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Home My WebLink About01-2092 FX 0-., !J,,_ ". . . ;I;:f.:f. '" '" '" "'''' . . . '" ",;I;;I;:f. "'''' '" '" . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . PENNA. . . . STA.TE OF . . Vincent E. Coller No. 01-2092 Civil Term . . . Plaintiff VERSUS PnnlA"R !=:mpp . . . . . nRfa-nnAnr . . . . . DECREE IN DIVORCE NOW~ ,~ . . ;t tt~~-SP: ,~ IS ORDERED AND ~ . AND . . DECREED THAT Vincent E. Coller , PLAINTIFF, . . . . AND Paula E. Smee , 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 ENTERr;:D; . . . . . . The parties' Separation and Property Settlement Aqreement . . dated April 9. 2002 is incorporated. but not merged, into this Decree. . . . .. . . J, . Otdk~ (' OTHONOTARY . .. . '" "',.,'" "'''' Of. Of. Of. '" '" ''''-',-1 f.",J_....., ,'C ",'t' .'" t., "1--- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' " . . . ,"; .k~~~~fi!iI!L;;E.~m""';liiid" ",,,-~, - '"'~r-i?lt~_~W~i\%~~lii!l'li1r~'.- ~_ilIlIllIiIill..1ii /t? /t- t7.;L /tJ A~ 0,;) ~ ~"-.J. ...;...... -~, - .. . ,'" ~.. M'~~~4~l /;~'~ $ ~~ .1..,".".-- , ",'" ~ ~ VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. . . : NO.OI- :l(j9~ CIVILTERM PAULA E. COLLER, Defendant . . : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VB 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, High and Hanover Streets, Carlisle, 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. IFYOUDONOT HA VB 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 '" - ~ ,,'--_O_"h_'~,_'_,'~"-"_o"___' "_,,-~. _'_-_~""_'_,,''''_' ,'~~f''']''"' ""--'".--_"'0" _r., ,< ",<~__~_ ~_ , "~ . =- NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas .demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo aI partir de la fecha de la demanda y la notificacion. Dsted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de au persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier quqa 0 a1ivio que es pedido en la peticion do demanda, Dsted puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGARTAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERlGDAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ",~-" " !f',~c:<q-_~o~'-'r;-:f',"~-~-,-,-",' -,' -",' ,_"..,..'~_?"~=," , nr""u" _,. ,~._,< ""0 .-.--~~,:" '-f~" -I' __,.~~_-_~~,_,,- . ~__,_ _",,_, .cO' - ~- -.-,.,--' '. VINCENT E. COLLER. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 0 I. .:Jo q.:L . CIVIL TERM PAULA E. COLLER. Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c).OR SECTION 3301(d) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Vincent E, Coller, by his attorney, Cara A. Boyanowski, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Vincent E. Coller, is an adult individual who resides at 272 W. Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013, 2. The Defendant, Paula E. Coller, is an adult individual who resides at 212 W, Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3, The Plaintiffhas been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4, ThePlaintitrand Defendant were married on August 14, 1993, in Carlisle, Cumberland County, Pennsylvania, 5. The Plaintiff and Defendant are both citizens of the United States of America. 6, There have been no prior actions in divorce between the parties. 7, The Plaintiff and Defendant are not members of the Armed Services of the United 5~",.,,,, '. '. '-'''''-~;'S'_'''''}_'::'_;'''_'."'_>~~'''L . _~=~...:'L ,'1' ,; ., I' ,_-,.",._<_" -'~',~- -,-~--, ,.",~,'",' ----~--~,,--,~ - -p~ ',,= "--.-- -'=-. - -.-,. ,-.. ~ . ~- ~ - ." States or any ofits allies. 8. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 9, The causes of action and sections of Divorce Code under which Plaintiff is proceeding are: A. Section 3301 ( c), The.marriage of the parties is irretrievably broken, After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken, The Plaintiff and Defendant separated on November 3,2000. WHEREFORE, the Plaintiff prays your Honorable Court to enter aD.ecree in Divorce from the bonds of matrimony. 0;"'," - .O"?iF'_~_7'~_'_: ;'\';"~""":<- ',. "" "r'~- ,_-,~,__"",'--' ,'; ". I'., ",'>-.--\'0;'<:'-'1', -/"C> i-~"-'- _ ,__, .