HomeMy WebLinkAbout01-03334
'-',I
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
'" "'''' '"
..
. .
.
.
. ..
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
GARY K. DARROWER,
PENNA.
STATE OF
Plaintiff
NO.
2001-3334
VERSUS
LISA M. DARROWER,
Defendant
DECREE IN
DIVORCE
A1q~ z ":"
AND NOW,
, ;t..6o'1 , IT IS ORDERED AND
GARY K. DARROWER
DECREED THAT
, PLAINTIFF,
LISA M. DARROWER
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
elEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The Marriage Settlement Agreement dated October 16, 2004 and signed by
the parties is hereby incorporated into this decree but not merged.
.
.
.
ATTE".~
' PROTHONOTARY
'" '" "''''
>., c'_O_?'9_"":";~,,,,' <. r' ',_
--'~
,^'''"-, I n-f-, ,
, ,~. , ~ ,--- .
",,?':;<'
J.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
~"'--'.,;jUM1~;~~ """"''''n:;i,~~~~~~iciOi~M~.1i>~lj,.:.b;;~<li:~i#",~~r&iilIlIIUili~"- t- ,~ "' ""'''ll' "-<"'-..."'.
II -J /)V
/(.3 tlf/
-/;;/7
.>;:;l
-~
;0 .. ' '
, .
W.~~1~<4/t ~~
'7!~ ~;t ~.
. ~; ~,
\\1
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION . LAW
: 2001 . 3334 CIVIL TERM
LISA M. DARHOWER,
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 330l(c) and/or (d) of the Divorce
Code,
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was
served upon the defendant, Lisa M. Darhower by certified mail, restricted delivery, on or about June 12,
2001. The Affidavit of Service was filed with the Prothontoary on or about October 13, 2004,
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: October IS, 2004 by defendant: October IS, 2004
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce
Code:
(b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4, Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service ofthe Notice of Intention to file Praecipe to Transmit
Record, a copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: October 21, 2004
Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: October 21, 2004
Date: October 28, 2004
~
Douglas . Miller, Esquire
Attorney for Plaintiff
:,'f ,~ , ,;__~<,
~,"';:;:?V-"F,(""'t. ,oc,"",'_" ,_o__~-,_'__',_,I ",""",--, ''''''_''"',';i'',.~.,.__, _~,~ ;-<""' __ ,,,,_w,., _~,"'" ',,,,, ",. "'
'1
I
1
I
I,
.J
I
~,?,- ,
''', L~
.-, ,~
Ef
/.?L
-" ,,,<,
~~ ,.. ~~
,-~ .r"",
,,--,' "
"lW---_
~~.:',~::"l",
~.._....l~,,_ '
n
-YJti
r1"1f'r
=:::)~-
"-:"",
u~~. -
~~ ~:. ~:':
:2"
~g~~
?.::
-<
-<
" ~ '-~'-
....,
=
=
.x-
c:;:>
(")
-l
r"
co
-0
:Jl:
Yi'
o
c,.;;
~
....
:ron
1"1';=:::
~8m
~~6
:c -t1
,('")~
'70
;5m
-.'1
.".
~
-~ - "~~"~7'_~~
lJI!J~l1l!l!IfjlII
..~l-l\R:.~_:"_:"_ _ ,
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this & day of Oc4" b-e,-. 2004, by and between
LISA M. DARHOWER, (hereinafter referred to as "WIFE") and GARY K. DARHOWER,
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on July 6, 1979, and a
Complaint in Divorce filed on May 31, 2001, in Cumberland County, Pennsylvania at Docket
No, 2001-3334; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
I.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties ofthe parties while they continue to live apart from each other.
~- '" '. .,-, . >:!'
,~"~~~",,, .~'~>'.'" _,.. '___~_W~'__"'''>'~="'_~_''_'_"__~''
',h , u~ ", ""~,
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective. rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carryon and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(1) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: HUSBAND is
2
!~~"
..~,n,~_"~.,_"
_,.,~~_""_ _. ~.. " __ ,,_~~, ~'U
",'>
represented by Douglas G. Miller, Esquire of Irwin & McKnight; WIFE was
represented by Thomas S. DieW, Esquire of Mislitsky & DieW, but at this time
chooses not to be represented by counsel, and by initialing this page
acknowledges her right to be represented by counsel ~;
(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision,
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations ofthe parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to 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 part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
3
!::,r:;1 "~~,<~ "__'~"_, ___..
