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HomeMy WebLinkAbout04-3880 JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2004-?&OCIVIL TERM NATHANIEL L. CHAPLINSKI, 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2004- 300 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the Plaintiff, Jennifer L. Chaplinski, by her attorney, Marcus A. McKnight, ill, Esquire, and files this Complaint in Divorce against the Defendant, Nathaniel L. Chaplinski, representing as follows: I. The Plaintiff is Jennifer L. Chaplinski, an adult individual residing at III Locust Way, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Nathaniel L. Chaplinski, an adult individual residing at 3276 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on January 17, 1998. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, By: A. ight, ill, Atto or Plaintiff We Pomfret Professional BIding 60 West Pomfret Street Car I la 17013-3222 (717) 249-2353 Supreme Court I.D. No. 25476 Date: August 4, 2004 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. (\.,...:*).> ~~- JE~FER L. CHAPLlNSKI Date: August 4, 2004 JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVILACTlON.LAW 2004- CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: August 4, 2004 (1.. '_\"~, ~(i'p\:'..,~L' J~NilER L. CHAPLINSKI ~ ~ 01 4: ,.--,. '::L ) ""-'" .-.....- "'-- ;:,: ,.~ :-::0, 0, 5\~\ 'J ~~J----~ :::g ""- ~ ~ "'- '::) c ~ T- ......., - ('dJ r' --;'j ~. . i..:"..' ~ (\ ., (,) o -..."- JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COl'RT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2004..3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, ill, Esquire, being duly sworn according to law, does depose and state: I. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Nathaniel L. Chaplinski, on August 13, 2004, by certified, restricted delivery mail, addressed to him at 3276 Spring Road, Carlisle, Pennsylvania 17013, with Return Receipt Number 7002 0860 0000 1074 4346. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are I:fe and co ecl. I understand that false statements herein made are subject to the penalties of Pa. C. Section 4904, relating to unsworn falsification to authorities. t./) Date: August 16,2004 ..Jl .:r ITI ~ U S Post . CE.RTIFIED MAil H(CLlP 1 (Do;nestJ( fll.lIl Dilly Nu Ilhur,jJH (> Cuv['rdql' Provided) .:r r- C .-'I C C C C QAlf fls'otC &mAl ,~~ ~,oO 5 3,50 $ 'l,~~ po..... $ Certffled Fee C Return _ Fee ..Jl(E- 00 _ C(E_ ru TotIII Postage &,... F.. PS Fur' \I,ll! Il.,. 1)02 ',{" Flt'verse for I structlon':; II Complete ~ems 1, 2, end 3. Also complete . ~em 4 If Restricted Delivery's desired. . Print your name and address on the reverse so that we can return the card to you. . Attech this card to the beck of the mellplece, or on the front ~ spece pennlts. 1, Article Addressed to: NATHANIEL L CHAPLIN SKI 3276 SPRING ROAD CARLISLE PA 17013 3. ServIce Type C[ Certified Mall 0 Express MslI [J Registered II. Return Receipt for M81ot_.... o Insun>d Mall 0 C.O.D. .. _DeIIvery?(FxtrBFi C[v.. 2. Article Number rrra~ from service 1sbaI) PS Form 3811, A~t 2001 7002 0860 0000 1074 4346 Domestic Return ReotMpt t0259S-02-M-1035 ", (';~:) ('~) C,) "-'i ::..""" '.,,,. Ci) --I r,.) C0 J;:'~ ('4- 26 JO MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this 23rd day of November, 2004 by and b tween JENNIFER L. CHAPLINSKI, (hereinafter referred to as "WIFE") and NATHAN L L. CHAPLINSKI, hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on January 17, 19 8, in Cumberland County, Pennsylvania. WIFE filed a Complaint in Divorce in Cumberland C unty, Pennsylvania, docketed at 2004-3880 Civil Term on August 6, 2004. The parties hereto agree and covenant as follows: I. 