Loading...
HomeMy WebLinkAbout95-06744 ~ 01' ~ . f' ~ -- d (,.. ~ ~ J -:::r T r- ..j ~~..~. 'leCO ... .....-:q{f......:_... .. . ........ .':_>llI<___:.::~__~ ~ .. $ IN THE COURT OF COMMON PLEAS g $ . $ OF CUMBERLAND COUNTY ~ ~ '* . ~ -. ~ STATE OF ".' : PENNA. I ~ . 8 ~ a......................................... ................... II 95 6744 96 g :MIND!S,ST~;::mm I' No, ........:..m..... ,mm_,_19 , I :....~~~~~~~>.~..~i~~~~.~.................:::::..... I ~ ~ ~ $ ~ $ DECREE IN i : DIVORCE : ! AND NOW, . . ..;:r ~ e....I.Z-.. . .. .. . .. ., 19.1.<... It is ordered and S ~ ry v I :.~. ~ decreed that ..~~~P.X.l?: ..~~I,t!'.I.:~~ .. .. .. .. .. .. .. .. .. . .. .. .. .. .. p aintiff, ~ and .... .n:.F:~~J;::t..~, . ~.'l:Il~~~.Y.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ... defendant, $ are divorced from the bonds of matrimony. $ w ~ 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; ~ ~ ..' s THAT TERMS OF THE SETTLEMENT AGREEMENT DATED JUNE 3 ..1996. c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I. . . . . . . . . . . , .BE. 1.NCORP.ORlITED .lIND .NOT. .MERGED. IN.'CO. THE . DIYDRCE~. . . . . . . . . . . . .. . . . .~ ~ ~ Dy The Court: /J 'f.L . ~.. t//e-.K~..O~. ..... ....... Allest: ..... IJA <" /J ~ J. .....,.-...~ <:.. . [!(, /.:'1.l! ".......7 ~.t.le~, ~.... .. ...... I #TT Prolhonolary ~ ~ fo' ~ ~ .' ~ ~ ~ i:l ~ .. - - - - - '.- - - - .. ~>...;. ~:c-' -:<<. .~:. .:.:. .:. . ., ~__,__~_..__..~.__.~.~..,_ ,.".. ~..._._~._______.____.~--........._..........-.....~_...~~ '~__",.~ IV. .. .:.:. .:e:. .:.:. .:.:. .:~ .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .=-:. -:.:- .:to:. .:.:. .:.:. -:.:. -:.:. -:.:. -:.:. .:to:.' ~ ... ~ ., .. ~ ~.: ~ ~ ~ ~~ ~ w ~ ~ S 8 ~ ~ s * '.' ~ ~ .', ~ .-, "",-'~<('-~.'- ..'iI.. {".'....,"', ;"..".. . ~:;.;...., -' . "--",." .~~-. .. ".on . ~ ./(/.ft1 &4- @/j' ~ rt -4 4~ ~/f/~ ~ /t(~ ~ 4 ~4 . '../ . " ;r,i THIS JlGRBBIfBN'l' made this r-;J doy o,~ STRALEY, heref fter called "Wife", ... ~ . . IN THB COUI(}.' OF COHIION PLEAS CUMBERLAND COUNTY MINDY S. STRALEY V. JBFFREY L. STRALEY DOClCB'l' NO. 95-6744 CIVIL TBRN - AC'l'ION IN DIVORCB MA.RXT.A T_ SETTT.R_ENT AGRR7l!MENT 1996, by and between MINDY S. AND JEFFREY L. Stral.ey, hereinafter called "Husband". JiI'l'NBSSB'l'H: JiHBRBAS, Husband and Wife were married on September 3, 1988 in Adams County, Pennsylvania; and JiHBRBAS, no children were born of this marriage; and JiHBRBAS, certain differences have arisen between the parties as a result of which they separated on May 10, 1995 and are desirous, therefore, of entering into an Agreement which will distribute their marital property in a manner which is considered to be an equitable division of all joint property, and will provide for the mutual responsibilities and rights growing out of the marriage relationship; and JiHBRBAS, there has been a complete disclosure of the earnings and property of each party, and each understands his\her rights under the Divorce Code of the Commonwealth of Pennsylvania; and ....~.~.....,,""" ",'..-.....-..........,-..--. 4, " WHEREAS, the parties hereto, Wife having been properly advised by her attorney, Lawrence J. Rosen and Husband having been property advised by his attorney, John J. Connelly, Jr., have come to the agreement which follows. The parties heretofore, intending to be legally bound, covenant, promise and agree as follows: 1. CONSIDERATION. The consideration for this Agreement is the mutual promise, covenants and agreements herein contained. 2. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart. 3. NO INTERFERBNCE. Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. 