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:1 IN THE COURT OF COMMON PLEAS .
I!I OF CUMBERLAND COUNTY ·
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:' STATE OF ~~ PENNA. :
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tI ELVIN B, DILLER, .
Plaintiff ;\; I)" ...~I;\~~." "",,,,,,.',,, 1997 ,;,
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tI DARLENE Fl, DILLER, ·
~ Defendant 8
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~ DECREE IN .
tI DIVORCE 8
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~' AND NOW, ' " " , .." ,.-9M '.C .. :"1/" " '. 19, ?!I" ., it is ordered and 8
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.. decreed that. . . . , " . ", . ,,~l~i.~ .B~ "D~~~:e.~ . . ,,, ,,,,,,.. ." " plaintiff,
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. and",.""",...".." ..~a..r~~!l~. ,A" PXn~.r,..,........." defendant, 8
* are divorced from the bonds of matrimony_ .
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* The court retains jurisdiction of the following claims which have l8,
. been raised of record in this action for which a final order has not yet l)!
",' been entered; I'
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I!I on March 19, 1998 and the Addendum thereto of the same date is ~
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
ELVIN B, DILLER,
Plaintiff
DARLENE A. DILLER,
Defendant
DIVORCE 97.6626
Thl. Agreement is hereby made and entered into this ~ day of March,
1998 by and between Elvin 8, Diller, "Husband," and Darlene A. Diller, hereinafter 'Wife."
Wltneueth:
Wh......, marital differences and difficulties have arisen between the Parties, and
Wh.r..., Parties have separated physically and intended to continue to live apart
and desire to forever completely settle, determine and provide for the support of Wife,
separation of their marital and non marital, real and personal, belonging to either and/or
both of the parties here!o and all other rights, entitlements, benefits, and privileges
involved between the parties hereto arising directly or indirectly out of the marriage
relationship, and
Wher..., Parties have had adequate time and opportunity to consult with
separate legal counsel of their own, and
Wh......, both Parties acknowledge that they are satisfied with the legal advice
they have received and understand the full importance of the Agreement they are
entering into;
Now, Therefore, the parties, in consideration of the foregoing premises, and the
mutual promises and undertakings hereinafter set forth, agree as follows:
1. RIGHT TO LIVE SEPARATE
It shall be lawful for Husband and Wife at all times hereinafter to live separate and
apart from each other and to reside from time to time at such place or places as he and
she shall respectively deem fit, free from any control, restraint or interference, direct or
Indirect, by each other. The foregoing provisions shall not be taken to be any admission
on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes
leading to their living apart.
2, FREEDOM FROM INTERFERENCE
Each party shall be free from IntBrference, authority and contact by the other as
it he or she were single and unmarried except as necessary to carry out provisions of
this Agreement. Neither party shall harass the other or attempt to endeavor to harass
the other, nor compel the other to cohabit with the other, or In any way malign the other,
nor In any way intBrfere with the peaceful Bxlstence, separate and apart from the other,
3. DISTRIBUTION OF VEHICLES
Wife shall assume all payments, Including all loan, Insurance and repair bills
connected with any vehicles presently In her possession.
Husband shall assume all paymBnts, including all loan, Insurance and repair bills
connected with any vehicles presently In his possession.
4, DISTRIBUTION OF POSSESSIONS
As ot the date of the execution of this Agreement, the parties shall transfer and
assign their rights, title, claim and Interest in specific property. Wife shall have as her
own, free and clear of any claims of Husband, all of the Items, household goods,
furniture, furnishings, appurtenances, and appliances which are In her possession,
. Husband shall have as his own, free and clear of any claims of Wife, all of the Items,
household goods, furniture, furnishings, appurtenances, and appliances which are In his
possession.
5, DISTRIBUTION OF PERSONAL PROPERTY
It Is further agrBed that both Husband and Wife shall retain as his or her own any
and all personal effects, clothing, and personal jewelry. The parties further agree that
any property not assigned In this AgreemBnt as marital or nonmarltal property will be
deemed the property of the physical possessor of said property,
6, RETIREMENT ACCOUNTS
The parties shall keep all IRA's, 401 k's and other retirement accounts which are
held In their names as personal property, free and clear of claims from the other party.
