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: STATE OF ~_ PENNA. :
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N (). ..9.4:::.2;1.,;1...11... ..C.X.v..U. 1994
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. LARRY . DAVID.. KUHNS,
Plaintiff
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..F.AYE. .A.KUH~S'H"
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Defendant
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DECREE IN
DIVORCE
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AND NOW, oo , oo . oo ooJ!~'r'h.,I?~oo oo ..?'i.~, 19. r.%'oo. it is ordered and
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decreed that . .~~l{ .J??'>.~~J? ~.l!~l;l;;...................,....".. plaintiff,
and.. oof1\.Y.F4 '~"oolS1,1tlN~.oo....oo.oo...oo.oooo.oo..oooo.oo.oo. defendant,
are divorced from the bonds of matrimony.
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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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covenants set ~orth n the wr~tten Property Sett ement Agreement
. J)\1l.c\~ . <l11.c\ .li!Il~.~J;ed. .int9. .!:ly. the: . PIl.r.ties. .QI), N.Q1(li!U1P.~J; , 41;2". .19.9,~ ,are.
incorporated into this Decree by reference thereto, but not merged ~
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LARRY DAVID KUHNS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2118 Civil Term
vs.
FAYE A. KUHNS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this J;:; rnJ... day of nOlWr,1 ~ , 1994,
by and between LARRY D. KUHNS, of Mechanicsburg, Cumberland
County, Pennsylvania (hereinafter referred to as "Husband"), and
FAYE A. KUHNS, of Harrisburg, Dauphin County, Pennsylvania,
(hereinafter referred to as "Wife").
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on October
31, 1987 in Summerville, South Carolina; and
WHEREAS, no children have been born of this marriage; and
WHEREAS, diverse differences and difficulties have arisen
between the parties respecting their interests, rights and title
in and to certain property, real and/or personal, owned by or in
possession of the said parties to either of them; and
WHEREAS, Husband and Wife desire to settle and determine
their rights and obligations and to amicably adjust, compromise
and forever settle all property rights and all rights in, to or
against each other's property or estate of any kind or nature
whatsoever, including property heretofore or subsequently
MEYERS. DESFOR
410NORTH SECOND STREET . POBOX 1062 . HARRISBURG. PA.l7l06
11171238-942B . FAX 17111 238-2B17
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acquired by either party and to settle all disputes existing
between them, including any and all claims for Wife's and/or
Husband's rights to equitable distribution, maintenance and/or
support, alimony, counsel fees and costs; and
WHEREAS, the parties acknowledge and agree that in entering
into this Agreement, including foregoing waivers, they are each
relying on truth and completeness in all material respects as to
all information provided by the other party hereto regarding the
assets of such person.
NOW THEREFORE, in consideration of the mutual promises,
covenants and agreements hereinafter contained, each of the
parties hereto intending to be legally bound hereby promises,
covenants and agrees as follows:
1. DIVORCE: The parties have been living separate and
apart for more than two years and do agree that their marriage is
irretrievably broken and that they mutually consent to a divorce
and agree and have executed all necessary Affidavits required by
the court for the entry of a mutual consent divorce. Both
Husband and Wife have executed said Affidavits of Consent and
will be filing said Affidavits with the Court in requesting a
Decree in Divorce from the bonds of matrimony under Section
3301(c) of the Divorce Code.
2
MEYERS" DE8fOR
410 NORTH SECONO STREET . P. O. BOX 1062 . HARRISBURG. PA 17108
17171238-942B . FAX 17171 238-2B17
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4.
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2. INTERFERENCE: Each party shall be free from
interference, authority, and contact by the other, as fully as if
he or she were single and unmarried except as may be necessary to
carry out the provisions of this Agreement. Neither party shall
molest the other or attempt to endeavor to molest the other, nor
compel the other to cohabit with the other, or in any way harass
or malign the other, nor in any way interfere with the peaceful
existence, separate and apart from the other.
