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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND
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COUNTY
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STATE OF
PENNA,
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Jeffrey L. Donnelly
Plaintiff
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Gina L. Donnelly
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Defendant
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DECREE IN
DIVORCE
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AND NOW, ..........1~...?-=!........, 19.r.f.... it is ordered and
decreed that ... o!~.f.~~~y. .r,.:. P.~~I;l~.1.l.x. . . . . . . . . . . . . . . . . . . . . . .. plaintiff,
and. ... . .. .. .. . .~~~~. .1:: . ~?~~7~.lX . ... . .. ...... . ... .. . .. ..., defendant,
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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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this fJO"{-L day of H(V..~, 1998 by and
between GINA L. DONNELLY of Perry County, Pennsylvania (hereinafter
referred to as WIFE), and JEFFREY L. DONNELLY of Cumberland County,
Pennsylvania (hereinafter referred to as HUSBAND),
WHEREAS, HUSBAND and WIFE were lawfully married on June 10,
1985 in Hagerstown, Maryland, and;
WHEREAS, there is one (1) child of this marriage, namely,
BRANDY LEIGH DONNELLY, born May 8, 1988, and;
WHEREAS,
diverse,
and
differences,
unhappy
disputes
difficulties have arisen between the parties and it is the
intention of HUSBAND and WIFE to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and property
rights and obligations as between each other, including without
limitation by specification: the settling of all matters between
them relating to the ownership and equitable distribution of real
and personal property; the settling of all matters between them
relating to past, present and future support and alimony; and in
general, the settling of any and all claims by one against the
other or against their respective estates.
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NOW, THEREFORE, in consideration of the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
and for other good and valuable consideration, receipt of which is
hereby acknowledged by each of the parties hereto, HUSBAND and
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WIFE, each intending to be legally bound, hereby covenant and agree
as follows:
1. Separation: It shall be lawful for each party at all
times hereafter to live separate and apart from the other party at
such place as he or she may from time to time choose or deem fit.
The foregoing provision shall not be taken as an admission on the
part of either party of the lawfulness or unlawfulness of the
causes leading to their living apart.
2. Interference: Each party shall be free from
interference, authority, and contact by the other, as fully as if
he or she were single and unmarried, except as may be necessary to
carry out the provisions of this Agreement. Neither party shall
molest the other or attempt to endeavor to molest the other, nor
compel the other to cohabit with the other, or in any way harass or
malign the other, nor in any way interfere with the peaceful
existence of the other, while living separate and apart.
3. Subsequent Divorce: The parties hereby acknowledge that
HUSBAND had filed a Complaint in Divorce on January 15, 1998 in
Cumberland County, Pennsylvania to docket number 98-229 civil,
claiming that the marriage is irretrievably broken under the no-
fault mutual consent provision of Section 3301(c) of the
Pennsylvania Divorce Code. WIFE hereby expresses her agreement that
the marriage is irretrievably broken and expresses her intent to
execute any and all affidavits or other documents necessary for the
~arties to obtain an absolute divorce pursuant to Section (c) of
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the Divot'ce Code. The parties hereby waive all rights to request
Court-order.ed counseling under the Divorce Code. It is specifically
understood and agreed by the parties that the provisions of this
Agreement as to equitable distribution of property of the parties
are accepted by each party as a final settlement for all purposes
whatsoever, as contemplated by the Pennsylvania Divorce Code.
Should a decree, jUdgment or order of separation or divorce be
obtained by either of the parties in this or any other state,
country or jurisdiction, each of the parties hereby consents and
agrees that this Agreement and all of its covenants shall not be
affected in any way by any such separation or divorce; and that
nothing in any such decree, judgment, order or further modification
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or revision thereof shall alter, amend or vary any term of this
Agreement, whether or not either or both of the parties shall
remarry. It is specifically agreed, that a copy of this Agreement
or the substance of the provisions thereof, may be incorporated by
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reference, but not merged, into any divorce, judgment or decree. It
is the specific intent of the parties to permit this Agreement to
survive any judgment and to be forever binding and conclusive upon
the parties.
