HomeMy WebLinkAbout95-06568
,L~' ,
.
~,
;.-"
,.
~~~:".n'
";:-tiFi ~
"-'>,','.
<,:.;"',
.
., .
._..._..._._-~------>-~~~----~~
j -'-' ,-----,------- - ,
, .
: IN THE COURT OF COMMON PLEAS :
. OF CUMBERLAND COUNTY .
. .
! STATE OF '* PENNA. :
, .
. NANCY L. HALLMAN, 8
. ~ *
"'Plaintiff ,. _''''I No. "",?s.~,~,~,~~ "~,~~,I,~,, llJ
~ !i"
. V '
, ('1'~t1H '1 ,
. ,,,,,ROY, DANIEL HALLMAN ""', , "I,' 8
8,'i i
. Defendant d '
,"
.
.
.
.
,
.
.
~
.
.
.
.
~
.
.
'-
.
.
.
.
.
lk-. _
.
DECREE IN
DIVORCE
AND NOW, ." tl(l,t(~J.. , ,C\...,.",. .. 19, .q,~ it is ordered and
Nancy L. Hallman I "
decreed that ..".."..".....................",.......,....., paint! .
and....... .. .. .... ... ~,~~. ~~.~~~~. .~~~~~.~~... .. . .".....,.., defendant.
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered; None.
~/~
(_ _ u !l!lt.-...l,JI. r _ ..L _Ji t_ parties' Post-Nuptial Agreenent
'dated 'i\Prii . i; 'i996; ':.. : ... . . ~. . , . . 't' is' 'made' apart' of' these' proc~ngs'
.................. ....... .... ...",.. ............. .... ........... ... ......
t Order of even date herewith but is not merged herein.)
Dy ~hecou~~' ~/V'......
( ,,/ "
^lIe.t:0'6I'lfu'~, , 'k. ' ~"~7 J.
,+'fn J:"- ~k, fH Prothonotary
I,
., ,. .." ,- .', " ,~
-----~~~*~-~-----*---~
.
r~
.
.
-
.
8
.IIl,;
.
.
"
.
.
~
.
.
i!I
~
i!I
~
,;,
"
w
;:0
~
Ii!
I'
~
~
'.'
,!/(l~t dJd. to/?' ~ ~ -4 ~
-s',? ~t? )'Nt;, /JoI;W -;? .:'~'
q
, \
-~,l -
." :"'I ".r:~''''',.':
\\'::\,-\.,1,::.',: .q' ,
. ,
(I. '1 I.
('.., ~~"', - J
.., ",
.' ';': t,~
\ l....
,.\\
i\ ",; ,'. I'
'-'... ..."",\"' ."i' :;,:..
~ 'L~ i ~.',.. ." ..
,y~~ M'~,1H.i.U.,g4~
I/f,tJ~ 'J1~ /~i~ -dr ~.
.
u,. a,.PICI.
BNIL.Ater"
a
."ENNIMAN
Pleas of Cumberland county, Pennsylvania (hereinafter called
"Divorce Action"); and
WHEREAS, the parties agree that their marriage is
irretrievably broken; and
WHEREAS, Wife is represented by Philip H. spare, Esquire,
of the firm of Snelbaker , Brenneman, P. C., and Husband
knowingly and intelligently elected not to retain legal counsel.
Husband agrees and acknowledges that he was advised by Wife's
counsel that he should retain an attorney to advise him in this
matter. Husband agrees and acknowledges that he has not
received or relied upon any legal advice from Wife's counsel;
and
WHEREAS, the parties having a full opportunity to be so
advised of their respective rights, duties and obligations
arising out of their marital status, and each having a full
opportunity to investigate and evaluate the assets, liabilities
and all other aspects of each other's property and their jointly
owned assets and liabilities, have come to an agreement for the
final settlement of their property and affairs.
NOW THEREFORE, in consideration of these presents and the
mutual covenants, promises, terms and conditions hereinafter set
forth and to be kept and performed by each party hereto, and
-2-
intending to be legally bound hereby, the parties mutually agree
as follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and
paragraphs are incorporated by reference herein in their
entirety.
2. DECI~TION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties agree that the items of property set forth in
Paragraph 3 hereinbelow are all of the a6sets which they
acquired during their marriage and which would be the subject of
equitable distribution if submitted to a court for division
under the provisions of the Pennsylvania Divorce Code. The
parties declare and agree that they are familiar with said
assets and hereby waive the evaluation thereof, although each
party declares that she/he has had full opportunity to obtain
such evaluation.