3. WIPE'S DEBTS: Wife represents and warrants to Husband
that since the separation, to wit, May of 1992, she has not and
in the future she will not, contract or incur any debt or
liability for which Husband or his estate might be responsible
and shall indemnify and save harmless Husband from any and all
claims or demands made against him by reason of debts or
obligations incurred by her. The parties acknowledge that the
definition of debts shall also include any and all credit card
debts and/or loans from any individual or entity.
4. HUSBAND'S DEBTS: Husband represents and warrants to
wife that since the separation, to wit, May of 1992, he has not
and in the future he will not, contract or incur any debt or
liability for which Wife or her estate might be responsible and
shall indemnify and save harmless Wife from any and all claims or
demands made against her by reason of debts or obligations
3
MEYERS" DE8FOR
410 NORTH SECOND STREET . P.O.BOX1062 . HARRISBURG. PA.17106
17171238-942B . FAX 17171 238-2B17
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incurred by him. The parties acknowledge that the definition of
debts shall also include any and all credit card debts and/or
loans from any individual or entity.
5. MUTUAL RELEASES: 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 causes of action for termination of the marri.age by divorce
or annulment and except any or all causes of action for breach of
any provisions of this Agreement. Husband and Wife specifically
release and waive any and all rights he or she might have to
raise claims under the Divorce Code of 1980, as amended in 1988
including, but not limited to claims for equitable distribution
of marital property, support, alimony, alimony pendente lite,
counsel fees or expenses. The fact that a party brings an action
to enforce the property agreement as incorporated in the divorce
decree, under the Divorce Code of 1980, as amended in 1988, does
not give either party the right to raise other claims under the
Divorce Code, specifically waived and released by this paragraph
and all rights and obligations of the parties arising out of the
marriage shall be determined by this Agreement.
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MEYERS" DE8fOR
410 NORTH SECOND STREET . POBOX 1062 . HARRISBURG. PA 17106
17171238-9428 . FAX 17171 238-2B17
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6. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for
in this Agreement, each of the parties hereto shall have the
right to dispose of his or her property by Last Will and
Testament or otherwise and each of them agree that the estate of
the other, whether real, personal or mixed, shall be and belong
to the person or persons who would become entitled thereto as if
the decedent had been the last to die. This provision is intended
to constitute a mutual waiver by the parties of any rights to
take against each other's Last wills under the present or future
laws of any jurisdiction whatsoever and is intended to confer
third-party beneficiary rights upon the other heirs and
beneficiaries of each.
7. LEGAL ADVICE/VOLUNTARY EXECUTION: The provisions of this
Agreement and their legal effect have been fully explained to the
parties by their respective counsel. The Husband has employed
and has had the benefit of counsel of Laurie A. Saltzgiver,
Esquire, as his attorney. The Wife has employed and has had the
benefit of counsel of Gregory H. Knight, Esquire, as her
attorney. Each party acknowledges that they have received
independent legal advice from counsel and that each party fully
understands the facts and have been fully informed of their legal
rights and obligations, and each party acknowledges and accepts
that this Agreement is, under the circumstances, fair and
equitable, and that it is being entered into freely and
voluntarily after having received such advice and with such
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MEYERS .. DE8FOR
',0NORTH SECOND STREET . POBOX 1062 . HARRISBURG. PA 17106
17171238-9428 . FAX 17171238-2817
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knowledge, and that execution of this Agreement is not the result
of any duress or undue influence and that it is not the result of
any collusion or improper or illegal agreement or agreements.
Also, each party hereto acknowledges that he or she has been
fully advised by his or her respective attorney of the current
Pennsylvania Divorce Law, and his or her rights thereunder, each
party hereto still desires to execute this Agreement
acknowledging that the terms
and conditions set forth herein
are fair, just, and equitable to each of the parties and waives
their respective right to have the Court make any determination
or order affecting the respective parties' right to a divorce,
alimony, alimony pendente lite, equitable distribution of all
marital property, counsel fees and costs and expenses.
8. NATURE OP PROPERTY DIVISION: 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 nontaxable division of property between co-owners rather
than a taxable sale or exchange of such property. Each party
promises not to take any position 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.
