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MELISSA L, BECKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, fENNSYLVANIA
NO, 96-3100
CIVIL ACTION - LAW
vs.
DANIEL E, BECKER,
Defendant
P~OPERTY SETTLEMENT AGREEMEN!
THIS AGREEMENT, made this 2yf1.. day of A fill' J
, 2001,
by and between Daniel E, Becker, hereinafter "husband", and Melissa L.
Becker, hereinafter "Wife".
WITNESSETH,
WHEREAS, Husband and Wife have been intermarried since July 7,
1990, and
WHEREAS, certain difficulties have arisen between the parties
hereto which have made them desirous of living separate and apart from
one another and there is a divorce action pending between the parties,
and
WHEREAS, Husband is represented by Joseph J. Dixon, Esquire,
Esquire and Wife is represented by Jeffrey N. Yoffe, Esquire, and
WHEREAS, Husband and Wife have exchanged full and complete
information as to the property, assets and liabilities owned and owed by
each and havt! disclosed same ~o each other, together with a full
disclosure to each other of their esrnings and earning capacity, and
WHEREAS, the parties hereto have mutually entered into this
agreement for the division of their assets, to provide for the
liabilities they owe, and make provillion for. the resolution of their
differences, after both parties have had full and ample opportunity to
consult with each other and any advisers of thei r cwn choosing and the
parties now wish to have that agreement reduced to writing,
NOW THEREFORE, the parties hereto, in consideratir)O of the
above recitals, the mutually made and to be kept promises set forth
hereinafter, and for other good and valuable considerations and
intending to be legally bound and to legally bind their heirs,
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successors/ assigns, and personal representatives, the parties do hereby
covenant, promi~e and agree as followsr
1. Wife shall payoff the marital debt owing to Nationsbank
(approximately $1/693.19)
(approximately $1/100.00).
shall be with Wife.
and also the debt owing
to PSECU
Exclusive possession of thl! Toyota Camry
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2. Currently Ianni Abstract has escrowed approximately
$7,399,24 belonging to Husband and Wife. All of this escrowed money
shall upon the signing of this agreement become the exclusive property I
~,f~ j'ft'" r,"#/Iy ,4jret.6 t.J f~'1 I'" ~fl/I t;,-t. .;t ~!JfJ"lt,w~' I/.sh ,1.v
~f,~t;:'ltl 'II'(~' t.J''j NCol,pr ~ f t4't t!!iC/{CWl<-j} Ft.JN.P5 _ k,JJ.. Ga.
3, ~sband and Wife will each give up any claim tor alimony,
counsel fees or expenses.
4. Husband shall maintain health insurance, containing the
same, or to the maximum extent possible, similar benefits, for the two
minor children <Davis D. !lecker and Ross J. Becker) for as long as
Husband has th~ option of so doing through his current or future
employer, The health insul'ance benefits shall r;ontinue for each child
until that child turns 23 years of age, until that child graduates from
college or until Husband/s current or future employer no longer offers
to Husband health insurance benefits for the children of the parties _
whichever occurs earlier.
5, Wife agrees to return to Husband the cedar chest,
6. Wife agrees to sign off as heneficiary of Husband's
current retirement plan ilnd Husband agr.ees that he will indefinitely
instruct the current and any successive administrator of said plan
that each of the parties children, Davis D. Beck~r and Ross J. Becker,
shall be the beneficiaries on that account in the event of Husband's
death,
The intent. of this paragraph is that the two aforesaid
children shall be the remainder beneficiaries, in equal shares, of the
current principal in Husband's current retirement account and the
interest which accrues on that principal in the future. The
childrens' interest in the principal and accrued interest as aforesaid
shall remain the same regardless of whether said principal and
interest stays in the current account or is transferred to a different
account, Nothing herein, however, preventl3 Husband from taking during
his own lifetime and for his own be~efit the aforesaid principal and
accrued interest pursuant to plan provisions, rather it is the intent
of the parties that in the event Husband does not use this money
during his own lifetime and for his own benefit than each of the two
children shall receive, upon the death of Husband, ,in equal shares,
the remainder balance of the account. Husband agrees that all future
directlons he gives regarding this aforesaid principal and accrued
interest shall be consistent with the terms and int.ent set forth
herein,
7, On any tax return where the same is relevant, Wife shall be
entitled to any deduction for each of the children (Davis D. Becker and
Ross J. Becker).
