HomeMy WebLinkAbout01-05965
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA,
DANA L. CARRIERI,
Plaintiff
NO,
01 - 5965 CIVIL TERM
.
VERSUS
DAMIAN CARRIERI,
.
Defendant
.
DECREE IN
DIVORCE
.
AND NOW,
~;\ os-
Dana L. Carrieri
, PLAINTIFF,
~ IS ORDERED AND
.
DECREED THAT
AND
Damian Carrieri
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None
.
The attached Property Settlement Agreement is hereby incorporated, but
.
PROTHONOTARY
not
into this Decree in Divorce.
.
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ATTEST:
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PROPERTY SETTLEMENT AGREEMENT
TIDSAGREEMENT,madethis rill day of ~lJ~ , 2002, by and
between Damian Carrieri, hereinafter called "Husband", an Dana 1. Ceri, hereinafter called
"Wife",
WITNESSETH:
WHEREAS, Husband and Wife were legally married on April 3, 1981;
WHEREAS, three (3) children were born of this marriage;
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and obligations.
NOW THEREFORE, in consideration of the premises and covenants contained herein, it is
agreed by and between the parties hereto that:
1. SEPARATION.
It shall be lawful for each party at all times hereafter to live separate and apart from each
other at such place as he or she from time to time shall choose or deem fit. The foregoing provision
shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of
the causes leading to their living apart.
2. INTERFERENCES.
Each party shall be free from interference, authority and control by the other, as fully as if
he or she were single and unmarried, except as may be necessary to carry out the provisions of this
Agreement. Neither party shall molest or-lf'ttempt to endeavor to molest the other, or in any way
harass or malign the other, nor in any other way interfere with the peaceful existence, separate and
apart from the other,
3. DIVISION OF REAL PROPERTY.
Husband agrees to transfer all his right, title and interest in and to the real estate located at
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403 Huron Drive, Mechanicsburg, Cumberland County, Pennsylvania, now titled in the name of
Husband and Wife. Husband shall execute a Deed at the time of the execution of this Agreement
which shall be held in escrow by counsel for Wife, John J. Connelly, Jr., Esquire, pending the
refinancing of the marital residence the details of which are set forth herein,
Wife has applied to refinance the existing home mortgage in her name individually thereby
releasing her Husband from any further liability, It is anticipated by the parties that the said
refmancing shall occur on or before February I, 2002. The parties agree that the Deed, being held
in escrow by counsel for Wife, shall be released to Wife at the time of the refinancing,
Husband has agreed to pay all household related expenses including the home mortgage
through the month of January 2002, Thereafter,Wife shall indemnify and hold Husband harmless
on any obligations relating to the said real estate.
Husband has agreed that he shall vacate the marital residence on or before February 1,
2002,
4. DIVISION OF PERSONAL PROPERTY.
The parties have divided between them to their mutual satisfaction, personal effects,
household goods and furnishings and all other articles of personal property which have heretofore
been used in common by them, and neither party will make any claim to any such items, It is
anticipated that at the time Husband moves from the marital residence the items agreed upon
between the parties to be Husband's sole and separate property will be removed by him at that time.
5. CUSTODY AND VISITATION.
The parties have agreed that the parties' minor children, Ashley M. Carrieri and Matthew
W. Carrieri, shall remain in the primary custody of Wife at the marital residence of the parties.
Husband shall have liberal partial custody rights. The parties shall take into account the requests
and preferences of the minor children when setting up the partial custody schedule. In the event the
parties cannot agree on this issue, the matter can be presented to the Court.
6. SUPPORT.
The parties shall attempt to resolve the support issues between themselves on a negotiated
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basis, In the event child support cannot be agreed upon Wife shall file an action with the Court of
Common Pleas of Cumberland County, Pennsylvania to establish an Order for child support.
Husband further agrees that he shall maintain the children on his medical insurance as
supplied through his employer.
7, EOUlTABU~ DISTRIBUTION.
Husband agrees to pay to Wife in the form of equitable distribution the sum of Forty Three
Thousand Five Hundred Sixty Eight ($43,568.00) Dollars. This sum should be rolled over from
Husband's AG, Edwards IRA rollover account to an IRA designated by Wife which she anticipates
opening at AG. Edwards for convenience of transfer, Counsel for Wife shall prepare, if necessary,
a Domestic Relations Order permitting the transfer in a tax exempt manner. It is anticipated that
the parties may accomplish this transfer without a need for a Court Order. However, if one is
necessary it shall be provided promptly to AG, Edwards.
