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Home My WebLink About08-1509JO E. DOWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW ROBERT E. DOWELL, : NO. 08 -IM? CIVIL TERM Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM 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 will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 JO E. DOWELL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E. DOWELL, Defendant CIVIL ACTION - LAW NO. 8' ?sZ S CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jo E. Dowell, an adult individual currently residing at 1568 Boiling Springs, Road, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Robert E. Dowell, an adult individual currently residing at 1568 Boiling Springs Road, Boiling Springs, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 27, 1977, in Baltimore County, Maryland. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. COUNT II EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 14 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 13. Plaintiff and Defendant are joint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. COUNT III ALIMONY ALIMONY PENDENTE LITE AND COUNSEL FEES 15. Paragraphs 1 through 18 are incorporated herein by reference as if set forth in their full text. 16. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 17. Plaintiff is without sufficient property and otherwise unable to financially support herself although gainfully employeed. 18. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, as well as alimony, and alimony pendente lite for the Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay for Plaintiffs counsel fees, expenses, and costs as well as providing for payment of an appropriate alimony and alimony pendente lite to Plaintiff. Respectfully submitted, . Griffie, Esquire tto ey for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. J „ DATE: 3 vS v JO E. ELL, Plaintiff/Petitioner ? w w ?J ?I *ts 411 VV w E as t a ZE 9R ;J u:b z JO E. DOWELL, Plaintiff/Petitioner V. ROBERT E. DOWELL, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :No. 0 SO R CIVIL TERM : IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes Petitioner, Jo E. Dowell, by and through her counsel of record, Bradley L. Griffie, Esquire and petitions the Court as follows: 1 2 3 Your Petitioner is the above named Plaintiff, Jo E. Dowell, an adult individual currently residing at 1568 Boiling Springs Road, Boiling Springs, Cumberland County, Pennsylvania. Respondent is the above named Defendant, Robert E. Dowell, an adult individual currently residing at 1568 Boiling Springs Road, Boiling Springs, Cumberland County, Pennsylvania. Plaintiff has filed a Complaint in Divorce requesting a divorce based upon 3301 (c) of the Divorce Code of 1980, as amended, as well as requesting equitable distribution of marital property, alimony, alimony pendente lite, counsel fees, and expenses. 4. Throughout the parties 31 year marriage, Respondent has maintained and controlled all of the parties various marital assets, including investment accounts and retirement accounts, whether in individual names or in joint names. 5. Respondent, who turned 65 years of age in May 2007, has recently indicated to Petitioner that he intends to retire from his employment. 6. Based upon documents that Petitioner has seen, she believes that Respondent has, in his name alone, certain investment accounts and retirement accounts such as 401Ks and/or IRA accounts that exceed $300,000.00 in value. 7. The only other substantial asset owned by the parties is their residence where they currently reside in Boiling Springs, Cumberland County, Pennsylvania which Petition believes has equity of less than $150,000.00. 8. In the past, Petitioner believes Respondent has retained large sums of cash in his personal possession such that it would not be accounted for through any type of financial accounts. 9. Petitioner believes and therefore avers that Respondent will liquidate assets that are available to him, transfer funds to names of third party individuals, and otherwise remove funds that are marital funds which have accrued during the parties 31 year marriage such that those funds will be placed in accounts or otherwise hidden so as to reduce the funds available for equitable distribution, or, more importantly, eliminate funds available to compensate Wife for her interest in the equitable distribution portions of this divorce action. 10. Petitioner believes and therefore avers that without court intervention, the funds will be liquidated in such a manner that Petition will not be able to receive the financial benefits to which she is entitled pursuant to the Divorce Code of 1980 as amended. 11. Petitioner does not have details of all of the funds or accounts or investments that Respondent has maintained, some of which are believed to be in Petitioner's name, and therefore she has no means to determine even the names of the companies or financial investment institutions where the funds are located. 