,_,.,~,_~o
.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to
the other of all of his or her property interests of any nature, including any mortgage, pledge,
lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
mamage.
7.
REAL ESTATE: WIFE agrees to transfer all right, title and interest which she may
have in that marital property located at 610 Burgners Road, Carlisle, Cumberland County
County, Pennsylvania, 17013 and any improvements thereon to HUSBAND and releases all
claims which she may have regarding said real estate in accordance with this paragraph.
HUSBAND agrees to pay any outstanding payments on any mortgages on said property, as well
as all real estate taxes, insurance, and any maintenance and repair costs, and hold WIFE
harmless from any obligations on said payments and indemnify her if any claim is made against
her. In furtherance of the transfer of all right, title and interest in said real estate, WIFE hereby
agrees to execute a Deed conveying her interest in the property to HUSBAND. HUSBAND
agrees to refinance the existing mortgage obligations on the property and thereby remove
WIFE'S name from said obligations, at which time, or earlier, WIFE shall move from the
marital residence. Legal counsel for HUSBAND shall hold the signed document in escrow until
such time as necessary for HUSBAND'S refinance, at which time the Deed shall be filed of
record with the Cumberland County Recorder of Deeds.
4
: ,<j!~ ,,-,~ , ,-;:"" ,,~
,~,~'~~~""""c<~ . ~
.
,
-- ~ '
It is the understanding of the parties that their Florida time share property is no longer an
asset as the parties ceased making the required payments. In the event that the parties still have
an ownership interest, WIFE agrees to transfer all right, title and interest which she may have in
the time share to HUSBAND and hereby releases all claims which she may have regarding said
property interest. HUSBAND agrees to hold WIFE harmless from any obligations relating to
said time share property and indemnify her if any claim is made against her.
8.
SUPPORT: Following the execution of this Agreement, it is the mutual desire of the
parties that HUSBAND will not be required to pay spousal support, alimony, alimony pendente
lite, or any other financial support to WIFE, and that WIFE will not be required to pay spousal
support, alimony, alimony pendente lite, or any other financial support to HUSBAND. The
parties thereby waive any rights they have to receive spousal support, alimony or alimony
pendente lite payments from the other either prior to or following the entry of the Divorce
Decree in this matter.
9.
PERSONAL PROPERTY: The parties agree that the personal property will be divided
to the parties' mutual satisfaction upon WIFE'S removal from the marital residence. In the
event the parties are unable to agree as to the division of property, then the parties agree to
submit their disputes regarding division to a mediator, mutually agreed upon by the parties.
Upon the final division of property, WIFE hereby waives all right, title and interest which she
may have in any personal property of the HUSBAND, and HUSBAND likewise waives any
right, title and interest which he has in the personal property of WIFE. Upon the final division
of property, each of the parties shall own, have and enjoy independently of any claim or right of
the other party, all items of personal property of every kind, nature and description and wherever
5
I1*'< , "" c_~ "'''',".'''',~,~_~~~,=~~.~ ,~, ,_,e-__,f"""',,c"' .~"__o,, '<~"''''''''V' _N = ,.~""",,,C.''''" ,;~,~_~" .~~ ,='''''''', __" ~_~" ",__
~ ~
situated, which are then owned or held by or which may hereafter belong to HUSBAND or
WIFE with full power to HUSBAND or WIFE to dispose of the same as fully and effectually,
in all respects and for all purposes as if he or she were unmarried.
10.
