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IN THE COURT OF COMMON PLEAS
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ANDNOW.~..k>........ 1:9.200.1, it is ordered and !
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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;
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None.
The Marital Settlement Agreement executed by the partie~ on
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NUUUTALSETTLEMENTAGREEMENT
THIS AGREEMENT made this j6-11. day Of~~ ,2001 between
DONALD E. CLARK now of Dauphin County, Pennsylvania, hereinafter referred to as Husband,
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DOROTHY R. CLARK of Perry County, Pennsylvania, hereinafter referred to as Wife.
WITNESSETH:
WHEREAS, the parties were lawfully married onMarch 2, 1968; and
WHEREAS, the parties are the parents of two adult children; and
WHEREAS, in consequence of disputes and unhappy differences, the parties have been living
separate and apart from each other since January 5, 2001; and
WHEREAS, the parties desire to confirm their separation and make arrangements therewith,
including the division of their marital property and other rights and obligations growing out of their
marriage; and
WHEREAS, the parties acknowledge and agree that in entering into this Agreement, including
all waivers stated herein, they are each relying on truth and completeness in all material respects as
to all information provided by the other party hereto regarding the assets of such person.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
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mutually kept and performed by each part, as well as for other good and valuable consideration and
intending to be legally bound it is agreed as follows:
(I) The parties agree that their marriage is irretrievably broken and that they mutually
consent to a divorce and agree to execute all necessary Affidavits of Consent and Waivers of Notice
forms required by the court for the entry of a mutual consent divorce. Husband, as Plaintiff in the
action, agrees to file the Praecipe to Transmit and all other papers necessary for the completion of
the divorce and to provide Wife with a certified copy of the divorce decree once issued.
(2) It shall be lawful for each party at all times hereafter to live separate and apart from
the other party at such place or places as he or she from time to time may choose or deem fit.
(3) Except as herein otherwise provided, each party hereby releases the other from any
and all claims, or demands up to the date of execution hereof.
(4) The parties are the owners as tenants by the entireties of certain real estate with
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improvements thereon~own as R.D. #1, Bell 91A,Loysville, Peny County, Pennsylvania, all that
certain piece ofland situate in Northeast Madison Township, Peny County, and more fully described
in deed recorded in Peny County Record Book 247 at Page 424. Said property is subject to a home
equity/consolidation loan, including the outstanding mortgage held by the Bank of Landis burg, with
Traveler's Bank & Trust, FSB, 100 Commerce Drive, Newark, DE 19713, account number 6616045.
The outstanding balance on this loan is approximately $72,000.00.
Husband and Wife agree that the Loysville property shall be sold. They have signed or will
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sign an Agreement of Sale which provides for a purchase price of$90,000.00, $5,000.00 to be paid
at or before the signing of the Agreement of Sale and $85,000.00 at settlement.
Husband and Wife agree that Wife shall receive the entirety of the net proceeds from the sale
of the property. They also agree however, that Wife shall be responsible for the satisfaction of all
liens and for all taxes, costs and fees due prior to or at settlement (including but not limited to all real
estate transfer taxes, all county municipal and school district taxes), the cost of any termite inspection,
the cost of securing a certificate from a reputable septic system installer that the septic system at the
property is in satisfactory operating condition, the cost of securing a certificate from a licensed
laboratory indicating that the water at the property is potable, the cost of insuring that the title to the
property is good and marketable and the cost of any reappraisal. All such taxes, fees and costs shall
be paid and the satisfaction of all liens on the property made before disbursement of any proceeds to
Wife. Husband shall have no responsibility for any ofthese taxes, fees, costs or liens and Wife agrees
to indemnify, reimburse, hold hann1ess and forever defend Husband on all claims or demands arising
out of such taxes, fees and costs or liens, which she hereby agrees to payor satisty..