12. Petitioner has provided a copy of this Petition along with a true and attested copy of the Complaint in Divorce in this matter by certified mail, restricted delivery to the Respondent, but proof of service has not yet been received. WHEREFORE, Petitioner requests your Honorable Court to issue a Rule upon Respondent to show cause, if any he has, as to why the parties should not be enjoined from liquidating any of their investment funds, including investment accounts, retirement accounts, 401K accounts and the like, or otherwise dissipating, transferring, selling or alienating any of their tangible or intangible personal property, as well as such other relief as the Court deems just and proper. Respectfully submitted, Date: 3I LCE yriffie, Esquire Attorney for Plaintiff/Petitioner GRIME & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: JO E. DOWELL, Plaintiff 0 N C= ti Z _ m n G f ? JJ A j, e`J 1? J JO E. DOWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROBERT E. DOWELL, Defendant NO. 08-1509 CIVIL TERM ORDER OF COURT AND NOW, this I1`h day of March, 2008, upon consideration of Plaintiff's Petition for Special Relief, a hearing is scheduled for Monday, May 5, 2008, at 9:30 a.m. in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. PENDING FURTHER order of court or agreement of the parties, the parties are enjoined from liquidating any of their investment funds, including investment accounts, retirement accounts, 401K accounts and the like, or otherwise dissipating, transferring, selling or alienating any of their tangible or intangible personal property. BY THE COURT, Y J/) Wesley 016r,l Jr., J. `,' Bradley L. Griffie, Esq. 200 North Hanover Street Carlisle, PA 17013 Attorney for Plaintiff Robert E. Dowell 1568 Boiling Springs Road Boiling Springs, PA 17007 Defendant, pro Se me (20 t ES m;a t LFcL -3//:L/08 r__.1_ f-77 I?J 91 :9 WN Z 1 NVW JON MVIONC LU*-`-d 31HI JO JO E. DOWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW ROBERT E. DOWELL, : NO. 08-1509 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this j?day of) 008, comes Bradley L. Griffie, Esquire, and states that he mailed a certified and true copy of a Complaint in Divorce and Notice to Defend and Claim Rights, as well as a photocopy of a Petition for Special Relief, to the Defendant, Robert E. Dowell, at his address of 1568 Boiling Springs Road, Boiling Springs, PA 17007, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on March 8, 2008. ra fie, Esquire ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 Sworn and subscribed , to before me this I'4 ? day of tj'L, , 2008 NO ARY P BLIC NCTI1RMt lEAL ROSIN J. WASE" Hoary Pub0c CO MtE ROROUGK GUII11N AND MY, Cora d~ upk" Apt 17. "11 - 11I no F:%: _ ?X7 A.. 4j 'k?S6el?A1Aa1M WNMesh GVYY:WM?.W *s?w+,?e++'?*nsaFw+v?.e.,?.e,eo'+xa`eeu?ra? ane+en .• ++av. r. 11 ., a CFRTIF'I'E(') MAIL F co co - Postage $ 7715, C? C3 certified fee r C3 pl F" JFI?R co aestdctea oervery fee E t a i d ???'' ,- • ? N ) ( raorsensu? sc? re Total Postage d Fess ?._ __.- ';, M1 Sent To wt-T e< C-11 ?- Strait, ApG 1{Io.,? L ?(l/g •?/ t I w PO tJwr No. , - - .?PY'? ?'l --s -»i2.? .... ----- City, State, ZIP+I _ ----- ----------- S ??i n P DD7 ? t - j y -?7 f 5 Qj T 5 ,r it JO E. DOWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW ROBERT E. DOWELL, NO. 08-1509 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ? day of ?9 2008, comes Bradley L. Griffie, Esquire, and states that he mailed a certified and true copy of a Petition for Special Relief and the resulting Order of Court dated March 11, 2008 to the Defendant, Robert E. Dowell, at his address of 1568 Boiling Springs Road, Boiling Springs, PA 17007, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on March 20, 2008. Griffie, Esquire `- (IFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 Sworn and subscribe to before me this / day of 2008 '. ? )?s?1 '<? TARP,PUBLIC RCNN J. &MKTT pwary ?ubft C*AW • iCU,+K??, 2011 JMV CoffWoision bxP n'! r xI woos i?ds ` i ?': :.F` r?+?tc?k? tCiltklf!"4;Kt:7;1 °? U.S. Postal Service CERTIFIED MAIL,,,, RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.com ,, Certified Fee ? c 4 . O Returrf Receipt Fee Postmark - O (Endorsement Required) Here Restricted Delivery Fee ?.;-- ? (Endorsement Required) :T y.4 ru O Total Postage & Fees \ N Sent To ? Street, Apt. No.; or PO Box No. ----••---- No. .1 LLB D if Ciry, State, ZIP+. - ---• • -------------• Uri' / / . rL u1 4 Postage $ nI ¦ Complete its= 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that Ws can return the card to you. ¦ Attach Ibis card to the back of the mailpiece, or on"front If space permits. 1. Article Addressed to: /7 AV AV-d- k3ol if 'SPA tAA20. P14 17061 X 1 / 1 r ?... lddre dr wiivi" 7-. D. Is delivery address dir If YES, enter delivery ss 3. Type CaRlflsd Mail ? Express Mail ?Q Regkw d ? Retum Receipt for Merchandise ? Insured Mall ? C.O.D. 4. ReaMctee t)eNvertR (Extra Feel Yes 2. (TAt" Mrw Wunher X007 o4a? ?aoa Ja? ad ? (Transfer fhxn service hd* PS Form 3811, February Zoos Donroatlc Return Recut io2595.02-M-1540 cz- t :s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JO E. DOWELL PLAINTIFF Vs. ROBERT E. DOWELL IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO PROTHONOTARY: Please enter the appearance of Gettle & Veltri, by Gregory H. Gettle, Esquire, as counsel on behalf of the Defendant, ROBERT E. DOWELL. Dated: APRIL 2008 GETTLE & VELTRI BY: 1XIIAw7717 N Gregory fl. Gettle, Esquire Sup. Ct. I.D. No. 18053 13 E. Market St. York, PA 17401 Phone: (717) 854-4899 : CIVIL ACTION -LAW NO. 080-1509 C3 - f-J c_D C`) r C n C ) r JO E. DOWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW ROBERT E. DOWELL, NO. 08-1509 CIVIL TERM Defendant IN DIVORCE STIPULATION OF COUNSEL AND NOW, the day and year hereinafter set forth, Bradley L. Griffie, Esquire, counsel of record for the above named Plaintiff, and Gregory E. Gettle, Esquire, is counsel of record for the above named Defendant, stipulate as follows: 1. Counsel hereinbefore named confirm that they have authority, provided to them by their clients, to enter into a Stipulation relative to the matters set forth herein. 