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HomeMy WebLinkAbout01-5644Stefanie L. Barley, Richard A. Barley, Plaintiff, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA No. qL/ CIVIL ACTION - LAW 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. 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 of the Prothonotary at the Cumberland Cotmty Courthouse, Carlisle, Permsylvania. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Stefanie L. Barley, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND CO., PENNSYLVANIA v. NO. 6t~(~ q/"'/ ~ Richard A. Barley, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 1. Plaintiff is Stefanie L. Barley, an adult individual who resides at 6152 Haymarket Way, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Richard A. Barley, an adult individual who resides at 35 Dogwood Circle, Elizabethtown, Dauphin County, Pennsylvania 17022. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 17, 2000 in Mechanicsburg, Pennsylvania. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between fire parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and that Defendant may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. Plaintiff avers that there are no children of the parties under the age of eighteen (18). 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to Section 3301(c) or (d) of the Divorce Code. Date: September 27, 2001 By: Respectfully Submitted, REAGER & ADLER, P.C. DEB~,~I~E~ISO/b~ CANTOR, ESQUIRE Attorney I.EM~o. 66378 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. [717] 763-1383 Attorneys for Plaintiff VERIFICATION I, Stefanie L. Barley, verify that the statements made in the foregoing pleading are true and correct to the best of my knowledge, information and belief. ! understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~/'~/0~ ~B'~' '~~arley £8g L-~:gL (LLL) Zt9t-L LOLl, ¥cJ '¥JJH d~1¥3 M'~I J-¥ SA3NI::IOI1¥ Stefanie L. Barley, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Richard A. Barley, Defendant : NO. 01-5644 Civil : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Debra Denison Cantor, Esquire of REAGER & ADLER, P.C. do hereby certify that I served a certified copy of the Divorce Complaint on the Defendant Richard A. Barley, by Certified Mail, Return Receipt Requested on the 28~ day of September, 2001 as is evidenced by the signature of the Defendant on the Return Receipt card attached hereto as Exhibit A. Said Complaint in Divorce was mailed to Defendant by depositing a tree and exact copy thereof in the United States mail, first class, Certified Mail, Return Receipt Requested postage prepaid, addressed as follows: Richard A. Barley 35 Dogwood Circle Elizabethtown, PA 17022 Date: /~- ~7 7- O/ Subscribed and sworn to before me this o~q~ day of T)ec~rnb~ ,2001 Respectfully submitted, REAGER & ADLER, PC 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Notary Public No.rial Seal Micbelie M. Leaver, Notavj Public _C. am~ Hill Bom, Cumberland Count~ M,i' Cry ommission Expires July 11, 200:5 .~ELT SSA KATN i ~,~AGER & ADLER, PC '~331 MARKET STREET CAMP HILL, PA 17011-4642 Print of DeliVeiy Artiale Number 7111 1746 2100 0000 7602 7111 1746 2100 0000 7602 Article Addreesed To: RICHARD A. BARLEY 35 DOGWOOD CIRCLE £LIZABETHTOWN PA 17022 Exhibit "A" 8~L-~gL (LI, L) Z'~9~L LOLL ~'cl 'lllH ,-IINyD /'q':IEI.L$ J.':INEI¥1N L££Z AA¥'I J.¥ SA:IN~IOI I¥ MARITAL SETTLEMENT AGREEMENT Stefanie L. Barley, (hereinafter "WIFE") and Richard A. Barley, (hereinafter "HUSBAND"); W I TN E S S E T H: WHEREAS, the parties hereto were married on June 17, 2000, in Mechanicsburg, Cumberland County, Pennsylvania; and WHEREAS, the parties have no children of this marriage; and WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling completely the economic and other rights and obligations between each other, including, but not limited to: the equitable distribution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. WIFE is represented by Debra Denison Cantor, Esquire of Reager & Adler, PC. HUSBAND is not represented by counsel. The parties further declare that each is executing the Agreement freely and voluntarily having either obtained sufficient knowledge and disclosure of their respective legal rights and obligations, or if counsel has not been consulted, expressly waiving the right to obtain such knowledge. The parties each acknowledge that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. DIVORCE ACTION. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code. A divorce action was filed by WIFE with the Court of Common Pleas, Cumberland County, Pennsylvania at Civil Action No. 01-5644on September 27, 2001. The parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement or upon expiration of ninety (90) days. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Agreement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" and "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 as the date of execution by the party last executing this Agreement. 4. MUTUAL RELEASES. Each party absolutely and unconditionally release the other and the estate of the other from any and all rights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Page 2 of 10 Each party absolutely and unconditionally releases the other and his or her heirs, executors, and estate from any claims arising by virtue of the marital relationship of the parties. The above release shall be effective whether such claims arise by way of widow's or widower's rights, family exemption, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, Commonwealth, or territory of the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this Agreement an absolute and unconditional release form all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The parties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Each party understands that he/she had the right to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair and equitable, and that the terms adequately provide for his or her interests, and that this Agreement is not a result of fraud, duress or undue influence exercised by either party upon the other or by any person or persons upon either party. 