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Home My WebLink About96-00386 ~ .' ~'-*~~~~~~*~-~~***~**)-'*,~-~-~~~'~ ~ .~_~~______,_._.v -.,...,--,....-.., ",.,-.. "',.0'0_.'''__' ....,...-....-,-.--.-- V' 8 8 n y The C 0 u r iJ' L L J. LU .iI.{('-e 0 L-o . . All ,I ....!....... I ,/L' :.:2..,// ~ J ~ e .:x,~".~-;t.U' tJd~"(. /A:tffAe>1l"-07 . ? ;.i!~/"Cl r ~&. f 1 'T ~ (/ ~olhonolnry ~ !~ ~ ~ ~ ~.", ,--, . ~~~~*~~~~****~*-**~.****~*~.**~.~. ? ~ IN THE COURT OF COMMON PLEAS ~ ,~ :, OF CUMBERLAND COUNTY STATE OF ~ PENNA. ~ ,;, " ,~ ~ ~, ~ ~ .' MELODY JEAN MOORE, 'I 1 i\: (). ..!J.6.:::~l;l,li...... c.:J:'y'J;~.... It) ~ '.' ~ '.' PLAINTIFF ~, Vl'l"..;llS * BARRY LEE MOORE, s DEFENDANT ~ '.' .' ~, ~ w '.' DECREE IN DIVORCE * ~) ") .. ~ AND NOW, . . . .O.c.:t...~<.T. . . 7,.~ . . . .. " 19.96..., it is ordered and decreed that . ~.~l,Q!iY. .o1~!lA .l:I9P.X:E1.. .. .. . .... ..... ........, '" plaintiff. and . ~~.x:x:~. ~.~~. ~~.~J;~.. ... . .. . .. , .. ... . .. .. .. .. . .. . .. .. .. .., 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 s ,;, ~, ~ '.' . :r.l!~. ~.a.t:H!l.1, .l?e~.t;J,.e\lle.l\~ .l\gJ;eelD.~nt. l:I.a~eli. ,QctP~er. :4.,. .199.6. is. . . . , . ~.~~~~;V. .~~7.~rl?~r.~ted. .~~~o. .t:I,1~!3. .I?~~~.~~. ~P. .I?~Y.~J;~~......,.....,..... $ ~ ~ ~ !="' * ~ ~ ,:> ,', ~ ~ ~, ~ ,:> ,;, " ,', ~ ~ " ~ '.' ~ ~ ,'. ~ ~ f~ ~ " ~ w '.' ~ ~, ~ ~ ~ w '.' ~ ~ ~ l~ " I~ I',' !~ '" i~ i'" i~ )'.' , . '~ ;',' ,* ~ '~ o //). oJ ' . /? J/ ,d //J . 3 '9~ &d. (~I' /:.,~~--V/ ~ ~a? x:/~ /P(jJ3-?t- /t~ ~;4/ ;B 4~,( THIS AGREEMENT made this ~ day of ~, 1996, by and between Barry Lee Moore, (hereinafter referred to as "Husband") and Melody Jean Moore, (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on October 1, 1983; and WHEREAS, differences havs arisen betwesn Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, there was one child born of this marriage, Ashley Rose Moore, born 5/2/91; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; 1. 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 provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE Each party shall be free from interference, authority, and contact by the other as fully as if he or she were single and unmarried except as maybe necessary to carry out the provisions of the agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. DIVISION OF PERSONAL PROPERTY The parties have agreed to divide between them and already have divided between them to their mutual satisfaction the personal affects, household furniture and furnishings and all other articles of personal property which heretofore have been used by them in common. Neither party will make any claim to any such items which are now in the possession or under the control of the other. , 4. AUTOMOBILBS The Husband shall have all rights and title to the 1984 K-5 Blazer and Wife shall have all rights and title to the 1987 Grand Am. Each party shall be fully responsible and liable for any and all loans, maintenanca, insurance, or other costs associated with the ownership of their respective vehicles. Each party agrees to indemnity and hold harmless the other for any liability arising from the vehicle in their possession. 5. DIVISION or REAL PROPBRTY Husband shall transfer by deed his interest in the marital home to Wife. Wife shall give Husband a $16,000.00 Mortgage & Note as security. The parties agree that Wife and child shall be allowed to remain in the marital home at 2112 Wentworth Drive, Camp Hill, Cumberland County, Pennsylvania until the child graduates from high school. After the child graduates from high school the house shall be sold. Husband shall receive the first $16,000.00 from the proceeds of the sale of the house to satisfy the mortgage. If the selling price is more than $85,000.00 Husband and Wife agree to