2. The parties wish to have the Order scheduling a hearing in this matter for Monday, May 5, 2008, at 9:30 a.m., vacated as no hearing will be necessary. 3. The parties wish to have an Order entered providing that both of the parties are enjoined from liquidating any of their investment funds, including investment accounts, retirement accounts, 401(k) accounts and the like, or otherwise dissipating, transferring, selling or alienating any of their tangible or intangible personal property absent further Order of Court or written Agreement of the parties. 4. The parties wish to have the foregoing proposed Order of Court executed by the Court in full satisfaction of the Petition for Special Relief filed by Plaintiff/Petitioner, Jo E. Dowell, in this matter. 1 Date Date Attorney for Respondent rd CAD _ r C3R ' 'APR 21 2001 JO E. DOWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW ROBERT E. DOWELL, NO. 08-1509 CIVIL TERM Defendant IN DIVORCE ORDER OF COURT AND NOW, this ZS t ? day of April, 2008, upon presentation and consideration of the within Stipulation of Counsel, IT IS HEREBY ORDERED AND DIRECTED that the hearing scheduled in this matter for Monday, May 5, 2008, at 9:30 a.m. in Courtroom No. 1 of the Cumberland County Courthouse, is hereby vacated. PENDING FURTHER ORDER OF COURT, or written Agreement of the parties, the parties are enjoined from liquidating any or their investment funds, including investment accounts, retirement accounts, 401(k) accounts and the like, or otherwise dissipating, transferring, selling or alienating any of their tangible or intangible personal property. BY THE COURT, Cc: )h/adley L. Griffie, Esquire Attorney for Plaintiff ?"legory H. Gettle, Esquire Attorney for Defendant .l !? w 1 V Lul JO E. DOWELL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E. DOWELL, Defendant CIVIL ACTION - LAW NO. 08-1509 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 6, 2008, and served on March 8, 2008, as indicated in Affidavit of Service. 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 THE FOREGOING 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.7 - 1-7- 0 9 o c 1 6 Jo E. owell, Plaintiff qtr r,??"•,-;??.-_:r?{;; -F Tl? v'.. 2 1?i 2 ' '3 JO E. DOWELL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E. DOWELL, Defendant : CIVIL ACTION -LAW NO. 08-1509 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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: 6 -7 -1--7 " O 9 Z, 1?', b Jo E. owell, Plaintiff f"?L 'y ? 3r - 2??? tug ""' ??. 4•? wr e"^. .f ? ???1 i ? ? ??_?•??jt ' ^- f 1 JO E. DOWELL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E. DOWELL, Defendant CIVIL ACTION -LAW NO. 08-1509 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 4. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 6, 2008, and served on March 8, 2008, as indicated in Affidavit of Service. 5. 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. 6. 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 FOREGOING 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 AUTHORITI DATE: v1 elorr Bert . Dowell, Defendant 20 03 J! j ? t 7 JO E. DOWELL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E. DOWELL, Defendant CIVIL ACTION -LAW NO. 08-1509 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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 THE FOREGOING 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 AUTHORIT DATE: obert E. Dowell, Defendant 4 t„ ii ..?• ne 1! JO E. DOWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT E. DOWELL, Defendant CIVIL ACTION -LAW : NO. 2008-1509 CIVIL TERM : 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) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: March 8, 2008, by certified mail, restricted delivery. 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: July 17, 2009 by Defendant: July 8, 2009 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 29, 2009 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 29, 2009 B , Esquire ASSOCIATES Attorney for Plaintiff ELL, 1 - f t l S' ", 9 A .., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JO E. DOWELL V. ROBERT E. DOWELL NO. 08-1509 DIVORCE DECREE AND NOW, 1 Z 00 , it is ordered and decreed that JO E. DOWELL plaintiff, and ROBERT E. DOWELL , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The parties' Separation and Property Settlement Agreement, dated June 6, 2009, is incorporated herein, but not merged. By the Court, 69 ,., 4 w