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Home My WebLink About00-00926 . .. . . . . . . . . . . . . . . . . . , ".~" -- . . - ~ , ' ,,;. ,- ~ !-- . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF MICHAEL C. MANNING VERSUS LORETTA RENEE MANNING . . . . . . AND NOW, DECREED THAT . PENNA. No. DECREE IN DIVORCE ()\~ ~( , 2003 MICHAEL C. MANNING AND LORETTA RENEE.MANNING . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . 2000 - 926 CIVIL ~'~7tM. e/f r- .. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, . 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 . . . . ~. ~ J. ~~~OTHONOTA'Y ATTEST: . . . . . "' ", ~ .-' , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " . . . . . . . . . '. -, ~. '~ " ~ - . ~ <, , . .3-~-03 M,~~~'4~ J<J!L -c(3 71~ ~ ~ 1fT- . .. " I~ - .-.... ,- , ~ .~...~~,!,~", -.-",,~" ""--~ ,...."""',~~iilit!I,. - ~" _J MICHAEL C. MANNING- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. LORETTA RENEE MANNING CIVIL DIVISION 2000 - 926 CIVIL TERM NO. 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 !l3301(c) ~~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of service by counsel on 2/18/2000. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required bY!l3301 (c) of the Divorce Code; by plaintiff 3/12/03 ; by defendant 3/14/03 (b) (1) Date of execution of the affidavit required bY!l3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transrnit record, a copy of which is allached; (b) Date of plaintiff's Waiver of Notice in !l33.01 (c) Divorce was filed with the Prothonotary; mailed to Prothonotary on 3/20/03 Date defendant's Waiver of Notice in !l3301 (c) Divorce was filed with the Prothonotary: mailed to Prothonotary on 3/20/03 /~~~ ~-' ..~,-'-n~~ ,~, _"',r,,,,~~' "" - ~ -..""IIlildilIllI@.' ,- ~-- - _"',~..' ,I 'f<';>, l' ~. ,'_~,,+'_~ ,~, .,' < ~_ "~-._~ ,,', ~~-~ ". ,,~ (") CJ 0 C w '..., :s: 3: "'U is.., :'O.l> ITlri": :;:0 :D Z::-!~'.: ("" Z t'" N iTl ~:~> ^.: CJ " ~~', "~-~; (~) -fJ .'-l"i ,-- -~-) ~ -~ C) ):;2= F:S ~.~rTl Z -I :J1 "'~' =<:! r" :::r:J -< ~ ."-~~~ -~ . d' -~,-- MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL NO. 2000-926 Civil : CIVIL ACTION LORETTA RENEE MANNING, Defendant : DIVORCE ORDER AND NOW, this I~~ of August, 2000, upon consideration of Plaintiff s Petition to approve and adopt the parties' Stipulation of Confidentiality, the Stipulation is hereby approved and adopted as an Order of Court. L / , C apW -fY)oJJ- ~-lj.()O RXS . ~~ . = ~ - ~ .. _~'f-< n\ r:;C\...!j,:rw,r: rLJ:JJ \.I' (;vt.. O~ ..., "... ,,,.,,.......,' ,.~' .O~'nv \ \;~C_ ~_,;,~-.',_.J\:-lUN\~ \r'-J1\ 00 ~UG \ 5 Ml II: 08 CUMb2F\LF,HD COUNTY PENNSYLVi\i4\A " "~~-,"""", ~, ~ V,," ~'"!"11""""""~ ., ~'~ _ ,_..J - ~~ MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL NO. 2000-926 Civil CIVIL ACTION LORETTA RENEE MANNING, Defendant : DIVORCE PLAINTIFF'S PETITION TO APPROVE AND ADOPT STIPULATION OF CONFIDENTIALITY 1. The parties to this litigation are husband and wife. 2. The parties to this litigation anticipate that discovery in this action will include documents and information which are commercially sensitive, confidential and/or proprietary in nature. 3. The parties to this litigation wish to protect the confidentiality of such documents and information. 4. Accordingly, the parties, through their counsel, have executed a Stipulation of Confidentiality, a copy of which is attached hereto as Exhibit A. 5. The parties agree to have the court approve and adopt the Stipulation of Confidentiality as an Order ofthe court. - _~4 "', ., J "{ WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant his Petition and approve and adopt the Stipulation of Confidentiality as an Order of Court. Respectfully submitted, By: DRUBY, L.L.P. r I I Date: ~ 'chard B. Druby, Attorney LD. No.6 475 West Governor Road Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-4483 Attorney for Plaintiff " , " -"" '\, .. MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS ; CUMBERLAND COUNTY, : PENNSYLVANIA v. CIVIL NO. 2000-926 Civil CIVIL ACTION LORETTA RENEE MANNING, Defendant DIVORCE STIPULATION AND ORDER OF CONFIDENTIALITY WHEREAS, the parties to this litigation anticipate that discovery in this action will include documents and information which are commercially