LAW OPPIC'.
SNILDAKE"
a
B'UNNEMAN
3. DIVISION OF ASSETS. Upon the granting of a final
decree of divorce in the Divorce Action, and except as otherwise
provided, the parties agree to divide, allocate, retain and/or
transfer the following assets as follows:
ASSETS TO WIFE:
a. any and all amounts or increase in value of
her Voluntary Investment Plan (VIP) available through
her employer, Pennsylvania Blue Shield;
b. any and all interest in her 1995 Honda civic
-3-
LAW O"ICI.
BNILDAKE"
a
."INNIMAN
lease and the 1984 Subaru station Wagon which was
traded in at the inception of the lease; and
c. any and all household goods, furnishings and
other items of personal property in her possession.
ASSETS TO HUSBAND:
d. 1958 Ford pick-up truck;
e. 1965 Chevrolot automobile or any motor
vehicle that Husband currently owns or operat.s;
f. funds Husband acquired from the Belco joint
checking account at the time of separation; and
g. any and all household goods, furnishings and
other items of p.rsonal property in his poss.ssion.
4. NON-MARITAL ASSETS. The parties agree and acknowledge
that Wife's real property located at 2303 stumpstown Road,
Mechanicsburg, Pennsylvania and all of its contents were the
sol. prop.rty of Wife prior to the marriage and remain the sole
property of Wife.
5. RESPONSIBILITY FOR EXISTING LIABILITIES. The parties
agree that they have no existing joint liabilities. Husband
acknowledges his sole responsibility to pay any existing debt or
liabilities in his name including, but not limited to, an amount
h. may ow. to Holy Spirit Hospital. Wife shall be sol.ly
responsible for payment of any existing debt or liabilities in
her name. Each party agrees to indemnify and hold harmless the
-4-
u,w a"ICII
SNIELI"teER
a
BRENNEMAN
other party of and from any and all obligations arising from
individual liabilities.
6. FUTURE OBLIGATIONS. The parties agree that any and all
obligations incurred subsequent to the date of the Agreement
shall be the sole and separate liability and responsibility of
the party incurring the obligation and each party agrees that
he/she will not incur or attempt to incur any obligation for or
on behalf of the other party and will indemnify and hold
harmless the other party of and from any and all liability
arising from such future obligation.
7. DIVORCE. The parties agree to terminate their marriage
by mutual consent without counselling and each agrees to make
and execute the necessary affidavits and consents to procure a
consensual divorce under the provisions of the Pennsylvania
Divorce code, such documents to be filed in the Divorce Action
as aforesaid. This Agreement and the terms and conditioins
herein as well as the enforcement of said terms, shall be and
is/are contingent upon the issuance of a final decree of divorce
in the Divorce Action.
8. RELEASE OF RIGHTS UNDER DIVORCE CODE. Except only as
specifically provided to the contrary hereinabove in this
Agreement, each party hereby waives and forever releases the
other party of and from any and all claims which either may have
against the other by reason of and pursuant to the Pennsylvania
-5-
LAW O"ICII
SNILUAKER
a
BRENNEMAN
Divorce Code (and the divorce law of any other juriSdiction)
including, but not limited to, alimony, alimony pendente lite,
equitable distribution of marital property, counsel fees, costs
and expenses, except that the performance of any obligations
created hereunder may be enforced by any remedies under said
Divorce Code.
9. INDIVIDUAL PROPERTY. Except only as may be provided
specifically to the contrary hereinabove, each party shall
retain all property, real, personal or otherwise, which is
presently titled in his or her name and ownership, whether or
not said property is or would be deemed to be marital property
under the Pennsylvania Divorce Code and each party hereby
expressly releases the other of and from any and all right of
equitable distribution in and to said individually owned
property of such other party, including, but not limited to, the
respective pension rights and plans, of the parties.
