HomeMy WebLinkAbout01-06584
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
BRUCE A. DOOLITTLE
No. 01 fi'lR4
VERSUS
BONNIE L. DOOLITTLE
DECREE IN
DIVORCE
AND NOW,
fr}~
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UO Z-; IT IS ORDERED AND
OECREED THAT
BRUCE A. DOOLITTLE
, PLAINTIFF,
AND
BONNIE L. DOOLITTLE
, 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;
THE MARITAL SETTLEMENT AGREEMENT EXECUTED BETWEEN THE PARTIES .
SHALL BE INCORPORATED INTO THE FINAL DIVORCE DECREE
J.
PROTHONOTARY
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT OF
BRUCE A. DOOLITTLE AND BONNIE L. DOOLITTLE
TillS AGREEMENT, made this r;;.~ff7 ' day of Atr t I
between Bruce A. Doolittle, hereinafter referred to as "Husband", and
hereinafter referred to as "Wife".
2002, by and
Bonnie L. Doolittle
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on 16th day of January 1998; and
WHEREAS, certain differences have arisen between the parties as a result of which they have
separated and now live separate and apart from one another, and are desirous, therefore, of entering into
an agreement which will provide for support, distribute their marital property, and will provide for their
mutual responsibilities and rights growing out of the marriage relationship; and
WHEREAS, the parties hereto, after being properly advised, have come to the following
agreement.
NOW, THEREFORE, in consideration of the above recitals and the following covenants and
promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and
to legally bind their heirs successors and assigns thereby, covenant, promise and agree as follows:
1. SEPARATION:
It shall be lawful for each party at all times hereafter to live separate and apart from the other at
such place or places as he or she may from time to time choose or deem fit.
2. INTERFERENCE:
Each party shall be free from interference, authority and contact by the other as fully as if he or she
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was single alld unmarried, except as may be necessary to carry out the provisions of this Agreement.
Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to
cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the
peaceful existence, separate and apart from the other in all respects as if he or she were single and
unmarried
3. WIFE'S DEBTS:
Wife represents and warrants to Husband that since their 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 shall indemnify and save Husband harmless from any and all claims and demands
made against him by reasons of debts or obligations incurred by her.
4. HUSBAND'S DEBTS:
Husband represents and warrants to Wife that since their 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 shall
indemnify and save Wife harmless from any and all claims and demands made against her by reasons of
debts or obligations incurred by him.
5. OUTSTANDING JOINT DEBTS:
Husballd and Wife agree that they have no outstanding debts and obligations of the Husband and
Wife incurred prior to the signing of this Agreement that are not otherwise specifically addressed by
provision of this Agreement. In the event that either party contracted or incurred any debts since the date
of separation, any party who incurred said debt shall be responsible for the payment thereof regardless of
the name in which the aCcount may have been charged.
6. MUTUAL RELEASE:
Subject to the provisions of this Agreement, each party waives his or her right to alimony and any
further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an
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equitable distribution of their marital property in accordance with the Divorce Code of 1980, as amended.
Subject to the provisions of this Agreement, each party has released and discharged, and by this
Agreement does for himself or herself, and his or her heirs, legal representatives, executors,
administrators and assigns, release and discharge the other of and from all causes of action, claims, rights
or demands whatsoever in law or equity, which either of the parties ever had or now has against the other,
except any or all cause or causes of action for divorce and except in any or all causes of action for breach
of any provisions of this Agreement. Each party also waives his or her right to request marital counseling
pursuant to Section 202 of the Divorce Code.
7. EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY:
The parties have attempted to distribute their marital property in a manner which conforms to the
criteria set forth in Section 401 of the Pennsylvania Divorce Code, and taking into account the following
considerations: the length of ~e marriage; the age, health, station, amount and sources of income,
vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each
party to the education, training or increased earning power of the other party; the opportunity of each
party for future acquisitions of capital assets and income; the sources of income of both parties' including
but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each
party in the acquisition, preservation, depreciation or appreciation of the marital property, including the
contribution of each spouse as a homemaker; the value of the property set apart to each party; the
standard of living of the parties established during the marriage; and the economic circumstances of each
party at the time the division of property is to become effective.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets, funds or other property not constituting marital property. The division of
property under this Agreement shall be in full satisfaction of all marital rights of the parties.