In the event she decides to remain in the property following settlement and prior to actual
occupancy by the Buyer, Wife shall be responsible for making all rental arrangements and costs with
Buyer. Husband shall have no responsibility in this regard and Wife agrees to indemnify, reimburse,
hold hann1ess and forever defend Husband on all claims or demands arising out of rental
arrangements with Buyer, which she hereby agrees to assume entirely in new own name..
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Husband and Wife agree that the tools in the garage and tool shed on the property and the
riding mower also on the property are not to be sold with the property but are to be given to the
parties' sons prior to Buyer's occupancy of the property.
Husband and Wife agree finally that Wife shall be solely responsible for all capital gains taxes,
if any, due from the sale of property. Husband shall have no obligation in this regard and Wife agrees
to indemnify, reimburse, hold harmless and forever defend Husband on all such claims or demands,
if any, which she hereby agrees to pay.
(5) Pending settlement on the property, Husband agrees to pay to Wife the sum of
$300.00 every two weeks as his contribution to the home equity/consolidation loan. Payment will
cease immediately upon settlement and Husband shall have no further obligation in this regard, either
in the form of spousal support, alimony or otherwise.
(6) The debt of the parties, in addition to the home equity/consolidation loan referenced
in Paragraph (4) supra are:
A. PSECU loan number 0197405573, in Husband's name alone which was
secured to purchase the 1998 Chevrolet V ortec 5700 pick-up truck which Husband drives. Husband
agrees to be solely responsible for payment of and to indemnify, reimburse, hold harmless and forever
defend Wife on all claims or demands arising out of this PSECU loan debt, which he hereby agrees
B.
Landisburg Bank notes number 1091115
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,in both parties' n~~/(//f7!OAm
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to retire;
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which were secured to purchase the 1995 Nissan pick-up truck which Wife drives and to payoff
credit card debt. Wife agrees to be solely responsible for payment of these loans and to indemnifY,
reimburse, hold harmless and forever defend Husband on all claims or demands arising out of this
debt, which she hereby agrees to retire;
C. VISA credit card account number 4108420000078256 (exp. 2/03), the
balance due thereon being in both parties' names. Wife agrees to be solely responsible for payment
of this debt and to indemnifY, reimburse, hold harmless and forever defend Husband on all claims or
demands arising out of the Visa cred~'t d debt, which she hereby agrees to retire; d.
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D. Any other cre I card debt, shall be the sole and individual responsibility of '-C/o
Wife. Wife agrees to indemnifY, reimburse, hold hannless and forever defend Husband on all claims
or demands arising out of this credit card debt, which she hereby agrees to retire;
(7) Each party relinquishes any right, title and interest he or she may have to the motor
vehicle currently in possession of and! or titled to the other party, specifically the 1998 Chevrolet truck
driven by Husband and the 1995 Nissan truck driven by Wife. The parties agree to cooperate in the
preparation of all papers necessary for the transfer of title of the automobiles, as necessary. Each
party shall be responsible for payment of all insurance, maintenance, repair and fuel costs for the
automobile in his/her possession and titled to him/her. As per Paragraph (6), ~ each party shall
be responsible for payment of the loan secured to purchase his/her vehicle and agrees to indemnifY
and hold the other party harmless on that debt.
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(8) The parties hereto mutually agree that they have effected a satisfactory division of the
furniture, household furnishings, appliances, tools and other household personal property between
them, and they mutually agree that each party shall from and after the date hereof be the sole and
separate owner of all such property presently in his or her possession whether said property was
heretofore owned jointly or individually by the parties hereto. Husband's share of the personalty shall
include at leas~ the following items: the 17 $ss tracker boat with 40 hp motor, the black case
socket set, ,~s~~ iIttmiBg Qletk~~d hunting equipment, the 13 inch Zenith tv, his fishing and
fly tying equipment, his five (5) mounted fish, one (I) set of deer horns and the picture of his brothers
and sisters. 'Ihis Agreement shall have the effect of an assignment or bill of sale from each party to
the other for such property as may be in the individual possession of each of the parties hereto.