10. GENERAL RELEASE. Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of
the parties hereto by these presents, for himself or herself,
his or her heirs, executors, administrators or assigns, does
hereby remise, release, quit-claim and forever discharge the
other party hereto, his or her heirs, executors, administrators
or assigns, or any of them, of any and all claims, demands,
-6-
damages, actions, causes of action or suits at law or in equity
of whatsoever kind or nature, for or because of any matter or
thing done, omitted or suffered to be done by such other party
prior to the date hereof, except that this release shall in no
way exonerate or discharge either party from the obligations and
promises made or imposed by reason of this Agreement. This
Agreement shall not be construed to affect or bar the right of
either party to an action for the enforcement or performance of
this Agreement which may be instituted pursuant to the remedies
available under the Pennsylvania Divorce Code.
11. SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Post-Nuptial Agreement shall survive any
action in divorce which may be instituted or prosecuted by
either party, and no order, judgment or decree of divorce,
temporary, interlocutory, final or permanent, shall affect or
modify the terms of this Agreement, but said Agreement may be
enforced by any remedy at law or in equity, inclUding
enforcement proceedings under the Pennsylvania Divorce Code.
The parties agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this
Agreement shall not be merged into said order or decree in
divorce.
LAW O"ICI.
SNIL.AKIIt
a
BRINNEMAN
12. COOPERATION. The parties agree to cooperate with each
other and to make, execute, acknowledge and deliver such
-7-
instruments and take such further action as may hereafter be
determined to be requisite and necessary to effect the purposes
and intention of this Post-Nuptial Agreement.
13. VOLUNTARY EXECUTION. The provisions of this Agreement
and their legal effect have been fully explained to wife by her
lawyer and Husband has elected to not seok the advice of a
lawyer.
Each party acknowledges that this Post-Nuptial
Agreement is fair and equitable, that it is being entered into
voluntarily, with full knowledge of the assets of both parties,
and that it is not the result of any duress or undue influence.
The parties acknowledge that they have been furnished with all
information relating to the financial affairs of the other to
the extent same has been requested by each of them.
LAW a"lcu
SNILeAKER
a
BRENNIEMAN
14 . ENTIRE AGREEMENT. This poet-Nuptial Agreement
contains the entire understanding of the parties and there are
no representations, warranties, covenants or undertakings other
than those expressly set forth herein. The parties acknowledge
and agree that the provisions of this Agreement with respect to
the distribution and division of marital and separate property
are fair, equitable and satisfactory to them based on the length
of their marriage and other relevant factors which have been
taken into consideration by the parties. Both parties hereby
accept the provisions of this Agreement with respect to the
division of property in lieu of and in full and final settlement
-8-
and satisfaction of all claims and demands that they may now
have or hereafter have against the other for equitable
distribution of their property by any court of competent
jurisdiction pursuant to the Pennsylvania Divorce Code or any
amendments thereto. Each party voluntarily and intelligently
waives and relinquishes any right to seek a court ordered
determination and distribution of marital property, but nothing
herein contained shall constitute a waiver by either party of
any rights to seek the relief of any court for the purpose of
enforcing the provisions of this Agreement.
15. WAIVER. The waiver of any term, conditions, clause or
provision of this Agreement shall in no way be deemed or
considered a waiver of any other term, condition, clause or
provision of this Agreement.
16. APPLICABLE LAW. This Agreement shall be construed,
interpreted and enforced according to the laws of the
Commonwealth of Pennsylvania.
17. HEADINGS. The headings or titles of the numbered
paragraphs of this Agreement have been used only for the purpose
of convenience and shall not be resorted to for the purposes of
LAW O"ICU
8NIL....telft
a
BRENNIMAN
-9-
LAW O"ICI.
SNIIL.AKE..
a
BRENNEMAN
NANCY L. HALLMAN,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6568 CIVIL TERM
v.
ROY DANIEL HALLMAN,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO: Prothonotary of Cumberland County:
Please 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 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: service via
certified mail, restricted delivery, return receipt requested on
December 28, 1995. (See Affidavit of Service filed January 23,
1996.)
3. Date of execution of the Affidavit of Consent required
by section 3301(c) of the Divorce Code: By the Plaintiff: March
29, 1996; by the Defendant: April 1, 1996.
4. Related pending claims: None.
5. Date of execution of the Waiver of Notice of Intention
to Request Entry of a Divorce Decree Under S3301(C) of the
Divorce Code: By the Plaintiff: March 29, 1996; by the
Defendant: April 1, 1996.
SNELBAKER & BRENNEMAN, P.C.
Date: April 8, 1996
By '~e~.l' spare
Attorneys for Plaintiff
;:.' .. ~'I'iH
':,.i.
