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HomeMy WebLinkAbout02-3104PHYLLIS E. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : 2002-310~ CIVIL TERM : GARY R. JONES, .. Defendant : IN DIVORCE NOTICE 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 in 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 imporW, nt 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, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THI~ RIGHT TO CLAIM ANY OF TUF. M. 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 TI~, OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 PHYLLIS E. JONES, Plaintiff Ye GARY R. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002-3104 CIVIL TERM : : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT .PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND : NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Gary R. Jones, on July 11, 2002, by certified, restricted delivery mail, addressed to him at 11 Garden Drive, Carlisle, Pennsylvania 17013, with Return Receipt Number 7000 1530 0002 4693 5960. hereof. 3. That the said receipt for certified mail is signed and attached hereto and made a part I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalti~ 18 Pa. C. S. Section 4904, relating to Date: July 16, 2002 (~F~/~a/I~2C~oI~E~V ~ONESU S E Postage Certified Fee Ret~ Rece~ Fee Here I~1 I ~ent To ,"lL ~ GARY R JONES ,-'*' ~.~.~.~.,~4~-o~.~- .................................... ' II~m 4 ff ~ Ddl~14~ i (JjlirlN::L 1. Adlole Addmeled to: MR GARY R JONES 11 GARDEN DRIVE CARLISLE PA 17013 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the schaduiad conference or hearing. PHYLLIS E. JONES, Plaintiff GARY IL JONES, Defendsmt IN TI:IE~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2002-.o~/,~CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301¢a}¢6} AND 3301(e) OF Ti~le~ DIVORCE CODE COUNT I AND NOW comes the Plaintiff, Phyllis E. Jones, by her attorneys, Irwin, McKnight & Hughes, Esquires, and files this Complaint in Divorce against the Defendant, Gary R. Jones, upon the cause of action hereinai~er set forth: The name of the Plaintiff is Phyllis E. Jones and the name of the Defendant is Gary R. Jones. The Plaintiff is an adult individual who resides in Cumberland County, Pennsylvania; her current address being 11 Garden Drive, Carlisle, Pennsylvania 17013. The Defendant is an adult individual residing in Cumberland County, Pennsylvania, his current address being 11 Garden Drive, Carlisle, Pennsylvania 17013. 4. The Defendant and Plaintiff have resided in the Commonwealth of Pennsylvania for at least six months previous to the filing of this action in divorce. 5. The Defendant and Plaintiff were married on January 19, 1974 in Carlisle, Cumberland County, Pennsylvania. 6. There were two children born to this marriage; namely, Kelly R. Grant, bom August 24, 1974, age 27 years, and Aaron D. Jones, bom June 21, 1979, age 23 years. 7. Pursuant to the Divorce Code, Section 3301(a)(6), the Plaintiff avers as the grounds upon which this action is based that the Plaintiff is the injured spouse and that the Defendant has offered such indignities to her as to render her condition intolerable and life burdensome. 8. The Plaintiffavers that she has been advised of the availability of couuseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff demands judgment a. Dissolving the marriage between the two patties; b. Equitably dista'ibuting all property, both personal and real, owned by the parties; c. for legal fees and costs; d. for alimony;, and e. for such further relief as your Honorable Court may deem equitable and just. COUNT II The averments of Paragraphs One through Six are incorporated herein by reference as though fully set forth below. 10. Plaintiff avers as the grounds upon which the Action in Divorce is based is that the marriage of the parties is irretrievably broken. 11. The averments of Paragraph Eight are incorporated herein by reference as though fully set forth below. WHEREFORE, the Plaintiff demands judgment a. Dissolving the marriage between the two parties; b. Equitably distributing all property, both personal and real, owned by the parties; c. for legal fees and costs; d. for alimony;, and e. for such fin'ther relief as your Honorable Court may deem equitable and just. Date: June ~,'/% , 2002 Respectfully submitted, IR~~IGHT & HUGgiES BY:~~/~ West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Complaint and they are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. /PHYLLIS E. JdNES Date: June ~7~ ,2002 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this~_'day of May, 2003 by and between PHYLLIS E. JONES, (hereinafter referred to as "WIFE") and GARY R..JONES, hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on January 19, 1974, in Carlisle, Cumberland County, Pennsylvania. WIFE filed a Complaint in Divorce in Cumberland County, Pennsylvania, docketed at 2002-3104 Civil Term on June 28, 2002. The parties hereto agree and covenant as follows: The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. The parties have attempted to divide their matrimoniai