Page 2 of 10
7, JOINT ACCOUNTS
The parties shall stop using all Joint bank and charge accounts, credit cwd
accounts and any other joint accounts shall be terminated and each party shall take
those steps necessary to have the other removed as a responsible party from such
accounts. The parties further specifically agree that all bank, savings, cash and checking
accounts shall become the sole property of party named on the account.
8. MARITAL LIABILITIES
Unless otherwise set forth herein, Wife assumflS full responsibility for any
Indebtedness which she has contracted or Incurred In her name, alone or jointly, after
the date of separation. Unless otherwise set forth herein, Wife represents and warrants
to Husband that, since the filing of the divorce action, she has not contracted or Incurred
any debt or liability, for which Husband or his Estate might be respol'\Bible, and shall
Indemnify and save Husband harmless from any and all claims or demands made
against him or his Estate by reason of debts or obligBtlons Incurred by Wife and/or
assumed herein,
Unless otherwise set forth herein, Husband assumes full responsibility for any
indebtedness which he has contracted or incurred in his name, alone or Jointly, Biter the
date of execution of this Agreement. Unless otherwise set forth herein, Husband
represents and warrants to Wife that, since the filing of the divorCfl action, he has not
contracted or incurred any debt or liability, for which Wife or her Estate might be
responsible, and shall indemnity and save Husband harmless from any and all claims or
demands made against her or her Estate by reason of debts or obligations incurred by
Husband and/or assumed herein.
9. QTHER MARITAL ASSETS
The Parties hereto agree that basfld Qn the provisions of thiB Aaresmenl. Husband E.1I~Dc~
ullNIN TVIoI ,.0 I DtI~ DF ,3..,-.JI\NGE Dr f\ iJIf:~R..-r; IN (JI ~
shall pay to Wife the sum of Two Thousand Dollars ($2,OOO,OOk The Partles hereto-~
agree that said amount shall fully and sufficiently prOVide for Wife's needs based on an
equitable distribution of the marital assets and debts.
Page 3 of 10
10, TAX LIABILITY
The parties hereto believe and agree that the division of pioperty heretofore made
by this Agreement is a non-taxable division of property between co-owners rather than
a taxable sale or exchange of property, Each party promises not to take any position
with respect to the adjusted basis of the property assigned to him or her with respect to
any other Issue which Is inconsistent with the position set forth In the preceding sClntence
on his or her Federal or State income tax return.
11. MUTUAL RELEASE
Subject to the provisions of this Agreement, each party waives his or her
right to alimony any further distribution of property inasmuch as the parties hereto agree
that this Agreement provides for an equitable distribution of their marital property in
accordance with Pennsylvania's Divorce Code, Subject to the provisions of this
Agreement, each party has rBleased and discharged, and by this Agreement does for
himself or herself, and his or her heirs, legal representatives, executors, administrators
and assigns, release and discharge the other of and from ell caused of action, claims,
rights or demands whatsoever in law or equity, which either of the parties ever had or
now has against the other, except any or all causes of action for divorce and except any
or all caused of action for any breach of any provision of this Agreement. Each party
also waJves his or her right to request marital counseling pursuant to Pennsylvania's
Divorce Code.