.i:';l
f,' If:"
ir. N -...
en r..
"
~ M :-~~
C' ~ )r.-;1
~-'
.... ';)::;:
~~.: ;;;: --
r c!8
CO ."~'l
.... I .,..j /.:
,'l:..-'.
ifl'. c; ..Iti]
. . ~ .:J u..
i F ~ t:j
u.. ...r:>
0 G' D
"
.
.
. .
NANCY L. HALLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 91. t6tJS CIVIL TERM
vs.
ROY DANIEL HALLMAN,
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 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 divorce is indignities or irretrievable
breakdown of the marriage, you may request that the court require
you and your spouse to attend marriage counseling prior to a
divorce decree being handed down by the court. A list of
marriage counselors is available in the Office of the
prothonotary at the cumberland county court House, Carlisle. You
are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to
be borne by you and your spouse.
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 WHERE YOU CAN GET LEGAL HELP.
Court Administrator
One Courthouse square
Carlisle, Pennsylvania 17013-3387
(717) 240-6285
LAW O,l'lCIB
SNELBAKER
a
BRENNEMAN
SNELBAKER & BRENNEMAN, P.C.
By
f1)j)/I(~J
AttPrn s for Plaintiff
"
"
.'
NANCY L. HALLMAN,
plaintiff
IN THE COURT OF CoMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
CIVIL TERM
vs.
.
.
.
.
ROY DANIEL HALLMAN,
Defendant
: IN DIVORCE
~OMPLAIN'l'
1. The Plaintiff in this action is NancY L. Hall..n, an
adult individual, who resides at 2303 stumpstown Road,
Mechanicsburg (Upper Allen Township), cumberland county,
pennsylvania 17055.
2. The Defendant in this action is ROY Daniel Hall..n, .n
adult individual, who resides at 7B Richland Lane, Apart.ent 207,
Camp Hill, cumberland county, pennsylvania 17011.
3. Both the Plaintiff and Defendant have been bona fide
residents of the commonwealth of pennsylvania for at least six
(6) months immediately previous to the filing of this co.plaint.
4. The plaintiff and Defendant were lawfully joined in
marriage on May 20, 1994 in the city of Winchester, Virginia.
5. There have been no prior actions of divorce or
for annulment between the parties hereto in this or eny other
jurisdiction since the date of the marriage averred in paragraph
4, above.
LAW o,""CE.&
SNELBI\KER
a
BRENNEM^N
"
,"
.'
6. Neither party is a member of the armed forces of the
United states of America.
7. The plaintiff avers that the marriage between the
parties hereto is irretrievably broken.
8. The 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.
9. The Plaintiff requests this Court to enter a decree of
divorce.
WHEREFORE, plaintiff Nancy L. Hallman requests your
Honorable Court to enter a decree of divorce, divorcing the
plaintiff from the bonds of matrimony heretofore existing between
the plaintiff and the Defendant.
Respectfully submitted,
SNELBAKER , BRENNEMAN, P. C.
~)~
By: ( , '7tr-t
Phll P . S re, Esquire
44 West Main street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Plaintiff
Nancy L. Hallman
Date: November /7, 1995
LAW O"ICU
SNELBAKER
II
BRENNEMAN
-2-
LAW orr.en
SNILBAteER
a
BRENNEMAN
NANCY L. HALLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6568 CIVIL TERM
va.
ROY DANIEL HALLMAN,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
COUNTY
: ss.
OF CUMBERLAND)
Philip H. Spare, Esquire, being duly sworn according to law
deposes and says: that he is an associate in the law firm of
Snelbaker' Brenneman, P. C., being the attorneys for Nancy L.
Hallman, the plaintiff in the above captioned action in divorce;
that on December 12, 1995, he did send to Defendant Roy Daniel
Hallman by certified mail, return receipt requested, restricted
delivery, a duly certified copy of the Complaint in Divorce which
was filed in the above captioned action as evidenced by the
attached cover letter of the same date and Receipt for certified
Mail No. P 115 697 467; that both the Complaint and cover letter
were duly received by Roy Daniel Hallman, the Defendant herein,
as evidenced by the return receipt card for said certified mail
dated December 28, 1995; that a copy of the aforementioned cover
letter dated December 12, 1995 is attached hereto and
incorporated by reference herein as "Exhibit A" and that the
original Receipt for Certified Mail and the Domestic Return
5NELBAKER. a BRENNEMAN
A PIlOfUIIQNAL COQOaATION
^1T01'NM ^T lAW
.. WUT MAIN sTUaT
MECHANICSIlURG. PENNSYLVANIA 17055
~~ C. 1NII.II-.DP
IlII'IH 0. _
~ H. IPAAI
717.ew'aN.
