HomeMy WebLinkAbout01-5381ROBERT A. DOREN,
Plaintiff
THERESA A. CHRISTOPHER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ol --.~32/
CIVIL ACTION- LAW
1N DIVORCE
COMPLAINT IN DIVORCE
1. The Plaintiff is Robert A. Doren, an adult individual currently residing at 4833
Charles Road, Mechanicsburg, Cumberland County, Pennsylvania, since 1994.
2. The Defendant is Theresa A. Christopher, an adult individual who currently resides
at 906 Schoolhouse Lane, Lewisberry, York County, Pennsylvania, 17339, since October of 2000.
3. The Defendant has been a bona fide resident in the Commonwealth of Pennsylvania
for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 12, 1996, in Dauphin,
Dauphin County, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress
of 1940 and its amendments.
6. There have been no prior actions of divome or for annulment between the parties.
7. Plaintiffhas 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. No children were bom of the marriage.
9. The marriage is irretrievablybroken.
Document #205968
10. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse,
as to render Plaintiff's condition intolerable and life burdensome.
11. During the marriage the parties acquired marital property and assets which Plaintiff
requests the Court equitably distribute and assign.
12. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and
Defendant.
WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce, and enter an
Order equitably distributing marital property, and enter such other orders as are appropriate.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Karl R. Hildabrand, Esquire
Attorney I.D. No. 30102
P.O. Box 5300
3211 North Front Street
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Dated:
Document #205965
-3-
VERIFICATION
I, Robert A. Doren, hereby 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.A.
§4904 relating to unswom falsificationto authorities.
Robert A. Doren
Document #205968
VITAL RECORDS
COUNTY
CUMBERLAND
RECORD OF
DIVORCE OR ANNULMENT
[] ICHECK ONE) []
STATE FILE DATE
NAME
RESIDENCE
NUMBER
OF THiS
MARRIAGE
HUS.BAND
Robert A. Doren, Jr. I oF
· ,RT~ 12 10 1965
4833 Charles Road, Mechanicsburg, Cumberland, PABIRTHOF Pennsylvania
1st ~i~ [] Computer Network Administrator
WIFE
MAIDEN NAME
Theresa A. Christopher
906 Schoolhouse Lane, Lewisberry,
12. NUM"ER ' WHIT
OF THIS 2nd
OF THIS Dauphin
D REN TH IS
MARRIAGE 0
York
BI.TH 11 19 1958
PA OF
.,nTH Pennsylvania
Computer Analyst
MARRIAGE 10 12 1996
Pennsylvania
NOMBIER OF HUSBAND WIFE ~;f'LIT CUSTQDY OTHER
DATE OF DECREE (~h) (~y) (Y~r)
21, ~.EGA~.GROUNDS FOR
DIVORCE OR ANNULMENT
23. DATE REPORTSENT
ROBERT A. DOREN,
PlaintilT
THERESA A. CIIRiSTOPI [ER,
Defendant
IN TI IE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSY1,VANIA
NO. ? '~ · o '
CIVIl, ACTION LAW
IN DIVORCE
CERTIFICATE OF SERVICE
1, Karl R. Hildabrand, Esquire, counsel tbr Plaintiff; Robert A. Doren, hereby certify that a
true and correct copy of the Complaint in Divorce was served by certified mail, return rcccipt
requested, upon Defeudant, Theresa A. Christopher, on September 21, 2001. Attached hereto,
marked as Exhibit "A', and incorporated herein by reference is the signed return rcceipt card fnr
said service.
METZGER, W[CKERSIIAM, KNAUSS & ERB. P.C.
Dated:
Karl R. Hildabrand, Esquire
Attorney I.D. No. 30102
P.O. Box 5300
3211 North Front Street
! larrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
Exhibit A
· Complete iten~ 1, 2, and 3. Also complete
item 4 if Re~flcted Delivery i. desired.
· Print your name ancl addre~ on the reverse
so that we ~an return the card to you.
· Attach this can~ to the back of the rnailpiece,
or on the front if space permits.
Theresa A. Christopher
906 Schoolhouse Lane
Le~s~erry, PA 17339
YES, 1
: [] NO
2. Artiole Num/oer (Copy hotw ~e~ce/a~e0
7000 ~ ¢~'!; 4~0~ ~9~t
PS Form 3811, Ju~/1999 Oorn~tlo Return Receipt
4. Rear,ted O~-/~ ~ExUa Fee) DYes
ROBERT A. DOREN,
Plaintiff
Va
THERESA A. CHRISTOPHER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5381 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on
September 14, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
has elapsed from the date of filing and service of the Complaint.
3. I consent to the entry ora final Decree of Divorce after service of notice of
intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI 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.
Dated: /"/- 5 - O 2_
ober~ A. Doren~
Document it: 224105.1
ROBERT A. DOREN,
Plaintiff
Vo
THERESA A. CHRISTOPHER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5381 CIVIL TERM
CIVIL ACTION- LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(C) 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 ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorce 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.
Dated:
A. Doren /
Document #: 224106.1
ROBERT A. DOREN,
Plaintiff
THERESA A. CHRISTOPHER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5381 CIVIL TERM
CIVIL ACTION- LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on
September 14, 2001.
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days
has elapsed from the date of filing and service of the Complaint.
3. I consent to the entry ora final Decree of Divorce after service of notice of
intention to request entry of the decree.
4. I understand that I may lose rights conceming alimony, division of property,
lawyer's fees or expenses ifI do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are tree 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.
Theresa A. Christopher / --
Document #: 224105.1
ROBERT A. DOREN,
Plaintiff
THERESA A. CHRISTOPHER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5381 CIVIL TERM
CIVIL ACTION- LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(C) OF THE DIVORCE CODE
I. I consent to the entry ora final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorce 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.
Dated:
Theresa A. Christopher
Document #: 224106.1
MARITAL SETTLEMENTAGREEMENT
THIS AGREEMENT, made this [ ~ day of i .g~(~'t-'.¥q.'l._ , 2001, by and between Robert A.
Doren (hereinafter "Husband") of Hampden Township, Cumberland County, Pennsylvania, and
Theresa A. Christopher (hereinafter "Wife") of Lewisberry, York County, Pennsylvania.
WITNESSETH:
WHEREAS, the parties are Husband and Wife, married on October 12, 1996, in Dauphin,
Dauphin County, Pennsylvania; and
WHEREAS, no children were born of the marriage; and
WHEREAS, unhappy differences and difficulties have arisen between the parties, in
consequence of which the parties intend to live separate and apart for the rest of their natural lives;
and
WHEREAS, the parties desire to settle fully and finally their respective financial and
property rights and obligations as between each other, including but not limited to the ownership
and equitable distribution of real and personal property; past, present and future support, alimony
and/or maintenance; and any and all claims which either party has, or may have, against the other or
the other's estate;
NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings
hereinafter set forth and for other good and valuable consideration, receipt of which the parties
acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as
follows:
Document #205958
Each party shall have the right to live separate and apart from the other party, free from the
other party's interference, authority and control. Neither party shall interfere with the other or
attempt to interfere with the other, nor compel the parties' cohabitation.
2. HUSBAND'S AND WIFE'S DEBTS
Except as otherwise set forth in this Agreement, the parties represent and warrant to each
other that they have not incurred and will not contract or incur any debt or liability for which the
other or the other's estate might be responsible. Each party shall indemnify and save harmless the
other party from any and all claims or demands made against the other by reason of debts or
obligations incurred by that party.
3. WAIVER OF RIGHTS AND MUTUAL RELEASES
Except as provided in this Agreement, both parties absolutely and unconditionally release
and forever discharge each other and their heirs, executors, administrators, assigns, property and
estate from any and all rights, claims, demands or obligations arising out of or by virtue of the
marital relationship, whether such claims exist now or arise in the future. This release shall be
effective regardless of whether such claims arise out of former or future acts, contracts,
engagements or liabilities of the parties or by way of dower, curtesy, widow's rights, family
exemption or similar allowance, or under the intestate taws, 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 a deceased spouse's estate, whether arising under the laws of
Pennsylvania, any state, commonwealth or territory of the United States, or other country.
Document #205958
Except for any cause of action for divorce which either party may have or claim to have,
and except for the obligations of the parties contained in this Agreement, each party gives to the
other an absolute and unconditional release and discharge from all causes of action, claims, rights
or demands whatsoever, in law or in equity, which either party ever had or now has against the
other, including but not limited to alimony, alimony pendente lite, spousal support, equitable
distribution of marital property, counsel fees or expenses.