12. ALIMONY
Both parties mutually waive all spousal support or alimony from the other,
Both parties acknowledge and agree that the provisions of this Agreement providing for
the waiver of alimony are fair, adequate and satisfactory based on actual need, ability to
pay, duration of the marriage and other relevant factors taken into consideration by the
parties, Although the approval of this Agreement by a court of competent jurisdiction in
connection with this action In divorca filed by Husband or Wife shall be deemed an order
of the court any may be enforced as such, this Agreement, insofar as it pertains only to
spousal support and the payment of alimony following the entry of a final Decree in
Page 4 of 10
Divorce between the parties, may not be modified, suspended, terminated or reinstated
at the Instance of request of either party, or subject to further order of any court upon
changed clrcumstances. Upon that condition, both parties hereby accept the provisions
in this Agreement In lieu of and in full and final settlement and satisfaction of all claims
and demands that either may now or hereafter have against the other lor spousal
support or alimony and both parties voluntarily and intelligently waive and relinquish any
rights to seek a modification, suspension, termination, reinstatement, or other court order
with respect to the terms of this Agreement pertaining to the payment at support or
alimony,
13. ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES
Both parties hereby acknowledge and accept that the provisions of this Agreement
providing for the equitable distribution of marital property are fair, adequate and
satisfactory to them. Both parties agree to accept the provisions of this Agreement in
lieu of and In full and final settlement and satisfaclion of all claims and demands that
either may now or hereafter have against the other for alimony pendente lite, counsel
fees any expenses during and aftBr the commencement of any divorce proceeding
between the parties,
14, INCOME TAX RETURNS
Husband and Wife agree to individual tax returns for 1997 artd thereafter until their
divorce is final.
15. WAIVER OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may dispose of his or her
property in any way, and each party hereby waives and relinquishes any and all rights
he or she may now have or hereafter acquire, under the present or future laws of any
jurisdiction, to share in the property or the estate of the other as a result of the martial
relationship, including, without limitation, dower, curtesy, statutory allowance, widoW's
allowance, right to take intestacy, right to take against the will of the other, and right to
act as administrator or executor of the other's estate. Each will, at the request of the
Page 5 of 10
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other, execute, acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all
such Interests, rights and claims and both parties will revoke prior wills or testamentary
documents,
16, AGREEMENT NOT PREDICATED ON DIVORCE
It is specifically understood and agreed by and between the parties herBto and
each of the said parties does hereby warrant and represent to the other, that the
execution and delivery of this Agreement is not predicated upon nor made subject to any
agreement for institution, prosecution, defense, or for the non-prosecution or non-
defense of any action for divorce; provided, however, that nothing containBd in this
Agreement shall prevent or preclude either of the parties hereto from commencing,
Instituting or prosecuting any action or actions for divorce, Bither absolute or otherwise,
upon just, legal and proper grounds; nor to prevent either party from defending any such
action which has been, mayor shall be Instituted by the other party, or from making any
just or proper defense thereto,
17. SUBSEQUENT DIVORCE
There has been a divorce proceeding commenced by Husband against Wife in
Cumberland County to No. 6626 Civil Term 1997. The parties hereby mutually consent
to a divorce and the entering of a divorce decree on the no-fault grounds that their
marriage Is Irretrievably broken pursuant to ~3301 (c) of the Pennsylvania Divorce Code.
Parties herein shall execute Affidavits of Consent and a final decree in divorce will then
be obtained.
18, BREACH AND ENFORCEMENT
If either party hereto breaches any of the provisions of this Agreement, the other
party shall have the right to bring any actions or actions in law or equity for such breach,
and the breaching party shall be responsible for the payment of all costs and reasonable
legal fees Incurred by the other party In enforcing his or her rights under this Agreement.
Page 6 of 10
It Is expressly understood and agrl:led by and between the parties hereto that this
Agreement may be specifically enforced by either party in Equity, and the parties hereto
agree that if an action to enforce this Agreement Is brought In Equity by either party, the
other party will make no objection on the alleged ground of lack of jurisdiction of said
Court on the ground that there Is an adequate remedy at law. The parties do not Intend
or purport hereby to improperly confer jurisdiction on a Court in Equity by this
Agreement, but they agree as provided herein for the forum of equity In mutual
recognition of the present state of the law, and In recognition of the general jurisdiction
of Courts In Equity over agreements such as this one.
