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: IN THE COURT OF COMMON PLEAS :
8 OF CUMBERLAND COUNTY 8
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: STATE OF * PENNA. !
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HJ)EBORAH L .RElFRICH,
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DECREE IN
DIVORCE
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AN 0 NOW, ' .. .. , .. ..1,'l:?P.<:~.. ..~ ? ~ .. .., 19..~~... it is ordered and
decreed that ,.""" .JP.1i~ , ~~,I.I~l.m:H , , , , , , , , , , , , , , , , , , . , . . . . " plaintiff,
and, .. .. .. .. ,DEBORAH ,L. ..REIPRl:Cb.. , , .. .. .. .. , .. ...., .. .., defendant,
are divorced from the bonds of matrimony. The tenns of the Marriage
Settlemmt AgreelOOnt entered into by the parties on December 16, 1994, are
inco~1;ated herein,
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;
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HARRIAOB SBT'I'Y.RllRNT AGUBMBNT
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THIS AGREEMENT is made and entered into between John Reiprich
and Deborah L. Reiprich, hereinafter referred to as Husband and
Wife. The parties were married on March 28, 1981, and there are
two children born or adopted of their marriage, to wit, Andrew
Reiprich, born February 1, 1987, and Joseph Reiprich, born March
26, 1989.
As a consequence of disputes and unhappy differences, the
parties have separated.
The parties desire to confirm their
separation and make arrangements in connection therewith, including
the settlement of their property rights, custody, support, and all
other rights and obligations arising out of the marriage
relationship.
It is therefore agreed:
1. CONSIDERATION
The consideration for this Agreement is the mutual promises
and agreements herein contained.
2. SEPARATION AND NONINTERFERENCE
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 deem fit.
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B. Each party shall be free from interference, authority and
control, 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, rights, or demands whatsoever,
in law or equity, which either of the parties ever had or now has
against the other, except any or all cause or causes of action for
divorce.
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. Husband and Wife each represent and
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warrant to the other that he or she has msde a full and complete
disclosure to the other of all assets of any nature whatsoever in
which such party has an interest, of the sources and amount of the
income of such party of every type whatsoever, and of all other
facts relating to the subject matter of this Agreement. Husband
represents that he was represented by Kathleen Carey Daley,
Esquire, in reaching this Agreement. Wife acknowledges that she has
the right to counsel but has declined to retain counsel.
5. EOUITABLE 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. SUBSEOUENT DIVORCE
A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically
understood and agreed by and between the parties hereto and each of
the said parties does hereby warrant and represent to the 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-prosecution or non-defense of
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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, either absolute or otherwise, upon just, legal
and proper grounds; nor to prevent either party from defending any
such action which has been, mayor shall be instituted by the other
party, or from making any just or proper defense thereto. It is
warranted, covenanted 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 waives
any and all possible claims that this Agreement is, for any reason,
illegal or for any reason whatsoever, unenforceable in whole or in
part. Husband and Wife each do hereby warrant, covenant and agree
that, in any possible event, he and she are and shall forever be
estopped from asserting any illegality or unenforceability as to
all or any part of this Agreement.
B. ENTRY AS PART OF DECREE - It is the intention of the
parties that the Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order,
jUdgment or decree of divorce, temporary, final or permanent, shall
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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 be incorporated
for the purposes of enforcement only.
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C. MUTUAL CONSENT DIVORCE
The parties agree and
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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
330l (c). Accordingly, both parties agree to forthwith execute such
consents, affidavits, or other documents and to direct their
respective attorneys to forthwith file such consents, affidavits,
or other documents as may be necessary to promptly proceed to
obtain a divorce pursuant to said 23 Pa.C.S.A. Section 330l(c).
Upon request, to the extent permitted by law and the applicable
Rules of Civil Procedure, the named defendant in such divorce
action shall execute any waivers of notice or other waivers
necessary to expedite such divorce.
7. DIVISION OF PERSONAL PROPERTY
Husband and Wife have agreed to the division of personal
property as set forth on Exhibit "A".
