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HomeMy WebLinkAbout03-5126STEVEN D. DOPPES, CHRISTINE M. DOPPES, Plaintiff, Defendant. : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Christine M. Doppes 375 Stumpstown Road Mechanicsburg, PA 17055 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. 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 at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F1ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1(800) 990-9108 STEVEN D. DOPPES, : Plaintiff, : V. ' : CHRISTINE M. DOPPES, : : Defendant. : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff Steven D. Doppes is an adult individual currently residing at 375 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant Christine M. Doppes is an adult individual currently residing at 375 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiffand Defendant have been bona fide residents of the Commonwealth for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 20, 1979 in Cumberland County, Pennsylvania. 5. Neither Plainfiffnor Defendant is in the military or Naval service of the United States or its allies within the provisions of the Soldiers and Sailors Civil Relief Act of the Congress of 1940 and its Amendments. 6. Plaintiff's Social Security number is 097-38-7924; Defendant's Social Security number is 206-52-4968. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plalntiffhas been advised that counseling is available, and that Plalntiffmay have the right to request the Court require the parties to participate in counseling. 10. 11. Defendant. 9. There were two children bom of this marriage: Andrew D. Doppes (Date of Birth: 12/28/8 I; Julia M. Doppes (Date of Birth: 6/07/84). The marriage is irretrievably broken. Plaintiff requests the Court to enter a degree of divorce, divorcing Plaintiff and WHEREFORE, Plaimiffrequests that this Court enter a decree in divorce and any such other orders that are appropriate and just. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Andrew C. Spears Supreme Court I.D. No. 87737 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff VERIFICATION I, Steven D. Doppes, hereby certify that the facts set forth in the foregoing Complaim in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Steven D. Dopl~es 288458-1 STEVEN D. DOPPES, : Plaintiff, : V. : CHRISTINE M. DOPPES, : : Defendant. : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW DIVORCE PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this 19th day of September, 2003, by and between Steven D. Doppes (hereinafter "Husband") of Mechanicsburg, Cumberland County, Pennsylvania, and Christine M. Doppes (hereinafter "Wife") of Mechanicsburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties are Husband and Wife, married on October 20, 1979, in Cumberland County, Pennsylvania; and WHEREAS, two children was bom of the marriage: Andrew D. Doppes (d.o.b. 12/28/81); and Julia M. Doppes (dob 6/7/84); WHEREAS, unhappy differences and difficulties have arisen between the parties, in consequence of which the parties intend to live separate and apart for the rest of their natural lives; and WHEREAS, the parties are Plaintiff and Defendant, respectively, in a divorce action filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to Docket No. ; and WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including, but not limited to, the ownership Document #: 243327 and equitable dislribution of real and personal property; past, present and future support, alimony and/or maintenance; and any and all claims which either party has, or may have, against the other or the other's estate. NOW, THEREFORE, in consideration of the mutual promises, covenants, and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as follows: 1. SEPARATION Each party shall have the right to live separate and apart from the other party, free from the other party's interference, authority, and control. Neither party shall interfere with the other or attempt to interfere with the other, nor compel the parties' cohabitation. 2. HUSBAND'S AND WIFE'S DEBTS Except as otherwise set forth in this Agreement, the parties represent and warrant to each other that they have not incurred and will not contract or incur any debt or liability for which the other or the other's estate might be responsible. Each party shall indemnify and save harmless the other party from any and ail claims or demands made against the other by reason of debts or obligations incurred by that party. 3. WAIVER OF RIGHTS AND MUTUAL RELEASES Except as provided in this Agreement, both parties absolutely and unconditionally release and forever discharge each other and their heirs, executors, administrators, assigns, property, and estate from any and all rights, claims, demands, or obligations arising out of or by virtue of the marital relationship, whether such claims exist now or arise in the future. Tlfis release shall be -2- Document #: 243327 effective regardless of whether such claims arise out of former or future acts, contracts, engagements, or liabilities of the parties or by way of dower, curtesy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or other country. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement, each party gives to the other an absolute and unconditional release and discharge fi.om all causes of action, claims, rights, or demands whatsoever, in law or in equity, which either party ever had or now has against the other, including, but not limited to, alimony, alimonypendente lite, spousal support, equitable distribution of marital property, counsel fees or expenses. 4. DIVISION OF PERSONAL PROPERTY The parties have divided all items of personal property, except as otherwise specified heroin, to their mutual satisfaction. All personal property currently in Husband's possession shall be the sole and separate property of Husband. All personal property currently in Wife's possession shall be the sole and separate property of Wife. 5. MOTOR VEHICLES Husband shall retain sole and exclusive ownership of the vehicles in his possession. Wife shall retain sole and exclusive ownership of the vehicles in her possession. Husband and Wife agree to execute, within thirty (30) days of the date of this Agreement, any and all forms, titles, and Document #: 243327 -3- documents necessary to transfer the aforesaid vehicles from joint ownership to individual ownership, as specified herein. 6. JOINT DEBTS Any debts or obligations incurred by either party in his/her individual name, whether incurred before or after separation, are the sole responsibility of the party in whose name the debt or obligation was incurred. 7. RETIREMENT BENEFITS Each of the parties does specifically waive, release, renounce, and forever abandon ail of their right, ritle, interest, or claim, whatever it may be, in any pension/retirement/profit sharing plan of the other party, whether acquired through said party's employment or otherwise, and hereafter the pension/retirement/profit sharing plan shall be identified above as being either husband's or wife's and shall become the sole and separate property of the party in whose nmne or whose employment said plan is carried. 8. DIVISION OF BANK ACCOUNTS Husband and Wife acknowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. 9. AFTER-ACQUIRED PROPERTY Each of the parties shall own and enjoy, independently of any claims or rights of the other, all real property and all items of personal property, tangible or intangible, hereafter acquired, with full power to dispose of the same as fully and effectively as though he or she were unmarried. Any property so acquired shail be owned solely by that party and the other party shall have no claim to that property. -4- Document #: 243327 10. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, AND AL1MONY Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony pendente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this Agreement shall not constitute alimony, but is made as part of the parties' equitable distribution. 11. TAX MATTERS The parties have negotiated this Agreement with the understanding and intention to divide their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of Section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. 12. COUNSEL FEES AND EXPENSES Except as otherwise specified herein, each party shall be responsible for payment of his/her own counsel fees and expenses. 13. ADVICE OF COUNSEL The parties acknowledge that each has received or has had the opportunity to receive independent legal advice from counsel of their selection and that they have been informed fully as to their legal rights and obligations, including all rights available to them under the Pennsylvania Divorce Code of 1980, as amended, and other applicable laws. Document #: 243327 -5- Each party confrrms that he/she understands fully the terms, conditions, and provisions of this Agreement and believes them to be fair, just, adequate, and reasonable under the existing circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement. 14. AFFIDAVITS OF CONSENT Each party agrees to execute an Affidavit of Consent for the obtaining of a no-fault divorce under the provisions of the Divorce Code of 1980, as amended. 15. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in Section 3105(a) of the Divorce Code, as amended. As provided in Section 3105(c), provisions of this Agreement regarding equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modification by the court. 16. DATE OF EXECUTION The "date of execution", "date of this agreement", or "execution date" of this Agreement is the date upon which it is signed by the parties if they sign the Agreement on the same date. Otherwise, the "date of execntion", "date of this agreement", or "execution date" shall be the date on which the last party signed this Agreement. 