AUTOMOBILES: HUSBAND agrees to pay the existing loan on the Suzuki Sidekick
currently in possession of WIFE and upon payoff of the automobile loan with American General
Finance, HUSBAND agrees to execute all documents necessary to transfer the title of the Suzuki
Sidekick to WIFE. WIFE shall be solely responsible for all insurance and other financial
responsibility associated with said vehicle. WIFE hereby waives all right, title and interest in
any vehicle that HUSBAND currently owns or may own in the future, and within thirty (30)
days of this Agreement agrees to execute all documents necessary to transfer title of any jointly
titled vehicles that HUSBAND may have in his possession. HUSBAND shall hold WIFE
hannless for any and all liability associated with the use and purchase of any vehicle he may
own, and shall be solely responsible for all insurance and other financial responsibility associated
with said vehicle. HUSBAND hereby waives all right, title and interest in any vehicle that
WIFE currently owns or may own in the future. WIFE shall hold HUSBAND hannless for any
and all liability associated with the use and purchase of any future vehicle she may own, and she
shall be solely responsible for all insurance and other financial responsibility associated with said
vehicle.
11.
MARITAL DEBTS: The parties to this matter are not aware of any joint credit card
debts. However, it is mutually agreed by and between the parties that WIFE shall assume all
liability for and pay and indemnify the HUSBAND against all credit cards and other debts
incurred by WIFE in her name alone. WIFE represents and warrants to HUSBAND that since
the filing of the Divorce Complaint she has not contracted or incurred any debt or liability for
6
--- f! ,"""""""",,~~.,=.. ~_~"~,,_'''~_'__".'''',, ". ~M~' ~_" _ "~ ~ ~ "",_, ,',
which HUSBAND or his estate might be responsible and WIFE further represents and warrants
to HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify
and save HUSBAND harmless from any and all claims or demands made against him by reason
of debts or obligations incurred by her.
HUSBAND shall assume all liability for and pay and indemnify the WIFE against all
credit cards and other debts incurred by WIFE in her name alone HUSBAND after the date of
separation. HUSBAND shall also indemnify WIFE and hold her harmless against IRS tax
penalties being paid by HUSBAND for the early termination of WIFE'S 401(k) retirement plan.
HUSBAND represents and warrants to WIFE that since the parties' marital separation he has
not contracted or incurred any debt or liability for which WIFE or her estate might be
responsible and HUSBAND further represents and warrants to WIFE that he will not contract or
incur any debt or liability after the execution of this Agreement, for which WIFE or her estate
might be responsible. HUSBAND shall indemnify and save WIFE harmless from any and all
claims or demands made against her by reason of debts or obligations incurred by him.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE and any other employee benefits,
including but not limited to retirement, profit sharing or medical benefits of either party, shall be
their own. WIFE waives all right, title and claim to any of HUSBAND'S employee benefits,
and HUSBAND waives all right, title, and claim to any of WIFE'S employee benefits.
13.
BENEFITS. STOCK AND BANK ACCOUNTS: WIFE agrees to waive all right, title
and interest which she may have in the savings or checking or any other bank accounts of
7
',;?"
. ~. - ...~
= . =~-, ~,
,,=
HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce, Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it is not the result of any duress or undue influence. It is the
8
'_"'~ ..,~e"~,""""";,_.~",, ~'"_~_, .__.' _"O"_~_<_"'. ,,_=-,,_~,,_ ,',' '._, '_"__'_'. .~ ,<,,_ ~_.,,_ ,,_
. -
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
9
~~-'1f,':'<"^,-," , ,", ',_"'"".. _,""C ~,=_"7" ,_.~_~.""___~___,,__,,,,~, ~ ~"'"
,~ ,~.' ~~--~',--"" - ,'~-~-~. ~,~ ~.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
~MW~ ~~~
LISA . DARHOWER
(SEAL)
4ri;1.1W V\\M)~ ~1i J'. f}~~ (SEAL)
RY .DARHOWER
10
:i,~~z_' <'- .; -"_;"",,., ,~" ",.,T ',"""'~"''''',,, -.,,_ _,"'~ ",\~"'~1.~,':'n{,>:,"'-"'..,''''''' ,7'" .. n~,<A,,' ,__"',"'''''>c~~ """"~'''_~ __ "'_<'''''' " ~,.
COMMONWEALTH OF PENNSYL VANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this A day of Oc f.
