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HomeMy WebLinkAbout96-05741 . . . .. .--~~--~~~~--~~~~~~~~>-~~~~-_.~~ 8. ---....-...--"-...- ---.........~~....... ...... , . ~ 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 8 * . . ~ ~ . 8 8 8 $ . 8 8 8 , - 8 . . ;, _ _w . q ... .. -ltC. .w.. " 8 . 8 8 . . $ 8 . . . . . . ~ . .. . . . e. . 8 . 8 8 8 8 8 8 8 ~ 8 ,8 !~ , . ',~ ; 'iii , . I~ ., ~ .~~-~--~~-~.~...~~.*~*~.~.~'~.~~'~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '* PENNA, JEAN H. HEULER, Plaintiff N ll. 96~5?4~. ."....,..". It) \'t'I..~H!'i DENNIS R. HEULER, AND NOW, ........ .. ?e:6r:'*7 ..o:l,?..., 19 .~1:.., It Is ordered ond Jean H. Meuler decreed that ",.,..",.""."""".."."".,.,.".,.,',..., plaintiff, and. , , , . . ~~,~~~~, .~: , ~.~~~~.r, , , , , . , , . . , , , . , , ,. . . , , , . ,. , , . . . " defendant, are divorced from the bonds of matrimony, The court retains lurlsdlctlon of the following claims which have been raised of record In this action for which a final order has not yet been entered: The Marriage Settlement Agreement entered into by the parties .,.., ,......... ......,.......... '.....".......,...,.. ,... ............ "'" "'~~. ~fl.cql;"rp,t:I!~e,d. .tl,lro. ,I?\.I':. .TJQ~. /11l1n~llq .1(/~I=,h. ~n~ .Oef.:.l:ee."....,.,. . . i Defendant DECREE IN DIVORCE IJ~T e C/lIi Atleol ' lL;.. I . f" / /#,' I '7l'. Y J, C>;,f' fi,/(C( I<.-~(",..~~, ~J"~~'T~~ 'l.-411if ;-J. ..-k,/Ir ~;{ If ' / ..-Jlrnlhnnnlftry , ,;) .;J ~ ,17 ta-ll~ /iAtt'4/ ?J;- /;71 j1~~ c} .~? ,9'1 7~~ /J:t.R/'~ dfI' " , . t .....~. LAW OFFICES I\IJRIN tic JACOllS<)~ 8110 DERRY STREET IlARRI~PlJRO, "A 1~1I1.111\() 17171161.1111 'fa"'~<"---- --.-T _.. .-. M _........4-.-_~.~_-,--.~..~- ..'~ J>>OST-NUPTIAL AGREEMENT THIS AGREEMENT made this M day of b'-C))16"'~ I 9.1L , by and between DENNIS MEULER of New Cumberland, Cumberland County, Pennsylvania, hereinafter, for purposes of convenience, tenned "HUSBAND" and JEAN M. MEULER of Harrisburg. Dauphin County, Pennsylvania, hereinafter, for purposes of convenience, temled "WIFE", WHEREAS, the parties hereto are Husband and Wife, having been married on October 24, 1974 In Lebanon County, Pennsylvania. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the Parties and It is the Intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the Parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, Including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the sellllng of all matters between them relatIng to the past, present and future support, alimony and/or maintenance of WIFE by HUSBAND or HUSBAND by WIFE; and In general, the settling of any and all claims and possible claims by one allainstthe other or allalnsttheir respective estates. NOW, THEREFORE, in consideration of the promises and of the mutual covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged hy each of the Parties hereto, WIFB and HUSBAND, each intending to he legally hound, covenalll and agree as follows: i t 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This agreement shall not be considered an affect or bar on the legal right of HUSBAND and WIFE to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either Party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either Party hereto of any act or acts on the part of the other Party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof, The parties intend to secure a mutual consent, No Fault Divorce pursuant to the temlS of section 3301(d) of the Divorce Code of 1980 as amended, 2, EFFECT OF DIVORCE DECREE The Parties agree that unless otherwise specif1cally provided herein. this Agreement shall continue In full force and effect after such time as a tinal Decree In Divorce may be entered with respect to the Parties. 