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A. DISTRIBUTION OF PERSONAL PROPERTY
The parties hereto mutually agree that they have effected a satisfactory division of the furniture,
household furnishings, appliances, and other household personal property between them, and they
mutually agree that each party shall from and after the date hereof be the sole and separate owner of all
such tangible personal property presently in his or her possession except to the extent otherwise provided
within this document.
Except as otherwise provided by the tenns of this Agreement, the parties hereto have divided
between themselves, to their mutual satisfaction, all items of tangible and intangible marital property.
Neither party shall make any claim to any such items of marital property of either party, which are now in
the possession and/or under the control of the other. Should it become necessary, the parties each agree
to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be
deemed to be in the possession or under the control of either party if, in the case of tangible personal
property, the item is physically ,in the possession or control of the party at the time of the signing of this
Agreement and, in the case of intangible personal property, if any physical or written evidence of joint
ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in
the possession or control of the party. Husband and Wife shall each be deemed to be in the possession
and control of his or her own individual pension or other employee benefit plans or retirement benefits of
any nature with the exception of Social Security benefits to which either party may have vested or
contingent right or interest at the time of the signing of this Agreement, and neither will make any claim
against the other for any interest is such benefits.
From and after the date of the signing of this Agreement, both parties shall have complete freedom of
disposition as to his/her separate property and any property which is in their possession or control
'pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise encumber or dispose of
such property, whether real of personal, whether such property was acquired before, during or after the
marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or
other instrument of the other pertaining to such disposition of property.
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8. REAL PROPERTY
The parties are neither the legal nor equitable owners of any real property that would otherwise be
subject to division and distribution.
9. MOTOR VEmCLES:
The parties hereby agree that the party in whose possession there remains a Motor Vehicle shall
continue to own this motor vehicle free and clear from any claims legal or equitable that the other party
may assert. To the extent the vehicle in possession of either or both parties in is both parties names then
the party relinquishing ownership shall sign title of said vehicle over into the other spouses name.
All existing automobile insurance policies that are jointly held shall be transferred to the respective
party's individual names and each will assume sole fmancial responsibility for payment to the same.
10. SUPPORT: ~
Husband agrees to pay to Wife Suppor! which shall end on October 15th 2002 in the amount as
established by Domestic Relations of Cumberland County on the 31st day of August 2001. Wife upon the
signing of this document agrees, covenants, and promises that she shall relinquish, release and waive all
claims against Husband for support and the same shall cease entirely including but not by way of
limitation Alimony, Spousal Support, Alimony Pendente Lite and any and all other forms of legal and/or
equitable support except as outlined herein. Husband upon the signing of this document agrees,
covenants, and promises that she shall relinquish, release and waive all claims against Wife for support
and the same shall cease entirely including but not by way of limitation Alimony, Spousal Support,
Alimony Pendente Lite and any and all other forms oflegal and/or equitable support
11. BANK ACCOUNTS/PENSION PLANS:
The parties release any interest in the opposite spouse's Pensions, bank accounts, stocks, bonds, or
any other tangible or intangible assets wheresoever located and accumulated prior to, during, and/or
subsequent to the dissolution of their marriage. All existing bank accounts shall closed and accounts
thereafter shall be kept in each of the party's separate names.
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12. COUNSEL FEES AND EXPENSES:
Husband and Wife Acknowledge and agree that the provisions of this Agreement providing for the
equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both
parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement
and satisfaction of all claims and demands that either may now or hereafter have against the other for
alimony pendente lite, counsel fees or expenses or any other provisions for their support and maintenance
before, during and after the commencement of any proceedings for divorce or annulment between the
parties.