8. Except aa herein otherwise provided, each party shall
continue to own and may dispose of hia or her property in any way or
manner, and each party expressly waives and relinquishes any and all
rights he or she may now have or hereafter acquire, under the present or
future laws of any' jurJ.sdiction, to share in the property of the other
or in the property of the estate of the other as a result of the marital
relationship, including without limitation, the right to equitable
distribution of marital ~roperty, alimony, alimony pendente lite and
counsel fees, and furt.her waiving all dower, courtesy, statutory
allowance or allowances, wi dow' a or widower's allowance, right to take
in intestacy, right to take against the will of the other, the right to
act as administrator or executor of the other' a estate, the right to
share in any ret irement accounts or pens ions of the other, 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 interest, right
and claims. It is further agreed that any property purchased by either
party subsequent to the signing hereof belongs solely to the party
purchasing the same.
9. Any and all property currently held by either of the
parties individually or titled in the name of a party individually,
shall remain that party's sole and separate property free and clear from
any claims of the other except as otherwise provided in this agreement.
The parties agree that at the time of signing this agreement all cash
has been equitably divided and that neither has a claim to cash in the
possession or control of the other.
10. Each party will be solely responsible for any debts or
liabilities in their respective names unless specifically directed
otherwise in this agreement.
11. Husband releases his inchoate intestate right in the
estate of Wife an.d Wife releases her inchoate intestate right in the
estate of Husband, and each of the parti.es hereto by these presents for
himself or herself, his or her heirs, executors, administrators, or
assigns, does remise, release, quit claim, and forever discharge the
other party hereto, his or her heirs, executors, administrators, or
assigns, or any of them, of any and all claims, demands, damages,
actions, causes of action or suits in law or in equity, of whatsoever
kind or nature, for or because of any matter or thing don.e, omitted, or
suffered to be done by such other party prior to the date hereof, except
that this release shall in no way exonerate or discharge either party
hereto from the obligations and promises made and imposed by reason of
thls Agreement and shaH in no way affect any cause of action in
absolute divorce which either party may have against the other.
12, Each of the parties hereby represents to the other that he
or she has not incurred any debt in the name of the other or which
obligates the other and which is not di~closed in this agreement. Both
parties hereto mutually agree and promise chat neither will contact or
otherwise incur debtll in the other's or joint names without the prior
permission and consent of the other party hereto. Both parties her~to
represent and warrant to the other party that they have not so
contracted any debts unbeknownst to the other up to the time and date of
this Agreement,
13. The parties acknowledge that they are aware of the income,
education, income potential, and assete and holdings of the other or
have had full and ample opportunity to become familiar with such
matters. Both parties acknowledge that they are able to support and
maintain themselves comfortably, without contribution from the other,
upon the income and assets owned by each of them. The parties hereby
accept the mutual covenants and terms of this Agreement and the benefits
and properties passed to them hereunder in lieu of any and all rights to
support or alimony for themselves, counsel fees, and alimony pendente
lite at this time and during any and all further or future actions of
divorce brought by either of the parties hereto and the parties do
hereby remise, release, quit claim, and relinquish for.ever any and all
of their said rights to support for themselves, counsel fees, alimony,
and alimony pendente lite during the pendency of or as a result of any'
such actions, as provided by the Divorce Code of Pennsylvania or any
other applicable statute, at this time and at any time in the future,
except as may be herein provided.