19. RE-ACKNOWLEDGMENT
Each party acknowledges that It may be appropriate and required that this
Agreement be re-acknowledged at some time In the Mure before the Clerk of the
Commonwealth Court, Clerk of Orphans Court or some other Court, and each party
agrees that they will re-acknowledge thBir signature before the Clerk of such Court upon
request of the othBr party so that this Agreement may comply with the acknowledgement
rules and provisions of any such Court,
20, ADDITIONAL INSTRUMENTS
Each of the parties hereto agrees that he or she will join in the executJon,
acknowledgment and delivery of any deed or other document which may be reasonably
necessary to carry out the intent of this Agreement, and, in the event either of the parties
hereto would not join In the execution, acknowledgement and delivery of such
Instrument, then such party does hereby irrevocably appoint the other party hereto as
his or her AttomBy-ln-Fact to execute, acknowledge and deliver such instrument hereby
ratifying all that such other party hereto may do by virtue hereof with a copy of this
Agreement to be a sufficient Power of Attorney to carry out the intent and purpose of this
paragraph.
Nothing contained in this section shall affect the right of one party to expressly
include or exclude, as the case may be, the other party as beneficiary in any will,
Page 7 of 10
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Insurance policy or other document whether the same is presently in effect or would
become effective In the future,
21. VOLUNTARY EXECUTION
The provisions of this Agreement and their legal effect have been fully explained
to the parties by th..ir respeciive legal representatives, and each party acknowledges that
the Agreement is fair and equitable, that It Is being entered Into voluntarily, with full
knowledge of the assets of both parties, and that It Is no the result of any duress or
undue Influence. The parties acknowledge that they have been furnished with all
information relating to the financial affairs of the other which has been requested by each
of them or their respective counsel.
22. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the parties and there are not
representations, warranties, covenants or undertakings other than those expresBly set
forth herein.
23. DISCLOSURE
Each of the parties hereto acknowledges that there has been full disclosure of all
relevant matters of each party to the other party, that each of the parties is fully cognlumt
of his and her legal rights and liabilities with respBct to the terms and conditions of this
Agreement, that he and she understand the legal effect of this provisions of this
Agreement and acknowledge that this Agreement is fair and equitable to each of the
parties hereto, and that this Agreement was entered into voluntarily and without any
undue Influence or duress upon either party hereto.
24. MODIFICATION AND WAIVER
This Agreement shall constitute a full, complete, and total binding Agreement
between the parties concerning support, maintenance, alimony and property settlement,
and Is precluded from modification EXCEPT If the parties spBcifically agree to modify this
Agreement.
Page 8 of 10
. '.
Any and all modifications to this Agreement shall only be by written agreement
containing the same formalities as this Agreement and shall exhibit the notarized
signatures of both parties, along with two witnesses.
The parties specifically agree that they may rescind this Agreement only by written
agreement containing the same formalities as this Agreement which shall exhibit the
notarized signatures of both parties, along with two witnesses.
Any waiver of a breach of any provision of this Agreement shall not constitute an
ongoing walver.
25. PRIOR AGREEMENTS
this Agreement constitutes the entire understanding and agreement between the
parties hereto, and there are no other representations, warranties, covenants,
understandings or agreements other than those expressly set forth herein.
26, INCORPORATION INTO DECREE OF DIVORCE 8lir Nor f. {)
M~ ~~s as otherwise provided herein, this Agreement shall be Incorporated il'l aRa -.vP
made a "aft af any Decree that might be entered in any dissolution proceeding between
the parties hereto upon the filing by either or both parties of an executed copy of this
Agreement In such action and, same may be incorporated by reference into any such
Decree or court order.
27, DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience only. They shall have
no effect whatsoever in determining the rights or obligations of the parties.
28, INDEPENDENT AND SEPARATE COVENANTS
It Is specifically understood and agreed by and between the p3rties hereto, that
each paragraph shall be deemed a separate and independent covenant and agreement.
Page 9 of 10
29, APPLICABLE LAw..