13. 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 estate of the other
as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance,
widOW'S allowance, intestate share, right to take against the will of the other, and right to act as
administrator or executor of the others estate. 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.
14. SUBSEOUENT DIVORCE:
. Husband intends to file a no-fault compla~st Wife. Husband and Wife each agree
to jurisdiction of the Court of Common Pleas oLe J ___rMl County and further agree to sign an affidavit of
consent to be f1led in said divorce action. In the event such divorce action is concluded, the parties shall
be bound by all the terms of this Agreement which may be incorporated by reference into the Divorce
Decree, shall not be merged into the Divorce Decree, and shall not be modified, but shall in all respects
survive the same and be further binding and conclusive upon the parties. It is the intention of the parties
that the Agreement shall survive any action for divorce which may be instituted and prosecuted by either
party and no order, judgment or decree of divorce, temporary, final or permanent shall affect or modify
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the financial terms of this Agreement. This Agreement may be incorporated in but shall not merge into
any such judgment or decree of fmal divorce, but shall be incorporated for the purposes of enforcement
only.
15. BREACH AND ENFORCEMENT:
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, or seek other such remedies or relief as may be
available to him or her, and the party breaching this Agreement should be responsible for payment of
legal fees and costs incurred by the other in enforcing his or her rights under this Agreement.
A. It is expressly understood and agreed by and between the parties hereto that this Agreement
may be specifically enforced by either Husband or Wife in Equity, and the parties hereto agree that if an
action to enforce this Agreement is brought in Equity by either party, the other party will make no
objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an
adequate remedy at law. the parties to not intend or purport hereby to improperly confer jurisdiction on a
Court in Equity by this Agreement, but they agree as provided herein for the forum of Equity in mutual
recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in
Equity over agreements such as this one,
B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an
action at law for redress of his or her rights under the terms of this Agreement, and in such event it is
specifically understood and agreed that for and in specific consideration of the other provisions and
covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and
disposition of such case and so as to avoid delay.
C. Each party further hereby agrees to pay and to save and hold harmless the other party from any
and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any
way wllatsoever, or shall pay upon, or in consequence of any default or breach by the other of any of the
terms or provisions of this agreement by reason of which either party shall be obliged to retain or engage
counsel to initiate or maintain or defend proceedings against the other at law or equity or both in any way
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whatsoever; provided that the party seeks to recover such attorney's fees, and costs of litigation must first
be successful in whole or in part, before there would be any liability for attorney's fees and costs of
litigation. It is the specific agreement and intent of the parties that a breaching or wrongdoing party shall
bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or
herself as well as the other party in endeavoring to protect or enforce his or her 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. VOLlJNTARY EXECUTION:
The provisions of this Agreement and their legal effect have been completely reviewed by the
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into
voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or
undue influence. The parties acknowledge that they have been fumished with all information relating to
the financial affairs of the other which has been requested by each of them.
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. Husband and Wife
acknowledge and agree that the provisions of this Agreement with respect to the division and distribution
of marital and separate property are fair, equitable and satisfactory to them based on the length of their
marriage and other relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in
full and final settlement and satisfaction of all claims and demands that they may now have or hereafter
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have against the other for equitable distribution of their property by any court of competent jurisdiction
pursuant to Section 401(d) of the Divorce Code or any other laws. Husband and Wife voluntarily and
intelligently waive and relinquish any right to seek a court ordered determination and distribution of
marital property, but nothing herein contained shall constitute a waiver by either party of any rights to
seek the relief of any court for the purpose of enforcing any provision of this Agreement.
19. 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 party of all assets of any nature whatsoever in which such party has an
interest, the sources and amount of the income of such party or every type whatsoever and of all other
facts relating io the subject matter of this Agreement.
20, MODIF1CATION AND WAIVER:
A modification and waiver of any of the provisions 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.
21. 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.
22. DESCRJPTIVE HEADINGS:
The descriptive headings used herein are for convenience only. They shall have no effect
whatsoever in determining the rights or obligations of the parties.