sensitive, confidential and proprietary in nature; and WHEREAS, the parties to this litigation wish to protect the confidentiality of such documents and information and to ensure that the parties can obtain and pursue discovery with the minimum of delay and expense; THEREFORE, the parties to this action, through their below-listed attorneys, hereby enter into the following stipulation and consent that the Court may enter the following Stipulated Protective Order (hereinafter "Order"); , IT IS ORDERED THAT; L Documents and stipulated facts that will be produced by, or agreed to by the Plaintiff pursuant to this Stipulation and Order are claimed by Plaintiff to be of a confidential and proprietary nature. The purpose of this Order is to protect the confidentiality of these documents. 2. All documents produced by Plaintiff in this case are designated "confidential" and shall be used solely for the purpose of "this action" and shall not be disclosed or made known to any person other than qualified persons as defined in paragraph 3. "This action" specifically refers to the pretrial proceedings and trial, settlement or appeal of the above captioned case. 3. "Qualified person" means: a. counsel of record for the parties and the legal assistants and regularly-employed office staff of the counsel of record for the parties; and/or b. a person retained by a party or its attorneys of record to assist in this action, such as expert witnesses, consultants or other technical experts and/or consullanw;and/or c. court officials involved in these actions, including the court and its staff, court reporters, persons operating video recording equipment at depositions, and any Special Master appointed by the Court; and/or d. actual or potential witnesses in this action who are assisting counsel in the prosecution or defense of this action or individuals counsel must advise concerning the status of this action. , '< , -I. ._ ',' 4. Qualified persons, as defined in Paragraph 3(a)-(d), must agree to the terms stated herein prior to reviewing the documents deemed confidential hereunder, and the party disclosing to such person(s) must obtain such agreement prior to disclosure. 5. Confidential documents shall include all originals and copies of any document and/or information that is produced by Plaintiff, including all past and future document disclosures and deposition testimony. 6. If Plaintiff or Defendant submits and/or files with the Court any document or other discovery information designated for protection hereunder, such documents and/or other discovery information shall be filed and submitted under seal and shall be maintained under seal by the Court. No party shall file with the Court any motion, brief or other paper containing or otherwise exhibiting any confidential information unless said motion, brief or other papers are filed in sealed envelopes or other appropriate sealed containers on which shall be the words 'CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER." 7. Within sixty (60) days after fmal judgment in or settlement of this action, each party shall assemble all originals or reproductions of deposition transcripts, as well as any other documents or other discovery information produced by Plaintiff (excluding any documents that have been filed with the Court), which shall, upon Plaintiffs request, either be returned to counsel for Plaintiff or destroyed, in which case counsel for the party destroying said documents shall certifY in writing to counsel for Plaintiff within thirty (30) days that such destruction has taken place. Insofar as the provisions of this or any other Protective Orders entered in this action restrict the use of the docUlIlents or other ,I"." _3- , -'~ .. , discovery materials produced hereunder, such Orders shall continue to be binding after the conclusion of this case. 9. This Order may be modified by stipulation among the parties, approved by the Court or by application to the Court by noticed motion. 