14. Both parties agree that they shall accept the terms and
provisio~s of this Agreement in full satisfaction of any claims they may
have under the Divorce Code of the Commonwealth of Pennsylvania,
including, but not limited to, alimony, alimony pendente lite, counsel
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fees, equitable distl'ibution, and the likl'l, It is anUdpated by the
parties that thia Agreement llhall be adopted by tho Oil 1<1 <:OIlI't by the
,
filing of a supplemental decree as part of the filial decl'ee 111 divorce,
The parties agree that said COUrt shall have full power and /lllthori.ty to
enforce this Agreement as an order or decree of <:,)Url, but. Bgree that
this Agreement sball not m(!l'ge with 01' be IlUpplallt.u,' by any ouch order
or decree of Court but llha} 1 ,~lBo be capilble of ""P'll'llt." el1for<:ement
under the contract law of the Commonwealth of [>',lIuluylvalllll,
15. It ill expl'essly stipulated thilt it <'Jlthln party fal10 i'I
the due performilnce of any of hill aI' hel' m/.lt()r["l <!hl i'Jutiollll undo l' this
a.greenlent, the other party ahall lhlVe the l'l~Jht, ,~t hiu or her election,
to aue for damagea for breach ther(!Q(, to uue tor lll'(tclf lc performance,
to reacind this agreenlent, 01' to ueek illlY oth"r 1"~J.~1 remedlell as may be
available, and the defaultiWJ party Uh,ll] lulmbllnw t.he nondefaulting
palty for any legal fees and IIXP'!II1ll'U tor IIny uelvlceu I.lIcurred in any
action or pJ;oceeding to compel p'llf(llmilll.'" llellllllltl<n,
16. The parties acknowled'J(l, n'IH'tllltlllt, und UI~rcll that thia
Agreement J;epresents a fair dlrll'o"lllOI1 of t1111lr' VIll'iOl1l.1 marltlll dghts
and obligations, in light of lh.' dlv'.II:"", I"IWII of I'ennuylvania and of
their /laaets, opportunit.i".., U1C'jll\'W, 1.\I1d ilIJIIILl'!/J, The division of
any pJ;operty between the part 11113 Is lIot Intended to be an exchange OJ;
sale of ouch itema, but only" "llviuloll of tl",ir vllrious marital asasta,
opportunitiea, and obligatl~nu,
17, This Agreell\ent con!:alnl.l till! whole Agreement between the
partiea hereto and iu In!:cndtld by t;ll<! partieu as the final and
integrated expr<lsuion '"11 the 'j!lbj,',,!: IlIiltl,el' herein, 1'here an't no otheJ;
terma, obligiltionf.l, COVlHl,Ultu, n'pr'''Ilt!ntilt.ioull or conditiona, oral or
otherwise, of any k Iud Whill'IJO"Vl,.., Nn l1Iorll f. \'''<It ton or. aml!ndment to thia
Agreement shall be ..,,: e""" IVl' 11111"",1 '11.' '10111\" !.. Hct forth in writing and
executed by a 11 P'1l t I"" h")'.,I, I,
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18. This Agreement shall be governed by the laws of
Pennsylvania and shllll be binding on the parties hereto, their heire,
executors, administrators and assigns,
IN WITNESS WHEREOF, the parti~s hereto have set their hands and
seals this date aforewritten.
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rD~g er .
(Seal)
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~ep J. D xon;-!:Squ re
ttorney for Daniel E. Becker
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Me ssa L. Bee er ,-.
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MELISSA L. BECKER,
I>laintiff
IN THE COURT OF COMMON I>LEAS OF
CUMBERLAND COUNTY, I>ENNSYLVANIA
vs.
NO. 96-3100
DANIEL E. BECKER,
Defendant
CIVIL ACTION - LAW
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under S3301(c) of the Divorce Code was
filed on June 3, 1996.
2. The m..rriage of Plaintiff and Defendant is irretrievably
broken and ninety (90 I days have elapsed from the date of filing and
service of the Complaint.
3. I consent to the entry of a final Decree in 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. S4904 relating to:> unsworn
falsification to authorities,
Date:~ ~/;t>Io/
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MELISSA L. BECKER,
Plaintiff
IN THE COURT Of COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO, 96-3100
DANIEL E. BECKER,
Defendant
CIVIL ACTION - LAW
AFfIDAVIT OF CONSENT
1, A Complaint in Divorce under S3301(c) of the Divorce Code was
filed on June 3, 1996.
