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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
PENNA.
EDWARD MARK RIGLING.
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NO.
2000-470
Pl"inriff
VERSUS
KRISTEN BACON RIGLING,
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Defendant
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DECREE IN
DIVORCE
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AND NOW,
, PLAINTIFF,
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DECREED THAT
AND
KRISTEN BACON RIGLING
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY. The terms of the
Marriage Settlement Agreement entered into by the parties
on July 15, 2000, are incorporated herein.
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;
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HONOTARY
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AGREEMENT
BETWEEN
KRISTEN B. RIGLING
AND
EDWARD M. RIGLING
KatWeen Carey Daley, Esquire
Counsel for Wife
Barbara Sumple-Sullivan, Esquire
Counsel for Husband
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TABLE OF CONTENTS
SECTION I:
Introduction ............................................................... 3
SECTION II:
General Provisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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SECTION III:
Alimony and Alimony Pendente Lite
Provisions ................. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
SECTION IV:
Property Distribution Provisions ............................................... 11
SECTION V:
Closing Provisions and Execution .............................................. 14
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SECTION I
INTRODUCTION
THIS AGREEMENT made this 4. "S {-l.. day of
between KRISTEN B. RIGLING ("Wife") and EDWARD M.
2000, by and
("Husband").
WITNESSETH:
WHEREAS, KristenB. Rigling, Social Security Number 183-48-7443, was born on February
22, 1972, and currently resides at 409 3" Street, New Cumberland, Cumberland County,
Pennsylvania 17070.
WHEREAS, Edward M. Rigling, Social Security Number 159-52-8023, was born on May
5, 1971, and currently resides at 1111 Apple Drive, Apartment No.7, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
WHEREAS, the parties hereto are Husband and Wife, having been married on April 19,
1997, in New Cumberland, Cumberland County, Pennsylvania.
WHEREAS, the parties have no minor children.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties, and it is the intention of Wife and Husband 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, the settling
of all matters between them relating to the ownership ofreal and personal property, the equitable
distribution of such property; the settling of all matters between them relating to the past, present and
future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the
settling of any and all claims and possible claims by one against the other or against their respective
estates.
NOW, THEREFORE, in consideration of the mutual promises, set forth herein and for other
good and valuable considerations, Wife and Husband, each intending to be legally bound hereby
agrees as follows:
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SECTION II
GENERAL PROVISIONS
1. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of
~3301(c) of the Divorce Code of 1980, as amended and will execute the documents necessary to
effectuate a divorce under those provisions concurrently with the execution of this Agreement.
2. EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provided herein, this Agreement shall
continue in full force and effect after such time as a final decree in divorce may be entered with
respect to the parties.
3. AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE
DECREE
The provisions of this Agreement may be incorporated by reference but shall not be deemed
merged into any judgment or decree for divorce obtained by either party. This agreement shall
survive any such final decree of divorce, shall be entirely independent thereof, and the parties intend
that all obligations contained herein shatl retain their contractual nature in any enforcement
proceedings, whether enforcement is soughtin an action on the contract itself or in any enforcement
action filed to the divorce complaint.
4. DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined as the date
upon which it is executed by the parties if they have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date
of execution by the party last executing this Agreement.
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5. ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to Wife by
her attorney, Kathleen Carey Daley, Esquire. The provisions of this Agreement and their legal effect
have been fully explained to Husband by his attorney, Barbara Sumple-Sullivan, Esquire. The parties
acknowledge that they fully understand the facts and have been fully informed as to their legal rights
and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair
and equitable and that it is being entered into freely and voluntarily, after having received such advice
and with such knowledge and that execution of this Agreement is not the result of any duress or
undue influence and that it is not the result of any collusion or improper or illegal agreement or
agreements.
6. TAX PROVISIONS
The parties believe and agree, and have been so advised by their respective attorneys, that the
division of property heretofore made by this Agreement is a non-taxable division of property between
co-owners rather than a taxable sale or exchange of such property. Each party promises not to take
any position with respect to the adjusted basis ofthe property assigned to him or her or with respect
to any other issue which is inconsistent with the position set forth in the preceding sentence on his
or her federal or state income tax returns.