~ __~-_ ,_ _,. '0,__",' ,_ - ,,', '.. _ ? "'" _ ,_ _,"" _~_ _', ~ ,_,_ ,,~_ _. . ~. I verilY that the statements made in this Complaint are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C,S,A. ~4904 relating to unsworn falsification to authorities. By: \~> Vincent . Coller, Plaintiff Date: 1- ~ _0 \ B: ara A Boyanows Attorney No. 68736 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff T~ . '_,,,."_,>^_",';"';',..,.;; " _'__;;_-'_C"_,",~__ - "'"'I','. , , _ c",= ,_. _"~__.. iI-' " DR#: VINCENT E. COLLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff! Respondent : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAULA E. COLLER, : NO. 01-2092 CNIL TERM Defendant/Petitioner : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE, INTERIM COUNSEL FEES AND EXPENSES AND NOW comes Petitioner, Paula E. Coller, by and through her counsel of records, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above named Defendant, Paula E. Coller, an adult individual currently residing in Carlisle, Cumberland County, Pennsylvania. but whose specific address is being withheld from these documents as Petitioner currently has a Protection from Abuse Order in effect against Respondent and does not wish to disclose her address. 2. Your Respondent is the above named Plaintiff, Vincent E. Coller, an adult individual currently residing at 272 West Ridge Street, Carlisle, Cumberland Connty, Pennsylvania. 3. Petitioner's date of birth is January 13, 1972, and her Social Security number is 178- 50-1404. 4. Respondent's date of birth is April 18, 1971, and his Social Security number is 176- 58-3422. ;m_","",_ .-- >"'__1-"F"," ".~ '" '1'","--' -,--'~ ~". - . 5. The divorce action filed to the above docketed number in the Court of Common Pleas of Cumberland County requests a divorce based upon Section 3301(c) of the Divorce Code of 1980 as amended. 6. Petitioner has employed counsel and will incur certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support herself, pay for attorney's fees, or pay for the costs and expenses associated with this action. 7. Respondent has substantial income and earning capacity, as well as assets, to support the Petitioner or to assist in supporting Petitioner, and to pay alimony pendente lite to Petitioner, as well as assist in paying her counsel fees, costs and expenses. 8, Petitioner previously filed a Complaint for Spousal Support, which is scheduled to be heard at the Cumberland County Domestic Relations office before Melissa Calvanelli, Hearing Officer, on April 30, 2001, at 10:30 a.m. WHEREFORE, Petitioner request you Honorable Court to enter an Order of Alimony Pendente Lite, Interim Counsel Fees, Costs and Expenses in this matter. Respectfully submitted, . riffie, Esquire tt ey for DefendantlPetitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ,.~,:'^ 'L:",S,,_'_,,_ ',;j,"",',"- .,e, '._",_~-~ ~o_ >',"--r"", ,_ .~_' ~ ,,-- VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: (It.J\7/ol , ) / '. iI. 9 /! / d. lli.d-e-A L (;tJ.LP- PAULA E. COLLER, Defendant/Petitioner ,,'-- ~ , -"c, , ,_~_ " 1','-" , I!-_ <'4 <".< -"., "" '-- ' ~ ~ ~,. l~l~t '-' .fillfun '_ ~~N .' g 0 0 - 'T\ :c;: .".. .--1 ~ '"0 OJ -0 "I ~ -':1 q;!t1l :;0 ~-:~~ J;- :TJ N tAC .n;:J ,!cC Ui ~;i~t 0:<2. ~O .." ~8 3 C)~ :-?:ffl - 0 ):>C ., .~'-l: Z c;.rl Jo: =< m ?Z '~-'. ,-~lIf"'~~,~,~~z~- -'~~~-~~~~~"_, -~!,~JC~ i'~ T",_~ " ~ ,. VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAULA E. COLLER, Defendant : NO. 01-2092 CIVIL TERM : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter hereby elects to retake and hereafter use her previous name of Paula E. Smee. ./--~) ( r-a H~4 f ~fJ ,Q1J1 Paula E. Coller /~ J ( ) ~~ r ()UPA (: \. rr(U~ Paula E. Smee COMMONWEALTH OF PENNSYLVANIA COUNTYOF CUv'V\bev(C(~ On this l.5~ day of f'/pn/ , 2001, before me, the undersigned officer, personally appeared Paula E. Coller, now known as Paula E. Smee, known to me (or satisfactory proven) to be the person whose name is subscribed to the within document and SS acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 1rttfA&1 ~ ,~Ukt~ ( t1 Notarial Seal Karisa J. Lehman, ~ PublIc CarII,1e 80m. CUnlbeIlarKI CountY My Commill,1on ExpIres Aug. 25, 2003 ",>',' ::,:f,? . t.' , .~ -' J''; ;~ -- . '"1 -' - ,~ ~ "'-7~~"-"- --- ~ . ~ ie, C' " '_ ,.~,."._.,.l",.".,. - ~ ,~ ':_1'~_"'" '"_d_;,~~~,,-at__r',',.,,"'-' "! ''1. ~. ~ "' ,- "'=, -,~-"-.,,~- .,~, "~' "~~ 1 @ 0 0 ." s::. ". .,-.J ?ltt:' .." ;:~ :JJ ~ ~] , 'IIJ :::0 ' "r- ~ :::1) N -"8 1>,- ., ~,~ (,("; ~~J'1 ~ .. ~o --.;:, ~o '"U ., ~. ~ ':5 ::D ~ ~2 3: .