8. PENSIONS.
Each party shall retain as their sole and separate property any pension benefits in their own
name including, but not limited to, lRAs, 401(k) plans, 403(b) plans or other pension benefits.
As indicated previously, Husband has an IRA with A,G. Edwards and with the exception of
the rollover set forth above, Husband shall retain that IRA as his sole and separate property. He
shall also retain his pension and 401(k) plan with Roadway.
Wife shall retain as her sole and separate property her pension plan with Pinnacle Health as
well her 403(b) plan with the same employer and any other IRAs or rollovers in her own name
individually,
9. MOTOR VEIDCLES.
Wife shall retain the 1993 Jeep Cherokee as her sole and separate property and Husband
shall retain the 2000 Pontiac Van and shall assume sole responsibility for the loan with GMAC.
Husband shall indemnify and hold Wife harmless of the said obligation and to the extent he is able,
will remove Wife's name from the said obligation should it appear, The parties agree to execute
any and all documents necessary to accomplish the terms of this paragraph,
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10. CREDIT CARDS.
Each party retains a Master Card in their own name individually with a balance due of
approximately $5,000.00. Each shall assume sole responsibility for the credit card in their name
individually.
11. UGMA ACCOUNTS.
Husband shall retain responsibility for the administration of the UGMA accounts for the
benefit of the minor children. It is the intent of the parties for these monies is to be used for the
children's education and Husband assumes responsibility for applying those funds appropriately,
12. LIFE INSURANCE.
Each party shall retain any life insurance policies in their names individually including any
cash value related thereto.
13. 2001 TAX RRTURN.
The parties agree that they will file joint Federal and Commonwealth of Pennsylvania Tax
Returns for the tax year 2001 and will divide any refunds equally.
14. BRRACH.
If either party breaches any provision of this Agreement, the other party shall have the right,
at his or her election, to sue for damages for such breach. The party breaching this contract shall be
responsible for the payment oflegal fees and costs incurred by the other in enforcing his or her
rights under this Agreement, or seeking such other remedy or relief as may be available to him or
her.
15. FULL DISCLOSURE.
Husband and Wife each represent and warrant to the other that he or she has made a full and
complete disclosure to the other of all assets of any nature whatsoever, and of all other facts relating
to the subject matter of this Agreement to which such party may reasonably require to make an
informed decision regarding this Agreement.
16. ADDITIONAL INSTRUMRNT.
Each of the parties shall on demand execute and deliver to the other any documents
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necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party
fails on demand to comply with this provision, that party shall pay to the other all attorneys' fees,
costs and other expenses reasonably incurred as a result of such failure.
17. WIFE'S DEBTS.
Wife represents and warrants to Husband that since the parties' separation she has not and in
the future she will not contract or incur any debt or liability for which Husband or his estate might
be responsible and 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.
18. HUSBAND'S DEBTS.
Husband represents and warrants to Wife that since the parties' separation he has not and in
the future he will not contract or incur any debt or liability for which Wife or her estate might be
responsible and 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.
19. WAIVERS 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, curtsy,
statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of
the other, and right to act as administrator or executor of the other's estate, and each will, to the
request of the other, 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.
20. REPRESENTATION.
It is recognized by the parties hereto that Dana 1. Carrieri is represented by John J.
Connelly, Jf., Esquire, and Damian Carrieri is represented by Jay R, Braderman, Esquire. It is fully
understood and agreed that by the signing of this Agreement, each party understands the legal
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impact of this Agreement and further acknowledges that the Agreement is fair and reasonable and
each party intends to be legally bound by the terms hereof.
21. VOI"UNTARYEXECUTION.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and
that it is not the result of any duress or undue influence.
22. ENTIRE AGREEMENT.
This Agreement contains the entire understanding of the parties and there are no
representations, warranties, covenants or undertakings other than those expressIy set forth herein.
23. PRIOR AGREEMENT.
It is understood and agreed that any and all property settlement agreements which mayor
have been executed prior to the date and time of this Agreement are null and void and of no effect.
24. MODIFICATION AND WAIVER.
Any modification or waiver of any provision of this Agreement shall be effective only if
made in writing and executed with the same formality as this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of this Agreement shall not be
construed as a waiver of any subsequent default of the same or similar nature,
25. GOVERNING LAW.
This Agreement shall be governed by and shall be construed in accordance with the laws or"
the Commonwealth of Pennsylvania,
26. INDEPENDENT SEPARATE COVENANTS.
It is specifically understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent covenant and agreement.
