430-7 which has been conv~rted to TIAA Contract No.
L.
,,
•
GA32552-6. Should Alternate Payee survive the Annuitant, then the Alternate
Payee would be entitled to 100% of the death benefit available at that time.
Should the Alternate Payee predecease ths: Annuitant, then payment of all
benefits would revert to the Annuitant.
WHEREFORE, it is hereby ordered:
1. That Barbara D. Bateman n/k/a Barbara D. Scheuren as Alternate
Payee is entitled to the benefits due under the subject annuity contract.
2. TIAA-CREF is hereby directed to issued checks to the Alternate
Payee, if it receives the appropriate rreleases from the parties.
3. This Order:
1. Does not require any Plan to provide any type or form of benefit, or
any option, not otherwise provided under the Plan, and
2. Does not require TIAA-CREF to provide increased benefits, and
3. Does not require the payment of benefits to an Alternate Payee
which are required to be paid to another Alternate payee under
another Order previously determined to be Qualified Domestic
Relations Order.
BY THE COURT:
J.
• 4
LAW OFFICES OF PETER J. RUSSO, P.C.
Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMM0~1 PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA D. BATEMAN
Plaintiff
vs.
J. BRUCE BATEMAN, SR.
Defendant
No. 95-632p CIVIL TERM
CIVIL ACTION -LAW
IN DIVORICE
CERTIFICATE OF SERVICE
I hereby certify that I have on this day served a true and correct copy of the Addendum to
March 20, 1996 Property Settlement Agreement, upon the following person, in the manner
indicated:
VIA US MAIL:
J. Bruce Bateman, Sr.
168 Flug Ave
Indialantic, FL 32903
r "--~ ~ -_
DATE: '~ ~~~ ~
- ~.. _.--~1 ` ~ ~%
-~ `~' ~ ,~ Ashley R. Sipe, Paralegal '
i
~~
.~
~ ~- .
LAW OFFICES OF PETER J. RUSSO, P.C.
Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMMCIN PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA D. BATEMAN
Plaintiff No. 95-630 CIVIL TERM
vs. .
J. BRUCE BATEMAN, SR. :CIVIL ANION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SE~tVICE
I hereby certify that I have on this day served a true and correct copy of the Motion to
Distribute Assets, upon the following person, in the manner indicated:
VIA US MAIL:
J. Bruce Bateman, Sr.
168 Flug Ave
Indialantic, FL 32903
_ ,~~; ~ <
DATE: •~ ~~ l 4~
Ashle . Side, Pa legal
.r •~
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
,
PENNSYLVANIA
BARBARA D. BATEMAN n ~ ~~
-~
Plaintiff ~-
No. 95-6320 CIVIL TERM ~t.~~ ~,
~ ~
~-~
:.te
:!
VS. r
."
~ _ -C'.`J
,
r ' ~ ~
{ C~1
J. BRUCE BATEMAN, SR. :CIVIL ACTION -LAW ~<' {.. ~= '~'
Defendant IN DIVORCE
~ --~
ADDENDUM TO MARCH 20, 1996 PROPERTY SETTLEMENT AGREEMENT
THIS ADDENDUM to the March 20, 1996 Property Settlement Agreement is
made this ~_ day of bs.-~~09 by and between Barbara D. Bateman n/k/a
Barbara D. Scheuren (hereinafter referred to as "Wife", and J. Bruce Bateman, Sr.,
hereinafter "Husband."
WITNESSETH:
WHERAS, the Wife and Husband were married on April 16, 1966; and
WHERAS, a complaint in Divorce was filed in the Court of Common Pleas for
Cumberland County, Pennsylvania, docketed at 95-6320.
WHERAS, Wife and Husband entered into a Property Distribution Agreement on
March 20, 1996
NOW, THEREFORE, the parties intending to legally bound hereby do covenant
and agree to the following:
.ry
TIAA CREF ACCOUNT
Husband and Wife agreed that the TIAA CREF AACCOUNT, Account Number
GA32552-6 shall be changed according to the Qualified Domestic Relations Order
which is attached hereto as Exhibit A.
IN TESTIOMY WHEREOF, witness the signature of the parties hereto and their
respective counsel this ~_ day of ~~~,,ry~, , 2009.
Pe er .Russo
For Barbara D. Bateman n/k/a
Barbara D. Scheuren
Barbara D. Bateman n/k/a
Barbara D. Scheuren
/ / .~~~.
.Bruce Bateman, Sr.,
•,.
COMMONWEALTH OF PENNSYLVANIA
:SS.
COUNTY OF ~ ~ ~~~~
On this, the _z~ day of'Q~m 10,2.E , 2009, before me, a Notary Public,
personally appeared Barbara D. Bateman n/k/a Barbara D Scheuren and in due
form of law acknowledged the foregoing Agreement to be her act and deed, and desired
that the same might be recorded as such.
Sworn to and subscribed
before me this ~ day
of `~~,y~~ , 2009.
