HomeMy WebLinkAbout01-2762James V. Darden, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 01- ,~?~,~. CIVIL TERM
Pamela S. Darden, : CIVIL ACTION
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 in divorce or annulment may 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 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 the 1a Floor, Cumberland County
Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
James V. Darden, .' IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 01- ,; .7~,,~. CIVIL TERM
:
Pamela S. Darden, : CIVIL ACTION
Defendant : IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHT-~
1. Plaintiff is James V. Darden, an adult individual, currently residing at
35719 Castlewoods Ct., Wayne County, Michigan.
2. Defendant is Pamela S. Darden, an adult individual, currently residing at
2284 Pine Road, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing
of this Complaint.
4. Plaintiff and Defendant were married on February 5, 1982 in Baltimore
County, Maryland.
5. There have been no prior actions for divorce or annulment between the
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The 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, the 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 have lived separate and apart since November 15, 1997 and
continue to live separate and apart as of the date of this Complaint.
10. The parties marriage is irretrievably broken.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in
Divorce.
Respectfully Submitted
TURO LAW OFFICES
Date Robert J. Multi,rig, Esq'ul're
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
James V. Darden, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 01- o3'7~,~ CIVIL TERM
Pamela S. Darden, CIVIL ACTION
Defendant : IN DIVORCE
NOTICETO THE DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file a
Counteraffidavit within twenty (20) days after this Affidavit has been sewed on you or
the statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER
6330'1(D~ OF THE DIVORCE CODE
1. The parties to this action separated on November 15, 1997 and have
continued to live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of marital
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT· I UNDERSTAND THAT FALSE STATEMENTS HEREIN
MADE ARE SUBJECT TO THE PENALTIES OF PA. C.S. ~4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES·
II i
JAMES V. DARDEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : NO. 01-2762 CIVIL TERM
:
PAMELA S. DARDEN, : CIVIL ACTION
Defendant : IN DIVORCE
ACCEPTANCE OF SERVICE
I, Pamela S. Darden, the Defendant, in the above captioned divorce action,
hereby accept service of the Complaint in Divorce and the Plaintiff's Affidavit filed on
May 7, 2001, in the Court of Common Pleas of Cumberland County, Pennsylvania, and
certify that I am authorized to do so.
Date Pamela S. Darden
James V. Darden, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 01- ~7(~'~. CIVIL TERM
Pamela S. Darden, : CIVIL ACTION
Defendant : IN DIVORCE
DEFENDANT'S COUNTERAFFIDAVIT
UNDER 6330'1(D) OF THE DIVORCE CODF
1. Check either (a) or (b)
v/" (a) I do not oppose entry of a Divorce Decree.
(b) I oppose the entry of a Divorce Decree because:
(i) The parties to this action have not lived separate and apart
for a period of at least two years.
(ii) The man'iage is not irratdevably broken.
2. Check either (a) or (b)
/,~ (a) I do not wish to make any claims for economic relief. I understand
that I may lose dghts concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is
granted.
(b) I wish to claim economic relief which may include alimony, division
of property, lawyer's fees or expenses or other important rights.
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I undemtand that false statements herein made are subject to the penalties of
Pa. C.S. §4904 relating to unswom falsification to authorities.
Date Pamela S. Darden
JAMES V. DARDEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : NO. 01-2762 CIVIL TERM
PAMELA S. DARDEN, : CIVIL ACTION
Defendant : IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF § 3301(d) DIVORCE DECREE
TO: Pamela S. Darden
2284 Pine Road
Newville, PA 17241
You have been sued in an action for divome. You have failed to answer the Complaint or file a
Counter-Affidavit to the §3301(d) Affidavit. Therefore, on or after June 16, 2001, the other party can
request the Court to enter a final Decree in Divorce.
If you do not file with the Prothonotary of the Court an Answer with your signature notarized or
verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. A
Counter-Affidavit which you may file the Prothonotary of the Court is attached to this Notice.
Unless you have already filed with the Court a written claim for economic relief, you must do so
by the above date or the Court may grant the divorce and you will lose forever the right to ask for
economic relief. The filing of the form Counter-Affidavit along does not protect your economic claims.