p, 0. _ 318
'ACSIMlU 0l1l ew.lUI
December 12, 1995
, Iloy Dani.l Ballun
230 South front street
ApartMnt 1
Woraley.buz'9, PA 17043
Dear 1Ir. H.llun:
Pl.... note thi. tim'. r.pr..entation of Haney L. Ballaan.
Inclo.ed tor .ervice upon you i. a certified, true and correct
copy of a coapl.int in Divorce, the origin.l of which b.. been
filed in the Court of Co_on Pl... ot CII-"u'land County,
Penn8ylvania.
In the .vent you are repr..ented by an .ttorney, I reque.t
that you instruct your attorney to contact .. .. .con .. po..ible
to di.cua. thi. utter.
Very truly your.,
Philip H. Spare
1'1I8/..
Inclo.ur.
Vi. certified uil, re.tricted delivery, return
rec.ipt requ..ted, P.rcel Ho. Z 115697 467
CC: H.ncy L. H.llman
EXHIBIT ^
z US ...,7 L...7
~ Receipt for
Certlfted Mal
Na IllOUI_O CovorOQO Provldod
__ Do nol _ 101 lntornotlono' Moll
18.."..._1
'''lily Daniel Hallman
""'"
s.
CIIIIlI..clFH
PA 17043
. , _-S~
1.10
Il*lel~yf..
""lI'ICWd D.h.-rt' f..
2.75
1.10
~... ~=::....-- ','
\ I'.~!!"'-_."-""_._---"
I" =~....~_..........."""""'-"
\ '. .I!!!I.,J~llllll!ltl""'.""""'--"""-
\1 ~,~.....-......~--_..-
\1
...............
II. ....... (IIr III '
-.,... '.'"
t.e U!I ......(
..lRliu 1....,; ,
0IMllI' .' . ......,' ,
Z 115697 467
auy Daniel Hallun
230'South Front Street
Al\arcMnt 1
WonJ,eyeburl. PA 17043
LAW O,'IC18
8NILDAKE"
a
"RINNIMAN
--
D 1'. J" .. II ClIIlIIIII
D ........ D .....'
D.....-...Ib..h.... D 0ClD '.
I
I.
r:::
. DI J ..... ,..
EXlllBlT B
~ en ....
<:) L;
~ .N ~11
~9-
[' ,'"~ C.J
IC- :--.. .i
() ,.,
,.,
0- N
I" ~.. \ ~. ~"
-,' ,
I" !'..-
.-
11, ',n ::;
u C" U
tr. CJ "..
("', \--:
i2-: M --)~
Ulr--:: -I:-~
0'- .):':~
EEc. ' "j~
-, ~
~~- C;) ,"en
r.. 1-'
.' I '-~:
EEl' (,.- tt1(O
,~~. C? 0-
, '1~
,. ..-:
1.1. ..n :.'
0 01 L)
. .
. . "
NANCY L. HALLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6568 CIVIL TERM
IN DIVORCE
v.
ROY DANIEL HALLMAN,
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(C) of the
Divorce Code was filed on November 17, 1995. Defendant was
served with a copy of the complaint on December 28, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the complaint.
3. I consent to the entry of a final decree of divorce
after service of notice of intention to request entry of the
decree.
I verify that the statements made in 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
falsification to authorities.
Date: March!J.9, 1996
llIaJUII ;/ IIrlll)l1(I~v
~ancy L. Hallman
(plaintiff)
LAW O,.,ICU
SNELBAteER
a
BRENNEMAN
~ - f.;
.<t ("") :j~
"'" ,-
f M ") ....~
..,- .J;'"
C- ,:j
'-
L, o:J "\:n
(' ~,~. ~.z"
~ , ..1.._
t ,: :,Y
-Il' c;;. '.!l~Q
~ ;iH~
r..:.:', .....;
l',. ..0 :.'j
I,.) ell C.)
.~t1!,,~~~:'?t~~f"',~4.'",,:
. . .
. . .
