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HomeMy WebLinkAbout05-5092 BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. - dC VS. KELLY O. DILL, CIVIL ACTION -LAW 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)-990-9108 BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. VS. KELLY O. DILL, CIVIL ACTION -LAW Defendant IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud. se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por las Corte. una decision puede tambien ser emitida en su contra por caulquier otra queja o compensacion eclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)-990-9108 BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. t?_s=? f, ?- ? vs. VS. KELLY O. DILL, : CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DOMESTIC RELATIONS CODE AND NOW, comes Plaintiff, Brenda M. Dill, (hereinafter referred to as "Plaintiff'), by and through her counsel, Linda A. Clotfelter, who files this Complaint in Divorce, and in support thereof states the following: 1. Plaintiff is Brenda M. Dill an adult individual who resides at 351 South Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Kelly O. Dill, an adult individual who resides at the Cumberland County Jail, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this divorce Complaint. 4. Plaintiff and Defendant were married on February 7, 1987 in Cumberland County, Pennsylvania. 5. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since January 3, 2003. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Defendant is not a member of the armed forces of the United States or any of its allies. 8. Plaintiff avers that the marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this Court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER r Date: U S Li da A. Clotfelter, Esquire A orney ID No. 72963 ,421 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 Attorney for Plaintiff BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. VS. KELLY O. DILL, CIVIL ACTION -LAW Defendant IN DIVORCE VERIFICATION I, BRENDA M. DILL, verify that the statements in the foregoing DIVORCE COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date: A *S BRE A M. DILL C'? ?..3 c? ? -rs {? ?+ 'i??? ?-sq C:'1f ? ?, ? s s ?? ? _ -i'< ?? _p ? ? ? ? ?3 ?? r BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL NO. 05-5092 CIVIL : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE Kindly reinstate the Complaint in the above-captioned matter. Respectfully submitted, Date: D Q to LAW OF LINDA A. CLOTFELTER By: Li da A. Clotfelter, Esquire A torney I.D. No. 72963 8021 East Trindle Road, Suite Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile rte` ;N?-J ? ._.?. ? _ cz? --, ?? r-.?- '"?: , , ' `? r -. =.:a ?_° , ? .. ' "? -- ' < ',..:? r _? . ?? tilt, ? ; •? -? ?? ry ? b BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL NO. 05-5092 CIVIL : CIVIL ACTION -LAW : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty (20) 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 January 3, 2003, and have continued to live separate and apart for a period of at least two (2) 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 amended 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 unworn falsification to authorities. to ? _ DA E DILL r.a t-a 0 BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 05-5092 VS. KELLY O. DILL, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, KELLY O. DILL, Defendant in the above-captioned matter, on this date, hereby accept service of the COMPLAINT IN DIVORCE initially filed September 29, 2005 and reinstated December 21, 2006, and the NOTICE and AFFIDAVIT under section 3301(d) of the Divorce Code signed December 20, 2006 and filed on December 21, 2006 by Plaintiff. Dated: -017 KELLY O. DIL , Defendant Address: )'4 ,? fo • Al'-A ?? p 1 AI 1 -1) Telep one: cg - "7 BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 05-5092 VS. KELLY O. DILL, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, on this date, the undersigned hereby certifies that a true and correct copy of the foregoing ACCEPTANCE OF SERVICE for the REINSTATED COMPLAINT IN DIVORCE was served upon the opposing party as follows: Kelly O. Dill 142 N. Pitt Street Carlisle, PA 17013 Date: t t 101 rBy: LAW FIRM OF LINDA A. CLOTFELTER ;'Ada A. Clotfelter, Esquire A rney ID No. 72963 5 1 East Trindle Road, Suite 1 Mechanicsburg, PA 17050 (717) 796-1930 Attorney for Plaintiff l; -«ti, U BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL NO. 05-5092 : CIVIL ACTION -LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(D) DIVORCE DECREE AS AMENDED TO: Kelly O. Dill, Defendant You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after May 17, 2007, 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. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)990-9108 M BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL NO. 05-5092 KELLY O. DILL, : CIVIL ACTION -LAW Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) 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 (2) years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claim 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. ? (b) 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 on Intention Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. f 1% 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 KELLY O. DILL NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. 1% BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL NO. 05-5092 KELLY O. DILL, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, on this date, the undersigned hereby certifies that a true and correct copy of the NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (D) DIVORCE DECREE with a COUNTER-AFFIDAVIT was served upon the Defendant by United States first class mail, postage prepaid addressed as follows: Kelly O. Dill 142 N. Pitt Street Carlisle, PA 17013 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: h ? in 'nda A. Clotfelter, Esquire / ttomey I.D. No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Attorney for Plaintiff (717) 796-1930 Telephone (717) 796-1933 Facsimile ? r-a ° O - ? ?, ? - `.' ?: -' ?„ -ts ? n? r-- rs?-` '? ..?? N `?3? ?. ' ? t°tz ?', ?" L-? ? ? J, p. .? ? BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL NO. 05-5092 KELLY O. DILL, : CIVIL ACTION -LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. The Complaint was filed on September 29, 2005 and reinstated on December 21, 2006. The Complaint was served by Acceptance of Service of Defendant on January 12, 2007, as evidenced by same filed on January 23, 2007. 