~ (') <:::. ZSm '" .r:: ~ j;! '.\) ...... ~ Ul ~ "N ....c" Ul "':K (<> ~Iffi~~~m~_ _ _,_~:_~~~,~""",tt:-_,_""O,.:I1!",!<O'- -,-7"'~~ ~,C,^ ~," : _ ',-c::, _; ,_ ,_' _ VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 01-2092 CIVIL TERM : IN DIVORCE PAULAE. SMEE, AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on April 9,2001, and served on April 24, 2001. 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ilpd 1<6', ~ Q~ t' ,J~ PAULA E, SMEE, Defendant -'. ,~~ '\ ..",.J '.."- ~f ~ l'ilZl. ,- 'T~'-" "0' 1 ~.- ~ ,- " ~ . "- J " - I If., Ij I' !'''- ~~-'" ,," . " >~. .'~~' ~- -" (") C} -..) ~~; I',,) -q ;;:::'" ,J ex -0 !Ii CT .::U Z Z ~.,. !",) -- (;) v' ~ ::< () :,'::: '-."' "Ti -- =c <.~. C' c) 5> i"',::. C,'l c- 5j :z: =< , (.) ::J:J -', I J_ ",l'I>~'~il!\l!I\'Ii1~~I_~Pl~lJlYi,E'!~'_r.;};J""if'''P;'''"'''I*',*l'l:'''''ffl~"i~1?J'4'JWI>"o/ffi:~~~JMI-"ll'l1i!W!I!'I;m;$k'\iIl<~1J'~~~~ VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAULA E. SMEE, Defendant : NO. 01-2092 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. 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! do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary , I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: .Q,pu g It, ;lOW nOJJJ~, e , JmtU PAULA E. SMEE, Defendant "-"~:J>" ,.,: ;. ,....', ,~, it:T, ,,_= ,_" _. ,_,~_ ""O'~~' ""H 1m I. ;_ '1 -, ' - ! -,- ~..., , _ ~ ~" _" ..ef.ll'JJI!< >- ~ I +, ^-'~~~~" ~.-.~~ ~~~.-.:i!I~~.'" ,,.,...J '1JI'J '-~~'_~"" '__ _ .",C' ~_ '''''.~_~~,''' ~,w , -~- ~~'~-'- .._'~_ ,-,,' "_'-kW"",,~"",_,,'" "'--'.,', (") C z 0{~t -;>-."1 ~---.. t~S~ -<.,,::. t;::c ~(:~ wL,J J>S~; :;J ~~~,~ ~ C) i'.....) ~,~;~ := -',::} :;:'.1-:J p,.) 0". -'3 !".,) co 'l'L~.,~,......,~~ ,"""!"__..__"".4_r,lj>1~~~'IJ!t't'~1ti-~fJ~~'l,""j;"""""!%!;,1'''','jg,;'-,1;-"''!WN~fT!:-;qm\!l~'j;;:',\'JR'~l'!I'l!ii!l''.m.mt'jE'I'~''''I,,,n~~~~~ VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVll.. ACTION - LAW v. : NO. 01-2092 CIVll.. TERM PAULAE. COLLER, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Bradley L. Griffie, Esquire, do hereby accept service of the true and correct copy of the Complaint in Divorce on behalf of my client, Paula E. Coller, the Defendant in the above case. Respectfu11y submitted, GRIFFIE & ASSOCIATES Oc-t c..oI: A-~I" ';) ..} '1, .)..M I . e, Esquire ey No, JY31.f'l 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 Attorney for Defendant , . VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. PAULAE. (COLLER) SMEE Defendant, : CIVIL ACTION -LAW : NO. 01-2092 CIVIL TERM : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please note the fact that the Defendant in the above captioned action, Paul E. Coller, has filed a Motion to Retake Prior Name and is now known as Paula E. Smee. Please reflect the change in the caption accordingly. Respectfully submitted, GRIFFIE & ASSOCIATES DATE: '57.21/ 0 f f;~-"_,.~_ -,,-,' - - ',_,,;,,-'7'-~"'_''+-_'';7;_ ". , , 1-' - ,- - -, ,.~_~ ',' ""'_-0' '_~~"-- - . ~--~-- ,--,_. - -~--~ , ~ "_." _~ _,-. ~ ~, ..lmlll _ ~. ~_. ~_lJ. '" ~ '.' , .. ~ .,< D ~ " -ooj 111fT"; Z~:". ZC, ~~>', _r"' 1.<:--'- J;;C "-"CO ~(:: -?" :':::I -< ,." ,C) -' ~,:'JD ~~ . . n ~";:'; .r:" .-:".-; -"j ;,~;. .~~~' ~,?; C)' "1-~ .~ :<: :2 .,0.. ~; ,::::J c::) -._-f5!W~~"!llIii~~!~,_"",~_,,,~,"_c~_~-_~' ~ 't~~~~~~~~~ VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : CNIL ACTION - LAW PAULAE. SMEE, Defendant : NO. 01-2092 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A, Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on April 9,2001, and served on April 24, 2001. 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE S EMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ~ VINCENT E. C LLER, Plaintiff -)11', H~ '-=~~- ...,. "~ , '-F . ' I: I, I, I [\ J.!ll!,,_ nm .-.'.--. ,--, ^~" " ., 'e__, N~" ",.,. .',,"0' " _ ~,; --~ - ~ '.."" '~< ~ ~ (') 0 0 ~ N -n ::l!: -00:; ;p. :TI !:pm -< _::D ' :-,0<0'" ZC w ~,~I;? (/) -"~. ~z_ ~,Jo !;:::C' -0 1~ -I"i ZO - ~-"-) :!J ..h ::'-;,-.0 -(:) (..J c5m >c ~ z =<! e::- X -.I -< . ~~~WC:J~"",~,",<,_",,~@~~i\j!~~~.''1!l'''-w:-~r,.,;-''o-m!,''-,'''Vf'~I{H't''-''a'- q-"'"r%'," ""VlH"""(>t$.'l,'''''''l''fif'',l'jir"",;;,,,,%,,,,,,,=I'''-''W ;!,I-~;4''''"~!j,''''1'''WW!