10. Nothing in this Order shall be construed as a waiver or any rights by any party with respect to matters not specifically provided for herein. By: . ard B. Druby, Esq ttorney LD. No. 61904 475 West Governor Road Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-4483 Attorney for Plaintiff DATED r;/7/tfl> ( ( JAMES, SMITH, DURKIN & CONNELLY, L.L.P. By; DATED ~I 06 Attorney for Defendant VERIFICATION I Richard B. Druby, Esquire, counsel for Plaintiff, hereby verify that, upon information and belief, the statements made in the foregoing document are true and correct based upon the information available to me. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S4904, relating to unsworn falsification to authorities. Date; r It! (f7) , .','1 .-"-"- F ,'.", ~.' "--' "'-"", CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm ofNestico, Korposh & Druby, L.L.P., hereby certify that on the r;14- day of August, 2000, a copy of the foregoing document was sent first class mail postage paid, to the following; John J. Connelly, Jr., Esquire James Smith Durkin & Connelly, LLP 134 Sipe Avenue P.O. Box 650 Hershey, PA 17033 ~5li~"'~';'- ,~.~~ lltl..-MW! IIodIlilii ...~ ..'"~~-1liii (') C> 0 . C 0 -n s:: ~ ....,. -OU1 G'> _".c:!} n-In~ ", 2:: :n ---:.J~ 2::~ 0 -1)0 (r) "'"~ ~.~" 1 -0(.,;;:" ~-':-i~ r;::O .~o 2A;;'-H J;;, ~ (.)~ ?,C '7~ -=0 ""~l .: Pc; t:-? S z: =:> ~ ::< J:" '< ~ ~~, . , ":v MICHAEL C. MANNING, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYL VANIA : CIVIL NO. .;:;>t;Cl;:? -7~~ ~ : CIVIL ACTION LORETTA RENEE MANNING, Defendant : DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 LAWYER REFERRAL SERVICE COURTAD~STRATOR 1 COURTHOUSE SQUARE CARLISLE, P A 17013-3387 (717) 240-6200 - - - ti~]!v'il MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. f'l " _ ~/.. CIVIL NO. ~ crv-v. 9;L.(' ~ ~ CIVIL ACTION LORETTA RENEE MANNING, Defendant : DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Michael C. Manning, who currently resides at 999C Oak Lane, New Cumberland, Cumberland County, Pennsylvania 17070, since February, 2000. 2. Defendant is Loretta Renee Manning, who currently resides at 1706 Kathryn Street, New Cumberland, Cumberland County, Pennsylvania 17070, since 1984. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 31,1978. 5. There have been no prior actions for divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States of America or any of its allies. 7. The marriage is irretrievably broken. '" ~"~~ ~ - -, ." ~B1 .' 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff respectfully requests that this honorable court enter a decree dissolving the marriage between the Plaintiff and Defendant. Respectfully submitted, By: Date: () 1 S- ! fV I 'chard B. Druby, ire Attorney LD. No. 61904 475 West Governor Road Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-4483 Attorney for Plaintiff :::~_~L~ ~ =" - L. _ "\k~h;! . .' VERIFICATION I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. Date: ;2.- 11- 61) , j~iIl!!!lll~,jf;;f""l>.l#;,l!$)~~llii1ll/!!WIM-' 1>M"","",;r&:~"i'~i'-";j~""""",N,"~"~~lNiUI;~~~~IilWI_~~W" "'~ '" I , . " ~ '- ........ ~ ~ V\. ~ , I 'i.. b ~ . , ~~ ~ ~ (") c, \ \ c' c.;;- 0 ::?" ~n -{::: -oCr:: -.-, << 1 \ [216 r-ri , ~~i c'O :=C! , -"") ~n ~ ~ en -r7C'J r~(----~ :-.;;(S ;"'-<-'--f ~~~- ]? ~;C) ;~S ~EJ -,~ j;: >::..: ~ W ,:srn z > --j r- -<.' <=> :I.J -< ~ ,,- .~~ ~~ .. ..eW ~~ . - , MICHAEL C. MANNING, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL NO. 2000-926 Civil CIVIL ACTION LORETTA RENEE MANNING, Defendant DIVORCE AFFIDAVIT OF SERVICE I, Richard B. Druby, counsel for Plaintiff, Michael C. Manning served a copy of the Divorce Complaint, at the request of the Defendant, on Defendant's counsel, John 1. Connelly, Jr., Esquire. The Divorce Complaint was served via certified mail, return receipt requested on February 16, 2000. The green return receipt for said service indicates that the same was received on February 18,2000. The cover letter for said service and green return receipt are attached hereto as Exhibit A. Attorney Connelly also executed an Acceptance of Service on February 18, 2000. The Acceptance of Service is attached hereto as Exhibit B and incorporated herein by reference. ,,,. - ,-, ~! . Respectfully submitted, NESTleO, KORPOSH & By: Date: t1~ . ard B. Druby, Es . 1\.ttorney J.D. No. 61904 475 West Governor Road Hershey, Pennsylvania 17033 (717) 533-5406 (717) 533-4483 Attorney for Plaintiff ".."."",__I.~" ~ - . ~~ ~. ~. ' ~" . CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm ofNestico, Korposh & Druby, L.L.P., hereby certifY that on the .?