27. VOID CI,AUSES.
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
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valid and continue in full force, effect and operation.
28. ENTRY AS PART OF DECREE.
It is the intention of the parties that this Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order, judgment or decree of divorce,
temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This
Agreement shall be made a part of, but shall not merge with, any such judgment or decree of final
divorce,
29. DIVORCE ACTION.
The parties shall, at the time of the execution of the Agreement, execute documents
necessary to finalize the divorce action including, but not limited to, the withdrawal of any claims
pending under said action, indexed to number 01-5965, in the Court of Common Pleas,
Cumberland County, Pennsylvania, as well as Affidavits of Consent and Waivers of Counseling
and Waivers of Notice ofIntention to Request Entry of a Divorce Decree.
30. DOMESTIC RELATIONS CODE OF TIJ]i; COMMONWEALTH OF
PENNSYLVANIA.
Except as specifically provided in this Agreement, each party waives any claim they may
have against the other under the Domestic Relations Code of the Commonwealth of Pennsylvania
including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable
distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
hereunto set their hands and seals the day and year first above written,
J)a,~,\~:
Damian Carrieri
J ~ J J- CiOIlMM /
D a L. Carrieri
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COMMONWEALTH OF PENNSYL V AN1A
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COUNTY OF DAUPHIN
On this, the /~ii day of ce: ~ ' 2002, before me, a Notary Public,
personally appeared Damian Carrieri, own to me be the person whose name is subscribed to
the within Property Settlement Agreement and acknowledged that he executed the same for the
purposes therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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NOTAR UBL
NOTARIAL SEAL
Jean L. Kosier, Notary Public
City of Hummelstown,County of Dauphin
My Commission Expires Feb. 9, 2004
COMMONWEALTH OF PENNSYL VANIA
ss.
COUNTY OF DAUPHIN
On this, the IY A day Of~ /Juj.li. .k :t: ,2002, before me, a Notary Public,
personally appeared Dana 1. Carrieri, known to me be the person whose name is subscribed to
the within Property Settlement Agreement and acknowledged that she executed the same for the
purposes therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
,
NOTARIAL SEAL,
Jean L. Kosier, Notary Public
City of Hummelslown,Counly of Dauphin
My Commission Expires Feb. 9, 2004
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DANA L. CARRIER!,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v,
: NO. 01-5965 CIVIL TERM
DAMIAN CARRIER!,
Defendant
: CIVIL ACTION - LAW
: 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 (XX) 3301(c) ()
3301(d) of the Divorce Code,
2. Date and manner of service of the Complaint: October 22, 200 I by Certified Mail
No. 70001670001116980070.
3. Complete either paragraph (a) or (b),
(a) Date of execution of the Affidavit of Consent and Waiver of Counseling
required by Section 3301(c) of the Divorce Code: by Plaintiff: January 23,2002 by Defendant:
January 23, 2002.
(b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of
the Divorce Code:
(2) Date of service ofthe Plaintiff's Affidavit upon the Defendant:
4, Related claims pending: All claims of record have been resolved and settled pursuant to
a Property Settlement Agreement dated January 18, 2002.
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5. Date and manner of service of Notice ofIntention to file Praecipe to
Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d)
of the Divorce Code:
or, date of execution of Waiver of Notice ofIntention to Request Entry of a Divorce Decree
under Section 3301(c) of the Divorce Code: by Plaintiff: January 23, 2002; by Defendant: January
23,2002.
and, date of filing of the Waiver of Notice ofIntention to Request Entry of a Divorce
Decree: Both Waivers are being filed simultaneously with this Praecipe.
JAMES, SMITH, DURKIN & CONNELLY LLP
Date: OJ - c43 - ()J..
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DANA 1. CARRIERI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
v.
: NO. 01 - 69'-S
CLULL'-r~
DAMIAN CARRIERI,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following papers, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a Decree in Divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other rights important to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or Irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle,
Pennsylvania.
