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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
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DANIEL C. MAHONEY
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VERSUS
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KIM ANN MAHONEY
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AND NOW,
DECREED THAT
AND
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PENNA.
Plaintiff
No. 2000-5305 Civil Term
IN DIVORCE
Defendant
DECREE IN
DIVORCE
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, J.OO~IT IS ORDERED AND
, PLAINTIFF,
KIM ANN MAHONEY
, 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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NONE.
The terms of the Marital Settlement Agreement dated
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September 28, 2000 are incorporated but not merged into this
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Decree in Divorce.
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~ ROTHONOTARY
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Div Comp
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September 19, 2000
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DANIEL C, MAHONEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 2000. 5305 CIVIL TERM
IN DIVORCE
vs.
KIM ANN MAHONEY,
Defendant
MARITAL SETTLEMENT AGREEMENT
THIS Agreement made this
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Market Street, Camp Hill,
, 2000 by and
between KIM ANN MAHONEY, of 2609
Pennsylvania, hereinafter
referred to as WIFE, and DANIEL C. MAHONEY, of 31 High Street, Boiling Springs, Pennsylvania,
hereinafter referred to as HUSBAND,
WITNESSETH:
WHEREAS, the parties hereto are HUSBAND and wife, having been joined in marriage on
May 14, 1988, in Carlisle, Pennsylvania; and
WHEREAS, a Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County, Pennsylvania, to No. 2000-5305, Civil Term; and
WHEREAS, 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, the
settling of all matters between them relating to the ownership of real and personal property, claims
for spousal support, alimony, alimony pendente lite, counsel fees and costs, and in general, the
settling of any and all claims and possible claims against the other or against their respective
estates,
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Div Camp
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September 19, 2000
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NOW, THEREFORE, in consideration of these considerations, and the mutual promises and
undertakings hereinafter set forth, and for other good and valuable consideration, receipt and
sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE,
each intending to be legally bound, hereby covenant and agree as follows:
1. Advice of Counsel: The parties hereto acknowledge that each has been notified of
his or her right to consult with counsel of his or her choice, and have been provided a copy of this
agreement with which to consult with counsel. HUSBAND is represented by Carol J. Lindsay,
Esquire, and WIFE, has been advised that she may be represented by counsel of her choice. Each
party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable,
and that it is being entered into freely and voluntarily, after having received such advice and with
such knowledge as each has sought from counsel, and that execution of this agreement is not the
result of any duress or undue influence, and that it is not the result of any improper or illegal
agreement or agreements.
2. Divorce: The parties agree to the entry of a Decree in Divorce. The parties will
execute, 90 days after the service of the Complaint in Divorce, Affidavits of Consent and Waivers of
Notice under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce.
3. Personal Property: The parties acknowledge that they have equitably and
satisfactorily divided all of their personal property, and that all personal property shall be the sole
and individual property of the party in whose possession it is as of the date of this agreement.
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Div Camp
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Septamber 19, 2000
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WIFE will retain the 1994 Honda Accord. Within sixty (60) days of the sale of the
marital residence, as more fully described below, WIFE will pay the car loan encumbering the 1994
Honda Accord to AmeriChoice Federal Credit Union, or, in the alternative, WIFE will refinance the
loan so that HUSBAND is no longer liable thereon. Upon relief of liability for the AmeriChoice car
loan, HUSBAND will execute any and all documents necessary to transfer to WIFE all his right, title
and interest in the 1994 Honda Accord.
WIFE will retain her Morrison Knuteson 401 (k) Plan in the amount of approximately
$21,000.00 and her IRA with Solomon Smith Barney in the amount of approximately $18,000.00.
HUSBAND will retain his pension with Land 0 Lakes and his Land 0 Lakes 401 (k)
Plan in the amount of approximately $16,000.00
The parties hereby waive any interest they have in the retirement benefits of the other.
HUSBAND will retain the 1991 Toyota Camry and WIFE will execute and all
documents required by HUSBAND to release her interest in the Camry.