4. COUNSEL FEES. A. Husband and Wife agree that each shall be responsible for their own counsel and hereby waive any claim for counsel fees that one may have against the other. 5. SUPPORT. The parties agree to waive any rights to support which one may have for or against the other. 6. ALIMONY. The parties agree to waive any rights to alimony which one may have for or against the other. 2 '" .. 7. fiAlVBR OF PBNSION BBNBFI'l'S. Husband and Wife agree that each shall execute any documents necessary to release and waive forever any right, title or interest each party may have in the other party's retirement plan (which is defined to mean pension, profit-sharing, or any other plan or account or retirement or deferred income). Each party agrees to execute whatever documents are required to effectuate the purpose of this paragraph. Each party appoints the other as attorney-in-fact for the purpose of consenting to any election under any plan under Section 417 of the Internal Revenue Code or Section 205 of the Employee Income Security Act of 1974. It is specifically agreed that each party's rights under their respective retirement plans constitute their own separate property. 8. fiIFB'S DBIfl'S. Wife represents and warrants to Husband that since the separation she has not and in the future will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 9. HUSBAND'S DBIfl'S. Husband represents and warrants to Wife that since the separation he has not and in the future will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 3 .... ,. 10. OUl'S'l'ANDING DBBl'S. The parties acknowledge and agree that they have no outstanding debts or obligations incurred prior to the signing of this Agreement other than those specifically referred to in this Agreement. 11. REAL ESTATE. The parties acknowledge that they are the owners of certain real property located at 4708 Linden Avenue, Hechanicsburg, Pa. 17055. The parties agree that said real estate shall be listed for sale by a realtor chosen by mutual consent. Husband agrees to be responsible for any and all ongoing expenses related to said property until time of sale. Upon sale, the net proceeds therefrom shall be shared equally by the parties. The parties further agree that in the event capital gains tax is due and owing pursuant to the sale of the subject property, they will assume said burden equally and agree to indemnify the other in the event that Husband or Wife fails to pay his or her share of said tax liability and the other party is assessed thereon by the Internal Revenue Service. 12. DIS'l'RIBV'l'ION OF TANGIBLB AND IN2'ANGIBLB PROPBRTY. A. Household Prooertv. The parties hereto mutually agree that they have effected a satisfactory agreement as to tho division of the furniture, household furnishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and after date hereof be in the interim possession of 4 '" .. all such tangible personal property presently in his or her possession with the exception of the household property remaining in the mar! tal residence. The parties agree that the property remaining in said residence belongs to Husband with the exception of the property listed in Exhibit "A" which is attached to and expressly made a part of this Agreement. The property listed on Exhibit "A" belongs to Wife and upon sale of the marital residence, Wife shall be entitled to recover said property at her earliest convenience. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of ei ther party, which are now in the possession and/or under the control of the other with the exception of the property listed on Exhibit "A". Should it become necessary, the parties will agree to sign, upon request, any title or documents necessary to give effect to this paragraph. property shall be deemed to being the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of the Agreement with the exception of property appearing on Exhibit "A" and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar 5 .. .. writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which wither party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits during the period of separation, except as stated herein or subsequently agreed upon in writing. B. Intanaible Pronertv The parties acknowledge that Husband has accumulated 160 shares of GME stock during the course of their marriage of which 80 are restricted shares. Husband agrees to take all necessary steps to transfer ownership of 80 of aforesaid shares to Wife. Wife shall receive 40 shares of the restricted and 40 shares of the non- restricted shares of the stock. Said transfer shall be effected prior to the issuance of a Decree in Divorce. c. Autollobiles The parties agree that Wife shall retain ownership of a 1995 Pontiac Firebird. Wife has refinanced the indebtedness on said vehicle in her own name and expressly agrees to hold Husband harmless for any costs and expenses related thereto. 13. TAX RBTURNS. Both parties agree that they shall file individual federal tax returns for tax years 1995 and 1996. Husband and Wife shall pay all tax liabilities and/or receive all 6 4. '. refun~s associate~ with such fe~eral tax returns. The parties shall be responsible for their own state and local tax returns and any other tax liability for 1995 an~ 1996. 14. HU'rUAL CONSBN'l' DIVORCB. This Agreement shall operate as a full an~ final Settlement Agreement concerning all marital rights of both parties in accor~ance with the terms herein. The Parties hereto agree that each shall contemporaneously herewith sign an Affi~avit of Consent to a divorce pursuant to Section 3301 (c) of the Divorce Code and a Waiver of Notice of Intention To Request Entry of a Divorce Decree Under section 3301 (c) of the Divorce Co~e. Counsel for Wife shall prepare and promptly file the parties' respective Affidavit's of Consent, waiver, a praecipe to transmit record, and a vital statistics form, all for the purpose of obtaining an immediate Decree in Divorce. 15. TIHB OF DISTRIBUTION. The assets an~ interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective parties immediately upon the execution of this Agreement unless otherwise provi~e~ herein. The parties shall cooperate by executing whatever documents are necessary to effectuate a divorce under 3301(c) or 3301(d) of the pennsylvania Divorce Code, and this Agreement to cooperate shall be enforceable by an assumpsit action for specific performance. However, upon refusal to consent, all distributed property shall be returned to the party originally in possession, until the time of final decree. 7 . . 16. RBLBASB. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release, indemnify (including actual legal fees) and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, including equitable distribution, spousal support, alimony, counsel fees, alimony pendente lite, and expenses which either of the parties against the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or under any other statutory or common law, except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling, pursuant to 3302 of the Divorce Code. 17. fiAIVBRS OF CLJUHS AGAINST BSTATBS. Except as herein otherwise proviaed, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and any right 8 . '. existing now or in the future under the pennsylvania Divorce Code, as amended from time to time, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 18. RIGHTS ON BXBCUTION. Immediately upon the execution of this Agreement, the rights of each party against the other, despite their continuing marital status, shall terminate and be as if they were never married. 