The parties do hereby
specifically waive, release, renounce and forever abandon whatever
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claims, if any, he or she may have with respect to the listed items
which shall become the sole and separate property of the other.
8. DIVISION OF MOTOR VEHICLES
with respect to the motor vehicles owned by one or both of the
parties, they agree as follows:
The 1976 Cadillac Sedan de Ville and the Kenworth tractor
shall be the sole and separate property of Husband.
The Chevrolet Suburban and the Mercury shall be the sole and
separate property of wife.
The titles to the said motor vehicles shall be executed by the
parties, if appropriate, for effectuating transfer as herein
provided, on the date of execution of this Agreement or at any time
thereafter at the request of either party.
9. DISPOSITION OF PROPERTY
From and after the date of the signing of this Agreement, both
parties shall have complete freedom of disposition as to his/her
separate property and any property which is in their possession or
control pursuant to this Agreement and may mortgage, sell, grant,
conveyor otherwise encumber or dispose of such property, whether
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real or personal, whether such property was acquired before, during
or after marriage, and neither Husband nor Wife need join in,
consent to, or acknowledge any deed, mortgage, or other instrument
of the other pertaining to such disposition of property.
10. DIVISION OF REAL PROPERTY
Husband and Wife hereby agree and acknowledge that they own
certain real property located at 410 North l6th street, New
Cumberland, Cumberland County, Pennsylvania, as tenants by the
entireties.
Wife hereby agrees to convey all her right, title and interest
in said property to Husband. Wife agrees to execute a deed or
other instrument of conveyancing necessary to effectuate this
transfer at the time of the execution of this document. Husband
agrees to pay to Wife the sum of $lO,OOO.OO in satisfaction of her
claim to these premises. This payment shall be made as follows:
$3,700.00 shall be paid at the time Wife vacates the marital
residence and delivers to Husband a deed to these premises;
$6,300.00 shall be paid to Wife by Husband seven (7) months from
the date of this Agreement. Husband agrees to execute a judgment
note in the amount of $6,300.00 for which the premises shall serve
as security.
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The parties acknowledge that there are two existing mortgages
against this property. The first mortgage is held by Knutzson
Mortgage in the amount of approximately $46,000.00. The second
mortgage is held by Transamerica in the amount of approximately
$23,000.00. Husband agrees to obtain financing such that he shall
either satisfy said mortgages in total through a refinancing effort
to satisfy Wife's obligation under these mortgages. Husband shall
take immediate efforts to obtain this financing and shall satisfy
these mortgages within one year of the date of this Agreement. In
the event that Husband is unable to satisfy these mortgages under
these conditions, he agrees to place the subject real property for
sale. Husband shall hold Wife harmless and indemnify her from
liability for these obligations and other obligations arising from
this property.
ll. PAYMENT OF SPECIFIED OBLIGATIONS
The parties agree that the following constitute joint marital
obligations which shall be paid by the following person:
A. WIFE - All credit account balances in Wife's name
acquired after the signing of this Agreement.
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B. HUSBAND - Primary mortgage on principal residence held by
Knutzson Mortgage; Home equity line of credit held by TransAmerica;
ITT Account; Montgomery Ward Account; Terminex International,
Water, children's past due tuition; and all outstanding credit
account balances in Wife's name as of the date of this Agreement,
includingCitibank Visa, Citibank Preferred, JC Penney, and Fashion
Bug;
l2. LEGAL FEES
Each party shall pay his or her own attorneys fees.
l3. 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 the other for support, maintenance, alimony pendente lite
or alimony. Husband and Wife further, voluntarily and
intelligently, waive and relinquish any right to seek from the
other any payment for support, maintenance, alimony pendente lite
or alimony. The claim for child support is not terminated by this
provision.
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l4. PENSION PROGRAM
Bach party hereto shall maintain sole ownership over his or
her individual pension plan, profit sharing or similar retirement
plan acquired individually or as the result of contributions by his
or her employer. Wife hereby releases any interest that she has in
the retirement benefits of Husband accumulated as the result of his
employment and any other additional benefits he may have accrued.
