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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '~~I PENNA.
KATHY L. SMITII,
PLAINTIFF
i\: II. 7356
" II) 95
"IT-II
KIRBY L. SMITII,
DEFENDANT
DECREE IN
DIVORCE
. {1+-.4. ,.I 'J <-
KATHY L. SMITH
KIRBY L. SMITII
'. 19 '1~ '. II Is ordered and
. ...., plalnllff,
. '. delendanl,
AND NOW, . .
decreed thai
and.. .
are divorced Irom the bonds of matrimony.
The court retains jurisdiction 01 the lollowlng claims which have
been raised 01 record in this action lor which a final order has not yet
been entered;
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PROPERTY SETTLEMENT AGREEMENT DATED MAY 20, 1996 IS
INCORPORATED INTO, nUT IS NOT MERGED WITII, TillS DECREE
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KATIIY I,. SMITII, I IN '1'IIK COUR'l' OF COMMON PLEAS O~'
Plaintif f I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No. 95-7356 CIVIL TERM
I
KIRBY L. SMITII, I CIVIl. ACTION - LAW
Defendant I IN DIVORCE
PROPBR'ry SUTTI,HMHN'l' AGllUllMUNT
This Agreement, made on ths latest date subscribed hereto,
by Kathy L. Smith of 1738 HcClure's Gap Road, Carlisle,
Cumberland County, Pennsylvania 19013 (hereinafter referred to as
"Wife") and Kirby L. Smith of 309 Bobcat Road, Carlisle,
Cumberland County, Pennsylvania 17013 (hereinafter referred to as
"lIusband"), witnesses thatl
WIIEREAS, the parties hereto are lIusband and Wife, having
been married on September 12, 1986 at Carlisle, Cumberland
County, Pennsylvania I and
WHEREAS, the parties warrant that there are no dependent
ohildren to the marriage, and
WHEREAS, dif ficulties have ar laen between the parties as a
result of which they now desire to live separate and apart and by
tide Agreement to settle all finanoial and property rights
between theml and
WIIERIlAS, in preparing this Agreement and negotiations
contemporaneously therewith, Wife was represented by Matthew J.
Eshelman, Esquire, and lIusband was reprssented by Samuel I..
Andes, Esquire, eaoh of whom have given a full explanation of the
same to their respeotive olientsl and
WIIEREAB, the parties acknowledge that before signing thio
Agreement they have been fully advised by their respective
counsel of their rights and obligations, have read carefully and
understand the terms of this Agreement, and freely oonsent to
this Agreement, believing it to be fair, just, and equitable I and
WIIEREAS, the parties are satisfied that they understand the
value and extent of all property whioh would be considered
"marital propsrty" under the Pennsylvania Divorce Code, whether
titled or owned separately or jointly, as well as the value and
extent of nonmarital property held or expected to be held by eaoh
other I and
NOW, 'rIlEREFORE, in considerdtion of the mutual promises and
undertakings set forth herein, and intending to be legally bound
hereby, the parties agree as followsl
1. M.ll1.Ya1 Separation. Husband and wife shall be free from
constraint or control by the other as fully as if he or she were
unmarried. Neither ehall disturb, trouble and interfere in any
way with the other or wilh any person for assooiating with the
other. Neither shall molest or attempt to molest the other, or
in any way harass or malign the other, or in any other way
interfere with the other's peaoeful existence, separate and apart
from the other.
2
This Agreement shall not be deemed to have been waived or
otherwise affeoted by a reoonoi1iation, cohabitation, or
resumption of marital relations between the parties. The parties
shall not be deemed to have reconciled with the intention of
vitiating or terminating this Agreement unlese they make such
aotions through a written instrument, executed, and acknowledged
in the same manner as this Agreement.