6. SEPARATION/NON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on Page 3 of 10 and engage in any business, occupation, profession or employment which to him or her may seem advisable. WIFE and HUSBAND shall not harass, disturb, or malign each other or the respective families of each other. 7. REAL PROPERTY. The parties are the joint owners of real property located at 6152 Haymarket Way, Mechanicsburg, PA 17050. HUSBAND hereby waives any right, title or interest he may have to said property. WIFE shall assume exclusive possession of the marital home and agrees to be solely responsible for all costs and payments associated with the home, including but not limited to mortgages, taxes, insurance and utilities. WIFE agrees to refinance, assume or otherwise remove HUSBAND's name from the obligations associated with the marital home within 90 days of the execution of this Agreement. Concurrently with the execution of this Agreement, HUSBAND shall execute a deed prepared by WIFE's counsel transferring his interest in the home to WIFE. WIFE's counsel shall hold the deed until such time as the refinance or assumption is completed. 8. DEBTS. The parties have a joint credit card debt with Visa. HUSBAND agrees to assume the remaining balance on the credit card of $1,128.00 and agrees to indemnify and hold WIFE harmless. HUSBAND agrees to transfer the balance of this account to a credit card in his own name or otherwise remove WIFE's name from this obligation within 90 days of the date of the execution of this Agreement. 9. RETIREMENT BENEFITS. Both parties are employed in school districts as teachers and through said employment have PSERS retirement plans. HUSBAND'S PSERS account number is 168722434. WIFE'S PSERS account number is 002541371. The parties have been advised of their right to have such plans evaluated to determine the marital value of each plan. They specifically waive their right Page 4 of 10 to have said plans valued and agreed that they will waive their right, title and interest to their retirement accounts as above-described. 10. BANK ACCOUNTS. The parties acknowledge they each hold individual bank accounts and said accounts are held solely in individual names shall become the sole and separate property of the party in whose name it is registered. Each party does hereby specifically waive and release his/her right, title and interest in the other party's respective accounts. 11. LIFE INSURANCE. The parties each have life insurance policies. HUSBAND and WIFE waive any right, title and interest they may have in said policies. 12. PERSONAL PROPERTY. Except as set forth here below, the parties hereto mutually agree that they have divided all furniture, household furnishings and personal property between them in a manner agreeable to both parties. The parties mutually agree that each party shall from and after the date of this Agreement be the sole and separate owner of all tangible personal property in his or her possession. 13. VEHICLES. The parties are jo'mt owners of a 2001 Nissan Altima, which is subject to a loan through Nissan Motor Acceptance Corporation (loan number 0010249547666001). HUSBAND agrees to waive any right, title and interest he may have to this vehicle. WIFE agrees to apply for a loan in her own name and remove HUSBAND's name from said obligation within 90 days of the execution of the Agreement. HUSBAND agrees to execute any documentation necessary to transfer title of the vehicle to WIFE. HUSBAND is the owner of a 1995 Honda Accord. WIFE hereby waives any right, title or interest she may have to said vehicle. Page 5 of 10 14. BANKRUPTCY OR REORGANIZATION PROCEEDINGS. In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney fees and costs incurred in the enforcement of this paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contrary, and each party waives any and all right to assert that obligation hereunder is discharged or dischargeable. The parties mutually agree that in the event of bankruptcy or financial reorganization proceedings by either party in the future, any monies to be paid to the other party, or to a third party, pursuant to the terms of this Agreement shall constitute support and maintenance and shall not be discharged in bankruptcy. 15. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE. The parties hereby expressly waive, release, discharge and give up any and all rights or claims which either may now or hereafter have for spousal support, alimony pendente lite, alimony, or maintenance. The parties further release any rights that they may have to seek modification of the terms of this Agreement in a court of law or equity, with the understanding that this Agreement constitutes a final determination for all time of either party's obligations to contribute to the support or maintenance of the other. Page 6 of 10 16. ATTORNEY FEES, COURT COSTS. The parties agree to equally share all costs and expenses associated with the filing and finalization of the divorce, the preparation and finalization of the Marital Settlement Agreement, including attorneys' fees and costs, filing fees, and all fees associated with an annulment through the Catholic Church. WIFE will assume the cost of the application fee of $250.00 and the $900.00 fee for the assumption of the mortgage. The parties will thereafter divide any remaining costs associated with the assumption of the home. 17. ATTORNEYS' FEES FOR ENFORCEMENT. In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecting and enforcing his or her rights under this Agreement. 18. WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a.) The right to obtain an inventory and the appraisement of all marital and non-marital property; (b.) The right to obtain an income and expense statement of either party; (c.) The right to have all property identified and appraised; (d.) The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; and Page 7 of 10 (e.) The right to have the court make all determinations regarding marital and non-marital property, equitable distribution, spousal support, alimony pendente lite, alimony, counsel fees and costs and expenses. 