2001
2004, a Notary Public, LISA M. DARHOWER, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
/0 J II. (j
~1'''Vj J "Yl lJ 11, ~ lit-
Notary Public
Notarial Seal
Cyndi M. Wright, Notary Puhiic
Silver Spring Twp., Cumberland County
My Commission Expires Apr. 15. 2007
Member, Pennsylvania Association of Notaries
C......"'........."'..... tt:.f'..
4/1>1,.,
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ~ day of DC+- 2001 '
2004, a Notary Public, GARY K. DARHOWER, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
~ ndJ. I'Y\ WI,.( ~ Lt-
Notary Public
/6-1t._O,a
Notarial Seal
Cyndi M. Wright, Notary Puhiic 4/, s: I
SHyer Spring 1\vp" Cumheriand County I/)7
My Commission Expires Apr. 15, 2007
Member, PennsylvanieAssOClellon olNotanes
{'''''....''''...........+r-e~ p...
11
~f;;: ,~,'^.
" ,~' ">~,-'"::__" f_:::-}':f''''f_'?'' '---'--"';."_~'),"'c"~_'J:" ':<.~--""~'
''''c'"
--',,'--
,~- .'.~.
,.,',-~c;__1:=,._, ~,'l,,'~~'f',W "~,y"-~,,,_,,,~^ -',~." ~'C:':;""" .. ",-..,. "-'f'.."..,
~
I':L'
iP,
pV
-"'---"~'~"-' -
r;,,-
.,I!!l!"" ''';',,':1'''-,'~'- ","")'"~'~''''!'C':~~~::_~l'IJ\l'- ,.L~"Jl{.
"'~"'~-"'.,;'^""""'m'r
0 "->
C c:::. 0
0..-.
;;.--.-- "'- "'f1
:::..
f ...: C::)
('j ~:n
.......
r-
", ::grn
CO C)6
-u 'il...
::!l;: ., --+l
(,;to
~ ~ ;srn
2:,
..,~ CJ -""
-< 5J
c:.,,;. -<
~. "-,~.~~i"'",,,,",,",,_ c' ~~_~~
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTION - LAW
2001- 333<; CIVIL TERM
LISA M. DARHOWER,
Defendant
IN DIVORCE
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 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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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, Pennsylvania 17013
717-249-3166
1-800-990-9108
;'?~..'J. _,
" "",,:'~~;~tI.'_"-~;~">'~~'~-r:'-"-"~'C"_;~"lif!- :r.., ',,-',;1":'"-,,,;, '" ",,,_,f:;'?'~h">'- .- -. ' _ '-' ,",j'".-" . "-,' '~''':.(-', ~~ ,
_c,. "~,',,,,~_~_ .""""7, _~, ,~~ "~
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
!",: "" '''', ~ "- "":-;-,,').;;f::"","'i'-'i:,c0'~:;;'~""'" ";"""~':;-,' ,"':-:; ,-,7. __, ,,,", >,",""1-"','__ ""_~'" "'U
'--., ~;,--",:, -,','
", '-""=.., ,-"~--<;.,,,,.,,,,
'_~_,_. ""'. ,_,~_ ,,' ~.._ "'_,,, __ _~ .0' ,,' _,.,____
.,,<
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
200U3Yf CIVIL TERM
LISA M. DARHOWER,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the Plaintiff, GARY K. DARHOWER, by and through his attorney,
Douglas G. Miller, Esquire, and files this Complaint in Divorce against the Defendant, LISA M.
DARHOWER, and in support thereof avers as follows:
1. The Plaintiff is Gary K. Darhower, an adult individual residing at 610 Burgners Road,
Carlisle, Pennsylvania 17013.
2, The Defendant is Lisa M. Darhower, an adult individual residing at 791 Hamilton
Court, Carlisle, Pennsylvania 17013.
3. The Defendant has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing ofthis action in divorce.
4. The Plaintiff and the Defendant were married on July 6, 1979 in Carlisle,
Pennsylvania, and separated on January 14,2001.