~y of March, 2000, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: John J. Connelly, Jr., Esquire James Smith Durkin & Connelly, LLP 134 Sipe Avenue P.O. Box 650 Hershey, PA 17033 < .; ,~ -.".....". I I ! " = 6 I -a E 8 msl amliflor 2 for addIlienal'aervlces. .e&fi &: Items 3, 48, and 4b. - Print your name and addte&S on the reverse of this form so that we can retum this card to you. -Attach this 101Tl1 to the front of the mallplece, or on the back If apace does not pennlt. -Write.Rstum Rscsipt RSQusstsd- on the'maJlplece below the article number. _The Retum Receipt willahow to whom the -al1lc1e was d~d and the date delivered.. . ",.,,' I &I8G wl$IllO J808ive tile following services (for an extre lee): 1. 0 Addressee's Address 11 2. 0 Rest~cted Delivery .i Consult postmaster for fee. a 48. Article Number ] Z \Cl'if fuCo, ~ E 4b. Service Type g o Registered )!J Certified a: ... o Express Mail 0 Insured i o Retum Receipt for Merchandise 0 COD ::l 7. Date of Delive .e 3. Article Addresaed to: ::l g, ... " .. .c ... ."'" ~~",'-,.. ~~ '" "": MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL NO. CIVIL ACTION LORETTA RENEE MANNING, Defendant : DIVORCE ACCEPTANCE OF SERVICE I, John Connelly, Esquire, counsel for Defendant, hereby accept service of the Divorce Complaint on behalf of the Defendant, Loretta Renee Manning and certify that I am authorized to do so. Date: ~ ~ - 1,- .~~ . .. ;.. Nestico, K6rposh & Drub)', LLP Attorneys At Law Anthony J. Nestico Michael J. Korposh Richard B. Druby Merrill H. Jacobson Ann F. DePaulis, Of Counsel G. Bryan Salzmann, Of Counsel David C. Oipper, Of Counsel 475 W. Governor Road Hershey, PA 17033 Phone: 717-533-5406 Fax:717-533~3 ajn2@aol.com Harrisburg (]ffipe 317 North Front Street Harrisburg, PA 17101 Phone:717-260~0150 Fax:717-260~0203 mkorposh@paonllne.to1l'l February 16,2000 VIA CERTIF][ED MAIL (Z198-566-259) RETURN RECEIPT REQUESTED John Connelly, Esquire James, Smith, Durkin & Connelly 134 Sipe Avenue HummelstOWIl, P A 17036 Re: Manning v. Manning Dear John: It is my understanding that you represent Loretta Manning. It is also my understanding that you have agreed to accept service of the Divorce Complaint on her behalf. Therefore, I am enclosing a copy of the Divorce Complaint which has been filed in Cumberland County. If you are authorized to accept service, please sign the Acceptance of Service form enclosed and return it to me. If you are not authorized to accept service, please let me know and I will serve the complaint directly on Mrs. Manning. In the meantime, should you wish to discuss this matter further, please give me a call. RED/mp Enclosure By: Very truly yours, ard B. Druby, Esquire ail Address: RBDruby@ao\.com cc: Michael Manning ~2l. -".."""~~",-",.",,,,,~~,,,~,, ~~.- lll.Jl.J,d. "~.- .. ". I~~ ",-- . . () 0 0 c 0 -" 5: :x ::::l -On""! :Po miTi ;:>;) rhfH ;z::o ;Z:'- I "nt"'T1 (1')>; -.J ."7 .-.." -<.<:. SQ ~o :r> :t:: q ~o :x -. ..,., Qci -0 om Pc ~ N ';! :u (.) -< MICHAEL C. MANNING, IN TI-jE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 2000 - 926 CIVIL LORETTA RENEE MANNING, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code Was filed on February 16, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing <;Ind service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. 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. 5. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 3fA;0..:> i(~;;~fft{'--~ -~., ,,_k -?:=,V..T~:lo_;r.:""~',f:"'3~_-"'~'~"_~,~" -___"t')':.<'~.,' ,,~,,_-"_ ';~' -'-~'--"'''',?,c,.,?:_, -'j-'_ -',-_~ "e" -'''''--1:!'~ _ :::"-c",,,,,','7,'- '-~_'_"'~- "" .,. -",' ":',;''"', _ _'_;;f~' \. _' ""_"~ ,_ "-I. ~~_""~ ," " '.' ,,',.~ , '." _ "._=.... _, _ ~, _" .~~ . I \" , ..,.. ","r' "'.,-',- ,. - ,<,~ "" ~-, (') ~~ -<' r;:(-_ ~>:~, p(~ z ::;! <,,,, "I, -, ~ a L.) o -''''1 -. .~~ ;:0 '" ~, -';~J -~:~~ .::-...,.. -~() _~~l 'f] ~-.:; N :'.'1 r'0 --~". ~ -~, , MICHAEL C. MANNING, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. . NO. 2000 -- 926 CIVIL LORElTA RENEE MANNING, 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 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 I 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. Section 4904 relating to unswom falsification to authorities. Date: 3)'z.;0? 