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23. INDEPENDENT SEPARATE COVENANTS:
It is specifically understood and agreed by and between the parties hereto that each paragraph
hereof shall he deemed to be a separate and independent covemmt and agreement.
24. APPLICABLE LAW:
This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania.
25. VOID CLAUSES:
If any terms, conditions, 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.
26. AGREEMENT BINDING ON HEIRS:
This Agreement shall be binding and shall inure to the benefit of the parties hereto and their
respective heirs, executors, administrators, successors and assigns.
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IN WITNESS WHEREOF, the parties hereto have set their hand and seals the day and year first above
written.
-::n(\\IC'. IQY~
Bruce A. Doolittle
Commonwealth of Pennsylvania
County of Cumberland
On this, the ;'6 ~ ,day of / J A.D. 2oal. before me a Notary Public
Bruce A. Doolittle, known to me (or satis actorily proven) to be the person whose name is subscribed to
the within instrument, and acknowledged that he executed the same for the purposes therein contained.
Notarial Seal
Kenneth L. Schlegel, Notary Public
Hampden Twp., Cumberland County
My Commission Expires Apr. 4, 2005
Member, Pennsylvania Association of Notaries
IN WITNESS WHEREOF, the parties hereto have set their hand and seals the day and year first above
written.
Seal
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Bonnie L. Doolittle
Commonwealth of Pennsylvania
County of f q,.
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On this, the IS ,day of~A.~. 2001, before me a Notary Public al!peared.
Bonnie L. Doolittle, known to me (or satlsfactonly proven) to be the person. whose name IS subscrIbed
'to the within instrument, and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Seal
[)4/ . ~~MYJM-
Title of Officer
NOTARIAL SEAL .
ELLEN ROSENBLOOM, Notary PubliC
CitY of Harrisburg, Dauphm Coun
Mv COiM1illllien ISK Ires Ma
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYLVANIA
Bruce A. Doolittle,
PLAINTIFF,
Civil Action---Divorce
Docket No. 01-6584
VS.
Bonnie L. Doolittle,
DEFENDANT,
PRAECIPE TO TRANSMIT THE RECORD
To the Prothonotary:
Please Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(C) of the Divorce Code.
2. The complaint in Divorce was filed on the 21st day of November 2001 and served by
Acceptance of Service dated December 4th 2001. (Attached hereto)
3 The plaintiff, signed his Affidavit of Consent and Waiver of Notice of Entry of a Divorce
Decree on the 25th day of April 2002 which is attached hereto.
4. The plaintiff served his affidavit of consent, Counter-Affidavit, and Waiver of Notice of Intent
to request Divorce Decree on defendant on the 5th day of April, 2002
and the same was signed by defendant on the 11th, day of April 2002.
5. There are no related claims pending as between the parties hereto and listed herein to the
extent that all marital issues have been settled by way of a Marital Settlement Agreement which
was executed on the 26th day of April 2002.
6. The defendant signed a Waiver of Notice of Intention to Request Entry of Divorce Decree on
the 11th day of April 2002 pursuant to Rule 1920.72 a copy of which is attached hereto
Date: 'i (solo:;..
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,
PENNSYL VANIA
BRUCE A. D&ITTLE,
No.
ol-(p5S4 ~
PLAINTIFF,
Civil Action---Divorce
V.
BONNIE L. DOOLITTLE,
DEFENDANT,
NOTICE TO DEFEND AND CLAIM OF RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail
to do so, the case may proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY
OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, Pennsylvania 17101
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
,
PENNSYLVANIA
BRUCE A. DOOLITTLE,
No.1lJ -(R 1) z tf W
PLAINTIFF,
Civil Action----Divorce
V.
BONNIE L. DOOLITLE,
DEFENDANT
A VlSO PARA DEFENDER Y RECLAMAR DERECHOS
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas
expuestas en las paginas siguientes, debe tomare accion con prontitud, Se Ie avisa que si
no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulaminento
puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en
su contra por cualquier otra queja 0 compensacion reclamados por el demandante. Usted
puede perder dinero, 0 propiedades u otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del
matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros
matrimoniales estll disponible en la officina del Prothonotary, en la Cumberland County
Court of Common Pleas, 1 Courthouse Square, Carlisle, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL.