The parties have heretofore filed joint federal and state tax returns. Both parties agree that
in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any
such tax is made against either of them, each will indemnifY and hold harmless the other from and
against any loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely
and entirely by the individual who is finally determined to be the cause of the misrepresentations or
failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
7. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall
be free from any contact, restraint, interference or authority, direct or indirect, by the other in all
respects as fully as ifthey were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or her may
seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the
respective families of each other nor compel or attempt to compel the other to cohabit or dwell by
any means whatsoever with him or her.
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8. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
A. Each party hereby absolutely and unconditionally releases and forever discharges the
other and the estate ofthe other for all purposes from any and all rights and obligations which either
may have, or at any time hereafter have for past, present or future support or maintenance, alimony
pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or
obligation, economic or otherwise, whether arising out of the marital relationship or otherwise,
including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and
amendments, as well as under any other law of any other jurisdiction, except and only except all
rights, agreements and obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision thereof Neither party shall have any obligation to the
other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges the
other and his or her heirs, executors, administrations, assigns, property and estate from any and all
rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the
parties or otherwise, whether now existing or hereafter arising. The above release shall be effective
regardless of whether such claims arise out of any former or future acts, contracts, engagements or
liabilities or the other or by way of dower, courtesy, widow'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 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 or the United States, or any other country. It is expressly understood,
however, that neither the provisions of this release nor the subsequent entry of a divorce decree are
intended to defeat the right of either party to receive any insurance proceeds at the death ofthe other
of which she or he is the named beneficiary (whether the beneficiary designation was made prior or
subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest
or residuary portion ofthe other's estate under his or her will, or to act as personal representative or
executor if so named by the will of the other, whether such will was executed prior or subsequent to
this Agreement.
C. Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations of the parties contained in this Agreement and such rights as are
expressly reserved herein, each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims, rights or demands
whatsoever, in law or in equity, which either party ever had or now has against the other.
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9. FINANCIAL DISCLOSURE
The parties have disclosed to each other and they are each aware of the extent of each other's
income, assets, liabilities, holdings and estate. Each of the parties acknowledges that he or she is
aware of his or her right to seek discovery including, but not limited to, written interrogatories,
motions for production of documents, depositions and all other means of discovery permitted under
the Pennsylvania Rules of Civil Procedure. Each party is satisfied that no additional information is
necessary for the execution of this Agreement.
10. PRESERVATION OF RECORDS
Each party will keep and preserve for a period offour (4) years from the date of their divorce
decree all financial records relating to the marital estate, and each party will allow the other party
access to those records in the event of tax audits.
11. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in writing and
signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
12. REMEDIES IN THE EVENT OF A BREACH
Any party breaching this Agreement shall be liable to the other party for all costs, including
reasonable counsel fees incurred by the non breaching party to enforce his or her rights under the
provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of
whether litigation is instituted. In the event of default of any of the provisions of this Agreement by
one of the parties, the remedies available to the other are cumulative and include all remedies at law
and in equity, including those for breach of contract, under theories or equity, under the Domestic
Relations Code as amended, including S 3105 of the Domestic Relations Code (which includes
contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies
specifically referred to in this Agreement.
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13. LAW OF PENNSYL VANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
14. AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors, and
assigns.
15. INTEGRATION
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.
16. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will forthwith (within ten (10) days at most
after demand thereof) execute any and all written instruments, assignments, releases, satisfactions,
deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of
this Agreement.
17. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance
of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to
enforce the same, nor shall the waiver of any breach of any provision hereofbe construed as a waiver
of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any
provision hereof be construed as a waiver of strict performance of any other obligations herein.
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18. SEVERABllJITY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be deemed
to be a separate and independent covenant and agreement. 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. Likewise, the
failure of any party to meet her or his obligations under anyone or more of the paragraphs herein,
with the exception of the satisfaction of any conditions' precedent, shall in no way avoid or alter the
remaining obligations of the parties.
19. MANNER OF GIVING NOTICE
Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return
receipt requested, to Kristen B.Rigling, 409 3'd Street, New Cumberland, Pennsylvania 17070, or
counsel for Kristen B. Rigling, or such other address as Wife from time to time may designate in
writing.
Any notice required by this Agreement to be sent to Husband shall be sent by certified mail,
return receipt requested, to Edward M. Rigling, 1111 Apple Drive, Apartment No.7, Mechanicsburg,
Pennsylvania 17055, or counsel for Edward M. Rigling, or such other address as Husband from time
to time may designate in writing.
20. HEADINGS NOT PART OF AGREEMENT
Any headings 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.