. ~IiOACyhfWrW~A~,TM ON PENNSYLVANIA
a'~Y 81pe, Nolsry Piblic
~:.=.rr..^„ien Twp., Ctxnbedand Cc'.^' ~
~:nm~sion E~ires Od .,: ,
No ary P IIC k;,,;;' °-; annsytvanlaAssocfatior,,,, ,;.,__,;..3
.1
COMMONWEAL H OF PENNSYLVANIA
:SS.
COUNTY OF `~~~~~f; ( ,
On this, the '~ ""1day of 1~.~ ~, 2009, before me, a Notary Public,
personally appeared J. Bruce Bateman, Sr. 'rand in due form of law
acknowledged the foregoing Agreement to be his act and deed, and desired that the same
might be recorded as such.
Sworn to ands scribed
bef t i day
of , 2009.
Notary Public
n~
~ eam
awes ~ won~ero, Mot~rr Prbrc
e+- -..,~,+...,,,c., n~e.,,.r.yy~, ~l
EXHIBIT
', ',
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100 ~'
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMMON PLEAS OF UMBERLAND COUNTY,
PENNSYLVANI
BARBARA D. BATEMAN
Plaintiff No. 95-6 20 CIVIL TERM
vs. I,I
J. BRUCE BATEMAN, SR. CIVIL AC ION -LAW
Defendant IN DIVO CE
FI
AND NOW, THIS day of
Court as follows:
WITNESSETH:
it appears to the
1. Plaintiff, Barbara D. Bateman n/kJa Barbar D. Scheuren hereinafter referred
to as "Wife/Alternate Payee"
2. Defendant, J. Bruce Bateman, Sr., hereinafter "Husband/Annuitant" is a
participant, through his employment, in Te chers Insurance and Annuity
Association-College Retirement Equities F nd (TIAA-CREF).
3. Husband's current and last known mailing ddress is 168 Flug Ave,
Indialantic, Florida 32903
4. Wife's current and last known mailing add
is 4 Gale Road, Camp Hill,
Pennsylvania 17011.
' , ~,
5. Wife's date of birth is October 4, 1945 and social security number is 218-46-
1452.
6. Wife and Husband were married on April 16, 1966; and
7. A complaint in Divorce was filed in the Court of Common Pleas for
Cumberland County, Pennsylvania, docketed at 95-6320.
8. Wife and Husband entered into a Propert~r Distribution Agreement on March
20, 1996
9. Wife and Husband have settled all issues bf real and personal property rights
and the past and future support and maintenance of Plaintiff other than issues
relating to the parties' interest in TIAA-CR~F.
10. Husband and Wife wish to settle all issues',, relating to their interests in TIAA-
CREF.
11.Annuitant had irrevocably elected (income!option selected) for Formally TIAA
no. P414430-4 and CREF No. A414430-7 wvhich has been converted to TIAA
Contract No. GA32552-6. This option for rr~onthly payments for life, the last
payment to be made at the death of the Survivor. If both Husband and Wife
die before the end of the guaranteed period, John Bateman, Jr. and Charles
Bateman are Designated Beneficiaries for any death benefits due under these
contracts. ~'
12. Effective the date of the Order, Annuitant seeks to have Wife substituted as
Alternate Payee for 50% of the Immediate ,~nnuity benefits paid to him during
life under the Immediate Annuity Contract f ormally TIAA no. P414430-4 and
CREF No. A414430-7 which has been con~erted to TIAA Contract No.
'.
GA32552-6. Should Alternate Payee survive the Annuitant, then the Alternate
Payee would be entitled to 100% of the death benefit available at that time.
Should the Alternate Payee predecease the Annuitant, then payment of all
benefits would revert to the Annuitant.
WHEREFORE, it is hereby ordered:
1. That Barbara D. Bateman n/k/a Barbara D. Scheuren as Alternate
Payee is entitled to the benefits dui under the subject annuity contract.
2. TIAA-CREF is hereby directed to issued checks to the Alternate
Payee, if it receives the appropriate, releases from the parties.
3. This Order:
1. Does not require any Plan to prdvide any type or form of benefit, or
any option, not otherwise provided under the Plan, and
2. Does not require TIAA-CREF to provide increased benefits, and
3. Does not require the payment of benefits to an Alternate Payee
which are required to be paid to 'another Alternate payee under
another Order previously determined to be Qualified Domestic
Relations Order.
BY THE COURT:
J.
LAW OFFICES OF PETER J. RUSSO, P.C. i
Attorneys for Plaintiff '
BY: Peter J. Russo, Esquire ',
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
IN THE COURT OF COMMO~i PLEAS OF
CUMBERLAND COUNTY, PElyfNSYLVANIA
BARBARA D. BATEMAN '
Plaintiff No. 95-632 CIVIL TERM
vs. .
J. BRUCE BATEMAN, SR. :CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I have on this day served a true and correct copy of the Addendum to
March 20, 1996 Property Settlement Agreement, upon the fallowing person, in the manner
indicated:
VIA US MAIL:
J. Bruce Bateman, Sr. ',
168 Flug Ave
Indialantic, FL 32903
DATE: ;~...L ~ _ ..L
4 1 ~ Ashley R. , ' e, .Paralegal
1 ,
,~