equally divide the amount over $85,000.00. Husband and Wife also agree to equally share in any and all closing and realty fees related to the sale of the marital home. In the event the house proceeds, less expenses, do not total $16,000.00, Husband agrees to accept that amount in full and complete satisfaction of his interest/mortgage in the marital home. At Wife'S sole discretion she can elect to sell the marital home before the child graduates from high school and pay Husband his $16,000.00 plus one half of the selling price, less expenses, over $85,000.00. Wife shall not encumber, except for the current mortgage, the marital home without the written consent of Husband. 6. MARITAL DBBTS Husband shall be responsible for all marital debts solely in his name and Wife shall be responsible for all marital debts solely in her name. Wife agrees to assume sole responsibility for the mortgage and indemnify and hold Husband harmless for any expenses related to the marital home. 7 . CUSTODY Husband and wife shall share legal custody of their child. Wife shall have primary physical custody of the child subject to Husband's periods of partial custody as mutually agreed. Husband has stated his intention to move to Florida. At the present time the parties have agreed that Husband shall see the child for two (2) weeks during the child's summer vacation and on, with at least two (2) weeks notice, any weekends that he is in the area. Husband shall be responsible for all transportation costs related to his periods of partial custody. , " . . : 8 . rILING or IRS RETURN Husband and wife agree to file separate income tax returns with wife claiming the child and the mortgage interest on the marital home. 9. DIVORCB The parties agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that at the signing of this agreement, the parties shall execute and allow to be filed the necessary documents to obtain the divorce. 10. INCORPORATION This agreement shall be incorporated into any subsequent Decree in Divorce. 11. CONTINUED COOPERATION The parties agree that they will promptly execute any and all written instruments assignments, releases, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this agreement. 12. BREACH If either party breaches any provision of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this agreement or for seeking such other remedies or relief as may be available to him or her. 13. VOLUHTARY AGREEMENT The provisions of this agreement are fully understood by both parties and each party acknowledges that the agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. 14. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, 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 now 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, widows allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate. J.o: , I 15. BINDING APP'lCT This agreement shall be binding upon the parties' heirs, successors and assigns. 16. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and executed with the same formalities as !his agreement. The failure of either party to insist upon strict performance of any of the provisions of this agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 17. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time of this agreement are null and void and of no affect, 18. ENTIRE AGREEMENT This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 19. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall not have any binding affect whatsoever in determining the rights or obligations of the parties. 20. APPLICABLE LAW This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties set their hands and seals. j ,/ / 7// I ____ . wJness {,/l , l // :.;t(_ Ie -(,)'- 91- Date 'J ~ I)~..v'\..' 7:n 1n:l1q" B ry L. Moore 1/wmM]) AJdI Witness /';- I,L ,I, Melod l _/')~l.I~ It- 'I.