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HomeMy WebLinkAbout04-4589 LAW OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney LD. No. 71873 1017 North Front Street Harrisburg, P A 17102 Telephone No. (717) 232-9724 Attorney for Plaintiff, Darnen Richard Ginter DAMEN RICHARD GINTER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2004 - I..fsFf Civil Term HELENA CATHERINE GINTER, Defendant CIVIL ACTION - LAW 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 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 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 of Cumberland County, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 2 Liberty A venue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 DAMEN RICHARD GINTER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No, 2004 - -<Iliff Civil Term CIVIL ACTION - LAW IN DIVORCE HELENA CATHERINE GINTER, Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, The Plaintiff is Damen Richard Ginter, an adult individual whose current address is 60 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241, and whose social security number is 173-62-4230. 2. The Defendant, Helena Catherine Ginter, is an adult individual, whose current address is 59 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241, and whose social security number is unknown, 3. Plaintiff and Defendant were married on September 21, 2000, in Carlisle, Cumberland County, Pennsylvania. 4, Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing, 5. Defendant is not a member of the Armed Services of the United States or its allies, 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States, 7, There has been no prior action for divorce filed in any jurisdiction, 8, Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children born of the marriage. 10, Plaintiff avers that the grounds on which this action IS based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce, Respectfully submitted, < BY: {J h Diane M, D~Es4<<fre 1017 North Front Street Harrisburg, P A 171 02 (717) 232-9724 I.D. No. 71873 Date: September 8, 2004 VERIFICA TION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~.e;.~ ~ DAMEN RICHARD GINTER Date: September 8, 2004 1 p ~ ~ - ..0 D - CI) ~ - ("'. r-<.' ~ () L"} () ~ .--, ..c: ~ ";1 ~ ~ :,~ ""<;L -, ~ GO I ~': -- . ---- n "(:-' .. .- .;., ~ --..: FM'.m-' :[IILS and DILS FAX HO. : 71-:'23325E,7 t1a ~. 23 2006 11: 12AI-1 ='5 PROPERTYSETTLEMrnNTAGREEMENT AGREEMENT, is made this tI:J~ of May 2006, by and THIS between: HELENA C. GINTER. hereinafter referred to as Wife; --AND-- DAMEN R. GINTER, SR., hereinafter referred to as Husband; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on September 21, 2000, in Carlisle, Cumberland County, Pennsylvania; and 'vVHEREAS, there are no children born of the marriage, F~OM :DILS and DILS FR>:: NO. : 7172332567 11a ~, 23 2006 11: 13At1 P6 WHEREAS, diverse unhappy marital difficulties have arisen between the parties causing them to believe that their marriage is irretrievably broken, as a result of which they have separated and now live separate and apart from one another, the parties being estranged due to suc,h marital difficulties with no reasonable expectation of reconciliation; and the parties hereto are desirous of settling fully and fmally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership of real and pen;onal property; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estate, particularly those responsibilities and rights growing Ollt of the maniage relationsbip. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration. the receipt of which is hereby acknowledged by each of the parties hereto, husband and wife, each intending to be legally bound, hereby covenant and agree as follows: L SEP~~T10N It shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions ofmis Agreement, Neither party shall molest Initia1~ 2 ,1JB1l Initials 1::t,t',...---- FR!