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 OUR WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Respectfully Submitted
TURO LAW OFFICES
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT, made this ~-~% day of ~,
1997, at Carlisle, Cumberland County, Pennsylvania, by and
between JAMEs V. DARDEN of 2284 Pine Road, Newville, Cumberland
County, Pennsylvania 17241 (hereinafter referenced as "Husband,,)
AND
PAMELA S. DARDEN of 2284 Pine Road, Newville, Cumberlan~ County,
Pennsylvania 17241 (hereinafter referenced as "Wife',).
ARTICLE I
SEPARATION
1.01 Separation of Parties. Differences have arisen
between the parties as a result of which they have been living
separately and apart since November 15, 1997.
1.02 Intention to Live Apart. The parties intend to
fiaintain separate and permanent domiciles and to live apart from
each other. It is the intention and ~urpose of this Agreement to
set forth the respective rights and duties of the parties while
they continue to live apart from each other and to settle all
financial and property rights between them.
AR1/CLE ~
ENFORCEABILITY AND CONSIDERATION
2.01 Equitable Distribution of Marital Property. The
parties have attempted to divide their marital property in
accordance with the statutory rights of the parties and in a
manner which conforms to the criteria set forth in S401 of the
Pennsylvania Divorce Code, and taking into account the following
considerations: Any prior marriages of the parties; the age,
health, station, amount and sources of income, vocational skills,
employability, estate, liabilities and needs of each of the
parties; the contributions of each party; the opportunity of each
party for future acquisition of capital assets and income; the
sources of income of each party, including, but not limited to,
medical, retirement, insurance or other b~nefits; the
contribution or dissipation of each party in the acquisition,
preservation, depreciation or appreciation of marital property,
including the contribution of each party as homemaker; the value
of the property set apart to each party; the standard of living
of the parties established during the marriage; and the economic
circumstances of each party at the time the division of property
is to become effective.
The division of existing marital property is not intended by
the parties to constitute in anyway a sale or exchange of assets,
and the division is being effected without the introduction of
outside funds or other property not constituting marital
property. The division of property under this Agreement shall be
in full satisfaction of all rights of equitable distribution of
the parties.
2.02 Incorporation and Merger. This Agreement shall be
incorporated but not merged in the decree of divorce contemplated
herein. This Agreement shall survive any action for divorce and
decree of divorce and, unless otherwise set forth herein and,
except as to issues of child support and child custody, shall
forever be binding and conclusive on the parties; and any
independent action may be brought, either at law or in equity, to
enforce the terms of this Agreement by either Husband or Wife
until it shall have been fully satisfied and performed. The
considerations for this Agreement are 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.
2.03 Agreement Predicated on Divorce. It is specifically
understood and agreed, by and between the parties hereto and each
of the said parties does hereby warrant and represent to the
other, that the execution and delivery of this Agreement is
predicated upon an agreement for institution and prosecution of
an action for divorce. Nothing contained in this Agreement shall
prevent or preclude either of the parties hereto from commencing,
instituting or prosecuting any action or actions for divorce,
either absolute or otherwise, upon just, legal and proper
grounds; nor to prevent either party from defending any such
action which has been, may or shall be instituted by the other
party, nor from making any just or proper defense thereto. It is
warranted, covenanted and represented by Husband and Wife, each
to the other, that this Agreement is lawful and enforceable and
this warranty, covenant and representation is made for the
specific purpose of inducing Husband and Wife to execute the
-3-
Agreement. Husband and Wife each knowingly and understandingly
hereby waive any and all possible claims that this Agreement is,
for any reason, illegal' or for any reason whatsoever of public
policy, unenforceable in whole or in part. Husband and Wife do
each hereby warrant, covenant and agree that, in any event, he
and she are and shall forever be estopped from asserting any
illegality or unenforoeability as to all or any part of this
Agreement.
2.04. Representation by Independent Counsel. This
Agreement is being prepared for Wife by Wayne F. Shade, Esquire.
ARTICLE III
EQUITABLE DMSION OF MAKITAL P OPE TY
3.01 Equitable Division of Real Property. Concurrently
with execution of this Agreement, Husband will execute a Deed
transferring the marital residence of the parties at 2284 Pine
Road, Newville, Cumberland County, Pennsylvania 17241, to Wife.