4.
Date of Execution:
The
"date
of
execution"
or
"execution date" of this Agreement shall be defined as the day upon
which it is executed by the parties if they have each executed the
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agreement on the same date. otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of
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execution by the party last executing this Agreement.
5.
Distribution Date:
The transfer of property, funds
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and/or documents provided for herein, shall only take place on the
"distribution date" which shall be defined as specified herein.
6. Mutual Release: HUSBAND and WIFE each do hereby mutually
remise, release, quitclaim and forever discharge the other and the
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estate of such other, for all time to come, and for all purposes
whatsoever, of and from any and all rights, title and interests, or
claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of
such other, of whatever nature and wheresoever situate, which he or
she now has or at any time hereafter may have against the other,
the estate of such other or any part thereof, whether arising out
of any former acts, contracts, engagements or liabilities of such
other or by way of dower or curtesy, or claims in the nature of
dower or curtesy or widow's or widower's rights, family exemption
or similar allowance, or under the intestate laws, or the right to
take against the spouse's will; or the right to treat a lifetime
conveyance by the other as testamentary, or all other rights of a
surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) Pennsylvania, (b) any state,
Commonwealth or territory of the United States, or (c) any country,
or any rights which either party may have or at any time hereafter
shall have for past, present or future support or maintenance,
alimony, alimony pendente lite, counsel fees, property division,
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costs or expenses, whether arising as a result of the marital
relations or otherwise, except, all rights and obligation of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any provisions thereof.
It is the intention of HUSBAND and WIFE to give to each other,
by the execution of this Agreement a full, complete and general
release with respect to any and all property of any kind or nature,
real, personal or mixed, which the other now owns or may hereafter
acquire, except and only except all right and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
It is further agreed that this Agreement shall be and
constitute a full and final resolution of any and all claim which
each of the parties may have against the other for equitable
division of property, alimony, counsel fees and expenses, alimony
pendente lite or any other claims pursuant to the Pennsylvania
Divorce Code or the divorce laws of any other jurisdiction.
7. Advice of Counsel: The provisions of this Agreement and
their legal effect have been fully explained to WIFE by DEBRA
DENISON CANTOR, ESQUIRE counsel for WIFE, and to HUSBAND by MARYANN
MURPHY, ESQUIRE, counsel for HUSBAND.
HUSBAND and WIFE acknowledge and accept that this Agreement
is, in the circumstances, fair and equitable and that it is being
entered into freely and voluntarily and that execution of this
Agreement is not the result of any duress or undue influence and
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that it is not the result of any collusion or improper or illegal
agreement or agreements.
8. Warrantv as to Existing obligations: Each party
represents that he or she has not heretofore incurred or contracted
for any debt or liability or obligation for which the estate of the
other party may be responsible or liable except as may be provided
for in this Agreement. Each party agrees to indemnify and hold the
other party harmless for and against any and all such debts,
liabilities or obligations of every kind which may have heretofore
been incurred by them, including those for necessities, except for
the obligation arising out of this Agreement.
9. EXISTING DEBTS: HUSBAND and WIFE acknowledge that
both have filed Petitions in Bankruptcy, and anticipate that all
marital debt will be discharged in these proceedings.
10. Warranty as to Future Obliaations: HUSBAND and WIFE each
covenant, warrant, represent and agree that, with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable. Each party shall indemnify and hold
harmless the other party for and against any and all debts, charges
and liabilities incurred by the other after the execution date of
this Agreement, except as may be otherwise specifically provided
for by the terms of this Agreement.
11. Personal Property: HUSBAND and WIFE agree that all of
their personal property has been distributed between them to their
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mutual satisfaction. HUSBAND shall become the sole and exclusive
owner of all items of personal property currently in his
possession. WIFE shall become the sole and exclusive owner of all
items of personal property currently in her possession.