='t>1 :DILS ar'ld DILS FP.X He. :71""2332567 ~1a'::I. 23 2005 '11: 13AM P7 the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or maligt1 the other, nor in any way interfere with the peaceful existence, separate and apart from the other. Should a Decree, Judgment, or 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 be affected in any way by any such separation or divorce; and that nothing in any such Decree, Judgment, Order 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 and between the parties hereto, that this Agreement shall survive and shall not be merged into any Decree, Judgment, or Order of divorce or separation. It is specifically agreed however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any Order of divorce, Judgment, or Decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any Judgment and be forever binding and conclusive upon the parties. 2. EFFECTIVE n-UE The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of initial~ 3 Initial'~ ~Ot1 : DIL'::; and DILS FAX He. ;7172332567 ~la'" 23 2006 11: 14HM "8 execution" or "execution date" or this Agreement shall be defIned as the date of execution by the party last executing this Agreement. 3. MUTUAL RELEASE OF CLAIMS Husband and wife do hereby mutually remise, release, quit-claim or forever discharge the other and estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, or whatever nature and wherever situate, which he or she now has or at any time her<Jafter may have against such other, the estate of such other or any part thereof. whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, of claims in the nature of dower or cmiesy, or widow's or widower's tights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or' all other rights or a surviving spouse to participate in a deceased spouse's estate, whether arising under the United States, or any other country; or any righ.ts which either party may now have or at any time hereafter have for the past, present, or tuture support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Jnili'!~ 4 lIlitial'~ F'1:;:Ol'1 : DILS and DILS FAX NO. :7172332567 Ma~. 232006 11:15RM PS It is the intention of husband and wife to give to each other, by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal, or mixed, which the other now ovms or may hereafter acquire, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 4. DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of the Diyorce Decree, unless otherwise specified herein. 5, MUTUAL CONSENT/ADVICE OF COUNSEL Husband and wife acknowledge and understand the terms and conditions of this Agreement, and husband is represented by Diane M. Dils, Esquire, and wife is represented by Mark T. SiIliker, Esquire. Each party acknowledges that he or she has received or has been given an opportunity to receive independent advice from counsel of his or her selection <l11d was fully infonned as to his or her legal rights and obligations. Husband and wife acknowledge that they fully tmderstand the facts as to their legal rights and obligations under this Agreement. Husband and wife acknowledge and accept that this Agreement is, under the circumstances. fair and equitable and that it is being entered into freely and voluntarily, and that the Initi~~ 5 In;tia1~ FK9M :DILS and DILS FAX NO. :7172332567 Ma~. 232006 11:15RM ~10 execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. 6, FINANClAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Notwithstanding the foregoing, the rights of either paIt) to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owed by the other party in an asset of any nature at any time prior to the date of execution ofthi~ Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. It) the event that either party, at any time hereafter, discovers such an tmdisclosed asset, the parties shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of said asset. The non-disclosing party shall be responsible for payment of counsel fees, costs, or expenses incurred by the other party in seeking equitable distribution of said asset. 