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HomeMy WebLinkAbout00-00472 :., ,- .-,-- -.~ o-~ ~I , , ~;::i::.::~~::::~::c~;:;,x.}<:::~::+z,::~~.::{'::,~::.x-k.}f.:::~::C~f.:::!"f.~~>>>~,;~!::CK)::~f.}::+::~;:::,;~::+}r::~~::~~:)~::C{:::~>>>f.X~f.)::C{:::~::+::~$::n!:!::+:<?;'::~A~~::.}~\~::~~~::c!r~~::.::!t0~::+>&("*'l*I ~ ~ X ~ ~ I ~ IN THE COURT OF COMMON PLEAS * ~ ~.~ ""/ . ~ '~o~ ~o~ I ."', "'0'" ~ ~o~ I ljo~ ~os ~ ~os ~ ~.~ ~ ~ lj.~ i ~.~ ~.S ~ :,0,< ~ ~o~ ;0, ~ ~ ~~ ~~~~~~~~~~~~~~~~~~~~ OF CUMBERLAND COUNTY STATE OF PENNA. DAWN L. SPOTTS Plaintiff No. A??,.................. .................~ 2000 Versus I .MAZAN,ALTUBURm",u ~ ljo~ ~.s , ~ i ~.:. ~ , ,Def-endant DECREE IN D I V 0 R C E ~(O:CI.rA.,Nt. AND NOW, .... ~.~.. .?-?......., JM:.ZQQ~., it is ordered and decreed that.......... ..J?~~"'.~:.?l'?~~!'......................., plaintiff, and. . . . . . . . . . . . . . . . . . . . . . .M;a.z.'1u, AJ,t.l.\b.u.1\ . . . . , . . . . . . . . . . . . . . . ., defendant, are divorced from the bonds of matrimony. ',.,,' ~ ~o~ i ~.~ ~~ ~ .~" ''0" ~~ ~ >"', ~", ~ "'~'. ~":~ I c:: ~ " ~" ~.'~ . ~.~ ~ ~.~ t ~o~ 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; ".." ~ !\ ;os , .,....,.......................,..,..",......,...."............. ....,..,.. ~ ljo~ k~ ~ 8 '.'< h ~ ~~~ ~ ~ ~o~ ~ . , ~ ,;...::(:::..~-" '::*>-:,--;.:C~.: -....,..........,....,.."..,......,.. ....,.............. By Allest: Prothonotary ..:+x.::*>-:, '::<.::~:.:).( i ~.~ * lj.~ ~~~ ~ ~ ~ i lj.~ i N ~ 8 ~ ',,' ~ ~o~ ~.'~ ~ ~~ ~ ~ ~':~ ~ ~ N ~ ~~ ;'os ~ ~~ ~ i1 ~ ~ ljo~ ~os * ~ ~o~ ~ ~o~ ~ ~o~ ~ ~o~ ~ ~o~ ~ ... J. ,0; ~ ~ ,,' ~ et"r<". '_,,_'t-;-;' ..~_~,y~"'_<'cf_'" ~-~'^ ,--.", -"~ ~ c' . .. ""iJi ,,' of' < " 3~<()( tuJ-~~ ~ 4 ~# 3450' ~~ ~ :<t ~- - . - ~,-~~ ,,---~~- " '-!--'~' '-, ",~'~:'" ,~,...".. ...~- ! ".;";--^" _I _ .-", , DAWN L. SPOTTS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. MAZEN ALTUBUH, Defendant : NO. 2000-472 CIVIL TERMS : CIVIL ACTION-LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 Section (X) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: See Affidavit of Service 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: by Defendant: (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: January 14,2000 (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. ( a) Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: Certified Mail on 4/21/00 (b) Date ofPlaintitl's Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: Date of Defendant' s Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: '" ~~IliiilIIl'-~'~~~ _.. ~ _ ._ 1 ~", L-.~'" ~ = '~""" r 2 c:> 0 - -" :2; :> :::\ -005 y;." {~:"1~~ ffi1'Ti -;;;;;! z~' - ~_~'-ri:\ zr.;-,- ;;:- ,.~,o ':Q<;- c'')'<,"--. \20 :'V' ~:A ~o ..,,:.;.. :.--C} C? 5rf'l 'Pc -\ Z \"V ~ ::2 (f' -~......,;;.I .'" DAWN 1. SPOTTS, Plaintiff MAZEN ALTUBUH, Defendant , : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. .2000 - 47~ Cu~L ( /0'L-'1 CIVIL ACTION-LAW IN DIVORCE VS. 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 ground 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ,,-. ....~ I -:, DAWN L. SPOTTS, Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. dl11T6. '-I 7..2, ~ ~ MAZEN ALTUBUH, Defendant "' CIVIL ACTION-LAW IN DIVORCE COMPLAINT 1. The Plaintiff Dawn L. Spotts, is an adult individual whose residence is 24 South 2nd Street, Wormleysburg, Cumberland County, Pennsylvania 17043. 2. The Defendant Mazen Altubuh, is an adult individual whose residence is 175-39 Dalny Road, Apt. 3E, Jamaica, New York 11432. 3. The Plaintiff has been a bonafide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 23, 1994, in New York City, New York.. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties under the age of 18. "- "-- -.-~ 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff is a citizen of the United States. ~ 9. The Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to a divorce decree being handed down by the court. 10. The Plaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, PURCELL, KRUG & HALLER BY W. Purcell, Jr., Esquire I, 29955 17 9 North Front Street Harrisburg, PA 17102 (717) 234-4178 ...._1.. "I VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the ~ penalties of 18 Pa. C.S. !i 4904, relating to unsworn falsification to authorities. Dated: Januarv 14. 2000 L{hIZ.il ~Di-f7J Dawn L. Spotts ., Y CO FOAM NO ALL-STATE: LEGL~ 6S~~:i.G'r'. 611 !l6.WH 67152.BF'671!5~'8 , .. t:J ~~~S~ ~ ~ r~~ N t-< ~'" '" t-< > t-<(') Z < (') . (') ~ 0 0 ~ CJl '" ~ @~ ~ . 1-3 ~ ~ 01-3 r; c:: gj 1-3 I 00 H ~ r; ~~ t ~ ~ . . ~ r-~ C1 '" . ~ 1.;1 t:J H ro po t-h ,... "'0 " ~Z > t:J ro " " - ~ " rt t;j", H~> 0- ,... po t-h >-4t-< c . . I'd t-h t-<'" h 7.i 0 " '0 ::1 (') rt <I> 'z _ '" ~'" >" n " , , " " H <5 S 1<- N > ~ " J 0 ~ N ~~ '& ~ ~ ?2. ~D 'bg.. ......... '-.} ~h , 'I 8 0, r I /f!t?- ~ ......... ~ ~ -arc rhh-: ZT' 7'[" ~~~; ~_." ~C) L~C"'J )>C Z -3 "' Q ~:s: C,) o c) "1"j ""Jr. '- <"..- '-j j--i N <')'1 - ':; ~14 '-~~} '''( :: ::~ ~;~l ~~l~ --j > ::z G -u ~ ~-'".... '''''> U1 I ~ ,~ ~~ DAWN L. SPOTTS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. MAZEN ALTUBUH, Defendant : NO. 2000-472 CIVIL TERM : CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: )ss COUNTY OF DAUPHIN I, JOHN W. PURCELL, JR., Attorney for the Plaintiff in the above action, hereby swear and affirm that on January 28, 2000, I sent, by certified mail, return receipt requested, deliver to addressee only, a copy of the Complaint in Divorce with Notice to Defend and Claim rights and Plaintiff's 201(d) Affidavit under Section 3301(d) of the Divorce Code to the Defendant in the above action. The Mailing Receipt for Certified Mail is attached hereto as Exhibit "A". The return receipt was not returned by the U.S. Post Office. Attempts were made to trace the return receipt from the New York City Postal Service Office which were unsuccessful. Approximately one week after the above mailing, a man who identified himself as the Defendant, called this office and indicated that he had received both the Complaint in Divorce and the Section 3301(d) Affidavit. The purpose of his call was to dispute the date of separation, claiming that he was not separated for the six years indicated in the Affidavit but rather for a period of approximately two years. He was advised that two years was the minimum and the discrepancy would not have any .- ,-. _I ~ ~- ~i effect on the divorce. This office also attempted to have the Defendant acknowledge receipt of the Complaint in writing, but has had no response from a written request to do so. This Affiant believes and therefore avers that the Defendant did, in fact, receive the Complaint in Divorce with the 3301(d) Affidavit within one week of mailing. Sworn to and subscribed before me this I:J, '/--11 day of fI1 f-It?.t f) , 2001. ~A~[}'~ I Notary Public / NOTARIAL SEAl BARBARA A. SHADe.. Nolary PubIII: "-'-'-... .- ...""".............. ...... .-. ." ,. ,-,-.u;W~.Qf,J-,~~,....;j,.",__,-, My Commleslon EXp!1llS Maroh 17, 2003 c' ~~ ,...,._J'" "II Z 495 295137 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse to b Postage Certified Fee Special Delivery Fee Restricted Delivery Fee "' m Retum Receipt Showing to .... Whom & Date Delivered .~ Retum Receipt Showing to Whom, <( Date, & Addressee's Address 0' i TOTAL Postage & Fees ('l') Postmark or Date '\. ~ u.. ~ $ )-o-?i~O 0 . ~, Exhibit "A" ALL.STATE LEGAL SUPPLY CO. FORM NO. 67152..8F'67153-aL.671~.G'(.67'56":VH ~ :;;: ZOd!2: > '" ~ CI. 55 >-3 >-,j Z HNt:t1::C r >-,j <: t" <Opj'" H ~ Ol . 