2, The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing and
service of the Complaint.
3. I consent to the entry of a final Decree in 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, S4904 relating to unsworn
falsification to authorities.
Date:'/. (;1 ') It' (
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MELISSA L. BECKER,
Plaintiff
v.
I 'IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 96-3100 civil
I
I CIVIL ACTION - LAW
I IN DIVORCE
DANIEL E. BECKER,
Defendant
CERTIFICATE OF SERVICE
AND NOW, this 23rd day of December, 1996, I, MAX J.
SMITH, JR., Esqui,re, Attorney for Plaintiff, hereby certify
that I have this day sent a copy of Amended complaint in
Divorce by depositing a certified copy of the same in the
United states mail, postage prepaid, at Hershey, Pennsyl-
vania, addressed to:
Joseph J. Dixon, Esquire
Executive House, Suite *1
101 South Second Street
Harrisburg, PA 17101
J~~
MAX J. SMITH, J re
1.0. No. 32114
JAMES, SMITH & DURKIN
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
MELISSA L. BECKER, I tN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
I CIVIL AC'fION - LAW
I 96.31.00
VB. I NO. CIVIL 19
l>AN I E L E. BECKER, I
Defendant I IN DIVORCE
STATUS SHEE'l'
DATE I
4/29/97
ACTIVITIESI
Counsel are to get back to the Divorce Master's Office
with some suggested dates in August for an ,indignities
heRring
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I~ THE COURT OF COMMON P'LE.\S OF
CtOOlEJU..WD COUNT'i. PENNSnVANIA
~o:;r.'SS^ I.. nIWlq;;rl,
Plaintiff
VI.
...!?l.!1! [';1. f~, rIFCKf:r. ,
lIO. 96-3100 CiVIl L9
Mol l R8il L. Pt~C kt?'t"
~OTION FOR APPOI~~~T OF MASTER
(PLaintitf) on.t~~~,
following claiml:
1lI0VU the coure to appoint
a 11I&1 esr with rupee t to ehe
( X) Divorc.
( ) .~nulmene
( ) Alimony
( ) Alimony Pendente
Lice
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Distribution of Propert~'
Suppore
Counsel Fees
Costs and Expense.
and in suppore of the ~tion statel:
(l) Discovery is compleee 3S to che claims(s) for ~hich the
appointment of a malter is requested.
(2) The defendant (has) (ha ~1l appeared in
(by his attorney. ,loHeph ,r, Di xon
(3) The staturory groundGl) ror divorce (Ls)
the action (lla1UDc.U:lt)
,Esquire) .
(UIk) indlonitles
(~) Delete the inapplicable paragraph(s):
~.t.lj" ,~~ llll~ i. mOt.vlllJlWUuQo.
<:W:r y.~"all~llx~h-)~ub:eC<V*In- ><<::ie'Jl~ ~."I)ha
rorJla.1oltlaf >eillilllll<:
(c) The aceion Ls conteseed ~ith reapect :0 che rollowing
cla1mll: ell vorc.l:'
. (5) The actioii"TXWioivot$'J (does not involve) ,:omp14:o: issues of law
or fact.
(6) The hearing La 4XJlected eo
(7) Additional Lnior.nation. Lf
eh'ol1lrS) (days),
motion:
Daca: fl, n r i1 1 ~1. ,~ S i
ORDER APPOI~TI~G :lAST'ER
AND llowHL' L ~ -;19:i.2. t!. KCJbW ,".J. '~v1 .
il appointed uster '11th respect to the roll.owing claims: r 71/ ',) ,X
Esquire,
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MELISSA L. BECKER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-;'1/(' civil 'l'e'rm
CIVIL ACTION - LAW
IN DIVORCE
DANIEL E. BECKER,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you w~sh to defend
aqainet the claims set forth in the following pages, you
must take prompt action. You are warned that if you fail to
do eo, the case may prooeed without you and a deoree 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 the divorce is indignities or
irretrievable breakdown of marriage, you must request mar-
riage counseling. A list of marriage counselors is avail-
able in the Office of the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
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 CANNo'r AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND aUT WHERE YOU
CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR
1 COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013 3387
(717) 24?/;;~: @I f
MAX J. SMITH, ., Esqu re
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
MELISSA L. DECKER,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.11. }M) Civil ~ f.,J.,
va.