7. DEBTS AND OBLIGATIONS Husband represents and warrants to wife that since May 2004, he has not, and in the future he will not contract or incur any debt or liability for which wife or her estate might be responsible and shall indenmify and save wife harmless from Initial~ 6 ,Iall , Irtitial,~ rqOM :DILS and DILS FAX NG. :717233256( Na~, 23 20C6 11: 16m1 PH - any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise Set forth h.erein, Wife represents and warrants to husband that since May 2004, she has not, and in the future she will not contract or incur any debt or liability for which husband or his estate might be responsible and shall indenmity and save husband harmless from any and all claims or demands made against him by rea-~on of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 8, REAL E;STATE Husband and wife hereby acknowledge that wife is the sole owner of a mobile home situate at 59 Peachyann Drive, Newville, Cumberland County, PeIUlSylvania, which is in the name of wife alone and which was purchased by wife prior to the parties marriage. Husband hereby waives any right, title, and interest which he may have to said mobile home, and simultaneously herewith has executed a waiver. 9. Ut,RSONAL PROPERTY Except as set forth hereto, husband and wife have agreed that their personal property has been divided to the parties' mutual satisfaction and neither party will make any claims to the property possessed by the o'll:Ier, except as set forth hereto: )1#,;1/ Initi~ 7 lnitia~---- PROM :DI~3 and DILS Fm~ NO. :7172332567 !1a':h 23 2005 11: 16nM P12 - Husband and wife hereby acknowledge that they have amicably divided all personal property between themselves. 10. PENSION Husband and wife hereby acknowledge that they both have accumulated a pension, retirement, profit sharing, 401(k), or other employment related benefits during their marriage and both husband and wife hereby waive all of their right, title, and interest which they may have in the other's pension, retirement, profit sharing, 401 (k) and any other employment related benefits. 11. WAIVER OF RIGHTS The parties hereto fully uIlderstand their rights under and pursuant to the Divorce Code, Act of 1980, No. 1980-26, as amended February '12, 1998, particularly the provisions for alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support. equitable distribution of marital property, attorneys tees, and expenses, lnitiOIQ 8 IllitiJI&--- :rRDr'1 :DILS and. OILS Fm~ 1'10. : 7172332567 Ma~, 232086 11;17RM PL3 h. ..,~. -"-"" 12. WAIVER OR MODIFICATION TO BE IN WRITING A modification 0, waiver of any of the temlS of this Agreement shall be effective only if in writing, signed by both parties, and executed with the same formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 13. MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and an steps and execute, acknowledge and deliver to the other parry, any and all future instruments ancllor documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions of the Agreement. 14. AGREEMENT BINDING ON HEI~ This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, e"ecutors, administrators, successors, and assigns in the interest of the parties. 15. BREACH If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorneys fees and all costs incurred by the other in enforcing his or her fights under this Agreement. ~t~ 9 lniti'l~(!.V f'9011 : DILS ,end OILS FAX NO. :7172332567 11a". 23 2EJC6 11: lBAI'1 ?14 - 16. LAW OF PENNSYL VANIA APPUCABLF; This Agreement shall be construed in accordance with the Jaws of the Commonwealth of Pennsylvania. 17. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs/prOvisions and sub-paragraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect it. meaning, construction or effect. 18. DIVORCE The parties hereto acknowledge that their marriag<: is irretrievably broken. The parties further agree to execute the necessary Affidavits of Consent a.'ld Waiver of Counseling, and Waiver of Notice of Intent to Request Entry of Divorce Decree upon request so that the divorce may become finalized. The parties further agree and acknowledge that this Property Settlement Agreement shall be incorporated into said Decree in Divorce; however, shall not merge therewith, 19. IRREVOCABll.ITY It is understood and agreed to by and between the respective parties thereto that the property division - distribution affected by the herein agreement is IRREVOCABLE and that such division - dIstribution shall not be affected by any change of circumstances of the respective parties OR by other statutory or judicial ~~p