00t" CI ~O~ n ~ >-3 [J) g c:: 'd "" H "" 0 :;d >-3 c:: H "" 0 >-3 p:: H -.j 0 0 CI- 'd[J) N c::O r >-,j '" ....,- ~"1 M> Ol n [J) '" 1-" H ...<:: (j '" 5- ::I < - 0 ~ rT ~'d~ Ol 1-" ~ H ::I M> "'0 n rt M> H ZZ '" '" Z ~ ~ "' 'd ><:t" c< '" ~~ H :>- 0 C) 0 c: -n ~ ::Jt ';;- 'UC.r,! :'0/:W ;,} n-lf'n :.0:' z::n .:2~8 :zc .t:'" GQ v.., =.;C) -<:.2:, ;;..:C) ._J ~'l"-l );.";C" ~ i~~~ ~~5 Z...: O.rn j;C' Cf? c ~ Z N 3J ~ C' '< " 'I A' { , "-- DAWN L. SPOTTS, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ec)L'l~~ MAZEN AL TUBUH, Defendant ; NO. ;;2.000- '-I'7^,- : CIVIL ACTION-LAW : IN DIVORCE NOTICE TO THE DEFENDANT: If you wish to deny any of the statements set forth in this Affidavit, you must file a counteratfidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated February 24, 1994 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: January 14,2000 lOamA rf5, ffrrtJu DAWN L. SPOTTS , , ! .' ~. ." " > " " ~ c " o ~ r f~' R- 00 t" n >-3 H'd Ot" ZI> H wZ W>-3 OH ~"l n "l O~ t:1~CIl t"~ I> O"l "l"l H >-3t:1 0::1> t"<I H t:1>-3 H ~~ nto;J t":;O ~ >-3 C t:1'" '" C t-h::r: '" . ::> ~ " ::> rt " " w N w . w ~ ~ N ~ ) ALL-STATE LEGAL SUf'PLYCO. FORM NO 67152.SF'67IS:;s-BL.671SS.GY'67156-WH <: Ul t:1 ~ t" HnZ ZHO <I. t:1H Ht" 61> :;on n>-3 t"H o Z I t" ~ 00 'd 'dO >-'>-3 " >-3 ,...00 ::> . rt ,... t-h t-h 0 C1 ~ C) ~ r,__ -oF n-j....:i.i ::::;11," ~~ .."". , T! ';7,;: t"0 .. CT,:: <J' 'T ~ "; '? .:;::-- :~~ , " ~>C;, '~,} :.!J 2(, C) s>c~ (~5lr, 7' --" ~:=j "'-, ~ -< en -< COH ~~ 1:'10:: ,,, t" b ~8 iii CO >-3 o 90 '''' '" >-3 ,<in . 0 'd~ 1:0 0 ~Z CIl'd ><it" t:"t" <Ii> >00 Z H > ,. , dJ -." "_c _ ,'V ,-,--,,,,"1- 11.'-; LAW OFFICES g;~ ~ & ~ JOHN w. PURCELL HOWARD B. KRUG LEON P. HAlLER JOHN w. PURCELL.. JR. JILL M. WINEKA BR.IAN J. TYLER NICHOLE M STALEY O'GORMAN 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 233-1149 ,JOSEPH NtSSLEY U910-1982t VALERIE A. GUNN OF' COUNSEL HERSHEY 1099 GOVERNOR ROAD ln71 533-3836 March 12, 2002 Richard J. Pierce Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Dawn L. Spotts v. Mazen Altubuh No. 2000-472 Dear Rick: Pursuant to our conversation the other day, I am enclosing the documents necessary to finalize the divorce. As Indicated to you, I believe we have effectuated proper service of the original Complaint and 3301(d) Affidavit on the Defendant, by reason of his call to this office confirming that he received it, despite the fact that the Post Office failed to return the certified mail receipt. Could you please refer this to the appropriate Judge and let me know if this is acceptable. Thank you for your cooperation. Ve ours, Jo JWP,JRcm Enclosures ~~ ',~~...l......".. "= ~~, . DAWN L. SPOTTS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. MAZEN ALTUBUH, Defendant : NO. 2000-472 CIVIL TERM : CIVIL ACTION-LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: The Social Security Number of the Plaintiff is 210-48-2087, and the Social Security Number of the Defendant is unknown. Respectfully submitted, PURCELL, KRUG & HALLER BY J hn . Purcell, Jr. 1. 955 1719 North Front Street Harrisburg, P A 171 02 Attorney for the Plaintiff - ~" ~" " ~!Sa!iil\mia-"~'~'~ISlillII- ~"- '''>'-'- . -"'-'-iO~ .->, ,~~, " .m.o ~. . 