19. BRKACH. In the event of breach of any of the terms of this Agreement, the non-breaching party shall be paid, as part of any award or judgment against the breaching party, all costs, including actual counsel fees paid to or owing to his or her attorney. 20. INCORPORATION INTO FINAL DIVORCE DECREE. 'lhe teruB of this Agreement shall be incorporated but shall not merge into the final divorce decree between the parties. The parties intend that this Agreement shall be enforceable under the Divorce Code of 1980 , as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. 21. ADDITIONAL INSTRUHENTS. Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party, any and all further instruments that 9 .. may be reasonably required to give full force and effect to the provisions of this Agreement. 22. SBPARABILITY. In case any provision of this Agreement should be held to be contrary to, or invalid under, the law of any country, state or other jurisdiction, such illegality and invalidity shall not in any way affect the other provisions hereof, all of which shall continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate and undisputed covenant and agreement. 23. BN'l'IRB JlGRBBHBN'l'. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants and undertakings other than those expressly set forth herein. Husband and Wife 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 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 section 3502 of the Divorce Code or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court 10 . . 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. 24. HODIFICA!l'ION AND WAIVBR. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 25. IlI'PBlI'J.'. It is the intent of the parties by this Agreement to fully and finally foreclose any resort to the courts for relief on the basis of any statute or case law presently existing or which may exist at some time in the future within the Commonwealth of Pennsylvania, including but not limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended. This Agreement has been drafted and accepted on the basis that such resort would constitute a breach under this Agreement, entitling the non-breaching party to reimbursement for actual counsel fees. Other than as provided by the terms of this instrument, it is intended that the court shall treat the parties as if they had never entered into a marital relationship. This Agreement shall be interpreted and governed by the laws of the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms of this instrument shall govern. 11 . 26. VOLUBrARr BKBCVTION. The provisions of this Agreement and their legal effect have been fully explained to Wife by her counsel, Lawrence J. Rosen and to Husband by his counsel, John J. Connelly, Jr. and the parties agree that the instant Agreement is 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 which has been requested by each of them and/or by their respective counsel. 27. DESCRIP'l'IVE BEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 28. J/GRBBHBN'l' BINDING ON BEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto, and their respective heirs, executors, administrators, successors and assigns. 29. RBCONCILIATION. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. 12 , " IN JiI'PNBSS JiBBRmF, The parties hereto have hereunto set their hands and seals the day and year first above written. JiI'PNBSS: Jif~=- 13 " ." . . , RXIIIBIT "A" 14 Property Currently Located at 4708 Linden Avenue, Mechanicsburq, Pennsylvania, to be Returned to Wife Upon Sale: A. Dininq Room 1. China Cabinet 2. Hutch/Server 3. China Dishes B. Family Room 1. Desk 2. Copper Pot 3. 