-'t '" Date . Moore \ Commonwealth of Pennsylvania: . . . . ss: County of Dnufh'" PERSONALLY APPEARED BEFORE ME, thisIS~"day of oe\ob~,. , 1996, a notary public, in and for the Commonwealth of Pennsylvania, Barry L. Moore, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. , ,. (i; l.dldo... lUl:t.YN.,0 Notary P ( ", ( '~ I. , ( I {, ~ NOTARIAL SEAL LINDA WITMER, Notary PublIc Harrisburg, Dauphin County, PA My Commission ExpIres: 0302().2000 o. .' r~l ;,--.' Commonwealth of Pennsylvania: . . County of Cumberland . . PERSONALLY APPEARED BEFORE ME, this Lfth day of O~'L , 1996, a notary public, in and for the Commonwealth of Pennsylvania, Melody J. Moore, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. }JjO~~1 in. ~dvulj Notary Public Notarial Seal laola M. Gould. Notary Publlo Shlramanstown Bora, Cumbe~and COunty My Commission Expires Apm 8, 2000 tmDor. nnlY nit I on 0 011 IS , ~ \tJ ?: j~ c~ ., U...., 'j ~~:1 C~; .'-'" :.; C' .~ ,.,J niJi\' . jJ!. ::t: o:;? .~'. Ll.. W :., " ;)"/'1 . r' )~ r"-, ,. - '~i-J J.~' C'\J ,~- ,:S~ , .... ".~ j:..' g l;JI t-5 . ::Q;; It) ;F C.h oJ U ,. ",' . . MELODY JBAII MOORS, I IN THI COURT or COMMON PLEAS PLAINTIFF I CUMBIRLJUrD COURTY, PllfHSYLVJUlIA I v. I NO. 96 - 386 CIVIL TIRM I BARRY LlI MOORS, I IN DIVORCI DIFINDJUlT I PRAECIPE TO TRANSMIT RECORD To the prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. t' , ;'2. Date and manner of service of the complaint: February 7, , ,:1996~bY certified, restricted delivery u.s. Mail on the Defendant. ! ~~,' ( ..' (.l Hi- 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required (,', by Section 3301 (c) of the Divorce Code: Plaintiff 10/21/96; Defendant 10/15/96. (b)(l) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, Waiver signed by Plaintiff on october 21, 1996. Signed by Defendant on October 15, 1996. %JlnUvJ'D. ~ Thomas D. Gould Attorney for Plaintiff J >- ,- I q " " h :) " " i 1 ! ~ CD ~ M ~- .,. I! M :~l::!:: r.J.". :c ~I "- N ~n ~ I- 'V U '..) C -' -: ~ \0 :::l 0\ Q ,v ..) ... .) u ~. ". /r) !.': '- ,'! l', L; "('! r:!, "0 .... : I . ~ ( '. C_J .~ t.-, ,-. . - J:.. e v, 'r-', . .. .) j .~ I :.0. f >, 1-) ,', ,; ~1 => UI. (\I .... r. t..IJ " , - . ; . '.'..1 .. ....1. ,. I.') C. ~.~:, (0. (,J ~ 0 J ~.. ~ ~oJ ~ 101.. ijj ... Ii! i ! . <c :.n i: I ~ ~ Z ~ Pi :>. ~ :( ~ Z ~ 0 :E < ;: ~ ... W % .~ t ~ f\I ~ ~ * ~ (.fl. (,r;o,,/'I ATTIlIltU y All ''''W .~ I MAIN <, '''' I , ~)IIII~1 t.1^N~,T{Jwt' I'A 1/011 IIl-13t-I.1hl BARRY LBE MOORl!:, DEFENDANT IN DIVORCE v. I I I I I I I III Till: COURT or COMMON PLEAS CUMBERLAND COUNTY, PEIIIISrLVANIA NO. 96 - :3 J(.. CIVIL TERM MELODY JBAJI MOORl!:, PLAIIITIrr 1I0TICE TO DErEIID AND CLAIM RIGHTS YOU HAVE BEEII 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Cumberland County Court Administrator Cumberland County Courthouse Fourth Floor Hanover and High Streets Carlisle, PA 17013 (717) 697-0371 Ext 6200 , ....,.. \ ICBLOD!: JBAII MOOD, PLAIIITIPP III THE COURT OP CONNOII PLBAS CUMBBRLAND COUNT!:, PBIIIISYLVAJilIA v. I I I I I I I 110. 96 - CIVIL TBRN BARR!: LEB MOOD, DBPBIIDAJilT III DIVORCB COMPLAIIIT UNDBR SBCTIOII 3301(0) OR 3301(d) OP THE DIVORCB CODE III DIVORCB 1. The Plaintiff is Melody Jean Moore who resides at 2112 Wentworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Barry Lee Moore who resides at 2112 Wentworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant 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 Defendant were married on October 1, 1983 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. -rh.m,M D ~ /.;/ Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Fax 761-1974 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 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. -))7/L~I!JJ. ~~' IY)~ Melo y Jean Moore Date: / ,}Y. q (., MBLODY JEAH MOORS, I IN THE COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY, PEHHSYLVANIA I v. I NO. 96 - 386 CIVIL TERM I BARRY LEE MOORS, I IN DIVORCE DEFENDANT I AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 25, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Amended 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 ft~ , ;~ckn~ledge that pursuant to Rule 1920.42(e) I have waived the r . ~requirement that I receive notice of intention to request entry of /, the 4ecree.' ,', 4. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: /0 -JI.C;~ 1'1 ~L.tJr. (~ 0"'-' {I) ~ M 0 Y Jean Moore I' \Q f2 M M :3i - J - Q.. :)1 ~ " <... N .~ . ~ ..... LI c..: '1) 0 ~: , ~ \0 ::; a- U . . ~_,..~fl'fCt~' _ MBLODJ: JBAH MOORE, PLAIIITIFF III THB COURT OF COMMON PLEAS CUMBBRLAND COUIITY, PBNNSYLVANIA I I I I I I I . NO. 96 - 386 CIVIL TBRM IN DIVORCB v. BARRY LEB MOORE, DBFENDANT AFFIDAVIT OF CONSBNT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 25, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the ;fiiing and service of the Amended Complaint. , . f' : 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 ,'.: . acknowledge that pursuant to Rule 1920.42(e) I have waived the I, ., f . ~equ1rement that I receive notice of intention to request entry of the decree. 4. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: /1/ -/f;- 9 i., 'J, -- 'J I n"jI< ""'..R,, 7-1.-',~ arry Lee Moore ! \D ~ C? M ~:!( j~ - ,:)~ r=,' Ci: r!'J;j ~ - '"(I) ('oJ ~~ .... u:~ J.UfiJ ~ U ~qa.: Q l:5 U) ~ 0"> MELODY JBJUI MOORS, I IN THE COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA . . V. I NO. 96 - 386 CIVIL TERM I BARRY LEE MOORS, . IN DIVORCE . DEFENDANT . . NAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c\ OF THE DIVORCE CODE ~ ,~ 1. . f ~ . . I consent to the entry of a final decree without notice. , ~'~ 2. I ,"division of f.. them _before understand that I may lose rights concerning alimony, property, lawyer's fees or expenses if I do not claim 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 ~ent 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: /0-21..9' tn. Lo-l1 ~'LL-.. f>1~ Melod ean Moore " . ~ CD >- M ';; .. :s~ M - -- :...l'1; n.. '"\~ " - "'9 '" N __1._ t- '~m C.1 Co] Q10- C :; U) :::> 0\ U ...........~,~.. "---- r....,"I'. . -- ".-. '-..- -~. '-'-:>'.. -. ;i' ." ,. -- --~- .. MELODY JBAJI MOORll, PLAIIITIrr IN THE COURT or COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 96 - 386 CIVIL TERM I I I I I I I IN DIVORCE v. BARRY LEE MOOD, DEFENDANT WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDBR SECTION 330110\ OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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. , t., . 3. I understand that I will not be divorced until a divorce rdecree is entered by the court and that a copy of the decree will l'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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ;.:Ja~ ...Y"-'UL. /Y? D~ Ba Lee Moore DATED: I 0 - I,r. '7 k .' ~t ~~ co ~ CO? :.: M :;'::1: ~' if: .'-'~ <...)~ , ;;; , ;} 5:! P - :5!..I) & N ._~ U. I- :~ i!= (,.) Q ::; ~ lO a en I..., " , '.1 . ComcIIet. item. 1 andIOf 2 far IdcI/IJcNI,HMceI. t I' C_o_3,ond".b, , . Pftm 'tOUt name tnd IddtHI on the reverl' of thll form 10 Wt WI cln "turn "'" Clrd to you. f '. AnKh thlI form to 1M front of the rnaUpleCtl, or on the blck If ,pece t dooo nol _. t.J . W'tt...Rttum.....R""'.tId..ontht~b1lowthllll1ldenumbef I . ThI Return Receipt wll ahow to whom thlafddt w.. dtUvefed end the daW 8 tS.lhmld. Conlult Dltma'ter for t... I J 3. Anlele Add'Lo- 10: 48, Artle~.r;'m65 29 t 'lIt tkry ~e. Moore. 4b.SorvleeType II .J ....... 0 R.gl.,.,ed 0 Inlured I '-111.. )We "t"~o,.r"," Crlll'- ~C.rtlfl.d 0 COD I CA/'f\P ~i I\~ (JI!,. ,.,011 o ExprellM.1I J!1Retum I 7. Olle 01 Oellv.ry I 8. Add",..I', Add,... ani .nd I.e I. p.ldl 6. Slgn,'ure IAgenll II PS Fa~ . . Dec.mbe' 1881 *11.& OPO: '..........714 .!I I .110 wllh 10 ,ec.lve the lallawlng ..rvlee. liar .n exl,. IHI: 1. 0 Add,e...,', Addr... 2, ~R..lrlelld Delivery , i\ 1\ ); r !( li II reque.'ed J : ..', - - ',< ~.."..... '^",... DOMESTIC RETURN RECEIPT .,,'1> -.,....~, ........-.-":'_ ">,i'.,,""';;.~'_-':'':'''''':';'' j'"'' - - "" _J' , " " '.~ \ I ~ q I \ .' , . . i , l~ '. , I , . . , , , , i.# i , , f c, ~ -.' .. ,.. ._JI , ,.'......,,,, ,;"",. UNITED STATU POSTAL SERVICE 111111 I I I 1 I I I I I I I , t I t , t . I I I I I Olflolll au....... PENALlY FOR PRIVATE USE TO AIIOlD PAYMENT OF POSTAGE. 1300 B Print your nama, addra88 and ZIP Coda hert · ~~O. ~u,ld, t=Sp. ). G"QJr /YIII;" Jil't>t'l Jhlrt""-eeMTOWIl, ~ nO It 1",1" 11,11I...,., II." II," ,r.;fl ,1ti)I , .1.,' f, "" I,' /I" .1. I' , . , , , , ; , ll"."",_,:.,~" ..;-;:1';';,'...~~;i'~<',;:, :-.<"h'i.c.....,..."",..~', , '. J I I ~ " I " , ..'If'- . , ' , .' " , t '1 ~t" "'. j I '.' , , f -.' ';-:, MELODY JBAII MOORE, PLAIIITIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - 386 CIVIL TERM I I I I I I I IN DIVORCE v. BARRY LBB MOORE, DEFBNDANT CERTIFICATE OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above ;, captioned action for divorce, hereby certify that a conformed and , , certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. Z 435 659 298, restricted delivery, return receipt requested, by depositing the same in the United States mail on February 2, 1996, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendant on 2/7/96. ~L1 '/) ..J::htJ.i. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 "'-- "4 .,.." o ~_.. .-.., ~ \0 >- M L~ "'- M ") fz j$ iE .J~ ..)~ - :~)I & N ,~ It .... :jj u :.Do.; c::: ~ 15 \0 O'l MELODY JBAJf MOORE, I IN THE COURT 0.. COMMON PLEAS PLAINTI.... . CUMBERLAND COUNTY, PENNSYLVANIA . I V. I NO. 96 - 386 CIVIL TERM I BARRY LEE MOORE , I IN DIVORCE DEFENDANT I NOTICE TO THE DE"ENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIF..'S AF"IDAVIT UNDER SECTION 3301(d) 0.. THE DIVORCE CODE _ 1. The parties to this action separated on April 8, 1994 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Date: ~. .)4' . 'I" 0"1 / {. ,~\ I}) . . . I .' ....~ i J I .,t..._ (. T '"-'-'"- Me o<<y Jean Moore ',.- . .,.- c-I r:: c.G lr: j::: .. ,; U..I(" 17"'; ..:;-~ ()~ " , f-' /' :.-.~ 1...; .;.~j ..,.1 0" ,-:11 . ' , -, C),- "...: i>'-: U-.I"'- ~ =--;5 , E:.\" t:. 'I' U I:,;,). i (J' \0_. '.~' 1 0 c' l:) . j .~~ ..' ......,...... i, '-....--' . MELODY JBAH MOORB, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAHDCOUHTY, PENNSYLVANIA . . v. . NO. 96 - 386 CIVIL TERM . . . BARRY LBE MOORB, . IN DIVORCE . DEFENDANT . . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 25, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. 4. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: J"" ,,l ~ (;(" (>) ~-;;J . 7 U-), (>}J'r"""- Melod Jean Moore < I ., I I I' I I i I I I I I [ ~ f. >- <'I r u; In ,'. ~~~ ':lr: (.~,; :< ~ . . '" ( F .J:~ U;,', .. ;;:1 tl ." <;i:C "., iii OL. c'- ' ,- WI- .--;,... _I,. <- 'Im tC-:: 1"- :...~C- r: V~ t~ I,;') :;; (..1 CJ'I U . ;,:.t t. . /. . . MELODY JBAH MOORE, I IN THE COURT OF COMMON PLEAS . PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA , . I V. I NO. 96 - 386 CIVIL TERM I I; BARRY LEE MOORE, . IN DIVORCE . . I DEFENDANT . t. . WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301{c\ OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. DATED: ~'.Jr. .'" fY) J.q,L~ (] /-AA" .0" >-c-u.. Melod {Jean Moore --- f= ('oj ~. '... v: 0:' ,'':''; (-:J }.:!: c~ ll.l-. ,'-... 0" ....::1 (j-: ~. -~ H_ 1.._ " ~:i 0' .~ en (.1\ I !~, .J' l..... '."/ lLP-' ""',> ...1, e . u.l fl ~ ". L~ , u.. l/ .' ",'} I L) C\ ~.J .