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 right and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner conforms to a just and right standard, with due regard to the rights of each party. It is the i tent of the parties that such division shall be final and shall forever determine their respective ri ts. The division of existing marital property is not intended by the parties to constitute in any w y a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from the othe at any place or places that he or she may select as they have heretofore been doing. Neither p y shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter what oever. Each party may carry on and engage in any employment, profession, business or other act vity as he or she may deem advisable for his or her sole use and benefit. Neither party shall i terfere with the uses, ownership, enjoyment or disposition of any property now owned and not sp ified herein nor property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefit to be obtai ed by both of the parties hereto and the covenants and agreements of each of the parties to the ther. The adequacy of the consideration for all agreements herein contained is stipulated, conti ssed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: a. is represented by counsel of his or her own choosing; b. is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities of the parties; c. enters into this Agreement voluntarily after receiving advice of counsel; d. has given careful and mature thought to the making of this Agreement; e. has carefully read each provision of this Agreement; and f. fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. This Agreement shall become effective immediately as of the date of execution. 2 5. It is the purpose and intent of this Agreement to settle forever and completely the nterest and obligations of the parties in all property that they own separately, and all property tha would qualifY as marital property under the PeIlIlsylvania Divorce Code, Title 23, Section 40 I ), and that is referred to in this Agreement as "Marital Property", as between themselves, their h 'rs and assigns. The parties have attempted to divide their Marital Property in a manner that conti rms to a just and fair standard, with due regard to the rights of each Party. The division of e isting Marital Property is not intended by the parties to constitute in any way a sale or exch ge of assets, and the division is being effected without the introduction of outside funds 0 other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obli tion under the PeIlIlsylvania Divorce Code relating to spousal support or alimony. 6. Each party represents and warrants that he or she has made a full and fair disclosure 0 the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each arty further represents that he or she has made a full and fair disclosure of all debts and obligatio s of any nature for which he or she is currently liable or may become liable. Each further repre ents and warrants that he or she has not made any gifts or transfers for inadequate considerati of Marital Property without the prior consent of the other. Each Party acknowledges that, to the extent desired, he or she has had access to all int and separate State and Federal Tax Returns filed by or on behalf of either or both Parties d ng marriage. 3 7. REAL ESTATE: The parties own the property known as 111 Locust Way, arlisle, Pennsylvania 17013. HUSBAND and WIFE agree to place the martial residence for s e. the following debts will be paid out of the proceeds of the sale of marital residence: a. The First and Second Mortgage; and b. The credit cards - Citibank and Discover. The balance will be split by the parties equally. 8. DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely responsible for her debts. HUSBAND will indemnifY and hold harmless WIFE fr all obligation related to his debts. WIFE will be solely responsible and will indemnifY an hold harmless HUSBAND from any claim made against him related to her debts. 9. SPOUSAL SUPPORT AND ALIMONY: The parties hereby agree that neither arty will seek spousal support or alimony. 10. PERSONAL PROPERTY: The parties agree that the personal property shall be div ded as follows: HUSBAND shall receive the following items: a. The personal property in his possession; b. His bank accounts; c. Any life insurance policy; and d. His employee benefits and retirement; 4 WIFE shall receive the following items: a. The personal property in her current possession; b. Her bank accounts; c. Any life insurance policy; and d. Her employee benefits and retirement. The WIFE hereby waives all right and title which she may have in any personal p of the HUSBAND. HUSBAND likewise waives any interest which he has in the p property of the WIFE. Henceforth, each of the parties shall own, have and enjoy indepen ently of any claim or right of the other party, all items of personal property of every kind, natu e and description and wherever situated, which are then owned or held by or which may h after belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to di pose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. Each party agrees that neither will incur obligations, liens or liabilities on acco t of the other and that from the date of this Agreement, neither party shall contract or ncur obligations, liens or any liability whatsoever on account of the other. 