3, AGREEMENT TO BE INCORPORATED BUT NOT MERGED INTO DIVORCE DECREE The Parties agree that the temlS of this Agreement shall be incorporated, but not merged, into any divorce decree which may be entered with respect to them. The Parties further agree that the Court of Common Pleas which may enter such divorce decree shall retain continuing Jurisdiction over the parties and the subject mailer of the Agreement for the purpose of enforcement of any of the provisions herein. 4. HATE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the 2 date of execution by the Party last executing this Agreement. S, DISTRIBUTION DATE The transfer of property I funds andlor documents provided for herein shall only take place on the "distribution date" which shall he defined as the date of execution of this Agreement unless otherwise specified herein. 6. ADVICE m' A1TOI\~EY Each party acknowledges that he or she has had the opportunity to seek the advice of legal counsel in the drafling of this Agreement, prior to the execution thereof. The WIFE had the benefit of Leslie David Jacobson, Esquire. The HUSBAND acknowledges that he elected not to seek the advise of counsel. Each party acknowledges that he or she understands the tenus of this Agreement and fully agrees to comply wilh the tenus herein. 7, PERSONAL RIGHTS HUSBAND and WIPE may and shall, at all times hereafler, live separate and apart, They shall be free from any control, restraint, interference or authorily, direct or indirect, by the olher in all respects as fully as if they were unmarried. They may reside at such place or places as they may select, Each may, for his or her separate use or benefit, conduct, carry on or engage In any huslness, occupation, profession or employment which to him or her may seem advisable, HUSBAND and WIFE shall not molest, harass, dlsturh or malign each other or thc respective families of each other nor compel or allemptto clllnpelthe other 10 cohabit or dwell by any means or In any manncr whatsoever wilh him or her. 8. MU1'U.\L RKl.KA!mS HUSIlAND and WIFE each do hereby mutually remise, release, quil claim and forever J discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such OIher, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have agnlnst such other, the estate of such other or any part thereof, whether arising out of any fomler acts, contracts, engagements or lIablllties of such other by way of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right 10 treat a IIfelhne 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 (a) Ihe Commonwealth, (b) any state, commonwealth or territory of the United States, or (c) any other country. or any rights which either Party may have or at any time hereafter have for past, present or future support or maintenance, alimony, pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquirc, except and only except all rights and ngreemcnts and obllgallons of whatsocver nature arising or which may arise under this Agreemenl or for the breach of any provision thereof. 4 9. PERSONAL PROPERTY The panles acknowledge that all Items of tangible and intangible marital personal propcny have been divided between them to the satisfaction of each, including household furnishings and other similar propeny. Neither party shall make any claim to any such Items of marital propeny, or of the separate personal propeny of either pany, which are now In the possession and/or under the control of the other, Should it become necessary, the parties each agree to sign, upon request, any tilles or documents necessary 10 give effecl to this paragraph. The propeny shall be deemed to be in the possession or under the control of ellher pany If, In the case of tangible personal propeny, the Item Is physically in the possession or control of the pany at the time of the signing of this Agreement, and in the case of intangible personal propeny, If any physical or written