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SECTION m
ALIMONY AND ALIMONY PENDENTE LITE PROVISIONS
1. ALIMONY
The parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted
by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either
may now or hereafter have against the other for support, maintenance, alimony pendente lite or
alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to
seek from the other payment for support, maintenance, alimony pendente lite or alimony.
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SECTION IV
PROPERTY DISTRIBUTION PROVISIONS
1. PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs,
carpets, household equipment and appliances, pictures, books, works of art and other personal
property. Wife agrees that all of the property in the possession of Husband shall be the sole and
separate property of Husband; and Husband agrees that all of the property in the possession of Wife
shall be the sole and separate property of Wife. The parties do hereby specifically waive, release,
renounce and forever, abandon any claims which either may have with respect to the above items,
which shaH thereafter be the sole and exclusive property of the other.
2. RETIREMENT BENEFITS
The parties agree that Wife shall retain sole ownership and possession of all of her retirement
benefits and plans, including her retirement/pension plan with Highmark (pennsylvania Blue
Cross/Blue Shield), and Husband specifically releases and waives any and all interest, claim or right
that he may have to these assets.
The parties further agree that Husband shall retain sole ownership and possession of all of his
retirement benefits and plans, including his retirement/pension plan with Highmark (Pennsylvania Blue
Cross/Blue Shield), and Wife specifically releases and waives any and all interest, claim or right that
she may have to these assets.
3. BANK ACCOUNTS
Husband and Wife are the owners ofindividllal bank accounts. Husband and Wife agree that
these accounts shall be the sole and separate property of the person in whose name they are titled and
each party waives any right, title or interest they may have in the other parties' account.
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4. AUTOMOBILES
The parties are the owners of various automobiles. Husband and Wife agree that the leased
1999 Kia automobile shall be the sole and separate property of Wife, and Husband waives any right,
title, or interest he may have in this vehicle. Wife agrees to be solely responsible for all costs and
expenses related to the vehicle she leases, including but not limited to insurance, maintenance,
gasoline and lease payments and she will indemnify .and hold Husband harmless from any obligation
relating to this vehicle. Wife's vehicle is leased in Husband's name.
Husband and Wife agree that the 1992 Saturn automobile shall be the sole and separate
property of Husband, and Wife waives and right, title or interest she may have in this vehicle.
Husband's vehicle is titled in his name alone.
Each party shall be responsible for any loans or indebtedness on his or her vehicles distributed
under this Agreement and each party will indemnify the other from any obligations related to the
other's vehicle.
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5. CURRENT LIABILITIES
Wife and Husband represent that they have taken all steps necessary to make sure that no
credit cards or similar accounts exist as of the date of execution of this Agreement which provide for
joint liability. From the date of execution of this Agreement, each party shall use only those credit
cards and accounts for which that party is individually liable.
Husband and Wife agree that there are two outstanding personal loans and a loan with Sears
which exist in the sole name of Husband, but to which both parties received a benefit. The first loan's
funds, account no. 08-200-075170, were used to consolidate both parties' outstanding debts, and the
second loan's funds account no. 08-800-409719, were used to make repairs to the marital home. The
Sears loan was used to require household equipment. Wife agrees to pay to Husband the sum of
Seven Thousand ($7,000) Dollars, which will satisfy her one-half interest in these two debts.
Thereafter, Husband agrees to assume sole responsibility for the remaining balance of these two
accounts.
6. WAIVER OF PAYMENT OF LEGAL FEES
Each party hereby agrees to be responsible for any legal fees incurred on their behalf
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7. AFTER-ACOUIRED PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or right of the
other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired
by him or her after execution of this Agreement, with full power in him or her to dispose ofthe same
as fully and effectively, in all respects and for all purposes, as through he or she were unmarried.
9. B.EAL ESTATE
A. Marital Residence - The parties acknowledge that they are the owners of certain real
property known as 409 3'd Street, New Cumberland, Cumberland County, Pennsylvania 17070
(hereinafter referred to as "Marital Resident"), which is subject to a mOligage. The parties agree as
follows with respect to the Marital Residence:
(I) Simultaneous with the execution of this marriage settlement
agreement, Husband shall execllte all documents necessary, including a deed, to
transfer all of his right, title and interest in the Marital Residence to Wife. Thereafter,
Wife shall be the sole and sep(\rate owner of the Marital Residence.
(2) Within three (3) years of the date of this agreement, Wife agrees that
she will exercise all reasonable diligence to refinance the existing mortgage on the
marital residence.
(3) Husband agrees that as ofthe date of execution ofthis Agreement, any
and all title policies and any other policy of insurance with respect to the Marital
Residence shall be endorsed to reflect Wife as sole owner thereof and further agrees
that Wife shall be entitled to receive any payments now or hereafter due under any
such insurance policies.
(4) Except as otherwise provided herein, commencing on the execution
date of this Agreement, Wife shall be solely responsible for all costs, expenses and
liabilities associated with or attributable to the Marital Residence regardless of when
the same shall have been incurred including, but not limited to, mortgage, taxes,
insurance premiums and maintenance and Wife shall keep Husband and his propeliy,
successors, assigns, heirs, executors and administrators indemnified and held harmless
from any liability, costs or expense, including attorney's fees, which may be incurred
in connection with such liabilities and expenses or resulting from Husband's
ownership interest in said property. In the event that Wife is more than sixty (60) days
delinquent with any liability related to this property, she shall be compelled to sell the
property and assume all liablity related to the sale as well as all outstanding loan
balances.
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SECTION V
CLOSING PROVISIONS AND EXECUTION
Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals on the date indicated below.
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WITNESS
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KRI TENB. LING1 1)
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EDW - M. RIGIi
7 /7'~a>c;l
DATE
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EDWARD MARK RIGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.{).006~1./70
KRISTEN BACON RIGLING,
Defendant
: 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 judgement 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 and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown ofthe marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
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, Pennsylvania 17013
(717) 249-3166
.Jo '.
BOWARD MARK RIGLING,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
: NO. ;l1rlJ'C) - 'f?o ~ 7~
KRISTEN BACON RIG LING,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT REGARDING COUNSELING
1. I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A
Section 4904 relating to unsworn falsification to authorities.
Dated:
1/17/ZJ)OO
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EDWARD MARK RIGLING,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
: NO. ;L/J'lJU-<f70 ~ -r.u.--
KRISTEN BACON RIG LING,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is EDWARD MARK RIGLING, an adult individual residing at 1111 Apple
Drive, Apt. 7, Mechanicsburg, Cumberland County, Pennsylvania 17011.
2. Defendant is KRISTEN BACON RIGLING, an adult individual residing at 409 Third
Street, New Cumberland, Cumberland County, Pennsylvania 17070.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on April 19, 1997 in Cumberland County,
Pennsylvania.
5. There are no minor children born of this marriage.
6. The parties separated on December 15, 1999.
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7. There have been no prior actions for divorce or annulment between the parties.
8. Neither Plainti:fl'nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940
and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAULT
10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with
S 3301 ofthe Pennsylvania Divorce Code.
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
Dated: January 24, 2000
2
EDWARD MARK RlGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO.
KRISTEN BACON RlGLING,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I, Edward Mark Rigling, hereby certify that the facts set forth in the foregoing
COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
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EDWARD MARK RlGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 2000-470
KRISTEN BACON RlGLING,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
1, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the
Complaint In Divorce in the above-captioned matter by United States Mail, Restricted
Delivery, Certified No. P 377 421 643, Return Receipt Requested, on the above-named
Defendant, Kristen Bacon Rigling, on February 2, 2000, at Defendant's last known address:
409 Third Street, New Cumberland, PA 17070. The original receipt and return receipt card
are attached hereto as Exhibit "A".
I hereby certify that the facts set forth above are true and correct to the best of my
knowledge, information and belief. I understand that any false statements made herein are
subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities.
Dated: February 3, 2000
Barbara Sumple-Sullivan, EsqUlre
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
. Supreme Court ID #32317
Attorney for Plaintiff
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P 377 421 643
US Postal SelVice
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail See reverse
Sent to
S Kristen Bacon Ri lOng
Street & Number
4 9 Third street
Posl Office, State, & ZIP Code
New Cumberland 0
Postage $
Certified,Fee
Special Delivery Fee
Restricted Delivery Fee
---------;'-'l---
i: .., plete it;ms 1 \ ~ndlor 2 for additional services.
I) .Complete items 3, 48. and 4b.