Husband hereby releases any interest that he has in the retirement
benefits of Wife accumulated as the result of her employment and
any other additional benefits she may have accrued. This waiver is
a full and complete discharge of each parties' marital claim.
15. MISCELLANEOUS
All assets including, but not limited to, savings accounts,
checking accounts, and life insurance policies shall be the sole
and separate property of the title holder of said asset.
The parties believe and agree, and have been so advised by
their respective attorneys, that the division of property
heretofore made by this Agreement is a non-taxable division of
property between co-owners rather than a taxable sale or exchange
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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.
The parties have heretofore filed joint federal and state tax
returns. Both parties agree that in the event any deficiency in
federal, state or local income tax is proposed, or any assessment
of any such tax is made against either of them, each will indemnify
and hold harmless the other from and against any loss or liability
for any such tax deficiency or assessment and any interest, penalty
and expense incurred in connection therewith. Such tax, interest,
penalty or expense shall be paid solely and entirely by the
individual who is finally determined to be the cause of the
misrepresentations or failures to disclose the nature and extent of
his or her separate income on the aforesaid joint returns.
l6. CHILDREN
A. CUSTODY AND VISITATION - The parties shall share \egal
and physical custody of the children born or adopted of this
marriage. The children shall reside with their mother. Wife shall
provide Husband with information concerning their health, education
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and welfare on a regular basis and shall encourage Husband to join
in the decision making process as to the children's schooling,
medical care and other important issues associated with their
lives.
Husband shall be afforded liberal periods of partial custody
at times to be agreed by the parties.
B. MAKE-UP TIME - The parties recognize that there may be
circumstances from time to time which may prevent the exercise of
custody at the agreed dates and times. To that end, the parties
agree that each will give timely and reasonable notice to the other
of the existence of such circumstances and will permit the other a
reasonable period in which to enjoy time with the child to make-up
for these lost periods.
C. ILLNESS OF CHILD - In the event of any serious illness of
the child at any time, any party then having custody of the said
child shall immediately communicate with the other party by
telephone or any other means, informing the other party of the
nature of the illness. During such illness, each party shall have
the right to visit the child as often as he or she desires,
consistent with the proper medical care of the said child. The
word "illness" as used herein shall mean any disability which
confines the child to bed under the direction of a licensed
physician for a period in excess of forty-eight (48) hours.
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D. BEST INTEREST OF CHILD - The parties shall exert every
reasonable effort to maintain free access and unhampered contact
between the child and each of the parties, and to foster a feeling
of affection between the child and the other party. Neither party
shall do anything which may estrange the child from the other
party, or injure the child's opinion as to his mother or father, or
which may hamper the free and natural development of the child's
love and respect for the other party.
17. CHILD SUPPORT
Child support shall be paid by Husband to Wife at the rate of
$110.00 per week.
Wife shall be entitled to claim Andrew Reiprich and Joseph
. Reiprich as her dependent on her tax return for 1994.
18. HEALTH INSURANCE - CHILDREN
Wife agrees to provide health insurance for the children for
so long as it is available to her at no or minimal cost by her
employer. If said insurance becomes unavailable to Wife and
Husband has entitlement to insurance which can be provided to him
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at no or minimal cost, said insurance will be furnished by Husband.
In the event that neither Husband nor Wife have insurance furnished
to them by their employer, at no or minimal cost, then the cost of
insurance shall be borne such that fifty percent (50\) shall be
allocated to Husband and fifty percent (50\) shall be allocated to
Wife.
19. MISCELLANEOUS PROVISIONS - CHILDREN
A. College - Husband and Wife agree to participate equally
in the payment of undergraduate or equivalent higher educational
expenses for the children.
B.
Extraordinary Medical Expenses
All extraordinary
medical expenses (those not covered by insurance) shall be split
equally by Husband and Wife. Husband agrees to reimburse these
expenses to Wife on a quarterly basis upon Wife supplying to
Husband proof of said expenses.
C. Estates - Husband and Wife both agree and acknowledge
that they have financial responsibility towards the support of
their minor children. In considering that obligation, Husband and
Wife agree as follows:
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1. Husband aqrees to provide $25,000.00 worth of
life insurance made payable at his death for the benefit
of his minor children. This benefit shall be made
payable in such a way that income and principle may be
used for the support of the children throuqh their
minority and shall be distributed to them at their
majority or at a later date, as determined in the sole
discretion of Husband.