9. DIVISION OP PERSONAL PROPERTY: The parties agree that
the following items shall be transferred to the wife from the
husband: clothing, shoes, wall hangings, pictures, small kitchen
6
MEYERS .. DE8FOR
410 NORTH SECOND STREET . PO. BOX 1062 . HARRISBURG. PA. 17106
17171238-9428 . FAX 17171238-2817
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appliances, including a toaster, a fryer, an electric carving
knife and a blender, bird figurines, an ironing board,
photographs, photo albums, pots, pans, dishes, flatware,
tupperware, glasses, cups, miscellaneous knickknacks, books,
Christmas decorations, linens, towels, curtain rods and assorted
vases, handbags and suitcases. Should it become necessary, the
parties each agree to sign any titles or documents necessary to
give effect to this paragraph. Excluding the items previously
listed, the parties acknowledge that any remaining personal
property in the possession of either party shall become the sole
and exclusive possession of that party.
10. BANK ACCOUNT/PENSIONS:
A. The parties acknowledge that there are no joint
bank accounts presently in existence. Any bank account(s) which
either of the parties currently have shall remain their sole and
exclusive property.
B. The parties acknowledge that there are no
pension/retirement plans presently in existence. should either
party acquire an interest in any retirement vehicle in the
future, then said retirement vehicle shall be that party's sole
and exclusive possession.
11. MEDICAL INSURANCE COVERAGE: Husband acknowledges that
he has maintained wife on his medical insurance through his
employer during the parties' separation. Upon the issuance of
the Divorce Decree, Wife can no longer be covered under Husband's
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MEYERS .. DESFOR
410NDRTHSECONDSTREET . POBOX 1062 . HARRISBURG. PA.17108
17171238-942B . FAX 17171238-2817
".;'?i~~-h:>r"\f'ry5:''''_~J.
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medical insurance as his spouse, however, the parties acknowledge
that Cobra coverage is available through Husband's employer's
insurance carrier following the issuance of the Divorce Decree.
Husband agrees to pay the monthly premium for the Wife's Cobra
coverage for a period of one year from the date of divorce or for
a minimum of twelve monthly premium payments. It is believed
that the premium payment for this Cobra coverage shall be
approximately $178.27 per month. The parties acknowledge that
Cobra coverage is expected to be available for a total of three
years and that after Husband has made twelve monthly premium
payments the Wife will be able to maintain that coverage, however
the monthly premiums will be her sole and exclusive
responsibility.
12. BREACH: If either party breaches any provision of this
Agreement, the other party shall 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
party breaching this contract shall be responsible for payment of
legal fees and costs incurred by the other in enforcing their
rights under this Agreement.
13. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: The failure
of either party to insist upon strict performance of any of the
provisions of this Agreement shall not be construed as a waiver
of any subsequent default of the same or similar nature. In the
event that the marriage of the parties hereto is terminated by
8
MEYERS" DE8FOR
410NORTH SECOND STREET . POBOX 1062 . HARRIS8URG. PA 17108
17171238-942B . FAX 17171238-2817
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divorce, this Agreement shall nevertheless remain in full force
and effect, and shall survive such decree and shall not in any
way be affected thereby, except as provided for herein.
14. ADDITIONAL INSTRUMENTS: (A). 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
and effect to the provisions of this Agreement.
(B). This Agreement shall be incorporated into a
Divorce Decree but not merged therein.
15. MODIPICATION AND WAIVER: A modification or waiver of
any of the provisions of this Agreement shall be effective only
if made in writing and executed with the same formality as this
Agreement. The failure of either party to ineist upon strict
performance of any of the provisions of this Agreement shall not
be construed as a waiver of any subsequent default of the same or
similar nature.
16. DESCRIPTIVE HEADINGS: The descriptive headings used
herein are for convenience only. They shall
have no effect whatsoever in determining the rights or
obligations of the parties.
17. VOID CLAUSES: 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
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MEYERS" DE8fOR
410NORTH SECOND STREET . POBOX 1062 . HARRISBURG. PA 17108
17171238-942B . FAX 17171 238-2B17
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Agreement and in all other respects, this Agreement shall be
valid and continue in full force, effect, and operation.
IN WITNESS WHEREOP, the parties have hereunto set their
year first above-written.