2. Mutual Release. Except as otherwioe provided herein,
lIusband relinquiohes hiD inchoate inteotate right in the estate
of Wife, and Wife relinquishes her inchoate intestate right in
the estate of lIusband, and each of the parties hereto by these
presents, for himself or herself, hill or her heirs, executors,
administrators or assigns, does remise, release, quit claim, and
forever discharge the other party hereto, his or her heirs,
executors, administratore or assigns, or any of them, of any and
all claims, demands, damages, actions, oauses of action, or suits
at law or in equity, or whatsoever kind or nature, for or because
of any matter or thing done, admitted or suffered to be done by
the other party prior to and inoluding the date hereofl further,
the parties acknowledge that all rights under the Pennsylvania
Divorce Code that arB not specifically incorporated herein are
hereby expreooly waived. Notwithstanding the foregoing language
of this paragraph, thia release shall in no way exonerate or
discharge either party hereto from the obligationo and promisee
3
made and imposed by reason of this Agreement and ehall in no way
affect any causes of action in divoroe which either party may
have against the other.
3. Effect of Divorce. Nothing contained in this Agreement
shall be deemed to prevent either party from pursuing a divorce
on the grounds permitted by law in this or any other
jurisdiction, nor to bar the other from defending any such suit.
In the event any such action is pursued or initiated, the partiee
shall be bound by all the terms of this Agreement.
4. Effect of Divorce Decree. 'l'his Agreement shall continue
in full force and effect after ouch time as a final decree in
divorce may be entered with respect to the parties.
5. Aareement to be Incorporated in Divorce Decree. The
terms of this Agreement shall be incorporated into any divorce
deoree, without being merged therewith, which may be entered with
respect to the partiee. The Court of Common Pleas which may
enter such divorce decree shall retain continuing jurisdiction
over the parties and the subject matter of the Agreement for the
purpose of enforcement of any of the provisions thereof.
6. Date of Execution. The "date of execution" or
"execution date" of this Agreement shall be defined as the date
upon which it is executed by the parties if they have each
executed the Agreement on the same date. otherwise, the "date of
execution" or "execution date" of this Agreement shall be defined
4
as the date of exeoution by the party last exeouting this
Agreement.
7. Debts. During ths course of the marriage, lIusband and
Wife have incurred certain bills and obligations and have amassed
a variety of debts. It is hereby agreed, without the necessity
of asoertaining for what purpose and to whose use eaoh of the
bills were incurred, that, except as otherwise provided herein,
both parties are equally responsible for all suoh bills,
obligations, and debts. lIusband and Wife each agree to hold the
other free and harmless from any and all liability which may
arise from any outstanding bills, obligations, and debts inourred
after the date of separation, and further agree to indemnify and
defend the other from any claim regarding same. Both parties
agree that, in the future, neither shall cause or permit to be
charged to or against the other any purchase or purchases which
either of them may hereafter mak<3 and shall not hereafter oreate
any engagements, debts, or obligations in the name of or against
each other.
8. )leal l'ropertv. lIusband agrees to transfer to Wife all
his interest in the marital residence at 1738 McClure's Gap Road,
Carlisle, Cumberland County, Pennsylvania 17013. Wife shall have
sole and exolusive possession of, and Husband shall if necessary
at any time make, exeoute, and deliver any and all documents in
the usual form oonveying, transfsrring, and granting to Wife all
5
of his right, title, and interest in and to the marital
residence.
9. Personal Proeertv. with the exception of thoee items of
personal property delineated in Exhibit "A" (Wife) and Exhibit
"B" (lIueband), which Exhibits are attached hereto and are
incorporated herein by reference, the parties have agreed between
themselves to a division of all household furnishings and
personal property which would be considered "marital property"
under the Pennsylvania Divorce Code. The parties further
acknowledge and agree that the assets in the possession of the
other spouse shall be that spouse's sole and separate property,
eaoh party hereto specifically releasing any claim he or she may
have with respect to such items. The parties agree that, as to
all assets not speoifically mentioned herein or in the attached
Exhibits, which are presently titled in the sole name of one of
the parties hereto or, if untitled, are presently in the sole
possession of one of the parties hereto, the party not having
title thereto or possession thereof hereby releases any claims
therein and acknowledges that the party having title or
possession of such items shall be the eole and exclusive owner
thereof.
10. Waiver of RemaininCl Economio Claims. Both parties
acknowledge that they have been advised that eaoh may have the
right to assert a claim for spousal support, alimony, alimony
6
pendente lite, attorneys fees, costs and/or expenses. Exoept as
otherwise provided herein, each party hereby waives any right to
suoh economic olaims ancillary to the divoroe and accepte the
provisions of this Agreement relating to these claims as a final
settlement for all purposes, as contemplated by the Pennsylvania
Divorce Code.