, I'., P"rint your name and address on the reverse of this form so that we can return this
" - ,card to you. ~
.,: _ ".,!,~ach this form to the front of the mailpiece. oron the back If space does not 0;:
permit. E:
, cD< "'lfW'rite.Retum Receipt Requested. on themailPiecebelowthearticlenumber.cI
~ .. ~'~e Return Receipt will show to whom the article was delivered and the date 1l
~ : ...",,,._delivered. . Consult postmaster for fee. "8
... 3. Article Addressed to: 4a. Article Number &!
t Ms. Kristen Bacon Rigling P 377 421 643 tiE
Ii 4'09 4b. Service Type
il Third street
.. 0 Registered G Certified 0::
New Cumberland, PA 17070 0 Express Mail 0 Insured
o Return Receipt for Merchandise 0 COD
7. Date of Delivery
efso willh \Q1'ec~tv\> the
following services(for an
extra fee):
1. 0 Addressee's Address
2. "Restricted Delivery
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EXHIBIT "A"
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EDWARD MARK RIGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
v.
: NO. 2000 - 470
KRISTEN BACON RIGLING,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301( c) of the Divorce Code was filed on January
25, 2000.
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 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.A. ~4904 relating to unsworn
falsification to authorities.
Date: 7 - ! 7 - J. 000
By: 7~~W7.~~
Kn ten Baco ' ghng, D e an\
Social Security No. 183 - Y e - 7 C; C( J
iiiliiIliial--< ,;,--.",
.
.
EDWARD MARK RIGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
v.
: NO. 2000 - 470
KRISTEN BACON RIGLING,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A 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! 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.A. 94904 relating to unsworn
falsification to authorities.
Date: 7-/7-JOOCJ
By:
Kri en Ba n 'gling, fe an
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EDWARD MtRK RIGLING,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 2000 - 470
KRISTEN BACON RIGLING,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 ( c) of the Divorce Code was filed on January
25, 2000.
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 of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this Affidavit are tru,e and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn
falsification to authorities.
Date: 7/ '1/ ;J..,,,V{)
By:
Social Security No. /51- SZ-- f(}J'3
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EDWARD MARK RIGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
v.
: NO. 2000 - 470
KRISTEN BACON RIGLING,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER &330HC) 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 in 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.A. 94904 relating to unsworn
falsification to authorities.
Date: '7/Lj/ ;J..OOO
By:
"- - ~,~I ~-
EDWARD MARK RIGLING,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. 2000-470
KRISTEN BACON RIGLING,
Defendant
: 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: January 28, 2000, by certified mail,
restricted delivery.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of eon sent required by 93301(c) of
the Divorce Code: by Plaintiff: July 4,2000; by Defendant: July 17, 2000.
(b )( 1) Date of execution of the affidavit required by 93301 (d) ofthe Divorce
Code: N/A; (2) Date of filing and service of the Plaintifi's Affidavit upon the
respondent: N/A.
. -- --,.",--,.
. . .
4. Related claims pending: None
5. (Complete either (a) or (b).)
( a) Date and manner of service ofthe notice of intention to file praecipe to
transmit record; a copy of which is attached: N/A
(b) Date Plaintift's Waiver ofNotiee in ~3301(c) Divorce was filed with the
Prothonotary: July 20, 2000
Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with
the Prothonotary: July 20, 2000
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EDWARD MARK RIGLING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
: NO. 2000-470
KRISTEN BACON RIGLING,
Defendant
: IN DIVORCE
ELECTION TO RETAKE MAIDEN NAME
Notice is hereby given that the parties, in the above matter, having been granted a Final
Decree in Divorce on the 27th day of July, 2000, hereby elected to retake and hereafter use her
maiden name of Kristen M. Bacon, and gives this written notice avowing her intention in
accordance with the provision of 54 Pa..C.S.A. 1/704(a).
Date:
~A4A~f?ffl
Kri en Bacon . g g
TO BE KNOWN AS:
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Mji
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COMMONWEALTH OF PENNSYL V ANlA
SS.
COUNTY OF CUMBERLAND
AFFIDAVIT
On the :JY\6 day of ~ c"",^^ lo.N\ , 2000, before me, a Notary Publie,
personally appeared Kristen Bacon Rigling, known to me to be the person whose name is
subscribed to the within document and acknowledged that she executed the foregoing for the
purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
f'" , ,NOTAR1AL€''::A,1..
p;.mlaAA. PA'l'TOM. NmlYo':::
l.o',"!erPmon TwIt.. DIuIlhflt ~
i My Commission ExpIres JI,lne 20. :>(l
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