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HomeMy WebLinkAbout07-5583PAUL L. DEHART, JR., IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA Vs. NO. JENNIFER L. DEHART, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attomey and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or fDr any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 244-3166 PAUL L. DEHART, JIL, Plaintiff Vs. JENNIFER L. DEHART, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA NO. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RE 1 AMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las pagmas siguientes, debe tomar accion con prontitud. Se le avisa que si no se defiende, el caw puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes pare usted. Cuando la base para el divorcio es mdigmdades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consocros matrimoniales esta disponible en la oficina del Prothonotary, an la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. SI USTED NO RECLAMA PENSION ALIlAUMCIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIEN'TO SEA MEITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAREL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O UAW A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PAUL L. DEHART, JR., Plaintiff VS. JENNIFER L. DEHART, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA NO. 0 Al : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c)OF THE DIVORCE CODE COUNTI AND NON, this al =t day of L-ee tou,, , 2007, comes the Plaintiff, Paul L. DeHart, Jr., by his attorney, Jane M Alexander, Esquire, and files this Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is Paul L. DeHart, Jr., 37 years of age, who currently resides at 122 Bridge Street, New Cumberland, New Cumberland Borough, Cumberland County, Pennsylvania 17070. 2. Defendant is Jennifer L. Deflart, 28 years of age who mrentiy resides at 9 Roop Street, Highspire, Swatara Township, Dauphin County, Pennsylvania 17034. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 11, 2004 in Highspire, Dauphin County, Pennsylvania. 5. Tyre was no child born between the patties. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, costs and property division. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT H 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT M 12. The allegations of Paragraph one (1) through eleven (11) are incorporated herein by reference and made a part hereof. 13. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and whosesoever situate and for such further relief as the Court may deem equitable and just. Respectfully submitted, o r4- South Baltimore Street Dillsburg, PA 17019 (717) 4324514 Verification I verify that the statements made in this Complaint in Divorce 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 unworn falsification to authorities. DATE: 9-dl-07 COMMONWEALTH OF PENNSYLVANIA ,?? -;z AeKr? Paul L. DeHart, Jr. COUNTY OF YORK S.S. Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, personally appeared Paul L. DeHart, Jr. who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. Sworn to and subscribed before me this _g ? s? day of Sfpk I.tr , 2007. 9 Notary Public TH OF PENNSYLVAMA COMMONWEAL NaWW 8wl Nar W Abwxler, Notary Pdd c !]Nebunp t3oro, York County IWT DomrrsMMI Expims Apr. 7,2010 Member. Penn,"Wania. Aws ds.tinn of Notaries Ntil L. DeHart, Jr. illy ?t? ?r ? r t r v -p =4 ,a Ali,V, ;'Ov; r '4, PAUL L. DEHART, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : OF W11RLAM 03IJN1Y , PENNSYLVANIA VS. : NO. 07-5583 Civil Term JENNIFER L. DEHART, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this day of , 2007 personally appeared Jane M. Alexand , Esquire who swears according to law, that a true and correct copy of a Complaint in Divorce was caused to be served by certified mail with return receipt requested upon the said, Jennifer L. DeHart 9 Roop Street Highspire, PA 17034 On September 25, 2007 leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part hereof. `Ja M. Alexander, squire A orney ID. #07355 1 8 S. Baltimore Street illsburg, PA 17019-0421 17) 432-4514 Sworn and subscribed before me this sr day of C C+V 6"- , 2007. y Notary Public COM O WEAUTH OF PENNSYLVANIA Notarial Seal Nwmid AWXWKW. Notary Public Dl skxq BM, York County * CownWWon Expires Apr. 7, 2010 Member, Pennsvivania Association of Notaries r t PAUL L. DEHART, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : OF YORK COUNTY, PENNSYLVANIA VS. : NO. 07-5583 Civil Term JENNIFER L. DEHART, : CIVIL ACTION - LAW Defendant : IN DIVORCE PROOF OF SERVICE -n CERTIFIED Ln m (Domestic Mail Only; No Insurance Coverage Provided) co For deliverv information visit our website at www.uspsxom(? m 70"a";FTM -l A L U S E M Postage G (? C3 Certified Fee ` C3 Return Reciept Fee (Endorsement Required) $2.1 5'e? Q Da" ` C3 Re stricted Delivery Fee {,1 (Endorsement Required) r C3 Total Postage & Fees $ f9. {$ S C3 -'Wd To ?eoh???"r or PO Box Wo. Roof --= --------------------------------- c71'r,GGI ------------------------------• ••• cr+,. saue, 21Pw 4-}is --...... ..----------------------------------- t.rA PA 1-7034- • Complerte Items 1, 2, and 3. Also complete item 4 if ResMcted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpkw% or on the front if space permits. 1. Ankle to: spire, PA t7o 34 A. Signature Agent B.,i?Celved by (f11N?[ed I C. D?ete of Delivery ? ?nt1 i rL • i q'?? a D. Is delivery address dMfererrt from (tern 1? If YES, enter delivery address t?elow: 161;;? 