The parties agree that their sons Troy and Chad shall receive all of Husband' s tools currently
stored in the garage and tool shed and that Chad shall receive the riding mower.
(9) The parties agree to divide the intangible personal property as follows:
A. Wife will receive the following: her retirement account with Pinnacle Health
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Services and the parties' four ~ cemetery lots at Center Presbyterian Church, Route 850, Loysville,
PA.
B. Husband shall receive the following: his SERS retirement account and his
Deferred Compensation account number 01111142 with the Commonwealth of Pennsylvania.
Husband shall be free to designate the beneficiary of the death benefit portion of his pension at will.
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C. Within ten (10) days of the execution of this Agreement, Husband and Wife
shall cooperate in the completion of any forms necessary to transfer ownership of the aforesaid
accounts and assets to the sole ownership of the party indicated.
(10) The parties acknowledge that they each own one or more insurance policies on their
lives. The parties agree that effective upon the signing of this Agreement and except as provided
herein, each shall be responsible for maintaining his/her own insurance, the beneficiary to be selected
at will by each.
(11) Except as provided in Paragraph (5) ~ Husband shall not pay to Wife nor Wife
to Husband any sum whatsoever as alimony, alimony pendente lite, or for his or her support or
maintenance.
(12) The parties agree that all jointly owned bank accounts have already been divided and
if):1L,J.~C ~d ag~ 10 fuo~ok, wi-l-'h
the funds therein distributed to their mutual satisfaction. W r ~ i f'"\ ~rc;. tto.{; on () ~ p, "3" () i (J r
kdtiUJ :r.nwmt...-to..y; /Wue.,n /U\a. t-Yl4;-'~F')'/~f\U\d StW..U bt1U(1~ 5olel'-j ro LOife.. ~tc
(13) Each party is now represented by counsel of his or her own choice, Marilyn C. ZiIIi, iIl!b
Esquire for Husband and Kevin Prosser, Esquire for Wife and each shall pay his or her own attorney
for all legal services rendered or to be rendered on his or her behalf
(14) Except as provided herein, each of the parties covenants and agrees that he/she has
not in the past and will not in the future incur or contract any debt, charge or liability for which the
other party, their legal representatives, or their property or estate may become liable; and each of
them further covenants at all times to keep the other free, harmless, indemnified of and from all debts,
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charges and liabilities hereafter or heretofor contracted by them.
(15) Each of the parties shall from time to time, at the request of the other, execute,
acknowledge and deliver to the other party any and all further instruments that may be reasonably
required to give full force and effect to the provisions of this Agreement.
(16) The parties do hereby warrant, represent, acknowledge and agree that each is fully and
completely informed of, and is familiar with, the wealth, real and personal property, estate and assets,
earnings and income of the other and that each has made a full and complete disclosure to the other
of his and her entire assets and liabilities and any further enumeration or statement thereof in this
Agreement is specifically waived.
(17) Husband and Wife acknowledge that each of them has read and understands his and
her rights and responsibilities under this Agreement and that they have executed this Agreement under
no compulsion to do so but as a voluntary act.
(18) It is further specifically understood and agreed by and between the parties hereto that
each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any
and all of said party's rights against the other for past, present and future claims on account of
support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable
distribution of marital property and any other claims of each party, including all claims which have
been raised or may be raised in an action for divorce.