0 = 0 C "., $: :x --, L1t.J.] - -T: -n mrn :'':'0 rnp Z::C -1-,fT\ :z:C -,';0 ~~ ~ c50 ~Ci "'"' :::;j --,", ;-j:D >,0 ...L_ ~.....,O :Z:c OfT'1 >c m :z: N ~ =< Xl (1\ =< , iIlio I ~c: . DAWN L. SPOTTS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2000 - 472 CIVIL TERM MAZEN ALTUBUH, Defendant CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF DAUPHIN I, JOHN W. PURCELL, JR., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 21st day of April, 2000, I sent, by certified mail, return receipt requested, deliver to addressee only, a copy of the Notice of Intention to Request Entry of Divorce Decree and Defendant's Counter-Affidavit Under Section 3301(d) of the Divorce Code to Mazen Altubuh, the Defendant in the above action. The return receipt, duly signed by the Defendant is attached hereto and made a part hereof as Exhibit "A" and a copy of the Notice and Defendant's Counter-Affidavit is attached as Exhibits "B" and "C". Sworn and SUbj~ed to before me this day of , 2000. No y.Public Notarial Seal An ela S. Eaton, Nqtary Public H~SbUrg, Da~ph," County 2004 My Commission Expires Jan. 12, . I. otNotarles Member, PennsytvaniaAssoCla Ion '" "~ _"'~~IlbIOIi", Complete item-s f; 2, anlS. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse SiD that we can return the ,card to you. . Attach this card to the back of the mail piece, or on the front if sP~ permits. 1. Article Addressed to:'~~,~~f (riO\L-~,", A?r",\J\A~ \ ")S J\ \Jt\\r\ 'J ~ ~ ~j1-J ~ 0CA.Y"r\O(, ~~ (V ~ \'~O~ D. I delivety address different from Item 11 If YES, enter delivery address below: 4;-;. 3. Service Type ~Certffied Mail tJ Registered o Insured Mail o Express Mall o Return Receipt for Merchandise o C.O.D. 4. Restricted ~livery? (Extra Fee) ~Y.. 2. Article Number (Copy from service label) ""::',. " PS Form ~g11,~jJI~ \~bb: ~ ; ~ I. ,. ""., ,;\ 1 ; :i! !:;:. ..; Doml3Sllc Return Receipt \'.'" 102595-99-M-1789 .., ;r '" .., '" ...... n.J ;r Postage $ r Certified Fee '" c c c c c ;r '" Return Receipt Fee (Endorsement Required) i RestrictEld Delivery Fee (EndorsernentRequired) Postmark Hore a- a- c " Total Postage & Fees $ m(Q,:~t;:.rly)~t~b':~_..__m......_.....__m._m.. \~~t:;':"{,~lli\':\_.. ~~.....GW).m_~_~.m C; State, ZJP~'l . IlL Exhibit "A" , , I, ~ -"8, DAWN L. SPOTTS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 473 CIVIL TERM MAZEN AL TUBUH, Defendant CIVIL ACTION-LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Mazen Altubuh, Defendant You have been sued in an action for Divorce. You have failed to answer the Complaint or file a Counteraffidavit to the Plaintiff's Affidavit. Therefore, on or after May 3, 2000, the Plaintiff 'can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counteraffidavit by the above date, the Court can enter a final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the Divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 liberty Avenue Carlisle, PA 17013 (717) 249-3166 800-990-9108 > Exhibit HBn ~ DAWN L. SPOTTS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 473 CIVIL TERM MAZEN AL TUBUH, Defendant CIVIL ACT/ON-LAW IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301 (dl OF THE DIVORCE CODE 1. Check either (a) or (b): tal I do not oppose the entry of a Divorce Decree. _ (b) I oppose the entry of a Divorce Decree because (Check (i), Oi) or both): _ (i) The parties to this action have not lived separate and apart for a period of at least three years. _ Oi) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. > Exhibit "COO " "",ft-;, , . I verify that the statements made in this counteraffidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a Divorce Decree and you do not wish to make any claim for economic relief, you need not file this Counteraffidavit. > "~ '"' .'"'~...... """""'"iilillllIiIlUilIiIlllIlIlII'-.......... -""' , ..' " , ",",'", ., T. i i I 8 C7 () C) ---) -;:-; f':','C =: j rr: C: ., ,. L- ~,,~ f~"" p f'0 rn ""~~ , CJ ~) eJ , r-:: l c ., t:J 5:.~ )':::ao -r, e' c-=-) --r; .' ;"5 r"\ :::~ ):~ c: co l.::; fT1 ~;.>" '--1 ,"- ::) ~ --i -< 1::> -< ('"