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HomeMy WebLinkAbout02-1848JULIE BRICKER, Plaintiff ALAN BRICKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may 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 grounds for the divorce are 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 Ceunt~ Ceurtheuse. 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. CUMBERLAND COUNTY LAWYER REFEREAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 854-8755 JULIE BRICKER, Plaintiff ALAN BRICKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. O:- CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301¢C~ OR SECTION 3301(D~ OF THE DIVORCE DECREE CODE AND NOW, comes the Plaintiff, Julie Bricker, by and through her attorney, of The Law Office of Darrell C. Dethlefs, seeks to obtain a Decree in Divorce from the Bonds of matrimony with the above*named Defendant and in support of her Complaint avers the following: Plaintiff, Julie Bricker, is an adult individual, who currently resides at 702 B North Front Street, Wormleysburg, Cumberland County, Pennsylvania. The Plaintiff's social security number is 210-64-7825. Defendant, Alan Bricker, is an adult individual, who currently resides at 2722 Walnut Street, Camp Hill, Pennsylvania. The Defendant's social security number is 179-58-6887. Both Plaintiff and Defendant have been bonified residents of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint. .. The parties were married on October 3, 1998 in Dauphin County, Commonwealth of Pennsylvania. 5. The Plaintiff and Defendant are citizens of the United States of America. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. Plaintiff has been advised of the availability of counseling and that he and the Defendant may have the right to request that the Court require the parties to participate in such counseling. COUNT I REQUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301~CI OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that the Defendant may also file such an affidavit consenting to a divorce. 11. Plaintiff has been advised of the availability of counseling and that he and the Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to divorce after ninety (90) days have elapsed from filing of the Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(C) of the Divorce Code. COUNT II REOUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301(D~ OF THE DIVORCE CODE 12. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 13. The Marriage of the parties is irretrievably broken. 14. After a period of two (2) years has elapsed form the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. 15. Plaintiff has been advised of the availability of counseling and the Plaintiff and Defendant have the right to request the Court to require parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(D) of the Divorce Code. Date: Respectfully Submitted; /~ Michael J. F~osh Attorney I.D, 58851 P.O. Box 368 Camp Hill, PA 17001 (717) 975-9446 Attorney for Plaintiff JULIE BRICKER, Plaintiff ALAN BRICKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I hereby verify that the statements of fact made in the foregoing Complaint in Divorce, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: l"l/q/°~'~. Ju. li~?ker * (~/ /~-~ JULIE BRICKER, V. ~AI,AN BRICKER, Plaintiff Defendant : UN THE COURT OF COMMON PLEAS : CUMBERI,AND COUNTY, PENNSYLVANIA : NO. 2002-1545 : CIVH, ACTION - LAW : DIVORCE ACTION CERTIFICATE OF SERVICE I, Michael J. Pykosh, Esquire, hereby certify that Defendant, Alan Bricker was served with the Divorce Complaint in this matter by Certified Mail, Return Receipt Requested on May 7, 2002. A copy of the green card, evidence of the same, is attached hereto and labeled "Exhibit A". I hereby verify that the statements of fact made in the foregoing are tree and correct to the best of my knowledge, information, and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unswom falsification to authorities. Date: Mictlffel J. Pykosh,'"E'~uire Attorney ID # 58851 Law Office of Darrell C. Dethlefs 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 SENDER: · Complete items 1 and/or 2 for additiona~ services. · Complete items 3, 4a, and 4b. · print your name and address on the reverse of this form so that we can return this card to you. · Attach this form to the front of the mailpiece, or on the back if space does not 2. [] Restricted Delivery ~- · ~lr e "Return Receip Requested" on the mailpiece below the article number. ~r- · The Return Receipt will show to whom the art cie was delivered and the date Consult postmaster for fee. ~ delivered. ~3 3. Article Addressed to: 4a. Article Number ~ ~UC~ ¢ 4b. Series Type % ~ Re istered CeKified o~~~ ~ Express Ma ~~e 5. Received By: (PrintName) 8'~s~a~~e ~ 6, Sig~Addre~ee or. ge t) ~ o~ =~.