HONORARIOS DEABOGADO U OTROS GASTOS ANTES DE QUE EL
DECRETO FINAL DE DIVORCIO 0 ANULIAMIENTO SEA EMITIDO. USTED
PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBELLEV AR ESTE P APELA UN ABOGADO DE INMEDIATO SI NO
TIENE 0 NO PUEDEPAGAR UN ABOGADO. V AYA 0 LLAME A LA
OFFICINA INDlCADA ABAJO PARA A VERIGUAR DONDE PUEDE
OBTENER ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LmERTY AVENUE
Carlisle, Pennsylvania 17101
(717) 249-3166
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AVAILABILITY OF COUNSELING
THE DIVORCE COIDE OF PENNSYLVANIA REQUIRES THAT YOU BE
NOTIFIED OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE
IS SOUGHT UNDER ANY OF THE FOLLOWING GROUNDS:
23 Pa.C.S. & 3301(a)(6)-------Indignities
23 Pa.C.S. & 3301(c)----------Irretrievable Breakdown; Mutual Consent
23 Pa.C.S. & 3301(d)----------Irretrievable Breakdown; Two year separation where the
court determines that there is a reasonable prospect of
reconciliation.
A list of marriage counselors is available in the Office ofthe Prothonotary
Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania
17013.
HAZLETT & OESTERLING
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
BRUCE A. DOOLITTLE,
No.J)j ,(a:58Lf
PLAINTIFF,
Civil Action----Divorce
VS.
BONNIE L. DOOLITTLE,
DEFENDANT,
COMPLAINT UNDER SECTION
3301 (C) OR 3301(D) OF THE DIVORCE CODE
PARTIES
1. Plaintiff is Bruce A. Doolittle, an adult individual, sui juris and who currently resides
at 19 East Main Street, Mechanicsburg, 17055 County of Cumberland, Commonwealth of
Pennsylvania
2. Defendant, is Bonnie L. Doolittle, an adult individual, sui juris, who currently resides
at 922 East Oak Street, Pahnyra 17078 County of Lebanon, Commonwealth of
Pennsylvania.
JURISDICTION & VENUE
3. Plaintiff has been a resident of the Commonwealth of Pennsylvania for a period of
more than 6 months.
4. The parties were married on the 16th day of January 1998, in Dauphin, Pennsylvania.
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5. Neither the Plaintiff nor the Defendant is in the military or naval service of the United
States or its allies within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of
The Congress of 1940 and its amendments.
6. There have been no prior actions for divorce or annulment instituted by either party
against the other in this or any other jurisdiction.
GROUNDS FOR DIVORCE
COUNT I
REOUEST FORA NO-FAULT DIVORCE UNDER SECTION 3301 (C) OF THE
DIVORCE CODE.
7. The prior paragraphs are incorporated herein by reference.
8. The marriage between the Plaintiff and Defendant is irretrievably broken.
After (90) days have elapsed from the date of the filing of this Complaint, plaintiff
intends to file an affidavit consenting to a divorce.
WHEREFORE, if the parties file affidavits consenting to a divorce after ninety (90)
days have elapsed from the date of the filing and the serving of this Complaint, plaintiff
respectfully requests the Court to enter a decree of divorce pursuant to section 3301(c) of
the Divorce Code.
COUNT II
REOUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (D) OF THE
DIVORCE CODE.
8. The prior paragraphs shall be incorporated herein as if fully set forth.
9. For the purposes of section 3301 (d) of the Divorce Code, the parties have been
separated since October 15th 2000.
10. The marriage is irretrievably broken.
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11. Plaintiff has been advised that counseling is available and that the plaintiff may have
the right to request that the court require the parties to participate in counseling.