19. MUTUAL COOPERATION. WIFE and HUSBAND shall mutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of documents. 20. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 21. APPLICABLE LAW. This Agreement shall be construed under the Pennsylvania. laws of the Commonwealth of 22. 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. 23. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. Page 8 of 10 This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. '-Stef~mie L~Barley Page 9 of 10 COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : On the l ~ day of /~o,_~y~-' . 2001, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undesigned officer, personally appeared , known to me (or satisfactory proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. COMMONWEALTH OF ~ COUNTY OF ,~eq A[C~q6'7't'/~ My Commission Expires: I Notarial Seal : Deborah L. Brenneman, Notary Public Camp Hill Boro, Cumberland County : SS. My con'~rnlssion Expires June 18, 2002 Member, Pennsylvania Association ot Notaries On the ,_~ day of /~/r6' ~'~ , 2001, before me, a Notary Public in and for the Commonwealth of t~"/-]' , the undesigned officer, personally appeared, known to me (or satisfactory proven) to be on of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. //~'6~'ary Public l My Commission Expires: Page 10 of 10 Stefanie L. Barley, go Richard A. Barley, Plaintiff, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA : NO. 01-5644 Civil : CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 27, 2001. 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 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 falsification to authorities. Date: /o~- o~-d)/ ~ 0 - STEFANIE t. BARLEY REAGER & ADLER, RC. ATrORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 (717) 763-1383 Stefanie L. Barley, Richard A. Barley, Plaintiff, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 01-5644 Civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 27, 2001. 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 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 unswom falsification to authorities. Date: /~/~///O i RICHARD A. B~ARLEY REAGER & ADLER, RC. A'I-I'ORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 Stefanie L. Barley, Richard A. Barley, Plaintiff, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 01-5644 Civil CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 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 ifI 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. § 4904 relating to unsworn falsification to authorities. DATE: REAGER & ADLER, RC. AI-rORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 (717) 763-1383 Stefanie L. Barley, Richard A. Barley, Plaintiff, : : . .. . Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 01-5644 Civil CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 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 ! 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. § 4904 relating to unswom falsification to authorities. DATE: /&/o~'7A / REAGER & ADLER, RC. ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 Stefanie L. Barley, Richard A. Barley, Plaintiff, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5644 Civil CIVIL ACTION - LAW IN DIVORCE 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on the 28~ day of September, 2001, by certified mail, return receipt requested, receipt number 7111 1746 2100 0000 7602. 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: by Stephanie Barley, Plaintiff, on December 29, 2001; by Richard A. Barley, Defendant, on December 29, 2001. 4. Related claims pending: Settled by Agreement dated November 14, 2001. Prothonotary: the Prothonotary: Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the December 31, 2001 Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with December 31, 2001 Date: Respectfuny submitted, REAGER & ADLER, PC 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorneys for Plaintiff REAGER & ADLER, P.C. ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 (717) 763-1383 Stefanie L. Barley, V. Richard A. Barley, Plaintiff, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5644 Civil : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: The Social Security number of the Plaintiff, Stefanie L. Barley, is 002-54-1371. The Social Security number of the Defendant, Richard A. Barley, is 168-72-2434. Respectfully submitted, REAGER & ADLER, PC iD.i~b, r o~~78~antor, Esquire ~'3~'1 Mar~'k~z~$xr--~et Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Stefanie L. Barley IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE Of ~ PENNA. NO. Ol-5644 VERSUS Decree IN DIVORCE AND NOW~ ~ DECREED THAT Stefanie L. Barley ~W IT IS ORDERED AND , PLAINTIFF, AND Richard A. Barley , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVe BEEN RAISED OF REC RD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ~ ENTERED; The terms of the parties' Marital Settlement Agreement, dated November 14, 2001, and attached hereto are incorporated herein but not merged herewith. BY THE C~ ATTEST: ~OTa R~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ,, Plaintiff : : File No. (~1 -- 5&ff~ vs. : IN DIVORCE efendant : 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 ~] day of b~a~._~ . hereby elects to resume the prior surname of C~0~ , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: - ~ Signature '9 a-tur~ of name being resumed COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF CHMBERLAND : SS. On tile . /~_ _ day of ~ · ~OO~.~ before me, a Notary Public, personally appear{~d the a~ove affiant known to me 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. seal. In Witness Whereof, I have hereunto set my hand and official