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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: CIVIL ACfION . LAW
~ NO, 97- if 11' CIVIL Term
: "~ST~':'. l\,;,', ".~
Daniel W. DaShiell,
Plaintiff
Tracey E. DaShiell,
Defendant
COMPLAINT
COUNT I . DIVORCE UNDER 330l(c) OF THE DIVORCE CODE
AND NOW comes Daniel W, DaShiell, by and through his attorneys, Frey &
Tiley, and states as follows:
I, Plaintiff is Daniel W, DaShiell. an adult individual, currently residing at 7 South
Hanover Street in the Borough of Carlisle, Cumberland County, Pennsylvania,
2, Defendant is Tracey E, DaShiell, an adult individual. whose current residence is
unknown but whose last known residence is elo Miriam Brenner, Fox Hollow Estates.
Lot AS. Shermansdale, Pennsylvania,
3, Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previo'Js to the tiling of this Complaint.
4, Plaintiff and Defendant were married on may 21, 1988 in Carlisle, Cumberland
County. Pennsylvania,
S, There have been no prior actions of divorce or for annulment between the parties,
6, The marriage is irretrievably broken,
7, 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,
WHEREFORE. Plaintiff requests your Honorable Court to enter a Decree in Divorce.
Divorcing Plaintiff and Defendant,
UOlllel W. l>uShlell,
Plaintiff
: IN TIlE COtlRT OF COMMON PLEAS OF
: CtlMBERLAND COllNTY.I'ENNSYLV ANIA
v,
: CIVIL AniON -I.AW
Tracey E. l>uShlell,
Dclcndwll
NO, 97-4K7K CIVIL Term
: Divuree
AFFIDA VIT OF CONSENT, WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF IHVORCE DECREE,
AND WAIVER OF MARRIAGE COUNSELING
I. A Complaint in divorce lllllkr Section .1.10i(cl of the DivllI'ce Cmk was filed on
September 9. 1997,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of tiling and service of the Complaint.
3, I consent to the entry of a final decree of divorce without notice,
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 divor(~e is granted,
5, 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 tiled with the Prothonotary,
6, 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,
7, I understand thilt the court maintains a list of marriage counselors in the Domestic
Relations Office. which list is available to me upon request.
8. Being so advised. I do not request that the court require my spouse and I participate in
counseling prior to a divorce decree being handed down by the court,
I verify that the statements made in this affidavit are true and correct, I understand that fabe
statements herein are made subject to the penalties of 18 Pa, C. S, ~4904 relating to unsworn
falsification to authorities,
DATE: 2120198
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Donlel W. DaShiell
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: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYI.V ANIA
: CIVIL ACTION .l.AW
Daniel W. DaShiell,
Plaintilf
Tracey 1>:. DaShiell,
Defendant
NO,97..jl!7l! CIVil. Term
AFFIDAVIT OF CONSENT,WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE,
AND WAIVER OF MARRIAGE COUNSELlN{;
1. A Complaint in divor~e under Se~tion 33()Ii~ I of the Divor~e Code was filed on
September 9. 1997,
2. The marriage of Plaintiff and Defend.lnt is irretrievably broken and ninety days have
elapseJ from the dale of tiling and servke of the Complaint.
3, I consent to the entry of a final de~ree of divorce without notice,
4, I understand that I may lose rights concerning alimony. division of properly. lawyer'\'
fees, or expenses if i do not claim them before a divorce is granted,
5, I understand that I will not be divorced unlil a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is tiled with the Prothonotary,
6, I have been advised of the availability of marriage counseling and understand that I may
request that the court require thaI my spouse and I participate in counseling,
7, I understand that the court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
S, Being so advised, I do not request that the court require my spouse and I participate in
counseling prior to a divorce decree being handed down by the court,
I verify that the statements made in this affidavit arc true and correct, I understand that false
statements herein arc made subject to the penalties of IS Pa, C. S, *4904 relating to unsworn
falsification to authorities,
DATE: HI ~\q'i<
2~~~-~L. iD c ~~ ~
Tracey E, DuShie
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