4. REAL ESTATE
The parties own as tenants by the entireties the improved real property situate at 4833
Charles Road, Mechanicsburg, Pennsylvania, 17050. Said property was purchased and owned by
both Husband and Wife prior to the marriage of the parties. In consideration of the mutual
promises of the parties, it is agreed as follows:
(a) Contemporaneous with the signing of this Marital Settlement Agreement, Wife shall
execute a deed conveying to Husband all of her right, title, and interest, if any, in the
marital residence, free and clear of all encumbrances.
(b) Husband shall pay for preparing and recording the new deed.
Husband is the sole owner of real property located at Mountain Road, Middle Paxton
Township, Dauphin County, Pennsylvania. Contemporaneous with the signing of this Agreement,
Wife shall execute a deed conveying to Husband all of her right, title, and interest in said property,
if any, free and clear of all encumbrances. Husband shall pay for preparing and recording the new
deed.
Wife is the sole owner of a property located at 906 Schoolhouse Lane, Lewisberry, York
County, Pennsylvania, which Wife purchased during the marriage. Contemporaneous with the
Document #205958
-3-
signing of this Marital Settlement Agreement, Husband shall execute a deed conveying to Wife all
of his right, title, and interest in said property, if any, free and clear of all encumbrances. Husband
will pay for preparing and recording the new deed. Furthermore, Wife agrees to assume sole
responsibility for the payment of the mortgage on said property and Wife agrees to indemnify
Husband for her failure to carry out said obligation.
5. DIVISION OF PERSONAL PROPERTY
The parties have divided all items of personal property, except as otherwise specified
herein, to their mutual satisfaction. All personal property currently in Husband's possession shall
be the sole and separate property of Husband. All personal property currently in Wife's possession
shall be the sole and separate property of Wife.
6. MOTOR VEHICLES
Husband shall retain sole and exclusive ownership of the Chrysler Jeep and Ford Escort
automobile in his possession and agrees to assume sole responsibility for all outstanding
encumbrances, if any.
Wife shall retain sole and exclusive ownership of the Ford van and Saturn automobile in her
possession and agrees to assume sole responsibility for all outstanding encumbrances, if any,
including the loan from Fulton Bank.
Both parties agree to execute, within thirty (30) days of the date this Agreement is signed by
both parties, any and all forms, titles and documents necessary to transfer the aforesaid vehicles
from joint ownership to individual ownership, as specified herein.
Document #205958
-4-
Except as otherwise stated in this Agreement, the parties acknowledge that they have no
debts which were jointly incurred during their marriage.
Any debts or obligations incurred by either party in his/her individual name, other than
those specified herein, whether incurred before or after separation, are the sole responsibility of the
party in whose name the debt or obligation was incurred.
8. RETIREMENT BENEFITS
Husband owns or is a participant in the following pension/retirement/profitsharing plans:
Commonwealth of Pennsylvania Employee #: 047711
State Employees' Retirement System
Commonwealth of Pennsylvania Account #: 01111142
(deferred compensation pm#ram)
Wife owns or is a participant in the following pension/retirement/profit sharing plans:
Commonwealth of Pennsylvania Employee #: 104607
State Employees' Retirement System
Commonwealth of Pennsylvania Account #: 01111142
(deferred compensation program)
Each of the parties does specifically waive, release, renounce and forever abandon all of
their right, title, interest or claim, whatever it may be, in any pension/retirement/profitsharing plan
of the other party, whether acquired through said other party's employment or otherwise, and
hereafter the pension/retirement/profit sharing plan identified above as being either husband's or
wife's shall become the sole and separate property of the party in whose name or whose
employment said plan is carded.
Document #205958
-5-
9. DIVISION OF BA. NK ACCOUNTS
Husband and Wife acknowledge that all joint bank accounts have been closed or divided to
their mutual satisfaction prior to the execution of this Agreement.
10. INVESTMENTS
Husband shall retain sole and exclusive ownership of the following investment accounts:
Name Account No.
PSECU 179567194
Ameritrade 178-316873
Scudder Aggressive Growth Fund 73-133325094-0
Scudder Blue Chip Fund 3 I- 1333325094-0
Wife shall retain sole and exclusive ownership of the following investment accounts:
Name Account No.
PSECU 206509668
Each party hereby agrees to completely relinquish and waive any and all interest they may
have in the investment accounts of the other. Both parties agree to execute, within thirty (30) days
of the date this Agreement is signed by both parties, any and all forms, titles and documents
necessary to transfer the aforesaid property from joint ownership to individual ownership, as
specified herein.
11. PAYMENT TO WIFE
In consideration for the promises and undertakings set forth herein, Husband has paid to
Wife the sum of $55,000.00, the receipt of which sum is acknowledged by Wife.
Document #205958
-6-
12, AFTER-ACOUtRED PROPI~RTy
Each of the parties shall own and enjoy, independently of any claims or rights of the other,
all real property and all items of personal property, tangible or intangible, hereafter acquired, with
full power to dispose of the ~ame as fully and effectively as though he or she were unmarried. Any
property so
acquired shall be owned solely by that party and the other party shall have no claim to that property.
13. sPOUSAL SUPPORT, ALIMONY PENDENTE LITE, AND ALIMONY
Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony
pendente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this
Agreement shall not constitute alimony but is made as part of the parties' equitable distribution
settlement.
14. TAX MATTERS
The parties have negotiated this Agreement with the understanding and intention to divide
their marital property. The parties have determined that such division conforms to a right and just
standard with regard to the rights of each party. The division of existing marital property is not,
except as may be otherwise expressly provided herein, intended by the parties to constitute in any
way a sale or exchange of assets. It is understood that the property transfers described in this
Agreement fall within the provisions of section 1041 of the Internal Revenue Code, and as such
will 'not result in the recognition of any gain or toss upon the transfer by the transferor.
15. COUNSEL FEES AND EXPENSES
Except as otherwise specified herein, each party shall be responsible for payment of his/her
own counsel fees and expenses.
Document
-7-
16. ADVICE OF COUNSEL
The parties acknowledge that each has received or has had the opportunity to receive
indepenflent legal advice from counsel of their selection and that they have been informed fully as
to their legal rights and obligations, including all rights available to
them under the PennsylvaniaDivorce Code of 1980 as amended, and other applicable laws.
Each party confirms that he/she understands fully the terms, conditions, and provisions of
this Agreement and believes them to be fair, just, adequate and reasonable under the existing
circumstances. The parties further confirm that each is entering into this Agreement freely and
voluntarily and that the execution of this Agreement is not the result of any duress, undue influence,
collusion, or improper or illegal agreement.
17. AFFIDAVITS OF CONSENT
Each party agrees to execute an Affidavit of Consent for the obtaining a no-fault divorce
under the provisions of the Divorce Code of 1980, as amended.
18. EFFECT OF DIVORCE DECREE ON AGRF.~MENT
Either party may enforce this Agreement as provided in section 3105(a) of the Divorce
Code, as gmended.
As provided in section 3105(c), provisions of this Agreement regarding equitable
distribution, alimony, alimony pendente lite, counsel fees or oxpenses shall not be subject to
modification by the court.
19. DATE OF EXECUTION
The "date of execution", "date of this agreement" or "execution date" of this Agreement is
the date upon which it is signed by the parties if they sign the Agreement on the same date.
Document #205958
-8-
which the last party signed this Agreement.
20. HEADINGS NOT PART OF AGREEMENT
The descriptive headings preceding the paragraphs are for convenience and shall not affect
the meaning, construction or effect of this Agreement.
21. SEVERABILITYAND INDEPENDENTAND SEPARATE COVENANTs
Each separate obligation shall be deemed to be a separate and independent covenant and
agreement. 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
provision shall be stricken from this Agreement and in all other respects this Agreement shall be
valid and continue in full force, effect and operation.
22. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding on and shall enure to the benefit of the parties and their
respective heirs, executors, administrators, successors, and assigns.
23. INTEGRATION
This Agreement constitutes the entire understanding of the parties and supersedes any and
all prior agreements and negotiations between them. There are no representations, warranties,
covenants or promises other than those expressly set forth in this Agreement.
24. MODIFICATIONOR WAIVER TO BE IN WRITING
No modification or waiver of any term of this Agreement shall be vaIid unless in writing
and signed by both parties.
Documem #205958
-9-
26. NO WAIVEROF DEFAULT
The failure of either party to insist upon strict pertbrmance of any term of this Agreement
shall in no way affect the right of such party hereafter to enforce the term·
26. VOLUNTARY EXECUTION
The parties acknowledge that this Agreement is fair and equitable, and that they have
reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or
improper or illegal agreements.