Each party will retain any amounts in his or her own checking and savings accounts.
4. Real Property: The parties are owners of a home at 31 High Street, Boiling Springs,
Pennsylvania. The marital home is listed for sale. The parties will accept any reasonable offer to
purchase the home. Upon settlement of the marital home, after payment of the costs of sale and
the liens encumbering the home, the parties will pay from the proceeds of sale the following
obligations: 1) The debt consolidation loan to AmeriChoice in the amount of approximately
$6,500.00; 2) The joint Visa account; 3) An oil bill to Shipley in the amount of $293.00; 4) An
outstanding obligation to Tuckey in the amount of approximately $100.00. In the event that
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Div Camp
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September 19, 2000
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HUSBAND is required to pay the Shipley's bill in order to obtain oil for the marital home pending
sale, HUSBAND will be reimbursed in the amount of $293.00 from the proceeds of sale.
5. Alimony: The parties waive any claim that they may have one against the other for
alimony, alimony pendente lite or spousal support. The parties acknowledge that each has sufficient
assets with which to maintain themselves after divorce.
6. Marital Debt: The parties have, in their own names, certain credit card accounts
which may include some marital debt. Except for those items of marital property which will be paid
from the proceeds of sale of the marital home, each party will be responsible for the debt on the
credit card accounts, or other debts, in his or her name, and for any other debt incurred by that
party. Each party will incur no debt for which the other may be liable, and will indemnify and hold the
other harmless for any debt so incurred.
7. Exchange of Information: The parties have requested from each other and received
any information regarding their assets, liabilities, income and expenses which the party requires
prior to entering into the terms of this Agreement. The parties acknowledge that the terms of this
Agreement are fair and equitable and constitute an equitable distribution of marital property and
debt, taking into account all of the relevant factors set out in Section 3502 of the Divorce Code, 23
Pa. C.s.s3502 including the length of the marriage; any prior marriage of the parties; the age,
health, station, amounts and sources of income, vocational skills, employability, estate, liabilities and
needs of each of the parties; the contribution by each party to the education, training or increased
earning power of the other; the opportunity of each party for future acquisitions of capital assets and
income; the sources of income of both parties, including but not limited to, medical, retirement,
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Div Camp
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September 19, 2000
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insurance or other benefits; the contribution or dissipation of each party in the acquisition,
preservation, depreciation, or appreciate of the marital property, including the contribution of a party
as homemaker; the value of the property set apart to each party; the standard of living of the parties
during the marriage; the economic circumstances of each party including federal, state and local tax
ramifications at the time of the division of the property, and whether the party will be serving as
custodian of any dependent minor children.
8. Modification: No modification, rescission, or amendment of this agreement shall be
effective unless in writing signed by each of the parties hereto.
9. Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania.
10. Agreement Binding on Parties and Heirs: This agreement, except as otherwise
expressly provided herein, shall bind the parties hereto, and their respective heirs, executors,
administrators, legal representatives, assigns and successors in any interest of the parties.
11. Agreement Not to be Merged: This agreement Shall be incorporated into the final
decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be
merged into said decree. The parties shall have the right to enforce this agreement under the
Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity
under this agreement as an independent contract. Such remedies in law or equity are specifically
not waived or released.
12. Documents: The parties hereto agree that they will execute and deliver one to the
other any documents necessary to give effect to the terms of this Agreement.
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Div Comp
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September 19, 2000
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13. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of such other, for all time to come,
and for all purposes whatsoever, of and from any and all rights, titles, 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 she or he now
has or at any time hereafter may have against such 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 widows' or widowers'
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 Pennsylvania, any other State, or any other Country, or any rights which either spouse may
have, or at any time hereafter have, for past, present or future support or maintenance, alimony,
alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital
relation or otherwise, except and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the breach of any term
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 rights and agreements and obligations of whatsoever nature arising or which may arise
under this Agreement, or for the breach of any term thereof.
