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HomeMy WebLinkAbout95-06433 'I~ . 1-~ _ ~,-, ". ~. T-i'-," ""' , ~~ . ~ . . .. .. . . ... .... · ... · · · ,... · ... ... ... · ... · .........::.: .,.... · .. *<"*';I . . -- - l~ ! IN THE COURT OF COMMON PLEAS ; : OF CUMBERLAND COUNTY ~ I STATE OF * PENNA. : . . . . : ...RO~~T B, SHI:~INTIFF . . d'" I! N ll. ...,9..s....~d..6...3~"""",,""" ~ .. 'I II: ~ V,'I','II" ~ . "d~~W~"B ~h SHIPP, . . d dl . ~ DBFENDANT ,! . ! ~ . . . DECREE IN . " DIVORCE . . . , ,., I, ., ~ AND NOW, .. .. . .. .. .. ~ 40.~.. C. .. .. .. ... 19.'. ... It I. ordered and ~ . decreed that....... ..~~~.~~~. ~'.. '!I!I.I.~~............ ........... plaintiff, ~ ii and....,.....,...,.,. ~.I!!~~~~~. ~'. .~~.I,~':'..........,.,...,. defendant, I i a.. dl.."cod I'am tho band. 01 mot,lmon.. ~ . The court retains jurisdiction of the following claims which have ~ ~ been ral.ed of record In this action for which a final order has not vet : . been entered: . . ~ . . . . . . ~~~.~~~~~.~~ , ~~.~ ,~~~~~~~~. .~~~~~~.~~ . ~~~.~~~~.~~ ,~~~~~. . , . . . . . . . . JANUARY 17 1996 IS INCORPORATED IN THIS DECRBE, . ~ ............1..... ........,............................................... 8 , . ~ Ily The CllurllA ~ I 8 . . d t.I.L, H.;\ t. . . . Allel" ~. '4.....:.1 t/fts,P. I, ."t'~".,lf'7 J. 8 ~Y"M /:'..J9h, f J.?!. w 77 "rlllhonolnry 0;0 * ~_.....__'~.._.H.... .."'" ......, ., 'M ------~--*~~~.~~._..~~~- ~. ~ . ./ while they continue to live apart from each other and to settle all financial and property rights between theml and, WHEREAS, the parties hereto have mutually entered into an agreement for the division of their jointly owned assets, lhe provisions for the liabilities they owe, and provisions for the resolution of their mutual differences, after both have had full and ample opportunity to consult with attorneys of their respective choice, and the parties now wish to have that agreement reduced to writingl and, NOW THEREFORE, the parties hereto in consideration of the mutually mads and to be kept promises set forth hereinafter and for other good and valuable consideration, and intsnding to be legally bound and to legally bind their heirs, succes8ors, assigns, and psrsonal representatives, do hereby covenant, promise and agree as followsl ARTICLB I SBPARATION 1.1 It shall be lawful for Husband and Wife at all timss hereafter 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, free from any control, restraint, or interference, dirsct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other Page 2 of 15 ./ .,.-C_\ I ~. to cohabit or dwell with him or her by any legal or other proceedings, The foregoing provisions shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II DIVORCE 2.1 This Agreement is not predicated on divorce. Notwithstanding the foregoing, it is, in fact, agreed and acknowledged between the parties that Husband will file a divorce action against Wife, and that both parties agree/ as a condition to this agroement/ to execute the necessary divorce consents required by Ssction 3301(c) of the Divorce Code so as to promptly finalize 'said action. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty/ covenant, and representation is made for the spscific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife eaoh knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason/ illegal, or unenforceable in whole or in part. Husband and Wife do eaoh hereby warrant/ covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any Page 3 of 15 .... . /. , illegality or unenforceability as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provisions of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decreet jUdgment or order of separation or divorce in any other state, country/ or jurisdiction, each of ths parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be affected in any way by any such separation and divorce I and that nothing in any such decreet judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties should remarry/ it being understood by and between the parties that this Agreement shall survive and shall not be merged into any decreet judgment or order of divorce or separation. 