The URL can be used to link to this page

Home My WebLink About04-6528 a ORIGINAL CHARLES L. MARTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04 -- &>S:2.! CULL <-rm.~ SANDRA PASSARELLA, Defendant CIVIL ACTION - LAW 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. 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, P A 17013-3302 (717) 249-3166 -1- CHARLES L. MARTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. SANDRA PASSARELLA, Defendant CIVIL ACTION - LAW DIVORCE COMPLAINT Plaintiff, Charles L. Martz, by his attorney, Diane G. Radcliff, Esquire, files this Complaint in Divorce of which the following is a statement: COUNT I DIVORCE 1. The Plaintiff is Charles L. Martz, an adult individual who currently resides 308 North 25th Street, Camp Hill, Cumberland County, Pennsylvania since 1978. 2. The Defendant is Sandra Passarella, an adult individual reSiding at 2680 Deep Hollow Road, Dover, York County, Pennsylvania 17315. She is believed to have resided at this address for a period of approximately six (6) months prior to the date of this Complaint. 3. Plaintiff and/or Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 28, 2002 at York County, Pennsylvania. 5. The parties have not resided together at any time, specifically they have not resided together and have lived separate and apart since the date of their marriage on December 28, 2002. 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Defendant is not a member of the Armed Services of the United States or any of its Allies. -2- 9. Plaintiff avers that the grounds on which the action is based are: a. Section 3301 (c) Mutual Consent No-Fault: The marriage is irretrievably broken; b. Section 3301 (d) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart and have lived separate and apart for a period of two years. Concurrently herewith Plaintiff is filing an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. ( Respectfully submitted, <:~~~~:t ~UIRE { ( Camp Hill, PA 17011 Phone: (717) 737-0100 Supreme Court 10 # 32112 Attorney for Plaintiff -3- VERI FICA TION Charles L. Martz verifies that the statements made in this Complaint are true and correct. Charles L. Martz understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: December 29, 2004 -4- 1\ ~ ~ '.() ~ - -a \) ~ ~ ~cJ F J (") c -.~ ...o~;i cnr :', -7......-. ;~f: (j) ,-, "'s"~' r- {,' ~ -, ~- z'-..:' <<::::,l..,..,' .YC: ~ ~ c:::> c:::> J:' c:;:) f"T1 ('"') N U) -0 =~ ~ -l ::r: ~~~ :0 s~ .,- , o:U -~.,.o b ?Srn > ~ - .. c..n c.n CHARLES L. MARTZ, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. tYi - rssJ.,} (1/0' L ~I CIVIL ACTION - LAW DIVORCE SANDRA PASSARELLA, Defendant IFYOU WISH TO DENY ANY OFTHE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 28, 2002 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 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsi fica za~o/s. Date: December 29, 2004 ~ ~ ~ CHARLES L. MAR , PLAI (') f') 0 c::::::>> C c::::::>> -n :s: or- 0 --I -0 llJ .,.. mrn rn fj;:D :-.:':" :7:1 ('"") ,-"hi zr- N :1)0 c.1j J.7: U) 06 -<~:: ~ ~.G -0 =R ,;;::- ..-" ::c 0(1 :z:l....l 2m _7CJ 9 >c: -y ?E ~ ~ Ul C1"I -< CHARLES L. MARTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-6528 CIVIL TERM SANDRA PASSARELLA, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Diane G. Radcliff, Esquire, being duly sworn according to law, depose and say that on January 5,2005, I served a true and correct copy of the Divorce Complaint and Plaintiff's 330 1 (d) Affidavit upon Sandra Passarella, thE~ Defendant, by Certified Mail, Restricted Delivery, addressed as follows: Sandra Passarella 2680 Deep Hollow Road Dover, PA 17315 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. \ a ~~DCLlFF Trinl~l Road . , A 17011 Supreme Court 1.0. No. 32112 Attorney for Plaintiff Q~l Sworn to and subscribed before me a Notary Public in and for Cumberland County, Pennsylvania this 6th day of Januarv , 2005. ~hX~T NOTARY PUBLIC My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Deborah L. Donley, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Sepl23, 2007 Member, Pennsylvania Association Of Notaries U.S. Postal Service!" CERTIFIED MAILr., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) M IT' IT1 ..D t::J IT' t::J M .::T CertIfied Fee t::J ~ Return RecIept Fee ...... (Endorsement RequlnKl) t::J ReSlricl8d DelIve1y Fee U') (Endorsement Required) ["- Cl .::J.J.......M.III USE Po8Iage $ 1"oeImark Here .::T Cl Cl ["- ~.... ,r-:': . ",<" " _ ~~. ~:- ,~ - ,,' ., . ~~~JmJ~j 7004 0750 0004 1090 6391 tmF~~~~__LU~~_~ '" ,.._______1~*'Il4tJ EXHIBIT "A" RETURN RECEIPT CARD -.!:,!O.J n;r"ij -7~} :!..-; t;. 65..;~ ~0 <: d':;o ~o $-C -7 ~ r.... ,. - ::P :z ........