Wife aqrees to provide $l5, 000.00 worth of life
insurance made payable at her death for the benefit of
her minor children. This benefit shall be made payable
in such a way that income and principle may be used for
the support of the children throuqh their minority and
shall be distributed to them at their majority or at a
later date, as determined in the sole discretion of Wife.
20. GENERAL PROVISIONS
A. WARRANTY AS TO EXISTING OBLIGATIONS Each party
represents that they have not heretofore incurred or contracted for
any debt or liability or obliqation for which the estate of the
other party may be responsible or liable except as may be provided
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for in this Agreement. Each party agrees to indemnify or hold the
other party harmless from and against any and all such debts,
liabilities, or obligations of every kind which may have heretofore
been incurred by them, including those for necessities, except for
the obligations arising out of this Agreement.
B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each
covenant, warrant, represent, and agree that each will now and at
all times hereafter save harmless and keep the other indemnified
from all debts, charges, and liabilities incurred by the other
after the execution date of this Agreement, except as may be
otherwise specifically provided for by the terms of this Agreement
and that neither of them shall hereafter incur any liability
whatsoever for which the estate of the other may be liable.
c.
SEVERABILITY
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. Likewise, the
failure of any party to meet his or her obligations under anyone
or more of the paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way void or
alter the remaining obligations of the parties.
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D. OTHER DOCUMENTATION - Wife and Husband covenant and agree
that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement, and as their respective counsel
shall mutually agree should be so executed in order to carry out
fully and effectively the terms of this Agreement.
E. 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.
F. WAIVER OR MODIFICATION TO BE IN WRITING - No modification
or waiver of any of the terms hereof shall be valid unless in
writing and signed by both parties and no waiver 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 time to time hereafter, take any and 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
require for the purpose of giving full force and effect to the
provisions of this Agreement.
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H. LAW GOVERNING - This Agreement shall be construed and
governed in accordance with the laws of the Commonwealth of
Pennsylvania.
I. BINDING EFFECT - Except as otherwise stated herein, this
Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors,
administrators, successors, and assigns.
J. NO WAIVER OF DEFAULT - This Agreement shall remain in
full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect 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 waiver of strict performance 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 solely for convenience or reference and shall not
constitute a part of this Agreement nor shall they affect its
meaning, construction, or effect.
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L. ADDRESS OF PARTIES - Each party shall at all times keep
the other informed of his or her place of residence, and shall
promptly notify the other of any change, giving the address of the
new place of residence.
M. 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
all rights he or she may have or hereafter 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, including, without limitation, dower,
curtesy, their statutory equivalents, widow's allowance, homestead
rights, right to take in intestacy, right to take against the will
of other, and right to act as administrator or executor of the
other's estate, and each party 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 interests, rights and claims.
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ATTORNEY'S FEES FOR ENFORCEMENT - In the event that
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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
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all reasonable attorneys' 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 \'J.cQ/w\L..v\ , 1994, at Harrisburg, Pennsylvania.
In the presence of:
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JOHN REIPRICH,
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS
JlOOOOIXJtXu>>mmJpa>X'lCllDq~
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-l787 CIVIL TERM
DEBORAH L. REIPRICH,
Defendant
CIVIL ACTION _ LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the followina
information, to the Court for entry of a divorce decree:
l. Ground for divorce: irretrievable breakdown
3301(c)
under Section (X) ~ ( 20l (d) (1) of the Divorce
Code. (Check
applicable section) .
2. Date and manner of service of the complaint:
04-l4-94: certified mail, restricted delivery .