lnilialS-~;;~:~~~;'/ ]0 lnitials~ F30H :DIL!; and. DILG ~AX NC. :71123325b7 Ivla':j. 23 20eG 11: 18Al"1 Pi5 - alternatives which may be available to the respective panies under prior, current, or future laws of the Conunonwealth of Pennsylvania or any other jurisdiction, Except as provided herein, the parties hereby waive any respective rights to financial support and/or alimony and/or pension or future expectancies each may respectively have under prior, curre,nt, or future laws or case decisions, IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written, ) // ,1/ DAMEN R GINTER, SR. ' lniti.l. 11 In,t..15 . F~Ot'l :['lLS and DILS FAX NO. :71?2332557 1'13'::1' 23 2006 11: 19r='lr1 ?16 COMMONWEALTH OF PENNSYLVANIA COUNTYOF /J~",,- On this, the c9.3rA.day of May 2006, before me, a Notary Public, the undersigned officer. personally appeared HELENA C, GIl\'TER, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpoS<:1S therein contained. IN 'NITNES N t SEAL Renee Dreisbach. Notary Publ' . tower Paxton Twp., Dauphin If ll111J:Commission B ires Nov. 30, 200 My Commission E y hand and official seal. &~ Notary Public COW.lONW~~ OF PENNSYLV ANlA COUNTYOF~~ On this, the,y Y ~ay of May 2006, before me, a Notary Public, the undersigned officer, personally appeared DAMEN R. GINTER, SR., known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and. acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunt set my hand and official ! Lt,,-- Q Notary Public 10TARlAt SEAL IIE8IlA A. AIlE. NOTARV PUBlIC Cl1Y OF HARRISBURG, OAUPll1N co. IIY COMMISSION EXPIRES OCT. 24. 20US My commission expires: ~;".,' \ " ~' ....------- . T ", ..'::~ .!! OJ ~ -\ ."...- '\<~" <..~ ' :--..... --: '" C:> ~O"" .. DAMEN RICHARD GINTER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 2004 - 4589 Civil Term HELENA CATHERINE GINTER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 13,2004, 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 in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa, C.S, ~4904, relating to unsworn falsification to authorities. r ./1-/ -(/' if, / Date: )-) 'l/);( .7(Je.I'h\..i'c' /:-: ;!A,{,(J.:; Damen Richard Ginter, Plaintiff t-,') (~, c__-, CJ'", o M-n '.... :~\: 11 r.if. -~C:j -' ., -'-'< f'-) (.;'l .--. C) :~J --< FRon ',DILS 31',d DILS FAX NO. :7172332567 May. 2320e6 11:11AM 03 DAMEN RlCHARD GINTER, Plaintiff IN THE COURT OF COiYrMON PLEAS CUMBERLAND COUNTY, PENNSYL V A"'iIA VS. No. 2004 - 4589 Civil Term HELENA CATHERINE GINtER, Defendant CIVIL ACTION - LA 'iN IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) oftlle Divorce Code was filed on September 13,2004. 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 consem to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa, C.S. S4904, relating to unsworn falsification to authorities. Date:~-( 5/ :J3/06J :~ o c.~: "" c_" ,~;:;) ,~" () -n .-1 :T- n< -~. ['" u' c;; DAMEN RICHARD GINTER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No, 2004 - 4589 Civil Ternl HELENA CATHERINE GINTER, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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 this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S. 94904 relating to unsworn falsification to authorities. )- J 1/"{)6 ~,,/.,v ,;:~:;/i: Damen Richard Ginter, Plaintiff Date: 0 ...., CJ ,.:":., C '-...:...~ n ~-, ,-, ~ l-t-l -. -r, r"> en ::: <~ CO ~--,-- F~OH : DIU" and DILS FAX NO. :7172332567 May. 232006 li:l1AM ~~ DAMEN RICH.ARD an.;TER, Plaintiff IN THE COURT OF COl'vfMON PLEAS CL'MBERLAND COUNTY, PEN1\SYLVA~"'L\ V$, No. 2004 - 4589 Civil Tem1 HELENA CATHERINE GINTER, Defendant CXVIL ACTION - LAW IN DIVORCE W AIYER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301((:) OF THE DIVORCE CODE 1, I consent to the entry of a fmal Decree in Divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree '\\'111 be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Waiver are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, s4904relating to unsworn falsification to au horities, Date: sJ ?