NANCY L. HALLMAN,
plaintiff
IN THE COURT OF COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6568 CIVIL TERM
IN DIVORCE
v.
ROY DANIEL HALLMAN,
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY or
A DIVORCE DECREE UNDER 5 3301(C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that T may lose rights concerning alimony,
4ivision of property, lawyer's fees or expenses if I do not claia
th.. 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 mad.
subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn
falsification to authorities.
Date: March..?9 ,1996
dMt~ Jf ~~
ancy . Ha man
(plaintiff)
LAW a,,,CI.
SNIl..8AKER
a
BRENNIMAN
',t,
,
f,
\
.~
.,
.... N ....
f~ C'. ~ ..:
i:-:= ih -"i ...
'{5~' ~'~I ;~1
".
.- ..)....
If.' .;::
r' ,,- ';..I
qi- ' -
(f.l , tJ)
r" ',~ ".
lB'. I .~~
\ ~. "\(Q
0:.\. (.~
c.'.~ ~p....
I' ..- '.5
p. ,"
U G' U
"
.
. ., ..
. . ,
NANCY L. HALLMAN,
plaintiff
:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6568 CIVIL TERM
IN DIVORCE
.
.
v.
ROY DANIEL HALLMAN,
Defendant
AFFIDAVIT OF CONSEN~
1. A complaint in divorce under Section 3301(C) of the
Divorce Code was filed on November 17, 1995. Defendant was
served with a copy of the complaint on December 28, 1995.
2. The marriage of plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the Complaint.
3. I consent to the entry of a final decree of divorce
after service of notice of intention to request entry of the
decree.
I verify that the statements made in 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
falsification to authorities.
[late:
April I , 1996
~
AQ~~
Roy Dan el aUman
(Defendant)
LAW O,.,.,cn
SNIH.BAKER
a
BRENNEMAN
"
~ 0 --
C"? I..
~ M r~.:1:
~Q '. ):.:;...
~K'. ~ '.J ~~
0: '\;:J
c ' --
&: ro -.t...,
I ..~I ;;..:
,'.- ~'i
a:\,', C~ t "Iitl
r:: 0- i.I~U.
~
It_ \.0 ::1
0 '" U
,
... .
'. -"""""'"' "...."'..,-.."."'..."""~_.~'.,."'-"..'.......'~...4i~~'.
. ,t ..
. . .
NANCY L. HALLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6568 CIVIL TERM
IN DIVORCE
v.
ROY DANIEL HALLMAN,
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER 5 3301(C) OF THE DIVORCE CODE
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
falsification to authorities.
Date: April I ,1996
~D-.>f~
oy Daniel Ha lman -
(Defendant)
LAW O"ICU
SNILBAKER
a
BRENNEMAN
~, - --
c'?
r.; ., :\~;;
i~; .....,
.- -",
..'.j.
~' \'- .:~~
.."i:1
t:" c? ' ~'n
S1'- I };~~
i-7'; ,.- !"ltq
"'- I. ~ ..-
I': .'"~ :_i
" ,.r')
C) ~, U
~ .. .
.; ..
'-",,~. '''~'''',,'-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
.
.
.
.
NANCY L. HALLMAN .
.
plaintiff .
.
. File No. 95-6568
.
:
VS. . IN DIVORCE
.
.
.
ROY DANIEL HALLMAN .
.
.
.
Defendant :
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
9th day of APRIL , 19 96 , hereby elects to resume the
prior surname of NANCY L. KRAMER , and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE:~
/1, /f~~
,
JaM:!-;f fA, LtmtJAN
Signature
~)ahl/:t ,f JpA~
signatu of name being resulIl8d
COMMONWEALTH OF PENNSYLVANIA:
: 55.
COUNTY OF CUMBERLAND
.
.
On the II-r;/... day of /).I:M~",,- , 19.2&..., before me, a
Notary Public, personally appea;~-th; above affiant known to IIl8 to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
In Witness Whereof, I have hereunto set my hand and official
seal.
9~.u Q,~;,J
Nota y Public
NoliUlal Sunl
PoInd. J Thomao, Nolary PublIC
w'ochllnlcsburg Bora, Cumberland County
My Commis51on E.p1ros Doc. 3\. 1990
~'''rt)l''. Pt>"rl:;"'t:'.!t1A.~~i"" uI t-1.'lf""'1.\