,. "' ';-'-,,'-"'<~~,'r, ;;,ry~' oc" Co, ,~_,,,," ~~,' '--'-'",""~-" -'.__. _~_
",. <., w c',._, ',--'
"',-, "':"'-:"." "',"',) -^
'.,",
,"~
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were two (2) children born to this marriage, namely Brandy L. Darhower, born
December 27, 1979, age 21 years, and Jason C. Darhower, born April 29, 1983, age 18 years.
7, Pursuant to the Divorce Code, Section 3301(c), the Plaintiff avers as the grounds
upon which this action is based that the marriage between the parties is irretrievably broken.
8. The Plaintiff avers that he has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the
two parties.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Dougla G. M' er, squire
Attorney for Plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 83776
Date: May 31, 2001
r~: ,"'--;<
~ 0 :v_..>:,;O---:~li';' ~~< ';:'-:","'_"",,',","';'\''''''_':-(''1_'_'_'''-'-' ";"ec,,' ~ '-_'_'~_"'; ~ ~,<" _ ',,' -7 -,-.:~ "" .
." ,.,,""-.
,0' , _, _' "~_? _~"', ,"' ,'" _ ", ~, ,
"".
-
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C,S.A. Section
4904, relating to unsworn falsification to authorities.
~J}b
---'
Date:
Kay 30
,2001
t" . _.
::',," ":"'-'--'~,_._-,'",,~,,," ,-,-"~', ,-~,,,-" .<, ',-'-'-'" ",'''~ ""-":'-f~'--
~,~ ~, ,-
,,~. w_ -' :;-" ,/_,_,~__< ",,,
"~
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001 -333 'f CIVIL TERM
LISA M. DARHOWER,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I lmderstand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
May 30
,2001
,rlttfR/t. W/~ --
G YK.D OWER
!~" '
'_~, -, 1__ _}'- '"" .
'~^ ", ,~ -,,"
""--'--"',,,,,,,<'
.- ,,'..-->.-..--.
_m ~,,_
'n_ 1,_ ,", ~"" _", "_"'-','
, -,,-,'~-,-- -~~ '" co"~,
i
j
:,1
1
j
:1
,I
'1
1
:j
,..:
J
'1
'I
C,\....
,._"~.,, .'m'c.,"%'c':"!"
:'1[1
-1-' ~
f'i
.;-'\-.
C)
-,
-",1
"T"
~-:--\
,.",)
\0
...';,:
::r:.:
--,
.....;.,:
,.-"_".,,, ._,,:,___,.l!,:,,~__!] ~-",~,^_,~-~~,~t!~:,-, ""'~"~"'~'~'\--':__-~,,~~~
-",~.y:~.'C\-J"",-."",
GARY K. DARHOWER,
P1aintift'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: CIVIL ACTION . LAW
.
.
: 2001 .3334 CIVIL TERM
LISA M. DARHOWER,
Defendant
.
.
: IN DIVORCE
PLAINTIFF'S AJ!'.ll'WA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May
31,2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a fmal decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authori ties.
Date: / tJ-IS - 0 'f
.
i"'::[', --->". ,~. '_P~"_, ^ I "
-.
., '
,,' "";-"
q
,
'::~. " .
"..'
""~<FI._~
,.-'
-~,
"
"
'..
:':3
-,
,....,
1:",;,,)
s:.a
G
.'1
c-,
CO)
-;
:Ii.."
ITlp:
[';1~
." ~ .-
:~:~;'r I
J'~
.1..;
~<
\'0.)
-"
_';'4
I~')
.-
.,.
GARY K. DARHOWER.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: CML ACTION. LAW
: 2001 . 3334 CML TERM
LISA M. DARHOWER,
Defendant
.
.
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May
31,2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date:
/ O/J5' Joe;
.li.V17J;Qd~~
M. DARHO R
Defendant
.< ~'.l '-, ,,' {""_~ \ ,_"
, '"',
,-,
";-~"
.,.-.'
C~j
a,?;
:~
C")
(.:;
. ,
.-'~I
I'J
,..;,
~.:;.