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
Phone: (717) 249-3166
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. 01- Q~u~L T~
DANA 1. CARRIERI,
Plaintiff
DAMIAN CARRIERI,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
To the Within Narned Defendant:
You have been named as the Defendant in a divorce proceeding filed in the Court of
Common Pleas of Cumberland County. This notice is to advise you that in accordance with
Section 3302( d) of the Divorce Code, you may request that the Court require you and your spouse
to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of
professional marriage counselors is available at the Office of the Prothonotary, One Courthouse
Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from this list. All necessary arrangements and the cost of
counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
Prothonotary
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. OI-S1(eo Cu'l.l<-r~
DANA 1. CARRIERI,
Plaintiff
DAMIAN CARRIERI,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
I. Plaintiff is Dana 1. Carrieri, who currently resides at 403 Huron Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is Damian Carrieri, who currently resides at 403 Huron Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 3, 1981, in Altoona, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The Plaintiff is a citizen of the United States of America.
7. The Defendant is not a member of the Armed Services of the United States of
America or its Allies.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
The parties to this action have been separated since July of 200 I.
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10. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the
marriage between the Plaintiff and Defendant.
JAMES, SMITH, DURKIN & CONNELLY
Date \a\ t "-10 I
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VERIFICATION
I verifY that the statements made in this Pleading 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 falsification to authorities.
Date:~I2-/o I
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DANA 1. CARRJERJ,
Plaintiff
: IN THE COURT OF COMMON P!:'EAS
: CUMBERLAND COUNTY, PENNSYL V ANJA
v.
: NO. 01-5965 CML
DAMIAN CARRJERJ,
Defendant
: CML ACTION - LAW
: IN DIVORCE
AFFJDA VIT OF SERVICE
COMMONWEALTH OF PENNSYL VANIA
: ss.
COUNTY OF DAUPHIN
AND NOW, this !l1.1:L day of ~
, 2001, personally appeared before
me, a Notary Public in and for the State and County aforementioned, John 1. Connelly, Jr., Esquire,
who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce
was served on the Defendant, Damian Carrieri, on October 22, 2001 by certified mail number 7000
1670 00 II 1698 0070, as evidenced by the return receipt card attached hereto and made a part
hereof.
Sworn to and subscribed
before me this ~1J:l
day of ~ ,2001.
NOTARIAL SEAL
. Jean L. Kosier. Notary Public
City of Hummelstown,County of Dauphin
My Commission Expires Feb. 9, 2004
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DANA L. CARRJERJ,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
v.
: NO. 01-5965
DAMIAN CARRJERJ,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance as attorney for Defendant, Damian Carrieri, in the
above captioned matter.
Date:
17108-1489
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DANA 1. CARRIERI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01 - 5965 CIVIL TERM
DAMIAN CARRIERI,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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WAIVER OF NOTICE OF INTENTION TO REQ1JEST ENTRY OF A DIVORCE
DECREE UNDER ~3301(c) OF THE DIVORCE CODE
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I consent to the entry of a final Decree of Divorce without notice.
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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.
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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
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Prothonotary.
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I verifY that the statements made in this Affidavit are true and correct. I understand that
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Date: 0/-;' 8 -Od-
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Dana 1. Carrieri, Plaintiff
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DANA 1. CARRIERI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01 - 5965 CIVIL TERM
DAMIAN CARRIERI,
Defendant
: CML ACTION - LAW
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 162001
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of Notice of Intention
to request entry of the Decree.
4. I haw 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. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
I verifY that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Date: () / - ~3 -() d..
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DANA 1. CARRIERI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01 - 5965 CIVIL TERM
DAMIAN CARRIERI,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S AFFJDA VIT OF CONSENT
AND WAIVER OF COlJNSEI,ING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 16 2001
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3. I consent to the entry of a fmal decree of divorce after service of Notice ofIntention
to request entry of the Decree.
4. 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. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
I verifY that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to
unsworn falsification to authorities.
DO/VM-M~ d~~
Damian Carrieri, Defendant
Date: OI-~!rO~
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DANA 1. CARRIERI,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01 - 5965 CIVIL TERM
DAMIAN CARRIERI,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER ~3301(J;) 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 ifI 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 are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Date: J/- /1,j-Dbl..
j)fVvY'~ ~
Darnian Carrieri, Defendant
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. DI - 6'i~ C,~~l ~'J
: CIVIL ACTION - LAW
: IN DIVORCE
DANA 1. CARRIERI,
Plaintiff
DAMIAN CARRIERI,
Defendant
Dana 1. Carrieri, social security no. 190-58-4199
Damian Carrieri, social security no. 186-52-7610
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