17. HEADINGS NOT PART OF AGREEMENT The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction, or effect of this Agreement. -6- Document #: 243327 18. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS Each separate obligation shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. 19. AGREEMENT BINDING ON HEIRS This Agreement shall be binding on and shall enure to the benefit of the parties and their respective heirs, executors, administrators, successors, and assigns. 20. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations, warranties, covenants, or promises other than those expressly set forth in this Agreement. 21. MODIFICATION OR WAIVER TO BE IN WRITING No modification or waiver of any term of this Agreement shall be valid unless in writing and signed by both parties. 22. NO WAIVER OF DEFAULT The failure of either party to insist upon strict performance of any term of this Agreement shall in no way affect the right of such party hereafter to enforce the term. Document #: 243327 -7- 23. VOLUNTARY EXECUTION The parties acknowledge that this Agreement is fair and equitable, and that they have reached this Agreement freely and voluntarily, without any duress, undue influence, collusion, or improper or illegal agreements. 24. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980, as amended. 25. ATTORNEYS' FEES FOR ENFORCEMENT If either party breaches any provision of this Agreement, the breaching party shall pay all reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the enforcing party is successful in establishing that a breach has occurred. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. WITNESS: Steven D. Doppes C tine M. Doppes Document #: 243327 -8- COMMONVVEALTH OF PENNSYLVANIA : .' SS cotr xY oF : ~d~ay ~pp~ o · appeared Steven D. Doppes known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital 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. NOTARIAL SEAL ROY EARIJE COOK, nots~.F[u_bJicr,~ ~ Bor0:, Gurmlerla~u ~i~-~ Expires Aug. 22, 200 My Commission Expires.~&O% *'--D/h/, '~0o ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~__~O{M. On this, the kC[ day : SS : , 200~, before me, the undersigned officer, personally appeared Christine M. Doppes, known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital 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 I ~ ~ ROY EARLE COOK, Notary Pub!ic_ [ Iff r~ 0 ~ t3-~'[5~t ~ ~ ~i~n ~m g. My Co~ission Expires: Respectfully submitted, 288458-1 STEVEN D. DOPPES, V. CHRISTINE M. DOPPES, Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW Defendant. : DD/ORCE AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff Stev{m D. Doppes, in the above- captioned divorce action, hereby certify that a true and correct copy of the Divorce Complaint in Divorce was served upon Defendant on September 28, 2003. Attached hereto, marked as Exhibit A and incorporated herein by reference, is an Acceptance of Se~wice signed by Defendant, Christine M. Doppes. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date: By: Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street P.O. Box 52100 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff STEVEN D. DOPPES, Plaintiff, V. CHRISTINE M. DOPPES, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE ACCEPTANCE OF SERVICE I, Christine M. Doppes, Defendant, hereby certify that I accept service of the Complaint in Divorce this ~8 dayof ,.~57'Crl~lj~,2003. ~,'istine M. Doppes 289888-1 STEVEN D. DOPPES, CHRISTINE M. DOPPES, Plaintiff', Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code was filed on September 26, 2003 and served upon Defendant on September 28, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. SteveC~n D. D~p2~'~ 289888-1 STEVEN D. DOPPES, V. CHRISTINE M. DOPPES, Plaintiff, Defendant. : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 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 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 imtnediately 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. § 4904 relating to unswom falsification to authorities. Dated: C~'hristine-M. Doppes ' ~ 289888-1 STEVEN D. DOPPES, CHRISTINE M. DOPPES, Plaintiff, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under §§ 3301(c) and (d) of the Divorce Code was filed on September 26, 2003 and served upon Defendant on September 28, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divome after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unsworn falsification to authorities. Dated: hristine M. Doppes 289888-1 STEVEN D. DOPPES, CHRISTINE M. DOPPES, Plaintiff, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 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 fights 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. § 4904 relating to unswom falsification to authorities. Dated: J ~q/L--~ Steven D. Doppes 0r 289888-1 STEVEN D. DOPPES, V. CHRISTINE M. DOPPES, Plaintiff, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 - CIVIL TERM DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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. Date and manner of service of Complaint: A Complaint in Divorce was filed on September 26, 2003 and served on Defendant on September 28, 2003, via certified mail, return receipt requested. An Affidavit of Service was filed on October 17, 2003. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiff's and Defendant's Affidavits of Consent required by Section 3301(c) of the Divome Code: Plainfif: Defendant: December 29, 2003; filed January 8, 2004 December 29, 2003; filed January 8, 2004 (b)(1) Date of execution of Plaintiff's Affidavit required by Section 3301(d) of the Divome Code: NA 295710-1 Dated: (2) Date of filing and service of the Plaintiff's Affidavit upon the respondent: Filing: NA Service: NA 4. Complete the appropriate paragraphs: (a) Related claims pending: None (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: All (d) State whether any written agreement is to be incorporated into the Divorce Decree: Yes. Marital Settlement Agreement dated September 26, 2003, is attached to Decree in Divorce 5. (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered trader Section 3301(d)(1)(i) of the Divorce Code: Service: NA Co) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 8, 2004 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 8, 2004 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By An~re~-C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 295710-1 STEVEN D. DOPPES, V. CHRISTINE M. DOPPES, Plaintiff, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CiVIL ACTION: LAW NO. 03-5126 - CIVIL TERM DiVORCE , CERTIFICATE OF SERVICE AND NOW, this I~]%y of January, 2004, I, Andrew C. Spears, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, Penny L. Williams, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Christine M. Doppes 375 Stumpstown Road Mechanicsburg, PA 17055 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: An&Cew/~C. Spears 295710-1 STEVEN D. DOPPES, Plaintiff, V. CHRISTINE M. DOPPES, : : Defendant. : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) and ( ) of the Divorce Code S~tember 26, 2003 ~d se~ed upon Defend~t on S~tember 28, 2003. 2. The m~age of Pl~nfiff ~d Defend~t is i~e~evablv bro ~,~ ~ ken, ~ have elapsed ~om ~e date of fihng ~d se~ice of~e Compl~t. 3. I consent to the entry of a Final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in th/s Affidavit are true and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to author/ties. Steven D. D~)pp4J 289888-1 STEVEN D. DOPPES, CHRISTINE M. DOPPES, COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY CiVIL ACTION: LAW NO. 03-5126 CiVIL TERM Defendant. DiVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code ~filec~n September 26, 2003 and served upon Defendant on September 28, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed fi.om the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are tree and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. Dated: k,-12hrist~e ~. Doppes 289888-I STEVEN D. DOPPES, V. CHRISTINE M. DOPPES, Plaintiff, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ;.~2 ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CO~!' 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. § 4904 relating to unsworn falsification to authorities. Dated: Steven D. Doppes 0'T 289888-1 STEVEN D. DOPPES, V. CHRISTINE M. DOPPES, Plaintiff, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION: LAW NO. 03-5126 CIVIL TERM DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST v,-:; ~ ~c~ ENTRY OF A DIVORCE UNDER § 3301(e) OF THE DIVORCE 1. I cons~t to ~e m~ ofa fin~ decree of divorce wi~out notice ~;e~. . . z~., ~ 2. I ~derstmd that I may lose n~ts conce~ng al~ony, &hsion lawyer's fees or expenses ifI do not clam ~m before a &vome is ~ted. 3. I ~derst~d ~at I ~11 not be &vorced ~fil a divome decree is entered by ~e Co~ md ~at a copy of~e decree Mll be sent to me medimely a~er it is filed wi~ ~e Pro~onot~. I v~fy ~at ~e statements made in t~s ~fi~vit ~e ~e md co=ect. I ~demmd ~at fllse statements herein ~e made subject to ~e penalties of 18 Pa.C.S. ~ 4904 relating to ~swom fllsification to au~ofities. Dated: Christine-M. Doppes , t 289888-1 STEVEN D. DOPPES VERSUS CHRISTINE M. DOPPES IN THE COURT Of COMMON PLEAS OF CUMberlaNd COUNTY STATE OF PENNA. NO. 03-5126 DECREE IN ANd NOW, DECREED THAT DIVORCE AND CHRISTINE M. DOPPES 2O04 ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD }N THiS ACTION FOR WHICH A fINAL ORDER HAS NOT YET BEEN ENTERED; The Marital settlement Agreement between the parties dated September 26, 2003 is incorporated but not merged herein. BY T H i/l~,~,~t: PROTHONOTARY