~'~~~~~i\\II'-$ VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF . : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAULA E. SMEE, Defendant : NO. 01-2092 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 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! do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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 F ALSIFICA TION TO AUTHORITIES. /1, ' ____ DATE: '1h1ti7- fA I VINCENT . COLLER, Plaintiff '1)~1;,1.'~, 7tJ.'l<(~:iOI::w<lH-, _ ~r~ ,~ - ,--,....".,~ =. ~ ^ ~ ~~ . " _".__'c"',,. -"", _",. IUij, "",-"-<' "'~.,< ,-.---,.'-'- , ~ '%'-, '. ", ",",< -"-'" -~" ~~, () 0 0 C N '" ~ ::JI: ._~ -oQ] ::''.:$t ;~:ri pg fT1m -< Z:u ZC;;: =':~!n ~~2 (...) :5A !;20 _--l,_ -0 '---=,i P(') ::u; (:5 :!: ze" ~--...(") 5>-' ~.,) an'1 ,- 2 r.:- ~ -~ 5J -< ..../ -< \ "~Ri~i!fli~ilS!J!i,\-~!j;i[''''F,,,",,i-IifF,:'~-'''''''W'-')'''';"'''; -;--,'''eo'_ff.~''''{'''"EmfWIilb'~!fffllf,'*i!iR''JWf~,~'_t:)tI'''i:~,','''-;;';''''H,,:,f'iWl'l!~I!mt4h1Mfll'I~1 . , VINCENT E. COLLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. PAULAE, (COLLER) SMEE, Defendant, : CIVIL ACTION -LAW : NO. 01-2092 CIVIL TERM : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please note the Defendant hereby withdraws the Petition for Alimony Pendente Lite pre\liously filed in the above captioned matter. Respectfully submitted, GRIFFIE & ASSOCIATES DATE: 5f/s( f) I esquire for Defendant 00 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 .,~ ..~~' " .ri'~;".to<' ",:,~ "'~~-' - ,~_,_c-" '/' _ _h' Y'_-c, --'~f,", __"_0,'_" __ II ,I H " iI II ~<_ II~ 'I ';;;p , . ~ , ~.I~L." " -_.,-, .-, o C' ):;~ !if fJ.~ ;~t' ~C: )i;i:; r~' :;? a-;:l '. - ~, ^., ':::' ...~,~ (? -- .;::.'" .."-.'" - C'> ~<;:; '- -,. ~ ~--..J .~, ~~_~~_'l1i!ljIlj@~~~~f"~""'!~t\l*)!"i~i"3lii1liM!ii-'l'~ll!I!W~~~J,J~~ ~ - . SEPARATION AND PROPERTY SETTLEMENT AGREEMENT , 1h THIS AGREEMENT, made this ~ day of ~r' ) , 2002, by and between PAULA E. SMEE, of 1920 A Fry Loop Avenue, Carlisle, Cumberland County, Pennsylvania, party of the first part, hereinafter referred to as "Wife", AND VINCENT E. COLLER, of 272 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Husbanlf', WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been married on August 14, 1993, in Carlisle, Cumberland County, Pennsylvania. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling their respective fmancial rights and obligations as between each other, and to fmally and for all time to settle and determine their respective property and other rights growing out of their marital relations; and wish to enter into this Separation and Property Settlement Agreement; WHEREAS, both and each of the parties hereto have had the opportunity to be advised of their legal rights and the implications of this Agreement and the legal consequences which may and will ensue from the execution hereof; WHEREAS, Wife acknowledges that she has had the opportunity to be thoroughly conversant with and know accurately the size, degree, and extent of the estate and income of ..Page 1 of 15-- __.::...:;-,~~:hi::..::.:,:_;-_,,-,,_.._. "'.> ,t, " -" - - !- , ' , . . ~~";'~":r_.p~ =_ ,~~. ~ Husband and Husband acknowledges that he has had the opportunity to be thoroughly conversant with and know accurately the size, degree, and extent of the estate and income of Wife; and NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth which are hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenants and agree as follows: 1. Advise of Counsel: The parties acknowledge that they have received independent legal advice from counsel of their own selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements and the parties hereto state that helshe, in the procurement and execution of this Agreement, has not been subject to any fraud, concealment, overreaching, imposition, coercion, of other unfair dealing on the part of the other, or on the part of the other's counsel.. 2. Warranty of Disclosure: The parties warrant and represent that they have made a full disclosure of all assets and their valuation prior to the execution of this Agreement. This disclosure was in the form of an informal exchange of information by the parties attorneys and this Agreement between the parties is based upon this disclosure. --Page 2 of 15-- "',- ~ ",",",_ '."