evidence of ownership. such as a passbook, checkbook, polley or cenil1cale of Insurance or other similar writing Is in the possession or control of the pany. 10. REAL PROPERTY The panles own property located at 305 Vesta Drive, Dauphin, PA. HUSBAND shall convey by deed all of his righi, title and inlerestto WIFE in eXchange for Sixteen Thousand Five Hundred and 00/100 Dollars ($16,500,00). Said transfer 10 take place no later thanthlny (30) days aOer the entry of the divorce. WIFE assumes all liabilities associated with the propeny and agrees to hold HUSBAND hannless for any cla1rn regarding said propeny, II, MOTOR VElUCUS The HUSBAND wlllves Ilny right to or Interest In WIFE'S vehicle and agrees thaI WIFE shall be the sole owner of any vehicle in her possession, HUSBAND agrees to execute the title 5 t to said vehicle, if appropriate, for effecting the transfer to WIFE. WIFE agrees to indemnify and hold HUSBAND hannless for payment of any loans or indebtedness with respect to her vehicle or any vehicle she owns or previously owned. 12. t\FfER-ACOUlRED PERSONAL PROPERTY Each of the Parties shal1 hereafter own and enjoy, independently of any claims or right of the other, al1ltems of personal property, tangible or intangible, hereafter acquired by him or her, with futl power in him or her to dispose of same as ful1y and effectively, in al1 respects and for al1 purposes, as though he or she were unmarried, 13. ALIMONY. ALIMONY I)ENDENTE UTE. SUPPORT AND COUNSEL mES The parties further hereto agree and do hereby waive any right and/or claim they may have, both now and In the future, against the other for Alimony. Alimony Pendent Lite. Support. Maintenance, Counsel Fees and Costs. 14, WIFE'S DEBTS WIFE represents and warrants to HUSBAND that since the Parties' marital separation, she has not contracted or Incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of the Agreement, for which HUSBAND or his estate might be responsible. WIFE shall Indemnify and save hamlless HUSBAND from any and al1 claims or demands made against him by reason of debts or obligations Incurred by her, 6 ( IS. HUSBAND'S DlmTS HUSBAND represents and warrants to WIFE that since the l)al1les' marital separation, he has not contracted or Incurred any debt or liability for which WIFE or her eslate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or Incur any debl or lIabllily after the execution of Ihis Agreement. for which WIFE or her estate might be responsible. HUSBAND shall Indemnify and save harmless WIFE from any and all claims or demands made against her by reason of debts or obligations Incurred by him, 16. BANK ACCOUNTS. CERTIJ1ICATES.INSURANCE POLICIES. PENSION FUNDS AND O1'IIl~R ASSETS, Each party shall retain any Individual retirement account In his or her name, Each party shall retain as his or her own property, any pension, Mock, savings or other planthruullh his or her place of employment, or otherwise, whether vested or non vested. Each party shall be and remain the sole owner of any other asset In his or her control not specifically covered by other provisions In this Agreement. Should II become necessary, each party agrees to sign any other titles or documents necessary to give effect to this section upon request of the other party, 17, FINAL EOUITAULE mVISION m'I'ROI)ERTV The Parties agree that Ihe division of all property set forth In this Agreement Is equitable and In the event an action In Divorce Is commenced, bolh Parties relinquish the right 10 divide said property 111 any manner not consistent wllh the terms set forth herein. It Is further the Intent, understanding and agreement of the Parties Ihal this Al!reemenl Is a full. final, complete and equllable property division. 