HomeMy WebLinkAbout00-00805
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
STATE OF
PENNA.
PAULA JEAN BIDDLE.
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No. 2000-00805
Plaintiff
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VERSUS
KEVIN LEE BIDDLE,
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Defendant
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DECREE IN
DIVORCE
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AND NOW,
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,2000 ,IT IS ORDERED AND
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DECREED THAT
PAULA JEAN BIDDLE
, PLAINTIFF,
AND
KEVIN LEE BIDDLE
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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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;
NONE
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PROTHONOTARY
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PAULA JEAN BIDDLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Vs.
NO. 2000-00805
KEVIN LEE BIDDLE,
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: Irretrievably broken under Section (XX) 3301 (c) or
( ) 3301 (d) of the Divorce Code. (Check applicable section)
2. Date arid manner of service of the Complaint in Divorce: Certified Mail on
February 17,2000.
[Complete either Paragraph (a) or (b).]
(a) Date of execution of Affidavit of Consent required by Section
3301(c) of the Divorce Code by Plaintiff, June 2,2000; by Defendant, June 8, 2000.
(b) Date of execution of Plaintiffs affidavit required by Section 3301 (d) of the
Divorce Code: N/ A date of service of Plaintiff s affidavit upon Defendant: N/ A.
4. Date of service of Notice ofIntent to Finalize under Section 3301(d) of the
Divorce Code: N/ A. Date of filing of Waiver of Notice of Intent to Finalize by
Plaintiff: simultaneously herewith; by Defendant: simultaneously herewith.
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5. Related Claims Pending: None
BY:
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Diane M. RUplC sqUire
(717) 232-9n4
Attorney for (xx) Plaintiff
( ) Defendant
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PAULA JEAN BIDDLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
Vs.
NO. 2000-00805 Civil
KEVIN LEE BIDDLE,
Defendant
DIVORCE
ORDER OF COURT
AND NOW, this 23; J Dayof r to)C-
,2000, it is hereby
Ordered that the Property Settlement Agreement dated June 2, 2000 attached hereto
is incorporated herein and made apart of this Order of Court.
BY THE COURT:
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PROPERTY SETTLEMENT AGREEMENT
TffiS AGREEMENT, ;, mad, th;~ day of ~
2000, by and between:
PAULA JEAN BIDDLE, hereinafter referred to as Wife;
-AND-
KEVIN LEE BIDDLE, hereinafter referred to as Husband;
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on June 27, 1992 in
Annville, Pennsylvania; and
WHEREAS, there are no 'children born of the marriage;
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WHEREAS, diverse unhappy marital difficulties have arisen between the parties
causing them to believe that their marriage is irretrievably broken, as a result of which
they have separated and now live separate and apart from one another, the parties
being estranged due to such marital difficulties with no reasonable expectation of
reconciliation; 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 of real and personal property; and the settling of all matters
relating to the custody and support of their minor children, and in general, the
settling of any and all claims and possible claims by one against the other or against
their respective estate, particularly those responsibilities and rights growing out of the
marriage relationship.
NOW THEREFORE, in consideration of the mutual promises, covenants and
undertakings hereinafter set forth and for other good and valuable consideration, the
receipt of which is hereby acknowledged by each of the parties hereto, husband and
wife, each intending to be legally bound, hereby covenant and agree as follows:
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L SEPARATION.
It shall be lawful for each party, at all times hereafter, to live separate and apart
from the other, at such place or places as he or she may, from time to time, choose or
deem fit. Each party shall be free from interference, authority or contact by the other,
as fully as ifhe or she were single and munarried, except as may be necessary to carry
out the provisions of this Agreement. Neither party shall molest the other or attempt
to endeavor to molest the other, nor compel the other to cohabit with the other, or in
any way harass or malign the other, nor in any way interfere with the peaceful
existence, separate and apart from the other.
Should a Decree, Judgment, or Order of separation or divorce be obtained by
either of the parties in this or any other state, country or jurisdiction, each of the
parties hereby consents and agrees that this Agreement and all of its covenants shall
not be affected in any way by any such separation or divorce; and that nothing in any
such Decree, Judgment, Order or further modification or revision thereof shall alter,
amend or vary any term of this Agreement, whether or not either or both of the parties
shall remarry, it being understood by and between the parties hereto, that this
Agreementshall survive and shall not be merged into any Decree, Judgment, or Order
of divorce or separation. It is specifically agreed however, that a copy of this
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Agreement or the substance of the provisions thereof, may be incorporated by
reference into any Order of divorce, Judgment, or Decree. This incorporation,
however, shall not be regarded as a merger, it being the specific intent of the parties
to permit this Agreement to survive any Judgment and be forever binding and
conclusive upon the parties.