(19) Except as may be otherwise specifically provided in this Agreement, Husband and
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Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises,
discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from
and with respect to the following: all liability, claims, causes of action, damages, costs, contributions,
expenses or demands whatsoever in law or in equity; all rights, title, interest or claims in or to any
property of the other, whether real, personal or mixed and whether now owned or hereafter acquired;
all rights of curtesy and dower and all claims or rights in the nature of curtesy and dower; all widow
or widower's rights; all rights, title and interest or claims in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims to take against the
other's will; under the laws of intestacy; to a family exemption or similar allowance; all other rights
or authority to participate or intervene in a deceased spouse's estate in any way, whether arising
under the laws of Pennsylvania or any other country, territory, state or political subdivision; all rights
or claims to any accounting; all rights, claims, demands, liabilities and obligations arising out of or
in connection with the marital relationship or joint ownership of property, whether real, personal or
mixed; all rights, claims, demands, liabilities and obligations arising under the provisions of the
Pennsylvania Divorce Code, Act 26 of 1980, as the same may be amended from time to time, and
under the provisions of any similar statute enacted by any other country, state, territory or political
subdivision; and all rights, claims, demands, liabilities and obligations each party now has, or may
hereafter have, against or with respect to the other.
(20) Except as may otherwise be provided, this Agreement shall be binding on the parties
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hereto and on their respective heirs, executors, administrators, successors and assigns.
(21) By this Agreement, the parties have intended to effectuate an equitable division of
their marital property. The parties have determined that such division conforms to a right and just
standard with regard to the rights of each party. The division of existing marital property is not,
except as may be otherwise expressly provided herein, intended by the parties to constitute in anyway
a sale or exchange of assets and the division is being effected without the introduction of outside
funds or other property not constituting a part of the marital estate. As a part of the division of the
marital properties and the marital settlement herein contained, the parties agree to save and hold each
other harmless from all income taxes assessed against the other resulting from the division of the
property as herein provided.
The parties acknowledge that other than as set forth herein, the parties intend to be bound and
follow all Internal Revenue codes, rulings and regulations as they relate to the assets that they are
receiving.
The parties acknowledge that the payments made by Husband to Wife pursuant to Paragraph
(5) of this Agreement will be fully deductible by Husband for federal income tax purposes.
(22) The parties agree that effective upon the signing of the Agreement each shall be
responsible for maintaining hislher own health insurance.
(23) The parties agree that none of the obligations created by this Agreement, whether in
Husband or Wife, shall be discharged or dischargeable in any bankruptcy or financial reorganization
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proceeding initiated by either, regardless of federal or state law to the contrary.
(24) This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all
other provisions shall continue in fun force and effect.
(25) In the event that either of the parties shall recover a final judgment or decree of
absolute divorce against the other in a court of competent jurisdiction, the provisions of this
Agreement shall be incorporated by reference or in substance but shall not be merged into such
judgment or decree, shall survive any such final judgment or decree of absolute divorce, shall not be
in any way affected thereby and shall be entirely independent thereof.
(26) If either party breaches any provision ofthis Agreement, the other party shall have the
right, at his or her election, to sue for damages for such breach or seek such other remedies or relief
as may be available to him or her, and the party breaching this contract shall be responsible for
payment oflegal fees and costs incurred by the other in enforcing his/her rights under this Agreement.
(27) This Agreement constitutes the entire understanding between the parties and there are
no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever,
other than those herein contained.
(28) A modification or waiver of any of the provisions of this Agreement shall be effective
only if made in writing and executed with the same formality as this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of this Agreement shall not be
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construed as a waiver of any subsequent default of the same or similar nature.
(29) Each of the parties shall hereafter own and enjoy, independently of any claims or right
of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her,
with full power in him or her to dispose of the same as fully and effectively, in all respect and for all
purpose, as though he or she were unmarried.
(30) 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.
(31) It is specifically understood and agreed by and between the parties hereto that each
paragraph hereof 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 to be void or invalid at
law, if any other reason, then only that term condition, clause or provision shall be stricken from this
Agreement as is held to be void or invalid, and in all other respects, this Agreement shall remain in
full force and effect. Except as otherwise stated herein, this Agreement shall be binding upon the
respective heirs, next of kin, executors and/or administrators of the parties.
(32) This Agreement contains the entire understanding of the parties and there are no
representations, warranties, covenants or understanding other than those expressly set forth herein.
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IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set
their hands and seals the day and year first written above.