3.02 Equitable Division of Personal Property.
-- (a) Prior to execution of this Agreement, Husband has
removed from the marital dwelling all of his items of personal
property, and Wife shall be considered to be in possession of all
personal property which remains in the marital dwelling. The
Turniture, household goods and other similar untitled personal
property have, accordingly, been divided to the mutual
satisfaction of the parties hereto, and each of the parties
retains absolute ownership of such items in his or her possession
or control at the date of this Agreement. The property shall be
--4--
deemed to be in the possession or under the control of either
party if, in the case of tangible personal property, the item is
physically in the possession or control of the party at the time
of the signing of this Agreement and, in the case of intangible
personal property, if any physical or written evidence of
ownership, such as passbook, checkbook, policy or certificate of
insurance or other similar writing is in the possession or
control of the party, unless provided otherwise in this
Agreement;
(b) Wife will transfer the Ford Tempo motor vehicle to
Husband, with Husband to pay the expenses of title transfer.
Wife will maintain ownership of the Chrysler van;
(c) The parties will execute and deliver any documents
necessary to formally release their rights in or claims to the
employee benefits, including without limitation, employee
pension, stock, profit sharing and savings plans, if any, of the
other~ and
\./ (d) Husband will execute and deliver any documents
necessary to formally designate the children of the parties as
beneficiaries of any life insurance proceeds which may mature
prior to the date that the youngest surviving child of the
parties obtains the age of eighteen years.
ARTICLE IV
DEBTS OF PARTIES
4.01 Loans. Responsibility for the outstanding loan
obligations of the parties is assigned, as follows:
-5-
(a) Wife shall assume the outstanding balance of the first
mortgage upon the marital residence at GMAC Mortgage Corporation
and the home equity loan at Dauphin Deposit Bank and Trust Co.,
N.A.; and
(b) Husband shall assume the loan at Members 1st Federal
Credit Union.
4.02 Post-Separation Obligations. Each party represents to
the other that, except as specifically set forth immediately
above, there are no outstanding joint obligations of the parties
and that since the separation neither party has contracted for
any debts for which the other will be responsible. Each party
indemnifies and holds harmless the other for all obligations
separately incurred or assumed under this Article IV.
ARTICLE V
CHILDREN
§.01 Custody. The parties shall share legal custody of
their minor children. Primary physical custody of said children
is awarded to Wife subject to any rights of partial custody in
Husband to which the parties may agree or as specified in any
separate Order of Court.
5.02 Support. Child support will be resolved through the
Domestic Relations Section of the Court of Common Pleas of
Cumberland County, Pennsylvania.
5.03 Health Insurance. Husband shall provide health
insurance coverage for each of the children of the parties until
they attain the age of eighteen years. Such insurance shall be
-6-
at least equivalent to Blue Cross Plan 361 and Blue Shield Plan
865 including major medical with the minimum available
deductible. In the event that the children of the parties should
remain eligible for coverage through Husband's employment after
attaining the age of eighteen years as college students or
otherwise, Husband will continue to maintain the coverages as
long as he is eligible to do so through his employment.
5.04 Uninsured Medical Expenses. The parties agree that
they will be responsible for all reasonably necessary uninsured
health care expenses including orthodontic expenses, incurred for
the care of the children which are not covered by insurance in
direct proportion to their relative net incomes for child support
purposes, but before adjustment for child support payments.
AR CLE %q
ALINfONY
6.01 Qualified Waiver. Alimony claims, if any, will be
resolved outside the terms of this Agreement. In addition, any
obligations assumed by the parties under this Agreement as to
which benefits flow to the other spouse shall be payable as
alimony for the purposes of enforcement and so as to constitute
an exception to discharge in bankruptcy but will not be
deductible by the payor or taxable to the payee for income tax
purposes.
-7-
ARTICLE VII
COUNSEL FEES
7.01 Present Pees. In the event of amicable settlement of
all marital issues and the entry of a Decree in Divorce pursuant
to mutual consent within one hundred eighty (180) days from the
date of this Agreement, each of the parties hereby assumes his
and her own counsel fees up to and includkng the date of the
Decree in Divorce.
7.02 Counsel Fees After Divorce. The parties agree with
respect to counsel fees incurred after the divorce, as follows:
(a) In the event that future legal proceedings of any
nature may be necessary for the interpretation or enforcement of
this Agreement or any valid modifications hereof, the prevailing
party shall be entitled to reasonable counsel fees incurred.
(b) Reasonable counsel fees hereunder shall be defined as
reasonable hours expended at the then hourly rate of counsel for
the prevailing party.
(c) Such counsel fees shall extend to any independent
proceedings necessary to collect counsel fees or to enforce any
other Judgment or decree in connection with this Agreement.
(d) Such counsel fees shall be payable as alimony so as to
constitute an exception to discharge in bankruptcy but shall not
be deductible by the payor or taxable to the payee for income tax
purposes.
-8-
ARTICLE VIII
GENERAL PROVISIONS
8.01 Inaome Tax Consequences. ' The parties have heretofore
filed joint federal and state income tax returns. Both parties
agree that in the event any deficiency in federal, state or local
income tax is proposed, or any assessment of any such tax is made
against either of them, each will indemniky and hold harmless the
other from and against any loss or liability for any such tax
deficiency or assessment and any interest, penalty and expense
incurred in connection therewith. Such tax, interest, penalty or
expense shall be paid solely and entirely by the individual who
is finally determined to be responsible for the deficiency or
assessment. Except as otherwise set forth herein, any income tax
incidents of any kind imposed by virtue of any transfers of
assets or other payments required under this Agreement will be
the responsibility of the transferee.
8.02 General Release of All Claims. Each party hereto
releases the other from all claims, liabilities, debts,
obligat~ons, actions and causes of action of every kind that have
been incurred relating to or arising from the marriage between
the part,es. However, neither party is relieved or d~scharged
from any obligation under this Agreement or any other ~nstrument
or document executed pursuant to this Agreement.
8.03 Sttbsequent Divorce. Nothing herein contained will be
deemed to prevent either of the parties from maintaining a suit
for absolute d~vorce against the other in any jurisdiction based
-9-
upon any past or future conduct of the other, nor to bar the
other from defending any such suit. In the event any such action
is instituted or concluded, the parties will be bound by all of
the terms of this Agreement.
S.04 Waiver of Estate Claim. Except as otherwise herein
provided, in the event of the death of either party hereto, each
party hereby waives, releases and relinquishes any and all rights
that he or she may have or may hereafter acquire as th~ other
parties, spouse under the present or future laws of any
Jurisdiction, as follows=
(a) to elect to take against the will or codicils of the
other party now or hereafter enforced;
(b) to share in the other parties, estate in cases of
intestacy; and
(c) to act as executor or administrator of the other
parties, estate.
8.05 No Debts an~ Indemnification. Each party represents
and warrants to the other that he or she will not incur any debt,
obligation or other liability, other than those already described
in this Agreement, on which the party is or may be liable. Each
party covenants and agrees that if any claim, action or
proceeding is hereafter initiated seeking to hold the other party
liable for any other debt, obligation, liability, act or omission
of such party or for any obligation assumed by a party hereunder,
the party liable will, at his or her sole expensel defend the
other against any claim or demand, whether or not well-founded,
-10-
and that he or she will indemnify and hold harmless the other
party in respect to all damages resulting therefrom. The
obligation created hereunder will be payable as alimony so as to
constitute an exception to discharge in bankruptcy.
8.06 Full Disclosure. Each party asserts that he or she
has made a full and complete disclosure of all of the real and
personal property of whatsoever nature and wheresoever located
belonging in anyway to each of them, of all sources and'amounts
of income received or receivable by each party, and of every
other fact relating in anyway to the subject matter of this
Agreement. These disclosures are part of the considerations made
by each party for entering into this Agreement.
8.07 Right to Live Separately and Free from Interferenoe.
Each party will live separately and apart from the other at any
place or places that he or she may select. Neither party will
'molest, harass, annoy, injure, threaten or interfere with the
other party in any manner 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 will interfere with the use,
ownership, enjoyment or disposition of any property now owned or
hereafter acguired by the other.
8.08 Agreement Voluntary end Clearly Understood. Each
'party to this Agreement acknowledges and declares that he or she,
respectively:
-11-
(a) Is fully and completely informed as to the facts
relating to the subject matter of this Agreement and as to the
rights and liabilities of both parti'es;
(b) Enters into this Agreement voluntarily after receiving
the advice of independent counsel or, having had the opportunity
to do so, having decided not to do so;
(c) Has given careful and mature thought to the making of
this Agreement;
(d) Has carefully read each provision of this Agreement;
and
(e) Fully and completely understands each provision of this
Agreement, both as to the subject matter and legal effect.
8.09 Compliance. The parties will execute and deliver any
documents necessary to formally conclude any of their obligations
under the terms of this Agreement to 9ach other.
8.10 Default. If either party ~ails in the due performance
of any of his or her material obligations hereunder, the party
not in default will have the right tolact against the other, at
his or her election, to sue for damages for breach hereof, or to
~escind this Agreement or seek such other legal remedies as may
be available to either party. Nothing herein shall be construed
to restrict or impair either party in the exercise of this
election.
8.11 Amendment or Modification. This Agreement may be
amended or modified only by a written instrument signed by both
parties.
-12-
8.12 Successors and Assigns. In the event of the death of
either party prior to the issuance of a Decree in Divorce, this
Agreement shall survive the death; and all property, whether
Jointly or separately owned, shall be divided under the terms of
this Agreement between the estate of the decedent and the
surviving spouse as .though the Decree had issued prior to the
death. Except as otherwise expressly provided herein, this
Agreement will be binding on and inure to the benefit of the
respective legatees, devisees, heirs, executors, administrators,
assigns and successors in interest of the parties.
8.13 Law Governing Agreement. This Agreement will be
governed by and will be construed in accordance with the laws of
the Commonwealth of Pennsylvania in effect at the date of
execution hereof.
8.14 Reconciliation. In the event of reconciliation,
attempted reconciliation or other coh+bitation of the parties
hereto after the date of this Agreement, this Agreement shall
remain in full force and effect in th~ absence of a written
Agreement signed by both parties hereto expressly setting forth
that this Agreement has been revoked or modified.
IN WITNESS WHEREOF, the parties hereto have hereunto set
their hands and seals, intending to be legally bound hereby, the
day and year first above written.
Sig~ed, Sealed and Delivered
~a~es V. Darden
-13-
COMMONWEALTH OF PENNSYLVANIA )
) SS:.
COUNTY OF CUMBERLAND )
On this, the ~-~ day of -~ ~'-~-/~ . , 1997, before
me, the undersigned officer, personally appeared JAMEs V. DARDEN,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the foregoing Agreement and acknowledged
that he executed the same for the purposes therein con~ained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
/ Michele A. Golden, Nota~ Public
/ Middlesex Twp., Cumberland Counl¥
~ My Commission Expires July 2, 2001
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND ) SS:
, , 1997, before
me, the undersigned officer, personaliy appeared PAMELA S.
DARDEN, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the foregoing Agreement and
acknowledged that she executed the same for the purposes therein
contained.
IN WITNEss W~EREOF, I hereunto set my hand and official
seal.
Notary Public-
I Michele A Golden, Notary PuBic
~ Mio~llesex Twp., Cum'oeflanel
-14- ,;I 6,,~:%;, Peflnsvlvani. A~o~lalf0n ~f Nota~-]
Darden, : IN THE COURT 0OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. · NO. 01-2762 CIVIL TERM
:
Pamela S. Darden, : CIVIL ACTION
Defendant : IN DIVORCE
PRAECIPE TO TRANSMIT RECOI:an
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(d) of the Divome
Code.
2. Date and manner of service of the complaint: Acceptance of Service on
July 20, 2001.
3. Date of execution of the Affidavit required by §3301(d) of the Divorce
Code: May 4, 2001
a. Date of filing and service of the Plaintiff's Affidavit upon the
Respondent: May 7, 2001
4. Related claims pending: None.
5. Date and manner of service of the Notice of Intention to file the Praecipe
to Transmit the Record, a copy of which is attached: May 24, 2001, regular mail
~obert J~.~¥uld~rig, Esqui~-__~
Attorney'for Plaintiff
IN THE COURT Of COMMON PLEAS
OF CUMBERLAND county
STATE OF PENNA.
..... J~.ES...V.,...DAR~E~I .......................................
........... ~!.~.~.~ ~ f .......................................... ~¢) ....... .0..?...-...2. ?..6...2 .................. [9
Verstl$
PAMELA S . DARDEN
Defendant
DECREE IN
DIVORCE
AND NOW, ......... ,,~9~.I.~..~.../..~. ..... xl~. go.Q], it is ordered and
decreed that ...... ~..~..~§..v.:..D.%~..o.~ .......................... plaintiff,
and PAMELA S. DARDEN ....... 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;
?HE PROPERTY SE?TLEMENT AND SEPARATION AGREE~E~
.. p.E.C.E.M..~.E~..{,...] ~.9.7. IS. IN.CORPORATE~ .BUT. ~OT. MERGF~. IN..THE. DECREE.
~ ...........................................
Prothonotary