-$jOG { (""'<' '-:-,-' c.:~) ,""~ () .'rl :::.J N 01 -:J C1 DAMEN RICHARD GINTER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2004 - 4589 Civil Tem1 HELENA CATHERINE GINTER, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Mark T. Silliker, Esquire, hereby accept service of the Complaint in Divorce under Section 330 I (c) of the Divorce Code on behalf of Helena Catherine Ginter, the Defendant, on the ::2 9- day of September 2004. BY: _.~ ark , I liker, Esquire 5922 Linglestown Road Harrisburg, PAl 7112 (717) 671-1500 LD.No. )) 67/ :-..:1 C',, c,~ c:.... o -;'1 :::::I .;.... fi-i ~~.~- f'.) <51 =? w ~ -( ..., DAMEN RICHARD GINTER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2004 - 4589 Civil Term HELENA CATHERINE GINTER, Defendant CIVIL ACTION - LAW 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: Irretrievably broken under Section (X) 3301(c) or ( ) 3301 (d) of the Divorce Code, (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By Acceptance of Service executed by Defendant's attorney on September 22,2004. 3. [Complete either Paragraph (a) or (b),) (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, May 24, 2006; by Defendant, March 24, 2006. (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A; Date of service of Plaintiff's affidavit upon Defendant: N/ A, -, 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: NI A; 5. Date of filing of Waiver of Notice ofIntent to Finalize by Plaintiff: May 24, 2006; by Defendant: May 24, 2006, 6. Related Claims Pending: None, Respectfully submitted, / / ) /' / ,/~,'/~~/<.t&c:;?), B~~.c'~l~ . Diane M. Dils, Esquire 1400 North Second Street First Floor, Front Harrisburg, PA 17102 (717) 232-9724 LD. No. 71873 Date: May 24, 2006 '" 0 , -n " , --< t"~ <.n -D -..- J - '.\ -' ....,. ..sJ ~ .. o LA W OFFICES OF DILS & DILS DIANE M. DILS, ESQUIRE Attorney I.D, No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 232-9724 Distribution: Diane M. Dils, Esquire, 1400 North Second Street, Harrisburg, PA 17102J~ Mark T. Silliker, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 ~ "dJ '/ ,/)t. 1. Attorney for Plaintiff, Damen Richard Ginter DAMEN RICHARD GINTER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA HELENA CATHERINE GINTER, Defendant No. 2004 - 4589 Civil Term CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this ~\ ~t day of ~, 2006, upon presentation and consideration of the within Agreement, it is hereby ORDERED that the Agreement attached hereto is incolporated herein and made an Order of this Court, said Agreement dated May 23,2006. BY THE COURT: \i.W\ " \\ -- '''J~ .J " ) V Ir~'i/'\-r/, S'f \1 !E3d .AlNnCi"" ,'" ;..,i:,w'JnQ SO :C t,!d I C ,1\ Vi190aZ }\t/V1C[\JG iLG'.].,) 3H1 .::10 :J8!J::CHJ::nl:l - '" '" '" '" "'''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DAMEN RICHARD GINTER, PENNA, STATE OF No. Plaintiff 2004 - 4589 Civil Term VERSUS HELENA CATHERINE GINTER, Defendant DECREE IN DIVORCE AND NOW, ,,",.1 1 \ ~ l' .\"'1 b{ !\""t-' lllPll. , IT IS ORDERED AND DECREED THAT DAMEN RICHARD GINTER , PLAINTIFF, AND HRTF.NA r.ATHRRTNR r-TNrRR , 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; See Property Settlement Agreement attached hereto. BY THE COURt ~j \ A~ . \ ROTHONOTARY '" J. "'''' '" '" 'I"N;r ~ f2 ~~;t., '717' 11 #J "TlY f!:P ? ~ u"tl- PJ 'J(J' 1)1-;; 1 '. , ' .- . , .' '\C . .. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wmef\ eurafrC( binh Plaintiff Vs _Wd.eno.. (lctfhPVl n..e. 6lnW Defendant File No, L-OOY ~ 4f M IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or '~after the entry of a Final Decree inDivorce dated~, hereby elects to resume the prior surname of A.: ~'/2.- . It and gives this written notice avowing his I her intentionpursu';D}to ~e pro~is' DS.. of 54 P.S, 704, Date: (III /O(p f:I:!l:{lU- _'41d-- , . ature IiJ(i(~ Signatur of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ('UAN> j", P.M<{ ) On the ~ day of ~ ' 200 j"" before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. (Iud' 0. n..,pp,~ ~ , ' Prothonotary or Notary Public f1ItIIffr)N rISMIL IlEAL I _aEClifli~=:'" MY COLlI_III flIPIIIEII MWIY 4, 2010 ~ ~ "-) r -11 ~ ...., -r- ~ hl;;C:! ,'0' , ~ "" <::: ~ - -f - 5 " r:) -<> (..,.~ ~ (~"' .. Jv ~ "" . -.) ~ Jl\3Cl Jl,lilATOI I lIIJllU'lJYP. I 011 ;YfiI\'iOrouf!ftM : '''''rnmlUO:l YilllJO:) O~4JIHeMU:l 3Jm.lllAO I Cla~ ,HflAUMAt 2"A;;l',] l4O'aa:M~'QO ',,,, I , -.I