11. AUTOMOBILES: a. HUSBAND agrees to waive any and all interest which he may have in the automobiles in possession ofthe WIFE. b. WIFE agrees to waive any and all interest which she may have 5 in the automobiles in possession of the HUSBAND. They each waive any claim which they have in any automobile owned by the other party. 12. INSURANCE and EMPLOYEE BENEFITS: The parties agree that any life in Ufance policies on the life of HUSBAND or WIFE or any other employee benefits, including ut not limited to retirement, profit sharing or medical benefits of either party, shall be their own. IFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND wai es all right, title, and claim to any of WIFE'S employee benefits. 13. BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, tit! and interest which she may have in the savings or checking or any other bank accounts f the HUSBAND. The HUSBAND agrees to waive all interest which he may have in the savi gs or checking or any other bank accounts of the WIFE. 14. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the maniage. It is agreed that the parties will execute and file the consents nece sary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall p all the costs and legal fees of the party who is seeking the divorce. 15. BREACH: If either party breaches any provisions of this Agreement, the other y should have the right, at his or her election, to sue for damages for such breach or seek such 0 remedies or relief as may be available to him or her, and the party breaching this contract will e 6 responsible for payment of legal fees and costs incurred by the other in enforcing thei rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all rther instruments that may be reasonably required to give full force and effect to the provisions f this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, and that it is being entere into voluntarily, and that it is not the result of any duress or undue influence. The provisions Agreement are fully understood by both parties and each party acknowledges that the Agre ment is fair and equitable, that it is being entered into voluntarily, and that it is not the result any duress or undue influence. 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding 0 the parties and there are no representations, warranties, covenants or undertakings other than t ose expressly set forth herein. 19. APPLICABLE LAW: This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania. 7 20. PRIOR AGREEMENTS: It is understood and agreed that any and all p operty settlement agreements which mayor have been executed prior to the date and time f this Agreement are null and void and of no effect. 21. PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for the own costs and legal fees required to obtain and complete the divorce. 22. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise pro ided, each party may dispose of his or her property in any way, and each party hereby waive and relinquishes any and all rights he or she may now have or hereafter acquire, under the pres nt or future laws of any jurisdiction, to share in the property or the estate of the other as a result 0 the marital relationship, including without limitation, dower, courtesy, statutory allowance, wi ow's allowance, right to take in intestacy, right to take against the Will of the other, and right to t as administrator or executor of the other's estate, and each will, at the request of the other, exe ute, acknowledge and deliver any and all instruments which may be necessary or advisable to any into effect this mutual waiver and relinquishment of all such interests, rights and claims. 8 IN WITNESS WHEREOF, the parties hereunto have set their hands and seals he day and year first above written. WITNESSES: ~Y",.,d.~.J.ld./~ ~~~~.k: lA~b~f~~ (S AL) ,W,;tA'..