- J _ . I'. , =. , . "''i;-B~'''''~;''f.'_r, 3, Personal Rights and Sevaration: Wife and Husband may and shall, at all times hereafter, live separate and part. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb, nor malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit nor dwell by any means or in any manner ,,:,hatsoever with him ~r her. ,J f'~ ,~ , ' ;1_ 1-c:>{eed /0 Ifern'</G 1';:;1 !>ZC/n1 !.1/.5J5"'11t> "",1/,,,, IS" d""'1()~...,_/ a,hle NUS, i"'r . prJ(~v<1-ron ~r& 4. Agreement not a Bar to Divorce Proceedings:, This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party, This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the party of the other party which may have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of ~3301(c) of the Divorce Code of 1980. 5. Agreement to be Incorporated in Divorce Decree: The parties agree that the terms of this Agreement may be incorporated into any divorce decree which may be entered with respect to them. Notwithstanding such incorporation, this Agreement shall not ..Page 3 of 15-- . . ..--'.'-.-,'. be merged in the decree, but shall survive the same and shall be binding and conclusive on the parties for all time. 6. Date of Execution: The "date of execution" or "execution date" of this Agreement shall be defmed as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7. Personal ProDerty: Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property and hereinafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other, with full power to him or her to dispose of .the same as fully and effectually, as though he or she were unmarried. 8. Marital Debt: Husband and Wife have each retained certain debts in their individual names alone, which do not create obligation for the other party. Each party has and retains sole responsibility for payment of those respective debts since the date of separation of February 22, 2001, forward. Each party shall continue to maintain --Page 4 of 15-- '~~'~'"~l"'I.,,"IIR~ "_~4>.,. - t- those debts in current status and, where possibly, refinance those debts to assure that there will be no claim of any nature whatsoever against the other party relative to debts. Each party shall indemnify the other and hold the other party harmless from any demand for payment or collection activity of any nature whatsoever on account of the debts that they each specifically assumed. 9. Bank Accounts: For the mutual promises and covenants contained.in this Agreement, Husband and Wife hereby waive all right, title, claim or interest they may have by equitable distribution in their respective bank accounts, checking or savings, if any, and each party waives against the other any duty of accounting for disposition of any jointly held funds. 10. After-Acquired Personal ProDerty: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or 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. 11. Motor Vehicles: With respect to the motor vehicles owned by one or both parties, the parties agree as follows: a.) Husband shall retain ownership and possesslOn of the parties 1997 Ford Expedition. Husband shall promptly sell this vehicle through whatever means he selects, At the time of sale, he should pay the outstanding financial obligation on this vehicle in full so as to have the vehicle title released from the lien holder and --Page 5 of 15.- ~-~~- .-~ r - ~ so as to remove any obligation of Wife for the repayment of any amount due and owing for the 1997 Ford Expedition loan. Pending the sale of the 1997 Ford Expedition, Husband shall maintain payments on the lien on the vehicle in current status. At the time of sale, Wife will executed any and all documents to waive, relinquish and transfer any and all right, title, and interest to the 1997 Ford Expedition to a third party purchaser for value contemporaneously with Husband paying the lien holder in full for the debt and obligation on this vehicle., b.) Wife shall executed any and all documents to waive, relinquish and transfer any and all of her right, title, and interest in the 1996 Toyota Tercel owned by the parties and shall make no claim of any additional right, title or interest in the aforesaid vehicle from the date of transfer forward. Wife shall execute any and all documents necessary to transfer her interest in this vehicle to Husband at his request. ., c.) Wife hereby waives, relinquishes and transfers any and all right, title and interest she has in a certain Toyota Landcruiser that is presently in Husband's possession and which is being renovated by Husband. Wife will execute any and all documents necessary to waive, relinquish and transfer her interest in the vehicle within fifteen (15) days of being requested to do so by Husband and shall make no claim of any interest in the vehicle from the date of execution of this Agreement forward. " 12. Recivrocal Waivers of Pension Interests: Husband and Wife agree to waive any and all right, title, or interest in the other party's 40l(k) account(s), Individual Retirement --Page 6 of] 5-- c'~'i."'-';:;; ~'I\~~-""m...~~ . , "r ~" " I' ~ Account(s), Pension(s), Annuities, profit-sharing plans, or other retirement accounts or plans. In the event it is necessary for either party to executed any documents to waive, relinquish or transfer any right, title or interest in the other party's retirement accounts, he/she will do so within fifteen (15) days of being requested to do so by the other party. / 13. Warranty as to Post Separation and Future Obligations: Husband and Wife each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other party indemnified from all debts, charges and liabilities incurred by the Husband or Wife, respectively. , 14, Waiver O(SuDvort: a.) Husband hereby waives any right or claim of any nature whatsoever relative to alimony, alimony pendente lite, spousal support, spousal maintenance, counsel fees and expenses against Wife, , b,) With the exception as hereinafter stated, Wife likewise waives any additional right or claim of any nature whatsoever relative to alimony, alimony pendente lite, spousal support, spousal maintenance, counsel fees and expenses against '! Husband. J Husband shall paYJ.<' Wife the sum of $400.00 per JIlonth by thei!!Slt ,r' ___..____.____.__.__ ______~______"____~___..____...___ ~a]~f.e<lchJtl.ontlLbeginning.thefirsLd~y of the first month following the ~ of "d~~ree in Di'l,()!c:e ip. the Jlartie~pen~ divQ.~ction. Husband is currently ------------~ -.-. --.--.--- under an obligation to pay spousal support which obligation is docketed in the Court of Common Pleas of Cumberland County, Pennsylvania, to docket # 00236 --Page 7 of 15-- .';-,-",, ' : ~~I;~"","~!"q"'" f";-. . ~., " - S 2001 and PACSES Case # 192103180. Rather than the parties creating any new obligation, Husband shall simply continue making payments under that Court Order which requires the payment of $400.00 per month, through December 31, 20021 Husband's obligation to pay spousal support under the above captioned and docketed Order shall continue to the date of the entry of the parties' decree in divorce, From that time forward the spousal support shall immediately convert to alimony and continue as indicated. This alimony is non-modifiable under any circumstances and shall not terminate upon either . party's cohabitation or remarriage, but shall only terminate upon the death of either party/ GJ As reasonably practical after January 1,2003, Wife shall notify the Cumberland County Domestic Relations Office that the spousal support/alimony Order shall cease effective January 1, 2003, and shall make no additional claim for spousal support, alimony pendente lite, alimony or any oth1r similar financial assistance ~(b W~'l'li'>iJ o~ from Husband from that date forwa, rd. ~, . pil./ J . /J I L' . A "...,vr f\ ;? f' // ~ '"' ~J,,- xe/r4--71b11 14<<:( r !1~ Ik ,1;z.r.e.el'l-f= fR.Um 11'e 11= · 1" u.st-i3e .:z:e'J),(9J 1If./.' ::JXn (zoo::', i,,,,fiI JVf) ;4cfJ 1/ S fJp&t- T/J ,. Husband shall not take any action to terminate the spousal support Order above ifff4fl {?J!t! 012- f'rPkr docketed so as to allow the ongoing attachment of his income through December .jA1' 1iitJ5 31, 2002, to make payment on the alimony amount agreed upon herein. Should Husband take any action to terminate the spousal support Order based upon the fact that the parties have secured a Decree in Divorce, Wife shall be entitled to immediately request the Cumberland County Domestic Relations Office to collect\! --Page 8 of 15.. ;:W->W',_~~~ . ,_ " "'1'" ". " ,',..'<,".,...... - .-- , . the ongoing alimony amount of $400.00 per month from the time of Husband's request for termination of the spousal support Order as alimony. 15. Mutual Releases: Husband and Wife each do hereby mutually remIse, release, quitclaim, and forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, 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 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 as 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 other country, or any rights which either party 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 thereof. It is the intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any ..Page 9 of 15-- :_~-! .~ - '", [-J-' '. and all property of any kind or nature, real or 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 thereof. 16. Divorce: Husband has initiated an action for divorce against Wife pursuant to S3301(c) of the Divorce Code of Pennsylvania by filing a Complaint in Divorce on or ~out April ,9, 200~ t;n\ the Court of Common Pleas of Cumberland County, '(gJl f'.:cv \'3. :)..,ocu~ '$J Pennsylvania. The parties shall executil'ih any and all necessary Affidavits of Consent , and a Waivers of Notice of Intention to request the Entry of a Decree in Divorce to conclude that divorce as a no,fault, consent, or S3301(c) Divorce.; a,) Each of the parties agree that this Agreement represents a complete and [mal agreement as to their respective property rights which arose from the marital relation and therefore mutually waive any and all rights they may have under S3502 (Equitable Distribution), of the Pennsylvania Code, Act. No 1980-26. b,) This Agreement may be offered in evidence in the action for divorce and may be incorporated by reference in the decree to be granted therein. Notwithstanding such incorporation, this Agreement shall not be merged in the decree, but shall survive the same and shall be binding and conclusive to the rights of all parties. 17, Legal Fees: In the review and preparation of this Agreement each party shall bear his or her own legal fees, v --Page J 0 of J 5-- "'",{:<'1~~""'>?";"'''''- "". ~~ "......, ~~ r- , " , 18. Remedv for Breach: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, either to sue for damages for such breach, in which event the breaching party shall be re.sponsible for payment of legal fees and costs incurred by the other in enforcing their rights hereunder, whether through formal court action or negotiations, or to seek such other remedies or relief as may be available to him or her., " 19. Equitable Distribution: It is specifically understood and agreed that this Agreement constitutes and equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either of them during the marriage as contemplated by The Act of April 2, 1980 (P.L. No. 63, No. 26) known as "The Divorce Code," 23 P ,S. 101 et seq. of the Commonwealth of Pennsylvania, and as amended. 20. Summary of Effect Qf Agreement: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against the other for any past, present and future clams on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims raised by them in the divorce action pending between the parties, 21. Tax Consequences: By this Agreement, the parties have intended to effectuate and by this Agreement have equally divided their marital property. The parties have detennined that such equal division conforms to a right and just standard with regard / --Page 11 of 15-- I",.. . ...:.'c.c..:..._.-.. '-',-i-"~-'" I" . " . to the rights of each party. The division of existing marital property is no, except as may be otherwise expressly provided herein, intended by the parties to institute or constitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting a party of the marital estate. ,/ 22. Mutual Coooeration/Duty to Effectuate Agreement: Each party shall at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to 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. Reconciliation: The parties shall only effectuate a legal reconciliation which supersedes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation, which action, if not consummated by the aforesaid agreement, shall not affect in any way the legal affect of this agreement or cause any new marital rights or obligations to accrue.,f 24. 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 failure of any party to meet her or his obligations under any nPage 12 0115-- '-'^);l'~'~~""""", ~ ~_ ...",.. 'I ~, ':' - _ - - . , .' , "!f\~~'!jll . one or more of the paragraphs herein, with exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 25. No Waiver of 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 breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein.,! 26. Integration: This Agreement constitutes the entire 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. This Agreement shall survive integration by any court into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contracL i 27. Effect of Divorce Decree: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 28. Notices: Any and all notices given hereunder shall be in writing and shall be sent registered mail, return receipt requested: .i --Page 13 of 15-- , ,~-- , . .. ',."r ~, ~, -" , - . . . ' ~@> }/ / /60 f.ec;&1J?dAldod~ C",d.le, At 1761:; --;; (f v!,;Jfn1IJ A=i ~ '" a.) ,q'-e.M'Ii~-at292 '.v",t Ridge Street, C1l1;~!t:, FA 1101'3 . . b,) To Wife at 1920 A, Fry Loop Avenue, Carlisle, PA 17013 29. Waiver or 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, 30. Cavtions: The captions of this Agreement are inserted only as a matter of convenience and for reference and in no way defied, limit or describe the scope and intent of this Agreement, nor in any way effect this Agreement. 31. A~eement BindinfJ on Heirs: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executor, administrators, successors and assigns. 32. Goveminl[ Law: This Agreements shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties have set forth their hands and seals to two counterparts of this Agreement, each of which shall constitute an original, the day and year first above written. WITNESSES: ..Page 14 of 15-- " ' '," ',;;-' -~ -; '-~-'-~---,--~---~--~.__.._--- - h\JJ,~_ _ ~,,_~,___ __~,"_ '_"' " _""",,-~,,_~_,,~__<__ "-' '''f .' <>:'. t' '. .'" .. .j,\. . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this q day of fJp; I , 2002, before me, the undersigned officer, personally appeared PAULA E. SMEE, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOfARlAL SEAL DAWN M, SHUGHART, NolaI)' Public Carlisle, Cumberland County CommJeslon Expires Noy. 28, 2002 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this q day of Nfh / , 2002, before me, the undersigned officer, personally appeared VINCENTE. COLLER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTAR\/>.L SEAL DAWN M. SHUGHART, NOlalYft~ Carfis\e cumberland Cou,", ZOO!! My~on Exolres Nov. 211. -C"';> >,-:') ..,.., ~ '1-" ' " ,--.", .,Page 15 of 15.. ~_>_~,'_."-.~'-C; ..,^":,,'r/""';'l ;11<f__,'O', ~- " . ~-- i~ ~ ~,.,. l.il1I_'~l_"'" "'F'" 1 llfn ,~- .-,. ,-.-= ""~"'='''~-"",,&''''~'''_r ~~- ~~ ',,",-~"'< ' (') ~~ CRPl; ~:~:J ' ~c c"'- -c;' ~~,~ , ~ . . S? "'-..' o 'fl a C) '~~1 ~l '-1' '~ _:.' ....) IL, '~""~"!"'""1"'''''"~ ,_~ '""" ~ '~1W!1fI1!ll'-*,.~",m'i'1l~~,F,;,>~i-_"f!~''''''~'!P'''-iW''~l~~W~I:>l<~p'l!i'10J1Fm,1r,'-"'\\l-""J,1)"JW~\'illl~~jiJ~i~iJ!tW!~'lf' ~ ,- VINCENT E. COLLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, CIVIL ACTION - LAW Defendant : NO. 01-2092 : IN DIVORCE CIVIL TERM PAULA E. SMEE, 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 93301(c) 33131(&)(1) efthe Diyefee Caae. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Acceptance of Service on April 24, 2001. 3. Complete either paragraph (a) or (b), (a) Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce Code: by Plaintiff: April 20, 2002 by Defendant: April 18, 2002 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs 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 of plaintiffs Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: May 13, 2002 Date defendant's Waiver of Notice III 93301 (c) Divorce was filed with the Prothonotary: April 26, 2002 , squire & ASSOCIATES Attorney for Defendant " J:'r-",;,< i>i,~~" ~_" ,'y, ~_ - - '] , . r( ""''''''''''''"'''!''"''<,- il fr _.rrrD~ ._, _~,~_.. lffl_Jl!lll!.JlifJ:J!.If~~'!W!+~~w,ftj'- ---- ~IliUI]~I.m__r_~~t~.r:l'j;r>if<-7'-,-'- ~~."".=~,~ (') c: ".. ~;h. -UO.':" IT'r..... zj' 63 5.~~ ~( M_ "' CJ ''0 o C) ,-4 ;2 .. ,., .= .' ~ ~:~~: J;:'" j::"" (:J' Ie: .--~-+-.: :;(") ;:-0:,1"1 ;::1 ::J -< ~ ,.- ;-~!,,~~-,,:,;;',,:r;rr'?1"'~1U-<J;~i*.fjl!"g~?i!''";,F.-;t'', '~fl",},r'; "fri~w;i'*!,'t(;i.~.["')'."!i~'1\"'!qb'~