2. EFFECTIVE DATE.
The effective date of this Agreement shall be the "date of execution" or
"execution date", 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.
3. MUTUAL RELEASES.
Husband and wife do hereby mutually remise, release, quit-claim or
forever discharge the other and estate of such other, for all time to come, and for
all purposes whatsoever, from any and all rights, title and interest, or claims in or
against the estate of such other, or whatever nature and wherever situate, which
he or she now has or at any time hereafter may have against such other, the estate
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of such other or any part thereof, whether arising out of any former acts, contracts,
engagements, or liabilities of such other or by way of dower or curtesy, of claims in
the nature 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 to treat a lifetime conveyance by the other as
testamentary or all other rights or a surviving spouse to participate in a deceased
spouse's estate, whether arising under the United States, or any other country;
or any rights which either party may now have or at any time hereafter have for the
past, present, or future support or maintenance, alimony, alimony pendente lite,
counsel fees, costs or expenses, whether arising as a result of the marital relation or
otherwise, 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 acquire, except, and only except, all rights and agreements and obligations
of whatsoever nature arising or which may arise under this Agreement or for the
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breach of any provision thereof.
4. DISTRIBUTION DATE.
The transfer of property, funds and/or documents provided for herein shall only
take place on the "distribution date" which shall be defined as the date of execution
of the Divorce Decree, unless otherwise specified herein.
5. MUTUAL CONSENT/ADVICE OF COUNSEL.
Husband and wife acknowledge and understand the terms and conditions of
this Agreement, and wife is represented by Attorney Diane M. Rupich and Husband
is represented by Attorney Charles Ritchie.
Husband and wife acknowledge that they fully understand the facts as to their
legal rights and obligations under this Agreement. Husband and wife acknowledge
and accept that this Agreement is, under the circumstances, fair and equitable and that
it is being entered into freely and voluntarily, and that the execution of this
Agreement is not the result of any collusion or improper or illegal agreement or
agreements.
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6. FINANCIAL DISCLOSURE.
The parties confirm that each has relied on the substantial accuracy of the
financial disclosure of the other as an inducement to the execution of this Agreement.
The parties acknowledge that there has been no formal discovery conducted in
their pending divorce action and that neither party has filed an Inventory and
Appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code.
Notwithstanding the foregoing, the rights of either party to pursue a claim for
equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest
owed by the other party in an asset of any nature at any time prior to the date of
execution of this Agreement that was not disclosed to the other party or his or her
counsel prior to the date of the within Agreement is expressly reserved. In the event
that either party, at any time hereafter, discovers such an undisclosed asset, the parties
shall have the right to petition the Court of Common Pleas of Dauphin County to
make equitable distribution of said asset.
The non-disclosing party shall be responsible for payment of counsel fees,
costs, or expenses incurred by the other party in seeking equitable distribution of said
asset.
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6. DEBTS AND OBLIGATIONS.
Husband represents and warrants to wife that since approximately the April of
1999, he has not, and in the future he will not contract or incur any debt or liability
for which wife or her estate might be responsible and shall indemnity and save wife
harmless from any and all claims or demands made against her by reason of such
debts or obligations incurred by him since the date of said separation, except as
otherwise set forth herein.
Wife represents and warrants to husband that since approximately the April
of 1999, she has not, and in the future she will not contract or incur any debt or
liability for which husband or his estate might be responsible and shall indemnity and
save husband harmless from any and all claims or demands made against him by
reason of such debts or obligations incurred by her since the date of said separation,
except as otherwise set forth herein.
Husband shall be solely responsible for the debts and credit card accounts
which are in the name of husband alone, which as of the year end 1999, consisted of
approximately five credit card accounts totaling approximately $24,000.00, and
hereby holds Wife harmless and indemnifies Wife from any and all liability
whatsoever due and owing on said credit card debt.
Wife shall be solely responsible for her debts outstanding on her two credit
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card accounts in her name alone, and hereby holds Husband harmless and indemnifies
Husband from any all liability whatsoever due and owing on said credit card debt.
Should either party include any of the above debt in a bankruptcy
proceeding, and in the event the other party is required to make any payments on this
debt due to a bankruptcy being filed, that party may pursue an action for contempt
against the other for the reimbursement of said payments, as set forth hereinafter, as
well as any attorneys fees incurred as a result of said breach.
7. REAL ESTATE.
Husband and wife hereby acknowledge that they do not own any real estate.
Husband and Wife had previously rented a home located at 958 East Maple Street,
Palmyra, Pennsylvania; however, Husband hereby acknowledges that said neither he
or nor Wife are obligated under said lease, at this time, and that there are no debts or
liabilities arising out of said rental/lease agreement.