3. (Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit 6f consent
3301(c)
required by, Section ~ of the Divorce Code: by
plaintiff
February 28, 1996
: by defendant
February 28, 1996
(b) (l) Date of execution of the plaintiff's
affidavit required by Section 20l (d) of the Divorce Code:
: (2) date of service of the P]Hintlff'H
affidavit upon the Defendant:
4. Related claims pending:
None
). Date anrl manner of !'cr\'icc of the nUlic,' of i"l~'"li,,"
to file praecipe to lL',lflSlnil n~..urrl. a <':l,lI'Y ur I,hilh j.. :illih.h.'.r
Waivers were signed February 28, lQQ~
,l')THON ..,
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LAW OFFICES
1029 SCENmy Of/IV!: .
HARr<lSBURG. PENNSYLVANIA 17109
(717) 657-4795
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IN THB COURT OF COMMON PLEAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
CIVIL ACTION - LAW
NO. q'-J- 1787 CIY;/ hr(Y\
JOHN REIPRICH,
Plaintiff
DBBORAH L. REIPRICH,
Defendant
IN DIVORCE
HOTICB TO DBPBND AND CLAIM RIGHTS
YOU HAVE BEBN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the 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 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPBRTY,
LAWYER'S FBES, OR EXPENSES BEFORE A DIVORCB OR ANNULMENT IS
GRANTBD, YOU MAY LOSB THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPBR TO YOUR LAWYER AT ONCB. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SBT FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA l70l3
(717) 240-6200
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Le han demandado a usted en la corte. 8i usted quiere
defenderse de estas demandas expuestas en las paqinas siquientes,
usted tiene viente (20) dias de plazo al partir de 1a fecha de la
demanda y la notificacion. Usted debe presentar una apariencia
escrita 0 en persona 0 por aboqado y archivar en la corte en
forma escrita sus defensas 0 sus objeciones alas demandas en
contra de su persona. Sea avisado que si usted no se defiende, la
corte tomara medidas y puede entrar una orden contra usted sin
previo aviso 0 notificacion y por cualquier queja 0 alivio que es
pedido en la peticion do demanda. Usted puede perder dinero 0 sus
propiedades 0 otros derechos importanates para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONOE SE PUEOE CONSEGUIR
ASISTENCIA LEGAL.
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA l70l3
(717) 240-6200
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JOHN RBIPRICH, I IN THE COURT OF COMMON PLEAS
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I CIVIL ACTION - LAW
v. I
I NO.
DEBORAH L. REIPRICH, .
.
Defendant . IN DIVORCE
.
COMPlAINT IN DIVORCB
COUNT I
DIVORCB
AND NOW comes the above Plaintiff, John Reiprich, by his
attorney, Kathleen Carey Daley, Attorney at Law, and seeks to
obtain a decree in divorce from the above-named Defendant, upon the
grounds hereinafter set forth:
1. The Plaintiff, John Reiprich, is an adult individual who
resides at 3ll Sharon Drive, New Cumberland, Cumberland County,
Pennsylvania 17070.
2. The Defendant, Deborah L. Reiprich, is an adult individual
who resides at 410 l6th Street, New Cumberland, Cumberland County,
Pennsylvania l7070.
3. The Plaintiff and Defendant are sui juris, and both have
been bona fide residents of the Commonwealth of Pennsylvania for a
period of more than six months immediately preceding the filing of
this Complaint.
4. The Plaintiff and Defendant were married on March 28, 1981
in Camp Hill, Pennsylvania.
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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. The cause(s) of action and section(s) of Divorce Code
under which Plaintiff is proceeding are:
A. Section 330l(c). The marriage of the parties
is irretrievably broken. 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 Defendant may also file
such an Affidavit.
B. Section 330l(d). The marriage of the parties
is irretrievably broken. The Plaintiff and Defendant
separated on February l8,. 1994.
7. There have been no prior actions in divorce between the
parties.
8. Plaintiff has been advised of the availability of
counseling and that Plaintiff may have the right to request the
parties to participate in counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a
Decree in Divorce, divorcing Plaintiff and Defendant.
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COUNT II
EQUITABLE DISTRIBUTION
9. Paragraphs 1 through 4 of this Complaint are incorporated
herein by reference as though set forth in full.
10. Plaintiff and Defendant have acquired property, both real
and personal during their marriage from the date of their marriage
until February 18, 1994, the date of their separation.
11. Plaintiff and Defendant have been unable to agree as to an
equitable division of said property.
WHEREFORE,
Plaintiff requests your Honorable Court to
equitably divide all marital property.
I 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 l8 Pa.C.S.A. Section 4904 relating to
unsworn falsification to authorities.
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Date:
4-1J~4
By:
Kath een Carey D
Attorney No. 300
1029 Scenery Drive
Harrisburg, PA l7l09
(717) 657-4795
Attorney for Plaintiff
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JOHN REIPRICH,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
Plaintiff
v.
: NO. 94-1787 CIVIL TERM
DEBORAH L. REIPRICH,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
Kathleen Carey Daley, Esquire, being duly sworn according to law, deposes and says that she
is an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on
the.l4th day of April, 1994, she did serve upon Deborah L, Reiprich, the Defendant in the foregoing
case, a true and correct copy of the Complaint in Divorce by sending to her, by certified mail,
restricted delivery, to 410 16th Street, New Cumberland, Pennsylvania 17070, The receipt for said
Complaint is attached,
Said copy of the Complaint was duly endorsed with notice to Defendant to appear and answer
or the matter would proceed without her,
Sworn to and subscribed before me this
k~aYOf~ll(J^- .1996
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tjOTARIAL SEAl. I
PATRICIA A PATTon tlo~"y PUbl'"
lower Padon Twp D.1uphln Co
M COmmissIon E~\o.!!!~~e 20 1~..
By: L
thleen Carey Daley,
Attorney No, 30078
1029 Scenery Drive
Harrisburg, P A 17109
(717) 657-4795
Attorney for Plaintiff
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1029 SCENERY DRIVE
HARRlSBURG.PENNSYL<.tANIA 17109
(717) 657.4795
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
JOHN REIPRlCH,
v,
: NO, 94-1787 CIVIL TERM
DEBORAH L, REIPRlCH,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 8,
1994.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing of the Complaint.
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3, I consent to the entry ora final decree of divorce after service of notice of intention to
request entry of the decree,
I verifY that the statements made in this Affidavit are true and correct. I understand that false
statements herein are mode subject to the penalties of 18 Pa,C,S.A. ~4904 relating to unsworn
falsification to authorities,
Date: ~ - :1&- 9b
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REIPRICH,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
JOHN REIPRICH,
v.
: NO, 94-1787 CIVIL TERM
DEBORAH L. REIPRICH,
Defendant
: IN DIVORCE
AFFIDA VIT
John Reiprich, Plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised ofthe 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 Domestic
Relations 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 by the Court,
I understand that false statements herein are made subject to the penalties of 18 Pa,C.S,A.
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: CIVIL ACTION - LAW
Plaintiff
v.
DEBORAH L, REIPRICH,
Defendant
: NO. 94-1787 CIVIL TERM
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER V330UC) 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 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. ~4904 relating to unsworn
falsification to authorities,
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO, 94-1787 CIVIL TERM
DEBORAH L. REIPRICH,
Defendant
: IN DIVORCE
AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on AprilS,
1994.
2. The maniage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing of the Complaint.
3, I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree,
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. ~4904 relating to unsworn
falsification to authorities.
Date:
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
Plaintiff
v.
: NO, 94-1787 CIVIL TERM
DEBORAH L. REIPRICH,
Defendant
: IN DIVORCE
AFFIDAVIT
Deborah L, Reiprich, 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 Domestic
Relations 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 by the Court,
I understand that false statements herein are made subject to the penalties of 18 Pa,C,S,A.
~4904 relating to unsworn falsification to authorities,
Date:
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1029 SCENERY DRIVE
HARRISBURG. PENNSYLVANIA 17109
017) 657-4795
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSVLVANIA
: CIVIL ACTION - LAW
: NO, 94-1787 CIVIL TERM
: IN DIVORCE
JOHN REIPRlCH,
v,
DEBORAH L. REIPRlCH,
Defendant
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER ~330IlC' OF TilE DIVORCE CODE
I, 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! 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 med with the Prothonotary.
I verilY 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. fi4904 relating to unsworn
falsification to authorities,
Date:
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