1/2 of Indian Pottery C. Spare Room 1. Bookshelf 2. Treadmill D. Miscellaneous 1. Doq Portrait . 2. Bathroom "Shell" Pictures H E-o en Z Z ~ ~ !il ! ~ III l1. >< III en II: ~ Z Z l.? 1ii:5 0 z 0( III ~ III E-o 11-I ..... ~ ~~ l1. E-o 11-I ><C . Z ~ ..... III III U >< III H ><.... ~'tl !iUI -~ E-o :E > talC <c z III H ~.... II:lU 0 ::J ~ U <Ill E-oII-I 0 E-o lI:o-i . enlU r.~. E-o U Eo< ... E-ol1. > Cl II: III ... en . '::J Cl en ... ~ < s::> 0 Z \0 . ::llll u < ~ I en >< ;;: ~ < III III ~ tal II: E-o '" >< II: :c III H Cl ~ E-o III II: . Z ~ ~ ;j 0 H III Z Z :E .., H U . . . . . . WN^1J..SNN3c1 }J.Nn01 O'!.nl'=lm'l(K) CO I~ \-Ie! g-Imr 96 ~.l.ONOHJC.dj :!dJ.:IO 3OI:J;l~' . I' 1~~; !iUI l~zir::: ;,: ~m ~ .. . '." l.j '. ,..' . ~. ...j .. ~ . IIINDY S. S'l'RALBY, PldntiU IN THB COUR'l' OF COIIIION PLBAS OF CUIIBBRLAND COUN'l'Y, PBNNSYLVANIA NO. 95-6744 CIVIL TBM CIVIL ACTION - IN DIVORCE v. JEFFRBY L. S'l'RALBY, De1'endlJJJt PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section (x\ 3301 (c\ ( \ 3301 (d\ (1\ of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complnint: ,. L'" ~. , November 29, 1996 Certified Mail ! r ~ r'''. j;, '. (8) (01'_. .. ";~equired by Section 3301 (c) of the Divorce Code: by the Plaintiff " l ~ I.: i) . bn June 3, 1996; by the Defendant on Mav 31. 1996. ",-3. ,(Complete either paragraph (a) or (b)). , . Date of execution of the affidavit of consent & waiver of (b)(l) Date of execution of the Plaintiff's affidavit required by Section 201 (d) of the Divorce Code: HLA. (2) date of service of the Plaintiff's affidavit upon the Defendant: 4. Related claims pending: Reauest that terms of Settlement Aareement dated June 3, 1996 , and executed bv the Darties be incorDorated and not meraed into the Divorce. 1- ~. 5. Date and manner of service of the notice of intention to .:i Y'.' file praecipe to transmit record, a cOfY ich is attached. . , Rosen, Esquire for Plaintiff (X) Defendant () CO) ~ C) .. ~ :lC ~ ~ ~ &D ! ... , ~ ~ ~ ~ '. , . . v. IN THE COUR'l' OF COIIHON PLBAS OF CUHBBRLMID COUN'l'Y, PBNNSYLVANIA NO. 15- 6. 1'1 '1 {J~t. ,j L-t-w'- CIVIL ACTION - IN DIVORCE HINDY S. S'l'RALIfY, PlaintUf J'BFFRBr L. S'l'RALBY, 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 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 marriage counseling. A list of marriage counselors is available in the Office 01' the prothonotary, First Floor, Cumberland county courthouse, carlisle, Pennsylvania 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 . COURT ADMINISTRATOR CUMBERLAND COUNTY COURHOUSE, 4TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 . , "INDY S. S'l'RALBY, Pla.1nt11'f IN THE COIJgr OF COIIIION PLBAS OF CU"BBRLAND COUN'l'Y, PBNNSYLVANIA NO. 9S. (.7'1'/ ~ r~ v. J'BFFRBr L. S'l'RALIfY, DerendlJJJt CIVIL ACTION - IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (Cl OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Mindy s. straley, by her attorney, Sanford A. Krevsky, and seeks a Decree in Divorce and related relief from the Defendant, and in support thereof, sets for the following: 1. Plaintiff is Mindy s. straley, a citizen of Pennsylvania, residing at 1072 Lancaster Blvd. Apt 8, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey L. Straley, a citizen of Pennsylvania whose primary residence is 4708 Linden Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are w.U. ;uris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. The parties are husband and wife married on September 3, 1988 Pennsylvania. 5. The marriage is irretrievably broken. 