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HomeMy WebLinkAbout99-04006l 1 I N TH E COU RT OF COM MON PLEAS OF CUMBERLAND COUNTY STATE OF ... PENNA: ROGER L. LOCKBAUM, No. 99-4o06 VERSUS M. RENEE LOCKBAUM, Defendant DECREE IN DIVORCE 0.te ? 0 (?'l AND NOW,, f!j?IT IS ORDERED AND DECREED THAT Rn(:FR 7 LOCKSAUM , PLAINTIFF, AND M_ RENEE TnrKRAr'M 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 BY THE O t TEST: J. PR HONOTARY / J ?"/vll? P %?Y? CL CY iC?? Al ot ?../ `1?JiLY_L? .atv7. J l r.. A%!C!L ?t.t?.,??" 1 ROGER L. LOCKBAUM, Plaintiff V. M. RENEE LOCKBAUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4006 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: On or about November 2, 1999, defendant was served by certified mail, restricted delivery, with a copy of the reinstated divorce complaint. See Affidavit of Service filed by plaintiffs counsel on November 3, 1999. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301 of the Divorce Code: By the plaintiff: NIA By the defendant: N/A (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: July 29,1999; and (2) Date of filing and service of the plaintiffs affidavit upon the defendant: November 2, 1999. 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: December 3, 1999 by regular first class to defendant. (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: N/A Date defendant's Waiver of Notice in Section 3301(c) Divorce pas filed with the Prothonotary: N/A February 3, 2000 JOH J. BARANSKI, JR. ATTORNEY ID NO. 82585 35 EAST HIGH STREET, SUITE 202 CARLISLE PA 17013 (717)243.6090 ATTORNEY FOR PLAINTIFF l.) I i7 JOHN J. BARANSKI, JR. ATTORNEY ID NO. 82586 36 EAST HIGH STREET CARLISLE PA 17013 (717) 2434080 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO. 99 -'yo'-?IVIL TERM Defendant : IN DIVORCE 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, 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 717-249-6200 ROGER L. LOCKBAUM : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO. 99 - ` boCIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S COMPLAINT IN DIVORCE UNDER 33011C) and 3301(D) of the DIVORCE CODE NOW, comes the plaintiff, by his attorney, John J. Baranski, Jr., Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff Roger L. Lockbaum, an adult individual residing at 144 West Church Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is M. Renee Lockbaum, an adult individual residing at 227 Three Square Hollow, Newbug, Cumberland County, Pennsylvania 17240 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on February 14, 1982 in Shippensburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301 (d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties hereto have lived separate and apart for a period of at least two years. 6. The parties have lived separate and apart since July 4, 1995. 7. The plaintiff avers that he has been advised of the availability of counseling and that he 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 parties and for such further relief as your Honorable Court may deem equitable and just. I verify 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. Section 4904, relating to unsworn falsification to authorities. 17 , _ JUNE ?I , 1999 J. for Roger L. Lockbaum JU"N J, UARANSKI, JR. ATTORNEY ID NO. 82585 78 EAST HIGH STREET CARLISLE PA 17073 (717) 2174080 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO.99 •y604 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. 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 understand 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. 1-2 June ) I, 1999 R L. LOCI B UM, Plaintiff ROGER L. LOCKBAUM, Plaintiff V. M. RENEE LOCKBAUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99 -100'`CIVIL TERM : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in July 4, 1995, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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 are made subject to the penalties of 18 Pa. C.S. of 4904 relating to unsworn falsification to authorities. JUNE 14 1999 R G R L. LOCK AUM ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO. 99 - CIVIL TERM Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 33011d1 OF THE DIVORCE CODE Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (both): (b) I oppose the entry of a divorce decree because (Check (i), (ii) or (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. In understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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. 1999 M. RENEE LOCKBAUM NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file this counteraffidavit. rn? c w '^ J JOHN J. BARANSKI, JR. ATTORNEY ID NO. 82506 36 EAST HIGH STREET CARLISLE PA 17013 (717) 2436060 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. M. RENEE LOCKBAUM, Defendant TO THE PROTHONOTARY. CIVIL ACTION - LAW NO. 99-4006 CIVIL TERM IN DIVORCE Please reinstate the Complaint in the above captioned matter. / October 28, 1999 (.. i BY: Joh . Baranski, Jr. Attorney for plaintiff G) ti F- Ir. E" u, !, (V is :J JOHN J BARANSKI, JR., ESQUIRE ATTORNEY ID NO. 82685 36 EAST HIGH STREET CARLISLE PA 17017 (717) 2433060 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO. 99 -14L?0CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920A a 1 i NOW, John J. Baranski, Jr., 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 above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about October 30, 1999, by certified mail, addressed to her at 227 Three Square Hollow, Newburg, PA 17240, certified mail, return receipt No. Z 339 062 150. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. 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- November 2, 1999 J. Baranski, Jr., ley for plaintiff Z 339 062 150 US Postal service Receipt for Certified Mail No Insurance Coverage Provided, rostato ?