9. PERSONAL PROPERTY.
Except as set forth hereto, husband and wife have agreed that their personal
property has been divided by the parties' and neither party will make any claims to
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the property possessed by the other, except as set forth herein: Wife shall retain the
1994 Corsica automobile, and Husband hereby agrees to execute the title to said
automobile, waiving all of his right, title and interest in said automobile to Wife.
Husband hereby acknowledges that the 1995 Bonneville which was leased in joint
names has expired, the vehicle has been returned to the dealer, and all costs
associated therewith, have been paid in full.
to.PENSION/RETIREMENT.
Wife hereby acknowledges that she is entitled to a portion of Husband's
pension through his employer, Commonwealth of Pennsylvania, Public School
Employes' Retirement System, and hereby acknowledges that the value of said
retirement as ofJune of1999 is in the approximate amount of $23,973.74; however,
Wife hereby waives all of her right, title and interest in said pension, retirement
account of Husband' s, and hereby relinquishes all of her rights to the same. Husband
hereby acknowledges that he is entitled to a portion of Wife's pension through her
employer, Commonwealth of Pennsylvania, Public School Employes' Retirement
System, and hereby acknowledges that the value of said retirement as of June of 1999
is in the approximately amount of $3,546.33; however, Husband hereby waives all
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of his right, title and interest in said pension, retirement account of Wife's, and hereby
relinquishes all of his rights to the same.
11. WAIVER OF RIGHTS.
The parties hereto fully understand their rights under and pursuant to the
Divorce Code, Act of 1980, No. 1980-26, as amended February 12, 1998, particularly
the provisions for alimony pendente lite, spousal support, equitable distribution of
marital property, attorneys fees, and expenses. Both parties agree that this Agreement
shall conclusively provide for the distribution of property under the said law and the
parties hereby waive, release and forever relinquish any further rights they may
respectively have against the other for alimony, alimony pendente lite, spousal
support, equitable distribution of marital property, attorneys fees, and expenses.
12. MUTUAL RELEASE OF CLAIMS.
Except as otherwise stated in this Agreement, husband and wife each do hereby
mutually remise, release, quitclaim and forever discharge the 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 the
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property hereafter accruing) of the other or against the estate of each other, of
whatever nature and wheresoever situate, which he or she now has or at any time
hereafter may have; specifically including any rights which either party may have or
at any time hereafter have for past, present, or future spousal support, or maintenance,
alimony, alimony pendente lite, spousal support, equitable distribution of marital
property, attorneys fees, costs or expenses, whether arising as a result of the marital
relation or otherwise.
It is the intention of the 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 acquire, 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.
13. WAIVER OR MODIFICATION TO BE IN WRITING.
A modification or waiver of any of the terms of this Agreement shall be
effective only if in writing, signed by both parties, and executed with the same
formality as this Agreement. No waiver of any breach hereof or default hereunder
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shall be deemed a waiver of any subsequent default of the same or similar nature.
14. MUTUAL COOPERATION.
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 future
instruments and/or documents that the other party may reasonably require for that
purpose of giving full force and effect to the provisions of the Agreement.
15. AGREEMENT BINDING ON HEIRS.
This Agreement shall be binding and shall inure to the benefit of the parties
hereto and their respective legatees, devises, heirs, executors, administrators,
successors, and assigns in the interest of the parties.
16. BREACH.
If either party breaches any provision of this Agreement, the other party shall
have the rights, at his or her election, to sue in law or in equity to enforce any rights
and remedies which the party may have, and the party breaching this Agreement shall
be responsible for payment of attorneys fees and all costs incurred by the other in
enforcing his or her rights under this Agreement.
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I 7. LAW OF PENNSYLVANIA APPLICABLE.
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania.
18. HEADINGS NOT PART OF AGREEMENT.
Any headings preceding the text of the several paragraphs/provisions 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.
19. DIVORCE.
The parties hereto acknowledge that their marriage is irretrievably broken.
The parties further agree to execute the necessary Affidavits of Consent and Waiver
of Counseling, and Waiver of Notice ofIntent to Request Entry of Divorce Decree,
simultaneously with the execution of this Agreement. The parties further agree and
acknowledge that this Property Settlement Agreement shall be incorporated into said
Decree in Divorce; howev~r, shall not merge therewith.
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IN WITNESS WHEREOF, the parties hereto have set their hands and seals the
day and year first above written.
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PAULA JEAN BIDDLE
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(SEAL)
(SEAL)
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On this, th~y of ~ ,2000, before me, a Notary Public,
the undersigned officer, personally appeared PAULA JEAN BIDDLE, known to me
or satisfactorily proven to be the person whose name is subscribed to the within
instrument, and acknowledged that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and offiCial seal.
NOTAIlW. SEAl.