Neither party shall make any claim to any such item of marital
property, or of the separate personal property of either party,
except as provided for in this Agreement, which will be in the
possession and/or under the control of the other at the time of the
execution of this Agreement.
Should it become necessary, the parties each agree to sign,
upon request, any titles or documents necessary to give effects to
this paragraph. Property shall be deemed to be in the possession or
under the control of either party if, in the case of tangible
personal property, the item is physically in the possession or
control of the party at the time of the execution of this
Agreement; and in the case of intangible personal property, if any
physical or written evidence of ownership, such as passbook,
checkbook, policy or certificate of insurance or other similar
writing is in the possession or control of the party at the time of
the execution of this Agreement.
13. Pension/Retirement Benefits: The parties acknowledge
that each has accrued pension/retirement benefits during the course
of their marriage through their respective employers.
HUSBAND and WIFE agree that WIFE shall become the sole and
exclusive owner of any and all pension/retirement benefits which
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she has accrued. HUSBAND waives any and all rights and interest he
may have in WIFE's pension/retirement benefits, and he agrees to
execute, upon request, any and all documents necessary to
effectuate the terms of this agreement.
HUSBAND and WIFE agree that HUSBAND shall become the sole and
exclusive owner of any and all pension/retirement benefits which he
has accrued. WIFE waives any and all rights and interest she may
have in HUSBAND's pension/retirement benefits, and she agrees to
execute, upon request, any and all documents necessary to
effectuate the terms of this agreement.
14. Medical Insurance: WIFE agrees that she will provide
health insurance coverage through her employer for the parties'
minor child, BRANDY. In the event that HUSBAND has health insurance
coverage available to him through his employer in the future, the
parties agree that the parent who can obtain employer-sponsored
health insurance coverage for BRANDY at the least expense shall
provide such coverage.
15. Motor Vehicle: The parties agree that WIFE shall become
the sole and exclusive owner of the 1992 Saturn titled in WIFE's
individual name. WIFE agrees to be solely responsible for the
balance of the loan on this vehicle. WIFE further agrees to
indemnify HUSBAND and hold him harmless from any and all liability
for same.
The parties agree that HUSBAND shall become the sole and
exclusive owner of the 1981 Impala titled in HUSBAND's individual
name. HUSBAND and WIFE agree that there is no loan on this vehicle.
16. Mter Acquired Personal Property: 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
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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
respects and for all purposes, as though he or she were unmarried.
17. ADplicabilitv of Tax Law to Prooertv Transfers: The
parties hereby agree and express their intent that any transfers of
property pursuant to this Agreement shall be within the scope and
applicability of the Deficit RedUction Act of 1984 (herein the
"Act"), specifically, the provisions of said Act pertaining to
transfers of property between spouses or former spouses. The
parties agree to sign and cause to be filed any elections or other
documents required by the Internal Revenue Service to render the
Act applicable to the transfers set forth in this Agreement,
without recognition of gain on such transfer and subject to the
carry-over basis provisions of said Act.
18. Waiver of Alimo~: The parties herein acknowledge that
by this Agreement they have respectively secured and maintained
substantial financial resources to provide for their comfort,
maintenance and support, in the station of life to which they are
accustomed.
HUSBAND and WIFE do hereby waive, release and give up any
rights they may respectively have against the other for alimony,
spousal support or maintenance. It shall be, from the execution of
this Agreement, the sole responsibility of each of the respective
parties to sustain themselves without seeking any support from the
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other party.
19. Waiver of Spousal Suoport. AlimollY Pendente Lite and
Legal Fees: Each party hereby waives any right to spousal support
and alimony pendente lite. The parties agree to be responsible for
their own attorney's fees.
20. Disclosure and Waiver of Procedural Rights: Each party
understands that he or she has the right to obtain from the other
party a complete inventory or list of all of the property that
either or both parties own at this time or owned as of the date of
separation, and that each party has the right to have all such
property valued by means of appraisals or otherwise. Both parties
understand that they have the right to have the Court hold hearings
and make decisions on the matters covered by this Agreement. Both
parties understand that a Court decision concerning the parties'
respective rights and obligations might be different from the
provisions of this Agreement.
Both parties waive the following procedural rights:
a. The right to obtain an Inventory and Appraisement of
all marital and separate property as defined by the Pennsylvania
Divorce Code;
b. The right to obtain an Income and Expense statement
of the other party as provided by the Pennsylvania Divorce Code;
c. The right to have the Court determine which property
is marital and which is non-marital and equitably distribute
between the parties that property which the Court determines to be
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marital;
d. The right to have the Court decide any other rights,
remedies, privileges, or obligations covered by this Agreement,
including but not limited to, possible claims for divorce, spousal
support, alimony, alimony pendente lite, counsel fees, costs and
expenses.
21. Waiver of Modification to be in Writing: No modification
or waiver of any of the terms hereof shall be valid unless in
writing and signed by both parties and no waiver of any breach
hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
22. Mutual Coooeration: Each party shall, at any time and
from time to time hereafter, take any and all steps and execute,
acknowledge and deliver the other party any and all further
instruments and/or documents that the other party may reasonably
require for the purpose of giving full force and effect to the
provisions of this Agreement.
23. Apolicable Law: This Agreement shall be construed in
accordance with the laws of the Commonwealth of Pennsylvania which
are in effect as of the date of execution of this Agreement.
24. Agreement Bindina on Heirs: This Agreement shall be
binding and shall inure to the benefits of the parties hereto and
their respective heirs, executors, administrators, successors and
assigns.
25. Integration: This Agreement constitutes the entire
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understanding of the parties and supersedes any and all prior
agreements and negotiations between them. There are no
representations or warranties other than those expressly set forth
herein.
26. Other Documentation: HUSBAND and WIFE covenant and agree
that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement.
27. No Waiver on Default: This Agreement shall remain in
full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the same, nor shall the waiver of any default
or breach of any provisions hereof be construed as a waiver of any
subsequent default or breach of the same or similar nature, nor
shall it be construed as a waiver of strict performance of any
other obligations herein.
28. Severability: 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 shall be stricken from this
Agreement and in all other respects this Agreement shall be valid
and continue in full force, effect and operation. Likewise, the
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failure of any party to meet his or her obligation under anyone or
more of the paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way avoid or
alter the remaining obligations of the parties.
29. Breach: If either party breaches any provision of this
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. The party
breaching this contract shall be responsible for payment of
reasonable legal fees and costs incurred by the other in enforcing
their rights under this agreement.
30. Headinas Not: Part: of Aareement:: Any heading preceding
the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience of reference and shall not
constitute a part of this Agreement nor shall they affect its
meaning, construction or effect.
IN WITNESS WHEREOF, the parties hereto have set their
hands and seals this day and year first above written.
S -13''If
Date
Witness
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF C(;V}~/;;;DI L-ft_iLCC
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On this the ..Y' day of . / 1998,
before me the undersigned, personally appeared GINA L. DONNELLY,
known to me (or satisfactorily proven) to be the person whose name
is subscribed to the within Property Settlement Agreement, and
acknowledged that she executed the same for the purpose therein
contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
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L Notary Public
NOlarial Seal
Ahonda L. Woods, Notary Public
Camp HIli Boro. Cumborland COunty
My CommissIon Expiro!j Sept, 1. 2001
emher r.nnS'/lv:llJla ssocl:\llrm 0 101,11105
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~v
ss:
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On this the '^ 0 day of I'" '--J-- 1998,
before the undersigned officer, personally aBpeared JEFFREY L.
DONNELLY, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Property Settlement
Agreement, and acknowledged that he executed the same for the
purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial
seal.
