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HomeMy WebLinkAbout02-0782DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. ~9o~-?~:o~ CivilTerm : : ACTION 1N 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 proceed without you and a decree of 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; : No. t~°c~,. 7~. Civil Term : · ACTION IN DIVORCE : COMPLAINT IN DIVORCE 1. Plaintiff is Daniel D. Plinski, a competent adult individual, who has resided at 221 Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania, since February 2001. 2. Defendant is Kathy E. Gill, a competent adult individual, who has resided at 12625 S.E. 42nd Street, Bellevue, King County, Washington, since July 1991. 3. Plaintiffhas been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 27, 1984 in Bucks County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the fight to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint 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. Daniel D. Plinski, Plaintiff Date: Respectfully submitted, /~ne Adams, Esquire ~,/D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 782 Civil Term 2002 : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND ANDCOMPLAINT AND NOW, this March 19, 2002, I, Jane Adams, Esquire, hereby certify that on March 12, 2002, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Kathy E. Gill 1075 Bellevue Way NE PMB #314 Bellevue, Washington 98006 DEFENDANT Respectfully Submitted: Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant IN THE COURT OF COMMON'PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 782 Civil Term 2002 ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated August 1, 1999, 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 my rights concerning alimony, division of property, lawyer's 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 false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unsworn falsification to authorities. FROM : JANE_ADAMS FAX NO. : 7172458538 ~pr. 29 2003 03:06AM P2 DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant IN THE COURT OF COMMON PLEAS'. CUMBERLAND COUNTY, PENNSYLVANIA No. 782 Civil Term 2002 ACTION IN DIVORCE 2002. AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3.301(c) of the Divorce Code was filed on February 13, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days t~ave elapsed from the date of the filing and service of the Complaint, 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct, I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to dnswom falsification to authorities. ~(athy ~./G-~ I~efendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §33011'c) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2, f 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 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. Kathy I~,/~ill, ~efendant DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant IN THE COURT OF COMMON PLEAS ' CUMBERLAND COUNTY, PENNSYLVANIA No. 782 Civil Term 2002 ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on February 13, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. ~ I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~'.'~--~'.~_'-'- O ~ D'anial. l~. Plinski, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF 1. I consent to 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 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 affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ¢.~ ~.,~_-_ O.5.. DANIEL D. PLINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 782 Civil Term 2002 KATHY E. GILL, Defendant ACTION IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~,_,~' day of -/~'~ ~"~'~c, ~ , 2003, by and between, KATHY E. GILL, of Bellevue, Washington, herein'after referred to as "WIFE", and DANIEL D. PLINSKI, of Mechanicsburg, Pennsylvania, hereinafter referred to as "HUSBAND"; WlTNESSETH: WHEREAS, Husband and Wife were lawfully married on April 27, 1984, in Bucks County, Pennsylvania, and; WHEREAS, there were no born of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. FROM : ~ANE_AD~MS FAX NO. : ?1724S85~8 ~ Apr. ~9 200~ O~:O?AM P4 :2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Jane Adams, as his attomey. The Wife is PRO SE. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. Wife has been advised of her right to counsel, voluntarily elected to forego representation, and understands that Jane Adams, Esquire is only representing Husband. 3. SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose 'of this agreement to set forth their respective rights and duties while they continue to live apart from each other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c)of the Pennsylvania Divome Code. Wife hereby expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable 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, 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 is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be 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 execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. ' FROM : JANE_A~AMS FAX NO. : ?172458570 ,Apr. o~9 200~ O~:O?AM R5 6. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, or whatever nature and wheresoever situate, which she or he now has or at any time hereafter 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, or claims in the nature of dower or curtesy of widow's or widower's rights, 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 of a surviving spouse to participate in the decease spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any dghts which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of any marital relation or otherwise, 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 thereof. - 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. 8. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. Ali names incurred in Wife's name alone; along with any debts Jn joint names that have been incurred without husband's knowledge, except as provided in this agreement. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. The MBNA ending in the account numbers in the amount of $1249.40. All debts incurred in Husband's name alone. 9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each party to the education, training, or increased earning power of the other party; the opportunity for each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living 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 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 marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. As such, the parties acknowledge that Husband or Wife's obligation to make the payments defined in this agreement shal{ not be subject to termination, discharge, or discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. At the time of the implementation of this alimony award, which may be made through the appropriate Domestic Relations of Support office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may select, such party shall then be responsible for any such debts extinguished through the other party's bankruptcy as described herein. 10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. FROM : JANE_AD~MS FAX NO. : 71?2458538 ,, Apr..29 2003 03:09AM PT 11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: Each party shall retain sole and exclusive possession of the motor vehicles they current have in their possession. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days of the execution date of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12. MARITAL HOME. HUSBAND and WIFE hold title as Tenants by the Entireties to the premises identified as 12625 S.E. 42nd St., Bellevue, Washington, 98006. The parties agree as follows with respect to the marital residence: (a) Within ninety days of this agreement, Wife shall assume or refinance the mortgage loan obligation on the marital home in her name alone. Wife shall complete all steps necessary to have Husband removed from any obligation under the loan on the marital home.' If a refinancing is not accomplished within this time frame, Wife shall list the home for sale with a reputable realtor. (b) On or before the date of refinancing or sale, Husband shall deliver a deed, conveying to Wife all of his right, title and interest in and to the marital residence. (c) As of the date of separation, and without regard to when bills for such items are incurred, received, or due, Wife shall be shall be solely responsible for the timely payments of all past, present and future prindpal, interest, and other fees under the mortgage. Wife will indemnify and save Husband harmless from any failure or refusal to pay the mortgage. (d) As of the date of separation, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for ail past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's ~nsurance, and gardening expenses and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors, and administrators indemnified and I~eld harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense. FROM : JANB_AD~MS FAX NO. : 7i72458538 , Apr..29 2003 03:09AM P8 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to spousal support, alimony, or aJimony pendente ~ite, and each party agrees to be responsible for his or her own legal fees and expenses. '. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively have against the other for alimony, support, or maintenance, it shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 15. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of. any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 16. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the prov!sions of this Agreement. 17. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 18. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. t9, OTHER DOCUMENTATION, Wife and Husband covenant and agree that they will forthwith execute any and all wdtten instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. FROM : JANS_AD~MS FAX NO. : 71724585S8 Apr...29 200S 03:10AM P9 20. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the dght of such party hereafter to enfome the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 21. SEVERABILITY. if any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be vaJid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 22. BREACH. if either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 23. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entedng into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: KAyH*I . gILL, Wife Date: FROM : JANE_A~AMS FAX NO. : 717245B538 .Apr.,~9 200~ O~:IOAM PlO STATE 0 t COUNTY O :ss O_; ~shj~,a~?eal~ day of ~4~ , 2003, before me, the undersigned officer, p y Ippeared KATHY~E. GILL known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. ..-}, !~i'WITNESS WHEREOF, I here~..~and and official seal. '~ .~{~C'?:'e ~ My commission expires: ' S~L D~ D. PLINSKI, Husband Witness On this, the ~ day of /~a)~ ,2003, before me, the undersigned officer, personally appeared DANIEL D. PLiNSKi known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/;h;~ executed the same for the purposes therein contained. IN WITNESS WHEREOF, i hereunto .~t my h_and and official seal. Notary Public My commission expires: SEAL DANIEL D. PLINSKI, Plaintiff VS. KATHY E. GILL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 782 Civil Term 2002 : : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, delivered on: -~ __ I '~ -- O ~ 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff: ,5'--- S-'"' -- O 3 By Defendant: ~--/'"-c~ "O ~ 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~-,.___ --~.~ O~3 : Date Plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: %.----.~_ -~ __ O 3 A ams, Esquire ~ S. 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