7 , 18, WAIVER OR MODlFICATJON TO BE IN WRITING No modification or waiver of any of the temls hereof shall be valid unless In writing and signed by both Parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature, 19. MUTUAL COOrERATION Each Party shall, at any time and from time to time hereafter, take any and all steps and execute. acknowledge and deliver to the other Party, any and all further Instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 20, LAW OF PENNSYLVANIA API)LlCABI,E This Agreement shall be construed In accordance with the laws of the Commonwealth of Pennsylvania, 21. AGJ{EEMJj:NT BINDING ON I-JEIRS This Agreement constitutes the entire understanding of the Parties and supersedes any and all prior agreements and negotiations between them, There are no representations or warranties other than those expressly set forth herein. 22. NO WAIVER 01<' IlEI<'AULT This Agreement shall remain In full force and effect unless and untlltemllnated pursuant to the tenus of this Agreement, The failure of either party to insist upon strict perfonnance of any of the provisions of this Agreement shall in no way affectlhe right of such Party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall It be construed B as a waiver of strict perfonnance of any other obligations herein, 23. BJlEACH If for any reason either the HUSBAND or the WIFE falls to perfonn his or her obligations hereunder to the olher spouse, and Ihe other spouse Incurs any expense thereby (Including, but not limited to, legal fees and costs) In enforcing his or her rights, the non- breaching Party shall have the right, at his or her election, 10 sue In law or In equity to enforce any rights and remedies which Ihe Party may have and Ihe spouse who falled to perfonn the obligations agrees to Indemnify the other spouse and hold him or her hannless for any and all such expenses, 24, lIEADlNGS NOT PART OF AGREEMENT Any heading preceding the text of the several paragraphS and subparagraphs hereof, are Inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect Its meaning, construction or effect. IN WITNESS WHEREOF, and Intending to be legally bound by the tennS hereof, the parties have hereunto set their hands and seals the day, month and year first above written. WITNESSI ~t1<"i- ~"i.<. -(SBAL) DENNIS MEULER )JJ~ J AN M, MEUtER meulelJln,ngr 9 (SEAL) i'. >- fr CI ~. ~,t:'; "- .. ,. .-- .or " ,"( EF i1 ~. ';.c ;. ~') 11: , ' ' . &: ~.. ; .J "I '. ~j' f\l ,>! , f!" C 14:' ';1 ., .... 1.. d ,... ':5 0' \...i ,- MIIUN &.JACOIISON 81!O'll~RRYSlRl!b" HARRISUURG, I'A 17111.!2l10 (7171561,15" JEAN M, MEULER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-5741 CIVIL ACTION - LAW IN DIVORCE v. DENNIS R, MEULER, Defendant rRAEqPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, togcther with the following infonnatlon, to the Court for entry of a divorce decrce: 1. Ground for divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code, 2. Date and manner of service of the complaint: served by First Class Mall on October 18, 1996, 3(1), Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: December 23, 1996; (2), Date of service of the Plaintiffs Affidavit upon the Defendant: December 31, 1996. 4. Relatcd claims pending: N/A 5, Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record was served on Defendant by First Class Mall on January 22, 1997. Respectfully submitted, MIRIN & JACOBSON DATED: 8150 Derry Street Harrisburg, PA 17111-5260 (717) 561-1515 mculer ,doc slle David Jac Attorney 10# 52 3 Attorney for Plaintiff . . . . ~ . v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5741 CIVIL ACTION. LAW IN DIVORCE JEAN M, MEULER, Plaintiff DENNIS R, MEULER, Defendant CERTIFICATE OF SERVICE I, the undersigned employee in the law orflces of Mlrln & Jacobson, hereby certify that I served a copy of lite foregoing Praecipe to Transmit Record and Counler-Arfldavit by depositing the same in the U,S. Mail, First Class, postage prepaid to the following: Mr, Dennis R. Meuler 1531 Bridge Street New Cumberland, PA 17070 , MIRIN & JACOBSON DATED:Yebrnary 13. 