+ Certified Fee Spedal Delivery Fee Restricted Delivery Fee 1Q•S" m I V IAA rostage A ..Fees $ Postmark or Date / 1 _?J L-?xkbc>.usr? v SENDER: ; m 0 Compete items t endlor 2 for admtionm services. Ciempale Name 3, 4a, and 40. eive the follow. n extra fee): i O Print your name and ademss on the revere or this form ea that we can return th r a m Attach card to o Amen this ree form to the from of ins mailpece, or on the back it space does not. permit' ' Addressee's Address elive m O t ? rj C W41e Rerum Roc ipr Requestaki the mailpace below the much, number. ry •• N O 0 The Return Receipt wifi show to whom the article was delivered and the date a ' O dalmenid. , 3. Article Addressed to: 4a. Article I RENEE LOCRBAUN Z 339 062 150 E, $ 227 BREE SQUARE HO LLOW N URG PA 17240 4b. Service T e yP ? Registered CertlOe i" m ¢ • ?Express Mail ?Insured c ? Holum Receipt for Merchandise O COD 7. Date of Delivery E Mm /0 -30.9 o. ived By: (Pn rN e) 6 Acdss s Address(ftnry 11 requested and . O fee is rd E m ' e 6. ign lure (Addre ee Agent) I a m PS Form 3811, December 1994 102595-99 9.0223 Domestic Return Remain ?. cr t ?- c ?--. ?? _:. .c ..:? ._ ?`?r ??? •:?? i„ ?. i ?. ?_. : c' i.i_ C _= ,?, o' r: j _? ?, JOHN J. 9ARANSKI, JR. ATTORNEY ID NO. 92585 36 EAST HIGH STREET CARLISLE PA 17013 (717) 2434080 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, Plaintiff V. M. RENEE LOCKBAUM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4006 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: M. Renee Lockbaum, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the plaintiffs affidavit. Therefore, on or after December 23, 1999, the plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counteraffidavit by the above date, the Court can enter a final decree in divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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, PA 17013 (717) 249 - 3166 ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO. 99-4006 CIVIL TERM Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or (both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. 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. ,1999 M. Renee Lockbaum NOTICE: If you do not wish to oppose the entry of a divorce decree and you to not wish to make a claim for economic relief, you need not file this counteraffidavit. ROGER L. LOCKBAUM, Plaintiff V. M. RENEE LOCKBAUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : N0.99-4006 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of Plaintiffs Notice of Intention to Request Entry of Divorce upon the Defendant by placing same in the United States mail at Carlisle, Pennsylvania, Regular Mail on this 3 day of December, 1999 and addressed as follows: M. Renee Lockbaum 227 Three Square Hollow Newburg, PA 17240 John Jr. 35 E99t High Street Suite 201/202 Carlisle, PA 17013 ID # 82585 Attorney for Plaintiff i ? LIJ r--) L . f - ?I.. L..: .'1 U c= LI_ O Q, ) c7i JOHN J. BARANSKI, JR. ATTORNEY ID NO. 82686 36 EAST HIGH STREET CARLISLE PA 17013 (717) 2434080 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA C7 • C a ? O n V. : CIVIL ACTION - LAW; •': ;! M. RENEE LOCKBAUM, : NO. 99-HoOi.CIVIL TERM - Y Defendant : IN DIVORCE c. N ern NOTICE > j 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, 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4th Floor Carlisle, Pennsylvania 17013 717-249-6200 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal t said Co rt at Carlisle, Pa. This day o e t -,- ? "l notary / ROGER L. LOCKBAUM : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW M. RENEE LOCKBAUM, : NO. 99 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S COMPLAINT IN DIVORCE UNDER 3301(C) and 3301(DI of the DIVORCE CODE NOW, comes the plaintiff, by his attorney, John J. Baranski, Jr., Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff Roger L. Lockbaum, an adult individual residing at 144 West Church Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is M. Renee Lockbaum, an adult individual residing at 227 Three Square Hollow, Newbug, Cumberland County, Pennsylvania 17240 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on February 14, 1982 in Shippensburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties hereto have lived separate and apart for a period of at least two years. 6. The parties have lived separate and apart since July 4, 1995. 7. The plaintiff avers that he has been advised of the availability of counseling and that he 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 parties and for such further relief as your Honorable Court may deem equitable and just. I verify 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. Section 4904, relating to unsworn falsification to authorities. JUNE ?? . 1999 J. BAR#KSKI, 7R. ey for Roger L. Lockbaum JOHN J. SARANSKI, JR. ATTORNEY ID NO. 02685 46 EAST HIGH STREET CARLISLE PA 17017 (717) 4434080 ATTORNEY FOR PLAINTIFF ROGER L. LOCKBAUM, Plaintiff V. M. RENEE LOCKBAUM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 99 CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. 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. 1 understand 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. June) 1999 R L. LOCK B UM, Plaintiff ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. M. RENEE LOCKBAUM, Defendant CIVIL ACTION - LAW NO. 99 - CIVIL TERM IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in July 4, 1995, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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 are made subject to the penalties of 18 Pa. C.S. of 4904 relating to unsworn falsification to authorities. JUNE T 1999 R G R L. LOCK AUM ROGER L. LOCKBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. M. RENEE LOCKBAUM, Defendant : CIVIL ACTION - LAW NO. 99 - CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (both): (b) I oppose the entry of a divorce decree because (Check (i), (ii) or (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. In understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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 unswom falsification to authorities. 1999 M. RENEE LOCKBAUM NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file this counteraffidavit. > a) L iC) U = C.. ! - Y. l- X71 C .: C 1 . . lu:.._ h l- l f tl CL C't )