2,3 It is specifically agreed that a copy of this Agreement shall be incorporated by reference into any divorce, judgment or decree if or whensver sought by either of the parties hereto. Such incorporation, however, shall not be regarded as a merger, Page 4 of 15 /. , ~. it being the intent of the parties to permit this Agroement to survive any euch judgment or decree. ARTICLB III BOUITABLB DISTRIBUTION OF MARITAL PROPBRTY 3,1 The partiee have attempted to divide their marital proporty in a manner which conforms to the criteria eet forth in Seotion 3502 of the Pennsylvania Domestic Relations Code, and taking into account the following cons!derationsl the length of the marriage 1 the prior marriages of the partiesl the age, health, station, amount and sources of income, vooational skill., employability/ estate, liabilitiee, and nsed. for each of the parties 1 the contribution of one party to the education, traininiJ or increaeed earning power to the other party / the opportunity of each party for future acquisition of capital auot. and inoome, the sources of income of both partiee, including but not limited to medical, retirement, insurance or other benefit., the contribution or dissipation of each party in tho acquisition, preservation, depreciation, or appreciation of marital properly, including the contribution of a party I\Il 1\ homemakeq t.hll vAluo of the property set apart to each party/ tho Iltal~ard of living of the parties established during their marriage/ tho ouollomio circumstances of each party, inoluding foclond, at.lllo IIl1d 10uIIl tax ramifications, at the time of lho divioioll of tho proport.y i. Page 5 of 15 - .,. . to become effectivel and whether the parties will be serving as the custodian of any dependent minor children. 3.2 The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribution of parties, 3.3 Husband agrees to relinquish all claims to any assets that may be acquired by Wife prior to the finalized divorce decreet or as may be listed in paragraph 3,4 below, in exchange for the following assets to be transferred to Husbandl 1991 Chsvy P/U Truck Clothing Personal Papers Husband further agrees to relinquish any and all claims to any additional, unlisted assets that titled soley in Wife's name including, but not limited to, Wife's 40lK/Profit Sharing Plan at her place of employment, 3,4 Wife agrees to relinquish all claims to any assets that may be acquired by Husband prior to the finalized divorce dscree, or as may listed in paragraph 3.3 above / in exchange for the following assets to be transferred to Wifel Page 6 of 15 _. -" . $15,000 Cash Burial Lots Marital Residence All Assets and Furniture in Marital Rssidence wife further agrees to relinquish any and all claims to any additional, unlisted assets that are titled solely in Husband's name, Furthermore, Husband will install a new roof and a new furnace in the marital residsnce within one year of the date of the Divorce Decree, ARTICLB IV DBBTS OP THB PARTIBS 4.1 Husband and Wife agree that all debts incurred during the time of their marriage and during their psriod of separation have been properly apportioned between the parties. ARTICLB V MISCBT.T.&Nl!OUS PROVISIONS 5.1 Each of the parties agree that should either of them be in breaoh of contract and fail to comply with the terms of the Agreement hsrein the breaching party shall be responsible for all court costs and attorney fess to enforce the Agreement, 5.2 Advice of Counsel, The parties acknowledge that they have been given full and fair opportunity to oonsult lsgal counsel regarding the legal effeot of this agresment, Thsy acknowledge and aocept that this Agreement is, in the ciroumstanoes, fair and Page 7 of 15 -, - equitable, that it is being entered into freely and voluntarily, after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence and that is not the result of any collusion or improper or illegal agreement or agreements, 5.3 Counsel Fees. Husband and Wife agres to be responsible for their respective attorney fees, 5.4 Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and tho estate of such other / for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresosver situate, which he or she now has or at any time hereafter may have against such other, ths estate of such other, or any part thereof/whether arising out of any formsr acts, contracts, engagements/ or liabilities of such other as by way of dower or curtesy/ or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse' swill, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of Page B of 15 - - a surviving spouse to