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2. INTERFERENCES.
Each party shall be free from Interference, authority and control by the other,
as fully as If ha or she were single ilnd unmarried, except as may be necessary to
carry out the provisions of this Agreement. Neither party shall molest or attempt to
endeavor to molest the other, or in any way harass or malign the other, nor In any
other way Interfere with the peaceful existence, separate and apart from the other,
Each of the parties hereto complet~lly understands and agrees that neither shall
do or say anything to the child of the parties at any time which might In any way
Influence the child adversely against the other party,
3. DIVISION OF REAL PROPERTY.
Wife agrees to transfer all her right, title and Interest In and to the real estate
situated at 267 North 24th Street, Camp Hili, Cumberland County, Pennsylvania, now
tlt.led In the name of Husband and Wife as tenants by the entireties to the Husband
and agrees to Immediately execute now or In the future any and all deeds, documents,
or papers necessary to effect such transfer of title upon request. Wife further
acknowledges that she has nn claim, right, Interest. or title whatsoever In sold
property In the future. Sold transfer shall be effective Immediately and shall be binding
regardless of the marital status of the parties. Husband agrees to Indemnify and hold
Wife harmless on any liens of record against the said property and shall
Immediately take steps to refinance the property removing Wife's name from the
existing liens of record.
4. EQUITABLE DISTRIBUTION.
Husband will pay to Wife, in the form of equitable distribution, the sum of
$26,000.00. Said SUIll shall be paid to Wife at the time of refinancing.
6. FEDERAL INCQMUA.>t.REJJJ.BN.
The parties agree that they shall file a joint 1997 Federal income tax return and
Husbend shell pay all tax liabilities due at the time of refinancing.
6, MQJ:.QflYfHlCJ.ES.
Husband agrees that he shall pay the balance on the lease payments on Wife's
1996 Volkswagon Jetta, payable to VW Credit Corporation until the loan Is paid In
full, The said payments are $229.00 per month with approximately seven 171 months
remaining on the lease.
Husband shall pay all car insurance relating to the 1996 Ford Explorer and the
1996 Volkswagon Jetta,
Wife shall make all lease payments relating to the '1996 Ford Explorer.
7. HEALTH INSUM!iCJi.
Husband agrees to sllpply the parties' minor child with health Insurance as It
presently exists and shall continue to carry Wife on the said polley until the finalization
of J.l divorce action,
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8, DUI,
Husband shall payoff the following debts at the lime of the refinancing of the
primary residence:
1. Pennsylvenla State Bank Mastercard with an flpproxlrnAtll balance of
$2,636.00; and
2. Three (3) lines of credit with Pennsylvania State Bank, account
numbers 700333801 with an approximate balance of $14,970,00,
600389279 with An approxlmatfl balance of $2,311.00, an1l500389201
with an approximate balance of $10,686,00.
Husband shall be solely responsible for thfl Sears Plus account with an
approximate balance of $1,303.00 and the Sears Regular account with an
approximate balance of $1,113.00, which are In Husband's name Individually, but will
not be paid off at the time of refinancing,
Andrea's college trust with an approximate balance of $9,000,00, will also be
the responsibility of Husband.
All further debts Incurred by the parties shall be their Individual responsibility,
9, S.QJiQ01..J.QANS..
The parties' daughter, StAcie, has three (31 Plus loans as follows:
1. Plus loan #1, Ithaca, $13,918,00 (PHEAA);
2. Plus loan #2, UMD, $16,705,00 (Star BAnk); and
3. Plus loan #3, UMD, $7,853.00 (Fannie Mae),
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Husband agraes that he shall continue to make payments on the said loans.
Wife agrees that she will be responsihle for fifty (60%1 percent of the sold loans and
will either contribute to the loans or reimburse Husband as she Is financially able.
10. p'IVISION OF PERSONALPROPER.IY.
The parties have divided between them to their mutual satisfaction, personal
effects, household goods and furnishings and all other artloles of personal property
which have heretofore been used In common by them, and neither party will make any
claim to any such Items which are now In the possession or under the control of the
other. Should It become necessary, each party agrees to sign any title or documents
necessary to give effect to this paragraph, upon request.
11. IAK..ON PROPERTY DIVISION.
Husband hereby agrees to pay all Income taxes assessed against him, If any,
as a result of the division of the property of the parties hllfellnder. Wife hereby agrees
to pay all Income taxes assessed against her, If any, as a result of the division of the
property of the parties hereunder.
12. BREACl1.
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. The party
breaching this contract shall be responsible for '-he payment of legal fees and costs
5
Inourred by the other In enforcing his or her rights under this Agreement, or seeking
suoh other remedy or relief as may be available to him or her.
13. fW DISCLOSUllE.
Husband and Wife each represent and warrant to the other that he or she has
made a full and complete disclosure to the other of all assets of any nature
whatsoever In which such party of every type whatsoever and all other facts relating
to the subject matter of this Agreement.
14. ADDITIONAl. INSTRUMENT.
Each of the parties shall on demand execute and deliver to the other any deeds,
bills of sale, assignment, consents to change of beneficiary on Insurance policies, tax
returns and other documents and do or caused to be done any othor act or thing that
may be necessary or desirable to the provisions and purposes of this Agreement. If
either party falls on demand to comply with this provision, that party shall pay to the
other all attorneys' fees, costs and other expenses reasonable Incurred as a result of
such failure.
15. WIFE'S DEBTS.
Wife represents and warrants to Husband that since the parties' separation she
has not and In the futuro she will not contract or Incur any debt or liability for which
Husband or his estate might be responsible and shall Indemnify and save Husband
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harmless from any and all olalms or demands made against him by reason of debts or
obligations Inourred by her.
16. liU.S.BAND'S DEBT.S.
Husband represents and warrants to Wife that since the parties' seperatlon he
has not and In the future he will not contract or Incur any debt or liability for which
Wife or her estate might be responsible and shall Indemnify and save Wife harmless
from any and all claims or demands made against her by reason of debts or obligations
Incurred by him.
17. WAIVERS OF ClAiMS AGAIN.S.LESTATES.
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 marital
relatlonshlp,lncludlng without limitation, dower, curtsy, statutory allowance, widow's
allowance, right to take In Intestacy, right to take against the Will of the other, and
right to act as administrator or executor of the other's estate, and each will, to the
request of the other, exeoute, 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,
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18. BEP.RESENTATION.
It Is recognized by the parties hereto that Rohert A. Horper Is represented by,
John J. Connelly, Jr., Esqulr~, and Pamela A. Hoprer Is rerresented hy Ann V. Levin,
Esquire, It Is fully understood and agreed that hy the signing of this Agreement, each
party understands the legal Impact of thiR Agreement and further acknowledges that
the Agreement Is fair and reasonable and each rarty Intends to be legally bound by the
terms hereof.
19. Y.Ql,UNTARY EKEC.UTION.
The provisions of th:J Agreement are fully understood by both parties and each
party acknowledges that this Agreement Is fair and equitable, that It Is being entered
Into voluntarily and that It Is not the result of any dllress or undue Influence,
20, E.NIl!1E AGREEMENT.
This Agreement contains the entke understanding of the parties and there are
no representations, warranties, covenants or undertakings other than thosa expressly
set forth herein.
21. PRIOR..A.GBEE.MENT.
It Is understood and agreed that any and all property settlement agreements
which mayor have been executed prior to the date and tlmo of this AQreement are
null and void and of no effect.
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22, MODIFICAtJOH.Al'J1LWAlYfB.
Any modification or waiver of any prOVision of this Agreement shal,' be effective
only If made In writing and exacuted Wllh the same formality as this Agreement. The
failure of either party to Insist lIpon strict performance of any of the provisions of thlll
' Agraement shall not be construed 89 a waiver of any Subsequent default of the same
or similar nature.
23. GOVERNIN.GJ.AW.
This Agreement shall be governed by and shall be construed In accordance with
the laws of the Commonwealth of Pel1nsylvanla.
24. INDePENDENT mABAn1.COVENANIS.
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.
25, VOID CLAUSI:.s..
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 a/l other
respects this Agreement shall be valid and continue in full force, effect and operation,
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YOU Aft. HllIle,V "OTl".O T9 ""140 TO
THIl IfrIl(lLO.ID WITHIN
fWt:NTV 1101 OA'I" 0' 1.'Wler, MIIIIIIO' 0"
A DI'AUI.T JUDO~,HT MAY IlIINn"lEb
AOAINIT vou,
LAW OPPICII
lAMES, SMITH, DURKIN & CONNELLY, LLP
P. 0. BOX 6~
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ImRSllR", 1'llNNSYI.VANIA 110]),11610
Al'fOJlNIlY
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WI .llElllltl"CIRTI'V 1'''AT THI Wr1tllN 'I
A Tr.1J1 ANf) COAII.er co.." 0' THI
ORlotNAl '-lllO 11'4 THIS ActiON,
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""OftHllY
PAMELA A, HOPPER,
Plnintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV ANIA
V.
NO. 98 ,." 2353 CIVIL TERM
ROBERT A. HOPPER,
Defcndunt
: CIVIL ACTION. LA W
: IN DIVORCE
PRAECIP/<; TO TRANSMIT RECORD
To. the Pro.tho.notary:
Transmit the reco.rd. together with thc following info.rmation, to the Court fo.r entry of a
Divo.rce Decree:
1. Ground fo.r divorcc: irretrievablc breakdown undcr Section ( ) 3301(c) (X)
3301(d) o.fthe Divo.rce Co.de,
2. Date and manncr of service o.fthe Complaint: Certilicate o.fService tiled May 5,
1998.
3. Complete eithcr paragraph (a) 01' (b).
(a) Date o.f executio.n of the Affidavit of Consent and Wnlver o.fCo.unseling
required by Sectio.n 3301 (c) of the Divorce Co.de: by Plaintiff:
(b) (1) Date o.fexecution o.fthc Defendant's Affidavit required by Section 3301(d)
of the Dlvo.rce Code: March 8, 2001.
(2) Date of service of the PlaintifPs Affidavit upon the Defendant: March 10,
20ll!.
4. Related claims pending: All claims of reco.rd have been resolved and settled pursuant to.
a Property Settlement Agreement dated October 6. 1998.
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PAMELA A. HOPPER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO,
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ROBERT A. HOPPER,
DEFENDANT
CIVIL ACTION - DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HA VF~ BF~EN SUED IN COURT. If you wish (0 defcnd against the claims sct forth
in thc following pagcs, you must takc prompt action. You arc warned that if you fail to do so, the
case may procecd without you and a decree of divorcc or annulmcnt may be entered against you for
any other claim or relief rcquestcd in these pupcrs by thc Plaintiff. You may lose money or property
or other rights important to you, including custody or visitution of your children.
When the ground for thc divorce is indignities or irretrievable breakdown of the marriage, you
may requcst marriagc counscling. A list of nmrriagc connselors is available in the Office of the
Prothonotury. Cumberland County Courthousc, Carlislc, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR I~XPENSES 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
;'101' HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICF; SET FORTH BELOW TO F'IND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VF;NUE
CARLISLE, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The COllrt of Common Pleas of Cumbcrland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about acccssible facilities and reasonable
accommodations available to disabled Individuals having business before the Court, please contact
our officc. All arrangements must bc madc at Icast 72 hours prior to any hearing of business before
the Court.
County. Pcnnsylvnnin.
5, There have been no prior actions of' divorce or f'or unnulment between the parties.
6, The marriage is Irretrievably broken.
7, Plnintif'f has been udvised that counscling is availuble and thut Pluintiff'muy have the right
to request thutlhe Court require the parties to participate in counseling.
8. Plaintiff avers that there arc children of the purties under the age of 18. namely:
Andrea Lee Hopper, date of birth, July 28, 1986.
WHEREFORE, Plaintiff requests the COlll't to enter u decree of divorce.
COIJNT II
DIVORCE UNDlm 330lia)(6) OF' THE DIVORCE CODE
9. Plaintiff'repeats and reullegcs the nVCl'll1ents of paragraphs I through 8 which are
incorporated by reference herein.
10. Defendant has nf'fered such indignities to Plaintiff. the innocent and injured spouse, as to
render her condition intolerablc and Iif'e blll'densol11e.
WHEREFORE, Plaintiff requcsts the Court to enter a Decrec in Divorce pursuant to Section
3301(a)(6) of the Divorce Code.
COUNT II!
EQUITABLE DISTRIBUTION
11. Plaintiff repeats and realleges the averments of paragraphs I through 10 which are
incorporated by rcferencc herein,
12. Plaintiff and Defendant possess various items of' both rellland personnlmarital property
which is subject 10 equitable distribution by this Court.
