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HomeMy WebLinkAbout03-0857II PETER P. KASSAB, Plaintiff VS. PAMELA J. SHIREY , Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 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 foregoing 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 in 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 at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 PETER P. KASSAB, ) Plaintiff ) ) ) PAMELA J. SHIREY , ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE .NOTICE OF AVAILABILITY OF COUNSELIN(" TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PETER P. KASSAB, Plaintiff VS, PAMELA J. SHIREY , Defendant ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE .,COMPLAINT IN DIVORCF AND NOW comes the above-named Plaintiff, PETER P. KASSAB, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is PETER P. KASSAB, an adult individual who currently resides at 14 Stone Spring Lane in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is PAMELA J. SHIREY, an adult individual who currently resides 14 Stone Spring Lane in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 1 February 2001 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -- IRRETRIEVABLE BREAKDOWf' $. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). ~PETER P. KASSAB PETER P. KASSAB, Plaintiff VS. PAMELA J. SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE PLAINTIFF'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Plaintiff, by his attorney, Samuel L. Andes, and makes the following Petition for Economic Relief: COUNT I - EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff pray this Honorable Court:, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. I verify that the statements made in this Petition for Economic Relief are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). P. KASSAB Sa'h~u~-L: And~)' ' " Attorney for Plaintiff Supreme Court ID 17225 ,525 North 1 2th Street Lemoyne, PA 17043 (717) 761-5361 PETER P. KASSAB, ) Plaintiff ) ) ) vs. ) ) ) PAMELA J. SHIREY, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. 25 March 2003 Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 PETER P. KASSAB, --LA J. SHIREY, : IN THE COURT : CUMBERLAND (: Plaintiff : : NO. 03- : : CIVIL : : Defendant : ACCEPTANCE OF SERVICE I, Melissa Peel Greevy, Esquire, attorney for Defendant, Pamela J. Shire acknowledge receipt of the Complaint in Divorce filed on February 26, 2003 captioned divorce action. I oertify that I am authorized to accept service on behal OF COMMON PLEAS OF :OUNTY, PENNSYLVANIA 857 CIVIL TERM ACTION - LAW DIVORCE t, hereby accept service and )y the Plaintiff in the above- ~of Defendant. Date: '~~~ ,2005 :211519 B'~.' ....fica P. Greevy, Esquire Attorney I.D. # 7795:) Johnson Duffle Ste¥ 301 Market Street P.O. Box 109 Lemoyne PA 1704,! Attorneys for Defen~lant tart & Weidner Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendant/Petitioner PETER P. KASSAB, PAMELA J. SHIREY, Plaintiff/Respondent Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-857 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCi- PURSUANT TO 23 Pa. C.S. § 3502 (c) The Petitioner, Pamela J. Shirey, WIFE, by and through her counsel, Johnson, Duffle, Stewart & Weidner, presents this Petition for Exclusive Possession of the Marital Residence and in support thereof avers as follows: 1. The Petitioner is Pamela J. Shirey, WIFE, who currently resides at 14 Stone Spring Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The HUSBAND is Peter P. Kassab, HUSBAND, who currently resides at 14 Stone Spring Lane, Camp Hill, Cumberland County, Pennsylvania 17011, which is the marital residence. 3. The parties were married on February 1, 2001 in Cumberland County, Pennsylvania and HUSBAND filed a Divorce Complaint on or about February 26, 2003. 4. There are no children born to the parties of this marriage. 5. WIFE has three (3) children to a previous marriage: RYAN McANINCH, age 16, born on June 12, 1986; DYLAN McANINCH, age 13, born on July 4, 1989; and ELISE McANINCH, age 9, born on June 4, 1993. 6. The marital home, located at 14 Stone Sprin9 Lane, Camp Hill, Cumberland County, Pennsylvania, is titled in joint name. 7. The parties purchased the property together before the marriage. 8. Through counsel, HUSBAND has indicated his pre'terence that the Petitioner either refinance the marital home in her name or promptly list it for sale. 9. Petitioner has applied to refinance the home in her name alone in anticipation of equitable distribution in the parties' divorce. 10. At no time has the HUSBAND indicated an interest in receiving the marital home as part of the equitable distribution plan in this divorce. 11. HUSBAND has consistently indicated a desire to reach a prompt settlement so that he can vacate the marital home. 12. HUSBAND refuses to leave the marital residence until the parties have reached a full settlement of all economic issues in the case. 13. Counsel for the parties have engaged in voluntary discovery to facilitate settlement discussions and settlement dialogue has begun. 14. WIFE has received approval and has been qualified to refinance the home in her name alone. 15. WIFE'S counsel sent a draft Stipulation for Exclusive Possession to counsel for HUSBAND on May 2, 2003, but has received no response. 16. Having voluntarily vacated the bedroom several weeks ago, HUSBAND informed WIFE on May 4, 2003 that he intends to move back into the bedroom by' May 9, 2003. HUSBAND informed WIFE that if she does not remove her belongings, he will move them oul'.. 17. The significant tension that exists between the parties is having a negative impact on the children as they complete the final marking period of the 2002-2003 academic year. 18. HUSBAND is employed full time with IBM, having produced a 2002 gross income of $147,439, is well able to afford separate dwelling. 19. WIFE believes, and therefore avers, that granting WIFE exclusive right to reside in the marital residence with her children will effectuate the purposes of the Divorce Code as set forth in § 3102(a), including the goal of mitigating the harm to spouses and their chil,dren which is being caused by dissolution of the marriage. WHEREFORE, WIFE respectfully requests this Court enter an Order awarding WIFE exclusive 3n of the marital residence, require HUSBAND to leave the premises within 14 days, and such other and further relief as this Court in equity deems just. Date: :213105 JOHNSO~ STEWART & WEIDNER I~'~lissa'l:~'el Greevy Attorney I.D. No. 77950 VERIFICATION I, Pamela J. Shirey, do verify that the statements made in the foregoing Petition for Exclusive Possession are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: Par el J. Shir _ CERTIFICATE OF SERVICF AND NOW, this day of May, 2003, the undersigned does hereby certify that she did this date serve a copy of the foregoing Petition for Exclusive Possession of the Marital Residence upon the Plaintiff's counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043 JOHNS~'~FIE, STEWART & WEIDNER Melissa Peel Greevy HAY 1 2 2003 PETER P. KASSAB, PAMELA J. SHIREY, Plaintiff/Respondent Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-857 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE RULE AND NOW, this ~'~'('f~day of ~~r~, 2oo3, upon consideration of the attached Petition for Exclusive Possession of the Marital Residence, a Rule is granted upon the Respondent, Peter P. Kassab, to show cause why the relief requested should not be granted. Rule returnable for hea.~, the ~1 day of /~"~ ,2003, at /~g) AJ __.M., in Courtroom No. ,~ , Cumberland County, Pennsylvania. Dist: ..~muelPeelL' AndeS,Greevy,ESquire,Esquire,POPO BOXBox 168,109,Lem°yne'Lemoyne,PA PA 17043 ~'~~ ~y~ ~ ~ ~~ ~/lelissa 17043 ,,~' PETER P. KASSAB, Plaintiff PAMELA J. SHIREY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-0857 CIVIL TERM : : CIVIL ACTION - LAW : 'IN DIVORCE QRDER OF COURT AND NOW, this 28th day of May, 2003, the attached stipulation is adopted as an order of this Court and shall be incorporated, but not merged, into the final divorce · the~ decree By Edward E. Guido, J. Samuel L. Andes, Esquire For the Plaintiff Melissa P. Greevy, Esquire For the Defendant {_,,.03-03 srs PETER P. KASSAB, Plaintiff Vo PAMELA J. SHIREY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-0857 CIVIL TERM : : CIVIL.ACTiON - LAW. : IN DIVORCE STIPULATION AND NOW, this 28th day of May, 2003, the parties have agreed to resolve all of the economic claims which have been raised or could have been raised in their divorce action on the following terms: 1. Peter P. Kassab, hereinafter referred to as Husband, shall vacate the marital residence no later than June 20, 2003. Until that time, both parties and their children will occupy the property. Mr. Kassab and his son will continue to occupy the bedrooms they currently occupy, and Ms. Shirey and her children will occupy the remaining three bedrooms as they see fit. The parties will share the common areas in the house, and will do so respectfully, and in doing so will observe the other party's rights and the rights of the children so that there will be no disputes and confrontations. Mr. Kassab will be out of the house this weekend from 5:00 p.m. on Friday the 30th of May until 4:00 p.m. on Sunday the 1st of June so that Ms. Shirey can celebrate a family occasion at the house without him or his family being present. 2. When Mr. Kassab vacates the property, he will take with him the following items of personal property: the mattress for the sofa bed, the beige rug in the office, the office chair, two CD burners, one laptop computer, the digital camera, the internet equipment which includes a router and other items, the love seat from the living room, the two end tables in the living room, the coffee table in the living room, and the sideboard in the living room, the bed and dresser and one end table from the bedroom he now occupies, and the carpet cleaner. In addition, he will remove and retain all of the items of furniture and tangible personal property which he brought to the home and which he owned prior to the marriage or which belong to his children. He shall leave in the house and Ms. Shirey shall retain the following items: two refrigerators, the washer, the dryer, the HP printer, the grill, the rectangular patio table and six chairs, the lawn mower, the chain saw, the armoire and one end table from the bedroom now occupied by Mr. Kassab, and the pool table. She will also retain those items of furnishings and tangible personal property that she brought to the home and owned prior to the marriage and such items that belong to her children. In addition, Wife shall retain the yellow Labrador retriever, Jessie, which will be her property hereafter. 3. Before Mr. Kassab moves from the house, he shall return and reinstall the latch and lock from the bedroom door. 4. All utilities for the home will be transferred to Wife's name as soon as possible after today's hearing. The parties will cooperate to make that change. Ms. Shirey shall be responsible to pay the utilities, mortgage and other expenses of the home after today, and Mr. Kassab will not be required to make any further contributions to those expenses. At the time that Mr. Kassab moves from the house, he shall return to Wife's attorney or his attorney shall return to Wife's attorney the knives which he had removed from the home and which belong to Wife or her children. At the same time, Wife, through her attorney, shall deliver to Husband's attorney a cash payment of $1,022.00. 5. The parties own jointly 22.468 shares of IBM stock, and they shall, as promptly after this morning as possible, transfer that stock to Husband's name alone. Both of them will execute the documents necessary to make that transfer no later than Friday, May 30, 2003. 