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Dorothy R. Clark
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DONALD E. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2564 CIVIL TERM
DOROTHY R CLARK,
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: April 20, 2000, certified mail, return
receipt requested, No. Z 159032 110. (Green card attached.)
3. Date of execution of Affidavit of Consent required by ~3301( c) of the Divorce Code:
by PlaintiffFebruarv 15. 2001: by Defendant March 6.2001.
4. Related claims pending: None. The Darties reauest that the terms of Marital
Settlement Aereement executed by them on Februarv 15. 2001 be incoroorated but not merged into
the divorce. (Agreement attached.)
5. Date Plaintiff's Waiver ofNotice in ~3301(c) divorce was signed: February 15, 2001.
Date Defendant's Waiver of Not ice in ~330 1( c) Divorce was signed: March 6, 2001.
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Marilyn C. ZOO, E ire
Attorney for Plaintiff
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Dorothy R. Clark,
Defendant
IN THE COURT OF COHMON PLEAS
CUMBERLAND COUNTY, PENNA. ~
NO. 00 - .:.zS'~lf Ci(J~( I~
CIVIL ACTION - LAW
Donald E. Clark
Plaintiff
:
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 visition 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 Prothonotary, Dauphin County
Court House, Harrisburg, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONV, DIVISION OF
PROPERTY, LAWVER'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 LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse-4th Floor
1 Courthouse Square
CarliSle, Pennsylvania 17013-3387
(717) 240-6200
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DONALD E. CLARK,
PLAINTIFF
v.
IN THE COURT OF COMM:ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. tl-tJ.;Z S{,. 't Cu;:) --r ..e--
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DOROTHY R CLARK,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
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COMPLAINT IN DIVORCE
The Plaintiff, Donald E. Clark, brings this action in divorce against the Defendant, Dorothy
R. Clark, upon a cause of action whereof the following is a statement:
1. Plaintiff is Donald E. Clark, a citizen of Pennsylvania, residing at 500 Walnut Street,
Apartment A5, Lemoyne, Cumberland County, Pennsylvania 17043.
2. Defendant is Dorothy R Clark, a citizen of Pennsylvania, residing at RD. #1, Box
91A, Loysville, Perry County, Pennsylvania 17047.
3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on March 2, 1968 in
Ickesburg, Perry County, Pennsylvania.
5. The marriage is irretrievably broken.
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6. Neither Plaintiff nor Defendant is currently in the military or naval services of the
United States or its allies.
7. There has been no prior action for divorce or annulment instituted by either of the
parties in this or any other jurisdiction.
8. There are no children under the age of 18 years born of this marriage.
9. The Plaintiff has been advised of the availability of counseling and of the right to
request that the Court require the parties to participate in counseling and as evidence by the attached
Affidavit does not request same.
COUNT I
Reauest for a No-Fault
Divorce under Section
3301(c) of the Divorce Code
10. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
I I. After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiffbelieves that Defendant may also
file such an Affidavit.
WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days
2
have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a
decree of divorce, pursuant to Section 3301(c) of the Divorce Code.
COUNT II
Request for a No-Fault
Divorce under Section
3301(d) of the Divorce Code
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12. The prior paragraphs of this Complaint are incorporated hereinby reference thereto.
13. The parties have lived separate and apart since April 15, 2000.
14. After two years have elapsed from the date of the filing of this Complaint, Plaintiff
may submit an Affidavit alleging that the parties have lived separate and apart for at least two (2)
years.
WHEREFORE, Plaintiff respectfully request the Court to enter a decree of divorce pursuant
to Section 3301(d) of the Divorce Code, at the appropriate time.
COUNT ill
Request for Eauitable
Distribution under Section
3502 of the Divorce Code
15. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
16. Plaintiff and Defendant have acquired property both real and personal during their
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marriage, from March 2, 1968 until April 15, 2000, the date of their separation.
17. Plaintiff and Defendant may be unable to agree to an equitable distribution of said
property.
WHEREFORE, Plaintiff prays for the entry of an Order equitably distributing all of the
aforementioned property.