1997 DY:""/rf.J ~{ I, )J-'.;fl_~'it,.,..-J , Karen A, Zlmmennan , tr, r::l ~:: N r-l .. >r. I'r, _0 t'" ' .<. , ~' "~ ',..~ r.:\' .... .:..~. .J> lit ,~ ~l, - ,'j) "I ~) [t\\' rf' "11,1 ~ .:\ f,- I:' ~; I'. r- -; (.) 0' L> . . " t "& J .!) g 00 In N ~~ '1" -; Cl .:> 0\ . ::r 5 ~ ~ ~ ~i cq u 0::1 - ti Cl U) a CI' P'l ;~ ..... lj.j ~ 'tl :::I ..... 08 ~ .-l ~ o iii ~ ~ ~ ,e 'tl Ml:l U .~ 1'10 fa. .... I:lu 0 f ;l:l ~~ ~ o!~ ~ . IE ~ >-~ ~ I> i~ . ~ ilP . Pl ::E: Ul ~ i \ uf:l l:l . -. ~ " ... JEAN M. MEULER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, qLr ''/1'1\ CIVIL ACTION - LAW IN DIVORCE DENNIS R. MEULER. Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued In court. If you wish to defend against the claims set forth In the following pages, you must take prompt action. You are warned that If you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the court, A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights Important to you, including custody or visitation of your children. When the grounds 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. PA 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 RJGHT 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 Carlisle, PA 17013 (717) 240-6200 ~ ... JEAN M, MEULER, Plaintiff IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v, NO, 'ft. 'j ;'11 (/" ,'/1.,. DENNIS R, MEULER, Defendant CIVIL ACTION . LAW IN DIVORCE COMPLAINT UNDER 330lCdl OF THE DIVORCE CODE I. Plaintiff Is Jean M. Meuler, who currently rerldes at 4123 Fawn Drive, Apartment A, Harrisburg, Dauphin County, PA 17112, 2, Defendant Is Dennis R. Meuler, who currently resides at 1531 Bridge Street, New Cumberland, Cumberland County, PA 17070. 3. Plaintiff and Defendant have been bona fide residents In the Commonwealth for at least six months Immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 24, 1974 in Lebanon, Lebanon County, Pennsylvania, 5, There have been no prior actions of divorce or for annulment between the parties except an action filed by Defendant In 1991 which was subsequently dismissed by the Court of Common Pleas for inactivity. The parties have been \lving separately and apart since Febnlary of 1991. 6, The marriage is irretrievably broken. 7, Plaintiff has been advised that counseling is available and that Plaintiff may have the right to requestthatlhe Court require the parties 10 participate In counseling. I - 8, Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. MIRIN & JACOnSO " DATED: 8150 Derry Street Harrisburg, PA 17111-5260 (717) 561-1S15 Jmeuldlv,cmp 2 ~ ~ CI!RTIFICATE OF SERVICE I, lhe undersigned employee in Ule law offices of Mirln & Jacobson, hereby certify thaI I served a lrue and correCl copy of lhe foregoing Complainl In Divorce by depositing lhe same In lhe U.S. Mall, FlrSl Class and Certified, postage prepaid 10 lhe following: Mr. Dennis Meuler 1531 Bridge Slreel New Cumberland, PA 17070 MIRlN & JACOBSON DATED: Oclober lB. 1996 By: 3 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5741 CIVIL ACTION. LAW IN DIVORCE JEAN M. MEULER, Plainllff DENNIS R. MEULER, Defendanl AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties 10 lhls aclion separaled on February 28, 1991 and have continued 10 live separale and apart for a period of alleasllwo years. 2. The marriage is irrelrievably broken. ". 3. I understand lhall may lose rlghls concemlng alimony, division of property, lawyer's fees or expenses If I do nol claim lhem before a divorce Is granled. I verify thaI the slalemenls made In this Affidavit are 111le and correcl. I undersland that false statemenls herein are made subjecllo lhe penalties of 18 Pa.C.S. fi4904 relaling 10 unsworn falsll1calion 10 authorhles. Dale: \ 'V~,V' ~V 7v~. to! fi: 1'"' .....,. '. ~ \-:: f.":. 