#X ~ ~.L f....t-./ //~l1~ (l ;J /' - NATHANIE L. HAPLINSKI (S L) COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this ~~ ofl)/JlI(lt}~ ,204, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumbe and, JENNIFER L. CHAPLINSKI, known to me (or satisfactorily proven) to be the person ose name is subscribed to the within Marriage Settlement Agreement, and acknowledges tha she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEAlTH OF PENNSYLVANIA NoIaI1aI Seal Martha l. Noel. NoIaIy Public CarlIsle Boro. CuTbeI1aiId County My Co.......... Explr"s Sept 18, 2007 Member, Pennsytvanla AssocJsflon Of Notaries 9 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this ~~ay of '1'jIJw,.,L(, 004, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumb rland, NATHANIEL L. CHAPLINSKI, known to me (or satisfactorily proven) to be the erson whose name is subscribed to the within Marriage Settlement Agreement, and acknowledg s that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NoIattal Seal Mar1ha L Noel, NcXary Pullic CaIflsIe Boro, 0Jrmer1and Ccooly My Ca..,...... 8qJ/fQs Sept. 18, 2.007 Member, ~n",y1Y"I. A_Ion 01 NoI.rIeI 10 JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COURT OF COMMON PLE S OF : CUMBERLAND COUNTY, PENNSYL ANIA v. CIVIL ACTION . LAW 2004.3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, ill, Esquire, being duly sworn according to la , does depose and state: I. That he is a competent adult and attorney for the plaintiff in the captioned a tion in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the deti ndant, Nathaniel L. Chaplinski, on August 13, 2004, by certified, restricted delivery mail, addre sed to him at 3276 Spring Road, Carlisle, Pennsylvania 17013, with Return Receipt Number 700 0860 000010744346. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are t e and co ecl. I understa d that false statements herein made are subject to the penalties of Pa. C. S unsworn falsification to authorities. G2 E Date: Angust 16, 2004 . ...0 :;r rn U.S. Postal Service CEflTIFIED MAIL RECEIPT (Domestic MatI Only, No Insurance Coverage Provided) :: POlltage $ \..> :;r r- Cl M Cl Cl Cl Cl 1f"1-- f:: "tJllAM'" Certlfltld Fee- C Return Receipt Fse ..n {Elldor9ement Requl cO Restricted Oellve Fee CJ (Endorsement Req ru TOtal_&F_ $ Cl Cl r- -... H". . 3.50 7, :':,9 '" \ ~,Ii ent 0 i('~._" NATHANIEL L CHAPLINSKJ; , _..._.u._.u..u.n...._~..___..._....__..._...._...n.u.._._.....n..."......~.._u..__..+._.n. S'"". Apt:Wb76 SPRING ROAD. , . or PO Box1iti. " _m_m..mCARLISl.E:....E.A....1.7.O'L3.........';_.n..m......n..~.;~...n. CIty,Stllte,ZlP+4 '"-'':;''' ~'~.'."-. ~ PS Form :3800, April 2002 See Reverse for Instructions . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery ;s 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 mail piece, or on the front if space permits. 1. Article Addressed to: D. Is delivet)1i~ . item 1? If YES, e~e; de~~ery address below: NATHANIEL L CHAPLINSKI 3276 SPRING ROAD CARLISLE PA 17013 3_ Service Type IX Certified Mail 0 Express Mail o Registered i2I Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee IX Yes 2. Article Number (Transfer from service label) PS Form 3811 . August 2001 7002 0860 0000 1074 4346 Domestic Return Receipt 102595-02-M-l035 < , '''','j " j-.i L) r,} t,,) J:~~ /~ ~~ - ---- JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVA IA v. CIVIL ACTION. LAW 2004 . 3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on Au ust 6, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days hav elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer" fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that alse statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to uns om falsification to authorities. Date: ~ C) ,"" ~ ,....., = C.~:, _C"" .,"',,~ c..~) .,;:;':: :"".1 ~~ --,1"' (') --11 .-4 r;;'iI\ -Orn :'':'1) ::;~'=\; "--,',.C) '".f11 ::--:'j ?:tl -< .r. (,n - JENNIFER L. CHAPLINSKI, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION. LAW 2004 - 3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on A ust 6, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days hav elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that alse statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to uns om falsification to authorities. / Date: 2 1. A~l.J 6 V /7 ;\.) \j. ~ NATHANIEL L. CHAPLINSKI Defendant ~-' ,',::::> ~~ - "s'~ \".} .,~::.. -- :S': .,-:." ~:?\ .-\ --r:-.;:,o" {~'f~ :9,\3 co.,"[ '.