participate in a deceased spouses's estate/ whether arising under the laws of (a) Pennsylvania, (b) any state/ commonwealth of territory of the United States/ or (c) any country, or any rights which either party may have or at any time hereaftsr have for past/ present/ or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses/ whethsr 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 thereof. It is the intention of Husband and Wife to give each other by execution of this Agreement a full, complete and general release with respect to any and all property of any kind of nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreemente and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 5.5 Warranties. Each party represents that they have not heretofore incurred or contracted for any dsbt or liability or obligations for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of each of them, including those for Page 9 of 15 - - necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant/ covenants, represent and agree that each will, now at all times hereafter, save harmless and keep the other indemnified from all debts, oharges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided for by the terms of this Agreement and that neither of them hereafter incur any liability whatsoever for which the estate of the other may be liable. 5.6 No waiver or modification of any of the terms of this Agreement shall be valid unless in writing and signed by both parties and no waiver of any breach or default shall be deemed a waiver of any subsequent default of the same or similar nature. 5.7 Husband and Wife covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for ths proper implementation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry fully and effectively the terms of this Agreemsnt. 5,0 Page 10 of IS - _. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect ae of the date of execution of this Agreement, 5,9 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors/ administrators, successors/ and assigns. 5,10 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. 5.11 Severability, If any term, condition, clause, section, or provision of this Agreement shall be determined or dsclared 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 obligation under anyone or more of the articles and sections shall in no way void or alter the remaining obligations of the parties, 5,12 Page 11 of 15 - -- It is specifically understood and agreed that this Agreement constitutes an squitable distribution of property/ both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by the Divorce Code of the Commonwealth of Pennsylvania, 5.13 Disclosure. The parties warrant and represent that they have made a full disclosure of all assets prior to the execution of this Agreement and that this agreement was entered into in reliance upon that disclosure, 5,14 Enforceability and Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties, and any independent action may be brought, either at law or in equity, to enforce the terms of the Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agresments of each of the parties to the other, The adequacy of the consideration for all agreements herein contained and stipulated, confessed and admitted by the parties, and the parties intend to be legally bound hereby. In the event either party breached the aforesaid Agreement and it is determined through appropriate legal action that the alleged Page 12 of 15 -. -. COMMONWEALTH OF PENNSYLVANIA ) ISS COUNTY OF CUMBERLAND ) On this the 11 day of OCV'lLl!V\",\.199(n , before me, the undersigned officer, persona11y appeared ROBBRT B. SHIPP/ SR., known to me (or satisfactorily proven) to be the person whole name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESSES WHEREOF, I hereunto se seal. NOTARIAL SEAL t,lICHEI LE L. SOlLENOEnGER, t>olar1 Publ;c F~I/I!Gv1'lo. Frankl!n County My Comml$Slon ElPlltS Ocl. 5. 1998 COMMONWEALTH OF PENNSYLVANIA ) I SS COUNTY OF CUMBERLAND ) On this the \1") day of OCLJ\lUft"-';\. 199 <; / before met the undersigned officer, persoJally appeared GBRALDINB SHIPP, known to me (or satisfactorily proven) to be the person whose name ia subBcribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained, -, ~. IN WITNESSES WHEREOF, I hereunto seal, HOTAOIAL SEAL I 1J1=IlEllr I SOll ENBERGER, tllll~rv Pubilc fJi'I'~~'I!. F'anlllll County ,,",,10'1""""5'011 ['pllfS Ocl. 5. 