3. Service IWW jD1c06 ied Mal 0 B peas Mail ? Registered m Receipt for Mwd=diee 13 lmkwed Md O C.O.D. 4. Restricted DeNvery? (Exba Fee) 2'Article " nl. 7004 0750 0003 6356 8356 ra??AarraarMrlsba? Ps Form 3811, February 2004 Dorn.atlc Raton Roar 102585-M4&1540 1 srv_ Y co -S PAUL L. DEHART, JR., : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-5583 JENNIFER L. DEHART, : CIVIL ACTION - LAW DEFENDANT : IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this , day of 12008 by and between Paul L. DeHart of 122 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070 (hereinafter referred to as "HUSBAND") and Jennifer K. DeHart, of 9 Roop Street, Highspire, Swatara Township, Dauphin County, Pennsylvania 17034 (hereinafter referred to as "WIFE"). WITNESSETH, WHEREAS, HUSBAND and WIFE were lawfully married on September 11, 2004 in Highspire, Dauphin County, Pennsylvania. HUSBAND instituted an action in divorce to No. 07-5583 in the Court of Common Pleas of Cumberland County, Pennsylvania on September 24, 2007. The pleadings in the case requested dissolution of the marriage between the two parties and for such further relief that the Court may deem equitable and just; WHEREAS, the parties have reached an agreement as to the settling of all matters relating to the divorce and including disposition of all marital property. There were no children born during this marriage. Page 1 of 9 NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable Consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from'each other. 2. The terms of this Agreement and their effect have been fully explained to the HUSBAND by his counsel, Jane M. Alexander, Esquire. WIFE has been advised of her rights to seek counsel of her own and has chosen not to do so. The parties acknowledge that they ( have received independent legal advice from counsel of their choice and have been fully informed as to their legal rights and obligations or have chosen not to do so. The parties understand the facts and acknowledge and accept this Agreement as fair and equitable. 3. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the Intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being affected without the introduction of outside funds or other property not constituting a part of the marital estate. Page 2 of 9 4. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, Profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 5. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 6. DEBTS OF THE PARTIES: It is mutually agreed and understood by and between the parties that all joint debts have been paid including open accounts, credit cards, and bank liabilities except as hereinafter set forth: 7. PERSONAL PROPERTY: As to all items of personal property which the parties have divided to their mutual satisfaction, henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are now owned or held by or which may hereafter Page 3 of 9 belong to the HUSBAND or WIFE, with full power to the HUSBAND or the WIFE to dispose of same as fully effectually, in all respects and for all purpose as if he or she were not married. Specific disposition of major items or personal property is as follows: 7.1) Bank Accounts and credit cards: Each party has opened and maintained their own separate bank accounts since the time of separation. Neither party will make a claim against those funds. Each party maintains their own credit cards and will be solely responsible for all debt thereon, if any. 7.2) Vehicles: a) HUSBAND shall receive possession, title, and sole ownership of the 1993 Dodge Van Caravan VIN#2B4GH2536PR221170 and shall be responsible for any debt thereon if any. 7.3) Household furnishings: The parties have divided the household furnishings to their mutual satisfaction. 7.4) Pensions: Stock options, Retirement funds, IRAs: a) Neither party makes any claim against the other for these or similar funds. b) Each party shall be responsible for their own health, dental, or other types of insurance as of date of the divorce decree. c) Both parties state that they do not own any IRAs, which would be Page 4 of 9 subject to equitable distribution. 8. REAL ESTATE: The Marital residence of the parties located at 9 Roop Street, Borough of Highspire, Dauphin County, Pennsylvania 17034 is presently occupied by the WIFE and has been occupied 2by her since the date of separation. WIFE has been and agrees to continue to be solely responsible for payment of all real estate taxes, mortgage payments, insurance and utility payments, and maintenance of the premises and will continue to do so and will hold husband harmless from any amounts presently due on those items. HUSBAND agrees to transfer his interest in the property within thirty (30) days of the execution of this agreement. However Attorney Jane Alexander will hold said deed in escrow until such time as Wife refinances the property held by Beneficial, account no. HF0001-59-62459, in the amount of approximately $81,220.00. Said refinancing shall be done within one year of the date of this agreement. However if at any time during the one year period wife should default in making the mortgage payment, the property shall be immediately listed for sale and if refinancing is not complete within one year the property shall be sold and the net proceeds, if any, would be payable to Wife. If the proceeds of the sale are not sufficient to pay the balance due on the mortgage, taxes, municipal charges and costs, Wife shall be solely responsible for payment of those unpaid debts. 