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PAMELA A. HOPPER,
PlubltilT
IN TIlE COURT or COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV ANIA
v.
: NO. 98- 2353 CIVIL
ROBERT A. HOPPER,
Defendarlt
CIVIL ACTION ... LA W
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF' CONSENT
AND W AIV.:R OF COUNSELlNQ
I. A Complaint in Divorce under Section 330](e) of the Divorce Code was filed on
April 27, 1998, and served on May 5, 1998.
2. The marriage of the Plainti ff and Defendant is irretrievably broken, and ninety days
have elapsed Irom the date of both the filing and service of the Complaint.
3, I consent to the entry of a final decree of divorce after service of Notice of Intention
to request entry of the Decree.
4, I have belJII advised of the availability of marriage counseling, and understand thut I
may request that the Court require that my spouse and I pm1ieipate in counseling. I further
understand that the C01ll1 maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. 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 thc
COlll1.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements heroin arc made su~iect to the penalties of 18 Pa. C.S.A, Section 4904, relating to
unswol'l1 falsification to authorities.
Date: I (J 7/20)(
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PAMELA A. HOPPER,
Plnintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV ANIA
v.
: NO. 98 2353 CIVIL
ROBERT A. HOPPER,
Defendnnt
: CIVIL ACTION '" LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO..RE.QlJES'f ENTRY OF A DIVORCE
DE-eREI'; UNDER ~3301(c) OF TWUUVORCE com:
I. I consent to the entry of a final Dccree of Divorce without notice.
2. I understand that I may lose rights eonceming alimony. division of property,
lawyer's fces or expcnscs If I do not claim them before a divorcc is grunted.
3. I understand that I will not hc divorced until a Divorcc Decree is entered by the
Court and that a copy of thc Decree will he sent to me immediately after it is tiled with the
Prothonotary.
I vcrify that the statcments made in this Affidavit arc true and correct. I undcrstand that
false statements hcrcin arc madc subject to thc penalties of 18 Pa. C.S.A. Scction 4904, rclatlng to
unsworn falsi fication to authorities.
Date: I' I1!Z{t)1
<)
i!I1dl :/ < ,fI:
fmela A. Hoppel', Plainti
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you A"S HI""" NOTI,lrO TO ~LlAD TO
'tHE ClNcLO.IO , wITHIN
fWJNfV 1101 DA'tI 0' ft'..VICltflfllIO'O"
I. UI'AULT JUDOMfNT);fAY .. ."'I"I"D
AGAINe' YOU.
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LAW OPPIfIl
JAMES, SMITH, DURKIN & CONNELLY, LLP
.
I', 0. BOX 611
HI!RSHny. PIINNSYI.VAN'A IlIlH~~,lO
WI HUll., C:'''71'Y THAT THIINlrtllN II
" 'ltUI IINO CQ""l;c'r COllY 0' THI
, O"IClINA~L "lln IN 'HI I ACTION,
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PAMELA A. HOPPER,
Plaintiff
v.
IIN TilE COURT m' COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 98 - 2353 CIVIL
ROBERT A. HOPPER,
Defendant
: CIVIL ACTION. LAW
: IN DIVORCE
~IVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER ~330I(c) OF THE DIVORCE CODE
I, I consent to the entry of a final Decfee of Divorce without notice,
2. I understand that I may lose rights conceming alimony, division of property,
lawyer's fees Of expenses if I do not claim them before a divorce Is granted.
3. I understand thaI I will not be divofced until a Divorce Decfee is entefed by the
COllrt 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 hefein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to
unsworn titlsification to authorities.
Date: 01- / '7- () I
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JAMBS, SMITH, DURKIN & CONNBLLY, LLI'
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PAMELA A. HOPPER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
v.
: NO. 98 - 2353 CIVIL
ROBERT A. HOPPER.
Defendant
: CIVIL ACTION - LA W
: IN DIVORCE
PRAECIPE TO ENTER SOCIAL SECURITY NUMBER!l
TO THE PROTHONOTARY:
Plense enter the following social security numbers in the above-captioned divorce action:
Pamela A. Hopper --, 183-56-4400
Robert A. Hopper - 193-38-2386
Date:.iLL::.L 7 - 0 I
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PAMELA A. HOPPER,
PlaintilT
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.98 2353 CIVIL TERM
ROBERT A. HOPPER,
Defondunl
: CIVIL ACTION - LA W
: IN DIVORCE
AEI!lIM.Y.IT 01<' SERVICE
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF DAUPHIN
AND NOW. this 5dL day Of_~
, 200 I, personally appeared before
me, u Notary Public in and for the State and County aforementioned, JohnJ. Connelly, Jr., Esquire,
who, being duly sworn according to law, deposes and says that a copy of the Defendant's Affidavit
under Section 3301 (d). Notice of Intention to Request Entry of Divorce Decree, and Plaintiffs
Counter-Affidavit Under Section 3301 (d) was sel'!ed on the Plaintiff, Pamela A. Hopper, on
March 10,2001 by certified mail number 7099 3400 0009 29161004, as evidenced by the return
receipt card attached hereto and made a part hereof.
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Sworn to and subscribed
before me~U
dayof ( ~~,2001.
Cb!lu."A1J'~
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County, pennsylvnnlu.
S. There hnve becn no prior uetions of divorce or for lInnulment between tho purties.
6. The IllnlTiage is irrctricvlIbly broken.
7. Plaintiff has been advised that counseling is availuble and thut Plulntlff muy huve tho right
to requost thut the Court require the parties to purticipute in counseling.
8, Plnintiff avers that there arc chlldrcn of the parties under the uge of 18, numely:
Andrea Lee Hopper, dutc of birth, July 28, 1986,
WHEREFORE, Pluintiff requests the ceurt to enter a decree of divorce.
COUNT"
DIVORCE"UNDER 3301(8)(6) OF THE DIVORCE CODE
9. Plaintiff repeats and rea lieges the averments of paragraphs 1 through 8 which are
incorporated by reference herein,
10. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to
render her condition intolerable and life burdensome,
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section
3301 (a)(6) of the Divorce Code.
COUN,.T III
EOUlTABLE DISTRIBUTION
11. Plaintiff repeats and realleges the averments of paragraphs 1 through 10 which are
incorporated by reference herein.
12. Pluintiff and Defendant possess various Items of both reat! and personal marital properly
which is subject to equitable distribution by this Court.
- 2 -
WIIEREl101m, Plnintiff requests this Court to equitnbly distribute thcmnritnl properly aftel'
nn inventory nnd npprnlselllent hilS been filed by the pnrties.
COUNT IV
ALIMONY PENI>ENTl~ LIT":. COUNSEL FEES. COSTS ANI>
EXPENSES VNDEIl. SECTION 3702
13. Plnintiff repents and rea lieges the averments of paragrnphs 1 through 12 which are
incorporated by reference herein.
14. Plaintiff has no adequate means of support for herself during the course of this litigation,
15, Plaintiff does not have sufficient funds to pay counsel fees, costs or expenses incidental
to this action.
16. Plaintiff has no health insurance other than that presently available to her through
Defendant's employment.
WHEREFORE, Plaintiff requests the Court to award her alimony pendente lite, counsel fees,
costs and expenses,
!;OUNT V
ALIMONY U~I>ER SECT/ON 3701 OF THE DIVORCE GQ!!E
17. Plaintiff repeats and rea lieges the averments of paragraphs I through 16 which lire
incorporated by reference herein.
18. Plaintiff requires suppol1 to adequately maintain herself In accordance with the standard
of living established during the marriage.
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S. R_lved By: (Print N.ma)
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
PAMELA A. HOPPER ) Docket Numher 98-2353 CV
Plalnliff )
vs. ) PACSES Cllse Numher 065100104
ROBERT A, HOPPER )
Defendant ) Other Slate ID Numher D-27539
ORDER
AND NOW, to wit on this
9TH DAY OF JULY, 1998
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify Of' QU Other
DEMAND FOR APt HEARING
filed on APRIL 27, 1998
in the above captioned
matter is dismissed witholll prejudice due to:
PLAINTIFF WITHDRAWING HER DEMAND FOR ALIMONY PENDENTE LITE CONFERENCE/HEARING.
o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner, if filed within one year from date hereof.
BY THE COURT:
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t.n.
O'
ee l defendant and plaIntHf
eel Ann LevIn, Esq.
cc: Juhn J. Cvnnel;ly, Jr., Esq.
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Edward E. GuIdo,
DRO: R.J, Sha1day
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Service Type M
Fnrlll OE-S06
Worker ID 21005
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