1998 Page 14 of 15 ROBERT E. SHIPP, I IN THE COURT OF COMMON PLBAS OF Plaintiff I CUMBERLAND COUNTY / PBNNSYLVANIA I vs, I No, 95-6433 I GERALDINE L. SHIPP/ I CIVIL ACTION - LAW Defendant I IN DIVORCE PRAECIPB TO TRANSMIT THE RECORD TO THE PROTHONOTARY I Transmit the record, together with the following information, to the Court for entry of a divorce decree I l, Ground for Divorcel Irretrievable breakdown under Seotion 330l(c) of the Divorce Code, 2. Date and Manner of service of the Complaint I Service by Certified Mail , Z 138 527 296/ delivered on November l5, 1995. 3, Date of execution of the Affidavit of Consent required by Section 3301 (0) of the Divorce Codel Plaintiff - February 27/ 1996 Defendant - February 27/ 1996 4. Date of execution of Defendant's Waiver of Notioe of Intention to Request Entry of a Divorce Decree I February 27/ 1996 5. Related claims pendin91 Please incorporate the enclosed Separation and Property Settlement Agreement into the divorce decree, submitted, Datel L/t-,/9(. Bri n J. Puhala, Sr., Esquire Law Offices of Patrick F, Lauer1 Jr, 2108 Market Street, Aztec Build ng Camp Hill, Pennsylvania 17011-4706 ID, 52677 Tel, (717) 763-1800 t ill '- f_ - I-,.t .. _.i.-f. ~f) ('.j I'," i~;' [. .- " or' ";:.J ~l - . .'" I I ~; (; lit) [C\ ,. it;'.. r . I',. V" ;,j U c, U ROBERT E, SHIPP, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs, I No, 95-6433 I GERALDINE L. SHIPP, I CIVIL ACTION - LAW Defendant I IN DIVORCE DBFBNDANT'S WAIVBR OF NOTICB OF INTBNTION TO RBQUEST BNTRY OF A DIVORCB DBCRBB UNDBR SBCTION 330l(cl OF THB DIVORCB COD! 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. 4. 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 IB Pa, C.S, 5 4904 relating to unsworn falsification to authorities. Signaturel..&UA~'~b <~ Geraldine L. Shipp Datedl 'l1~"A"'/I.f~ jf9( fi; Ln ~: ~ f~ .. :.J~ N ~~. 1.11"--;.. Ii' :z: ~J~?J t". '.- ~~~: .~;E '" :.,,,-, it. I .:J~-; I j ~ .:. !.1 r:,; .,jCJ1 r' .... IJU. _. "- .... '5 II. V) t) C\ b \ ROBERT E, SHIPP, I IN THB COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS, I No, ~< &V:3:, C;~..:/J ~../.\ I GBRALDINE L, SHIPP, I CIVIL ACTION - LAW Defendant I IN DIVORCE NOTICE TO DBPBND AIID CLAIM RIGHTS You have been sued in court. If you wish to defend against the olaime set forth in the following pages, you must take prompt action. You are warned that if you fail to do so/ the caee may prooeed without you and a decree of divorce or annulment may be entered against you by the court, A jUdgment may also be entered againet you for any other olaim or relief requested in these papers by the Plaintiff, You may loee money or property or other rights important to you, inoluding cuetody or visitation of your ohildren. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage couneeling. A liet of marriage counselors is available in the Offioe of the Prothonotary at the Cumberland County Courthouse, at the Interseotion of High and Hanover Streets, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY/ LAWYER'S FEBS OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED/ YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAltB THIS PAPBR TO YOUR LAWYER AT ONCB. IP YOU DO NOT HAW A LAWYIR OR CAIItfOT AFFORD OHB, GO TO OR TBLBPHOHB THB OPPICB SBT FORTH BBLOW TO PIND OUT WBBRB YOU CAN GBT LBGAL BBLP. OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 170lJ (717) 240-6195 . " ROBERT E. SHIPP/ I IN THB COURT OF COMMON PLBAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I vs. I No, I GBRALDINE L. SHIPP/ I CIVIL ACTION - LAW Defendant I IN DIVORCE COMPLAINT IN DIVORCB UNDBR SBCTIONS 3301(c) or 3301(d) OP THB DIVORCB CODB The Plaintiff, Robert E, Shipp, by and through his attorney., The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divoroel l, The Plaintiff/ Robert 8, Shipp, is an adult individual who ourrently residos at 3 Railroad Avenue/ Carlisle/ Cumberland County/ penneylvania l7013, 2. The Defendant/ Geraldine L, Shipp, is an adult individual who currently resides at 3 Railroad Avenue/ Carlisle, Cumberland County, Penneylvania 17013. 3, The Parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on January 3l, 1970 in Carlisle, cumberland County, Pennsylvania, 5. There have been no prior actions of divoroe or for annulment betwsen the parties, 6, The marriage is irretrievably broken. , .. 