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y D. K~NS
~a~
~y A. KUHN
10
MEYERS" DESFOR
410NORTHSECONDSTREET . POBOX 1062 . HARRISBURG. PA 17106
17171238-942B , FAX 17171238-2817
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LARRY DAVID KUHNS,
Plaintiff
I~ THE COURT OF COmlON !'LEAS OF
Cl1:IBERLAND comiTY. PE:INSYLVANIA
.
:10. 94-2118 CIVIL
1994
va,
FAYE A, KUHNS,
Defendant
PRAECIPE TO TR&~S~IT RECORD
To the Prothonotar/:
Transmit the record, together with the followin~ information, to the court
for entry of a divorce decree:
3301(c)
1. Ground for divorce: irretrievable breakdown under Section ~~
~lnI6cNxJtkX'K of the Divorce Code.
(Strike out inapplicable section,)
2. Date and manner of service of the complaint:
certified mail, restricted delivery
July 16, 1994
J. (Complete either paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by Section
3301
!l!:lD!(c) of the Divorce Code: by the plaintiff November 22, 1994
by defendant November 4. 1994
(b) (1) Date of execution of the plaintiff's affidavit required by
Section 201(d) of the Divorce Code:
(2) date of service of the plaintiff's affidavit upon the deiendant:
4. Related claims pending:
None
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LARRY DAVID KUHNS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANI
NO, 14 - :J If J (' ~( ....)
vs.
FAYE A, KUHNS,
Defendant
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 on the following pages, you must take promp
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
child (ren) .
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counselling.
A list of marriage counselors is available at:
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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.
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
MEYERS" DESFOR
"0 NORTH SECOND STREET . POBOX 1062 . HARRISBURG, PA 17108
17171238-9428 . FAX 17171 238-2B17
....~~,,'-.-;.',"-'''''t'1:
LARRY DAVID KUHNS,
Plaintiff
va,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO,
FAYE A. KUHNS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION
3301Cc) and 3301Cdl OF THE DIVORCE CODE
1. Plaintiff, Larry David Kuhns, is an adult individual who
currently resides at 5965 Eberly Drive, Cumberland County,
Mechanicsburg, Pennsylvania 17055,
2, Defendant, Faye A. Kuhns, is an adult individual who
currently resides at 210 North Palmetto Avenue, Daytona Beach,
Florida 32114,
3, Plaintiff and defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this Complaint,
4. Plaintiff and defendant were married on October 31, 1988
in Sommerville, South Carolina,
5. There have been no prior actions of divorce or
annulment between the parties.
6. The marriage is irretrievably broken,
7, Plaintiff has been advised that counseling is available
and that plaintiff may have the right to request that the Court
require both parties to participate in counseling,
8. Plaintiff requests the Court to enter a decree
of divorce,
MEYERS" DESFOR
410 NORTH SECOND STREET . POBOX 1062 . HARRISBURG, PA 17106
17171236-9428 . FAX 17171 238-2B17
IV_> .....1'11%-"."
4,
WHEREFORE, plaintiff, Larry David KUhns, respectfully
requests this Honorable Court enter a decree in divorce pursuant
to Sections 330l(c) or 330l(d) of the Divorce Code,
Respectfully submitted,
MEYERS & DES FOR
By
LAURIE A, SALTZGIVER, ESQU
Attorney I,D, No, 61382
MEYERS" DESFOR
410NORTH SECOND STREET . P,O BOX 1062 . HARRISBURG, PA,I7108
17171 238-942B . FAX 17171 238-2B 17
VF..R..T.FICl\'rIOH
I,
LARRY D. KUHNS
, verify that the
statements made in this
Complaint in Divorce
are true and correct to the
best of my knowledge, information and belief. I understand
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that false statements herein are made subject to the
penalties of ~6 Pa. c.S. section 4904, relating to unsworn
falsification to authorities.