27. APPLICABLE LAW
This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania
and more specifically under the Divorce Code of 1980, as amended.
28. ATTORNEYS' FEES FOR ENFORCEMENT
If either party breaches any provision of this Agreement, the breaching party shall pay all
reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the
enforcing party is successful in establishing that a breach has occurred.
IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first
written above.
WITNESS:
Robert A. Doren
Theresa A. Christopher
Document #205958
-10-
COMMONWEALTH OF PENNSYLVANIA:
:
cOUNTY OF (.-',., ,,., *,.r~,~.~,-.,.r, :
SS
On this, the ~ay of ~" &. r,*,~~, t ~, 2001, before me, the undersigned officer, personally
appeared Robert A. Doren known to me or satisfactorily proven to be the person whose name is
subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that he executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and o~Twial seal
' IX~O~. ]~sg ion-E xpir es i
_ · ot:.~.L I
***************************************************-**-****************************
COMMONWEALTH OF PENNSYLVANIA:
COUNTYOF -(~-~ re.r5 e,t~,q,v._q :
SS
On this, the/fi'>-~day of ~7?'Wz~d;>,L., 2001, ~before me, the undersigned officer,
personally appeared Theresa A. Christopher known to me or satisfactorily proven to be the person
whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that
she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand an.d_~l~s~t.
My CommissionExpire~; ,
Documcm #205958
ROBERT A DOREN,
Plaintiff
V.
THERESA A. CHRISTOPHER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-5381
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following infomxation, to the Court for entry
of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and manner of service of Complaint: A Complaint in Divorce was filed on
September 14, 2001, and served on Defendant on September 21, 2001 via certified
mail, return receipt requested. Affidavit of Service has been filed.
Complete either paragraph (a) or (b):
(a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent
required by Section 3301(c) of the Divorce Code:
Plaintiff- April 3, 2002
Defendant- April 3, 2002
(b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the
Divorce Code: n/a
(2) Date of service of the plaintiffs affidavit upon the defendant: n/a
Complete the appropriate paragraphs:
Document #: 225272.1
(a) Related claims pending: none
(b) Claims withdrawn:
none
(c) Claims settled by agreement of the parties: N/A
(d)
State whether any written agreement is to be incorporated into the Divorce
Decree. Marital Settlemem Agreement dated December 19, 2001.
(a) Date and manner of service of the notice of intemion to file praecipe to
transmit record, a copy of which is attached, if the decree is to be entered under
section 3301(d)(1)(i) of the Divorce Code: n/a
(b) Date plaintiWs Waiver of Notice in §3301(c) Divorce was filed with the
prothonotary: April 3, 2002
Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the
prothonotary: April 3, 2002
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
"t~arl R. Hildabrand, Esquire
I.D. No. 30102
3211No~h Front S~eet
P.O. Box 5300
Harrisburg, PA 17110-0300
(717)238-8187
Attorneys forPl~ntiff
Document #: 201020.1
ROBERT A DOREN,
Plaintiff
V.
THERESA A. CHRISTOPHER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-5381
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this t day of April, 2002 I, Karl R. Hildabrand, Esquire, of Metzger,
Wickersham, Knauss & Erb, attorneys for Plaintiff, Robert A. Doren, hereby certify that I served a
copy of the Praecipe to Transmit Record this day by depositing the same in the United States
mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to:
Theresa A. Christopher
906 Schoolhouse Lane
Lewisberry, PA 17339
MET. Z~G,/ER, WICKF~SHAM, KNAUSS & ERB, P.C.
XaKarl R. Hildabrand
Document #: 225272.1
IN The COURT Of COMMON PLEAS
OFCUMBERL~NDCOUNTY
STATE Of .~~~ PENNA.
ROBERT A. DOREN
VERSUS
THERESA A. CHRISTOPHER
No. 01-5381
DECrEe IN
DIVORCE
AND NOW, /~ /~::~
DECREED That ROBERT A. DOREN
, ~ , IT IS ORDERED AND
, PLAINTIFF,
and TNERRSA A. CHRISTOPHER
, 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;
The Marital Settlement Agreement between the parties dated December 19, 2001
is incorporated but not merged herein.
BY Th C~
ATTEST:
PROTHONOTARY