IlWe M. lIIJIllCH. Nulary PuIIIc
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My Commission Expi
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
day of ~
the undersigned officer, personally appeared KEVIN LEE BIDDLE, known to me
On this, the ~p,
,2000, before me, a Notary Public,
or satisfactorily proven to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
MyoQrrinission expires: ~ 711. ~~
Notary Public
NOTAR,AL SEAL
CAROL M. DAUGHERTY, NOTARY PUBLIC
ANNVILLE TWP., LEBANON CO., PA,
MY COMMISSION EXPIRES JULY 5. 200l
PAULA JEAN BIDDLE,
Plaintiff
vs.
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2000- POS' ec..>i..c--r-~
KEVIN LEE BIDDLE,
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 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.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 HA VB 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, P A. 17013
(717) 249-3166
1-800-990-9108
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PAULA JEAN BIDDLE,
Plaintiff
IN 1HE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No ' 2000 -
KEVIN LEE BIDDLE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE lI.NDER. SECTlO~ JJDl (l;) OF THE
DIVORCE CQJ)E
1. The Plaintiff is Pau1a Jean Biddle, an adult individual who currently resides at
11 Honeysuckle Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055
and whose social security number is 179-60-8236.
2. The Defendant, Kevin Lee Biddle, is an adult individual, who is currently
incarcerated in the 958 E. Maple Street, Palmyra, Lebanon County,
Pennsylvania and whose social security number is 146-68-4620.
3. Plaintiff and Defendant were married on June 27, 1992 in Annville,
Pennsylvania.
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4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for
a period of at least six (6) months prior to this fliing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff and Defendant are both citizens of the United States.
7. There has been no prior action for divorce flied in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are no children born of the marriage.
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10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable
Court to grant a Decree in Divorce.
CLAIM FOR ALIMONY. ALIMONY PENDENTE LITE,
COUNSEL FEES AND EXPENSES
11. Paragraphs one (1) through ten (10) of the foregoing Complaint are incorporated
herein and made a part hereof by reference.
12. Plaintiff hereby avers that she does not have sufficient funds to support herself
both during the pendency of this action and upon conclusion of the divorce.
13. Plaintiff hereby avers that Defendant does have sufficient funds to support the
Plaintiff.
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14. Plaintiff avers that she does not have sufficient funds to pay counsel fees, costs
and expenses, incidental to this action.
15. Plaintiff avers that Defendant does have sufficient funds to pay counsel fees,
costs and expenses, incidental to this action.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to
Order the Defendant to pay alimony pendente lite, alimony, counsel fees, costs and
expenses.
Respectfully submitted,
DILS & RUPICH
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Diane M. Rup' , squire
1017 North Front Street
Harrisburg, P A 17102
(717) 232-9724
J.D. No. 71873
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I verify that the statements made in this Complaint
,
~Je 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: January 27, 2000
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Paula Jean Biddle
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PAULA JEAN BIDDLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Vs.
NO. 2000-00805
KEVIN LEE BIDDLE,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I, Diane M. Rupich, Esquire, hereby certifY that a true and correct copy of
the Complaint in Divorce under Section 3301 (c) of the Divorce Code was served
upon the Defendant, Kevin Lee Biddle, by First Class, United States, Certified Mail
No. Z 569 114 925 at his address of 958 E. Maple Street, Palmyra, Pennsylvania
17078.
Attached hereto is the return receipt card executed by Kevin Lee Biddle
evidencing receipt of the same and dated February 17,2000.
'71
iane Mftupic ,
(717) 232-9724
I.D. No. 71873
June 13,2000
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PAULA JEAN BIDDLE,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
VS.
No, 2000-00805
KEVIN LEE BIDDLE,
Defendant
DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
February 11,2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service ofthe 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 made herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsific' authorities.
Date: (b4z1 ~ ofV(}'o
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PAULA JEAN BIDDLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
Vs.
NO. 2000-00805
KEVIN LEE BIDDLE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301( c ) OF THE DIVORCE CODE
I. I consent to the entry of a final Decree in Divorce without notice.
2. I unde~stand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is
filed with the Prothonotary.
I verify that the statements made in this Waiver 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.
nat'=;,.,. / M JRdO WAk&.Idib
Paula Jean Biddle, Plamtiff
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PAULA JEAN BIDDLE,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
VS.
No. 2000-00805
KEVIN LEE BIDDLE,
Defendant
DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
February 11,2000.
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 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 made herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
D,te ~ ~ Z/Jm 00 Bi~endant
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PAULA JEAN BIDDLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
Vs.
NO. 2000-00805
KEVIN LEE BIDDLE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301( c ) OF THE DIVORCE CODE
I. I consent to the entry of a final Decree in Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent tome immediately after it is
filed with the Prothonotary.
I verify that the statements made in this Waiver 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.
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vin ee Biddle, Defendant
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