11. Conssnt to Divorce. Both parties agree to pursue a no-
fault divorce under Seotion 330l(c) of the Pennsylvania Divorce
Code and, in connection therewith, to execute and acknowledge
whatever consents or other doouments that are neoessary to
aocomplish this. Both parties agres to exeoute as soon as
practioable the appropriate consent documsnts, waiving receipt of
the notice of intent to transmit the divorce, in order to
prosecute the divorce to a prompt oonolusion.
12. Enforcement. If either party defaults in the due
performance of any of the terms of this Agreement, the non-
defaulting party shall have the right to sue for speoifio
performance or damages for the breaoh of this Agreement, and the
defaulting party shall pay the reasonable legal fees for any
services rendered by the non-defaulting party's attorney in any
judioial or arbitral determination of breaoh as well as ooste to
bring the action or prooeeding of enforcement.
13. Execution of Documents. The parties agree to execute
all doouments, including but not limited to, deeds of title that
7
are reasonably necessary to effeotuate the purpose of this
Agreemsnt. In the event that either party shall refuss or fail
to sxscute and/or acknowledge any suoh dooument, then the other
party shall have, and is hersby granted, the right and power to
appoint, one or more times, any person or persons of his or her
choosing as attorney-in-fact for the other party to so execute
and acknowledge such documents.
14. After-Acquired Pronertv. Each of the parties shall
hersafter own and enjoy, independently of any claim or right of
the other, all items of property, be they real, personal or
mixsd, tangible or intangible, which are acquired by him or her
after execution of this Agreement, with full power in him or her
to dispose of the same as fully and effectively, in all respects
and for all purposes, as though he or she were unmarried.
15. Miscellaneous.
A. Thie Agreement conetitutes the entire agreement between
the parties, being the final and complete settlement of all
matters between them and supersedes any prior written or oral
agreements between them respecting the within subjeot matter.
There are no representations, agreements, arrangemente or
understandings, oral or written, between and among the parties
hereto relating to the subject matter of this Agreement whioh are
not fully expreseed herein.
B
8. This Agreement may not be amendAd, modified, altered or
revoked exoept in writing exeouted by both the parties hereto.
C. 'l'his Agreement may not be assigned by either party
without the prior written consent of the other party.
D. This Agreement may be executed in multiple
oounterparts, eaoh of which ehall be deemed an original for all
purposes, and all of which together shall constitute one and the
same instrument.
E. 'l'his Agreement ehall be binding upon the parties
hereto, their heirs, executors, administrators and assigns.
F. This Agreement shf.ll be interpreted under the laws of
the Commonwealth of Pennsylvania.
G. The failure to striotly enforoe any part of this
Agreement shall not be dsemed a waiver thereof, and a waiver of
any part of this Agreement shall not be deemed a waiver of any
other part of this Agreement.
II. All paymente or communioations pertaining to matters
provided for in this Agreement may be made or given if delivered
or mailed to a party, at such address as either party shall
designate to the other in writing from time to time, or, if no
such designation is made, then to the address set forth above.
I. Titles are for oonvenienoe and ease of reference only
and are not to be oonsidsred part of the Agreement for purposes
of interpretation.
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J. For purposes of oontraot interpretation and for the
purpose of resolving any ambiguity herein, lIushand and Wife agree
that this Agreement was prepared jointly by their rAspective
attorneys. Ilsrshey Foods Corp. v. General Electric Servioe Co.,
619 A.2d 205 (pa. Super. 1992).
IN WITNBSS WnBRBOF, the parties have hereunto set their
hands and seals.
WITNESSl
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DATBD
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Asssts
Two ice ohests
Three gas bottles
Box of cassette tapes
Camping stove
stock pot
Plastio tote
Debts
BXHIBIT "A" - WIPB
11
BxnIBIT "8" - IIUSBAND
/lnetll
lO-speed bike
Deer, elk, and bear pictures
Reloader
Personal papers
pillow casee (from Mrs. Adams)
T.V.