This Agreement shall be interpreted in accordance with the leM of the
Commonwealth of Pennsylvania,
30. VOID CLAUSES
If any term, condition, clause or provision of this Agreement shall be determined
or declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provision Bhall be stricken from this Agreement and in all other rllpects, this
Agreement shall be valid and continue in full force, effect and operation
31, AGREEMENT BINDING ON HEIRS
This Agreement shall inure to the benefit of and shall be binding upon the parti..
hereto, their heirs, executors, administrators, successors and assigns.
32, EFFECTIVE DATE
This Agreement shall be conaldered to be effective at 12:01 a,m, on the date lit
forth on page one of this Agreement.
In T..tlmony Whereof, witness the signature of the parties hereto thla
day of March, 1998.
P~~
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EMn B, Diller
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Peter J. Russo
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Darlene A, Diller
Page 10 of 10
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ELVIN B. DILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
v.
DARLENE A. DILLER,
Defendant
DIVORCE 87.926
Addendum to Property Settlement AgrHment
Whereas, Parties have had adequate time and opportunity to consult with
separate legal counsel of their own and executed a Property SeUlement Agreement, and
Whereas, both PartiBs acknowledge that they are satisfied with the legal advice
they have received and understand the full importance of the Agreement they are
entering into;
Now, Therefore, the parties, In consideration of the foregoing premises, and the
mutual promises and undertakings hereinafter set forth, agree as follows:
1. Elvin B. Diller agrees to maintain and provide a comprehensive health care
insurance for Darlene A. Diller,
2. Elvin B, Diller shall, at his own expense, provide said health care Insurance
;3D
through AprilJf. 199B,
ED 'PI
'1JD In Testimony Whereof, witness the signature of the parties hereto this 19
day 01 March, 199B,
f?&.ihPl---,:
Philip H. st>are
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Elvin B. Diller
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Peter J, Russo
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Darlene A. Diller
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VERIFICATION
I verify that the statements made in the foregoing Complaint
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. S 4904 relating
to unswor.n falsification to authorities.
, If'(}!'
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Elvin B. Diller
Date: December 1, 1997
LAW O"lcr;a
SNELDAKEA.
BRENNEMAN
a SPARE
ELVIN B. DILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-' (..J&
: CIVIL ACTION - LAW
CIVIL TERM
DARLENE A. DILLER,
Defendant
IN DIVORCE
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AFFIDAVIT
ELVIN B. DILLER, being duly sworn according to law, deposes
and says:
1. I have been advised of the availability of marriage
counseling and u~derstand 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 Office of the Prothonotary, which list is
available to me upon request.
3. Being so advised, I do liQI request that the court
require 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. S 4904 relating to unsworn
falsification to authorities.
LAW O,.,"ICli:'
SNELBAKER.
BRENNEMAN
a SPARE
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Elvin B. Diller
(Plaintiff)
Date;
December 1, 1997
.
PETER J. RUSSO, ESQUIRE Attorney for Defendant
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
ELVIN B. DILLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO, 97-6626 CIVIL TERM
DARLENE A. DILLER CIVIL ACTION. DIVORCE
Defendant
CERTIFICATE OF SERVICE
I, Peter J, Russo, hereby certify that I am on this day serving a copy of the
ENTRY OF APPEARANCE
upon the person (s) and in the manner indicated below, service by First-Class
Mall, Postage Prepaid, and Addressed as Follows:
....
Phillip H, Spare
Snelbaker, Brenneman & Spare
Attorneys At Law
44 West Main Street
'Mechanicsburg, PA 17055
(=Q-to(y
Peter J. Russo
61 West Louther Street
Carlisle, P A 17013
(717) 249-2721
Date: ---L);:;li I q lr"
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IN THE COURT OF COMMON PLEAS OF
CUMBERlAND COUNTY, PENNSYLVANIA
CIVIL ACTION. lAW
NO. 97-<<5628 CIVIL TERM
IN DIVORCE
ELVIN B. DILLER
Plaintiff
DARLENE A. DILLER
Defendant
DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NonCE
OF INTENTION TO ENTER DIVORCE DECREE
UNDER SECTION 3301 (c) OF THE DIVORCE CODE
1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on December 1, 1997.