9. SPOUSAL SUPPORT/ALIMONY: Page 5 of 9 Neither party has or will make claim for spousal support and/or alimony 10. OTHER DEBTS: Husband shall be responsible for payment of the Beneficial Loan No.711736-13- 521094 in the amount of approximately $22,809.77 and the balance due on the CITI Financial account number 67380278-0380329 in the amount of $7,037.81. Wife had agreed to be responsible to pay the balance on the AT&T account and it has been paid in full. The parties owe their friend Kevin Luther the sum of $4,000.00. Each agrees to execute a judgment note to Kevin Luther in the amount of $2,000.00 and to make payment of full of their respective share within one year. 11. BANKRUPTCY: The parties hereby agree that the provision of the Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other parry shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to Court determination the same as if this Agreement had never been entered into. 12. STATUS OF SETTLEMENT: The property settlement as provided herein between the parties shall be considered Page 6 of 9 an equitable distribution of marital property and both parties waive any and all rights or claims which they may have been entitled to raise with respect to the issue of equitable distribution under the Provisions of the Pennsylvania Divorce Act. 13. The parties agree that simultaneously with the signing of this Agreement they will sign the necessary affidavits of consent and affidavits acknowledging notice of marriage Counseling in order to conclude the divorce action filed by HUSBAND under the no-fault provisions of the Pennsylvania Divorce Act. 14. The waiver or unenforceability of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered to be a waiver of or forfeiture of right to Enforce any other term, condition, clause or provision of this Agreement. 15. This Agreement shall be construed and interpreted according to the laws of the Commonwealth of Pennsylvania. 16. It is understood and agreed that the heirs, administrators, executors and assigns of the parties hereto shall be bound by all the terms, conditions, clauses and provisions of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written, intending to be legally bound. Paul L.De art, , Plaintiff age 7 of 9 WITNESS BY: JJ-66 ifer L De art, Defendant COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF YORK On this, the ?y day of 2008, before me the undersigned officer, a Notary Public, in and for said Commonwealth and County, Personally appeared Paul L. DeHart, Jr., know to me (or satisfactorily proven) to be the person whose I name is subscribed to the foregoing Marriage Settlement Agreement and in due form acknowledged that he executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and aforesaid. 10M? I Z4?? t blic My Commission Expires: PENNSYLVANIA i,jn ariol Seal L.l?P;;!e? (11(1, Notary Public Yo?kGounty Page 8 of 9 COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF YORK On this, the day of ? 2008, before me the undersigned officer, a Notary Public, in and for said Commonwealth and County, Personally appeared Jennifer L. DeHart, know to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Marriage Settlement Agreement and in due form acknowledged that she executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and year aforesaid. jt?Public My Commission Expires: coMrfo?ar >?: ,? , SYLVAN t"" ;t Seal Leslie K. n, 1 i'?G ty Public We?Ercr{>;; „ Y uk Caunty 201 t Page 9 of 9 ?? o C3 zsa :!3 r nl rr? cr+ , , .ry. rn PAUL L. DEHART, JR., plaintiff vs. JENNIFER L. DEHART, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. NO. 07-5593 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on September 24, 2007. 2_ The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from 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 the 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. Date: o` i rn PQ -om " C.: CO rn Ul PAUL L. DEHART, JR., Plaintiff VS. JENNIFER L. DEHART, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. : NO. 07-5593 Civil Term : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. 9 Date: Je fer L. Hart 0 f -71 '"t_) CO J> W fJ"i PAUL L. DEHART, JR., Plaintiff VS. JENNIFER L. DEHART, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. : NO. 07-5593 Civil Term : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on September 24, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from 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 the 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 unworn falsification to authorities. Date: G1 `d a b ? ?l `Paul tNeAait Jr. ? ? '?ci ? "'f ?? ? ? ??r ' ? ` ? ? ^ L i L; ? ? n s _, ?. _ '? a t .` ?'t `-' ';`?} .a? PAUL L. DEHART, JR., plaintiff vs. JENNIFER L. DEHART, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. NO. 07-5593 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that 1 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 unworn falsification to authorities. Date: aul L. DeHart, Jr. G ? t vp > a ' " 6 a.'(? `y? . "yam -„l 11^^ W 47' PAUL L. DEHART, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. VS. : NO. 07-5593 Civil Term JENNIFER L. DEHART, : CIVIL ACTION -LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) (3301(d)(1 of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: was sent certified mail restricted delivery and was served to the Defendant on September 27, 2007, 3. (Complete either paragraph (a) or (b)) a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff September 24 2008 ; by defendant September 24.2008 b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing of the 3301(d) affidavit: (3) Date of service of the 3301(d) affidavit upon respondent: 4. Related claims pending: All claims are settled and satisfied by Marriage Settlement Agreement dated SWember 2412008 signed by both parties. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to request entry of the divorce decree, a copy of which is attached: (b) Date plaintiffs Waiver of Notice was filed with the Prothonotary: September 26, 2008. Date defendant's Waiver of Notice was filed with the Prothonotary: September 26, 2008. Date: an M. Ale Esq A rney for Plain fiff A rney I.D. #07355 1 S_ Baltimore Street Dillsburg, PA 17019 (717) 432-4514 r-a ? crs ?? J ?'. W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. PAUL L. DEHART, JR. II N O. 07-5583 Civil Term VERSUS JENNIFER L. DEHART DECREE IN DIVORCE DECREED THAT AND AND NOW, JENNIFER L. DEHART Oc?obe.r- I PAUL L. DEHART, JR. , 1.6V , IT IS ORDERED AND , PLAINTIFF, ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; BY THE COURT: PROTHONOTARY , ww z / . o/ lo, I - al M, -: