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HomeMy WebLinkAbout04-2034KURT W. KIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v : CIVIL ACTION - LAW : DEBBRAE. RIEHL, : NO. 2004- XO--~ ~ Defendant : DIVORCE NOTICE TO PLEAD 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney 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 for 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 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 32 South Bedford Street Carlisle, Pennsylvania 717-249-3166 KURT W. RIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v : CIVIL ACTION LAW : DEBBRA E. RIEHL, : NO. 2004 - ,20 -~ ¥' Defendant : DIVORCE COMPLAINT Plaintiff, Kurt W. Riehl, by his attorneys, Broujos & Gilroy, P.C,, sets forth the following: 1 Plaintiff, Kurt W. Riehl, is an adult individual residing at 2 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania. 2 Defendant, Debbra E. Riehl, is an adult individual residing at 2 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married on June 29, 1995 in Washington D.C. 4 Both Plaintiff and Defendant have resided continuously in the Commonwealth of Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of this action. 5 There have been no prior actions of divorce or for annulment between the parties. 6 The marriage is irretrievably broken. 7 Plaintiff has been advised that counseling is available and Plaintiff may have the right to request that the court require the parties to participate in counseling. 8 The Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing him from the Defendant. BROUJOS & GILROY, P.C. ~~e 4 North Itano~er Street Carlisle, PA 17013 717-243-4574 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 490~ relating to unsworn falsification to authorities. DATE: Ku~W.~ KURT W. RIEHL, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW No. 2004-2034 DEBBRA E. RIEHL, Defendant DIVORCE PRAECIPE TO ENTER APPEARANCE AND ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: Please enter the appearance of Robert B. Lieberman, Esquire, as attomey for Defendant, Debra E. Riehl, in the above captioned divorce action. On behalf of the Defendant, Debra E. Riehl, I hereby accept service of a certified copy of the Complaint in Divorce on May 12, 2004. Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor P.O. Box 1(}04 ttarrisburg, PA 17108-1004 (717) 236-1485 Attorney for Defendant KURT W. RIEHL, : IN THE COUI;',T OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v : 2004- 2034 CIVIL TERM : DEBRA E. RIEHL, : Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant through her attorney Robert B. Lieberman, by first class mail on May 12, 2004. A copy of the Praecipe to Enter Appearance and Acceptance of Service, is attached hereto and marked Exhibit A. Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before me this 2nd day o.f September, 2004 Notary Public Notarial Seal Bridget Ann Carcoran, Notary Public Carlisle Bom, Cumberland County My Commission Expires June 10, 2006 Member, Pennsy~van!a association of Notaries KURT W. RIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CML ACTION - LAW : No. 2004-2034 DEBBRA E. RIEHL, : Defendant : DIVORCE PRAECIPE TO ENTER APPEARANCE AND ACCEPTANCE OF SERVIL~E TO THE PROTHONOTARY: Please enter the appearance of Robert B. Lieberman, Esquire, as attorney for Defendant, Debm E. Riehl, in the above captioned divorce action. On behalf of the Defendant, Debra E. Riehl, I hereby accept service of a certified copy of the Complaint in Divorce on May 12, 2004. Dated: ~'- ]~-- ~ ~~ I~>' ~n'~n-'~ Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Defendant KURT W. RIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff i CUMBERLAND COUNTY, PENNSYLVANIA %. : 2004 - 2034 CIVIL TERM DEBRA E. RIEHL, : ; Defendant : IN DIVORCE STIPULATION The parties to the above action stipulate and agree that the caption can be modified to read "Debra E. Riehl" as the defendant rather than the original document which said "Debbra E. Riehl". SEPARATION AND PROPERTY SETTLEMENT AGI~E~MENT THIS AGREEMENT, mane this ,-~ 14 day of ,~c,~,b~'~'-- , 2004, by and between DEBRA E. RIEHL, now of Boiling Springs, Cumberland County, Pennsylvania, hereinaRer referred to as "Wife", -AND- KURT W. RIEHL, now of Boiling Springs, Cumberland County, Pennsylvania, hereinafter referred to as "Husband", WHEREAS, Husband and Wife were lawfully married on June 29, 1984, in Washington, D.C.; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which is considered to be an equal division of all joint property and will provide for their mutual responsibilities and rights growing out of the marriage relationship. NOW, THEREFORE, in consideration of the premises and of the promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of thc parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from thc other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken ns un anmission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. Each party shall b~ free from interference, authority and contact by the other, as fully as ifhe or she wea~ single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the oth~r, nor compel the other to cohabit with the other, or in any way harass or malign the ~ther, nor in any way interfere with thc peaceful existencc, separate and apart from thc other. 2. SUBSEQUENT DIVORCE Thc parties hereby acknowledge that Husband has filed a Complaint in Divorce in Cumheriand County, Permsylvania, docketed to No. 2004 - 2034, on or about May 6, 2004, claiming that the marriage is irretrievably broken under the no- fault, mutmd consent provision of Section 3301(c) of the Pcnusylvania Divorco Code. Husband and Wife hereby express their agreement that thc marriage is in~trievably broken and each express their intent to execute any and all affidavits, waivers or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code immediately following thc expiration of the ninety (90) day waiting period. The parties hereby waive all rights to request Court-ordered counseling under thc Divorce Code. Neither party to such action shall seek alimony or spousal support contrary to the provisions of this Agreeancnt. It is further specifically understood and ngreed by the parties that thc provisions of this Agrecraent relating to equiteblc distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not he effected in any way by any such separation or divorce; and that nothing in any such decree, judgment, divorce or order of =2- separation or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by end between the parties hereto that this Agreement shall survive end shall not bo merged into any decree, judgment, order of separation or divorce. It is specifically agreed, h~wever, that a copy of this Agreement or the substance of fha provisions thereof, may b~ incorporated into any divorce, judgmeat or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the perties to permit this Agreement to survive any judgment or decree end to be forever binding end conclusive upon the parties. 3. EFFECTIVE DATE The effective date of this Agreement shall be the "date of execution" or "execution date", defined as thc date upon which it is executed by thc parties if they have each executed the Agreement on the same date. Otherwise, thc "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 4. DEBTS AND OBLIGATIONS Husband represents and warrants to Wife that he has not, and in thc future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and he shall indcranify ~nd save Wife harmless from any end all claims or demands made against her by reason of such debts or obligations incurred by him, except as otherwise set forth herein. Wife represents end warrants to Husbend that sh~ has not, and in thc future she will not, contract or incur eny debt or liability for which Husbend or his estate might be responsible end she shall indemnify end save Husband harmless fi'om eny and all claims or demands made against him by reason of such debts or obligations incurred by her, except as otherwise set forth herein. -3- 5. SPECIFIC DEBTS Husband hereby agrees to assume the full and sole responsibility for the payment of ail debts and obligations in his name only and those in the joint names of the parties except for the Washington Mutual obligation incident t~ the mariiai residence. Husband further agrees to indemnify and save Wife harmless from any liability, obligation, expense, claim or demand made against her by reason of the aforesaid obligations in his name only or in the joint names of the parties. Wife hereby agrees to assume the full and sole responsibility for the payment of the obligation due Discover Card and she further agrees to indemnify and save Husband harmless from any liability, obligation, expense, claim or demand made against him by reason of the aforesaid obligation. 6. MUTUAL RELEASES Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representativas, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any and all cause or causes of action for divorce and except any or ail causes of action for breach of any provisions of this Agreement. Further, each party does hereby remise, release, quitclaim and forever discharge the other and the estate of the other from any and every claim that each other may now have, or hereafter have or can have at any time, against the other, or in and to or against the other's estate, or any part thereof, whether arising out ofeny former contracts, engagements or liabilities of the other, or by way of dower or claim in the nature of dower, widow's righis, or under the intestate laws, or the right to take against each other's will, or for support or maintenance, or of any other -4- nature whatsoever, except any rights accruing under this Agreement. 7. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances and other household personal property between them. The parties mutually agree that Wife shall, from and after the date hereof, be th~ sole and separate ownar of all such tangible personal property presently in her possession and that Husband hereby releases and relinquishes any right, title or interest he may have had in the past or now has in the aforesaid tangible personal property in Wife's possession. The parties further agree that Husband shall, from and after thc date hereof, be the sole and separate owner of all such tangible personal property presently in his possession and that Wife hereby releases and relinquishes any right, title or interest she may have had in the pest or now has in the afore, said tangible personal property in Husband's possession. 8. SUPPORT OF SPOUSE In exchange for and in consideration of the promises and representations made hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claim or demand of whatsoever nature which ho or she now has or hereafter can, shall or may have against the other or the respective separate property of the other under the laws of the Commonwealth of Pennsylvania or any other governing state, counlxy, territory or jurisdiction in the nature of spousai support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative, permanent or lump sum and right to se, ok equitable or community distribution or division or assignment of property or similar marital rights. 9. LEGAL FEES AND COSTS Husband and Wife hereby agree to assume the responsibility for their own attorney's fees and costs incident the pending divorce and the within Agreement. 10. VEHICLES Wife shall retain possession and ownership of the :2004 Cht3,sler 300 presently in her possession, free and clear of any ciaim, right, title or interest in said vehicle on the part of Hnsband. Wife further agrees to assume the full and sole responsibility for the obligation due M&T Bank in connection with said vehicle and she shall indemnify and hold Husband harmless from any liability, obligation, expense, claim oi demand relative to the ~_IL. vehicle and the aforesaid obligation. rid:2 Husband shall execute a Power of Attorney authorizing ~ ~ transfer ll~s-any interest he may have insaid vehicle to Wife. I 1. SEPARATE ASSETS The parties hereby agree that, as to all assets not specifically mentioned herein which arc presently titled in the sole name of one of the parties hereto or, if untitled, are presently in the sole possession of one or more of the parties hereto, the party not having title thereto or possession thereof hereby waives, releases, relinquishes and forever abandons any and ail claims therein, and acknowledges that the party having title or possession of such items shall be the sole and exclusive owner thereof. 12. RETIREMENT AND PENSION PLANS Each of the parties shall retain as their sole, separate and exclusive property any and all pension, retirement or 401 (lc) plans presently titled in their respective names free and clear of any claim, right, title or interest on the part of the other party. 13. PROPERTY SETTLEMENT Husband hereby agrees to pay Wife, contemporaneously with the execution of the within Agreement, the total sum of Tan Thousand ($10,000.00) Dollars which sum Wife accepts as a full, final and complete property settlement. 14. MARITAL RESIDENCE Husband and Wife hereby acknowledge that they are the joint owners ora marital residence situate at 2 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania. Husband hereby agrees to execute, contemporaneously herewith, a deed in order to transfer to Wife his interest in and to the aforesaid marital residence. -6- Wife shall assume as her sole obligation ail of the expenses incident to the use of the aforesaid residence, including, without limitation, any and all mur~gage payments (Washington Mutual), liens, taxes, liability and fire insurance, utilities, sewer, water, refuse collection, assessments, proper maintenance, repairs, additions and improvements, and she further covenants and agrees to indemnify and hold Husband harmless from any such liabilities, obligations or expenses or any claims or demands as a result thereof 15. TRANSFERS SUBJECT TO EXISTING LIENS Notwithstanding any other provisions in this document, ail property transferred hereunder is subject to tho existing lien or liens which may exist. The respective transferee of such property agrees to indemnify and save harmless the other party from any claim or liability that such other party may suffer or may be required to pay on account of such lien or encumbrance. 16. EQUITABLE DISTRIBUTION By this Agreement the parties have intended to effect an equitable division of their jointly owned property. The parties have determined that an equitable division of such property conforms to a just and right standard, with due regard to the rights ofeech party. 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 effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the intention of the parties to treat ail transfers herein as non-taxable. 17. ADVICE OF COUNSEL Husband and Wife declare that each has had a full and fair opportunity to obtain independent legal advice and counsel of his and her selection; that Wife, has been independently represented by counsel, Robert B. Liebennan, Esquire and that Husband has been independently represented by counsel, Hubert X. Gilroy, Esquire. The parties acknowledge that they fully understand the facts and they ecknowledge and accept that this Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and -7- voluntarily, with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any improper or illegal agreement or agreements. 18. ADDITIONAL INSTRUMENTS Each of the parties sh~ll, from time to time at the request of the other, execute, acknowledge and deliver to the ~ther party any and all further instruments or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 19. VOLUNTARY EXECUTION Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such parties have any interest, the sources and the amount of the income of such party of every type whatsoever and of all the facts relating to the subject matter of this Agreement. 20. WAIVER OF RIGHTS The parties hereto have been informed of their rights or have been advised to seek counsel to inform them of their rights under the Divorce Code, particularly the provisions for alimony, alimony pendente lite, equitable dislfibution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Each party may acquire either personal or real property in their own name. Any property so acquired shall be owned solely by the individual and shall not be subject to any claim whatsoever by the other party. -8- 21. MODIFICATION AND WAIVER A modification or waiver ofeny of the provisions of this Agreement shall be effected only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon the strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 22. ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties, and there am no representations, warranties, covenants or undertakings other than those expressly set forth herein 23. DESCRIPTIVE HEADINGS The descriptive headings used herein ate for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 24. INDEPENDENT SEPARATE COVENANTS It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shail be deemed to be a separate and independent agreement. 25. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other remedies or relief as may be available to him or her and the party breaching this Agrceroent shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement or in seeking such other remedies or relief ns may be available to him or her. 26. APPLICABLE LAW This Agreement shall bo construed under the laws of the Commonwealth of Peunsylvania. 27. VOID CLAUSES Ifauy term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only -9- that term, condition, clause or provision shall bc stricken from this Agreement and in all other respects this Agreement shall bc valid and continue in full force, effect and operation. 28. AGREEMENT BINDIN(} ON HEIRS This Agreement shall be binding on and shall inure to the benefit of the parties hereto and their respective heirs, ~xecutors, administrators, successors and assigns. 29. FINANCIAL DISCLOSURE The pm'tics confirm that each have relied on the substantial accuracy of thc financial disclosure of thc other as an inducement to the execution of this Agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands end seals the day and year first above written. WITNESS: -10- COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF DAUPHIN : On this .17x'a'day of ~4~ e-- o_~-v- ,2004, before me, the undersigned officer, personally appeared DEBRA E. RIEHL, knowp, to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. om~ [ Notary Pub~ COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : On tiffs ~'~ day of {)'IA~ ~o [,- 2004, before me, the undersigned officer, personally appeared KURT W. RIEHL, known to me (or satisfactorily proven) to be thc person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for thc purposes therein contained. B~ndget Ann Coec~. N~ ca~s,c ~. Conferred count, ~Iotary~bl~ My Commission E,xpites .lime I0, -Il- KURT W. RIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ; v : 2004 - 2034 CIVIL TERM : DEBRA E. RIEHL, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301~c) OF THE DIVORCE CODE I. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on May 6, 2004. 2. Defendant acknowledges receipt and accepts ser~'ice of the Complaint on or about May 14, 2004. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety, days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry, of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of properly., 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I veri~' 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. Kurt W. Riehl/Plaintiff f KURT W. RIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA _. v : 2004 - 2034 CIVIL TERM .. DEBRA E. RIEHL, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER .SECTION 3301(c} OF THE DIVORCE CODE I. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on May 6, 2004. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about Ma)' 14, 2004. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. ! consent to the entry, of a final decree of divoree without notice. 5. I understand that ! 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 divoreed until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediate.ly after it is filed with the Prothonotary.. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I veri~, that the statements made in this affidavit are true and correct. ! understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~/]~/~ ~~~ ~ Debra E. Riehl/Defendant KURT W. RIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff ~ v CUMBERLAND COUNTY, PENNSYLVANIA : 2004 - 2034 CIVIL TERM DEBRA E. RIEHL, : 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: I. Ground for Divorce: Irretrievable breakdown under Section (x)3301(c) (L~301(d)(I) oftbe Divorce Code. (Check applicable section.) 2. Date and manner of sen,ice of the Complaint: May 12, 2004 by Attorney Robert B. Lieberman, attorn~, for Debra E. Riehl. 3. (Complete either Paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: August 19, 2004; Defendant: August 17, 2004. (b) (I) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code:~; (2) Date of service of the Plaintiff's affidavit upon the Defendant: 4. Related claims pending: None. ~' 5. Complete either (a) (b). (a) Date and manner record, a copy of which of service of the notice · is attached: of intention to file praecipe to transmit (b) Date Plaintiff's Waiver of Notice in §3301(e) Divorce was filed with the Prothonotary: September 2, 2004 (c) Date Defendant,s Waiver of Not/ce in §3302(c) Divorce was filed with the Prothonota~.: September 2, 2004 .... 4 North Hanover Slreel Carlisle, PA 1701.t 7 i 7-243-4574 iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY I(URT I8. RIEHL STATE OF ~ PENNA. Platfitiff No. 2004 - 2034 VERSUS DEBRA E. RIERL Defendant DECREE IN DIVORCE --T AND NOW,. /~ , ~ IT IS ORDERED AND Kurt W. Riehl DECREED THAT , PLAINTIFF, AND Debra E. Riehl · 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; Property Settlement Agreeement dated August 5, 2004 ts incorporated into this Order ATTEST~ J. PROTHONOTARY