2, The marriage is Irretrievably broken and ninety daYB have elapsed from
the date of the filing and service of the Complaint.
3, I consent to the entry at a Final Decree of Divorce without further notice,
4, 1 understand that I may lose rights concerning alimony, division of
property, lawyers fees or expenses if I do not claim them before a divorce 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
filed with the Prothonotary's Office.
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, I understand that the court maintains a list of marriage counselors In
the Domestic Relations Office, which list is avaliable to me on request.
7, Being so advised, I, Darlene A. DIIIBr, do not request that the Court
require my spouse and me to participate In counseling prior to a divorce decree
being handed down by the Court.
t verify that the statements made In this Affidavit are true and correct, I
understand that false statements herein are made subject to the penaltles ot 18
Pa,C,S, g 4904 relating to unswom falsification to Authorities,
.
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Darlene A, Diller
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ELVIN B. DILLER,
PlaIntiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE 97-6626
v.
DARLENE A. DILLER,
Defendant
DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF INTENTION
UNDER SECTION 3301 (~) OF THE DIVORCE CODE
1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code
was tiled and received by thB Defendant on DBcember 8, 1998.
2. The marriage is irretrievably broken and ninety days have elapsed
from the date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce.
4, I understand that I may lose rights concerning alimony, division of
property, lawyers fees or expenses if I do not claim them before a divorce is granted.
However, I have reached an agreement with the Plaintiff which satisfies all of r.1Y
requirements. This agreement Is in the form of a Property Settlement Agreement which
I have executed and which I understand is to be incorporated but not merged in the
Divorce Decree in this matter.
5. 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.
6. I understand that the court maintains a list of marriage counselors
In the Domestic Relations Office, which list is available to me on request.
-'
7, Being so advised, I, Darlene A. Diller, do not request that the Court
require my spouse and me to 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,
understand that false statements herein are made subject to the penalties of 18 Pa,C,S,
~ 4904 relating to unsworn falsification to Authorities,
Date: Wednesday, March 11. 1998
\.-\~\h",-Il. Q '~'t,\})H)
Darlene A, Diller
Date: Wednesday. March 11. 1998
G~?-~
Witness
-
ELVIN B. DILLER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-6626 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ARLENE A. DILLER,
Defendant
AFFIDAVIT OF SERVICE
OMMONWEALTH OF PENNSYLVANIA)
OF CUMBERLAND)
Philip H. Spare, Esquire, being duly sworn according to law
S5.
eposes and says: that he is a principal in the law firm of
nalbaker, Brenneman & Spare, P. C., being the attorneys for
Diller, Plaintiff in the above captioned action in
LAW OI""CEI
S~I!:LBAKER.
BRENNeMAN
8: SPARE
that on December 3, 1998, he did send to Defendant
Diller, by certified mail, return receipt requested,
estricted delivery, a duly certified copy of the Complaint in
ivorce as filed in the above captioned action as evidenced by
he attached cover letter of the same date and Receipt for
ertified Mail No. P 206 994 ~31; that said Complaint and cover
etter were duly received by Darlene A. Diller, Defendant herein,
s evidenced by the return receipt card for said certified mail
ated December 8, 1998; that a copy of the aforementioned cover
etter dated December 3, 1997 is attached hereto and incorporated
y reference herein as "Exhibit A" and that the original Receipt
or certified Mail and the Domestic Return Receipt are attached
P 201. 994 231
US Poalll SoMco
Receipt tor Certified Mall
No InlU'IIlCI eov..lgI ProvIdod,
Do not Ulllor Inlomallonal Mail So. ....,..
D:r1ene ^. Diller
28~L.th Nountain Hd
Newvi'!' ~ P^ 17241
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320 North Nountain Rd.
NCI/ville, Pl. 17241
5, Rocllvod By: {PrlnllWne}
LAW OPflCEII
SNELeAICEH.
BRENNEMAN
6: SPARE
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PS Form 381 . Doc:embol l~
Domestic Return Receipt
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