Gun cabinet
Gun boxes
Glass collection
Summer shorts
stereo
Any items belonging to Shelly and Nate
Debta
Nl.h1~
12
KATHY L. SMITH, . IN THB COURT OF COMMON PLEAS OF
plaintiff . CUMBBRLAND COUNTY, PENNSYLVANIA
I
vs. I No. 95-7356
.
i KIRBY L. SMITH, . CIVIL ACTION - LAW
;i Defendant I IN DIVORCE
PRAECIPB TO TRANSMIT THE RECORD
TO THE PROTHONOTARY I
I~
Transmit the record, together with the following information,
to the Court for entry of a divorce deoree.
1. Ground for Divorce. Irretrievable breakdown under Section
3301(c) of the Divorce Codel
I, 2. Date and Manner of service of the Complaint I Servioe by
'II Cert.ified Mail H P 316 467 790, delivered on January 6, 1996.
"
!I .3. Date of exeoution of the Affidavit of Consent required by
II' Sect~on 3301 (c) of the Divoroe Code. Plaintiff - April 17, 1996,
filed with the Court on April 19, 1996, Defendant - May 29, 1996
,I ,and filed simultaneously with the Praeoipe.
ok 4. Date of execution of Defendant's Waiver of Notice of
Intention to Request Entry of a Divorce Decree. May 29, 1996 and
filed simultaneously with the Praecipe.
5. Related claims pending I Please incorporate, without
merging, the enolossd Property Bsttlement Agreement into the
divorce deorse.
o p~te. bH~t
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Re~~e\~ lly,...submitted,
ll~P ~ I .
Matthew J. Eshelmani Esquire
Law Office of Patr ck F. Laueri Jr.
2100 Market Strest, Azteo Build ng
Camp lIill, Pennsylvania 17011-4706
108 72655 Tel. (717) 76J-lOOO
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KATHY L. SMITH, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I No. Q6- 'I6lL e..., ( -II'.. " I
vs. I
I
KIRBY L. SMITH, I CIVIL ACTION - LAW
Defendant I IN DIVORCE
NOTICE TO DBFEND 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
prooeed 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 olaim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, inoluding custody or visitat~on of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling.
A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
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 SOOULO TAKE 'l'HIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONB TOB
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HBLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTnOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
(717) 697-371 X6200
.
KATHY L. SMITH, I IN THB COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No.
I
KIRBY L. SMITH, I CIVIL ACTION - LAW
Defendant I IN DIVORCE
COMPLAINT IN DIVORCE UNDER BBCTIONB 3301(0) or 330l(d)
OF THE DIVORCE CODE
The Plaintiff, Kathy L. Smith, through her attorneys, The
Law Offioes of Patrick F. Lauer, Jr., makes the following
Complaint in Divorce I
1. The Plaintiff, Kathy L. Smith, is an adult individual
who ourrently resides at 1738 McClures's Gap Road, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The Defendant, Kirby L. Smith, is an adult individual
who currently resides at 309 Bobcat Road, Carlisle, cumberland
County, Pennsylvania 17013.
3. The Defendant and the Plaintiff have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
months immediately prior to the filing of this Complaint.
COUNT I - DIVORCE
4. Paragraphs one through thrse abovs are incorporated
herein by referenoe.
5. 'l'he Plaintiff and the Defendant were married on
September 12, 1906 in Carliele, Cumberland County, Pennsylvania.
6. There have bssn no prior aotions of divorce or for
annulment between the parties.
.
7. The marriage is irretrievably broken.
B. The Plaintiff has been advised that counseling is
available and that the Plaintiff may have the right to request
that the court require the parties to participate in counseling.
9. This aotion is not collusive.
10. There are no dependent children to the marriage.
WHEREFORE, the Plaitiff respectfully requests this 1I0norable
Court to entsr a decree of divorce in this matter.
COUNT II - BOUITABLE DISTRIBUTION
11. Paragraphs one through ten are incorporated herein by
referenoe.
12. The parties have legally and beneficially acquired
property, both real and personal, during their marriage.
13. The parties been unable to agree as to an equitable
division of said property as of the date of the filing of this
Complaint.
WHEREFORE, the Plaintiff requests the Court to equitably
divide all marital property.
COUNT III - ALIMONY AND ALIMONY PBNDENTE LITH
14. Paragraphs one through thirteen are inoorporated herein
by referenoe.
15. The Plaintiff is the dependent spouse. The Plaintiff
laoks suffioient property to provids for her reasonable means is
unable to support herself completely through appropriate
employment.
16. The Plaintiff requires reasonable support to adequately
maintain herself in aocordanoe with the standard of living
established during the marriage.
WHEREFORE, the Plaintiff requests your 1I0norable Court to
enter an award of reasonable alimony upon final hearing and
permanently thereafter, and to permit the Plaintiff an interim
hearing before the Divorce Master in order to determine whether
an award of alimony pendente lite is appropriate and, if so, in
what amount.
COUNT IV - ATTORNEY'S FBES AND COSTS
17. Paragraphs one through sixteen are incoproated herein
by referenoe.
lB. The Plaintiff has entered into a fee agreement with her
attorney.
19. The Plaintiff may be in need of hiring an accountant,
a real estate appraiser, and other experts, and does not have the
funds required to pay the necessary and reasonable fees.
WHEREFORE, the Plaintiff requests your Honorable Court to
enter and award counsel fees, costs, and expenses as are deemed
necessary and appropriate.
Respeotful y submitted,
/
D.to. 4\-
Mat hew J. Es elman1 Esquire
Law Offices f Patr ck F. Lauer, Jr.
2100 Market treet, Azteo Building
Camp Hill, Pennsylvania 17011-4706
IDH 72655 Tel. (717) 763-1000
KATHY L. SMITH,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No.
I
I CIVIL ACTION - LAW
I IN DIVORCE
VS.
KIRBY L. SMITH,
Defendant
VERIFICATION
I verify that the statements mads in this Complaint are true
and correot. I understand that false statements herein are made
subject to ths penalties of 10 Pa, c.S. S 4904, relating to
unsworn falsification to authorities.
Datel:lO I\JfJI/ 9.5
Signature I tJ:~ / (,u;I-i
K thy . smith
I
I
i KATHY L. SMITH,
i Plaintiff
I ve.
Iii KIRBY L. SMITH,
II Defendant
!
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY,PBNNSYLVANIA
I
I No. 95-7356
I
I CIVIL ACTION - LAW
I IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSBNT
UNDBR SECTION 3301101 OF THE DIVORCE CODB
1. A complaint in divoroe under Section 3301 (c) of the
Divorce Code was filed on the 20th day of December 1995.
2. The marriage of the Plaintiff and the Defendant is
irretrievably broken and ninety days have slapsed from the date of
the filing of the Complaint.
3. I consent to the entti of a final decree of divorce after
service of notice of intsntion to request entry of the deoree.
4. I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein are
made subjeot to the penalties of 10 Pa, C.S. S 4904 relating to
II unsworn falsification to authorities.
Signature I _\\ ai~ ~' ~JJ-
Kathy .. Sm th
Datedl~
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KA'l'IIY L. OMITII,
Plaintiff
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IN THE COURT OF COMMON
PLEAU OF CUMBERLAND COUNTY,
PENNUYLVANIA
CIVIL ACT10N - LAW
vs.
NO. 95-1356 CIVIL TERM
KIRBY L. BMITH,
Defendant
IN DIVORCE
AFFIDAVIT OF COIORNT
1. A Complaint in Divorce under Bection 3301(c) of the Divorce Code
was filed on 2B December 1995 and was served upon the Defendant on or
about 5 January 1996.
, '
,2. Tha marriage of Plaintiff and Defendant iu irretrievably broken
!
alld nin'!ty 19?1 days have elapsed from the date of filing of the
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co'-flaint and'thl! date of serv ice of the complaint on the Defendant,
\", 3. I consent to the entry of a final decree in divorce either after
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Iserv~ce of a Notice of Intention to Requeot Entry of the Decree or upon
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I filing of my Waiver of the Notice of Intention to Request Entry of the
Decree.
4. 1 have been advised of the availability of marriage counseling
I and underotand that the Court maintaino a liot of marriage counselors and
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that I may request the Court to require my opouse and I to participate in
Icounseling and, being 00 advised. do not requ80t that the Court require
that my spouse and I participate in counoeling prior to the divorce
becoming final.
I verify that the statements made in thiu Affidavit are true and
correct and I
I
Ithe penalties
I falsification
I
underotand that false statements herein are made subject to
of 18 Pa, C.B. Uection 4904 relating to unsworn
to author! ties.
_~~A4-W...k__.
DA'l'E fl-
\l.~O~ 1m
~MITH
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KATHY L. IIMITH, I IN 'l'lIE COUR'l' OF COMMON
Plaintiff ) PLEAB OF CUMBERLAND coUNTY,
) PENNBYl,VANIA
)
vs. ) CIVIL AC'I'10N - LAW
)
) NO. 95-7356 CIVIL 'l'ERM
KIRBY L. BMI'rH, )
Defendant ) IN DIVORCE
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, :iWAlVHIl OF HOTICH OF IHTBNTIOlII TO IIHOtlH8T RNTIlY
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or A DIVOIlCB DBCIIBB t1NDRIl 8HCTJOH 3301lcl OF THE DIVOIlCB CODB
I"tonsent to the entry 01 a final decree in divorce without
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I notice.
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I understand that I muy lOBe rightu concerning alimony, division
2.
of property, lawyer's tees, or expenues it I do not claim them before a
divorce is granted.
I 3. I understand that I will not be divorced until n divorce decree
lis entered by the court and that a copy of the decree will be sent to me
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I: immediately atter it is filed with the Prothonotary.
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il I verify that the statements made in thiB Affidavit Bre true and
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\1 correct. I understand that false statements herein ore mode subject to
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Ithe penalties of 18 Pa, c.a. Bection 4904 relating to unsworn
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I falslf ication tu authori tieB.
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KlRBY BMITH
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KATHY L. SMITII,
plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No. 95-7356
I
I CIVIL ACTION - LAW
I IN DIVORCE
vs.
KIRBY L. SMITII,
Defendant
AFFIDAVIT OF SERVICE
TO THB'PROTHONOTARYI
I, Matthew J. Eehelman, Esquire, verify that the Complaint in
Divorce has been served upon the Defendant indioated above by first
clals, Certified Mail No. P 316 467 790, postage prepaid, pursuant
to
the P 1920.42 c
I . c....... ~'"" 1lftdJot 2 for ,ddltlon,1 IIfvlcn. I al,o With 10 receIve the
I' Compte,. 111m, 3. I,..d oil · b. following ..,vie.. Itor In ..UI j
. Ptln' your n.m. and .dd,... on thl 'IV"" of 'hi. 'DIm 10 th.1 WI tin f.e):
,.turn tN. card 10 you.
t AIt'th thl, 101m to thl hont olthl m.llpl,cl, 01 on thl b.clt If .pleI 1, 0 Addr...",I. Addr...
do.. nol plfmll.
· . Writ. "A.tumA,cliPI R.quIII.d" on Iht mlllpl"l btlo~ IhI illicit numbel [-~ J
tiS . Tilt R.!Urn R.cllpl will ,how 10 whom thl.rtiel. WI' d.llver.d.nd Iht dll, 2, IrRlllrlct.d Delivery
dIN I,d. Conlull a.lm..'., for ,".
13. Artlcll Addro... d to: . 41. Artlcll Number
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A-l'l-Lty. Xi. It.-(..I'[; 4b. SlIvlcl TYPI
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U I 73t< t<(~(ll -/ tf ft/;L. lB'Clltlflld [] coo .I!'
1 ' 0 EMp,ell Mell 0 A.turn A.cllplla, 9
f..a"lutLrfd 1'101-:;) 7.0Itla'Oelvery I ~
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8. Ad .. .el . Add.... 10nly II roqullted 1
Ind I e I. paldl ~
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. O,clmber 1881
*U.'.OPO:,_.!t4 DnM~RTIC A~TU"N RECEIPT
Hespeottul,lY 1!Ulii1lTLI..!lf,
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Matthew J. Eshelman, Esquire
Law Offices of Patrick F. Lauer, Jr.
2100 Markst Street, Aztec Building
Camp lIill, pennsylvania 17011-4706
IDH 72655 Tel. (717) 763-1000
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