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Notary
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Nolallat Seal, .., ,
Marlanne E. AlIdobllSCI', Ilc,r; '-'. ' .,
LoworPaxtonTwp.. D.:L::~,;,l; (;-";,.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
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JEFFREY L. DONNELLY,
Plaintiff
GINA L. DONNELLY,
Defendant
IN DIVORCE
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NO. 98 - 229 Civil Term
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
Section 3301(c) of the Divorce Code.
2. Date and Manner of service of the Complaint:
Certified/restricted delivery. Service on January 24, 1998.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent
required by Section 330l( c) of the Divorce Code: by Plaintiff:
5/20/98; by Defendant: 5/13/98.
(b)(l )
Date of execution of the affidavit required by
Section 3301(d) of the Divorce Code: N/A.
(2) Date of filing and service of the affidavit upon
the respondent. N/A.
4. Related claims pending: All claims have been resolved.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of
Intention to file praecipe to transmit record, a copy of which is
attached: N/A.
(b) Date Plaintiff's Waiver of Notice in Section 3301(c)
Divorce was filed with the Prothonotary: 5/21/98.
Date Defendant's Waiver of Notice in Section 3301 (c)
Divorce was filed with the Prothonotary: 5/18/98.
Maryann Murphy, Esqu're
Attorney for PLAINTIFF
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JEFFREY L. DONNELLY, IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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GINA L. DONNELLY, . CIVIL ACTION - LAW
.
Defendant . IN DIVORCE
.
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
take prompt action.
You are warned that if you fail to do so, the case may
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
visitation 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, Cumberland county
courthouse, Carlisle, Cumberland county, pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT 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.
aJMBERLAND CXlUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
E
NOTICIA
Le han demand ado a usted a la corte. si usted quiere
defenderse en contra estas demandas expuestas en las paginas
siguientes, usted tiene veinte (20) dias de plazo al partir de
la facha de la demanda y la notificacion. Usted debe presentar
una apariencia escrita 0 en persona 0 por abogado y archivar
en la corte en forma escrita sus defensas 0 sus objeciones a
las demandas en contra suya.
Se ha avisado que si usted no se def ienda, la corte
tomara medidas y puede entrar una orden contra usted sin
previo aviso 0 notificacion y por cualquier queja 0 alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO
o PROPIENDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED
NO TIENE 0 CONOCES UN ABOGADO, VAYA EN PERSONA 0 LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA
LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
carlisle, PA 17013
(717) 240-6200
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is
required by law to comply with the Americans with Disabilities
Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals
having business before the Court, please contact our office.
All arrangements must be made at least 72 hours prior to any
hearing or business before the Court. You must attend the
scheduled conference or hearing.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Court Administrator
Cumberland county Courthouse
Carlisle, PA 17013
(717) 240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY, .
.
Plaintiff
(!t;"';.J -
v . NO. 9f- .<..;1'1 I~<........
.
GINA L. DONNELLY, IN DIVORCE
Defendant .
.
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
AND NOW comes the Plaintiff, JEFFREY L. DONNELLY, by and
through his attorney, Maryann Murphy, Esquire, who respectfully
avers as follows:
1. Plaintiff is JEFFREY L. DONNELLY who currently
resides at 7325 Wertzville Road, Carlisle, Cumberland county,
Pennsylvania.
2. Defendant is GINA L. DONNELLY who currently resides
at 719-B Valley street, Marysville, Perry County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide
residents in the Commonwealth for at least six months immediately
previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 10,
1985 in Hagerstown, Maryland.
5. There have been no prior actions for divorce or for
annulment between the parties.
6. Defendant is not a member of the Armed Forces of the
United states of America or any of its Allies.
7. The marriage is irretrievably broken.
8. plaintiff has been advised of the availability of
marriage counseling and that he may have the right to request the
Court to require the parties to participate in such counseling.