3. The Affidavit required by § 3301(d) of the Divorce Code was executed by Plaintiff on December 20, 2006, and it was filed December 21, 2006. It was served upon Defendant on May 14, 2007 by first class mail postage prepaid as evidenced by the Affidavit of Service filed May 22, 2007. 4. There are no related claims pending. 5. The notice of intention to request entry of section 3301(d) divorce decree, a copy of which is attached, was served upon Defendant by first class mail April 26, 2006, as evidenced by the Certificate of Service filed April 26, 2007. The Plaintiff's Waiver of Notice was signed by Plaintiff May 14, 2007, and was filed with the Prothonotary May 22, 2007. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Lihda A. Clotfelter, Esquire / J orney I.D. No. 72963 (,/ 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 (Telephone) (717) 796-1933 (Facsimile) BRENDA M. DILL, Plaintiff vs. KELLY O. DILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL NO. 05-5092 : CIVIL ACTION -LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(D) DIVORCE DECREE AS AMENDED TO: Kelly O. Dill, Defendant You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after May 17, 2007, 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. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street ' Carlisle, PA 17013 Telephone (800)990-9108 s . aN T b m I CA) BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 05-5092 CIVIL ACTION -LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) 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 (2) years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claim 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. ? (b) 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 on Intention Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. 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 KELLY O. DILL NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL NO. 05-5092 KELLY O. DILL, CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, on this date, the undersigned hereby certifies that a true and correct copy of the NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (D) DIVORCE DECREE with a COUNTER-AFFIDAVIT was served upon the Defendant by United States first class mail, postage prepaid addressed as follows: Kelly O. Dill 142 N. Pitt Street Carlisle, PA 17013 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: h (W in IVnda A. Clotfelter, Esquire / ttorney I.D. No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Attorney for Plaintiff (717) 796-1930 Telephone (717) 796-1933 Facsimile t_-. w ??1 ..?-? ? . '? s=- ? __ ?? c.J _ _ . ?.- - _. _ ? c. .; ? - .. ,?: cti BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 05-5092 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the 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. Dat V w A M. DILL, Plaintiff r-a BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant JUDGE: J. WESLEY OLER, JR. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 05-5092 CIVIL ACTION -LAW : IN DIVORCE AMENDED PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. The Complaint was filed on September 29, 2005 and reinstated on December 21, 2006. The Complaint was served by Acceptance of Service of Defendant on January 12, 2007, as evidenced by same filed on January 23, 2007. 3. The Affidavit required by section 3301(d) of the Divorce Code was executed by Plaintiff on December 20, 2006, and it was filed December 21, 2006. It was served upon Defendant January 12, 2007 by Acceptance of Service of Defendant as evidenced by same filed January 23, 2007. 4. There are no related claims pending. 5. The notice of intention to request entry of section 3301(d) divorce decree, a copy of which is attached, was served upon Defendant by first class mail, postage prepaid April 26, 2006, as evidenced by the Certificate of Service filed April 26, 2007. The Plaintiff's Waiver of Notice was signed by Plaintiff May 14, 2007, and was filed with the Prothonotary May 22, 2007. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER /07 L' da A. Clotfelter, Esquire Attorney I.D. No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 (Telephone) BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL NO. 05-5092 : CIVIL ACTION -LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(D) DIVORCE DECREE AS AMENDED TO: Kelly O. Dill, Defendant You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after May 17, 2007, 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. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street C7 a Carlisle, PA 17013 Telephone (800)990-9108 SJ ? T BRENDA M. DILL, Plaintiff VS. KELLY O. DILL, Defendant : IN TBE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL NO. 05-5092 CIVIL ACTION -LAW IN DIVORCE COUNTER AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) 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 (2) years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claim 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. ? (b) 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 on Intention Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. 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 KELLY O. DILL NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. BRENDA M. DILL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL NO. 05-5092 KELLY O. DILL, CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, on this date, the undersigned hereby certifies that a true and correct copy of the NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (D) DIVORCE DECREE with a COUNTER-AFFIDAVIT was served upon the Defendant by United States fast class mail, postage prepaid addressed as follows: Kelly O. Dill 142 N. Pitt Street Carlisle, PA 17013 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: 11 I da A. Clotfeiter, Esquire ttomey I.D. No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Attorney for Plaintiff (717) 796-1930 Telephone (717) 796-1933 Facsimile t? ? Fn C CO IN THE COURT OF COMMON PLEAS BRENDA M. DILL, OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS KELLY O. DILL, Defendant BRENDA M. DILL DECREE IN DIVORCE AND NOW, I ut7 G ?i 2007 IT IS ORDERED AND DECREED THAT AND KELLY O. DILL No. 05-5092 CIVIL , PLAINTIFF, ,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; NONE BY THE COURT: ATT E J. PROTHONOTARY ?? Ak, 410