~. l'j
r',
~ "i'1
-(1
.- :
.-'
.1- -rt
~;~,t~~~
: ;,; (l)
"'t:~ :::",
}~)\
':'.\
~:..).
-.;~
{'-.';
"
GARY K. DARROWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
v.
: CIVIL ACTION . LAW
.
.
: 2001 .3334 CIVIL TERM
LISA M. DARROWER,
Defendant
.
.
: IN DIVORCE
WAIVER OF NOlICE OFINTE:N,TION TO REOUEST
ENTRY OF A DIVORCE DECREE ~J:R
5ECTION 3301(4:1 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 tbat I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: /~"/S-" y
~~k ill A~
RY ARHOWER
Plaintiff
"i_'!j~. . ,^"^ ^ ,_ ""~",_-,,,,,~ ,0'_":_'0"1':"- ~,," ~~ '!~' ~
,'.
""
" ...., 0
C"~
:;:" Co-=' .''11
.;:"
" c> .-\
; -;;r;-n
,"")
--, 1 ~ 'I f-:-
('~~ -n;:;::
:.';''-:-.'
^ -n .~) :1~
-:t: '~~~ c-:S
1.;' ~.,/ I I I
~ ,...)
'.
:.;.:" :;:s
~;:;~ .r.
-~ [';.> .".,
';01":"
,~
'c
,
C_'_.
~ -, , -, ',- ~-
,~ ,- ,~, ". ,. '
_~-- I, "',,;c___,.._', ,~"' ~,-,;- ~ ,,' ' ,,_, -~"'" 1~"-'M0<c_~~ .-"=---,""""'",-,,,,,.,., _"o,~, ,"" )",..,~ _"~," _",_,.,,' ,;
GARY K. DARHOWER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
: 2001 - 3334 CIVIL TERM
LISA M. DARHOWER,
Defendant
: IN DIVORCE
PLAINTIFF'S AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) ofthe Divorce Code was fIled on May
31,2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the fIling of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affIdavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsifIcation to authorities.
Date: / ()- IS - 0 'I
.
_,,"v.
_,N,
I''''. -"__O,~ ,~ '-.' ,"=-', __'~,~""~""--d"""""~~"o"""""",-"-,;~,',,
" "',I
GARY K. DARHOWER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
: 2001 - 3334 CIVIL TERM
LISA M. DARHOWER,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a fInal Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is fIled with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsifIcation to authorities.
Date: /1/-/.5- t> 'I
~{)44L~
G RY ARHOWER
Plaintiff
.-.,
""'" ,
~0
~
, ~-
, _,> .>1", ,~'" __
';"'lliirli
. ,. ",'~~ ,"
'-'"
\,'-
.
''': ~ -~
,-
'"
-
6';
S~
C)
('")
-,
,~~
o
"","j
.-~
:,:r.:-n
rnp..::.
-08
~~k
;':':'c:S
~lrn
'~
:1:!
*'f...
v
::r::
I)?
r
N
m
~,
~~,~ '<"eo ~,"" ~^,____ '''~'''' t,"",,,-, '.,,_" '''''''-'''''~__~__-'" ",,"~,'
"1-;.-,''':
'~~L"~' '" "i';,"'I,,," i-r_,'-' "."--,,,t,"i-:.ii;''';!''''a,",i~~~ -,;
~I
I'
,I
I
II
I
,
1
,
1
I
,
!I
I
'I
:1
I
I
1
I
"
,I
!I
:1
I
'I
il
,
,
I
I
I
!I
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION -LAW
: 2001 - 3334 CIVIL TERM
LISA M. DARHOWER,
Defendant
: IN DIVORCE
DEFENDANT'S AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on May
31,2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the fIling of the complaint.
3. I consent to the entry of a fInal decree in divorce.
4. 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.
I verify that the statements made in this affIdavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date:
/ of) /bC;
PJf)uhLUd<
tis M. DARHOWER
Defendant
liilll~
',~;..."",,~-~ '--
f6~
~~
;-""',,'''''- ,---'-'-~" - "~-~.