\ ~i~ ::;1 ~ --'- 11 nl;:":::: -rr ~~ --- L, . ~.) , (--:-~ !;~ c '""t --L ::! I_A,: 4 " .l - CHARLES L. MARTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 04-6528 SANDRA PASSARELLA, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : 55.: COUNTY OF CUMBERLAND Before me, the undersigned officer, personally appeared Charles L. Martz, Plaintiff in the above entitled case, who being duly sworn or affirmed according to law, deposes and says that the Defendant or Respondent above named is not in the military service of the United States of America, has personal knowledge that the Defendant or Respondent is now living at 2680 Deep Hollow Road, Dover, PA, and is a resident of York County, PA and is employed at or by Pathology Labs, Harrisburg, PA. / /~/ .) /1/ //' I // /-,,' ~j l~ar~.J4;t~' l/, n ~ff Sworn to and subscribed before me this Li'!!2 day of February, 2005. ~/ ~ .dh1h't Notary Public My Commission expires: COMMONWEALTH OF PENNSYLVANIA Notniaf Seal Deborah L. Oc.,ley. Nolary Public Camp Hili Bolo, Cumbel1and Counly My Commission Expires Sepl23, 2007 Member, Pennsylvania Association Of Notaries CHARLES L. MARTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-6528 CIVIl. TERM v SANDRA PASSARELLA, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE OF 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 Section 3301 (d) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of filing of Comolaint: December 29, 2004 b. Manner of service of Comolaint: Certified Mail/Restricted Delivery L Date of Service of Comolaint: January 5, 2005 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: N/ A b. Defendant: N/ A OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301 (D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: December 29, 2004 b. Date of Filing: December 29, 2004 L Date of Service: January 5, 2005 4. RELATED CLAIMS PENDING: No issues have been raised in this case, and there are no issues outstanding. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(0)(1)(1) OF THE DIVORCE CODE: a. Date of Service: January 25, 2005 b. Manner of Service: Regular U.S. Mail OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: N/ A b. Defendant's Waiver: N/ A ! rZ,_~~~7 ;. n ~~: ' "" " "'~~ DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 E-mail: dianeradcliff@comcast.net January 25, 2005 Sandra Passarella 2680 Deep Hollow Road Dover, PA 17315 Re: Charles L. Martz YS. Sandra Passarella Cumberland County Divorce Action No. 04-6528 Dear Ms. Passarella: I previously served you with a Divorce Complaint and 3301 (d) affidavit on January 5, 2005. Following service of the complaint Mr. Martz advised me that you would not be contesting the divorce. I informed him that if that remained your position, the divorce decree could be entered without further action by either party following service of the required Notice of Intent to Request Entry of Divorce Decree. To that end and in accordance with the Rules of Civil Procedure, I am herewith serving you with the Plaintiff's Notice of Intention to Request Divorce Decree and attached 3301 (d) counter-affidavit. If you have any questions regarding any of these documents you should contact the attorney for your choosing. If you take no action in this case, I will proceed with asking the Court to enter a final Decree of Divorce in this matter on or after February 15, 2005. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGR/rzs Enclosures: Notice of Intention 3301 (d) Counter-Affidavit cc: Charles L. Martz File No. 21-04-D Transmission by mail CHARLES L. MARTZ, Plaintiff : IN THE COURT OF CO~~/~LEAS J~~ E : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-652S CIVIL TERM SANDRA PASSARELLA, Defendant : CIVIL ACTION - LAW ; IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 3301 (d) DIVORCE DECREE TO: Sandra Passarella, Defendant 2680 Deep Hollow Road Dover, PA 17315 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 3301 (d) affidavit. Therefore, on or after February 15,2005, 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 with 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. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS AITACHED TO THIS NOTICE. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 249-3166 ~ ~ DI ..G~RAD )L1~UIRE I.D. No. 321 3448 Trindle Road Camp Hill, PA 17011 (717) 737.0100 Attorney for Pl.aintiff ~ ( v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-6528 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE CHARLES L. MARTZ, Plaintiff SANDRA PASSARELLA" LJefendant COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): [ ] [ ] (a) (b) I do not oppose the entry of a divorce decree. I oppose the entry of a divorce decree because Check (i), (ii) or both: [ ] [ ] (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): [] (a) [ ] (b) I do not wish to make any claims for economic relief. 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. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit 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. Date: SANDRA PASSARELLA, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. \"' cJ' - :+; c+;:+;:+;:+;<f.;ji;lo' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~;lo' + ~ <f. :+;:f.:+;+; . . +: "';;< <f. '+ + +' <f.:f. ;to::f.:f. Of. :f. :f++++'>'+'>'+ +.+.+.+.""+ +:f.+++'++ + ++'++++++ . . . . . . . . . . . . . . . . . . + + + + . + . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. CHARLES L. MARTZ, plaintiff No. 04-6528 CIVIL TERM SANDRA VERSUS PASSARELLA, Defendant DECREE IN DIVORCE cA '1: .J)A.1V1 ' AND NOW, ~ , IT IS ORDERED AND dr 2005 CHARLES L. MARTZ DECREED THAT , PLAINTIFF, SANDRA PASSARELLA AND , 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; No issues have been raised in this case, and no issues are outstanding. PROTHONOTARY ATTEST: +'+++'++++ . . . + .. 'Ii+ +++ ++:1'+++ . . . . . . . . + + . . . + . . . + . . + . . . . + + . . . . . . J. ~A'zJ., JO ';ie' C' . fl.vJ Z ~ v ~~ r;r;J5T:. e )1"" ~ hP? '-I- -v / ~ fj!: gftf. ... ,I' , . ~., . ~ -- CHARLES L. MARTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 04-6528 CIVIL TERM SANDRA PASSARELLA, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on January 25, 2005, I served a true and correct copy of the Notice of Intention to Request Entry of 3301 (d) Divorce Decree and 3301 (d) CounterAffidavit upon Sandra Passarella, the Defendant, by Regular U.S. Mail, addressed as follows: Sandra Passarella 2680 Deep Hollow Road Dover, PA 17315 Copies of the cover letter, Notice of Intention and Counter Affidavit are attached hereto and collective marked Exhibit "An and made a part hereof. 1/ I ,,' '- ~B DIANE G. RADCLIFF, ESQUIRE L. t' ;jJ ~ 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 E.mail: dianeradcliff@comcast.net January 25, 2005 Sandra Passarella 2680 Deep Hollow Road Dover, PA 17315 Re: Charles L. Martz vs. Sandra Passarella Cumberland County Divorce Action No. 04.6528 Dear Ms. Passarella: I previously served you with a Divorce Complaint and 3301 (d) affidavit on January 5, 2005. Following service of the complaint Mr. Martz advised me that you would not be contesting the divorce. I informed him that if that remained your position, the divorce decree could be entered without further action by either party following service of the required Notice of Intent to Request Entry of Divorce Decree. To that end and in accordance with the Rules of Civil Procedure, I am herewith serving you with the Plaintiff's Notice of Intention to Request Divorce Decree and attached 3301 (d) counter-affidavit. If you have any questions regarding any of these documents you should contact the attorney for your choosing. If you take no action in this case, I will proceed with asking the Court to enter a final Decree of Divorce in this matter on or after February 15, 2005. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGRfrzs Enclosures: Notice of Intention JJ01(d} Counter-Affidavit cc: Charles L. Martz File rjo. Z1-04.D Transmission by mail . ~ <( lA- c, ~ <( ~~"'-:'" .. 1 r~ ('5:~.!;J CHARLES L. MARTZ, Plaintiff : IN THE COURT OF COMMUN' PLEAS OF : CUMBERLAI'lD COUNTY, PENNSYLVANIA r'~.:::J tb~ v. : NO. 04-6528 CIVIL TERM SANDRA PASSARELLA, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 3301 (d) DIVORCE DECREE TO: Sandra Passarella, Defendant 2680 Deep Hollow Road Dover, PA 17315 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 3301 (d) affidavit. Therefore, on or after February 15, 2005, 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 with 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. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. c ~ ( v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAt~D COUNTY, PENNSYLVANIA : NO. 04-6528 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE CHARLES L. MARTZ, Plaintiff SANDRA PASSARELLA.l. uefendant COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCl: CODE 1. Check either (a) or (ib): [ ] [ ] (a) (b) I do not oppose the entry of a divorce decree. I oppose the entry of a divorce decree because Check (i), (ii) or both: [ ] [ ] (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (ib): [ ] (a) [ ] (b) I do not wish to make any claims for economic relief. 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. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit 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. Date: SANDRA PASSARELLA, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ;- ~ ~, , (." IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C t-{ J!d<2..L)3S L. MJ1.f'~ Plaintiff Vs FileNo. O,/-(P'5;<''i CiVil7erM IN DIVORCE SAMDRA Pit 5GA-{2cU-f} Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, ,~ &~ 'I ZZQ, "" . or L--- after the entry of a Final Decree in Divorce dated fbh a:s-; ;7.iJ()(J., , - hereby elects to resume the prior surname of PAsc;{je~cjA , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: :3- 3 - OS- f1J1(/il// ~. r-Hcuuf.LecL{1It:U:!t.J 19nature (::?'/ COMMONWE~L TH OF PENNSYIF ANIA COUNTY OF LL.f1/t.kaY0r1 On the3 rot day of Yh 0(./1 &-.-.. ) ,2001:, 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 / 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. Clal/dJ,- &rh~)b~)L/ Prothonotary or Notary Public i'iC.~T /,:,t\L SEAl ~ 1.~L':L.;ii', fe. f!;:;h'ibAK[-!~, N(:lARY PUBLIC I ,'-,',',.,-, [,(,-. r.o ',.!., "r. , ~:d ',', L ,)J,L'. L,,Jrn~JU'clnlJ l,QL1riIY rJ: ,::urr:I:',!:2iC:i i;'.;:: Apil ":, 2DGS ~ r':) ~ D ..w V'I , -- :r:::.... ~ ~ r> ~ '-'" ('.~ 23 u ;:"~~ ~. ;',;) <..f1 ;..1 rl ",..~ J ,