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Div Comp
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September 19, 2000
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14. BREACH: In the event that either party breaches any provision of this Agreement, he
or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but
not limited to, court costs and counsel fees of the other party. In the event of breach, the other party
shall have the right, at his or her election, to sue for damages for such breach or to seek such other
and additional remedies as may be available to him or her.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
Witness:
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Kim Ann. Mahoney
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Daniel C. Mahone <.
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franciscus proof of service February 5, 2001
DANIEL C. MAHONEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 - 5305 CIVIL TERM
vs.
KIM ANN MAHONEY,
Defendant
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. Ground for divorce: irretrievable breakdown under Section 3301 (c) 3201 (d)(1) of the Divorce
Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant
September 28, 2000.
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 the Plaintiff January 15, 2001; by the Defendant January
15,2001.
(b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of
the Divorce Code:
(2) Date of service of the Plaintiff's affidavit upon the Defendant: _
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: January 15, 2001.
(b)
Date Plaintiff's Waiver
Prothonotary: February
of Notice in 3301 (c) Divorce was filed with the
2001
Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary:
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DANIEL C. MAHONEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 - 530S"' CIVIL TERM
IN DIVORCE
VS.
KIM ANN MAHONEY,
Defendant
NOTICE
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 at
the Cumberland County Court House, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR
EXPENSES BEFORE A DECREE OF 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, PENNSYLVANIA 17013
(717) 249-3166
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
arol J i
ID#
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date:r1 27) 2/#[)
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Div Camp
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July 27,2000
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DANIEL C. MAHONEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 - S'81J5' CIVIL TERM
IN DIVORCE
V5.
KIM ANN MAHONEY,
Defendant
COMPLAINT
DANIEL C. MAHONEY, Plaintiff, by his attomeys, FLOWER, FLOWER & LINDSAY, P"C.,
respectfUlly represents:
1. The Plaintiff is DANIEL C. MAHONEY, who currently resides at 31 High Street, Boiling
Springs, Cumberland County, Pennsylvania, where he has resided since 1994.
2. The Defendant is KIM ANN MAHONEY, who currently resides at 214 Youngs Church
Road, Shermans Dale, Perry County, Pennsylvania, where she has resided since July 9, 2000.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 14, 1988, at Carlisle, Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties in
this or in any other jurisdiction.
6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code.
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July 27, 2000
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7. Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate in marriage counseling, and does not request
counseling.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
D"",'~1<J 7-7, )-P1i1/
Carol J. C' dsay, Esquire
ID # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~
4904, relating to unsworn falsification to authorities.
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26 W. IDgh street
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Nov~ber 2, 2000
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Aff of con
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DANIEL C. MAHONEY,
PI ai ntiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
V5.
CIVIL ACTION - LAW
NO. 2000 - 5305 CIVIL TERM
KIM ANN MAHONEY,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
2000"
1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on July 28,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa"C"S" 4904 relating to unsworn falsification to authorities"
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(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 riQhts 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 to the best of my
knowledge, information and belief I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 4904 relatin 0 unsworn falsification to authorities.
Date:
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Cadlsle, PA
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November 2, 2000
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DANIEL C. MAHONEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V5.
CIVIL ACTION - LAW
NO. 2000 - 5305 CIVIL TERM
KIM ANN MAHONEY,
Defendant
IN DIVORCE
2000.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on July 28,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa"C.S" 4904 relating to unsworn falsification to authorities.
~~~~a~ndant
Date: 'Ol--ts""- 0 I
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
s3301(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 to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
K~~ t'~~~endant
Date: 0/-15-0/
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DANIEL C. MAHONEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 - S-3 D'S CIVIL TERM
IN DIVORCE
VS.
KIM ANN MAHONEY,
Defendant
ACCEPTANCE OF SERVICE
I, KIM ANN MAHONEY, hereby accept service of the Complaint in Divorce filed in the
above captioned case on behalf of DANIEL C. MAHONEY, Defendant, this A jHt day of
~~ ,2000.
t< 1m o.n" <<\~
Kim Ann Mahoney
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