~ ~11 Dec~er-1994 102595-98-a-0229 Domestic ~e~urn JULIE BRICKER, V. ALAN BRICKER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1848 : : CIVIL ACTION - LAW : DIVORCE ACTION MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT is made and entered into between JULIE BRICKER and ALAN BRICKER, hereinafter referred to as Husband and Wife. Thc parties were married on October 3, 1998. As a consequence of disputes and unhappy differences, the parties have separated as of May 1, 2001 (herein after the date of separation). Thc parties desire to confirm their separation and make arrangements in connection ~ including the settlement of their property rights, and aH other rights and o~ligation~ arising out of thc mamage relationship. It is therefore agreed: 1. CONSIDERATION Thc consideration for this Agreement is thc mutual promises and agreements herein contained. 2. SEPARATION AND NONINTERFERENCI~ A. It will be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or d~m fit. B. Each party shall be free from interference, authority and o~ntrol, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 3. MUTUAL RELEASE Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, fights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against thc other, except any or aH cause or causes of action for divorce. Initials 4. FULL DISCLOSURE The provisions of this Agreement and their legal effect are fully understood by each party to this agreement, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Htrsbond and wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of aH assets of any whatsoever and of all other facts relating to the subject matter of this Agreement. Both parties represent that the terms of this Agreement have been fully explained to them by their respective counsel or that both parties have had thc opportunity to have legal counsel review and fully explain the terms of this Agreement. Wife is represented by Michael J. Pykosh, Esquire of the Law Office of Darrell C. Dethlefs. Husband is not represented. Hushand has been advised that he shollld oblain representation. Husband understands that the Law Office of Darrell C. Detlflefs represents his wife solely. 5. EQUFFABLE DIVISION By this Agreement, the parties have intended to effect an equitable division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 6. SUBSEQUENT DIVORCE A. AGREEMENT NOT PREDICATED ON DIVORCE -- It is specifically understood and agreed by and between the parties hereto and each of thc said parties docs hereby warrant and represent to thc other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecntion or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, may, or shall he instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenamed and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and aH ix~sible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole or in part. I-Iushand and wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever by stopped from asserting any illegality or unenforceability as to all or any part of this Agreement. Initials ~..~,~_ ,~ B. ENTRY ~ PP~RT OF DECREE - It is the intention of the parties that the Agreement shall survive any action for divorce which may he iustimted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall he incorporated for the purpose of enforcement only. C. MIJTUAL CONSENT DIVORCE - The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section 3301(c). Accordingly, both parties agn~e to forthwith execute such consents, affidavits, or other docmnents as may he necessary to promptly proceed to obtain a divorce purmant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent permitted by law and the applicable Rules of Civil Procedure, the named Defendant in such divorce action .qhall execute any waivers of notice or other waivers necessa~ to expedite such divorce. 7. DIVISION OF PERSONAL PROPERTY Wife agrees that all of the property in the possession of Husband as of June 1, 2001, shall be the sole and separate property of Husband and Husband agrees that all of the property in the possession of Wife as of June 1, 2001, sh~ll be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. 8. VEHICLES Husband and wife agree that each shall retain the automobile currently titled in their name. Wife agrees that she will take the necessary steps to remove her name from the Jeep Cherokee~ which shall he the sole property of husband. 9. LIABILITIES Husband and Wife agree all of the marital debt has been divided as of the date of separation. 10. AFTER-ACQUIRED PERSONAL PROPERTY Each of the parties shah hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her ;fflet June 1, 2001, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 11. DISPOSITION OF PROPERTY From and after the date of the signing of this Agreement, both parities shall have complete freedom of disposition as to his/her separate property and any property which is in thc,ir possession or control pursuant to this Agreement and may mortgage, sell, grant, convey or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after nutrriage, and neither Husband nor Wife need join in~ consent to, or acknowledge any deed, mortgage, or other ins~xument of the other pertaining to such disposition of property. 