12. In the event that consent from the defendant is forthcoming Plaintiff shall seek a
unilateral divorce pursuant to and in conformity with section 3301 (d) of the Divorce
Code subsequent to the filing of this Complaint upon the expiration of 2 years from the
aforementioned date of separation if consent is not forthcoming pursuant to 3301 (C).
13. The parties do not have any biological children under the age of majority.
WHEREFORE, if plaintiff request the Honorable Court to enter a Divorce Decree
under section 3301 (d) upon the expiration of two (2) years from the aforementioned date
of separation.
HAZLETT & OESTERLING
ATTORNEYS AT LAW
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VERIFICATION
I verify that upon personal knowledge or information and belief 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. & 4904, relating to unsworn falsification
to authorities.
Dfh~(\,) C':])"j)ito.
Plaintiff
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AMERICAN 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 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.
BY THE COURT:
Date:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYL VANIA
BRUCE A. DOOLITTLE,
Civil Action---Divorce
PLAINTIFF
Docket No. 01-6584
vs.
BONNIE L. DOOLITTLE,
DEFENDANT
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on
November 21 st 2001, and served upon defendant on by way of an Acceptance of Service
on 2ih day of November 2001 and the same was executed by defendant on the lfib-,
day of 'r>" u~2001. (Attached hereto).
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2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
Elapsed from the date of service of the divorce Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyers
Fees or expenses if! 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 are made subject to the penalties of 18 Pa.
Cons. Stat. S 4904 relating to unsworn falsification to authorities.
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Bruce A. Doolittle, Plaintiff
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IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY,
COMMONWEALTH OF PENNSYLVANIA
BRUCE A. DOOLITTLE,
Plaintiff,
No. 2001-6584
v.
Civil Action - Divorce
BONNIE L. DOOLITTLE,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A
DVORCE DECREE UNDER ~ 330UCl OF THE DIVORCE CODE
I. 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 inunediately 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. Section 4904 relating to unsworn
falsification to authorities.
Date: ~ 25) D'2..
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Bruce A. Doolittle, Plaintiff
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IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY,
COMMONWEALTH OF PENNSYLVANIA
BONNIE L. DOOLITTLE,
Plaintiff,
No. 2001-6584
v.
Civil Action - Divorce
BRUCE A. DOOLITTLE,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A
DVORCE DECREE UNDER ~ 330UCl OF THE DIVORCE CODE
I. I consent to the entry of a fmal decree of 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 1:Jefore 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 inunediately 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. Section 4904 relating to unsworn
falsification to authorities.
Date: .1/-//-02-
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Bonnie L. Doolittle, Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYL VANIA
BRUCE A. DOOLITTLE,
Civil Action---Divorce
PLAINTIFF
Docket No. 01-6584
VS.
BONNIE L. DOOLITTLE,
DEFENDANT
AFFIDAVIT OF CONSENT
1. A complaint in divQrce under Section 330l(c) of the Divorce Code was filed on
November 21 ,t 2001, and served upon defendant on by way of an Acceptance of Service
on 27th day of November 2001 and the same was executed by defendant on the!:tflL,
day of ~.l . -."t;; 2001. (Attached hereto).
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2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
Elapsed from the date of service of the divorce Complaint.
3. I consent to the entry of a fmal decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyers
Fees or expenses if! 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 are made subject to the penalties of 18 Pa.
Cons. Stat. S 4904 relating to unsworn falsification to authorities.
Date:ij-/I-o~
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Bonnie L. Doolittle Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
COMMONWEALTH OF PENNSYLVANIA
BRUCE A. DOOLITTLE
Plaintiff,
No. Ol-6584-CIVIL
v.
Civil Action - Divorce
BONNIE L. DOOLITTLE
Defendant
ACCEPTANCE OF SERVICE
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I Bonnie L. Doolittle, accept service of the Complaint in Divorce, Notice to Defend and Notice of
Availability of Counseling in the above-captioned matter. I acknowledge that I am the Defendant in said
matter or that I am authorized to accept on behalf of the Defendant.
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Bonnie L. Doolittle, Defendant or Anthorized Agent
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