Dated:
April 20, 1994
QpJ::~
() Defendant
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MEYERS .. DESFOR
:10 '.CFlr"" SE:C~.o S":'RE.P . PO Be\. '~e: . ,..:.ClRISB:...RG PJ, lj'1~
,7171 23&~2e . F:.\ ",,; 23&.2817
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LARRY DAVID KUHNS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 94-2118 Civil Term
Defendant
CIVIL ACTION - LAW
IN DIVORCE
FAYE A. KUHNS,
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF DAUPHIN )
I, Laurie A. Saltzgiver of Meyers & Desfor, attorneys for
Plaintiff in the above-referenced action, hereby certify that
on July 13, 1994 a certified copy of the Complaint in Divorce
was mailed to the Defendant, Faye A. Kuhns, 1926 State Street,
2B, Harrisburg, Pennsylvania 17103 by United States mail,
postage prepaid, restricted delivery, certified mail number
P922 217 647 and the same was received by her on July 16, 1994
as indicated on the return receipt card, attach d hereto.
Sworn to and subscr~ed
before me this Z'Zo"'" day
of ~994.
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2118 Civil Term
vs.
CIVIL ACTION - LAW
IN DIVORCE
FAYE A. KUHNS,
Defendant
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) and 3301(d) of
the Divorce Code was filed on April 22, 1994.
The marriage of the plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of this Complaint.
I consent to the entry of a final decree in divorce.
I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: /I ~
@N\M SlT:r k
RY. D. KUH~
MEYERS" Dl!8FOR
410 NORTH SECOND STREET . POBOX 1062 . HARRISBURG. PA,17106
17171238-9428 . FAX 17171238-2817
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2118 civil Term
vs,
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FAYE A. KUHNS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) and 330l(d) of
the Divorce Code was filed on April 22, 1994.
The marriage of the Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of this Complaint.
I consent to the entry of a final decree in divorce.
I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct, I understand that false statements herein are made
subject to the penalties of 18 Pa, C,S, Section 4904 relating to
unsworn falsification to authorities,
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Date: C)..;J 1- CJ~I
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YE A, KUHN
MEYERS" DESFOR
410 NORTH SECOND STREET . P. 0, BOX 1062 . HARRISBURG, PA,17108
17171238-942B . FAX 17171 238-2B17
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LARRY DAVID KUHNS,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94-2118 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
FAYE A. I<UHNS,
Defendant
COMPLAINT UNDER SECTION
3301Ccl and 3301Cdl OF THE DIVORCE CODE
1, Plaintiff, Larry David Kuhns, is an adult individual who
currently resides at 5965 Eberly Drive, Cumberland County,
Mechanicsburg, Pennsylvania 17055,
2. Defendant, Faye A, Kuhns, is an adult individual who
currently resides at 1926 State Street, 28, HarriSburg,
Pennsylvania 17013.
3. Plaintiff and defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this Complaint,
4, Plaintiff and defendant were married on October 31, 1988
in Sommerville, South Carolina.
5. There have been no prior actions of divorce or
annulment between the parties,
6. The marriage is irretrievably broken,
7. Plaintiff has been advised that counseling is available
and that plaintiff may have the right to request that the Court
require both parties to participate in counseling,
8, Plaintiff requests the Court to enter II decree
of divorce.
MMRS II D!8fOR
410NORTHSECONDSTREET . P,OBOX1062 . HARRISBURG, PA 17106
17171238-9428 . FAX 17171 238-2B17
WHEREFORE, plaintiff, Larry David KUhns, respectfully
requests this Honorable Court enter a decree in divorce pursuant
to Sections 330l(c) or 3301(d) of the Divorce Code,
Respectfully submitted,
MEYERS & DES FOR
MmRS II DlSfOR
410 NORTH SECOND STREET , po, BOX 1062 . HARRISBURG, PA. 17108
17171238-9428 . FAX 17171 238-2B17
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Larry David Kuhns
, verify that the
statements made in this C'.tYllp,..int, IJnr'II.r !':Iorot.inn ~~01 (~) ..nd
3301(d) of the Divorce Code are true and correct to the
best of my knowledge, information and belief. I understand
that false statements herein are made subject to the
penalties of ~~ Pa. C.S. section 4904, relating to unsworn
~ falsification to authorities.
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Dated:
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MEVERS II DEBFOR
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