"~,,",- ,"-,", ,
,..,,---,,',
~..,,~'"''''''' '''~.u~';d ~,,,",-
, ,,~". " " -~, ,,~
;, o,,,t,,~ ,
.."
~,;' ,--. :,~,. ;;:"', ",
~~
<
"'"
,::::::;
::~
C)
f~")
:-'"1
1',,)
-c1
:;1',:
!,~'"
~:"l
:.-:!
~~~l~
-Gf'i~
-q\",'
~;~ ~~(
;~~ ~~~~~
':'.~:\
:'p
","....
,~'~)
r--v
.....: , 'c, , ~-', ., 0 ,I 0 ., '",' ., . 1--"-,' "~",O-;;. " '<';';:~ '~\~j~",/,,,; :'e~-ii-.-,~',_~~, __ 'J ~, -"<i\};'~ \!
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: 2001 - 3334 CIVIL TERM
LISA M. DARHOWER,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affIdavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsifIcation to authorities.
Date:
JOffe;- /tJl!
~
' " "! Z.UL12A...
LISA M. DARHOWER
Defendant
i'M'.;;r;.
,,',<
.'.
'lli1m
'"
'0
~~
,
"-,-",,,,; ,,""c,,~',
....."--.",.;-"
. '~'(" '."' L'",'.'
,,,'<-,,,,--,
~I
,....,
c::::>
C?
...-
o
("'.)
...~':
C"
-n
::;1
i:';1~2
-nm
~lJ\-'1
~-~~.;
S',~~'~
c,srn
~1
1'.)
:;~
...;:;;;.
i~,?
.t-
,"-<!'
1'0
tI.
;$
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CML ACTION - LAW
.
.
: 2001 - 3334 CIVIL TERM
LISA M. DARHOWER,
Defendant
: IN DIVORCE
WAIVER OF ~OTlCE OF :t~NTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 330l(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 f1led with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
JO/;~ /tJt!
.~f~
LISA M. DARHOWER -
Defendant
,Y,(_
- ~""",'-"''''''"'''?~:'' '- ',' ,~,,~,
,. ..
.
~
_"F'f!'<.?
,r
1,,"""'"
c~ ......,
~ C)
" c.::::l-
J-- -1"1
" ;' 0 .-4
('~j :(
....: \ , ~ f!::.'
" 1'.) -..,(,1
."..)\:;-.1
-'iJ ~~.~~ {~~
..... '. .:(')
-:".
~y ::~?; I'n
.,
,..,:"~ .~ ~;:1
r....;; ..<
"'~^
f='''''''
'-'
-~
GARY K. DARHOWER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: 2001 - 3334 CIVIL TERM
USA M. DARROWER,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
:SS:
COUNTY OF CUMBERLAND
NOW, Douglas Miller, Esquire, being duly sworn according to law, does depose and state:
1. That he is a competent adult and attorney for the Plaintiff in the captioned action.
2.
That a certified copy of the Complaint was served upon the defendant, Lisa M.
Darhower, June 12, 2001 by certified mail, return receipt requested, addressed to
Lisa M. Darhower at her address at 610 Burgners Road, Carlisle, PA 17013, with
return receipt number 7099 3400 0018 4997 1216.
;,
\
3.
That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa,C.S. Section 4904, relating to unsworn
falsification to authorities.
IRWlN & McKNIGHT
Date: October 13, 2004
By:
Douglas . Mill r, Esquire
Supreme CourtId# 83776
60 West Pomfret Street
Carlisle, P A 17013
(717) 249-2353
Attomey for Plaintiff
Gary K. Darhower
J
~:
'-"'-~_C~:>'W';~!~"'{'~';'.~\ ~-~:., '-"-"'<P''--';<-'',,::'~-- "-.,, ~., 7'"" ~.:_,"- =<-,,"" ,,-- ',' <,"'" , ,-, ,", '. -? -- -',-
, - -, -'''-''~ -
~. ,. ~ ,-, ~,"~< _t'~" C'- ~'~_'~-"'- ;,~,,,'~f)':..,'_ -.' ''"l '
-r_~;~-,~
,.""
.'