1!1 :)..t' ~\:' ,:~\,.j .. (~ :r: ...~ t~ !.f' ... ;::):; ~\. c::\ ~ : (;~ ('" , . fi\'. t1: I:H~ i~. t;, 1:.1 ~ . - u. In is u Ul :" v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5741 CIVIL ACTION - LAW IN DIVORCE ... LAW OFFICES l\Il,.RIN ~JACOBSON 1150 DERRY STREET HARRISBURO. PA 11111.5260 (1111561.1515 JEAN M. MEULER, Plalnllff DENNIS R. MEULER, Defendanl CERTIFICATE OF SERVICE I, lhe undersigned employee In lhe law offices of Mlrln & Jacobson, hereby certify that I served a true and correcl copy of the foregoing Affidavit and NOllce by deposhing the same In the U.S. Mall, Flrsl Class, postage prepaid to the following: Mr. Dennis R. Meu1er 1531 Bridge Slreel New Cumberland, PA 17070 DATED: December 31, 1996 MIRlN & JACOBSON By,L_4.1.~~ Karen A. ZI~nnan . JEAN M. MEULER, Plainllff IN THE COURT or COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96.5741 CIVIL ACTION - LAW IN DIVORCE DENNIS R. MEULER, Defendonl NOTICE If you wish 10 defend any of the slalemenls sel forth in this Affidavit, you must file a counler-affidavit within twenly days ofter this Affidavit has been served upon you or the SlalemenlS will be admlued. , ''''t-. f1 - JEAN M. MEULER. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96.5741 DENNIS R. MEULER, Defendant CIVIL ACTION. LAW IN DIVORCE 'J -~.~ Q ~~ :c:1 "1 :'l :..) \::J ...., "1 ,. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE ,'" '. " ~ ..." .... ..- :;d~; ;:~ ' 'i '.l "im =l ~.:t -, .... ... w .', " ... .:.,) 1. The panles 10 this action separaled on Feb11lary 28, 1991 and have continUe!! 10 live separale and apart for a period of al least lWo years. 2. The marriage is Irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of properry, lawyer's fees or expenses if I do not claim them before a divorce Is granted. I verify thaI the statements made in lhis Affidavit are true and correct. I understand thaI false stalemenls herein are made subJeclto the penallies of 18 Pa.C,S. ti4904 relating to unsworn falsification to authorities. , Dale: \ -v\,'" \ ~V /Ju~. ... -. It~ U... . r I. .. : :~i ' . ~i )" ~~ " It-i' \:,,:j ~' ". . ;1 .. I .]:'=0 -, ir;") "': . . 'Q.. I' -. . j H. r- I,J 0' ,i . ~ LAW OFFICES r.URIN 6.JAronsoN suo DERRY STREET HARRISBURO. PA 11111.5260 17171 561,Illl .. JEAN M. MEULER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96.5741 CIVIL ACTION - LAW IN DIVORCE v. DENNIS R. MEULER, Defendanl CERTIFICATE OF SERVICE I, the undersigned employee In the law offices of Mirin & Jacobson, hereby certify lhBll served the original of lhe foregoing NOllce of Inlenllo Requesl Enlry of Divorce Decree and Counler-Affidavll by deposlling the sallie in lhe U.S. Mail, Firsl Class, poslBge prepaid 10 the following: Mr. Dennis R. Meuler 1531 Bridge Street New Cumberland, PA 17070 MIRlN & JACOBSON DATED: Januarv 22. 1997 By: . , ~ .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5741 CIVIL ACTION - LAW IN DIVORCE JEAN M. MEULER. Plalnllff DENNIS R. MEULER, Dcfendanl NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Mr. Dennis R. Meuler You have becn sued In all action for divorce. You have failed to answer the complainl or file a counter-affidavillO Ule Plaillliff's affidavit. Therefore, on or after February 12, 1997, Ule Plainllff can requesllhe court 10 enler a final decrce in divorce. If you do nol file with the Prothonotary of the court an answer with your slgnalure notarized or verified or a counler.affidavll by the above dale, the Court can enter a final decree In divorce. Unless you have already filed with the Court a wriuen claim for economic relief, you muSl do so by the above date or the Court may granllhe divorce and you wUllose forever lhe righllo ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Admlnlslrator 41h Floor. Cumberland Counly Courthouse Carlisle, PA 17013 (717) 240-6200 I '. . . , - . . JEAN M. MEULER. Plaillliff IN THE COURT OF COM~ION PLEAS CUMBERLAND cor:-;TY. PENNSYLVANIA v. NO, 96-5741 DENNIS R. MEULER. Defendant CIVIL ACTION. LA \V IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmll lhe record, together with the following infonnmion, 10 the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Secllon 3301(d) of the Divorce Code. 2. Dale and manner of service of the complaint: served by First Class Mail on October 18, 1996. 