7. The Plaintiff has bsen advised that counseling is available and that the Plaintiff may have the right to request that the oourt require the parties to participate in counseling. 8. There are no dependent children of the parties. 9. This action is not collusive. The Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. COUNT II The prior paragraphs of this Complaint are incorporated herein by reference thereto. lO, Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant faotors. WHBRBFORB, Plaintiff respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to S3502(a) of the Divorcs Code. Respeotfully submitted, ..........-...-J ,/ "J Datel 1II""/9~./ Bri. J. puhala,Br. Esquire Law Offices of Patriok F. Lauer, Jr. 2108 Market Btrset/ Aztec Build1ng Camp Hill, Pennsylvania l7011-4706 rD. 52677 Tel. (717) 763-1800 . I' I ROBBRT B. SHIPP, I IN THE COURT OF COMMON PLBAS or Plaintiff I CUMBBRLAND COUNTY / PBNNSYLVANIA I vs, I No. I GBRALDINB L. SHIPP, I CIVIL ACTION - LAW Defendant I IN DIVORCE VERIFICATION I 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 IB Pa.C.S. S 4904/ relating to unsworn felsification to authorities. Datel~~ Signature I 4~c-:..~~R Robert E. Shipp . t. . . , ROBERT E. SHIPP, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY / PENNSYLVANIA I vs. I No. 95-6433 I GERALDINE L. SHIPP, I CIVIL ACTION - LAW Defendant I IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 330l(cl OF THB DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on the l3th day of November 1995, 2, The marriage of the Plaintiff and the Defendant i. irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce after .ervice of notice of intention to request entry of the decree. 4. I verify that the statements made in this affidavit are true and correct, I understand that false statements herein are made subject to the penaltiss of 18 Pa. C.S. S 4904 relating to unsworn faleification to authorities, Datedl 't~ nj 11ft Si...tur.~e ~Z Robert E. Sh -' iE In f:: I~ .:r .. :.'1 "l :.,~ . :1 ~::: F u.. ~ .--j ,I,;. f\- ." 'Ul j) I )~l [I f , '.:]IU r:\- : . .! w.. ..0.- t""': .. -.f> .::l t..; C\ C) .. , . ~ ,. t ROBERT E, SHIPP/ I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS. I No. 95-6433 I GERALDINE L. SHIPP/ I CIVIL ACTION - LAW Defendant I IN DIVORCE DBFBHDABT'S AFFIDAVIT OF COHSBHT UHDBR SBCTIOR 330l(cl OF TUB DIVORCB CODB L A complaint in divorce under Section 330l(c) of the Divorce Code was filed on the l3th day of November 1995, 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divoroe after .ervice of notice of intention to request entry of the decree. 4. 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, S 4904 relating to unsworn falsification to authorities, Signature I ~ltJLJt_~.I.~ Geraldine L. Shipp Dated I 1~ .2~ / ?'1t ~ jf.:~ r. <, I! I'" 'I. t;) l/') ... [\1 .- !;: ::~ u: -,...... .h.:l , )~ "'::"1' ."b t (~) j'":'P i""il '1(11 ',.u. ~ (J I a:,' ...: to, .~ ..... ,,, Cl . , .. I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY / PENNSYLVANIA I , No. 95-6433 I I CIVIL ACTION - LAW I IN DIVORCE , ., . .. . ROBERT E. SHIPP, Plaintiff vs. GERALDINE L. SHIPP, Defendant AFFIDAVIT OF SERVICB TO THE PROTHONOTARY I 1/ Brian J, Puhala, Sr" Esquire, verify that the Complaint in Divorce has been served upon the Defendant indicated above by first class, Certified Mail No, Z 138 527 296/ postage prepaid, pursuant to the re uirements of Pa, R.C.P, 1920.42(c)(2), I. == 1':r.'1ot __ _, . t .. wWI " ,.... ... , I'...... I ..... .. f.....~" MMeM Ifw..PIII J ' ~ _""':: =....... on.... ..- If ""'loml.. n',I" I:on 1..11 " i I ~'='.::.~ to.... fron, .,... .......... II III 'ho..... ".- 1. 0 A~'. A...... I' :, . .:;:O~ft,'c~~"::':'';;:'''::J.J';..~'':'= ~trictIcIO~ 'I ,. . C IIIfO/f. : IG~rtWAj~oll.' Shipp ~: :!mc.TVPe 1 qc, J a ^. " _..l .II 0 fllllllllM 0 InlUlld '"'" mO-Q\o MHUlI.J...C- hilfled 0 coo r 8JrU~/t. "PA 110/.3 o Ex_" Mill 0 !llUmfl~fO! . . j , 7. DI'" of D .. \\ '\"it $ I e, Add_'. Addml COnly If /lClI*lIcIJ IIld IN II poWl . .. "",,"I 1 Respectfully submitted, Date I 2../t.'i/Pc. rJ/3- /. ./ Briwff J. PUhala, Sr., Esquire Law Offices of Patrick F, Lauer, Jr. 2108 Market Streett Aztec Building Camp Hi1l, Pennsylvania 17011-4706 ION 52677 Tel. (717) 763-1800 1'-' if. Ln .:1 l' ~..J ).~ h:-; t" .- ..~~~ -..... r' l.l. -';'.! ( - . (I) L I :: :-~; .., ,. ,() .. c j,L I. ..... .:. II. ,C> '.:J c I (.... C) '-"'",:,- . . , .. . .'