57474.1 b~~" -~I" -,~~ -' - ".:,'1 "'-f"!"'~"-::1if'>-"":'~"--' ~""'1 . __''"', ":"- ,,~- -~,-, ,,":"l _'r' 'r'~ ,',_'r" ,n".-",. :i,.,_"",_~_._,_w_,,_,<yc_"r~_ '. .~ ~,<t:_. '''''"'''0 __ _",=""_,,,~_, _"'~"',," <. ~,,,.. , ,'" __ ~_~,'_ .". '" ~~,_~~~,_, _ 0 c...:;, c; ~ (-,,~~I "I") ~. ~ :.~-=.I "1:Jl\j ~~ r~11~r: ;.,~ :;;: C; J"\,) u:J -<':- c=t:~ _.;~) ~13 ~-,~ N -, ~ :n , r" -, MICHAEL C. MANNING, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 926 CIVIL TERM LORETTA RENEE MANNING, DEFENDANT ; CIVIL ACTION - LAW ; IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 16, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 113301(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 above are true and.. correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A !l4904, relating to unsworn falsification to authorities. Date: 311l-J \0-.3 _d '""""",,,"..,,_~~,"I'" ",0"" "'~"_",,'o'l,,,'_-_,"'_~ "_~..__r_~_"'___r '-' "," ,_","__ - ,," ~_~ , "._ -Y_ ~ < _ , , ,. . - -~,,'" ". 0 f.........,' !) C L;) ~: :;;;,;: "1:.1 " :-,~ fT1 1~1C ::-:., Z 2.~ ''V S? --j- ,~ '. '--. ~'"~--j <~ )> , ~..;.,~ L C; )> ~.;: 1:--;1 =2 :.J1 ~~O f\) ~, ,'"< "~ MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS ; CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 926 CIVIL TERM LORETTA RENEE MANNING, Defendant : CML ACTION - LAW : IN DIVORCE PETITIONFORECONONUCRELffiF AND NOW, comes the above-named Defendant, Loretta Renee Manning, by and through her attorneys, James, Smith, Durkin & Connelly LLP, and petitions the Court for economic relief based upon the following: COUNT n CLAIM FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 1. Plaintiff and Defendant are the owners of various personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by this Court. COUNT III CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 2. Defendant is unable to support herself through appropriate employment. 3. Defendant lacks sufficient property and income to provide for her reasonable needs. 4. Defendant requires reasonable alimony to adequately maintain herself in accordance with the standard established during the marriage. I:., .,(,.,..". "~,~ - '-,> , 5. Plaintiff is financially able to provide for the reasonable needs of the Defendant. COUNT IV CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 6. Defendant does not have sufficient funds to support herself and pay the counsel fees and expenses incidental to this action. 7. Plaintiff is full and well able to pay Defendant alimony pendente lite, counsel fees and expenses incidental to this divorce action. WHEREFORE, the Defendant requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; c. directing the Plaintiff to pay alimony to Defendant; d. directing the Plaintiff to pay alimony pendente lite in Defendant's counsel fees and the cost of this suit; and e. for such further relief as the Court may determine equitable and just. Respectfully submitted, JAMES, SMITH, DURKIN & CONNELLY LLP Date: 10-4 - ()O '.~-. -.' --~=- .- ~'," ':':I~-~-':?---",,'--~~- ,_.j',- {";:., - '""" ",' .~. ',' ",-" ,-" '-.." , . "",..., -,- ,.' ,-L ,-_"'~,,_ c~_ , ~1~-_ -,~. VERIFICATION I verify that the statements made in the attached Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating 10 unsworn falsification to authorities. Date: 1{111...IOO I I 0" "'l ~~_,,~<:'tY_~S'I~''-~\-- '., -i-'_~ .,--" ~.-.-,~ "-"',,'"""T~-', - -,- ". ~, . " ~-, - """. ~.' MICHAEL C. MANNING, Plaintiff : IN THE COURT OF COMMON PLEAS ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; NO. 2000 - 926 CIVIL TERM LORETTA RENEE MANNING, Defendant ; CIVIL ACTION - LAW ; IN DIVORCE CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Durkin & Connelly, LLP, attorney for the Defendant, Loretta Renee Manning, hereby certifY that I have served a copy of the foregoing Petition for Economic Relief on the following on the date and in the manner indicated below; V.S MAIL. FIRST CLASS. PRE-PAID Richard B. Druby, Esquire Nestico & Druby, LLP 840 East Chocolate Avenue Hershey, PA 17033-1213 JAMES, SMITH, DURKIN & CONNELLY LLP DATE: /0 - 4 - DD ~-^ , -~~7-'~,~'1'-~''> - -i';-<_O~' - --""""_~ ,. ... _ _" ",'~__S' __ ~," .., ' ,. ."", " ".. 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