4. and were lawfully in Adams county, 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Curt require the parties to participate in counseling. , , COUNT I. Rsouest for Bauitable Distribution of MlJrital Procert:v Under 3104 and 35021a\ of the Divorce Code 8. Paragraphs one through eight are incorporated as if fully set .forth herein. 9. Plaintiff and Defendant have acquired tangible personal and intangible property during their marriage from the date of said marriage until the date of their separation. 10. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests the Court to equitably distribute the marital property of the parties, pursuant to 3104 and 3502(a) of the Divorce Code. Respectfully SUbmitted, DATE: NOll ~',.., '1/' ren J. Rosen, Esquire ttorney for Plaintiff 1101 North Front Street Harrisburg, pa 17102 ID # 10625 (717) 234-4583 , , v. IN TBB COUR'l' OF COIIIION PLBAS OF CU"BBRLAND COUN'l'Y, PBNNSYLVANIA NO. CIVIL ACTION - IN DIVORCB "INDY S. S'l'RALBr, Pldnt.t1'1' J'BFFRBr L. S'l'RALBr, De1'endlJJJt VERIFICATION I, MINDY S. STRALEY, hereby verify that the information contained in the foregoing Petition is true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa, C.S. S 4904, relating to unsworn falsification to authorities. DATE:~j.l2-7, {~ . , . "INDY S. S'l'RALIfY, PldntiL1' : IN THE COURP OF COIIIION PLBAS OF : CU"BBRLAND COUN'l'Y, PBNNSYLVANIA . . v. : 110. . . JBFFRBr L. S'l'RALIfY, De1'endant : CIVIL ACTION - IN DIVORCE . . CERTIFICATE OF SERVICE AND NON, this ~1 day of November, 1995, I, Lawrence J. Rosen, Esquire, of Law Office of Sanford A. Krevsky, attorney for Plaintiff, MINDY S. STRALEY, hereby certify that I have this day served a copy of the Complaint in the above-captioned matter, by First Class U.S. Mail on the following: JEFFREY L. STRALEY 4708 LINDEN AVENUE MECHANICSBURG, PA 17055 ~~..n, ....ir. 1101 North Front Street HarriSburg, PA 17102 (717) 234-4583 Attorney for Plaintiff U"'l ~ .'- t: ,- ..I't- . ;.--- U.l,_ ",:' 4. ~: =_r.,-~ I~~" \.';t h..-::I. ,',"_. O,~- r,I " .......-- "._.r'. ~"1 ~:l' >( ;.r _1...l..I..e Il'-'J I. :.tn.. ,......J :;';J(,.) = "- o <;> ~ CM '''-1 ".. _C> ..:::: , ' \ ' je, \ '<") '0 'C"'l ~~ , ~ ~ ~ ..... ;t;; , '::J<J ....... " ~ ~ ~ .... l. t; ~ .-.I ~ "'l"" <'("') ~ r-- ...., VO ~ c--..~\ '::-'. c:J ~~ H Z en< <> t>l..:l :E ..:1>< II: l1.en H l:l z~ < ~ ZIIl o tal' U ::J:e ~l1. Cl IIlE-o ! ~ o . ~ 1i!~ U>< ~~ c 00 ~ I! 0::> Z >~ 11-I . E-oO !:l H U .11-I ~.... Cl- >< 'M ~C II:U III Z.-<1Il ~~ ~~ ::Jel C HOCl !i ~~I 8~ 0 MO ~'M E-oC E-oMU E-o~ . III~ ..:I E-o Z > t>lll: enl1. lU j ~ z gF: :elll III III HZIIl 'Cl E-olD UE-o <OU . ~ ;,: s::> ~HII: Z~ H:C l1.E-oO en >< Iii ::ll!! E-ol.? :EU> >< !:l t-tU OH OIllH ~ i ZII: . Cl UUlCl 0 Z f<. Z H ~ :E III .., - . . ,., , ., . "INDY S. S'l'RALIfY , . IN THE COUR'l' OF COIIIION PLEAS OF . pldntiU . CU"BBRLAND COUN'l'Y, PENNSYLVANIA . . . v. . NO. 95-6744 . . . JBFFRBr L. S'l'RALIfY , . CIVIL ACTION - IN DIVORCB . De1'endant : CERTIFICATION OF SERVICE I, Lawrence J. Rosen, Esquire, attorney for the plaintiff, Mindy s. straley, hereby certify that a copy of the Complaint for a Divorce was served by Certified Mail, Return Receipt Requested on DECEMBER 6, 1995, on the following: JBFFREY L. STRALEY 4708 LINDEN AVENUB MBCHANICSBURG, PA 17055 DATE: :1 -1,/-"( re e J. Rosen, Esquire A torney for Plaintiff 1101 North Front street Harrisburg, PA 17102 (717) 234-4583 Atty. I.D. NO. 10625 ._.,.,;.;..t,,",";i:'_{"~':-"'!:~;;"':.""~';";';"'<5~i:t~~~~~.t\"r'~~i4,'7!>~'i#~~~ ( , { { ~ -- 0 r.. ~-."" ~0 .. ~'::i . .:r ~.!..~ {;! - ,~.~ ~~J ~. Q.. " f" ,.ft! ..;,.; I ~~:!..~ . .,.' :r.:~ _11' r.~ C-;"j u:.. ":;": , ..\t:- r .. '. ..