3(1). Dale of execution of the Plaintiffs Affidavil required by Section 3301(d) of the Divorce Code: December 23, 1996; (2). Dale of service of the Plaintiffs Affidavll upon lhe Defendant: December ~ I, 1996. 4. Related claims pending: N/A 5. Date and manner of service of lhe NOlice of Intention 10 File Praecipe 10 Transmil Record, a copy of which is allached: January 22, 1997 DATED: ReS~IIY suhmllled, MI '~.' I)O~N lJ; IPJr 8150 Derry Streel lIarrlsburu, PA 17 t 11.5260 li(7) 561.1.51.5 meulcr.doc By: Leslie David Jacobson Allomey 10# 52673 Allomey for Plaintiff I " . . " . .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-5741 CIVIL ACTION - LAW IN DIVORCE JEAN M. MEULER, Plaintiff DENNIS R. MEULER, Defendanl COUNTER.AFFIDA VIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check eltller (a) or (b): .JL. (a) J do not oppose Ule enlry of a divorce decree. _ (b) I oppose the entry of a divorce decree because (Check (I), (II) or both): (I) The parties 10 this action have nollived separate and apart for a period of Bt leasllwo years. (iI) The marriage is nol Irrelrlevab1y broken. 2. Check ellher (a) or (b): -1L (a) I do nol wish 10 make any claims for economic relief. I undersland thaI I may lose rlghls concerning alimony, division of property, lawyer's fees or expenses if I do nol claim them before the divorce Is granled. _ (b) I wish to claim economic relief which may Include alimony, division of property, lawyer's fees or expcnses or other Imporlanl rlghlS. ... 1 verify lhal the stalemenlS made In this Counler-Affidavll arc true and correcl. I understand lhat false slatemenls hercln are made subjccllo lhe penalties of IB Pa.C.S, fi4904 relating to unsworn falsification 10 aUlhorllles. DATED: Dennis R. Meuler, Defendanl "" ... Ifl ~ I~ \... I .. , r t1J'. .:'": " 1)- " li"\ " ,"c-o .~~~ l " I' [r) ,_'1 \. (.1 ~.. j. . ,{ij l., . '.~ I .' I' r- J t.) 0'\ U - . '. . O~; . MIHIN &.IACOIISON 81lU l,rnmvimu:n IIARRISlIlJRU. I'^ 17111.5260 (717)'61.11I5 . I' . .- JEAN M. MEULER, Plalnllff IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-5741 CIVIL ACTION . LAW IN DIVORCE v. DENNIS R. MEULER, Defendanl COUNTER.AFFlDA VIT UNDER SECTION 3301(d) OF TilE DIVORCE CODE 1. Check ellher (a) or (b): ..ll.- (a) I do nol oppose lhe enlry of a divorce decree. _ (b) I oppose lhe entry of a divorce decree because (Check (i), (Ii) or both): (i) The parties 10 lhis aClion have not lived separate and apart for a period of alleasl two years. \ (Ii) The marriage Is nOllrretrievably broken. 2. Check ellher (a) or (b): -1L (B) I do nol wish 10 make any claims for economic relief. I undersland lhall may lose rights concerning alimony, division of property. lawyer's fees or expenses if I do nol claim them before Ihe divorce Is granled. _ (b) I wish 10 claim economic relief which may Include alimony, division of property, lawyer's fees or expenses or other Importanl rights. I verify lhat lhe stalemenls made In Ihls Counter-Affldovil are lrue and correct. I undersland lhol false slatemenls herein are made subject to the penallles of 18 Pa.C.S. 04904 relaling 10 unsworn falsificallon 10 aUlhorllles. ) DATED: / Ii/) 9/ . ?i 0 ,... l N l:~: F .. ,--, l,~ uJ"- '. J ~t~ I':'" .-..\,.. ::\ ; ~~ . ...... fill '!rl 1jll N \~ Uy 0' , 'to ~: t:: 'I,. \5 {;; ;~) lJ Q, Clio 00 .,.. ..:;. A . . f ,. . . I .