DANIEL E. BECKER,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, MEI,ISSA L. BECKER, by her
attorney, MAX J. SMITH, JR., Eequire, and seeks to obtain a
Decree in Divorce upon the grounds hereinafter more fully
set forthl
1. The Plaintiff., MELISSA L. BECKER, is an adult indi-
vidual and citizen of the United States of America, whose
address is 6 Olive Street, Wormleysburg, Cumberland County,
Pennsylvania 17043.
2. The Defendant, DANIEL E. BECKER, is an adult indi-
vidual and citizen of the United states of America, whose
address is 1111 C-2 Yverdon Drive, Camp Hill, Cumberland
County, Pennsylvania 17011.
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3. Plaintiff and Defendant have been bona fide resi-
dents in the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this Com-
plaint.
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4. Plaintiff and Defendant were married on or about
July 7, 1990, in camp Hill, Pennsylvania.
5. Neither Plaintiff nor Defendant is a member of the
United States Armed Services.
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6. Plaintiff and Defendant have both been advi.ed of
the availability of marital oounselinq and that eaoh may
have the riqht to requeBt that the oourt require the parties
to partioipate in oounBelinq.
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7. Plaintiff averB that there has been no prior action
tor divoroe or annulment of the marriaqe filed by either
party in this or any other juriBdiotion.
8. Plaintift averB that the marriaqe is irretrievably
broken.
WHEREFORE, Plaintiff
enter a Dec~ee of Divorce
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Datedl May 28, 1996
prays your Honorable Court to
from the bO.?d\.\Of m~ rimony.
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MAX . SMITH, J ., Esquire
James, smith , Durkin
P.O. Box 650
Hershey, PA 11033
(717) 533-3280
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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.
section 4904, relating to unsworn falsification to authori-
ties.
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MELISSA L. BECKER
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MELISSA L. BECKER,
Plaintiff
VB.
IN THE COURT OF COMMON PLEAS
CUMBERr~D COUNTY, PENNSYLVANIA
I NO. 96-3100 civil Term
I
t CXVIL ACTION - LAW
IN DIVORCE
DANIEL E. BECKER,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUEn 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
divoroe or annulment may be entered against you by the
oourt. 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, inoluding oustody or visitation of your
ohildren.
When the ground for the divorce is indignities or
irretrievable breakdown of marriage, you must request mar-
riage counseling. A list of marriage counselors is avail-
able in the Office of the prothonotary at
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
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 COURTHOUSE, 4th FLOOR
1 COURTHOUSE SQUARE
CARLISLE, PEN.SYLt~A 1701' "S7
(717) 2uJl;cOy()) 1-/ --
MAX J. SMITH, JR., re
Attorney for Plain
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
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6. Plaintiff and Defendant have both been advised of
the availability of marital counseling and that each may
have the right to request that the court require the partie.
to parUoipate in counseling.
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7. Plaintiff avers that there has been no prior aotion
for divorce or annulment of the marriage filed by either
party in this or any other jurisdiction.
8. Plaintiff avers that the marriage is irretrievably
broken, pursuant to section 3301(c) of The Pennsylvania Di~
voroe Code Act 206 of 1990.
9. Defendant has offered such indignities to the
Plaintiff, the innooent and injured spouse, as to render her
oondition intolerable and life burdensome.
10. This action is not collusive.
WHEREFORE, Plaintiff prays your Honorable Court to
enter a Decree of Divorce from th bonds of matrimony.
Dated I Deoember~, 1996
C / h, (~)) tt6-
MAX J. SMITH, JR. re
I.D. No. 32114
James, Smith & Durkin
P.O. Box 650
Hershey, PA 17033
(717) 533-3280