6. As equitable distribution of the parties' marital assets, Husband shall retain his account at the AmeriChoice Credit Union, his stock in Prudential Financial Corporation, his account at Parker Hunter Investments, the increase in value of his IBM stock which occurred during the marriage, and the increase in value of his IBM 401(k) plan that occurred during the marriage. As equitable distribution of the marital property, Wife shall retain her account with AmeriChoice Credit Union and the increase in value in her 401(k) plan. 7. The parties will transfer the residence owned jointly by them at 14 Stone Spring Lane to Wife's name alone, and Husband shall waive and release any further claim to that property or interest in that property effective with the date of the delivery of the deed to Wife or her attorney. Husband shall deliver that deed or cause his attorney to deliver that deed at the time set by Wife for a settlement on new mortgage financing which Wife shall obtain to pay off and satisfy the existing lien or liens against the property so as to obtain Husband's unconditional release from those obligations. The parties will, by Monday, June 2, 2003, execute spousal waivers and other documents that may be reasonably required to facilitate that mortgage financing. Wife shall be responsible to pay all debts and expenses relating to the house from now until the date of that transfer, which the parties contemplate will be before the end of June of this year. 8. The parties own in their joint names an investment account with Parker Hunter which has been identified as Account Number 01015702/763097777CLKR. The parties shall make, execute, acknowledge and deliver all documents necessary to transfer that account to Husband's name alone no later than Monday, June 2, 2003. 9. Husband shall maintain the medical and dental insurance on Wife through his employer that exists today. If there is an expense for that, Husband shall document that expense to Wife and she shall reimburse him that expense. the end of June of this year, there shall be no further obligation by Husband to provide that insurance. 10. The parties enter into this agreement expecting that they will conclude a divorce by consent by the end of June or shortly thereafter. Accordingly, each of the parties having been made aware of their procedural and other rights under the Divorce Code of Pennsylvania, including the right to compel discovery and to have the Court distribute their marital assets and make other economic awards, hereby waive those rights. Each of the parties hereby specifically waives the right to have the Court make further equitable distribution of their marital property, to award spousal support, alimony pendente lite or alimony to either of them, or to award counsel fees or other After expenses. The parties agree that they will execute and deliver to Husband's attorney by the end of June, if not earlier, an affidavit of consent and a waiver of notice so those documents can be filed with the Court to conclude the divorce. PETER P. KASSAB, Plaintiff VS. PAMELA J. SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw all economic claims previously made in this matter by or on behalf of the Defendant, Pamela J. Shirey, specifically including her request for exclusive possession of the marital residence. Date: JOHI~ON DUfFlE STEWART & WEIDNER I Greevy Attorney for Defendal3.t/?,~..¢-~ Supreme Court ID # 301 Market Street Lemoyne, Pa 17043 (717) 761-4540 PETER P. KASSAB, Plaintiff VS, PAMELA J. SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 26 February 2003, was reinstated thereafter, and was served on 27 March 2003 upon Defendant. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. ~ consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming finai. I verify that the statements made in this Affidavit are true and correct and 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. 28 June 2003 PETER P. KASSAB PETER P. KASSAB, Plaintiff V$, PAMELA J. SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 26 February 2003, was reinstated thereafter, and was served on 27 March 2003 upon Defendant. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability., of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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. 28 June 2003 PETER P. KASSAB, Plaintiff VS, PAMELA J. SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODI' 1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 28 June 2003 PETER P. KASSAB PETER P. KASSAB, Plaintiff VS, PAMELA J. SHIREY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-857 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 {C} OF THE DIVORCE CODI 1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 28 June 2003 PAMELA J. ~l;ItEY ~ PETER P. KASSAB, 1~O-~2.- Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PAMELA J. SHIREY, 180-~o-60~ Defendant NO. 03-857 CIVIL TERM IN DIVORCE _PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce; Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceotance of Service filed by Plaintiff',-. counsel indicatinq service on or about 27 March 2003. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 28 June 2003 By Defendant: 28 June 2003 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 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: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 28 June 2003 and filed contemporaneously herewith, Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 28 June 2003 and filed contemporaneously herewith, Date: ~ Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .~_ PEN NA. PETER P. KASSAB~ Plaintiff VERSUS PAMELA J. SHIREY, Defendant NO. 03-857 CIVIL TERM AND NOW,. DECREED THAT aND DECREE IN DIVORCE , ~, IT IS ORDERED AND PETER P. KASSAB, PLAINTIFF, PAMELA J. SHIREY , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; none ATTEST: +~OTH O N OTA Ri'