~... U. ~O ::> 0 00 U " ,. . " . "INDY S. S'l'RALBY, . IN THB COURl' OF COIIIION PLEAS OF . Plaintif1' . CU"BBRLAND COON'l'Y, PBNNSYLVANIA . . ~744 ~ . yo- v. . NO. . : JBFFRBr L. S'l'RALBY , . CIVIL ACTION - IN DIVORCB . De1'endlJJJt . . AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 29. 1995 , :3. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of co. r, 'filing the Complaint. ~. ~ ~: > l~, ,', :l'ialimony, division of property, lawyers fees or expenses if I do not I .. I consent to the entry of final decree of divorce. .' :4. I understand that I may lose rights concerning ~" blaim them before a divorce is granted. 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. ~ 4904 relating to unsworn falsification to authorities. "T'c!F' c:z /9U 4' "_"'-''',~,,~,':'., ~ &D ~~ I ffi~ ~ ~ ~Q; l:5 ~ 0 -...:-.:<".." ;.' . .. . , .' . I .. . . " . "INDY S. S'l'RALIfY, Plaintiff : IN THB COURl' OF CO""ON PLEAS OF : CU"BBRLAND COUN'l'Y, PBNNSYLVANIA . . v. : NO. 95-6744 CIVIL TBRH . . JBFFRBr L. S'l'RALIfY, De1'endlJJJt : CIVIL ACTION - IN DIVORCB : WAIVER OF NOTICE OF INTENTION TO REDUEST ENTRY OF A DIVORCE DECREE UHDER SECTION 3301 (cl OF THE DIVORCE CODE (-', j, , . ." , 1. I consent to the entry of a final decree in divorce rt . . . \ fiwithout notice. - < . &~ ' Ii; ; 2. ~ understand that I may lose rights concerning alimony, "~ivIsion ~f property, lawyer's fees or expenses if I do not claim . 4-' \-, I ) 'them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered bj 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 18 Pa.C.S. Section 4904 relating to unsworn flasification to authorities. DATE' Ju..u. 3. I 9, b [}r~ ~ CO) ~ I~~' ~ ~~ - C>- D '.. ft '? ~ :g ill ~I "- \D ~ (.:) a> U . . .. . . .' . . . I . . . I . "INDY S. S'l'RALBY, Pla1nti~f : IN 'l'HB COUR'l' OF COIUfON PLEAS OF : CU"BBRLAND COUN'l'Y, PENNSYLVANIA . . v. : NO. 95-6744 CIVIL TERN . . JBFFRlIY L. S'l'RALBY, De1'endlJJJt : CIVI,r, ACTION - IN DIVORCE . . AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301 (c) of the Divorce Code was filed on November 29. 1995 . 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of (, .., ) ~'filfng the Complaint. I consent to the entry of final decree of divorce. " ':' . 3. I " , r" 4. . . c-, ,. .aliiiibny,' division of property, lawyers fees or expenses , 4_- 'c1ai~ them before a divorce is granted. I understand that I may lose rights concerning if I do not I verify that the statements made in this Affidavit are DATE: d, 31, /?9b ..-::!. y true and correct. I understand that false statements herein are made sUbject to the penalties of 18 Pa.C.S. !i 4904 relating to unsworn falsification to authorities. s C") fi Q M ..:z gf :t: a.; ~: U) ., , ,.;j ~ [~ t's ~ ~ . .. . , , " '>"""""~"'-t;.""---''';-",.''''.~-.;,;,~.......~l...."".~ \, I ., . '--~"~-'''''';''''''","",Ili<"W.;tp..... *.Ii......,i-~.,-__".. . .. . . , . "INDY S. S'l'RALBY, Plaint1r1' IN THE COUm' OF COIIIION PLEAS OF CU"BBRLAND COUN'l'Y, PBNNSYLVANIA NO. 95-6744 CIVIL TERN CIVIL ACTION - IN DIVORCE v. JEFFREY L. S'l'RALBY, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C\ OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. ( .. 2.) .' ",' , I understand that I may lose rights concerning alimony, r;. [,/: ~'. Fi: }; '. . - division1of property, lawyer'S fees or expenses if I do not claim them before a divorce is granted. , '"w 3." I understand that I will not be divorced until a divorce I ~~de9fee 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 18 Pa.C.S. Section 4904 relating to unsworn flasification to authorities. DATE: J'!~ 3~ /;?C ~~-' ., ~ C") ~ C) I~ .. g~ .;z :lC a.. CI ::1 g &D ~5m I ~ !; en '1] l5 \0 a Ol ;. J: " r~ ^ ::~; ~j ';J :! l! d '>l ,1 t~. . . . . . .. . .,..-.,'." .~.,,-;~........"""; . ",."',y, '. -"",'