Being so advised, Plaintiff does not request that the Court require
the parties to participate in counseling prior to a Divorce Decree
being handed down by the Court.
9. Plaintiff requests this Court to enter a Decree in
Divorce from the bonds of matrimony.
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WHEREFORE, Plaintiff respectfully requests this
Honorable Court to enter a Decree dissolving the marriage between
the Plaintiff and Defendant.
Respectfully submitted,
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Maryan Murphy, Esquir
Attorney for Plaintiff
845 sir Thomas Court
suite 11 A
Harrisburg, PA 17109
(717) 540-5100
Supreme Court I.D. # 61900
AFFIDAVIT
I verify that the statements made in this Complaint Under
section 3301(c) of the Divorce Code are true and correct. I
understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. section 4904, relating to unsworn
falsification to authorities.
Date:
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Sworn and
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this day
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY, .
.
Plaintiff :
.
.
v . NO.
.
.
.
GINA L. DONNELLY, . IN DIVORCE
.
Defendant .
.
CERTIFICATE OF SERVICE
I, Maryann Murphy, Esquire, do hereby certify that a true and
correct copy of the Complaint in Divorce under Section 3301 (c) of
the Divorce Code was mailed by first class U.S. mail, postage pre-
paid, certified/restricted delivery, addressed as follows:
Gina L. Donnelly
719-8 Valley Street
Marysville, PA 17053
Date:
.' .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY, :
Plaintiff .
.
.
.
v. . NO. 98 - 229 civil Term
.
.
.
GINA L. DONNELLY, :
Defendant . IN DIVORCE
.
AFFIDAVIT OF CONSENT
L A complaint in Divorce under section 3301(c) of the
Divorce Code was filed on January 15, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the complaint.
3. I consent to the entry of a final decree in divorce after
service of Notice of Intention to Request Entry of the Decree.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
~ #()!98'
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OOIlIlELLY(PLA~
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY,
Plaintiff
:
:
:
v.
: NO. 98 - 229 civil Term
.
.
GINA L. DONNELLY,
Defendant
:
: IN DIVORCE
AFFIDAVIT OF CONSENT
L A complaint in Divorce under section 3301(c) of the
Divorce Code was filed on January 15, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the Complaint.
3. I consent to the entry of a final decre& in divorce after
service of Notice of Intention to Request Entry of ~he 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. Section 4904 relating to
unsworn falsification to authorities.
5-/3- ??
Date
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY,
Plaintiff :
.
.
v. : NO. 98 - 229 civil Term
:
GINA L. DONNELLY, .
.
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
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
unsworn fals~cation
Date: 5J~o 9:t
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY, :
Plaintiff .
.
:
v. . NO. 98 - 229 civil Term
.
:
GINA L. DONNELLY, .
.
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
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 net 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
unsworn falsification
Date: :;- }3-7~
to authori ti~. , /F'''- 2/
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,'Fg~hSYLVANIA
CIVIL ACTION - LAW
JEFFREY L. DONNELLY, :
plaintiff .
.
:
v. . NO. 98-229 CIVIL
.
:
GINA L. DONNELLY, : IN DIVORCE
Defendant .
.
AFFIDAVIT OF SERVICE
I, Maryann Murphy, Esquire, depose and say:
1. That I am an adult individual residing in
Cumberland county, Pennsylvania.
2. That on January 22, 1998 I sent by u.S. mail,
postage prepaid, certified/restricted delivery, number Z 720 048
297, a 3301(c) Complaint in Divorce in the above-captioned case,
to:
Gina L. Donnelly
719 B Valley Street
Marysville, PA 17053
3. That on January 24, 1998, service of the 3301(C)
Complaint in Divorce was made upon Gina L. Donnelly, as evidenced
by her signature on the return receipt which is attached to this
Affidavit.
Maryann urphy, Esquir
845 Sir Thomas Court
Sui te llA
Harrisburg, PA 17109
(717) 540-5100
I.D. # 61900
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