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ilyn . ZiIIi, Es
Fetterhoff and ZiIIi
200 North Third Stree ,
Harrisburg, P A 17101
(717) 232-7722
Respectfully submitted,
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DONALD E. CLARK,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANITA
NO. fJ1-;)5(, 'I &;;J /41-'
v.
DOROTHY R. CLARK,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF COUNSELING
I, Donald E. Clark, being duly sworn according to law, depose and say:
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 request 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.
~4904 relating to unsworn falsification to authorities.
Date: ,c/-/9 - 00
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VERIFICATION
I verifY that the statements made in the foregoing document are true and correct to the best
of my knowledge, understanding, and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities.
Date: 1"'-/7- 00
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Donald E. Clark
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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the person or office listed
below by certified mail on the date indicated, as follows:
Mrs. Dorothy R. Clark
R.D. #1, Box 91A
Loysville, Pa 17047
Z 159 032 110
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Date
Marilyn C. ZiIIi, E
Fetterhoff and ZiIIi
200 North Third Street, Suite 800
Harrisburg, PAl 71 0 1
(717) 232-7722
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Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
1. Article Addressed to:
Mrs. Dorothy R. Clark
R.D. #1, Box 91A
Loysvill~, PA 17047
2. Article Number (CoPl' from service label)
Z 159 032 110
PS Fonn 38 j 1', July 1999
\..LJ 0 Agent
~D Addressee
D: Is delivery address different from item 1? 0 Yes .
If YES, enter delivery address below: 0 No
3. Service 1YPe
XM:::ertified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
DomestJc Refurn Receipt
1025SS.S9.M.1789
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DONALD E. CLARK,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00 - 2564 CIVIL TERM
DOROTHY R. CLARK,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under ~3301(c) of the Divorce Code was filed on APRIL 25, 2000.
2 The marriage of plaintiff and defendant is irretrievably broken and ninety 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. ~ 4904 relating to unsworn
falsification to authorities.
Date: :) - /s- 01
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Donald E. Clark
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DONALD E. CLARK,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DOROTHY R. CLARK,
DEFENDANT
NO. 00 - 2564 CIVIL TERM
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. ~4904 relating to unsworn
falsification to authorities.
Date: :A. - /5- - 01
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Donald E. Clark
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DONALD E. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
vs.
NO. 00-2564
DOROTHY R. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in divorce under ~ 3301(c) of the Divorce Code was filed on April 25,
2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing 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. ~ 4904 relating to unsworn
falsification to authorities.
Date: 3/(P/o /
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Dorothy R. Clark
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DONALD E. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
vs.
NO. 00-2564
DOROTHY R. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER g3301(c) OF THE DIVORCE CODE
I. 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 fee 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. g4904, relating to
unsworn falsification to authorities.
Date:
3/'/0/
,
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Dorothy R. lark
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DONALD E. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 00-2564
vs.
CIVIL ACTION. DIVORCE
DOROTHY R. CLARK,
Defendant
PRAECIPE
To the Prothonotary:
Please enter my appearance on behalf of the Defendant, Dorothy R. Clark, on the above
captioned matter.
Respectfully submitted,
~';,.~,ff::1 Jli-
Supreme Court ID #77227
227 No. High Street, PO Box 116
Duncannon, P A 17020
Dated: May 8, 2000
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DONALD E. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2564 CIVIL TERM
DOROTHY R. CLARK,
Defendant
IN DIVORCE
AFFIDAVIT: PARTIES' SOCIAL SECURITY NUMBERS
1. The Social Security number of Plaintiff, Donald E. Clark is 197-40-5573.
2. The Social Security number of De fend!l nt, Dorothy R. Clark is 162-36-9472.
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Marilyn C. Zilli, quire
Fetterhoff and ZiIli
200 North Third Street, Suite 800
Harrisburg, PA 17101
(717) 232-7722
Attorney for Plaintiff