>,(_1 ~1~~; ~~;'1 ,-, - .:;:"' C1' - JENNIFER L. CHAPLINSKI, Plaintiff v. : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION - LAW 2004 . 3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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 Com 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 alse statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to uns rn falsification to authorities. Date: \ \ - :)3-\jY I~= ~('1t~\1~.JG NNIF L. CHAPLI SKI Plaintiff ~,.. () "n .-' i~f?, -"r,,)n.; "::.u(,( (,),() '~~;~l~\ ~~.,:\ ~~~ ,,' c.:.;') {::":? ~:.;."'" ~. ..'.'.-" C) '""!~~ <:-} ....n G::. :::l ..!. .- ;::- Ci~ JENNIFER L. CHAPLINSKI, Plaintiff v. : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION - LAW 2004 - 3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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 Cou 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 statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to uns rn falsification to authorities. /~t(/C~ NATHANIEL L. CHAPLINSKI Defendant Date:?1 1\)\ ~I {} '/ ~ (..:~::';:'. .- -r-:. (i.~ ~>? .... o -1'1 .-\ -~J:;, '":52 .-I'i"-':' --;:iU:; ';]I::.( ';~)~A :J.l:: ,")' :A -;:) -- .' ,;1 .--<- ,," 0--' - JENNIFER L. CHAPLINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V A IA v. CIVIL ACTION. LAW 2004 . 3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that 1 ay request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotar 's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I pm1ici ate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that alse statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsw rn falsification to authorities. Date: Z\ /1)(,,--' cY! ^;~~k~/~ NATHANIEL L. CHAPLINSKI Defendant r--> c;"} :t'~ ~;~ 1" .~;- () .:~n .-4 ;J(~~', \ fT" -c,c__~ :';)\..( ~-~.C? ::fc. ~~\1 <)-,"~ ~~:. i.-.t\ , ) ~"".\ :P'> ......,. ....;;. -v -,,~ .;"... - '" _.1 JENNIFER L. CHAPLIN SKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2004-3880 CIVIL TERM NATHANIEL L. CHAPLINSKI, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infonnation, to the court for entry of a divorce deer e: l. Ground for Divorce: Irretrievable breakdown under Section 330t(c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was serv d upon the defendant, Nathaniel L. Chaplinski, on August 13,2004, by certified, restricted delivery mail, addresse to him at 3276 Spring Road, Carlisle, Pennsylvania 17013, with Return Receipt Number 7002 0860 0000 t074 4346 3. Comptete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the ivorce Code: by plaintiff: November 23, 2004: by defendant: November 23, 2004. (b)(I) Date of execution of the affidavit required by Section 330 t (d) of the Divorce Code: (b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention (0 file Praecipe to Transmit R cord, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed wi the Prothonotary: November 24, 2004. Date defendant's Waiver of Notice in Section 3 the Prothonotary: November 24, 2004. November 24, 2004 r-'> ~ .,- ~,"/' .(~ -~ r".,) .r;:' ---- 4:.'l -x" - o -"n -' ~,'-n ""'Ie; ..,.., '"t1Q ''':.1 --L C"2 C) -:~$~}) ;")\ ~,j, 'T~ , ~J. C"' -- J::~ -' - ~~~~~~~~~~ ~~~~~~~~ ~~ ~~ ~~~~~~ ~~~~~~~~~~~ ~~~~~~~~~~~~~ , ~ ~~'f.~~";~ 'f.~~~~:+::+:'f.~,., , , , , , , , , , , . , , , , . , . . . , . . . , . . . . , . . . , . . . . , . . . . . . , . . . IN THE COURT OF COMMON PLEA . . . . . . . . . . . . . . . . . . . . . OF CUMBERLAND COUNTY STATE OF JENNIFER L. CHAPLINSKI, Plaintiff VERSUS . . . . . NATHANIEL L. CHAPLINSKI, Defendant . . . . . . . . . . . . . . AND NOW, . . PENNA. NO. 2004-3880 CIVIL TERM CIVIL ACTION - LAW DECREE IN DIVORCE N~>!'-u-- 30r DECREED THAT JENNIFER L. CHAPLINSKI . . . , . . . . . . . . . . AND NATHANIEL L. CHAPLIN SKI ARE DIVORCED FROM THE BONDS OF MATRIMONY. IN DIVORCE 2004 , IT IS ORDERE AND , PLAI NTI FF , DEFENDAN , THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER H S NOT . . , . . . . . . . . . . . . . . . . . . The Marria e Settlement A reement dated No ember the . . . . . . orated into this Divorce, but not mer ed. BY THE COURT: PROTHON ARY ~:+:,., ~:+: ~:+:~ ~:+: ,.,~:+: :+::+::+:~:+::+: ~:+: ~:+:'f. ~~Of.:+:~ 'f.:+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ Of. ~ ~ Of'!' J. ~ ~ ~.H"'--- r.? . /?'TF :f!.'!/ ~ .~vtt,.w l:" C/ q~''''' r ? /'1"'- ~/ /'P fir? r t!/ ,. .