. '.',' ,q' ,"," - ,_' - _-<-' ,,,- ,,-', _,_""",'.'~"--__"F "1~"'-"-~ '-
.Compleleilems' ,2,and3: Also'complete
ilem 4 if>RestrictedOelfv8Iy is desired,
. Print your name and address on the reverse
so that we-can return the card to you.
. Attach this car,Ho the back of the mail piece,
or on the front II space permils,
1. Artiale Addressed to:
LISA :III)~WER
610 B'I'/BGNmlS ROAD
CARLISIiE PA 17013
3. Service Type
tl( Certified Mall
o Registered
o Express Mall
.'Return Receipt for Merchandise
Do.O,O,
4. Restricted Delivery? (Extra Fee)
.. Yes
2. Article Number (Copy/rom servlcel8beJ)
7.~'..._7 ."'~
PSFo"",lIlnl JIJlyflll$ . .C . ElIlIn..i\......_jpl
'11l!S.t'tlfl.M-assa
...l]
.-'I
ru
.-'I
Postage $
'"
IT'
IT'
=r
CertifJedFee
..,
.-'I
Cl
Cl
Return f'leceJpt Fee
(Endorsement Required)
estrlcted Delivery Fee
(Endorsement Required)
Postmark
Here
Total Postage & Fees $
t:;I
Cl
~ Recip/ent's Name (Please Print Clearly) (to be completed by mailer)
rr1 LISA :II DARllOWER
rr -St;eet:API~No.;-o;'f:i6'B'p;"No:-".'--_'h__-'h------_m-n----_---_-_____'_m___m___
IT' 610 BURGNERS ROAD
c -CJi;:siiifetzij5+4....u~.u--..".--------",-------------.------h----h.___.________________
'" 7
2
i7_",...,.,,_~,,'
_"',~ .<;,,," -._,~ "."'< . ,-',v""~_,-,~~-:P',',,
'"<,r_,,, ",-,. "'_~"." , -,
,,"
""" ~ '-
"fl,
[1
~
I
ill
f:J
Iii
!~ 1
P1
[:1
I:
F
~i
Iii
1,1,,'1'
i!
f,~'\
1;1
i{:;
H
:i
[1'
III
ii;
[",
l{:T!!!'\!!I1
'"
~ .. " = ~,
'-"-0'
_ - 0 ~,_ ,TIJI J."", "_ '-''"
,
':~
,-,
-~";--r
-I[
LJi:~
CD.
C)
c
(."J
~.
~
,
I' <)
C,::I
r.7.:.:)
..-t:..
c:;
C'')
-~I
c}
-n
(",)
t;~)
_':T't' ~1;:'~, ,:";)e;':P"i:~_\_,;,';'7:__,::"~~~_~~::~T.::.~~J~,~,,~,~},:~}~~[ -1Ir'~~_~~'~
,= ~
GARY K. DARKHOWER
vs.
LISA M. DARROWER
'"
In The Court of Common Pleas of
Cumberland County, Pennsylvania
File No. 2001-3334
STATEMENT OF INTENTION TO PROCEED
To the Court:
Plaintiff, Gary K. Darhower,
intends to proceed with the above captioned matter.
Date: October I, 2004
",'mom";;'
c ~
-- ~
A~l~:t~-J~
Supreme Court I.D. No.: 83776
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
~
,
"'
. .
,
r
""
~
I
1\
! "~"'"!"! ,,--T
,
"1"",-, ,~
m.""'~"'f"~mlil
~N
~, ~'o
:rr1Jt.,~.
" ,~.
Q
:;;;'<:::
~
~
.t:'"
..t::'"
IllIIllr1'r
'"
"",
=
-=-
o
<:-;,
-J
I
o
"f'/
:;J
i'lliJd,-
-om
:;;:10'
OJ..
,-"e'
:r"T'
(5"1'1
'?>(:)
(5"tl
,~-i
$
-<
-
.."
~
,_~~Jij'~@~\'t~":I:"'l"H':\>:;il>il>~~e_>il~~~~~~~~~~", ;}1'Ij1, ,~,,""'-"~,