property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. Further, the parties agree to continue living separately and apart fi.om the other at any place or places that he or she may select as they have heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. The consideration for this contract and agreement is the. mutual benefit to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: a. is represented by counsel of his or her own choosing; b. is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities of the parties; c. enters into this Agreement voluntarily after receiving advice of counsel; d. has given careful and mature thought to the making of this Agreement; e. has carefully read each provision of this Agreement; and f. fully and completely understands each provision of this Agreement, both as to the subject matter and legal cftc. ct. This Agreement shall become effective immediately as of the date of execution. It is the purpose and intent of this Agreement to settle tbrever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualify as marital property under the Pennsylvania Divome Code, Title 23, Section 401(e), and that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the rights of each Party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a pm of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divome Code relating to spousal suppo~r or alimony. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may becorne liable. Each further represents and warrants that he or she has not made any girls or transfem for inadequate consideration of Marital Property without the prior consent of the other. Each Party acknowledges that, to the extent desired, he ,ar she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marriage. REAL ESTATE: The parties own the property known as 11 Garden Drive, Carlisle, Pennsylvania 17013. HUSBAND agrees to convey his right, title and interest in the property to WIFE. WIFE agrees to refinance the mortgage and home equity mortgage into her own name and pay HUSBAND the sum of Twenty Two Thousand and no/100 ($22,000.00) Dollars. DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely responsible for her debts. HUSBAND will indemnify and hold harmless WIFE from all obligation related to his debts. WIFE will be solely responsible and will indemnify and hold harmless HUSBAND fzom any claim made against him related to her debts. The parties agree to pay offdebts as listed below: A. WIFE agrees to pay offdebts totaling the amount of $58,163.50 as follows: 1. PNC mortgages; 2. PNC home equity line of credit; 3. Charter One loan; 4. Bank of America credit card; and 5. Bon Ton credit card. B. HUSBAND agrees to pay offdebts totaling the amount of $40,000.00 as follows: 2. 3. 4. 5. Capital One credit card; First National credit card; PNC credit card; Bon Ton credit card; and Circuit City credit card. 4 SPOUSAL SUPPORT: The parties hereby agree to waive any spousal support, alimony pendente lite and alimony. 10. PERSONAL PROPERTY: The parties agree that the personal property shall be divided as follows: HUSBAND shall receive the following items: a. The personal property in his possession; b. His bank accounts; c. Any life insurance policy; d. His employee benefits; and e. The sum of Twenty Two Thousand and no/100 ($22,000.00) Dollars. WIFE shall receive the following items: a. The personal property in her current possession; b. Her bank accounts; c. Any life insurance policy; d. Her employee benefits; and e. The real estate at 11 Garden Drive, Carlisle, PA 17013, which is appraised at $160,000.00. The WIFE will retain possession of the computer, computer printer, television and VCR, and WIFE will compensate the HUSBAND a total of $1,000.00 for these items. The WIFE hereby waives all right and title which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. Each party agrees that neither will incur obligation:s, liens or liabilities on account of the other and that from the date of this Agreement, neither party shall contract or incur obligations, liens or any liability whatsoever on account of the other. AUTOMOBILES: 11. a. HUSBAND agrees to waive any and all interest which he may have in the automobiles in possession of the WIFE. b. WIFE agrees to waive any and all interest which she may have in the automobiles in possession of' the HUSBAND. They each waive any claim which they have in any automobile owned by the other party. 12. INSURANCE~ EMPLOYEE AND MILITARY BENEFITS: The parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including but not limited to retirement, profit sharing or medical benefits of either pasty, shall be their own. WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND waives all right, title, and claim to any of WIFE'S employee benefits. 13. BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all fight, title and interest which she may have in the savings or checking or any other bank accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of the WIFE. 14. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 15. BREACH: If either party breaches any provisions of this Agreement, the other party should have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the p~rty breaching this contract will be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force ~uad effect to the provisions of this Agreement. 7 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. The provisions of this Agreement are fully understood by both parties 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. 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. APPLICABLE LAW: Commonwealth of Pennsylvania. 19. This Agreement shall be construed under the Laws of the 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 21. PAYMENT OF COSTS AND LEGAL FF.i*.g: The p;mies agree to pay for their own costs and legal fees required to obtain and complete the divorce. 8 22. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and ail rights he or she may now have or hereafter acquire, under the presem or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, cotwlesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such inl~erests, rights and claims. IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written. / ~HYLLIS E. JC~ES ~~AR~~ (SEAL) 9 PHYLLIS E. JONES, Plaintiff GARY R. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : 2002-3104 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 28, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed fi:om the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. Date: ~, 2003 PHYLLIS E. JONES, Plaintiff GARY R. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2002 -:3104 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION 'FO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the ent~ of a final Decree of Divorce without notice. 2. I understand that I may lose r/ghts concerning alimony, division of propen'y, lawyer's fees or expenses ifI 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 at~er 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: ~ ,, 2003 PHYLLIS E. JONES, Plaintiff Ve GARY R. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2002-3104 CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSEl,lNG AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Pmthonotaffs Office, which list is available to me upon request. 3. Being so advised, I do not request that the corm require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~, 2003 PHYLLIS E. JONES, Plaintiff GARY R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2002,3104 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) oft_he Divorce Code was filed on June 28, 2002. 2. The marriage of plaintiff and defendant is irretriew~bly broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose fights 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 made are subject to the penalties of 18 ]?a. C. S. Section 4904 relating to unswom falsification to authorities. GARY R. JONES PHYLLIS E. JONES, Plaintiff GARY R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2002-3104 CIVIL TERM 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 divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediataly after it is filed with the Prothonotary. I verify that the statements made in this affidavit are trae and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: ~3~w.~ ~.~ ,2003 G.M~,Y~[~. JONES Defendant PHYLLIS E. JONES, Plaintiff GARY R. JONES, Defendant : IN THE COUiRT OF COMMON PLEAS OF ._ : CUMBERLAND COUNTY, PENNSYLVANIA _. CIVIL ACTION - LAW 2002 3104 CIVIL TERM _. IN DIVORCE DEFENDANT'S MARRIAGE COUNSEl JNG AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ,2003 R. JONES INThE CouRT OF COMIVION PLEAS OF CUMBERLAND COUNTY _~~,~ ~, PENNA. STATE OF PHYLLIS E. JONES~ Plaintiff VERSUS GARY R. JONES, Defendant NO. 2002-3104 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DECREE 1N DIVORCE AND NOW._ .3.,._%~.?p_' ~ 2003 DECREED THAT PHYLLIS E. JONES aND GARY R. JONES ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, __, DEFENDANT, 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 Marriage Settlement Agreement dated May 29, 2003 and signed by the parties is hereby incorporated into this Agreement, but not merged. BY THE COURT: ATTEST PHYLLIS E. JONES, Plaintiff Vo GARY R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002-3104 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORd)_ To the Prothonotary: Transmit the record, together with the following information, to the: court for entry ora divorce decree: 1. Ground for Divorce: Irreh%vable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Gary R. Jones, on July 11, 2002, by certified, restricted delivery mail, addressed to him at 11 Garden Drive, ' · Carhsle, Pennsylvama 17013, with Return Receipt Number 7000 1530 0002 4693 5960. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff.- May29,2003; by defendant: May29, 2003. Co)(l) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavi'I upon the defendant: 4. Related cia/ms pending: NONE. 5. Complete either (a) or (b). (a) Date and manner of service of thc Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: May 30, 2003. of Notice in Section 3 (c) DivorceA~as filed with the Prothonotary: May 30, 2003. ~ MARCU[; &. MeKNI~ui~ Attorney for PlaIn~.~,)