12. PAYMENT OF SPECII~IED OBLIGATIONS The parties agree that the following constitute joint marital obligations, which shah be paid by the following person: Wife - 1. All debts incurred by wife since the parties separation. 2. Any loan on the automobile titled solely in wife's name. B. Husband - 1. All debts incurred by Husband since the parties separation. 13. LEGAL FEES Each parly is responsible for their own legal fees with respect to tiffs matter. 14. ALIMONY Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against thc: other for support, maintenance, alimony pendente lite or alimony. Husband and Wife fro'flier, volnntorily and intelligently, waive and relinquish any right to seek from the other any payment for spousal support, maintenance, alimony pendente lite or alimony. 15. PENSION PROGRAM 3 Each party hereto shall maintain sole ownership over his or her individuai pension plan, profit sharing or and any other additional benefits he may have accrued. Husband hereby releases any interest that he has in the retirement benefits of W/fe accumulated as the result of her employment mid any other additional benefits she may have accrued. This wa/ver/s a full and complete discharge of each parties~' marital claim. 16. MISCELLANEOUS All assets including, but not limited to, savings accounts, checking accounts, certificates of deposit and life insurance policies shall be the sole and separate property of the title holder of said asset. The parties believe and agree, that the division of property hereto made by this Agreement is a non- taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. 17. GENERAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS - Each party represents that tl~ have not heretofore incurred or contracted for any debt or liability or obligation for Which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold thc other patty harmless from and against any and ail such debts, liabilities, or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for thc obligations arising out of this Agrecmeut. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at ail times hereafter save harmless and kccp the other after the execution date of this Agrecmcut, except as may be otherwise spccificaily provided for by the terms of this Agreement and that neither of tlaem shall hereafter incur any liability whatsoever for which the estate of the other may be liable. C. SEVERABILITY - ffany term, condition, clause, or prowision of this Agreement shall be determined or declared to be void or invaiid in law or otherwise, then only that term, condition, clansc, or provision shall he stricken from this A~een/cnt anti in all other respects this Agreement shall be vaiid and continue in full force, effect, and operation. Likewise, the failure of any parly to mcct his or her obligations under any one or more of thc paragraphs herein, with thc cx tion of thc satisfaction of the cond/tions receden shall in ' . . cep p t, no way void or alter the remmnmg obligations of the part/es. D. OTHER i)OCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written ass/gnments, releases, satisfactions, deeds, notes or such other writings as may be necessary or des/rable for the proper effectuation of th/s agreement, and as their respect/ye counsel shall mutually agree should be so executed/n order to carry out fully and effectively the terms of this Agreement. E. ENTIRE AGREEMENT - Th/s Agreement conUdns the entire understanding of thc par/ties, and there are no representations, warramies, convenants, or undertakings other than those expressly set forth herein. F. WAIVER OR MOI)HrlCATION TO BI: IN WRITING - No modification or wa/vet of any of the terms hereof Shall be vaiid unless in writing and signed by both parties ami no wa/ver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. G. MUTUAL COOPERATION - Each party shall, at any time and from to time to t/me hereafter, take any an 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 mqu/re for the purpose of giving full force and effect to the prov/sions of this Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. I. BINDING EIq~CT - Except as otherwise stated herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, execntors, administrators, successors, and assigns. J. NO WAIVER OR DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The thilure of either party to insist upon strict perfornmnce of any of the provisions of this Agreement shall in no way afli~-t the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiv~ of strict petrol, of any other obligations herein. K. HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted sc,lely for convenience or referenced and shall not constitute a part of this Agreement nor shall they affect its meaning, construction, or effect. L. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein otherwise provide, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or here~er acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, incl]gling, Imtials.A without limitation, dower, curtesy, their statutory equivalents, widow's allowan~, homestead rights, right to take in intestacy, right to take a~in~q the will of other, and right to act as administrator or executor of the others estate, and each party will, at the request of the other, execute, acknowledge, and deliver any and all instrumems which may be uece~ry or advisable to carry into effect this mutual waiver and relinquishment of all such interests, ri~ht~ and claims, v M. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that either party breaches any provision of this Agreement, and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay for all reasonable attorney's fees, court costs, and expenses incurred by the other party in enforcing the Agreement. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the__ day of ,2002. In the presence of f~IE BRICKER ALAN BRICKER JUUE BRICKER, ALAN BRICKER, Plaintiff Defendant IN THE COUR~r OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-t848 CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REGIUEST ENTRY OF A DIVORCE DECREE UNDER_ SECTION 3~'~._01(C~ OF THE DIVORCE Date:/':?_/Z ~/~2--- 1. I consent to entry of a final decree of divorce witl~out notice. 2. I understand that I may lose dghts concerning aliimony, 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 a decree will be sent to me immediately after it is filed with the Prothonotary. I vedfy 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.A.Section 4904 relating to unswom falsification to authorities. Alan Bficker, De-irendant JUME BRICKER, ALAN BRICKER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2002-1848 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (C) of the Divorce Code was filed on or about February 1, 2002. The marriage of Plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing an service of the Complaint. 3. I consent to the entry of a final decree of divorce. I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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.A. Section 4904 relating to unswom fa lsificatiOnDate:/~ ~/~,.~t° authorities. Alan Bricker, Defendant JUUE BRICKER, ALAN BRICKER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA :NO: l t]> .' .- : CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about April 8, 2002. 2. The mardage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. ! consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. ! 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.A. Section 4904 relating to unswom falsification to authorities. Date: ~ i ~ ! 03 Julj~ Bdcker, Plaintiff :i JUME BRICKER, ALAN BRICKER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TOREQUES? ENTRY OF A DIVORCE DECREE UND=~R SECTION 3301(C) OF THE DIVORCE COO~_ 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 a 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.A.Section 4904 relating to unswom falsification to authorities. Ju~' Bdcker, Plaintiff JULIE BRI, CKER, ALAN BRICKER, Plaintif~ Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNT~, PENNSYLVANIA .- : NO. 02-1848 ., : : CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Tran~nit the record, together with the following information, to the Court for entry of a divorce decree: '~; 1. Ground.l=or divorce: irretrievable breakdown under Section (x) 3301 C ( ) 3301 D of the Divorce Code. (Check 'applicable code) 2. Date and manner of service of the complaint: Certified Mail on 5-07-02. Certificate of Service si,qned and filed. · .3. (Complete.either paragraph (A) or (B)-) ..... (,~). ?~ Date of execution of th~ a-~davit of consent requi~ed by SectiOn 3301 (C) of the divorce -* bod~: By plaintiff 03-05.03; by defendant 12-25~02. . (~) (1),~Date of execution of the plaintiff's affidavit required by SeCtion 3301 (D) of the Divorce COde: N/A; " ~* (~ Date of filing and service of the plaintiff's affidavit upon ~h~ respondent N/A. 4. 'Related clai~ pending: None, * ' 5. (Complete either (a) or (b).) - - (A) Date and manner of service of the notice of intention to file praecipe to transmit record, a ,copy of which is attached: (B) Date plainti~s Waiver of Notice in § 3301 (c) Divorce was filec~ with the Prothonotary: March 7, 2003. Date defendant's Waiver of Notice in § 3301 (c) Divorce filed With the Prothonotary:.,___ January 8, 2003. Attorney I~ierYtifi~r ~EnS~l~ior. e58851 3805 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS Julie OF CUMBERLAND COUNTY STATE OF ..~. PENNA. Bricker Plaintiff VERSUS Defendant Alan Bricker NO. 2002-1848 DECREE IN ~!.~DIVORCE _ AND NOW, , , It S ORDERED DECREED THAT ]~ PLAINTIFF, AND .~.!~_...'''. n_rickcr , IDEFENDANT, 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; Separation Agreement and Property settlement da' 18, 2002, shall be incorporated into, but shall~not this decree. :ed December merge with