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81____ ._
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
Plaintiff
NIl. ,94.,.,611.4... ,.Civ.iL. 1994
V(l]':<lllS
W. DARRYL GRABLE,
Defendant
DECREE IN
DIVORCE
,11../ S" 9J
.........pn............ 19.......
it is ordered and
AND NOW, . . .
decreed that ,........, LINDA. J.., GR~~LE. , . . . . . . .
and . . , . . . . . . , . . . . . . . . . .W,. .DARR~L .GRABI~E . . . . . . .
are divorced from the bonds of matrimony.
. . , . . . . . . , . . . '. 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;
and thaL the attached post-nuptial agreement shall be incorporated but not
.....,..........,'.....'.........,......,......, ....,..".............,....
nv-K CO/Jd
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'1BI' ao.......'1, IllAde this -.. 01_ day of ()\ll('( h , 1995,
by and between LINDA J. GRABLE, of Cumberland County, Pennsylvania,
(hereinafter referred to as "Wife"), and W. DARRYL GRABLE of
Cumberland County, Pennsylvania, (hereinafter referred to as
"Husband");
WIT . a 8 8 a If 81
wa....., Husband and Wife were lawfully married on August 26,
1972, and
waa...., three children have been born of this IllArriage, to witl
JENNIFER GRABLE, SHERI GRABLE, and NICHOLAS GRABLE; and
wa....., diverse unhappy differences, dieputes and difficulties
have arieen between the partiee and it is the intention of Wife and
Husband to live separate and apart for the rest of their natural
lives, and the parties hereto are desirous of settling fully and
finally their respective financial and property rights and obligations
as between each other including, without limitation by specification I
the eettling of all matters between theul relating to the ownership and
equitable distribution of real and personal property; the settling of
all IllAtters between them relating to the past, present and future
support, alimony and/or ~aintenance of Wife by Husband or of Husband
by Wife; the eettling of all matters between them relating to the
paat, pre.ent and future eupport and/or maintenance of the children;
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the implementation at cu.tody/vi.itation arrangement. tor the minor
children at the partie., and in general, the .ettling at any and all
alaim. and po..ible claim. by one again.t th8 other or again.t their
re.peative e.tate..
.ON '....,0.., in consideration at the premi.e. and of the mutual
promi.e., covenant. and undertakings hereinatter eet torth and tor
other good and valuable consideration, receipt ot which i. hereby
acknowledged by each of the partieB hereto, Wife and Hu.band, eaoh
intending to be legally bound hereby, covenant and agree a. tallow..
1. Di.alo.ure of A..et.. Husband and Wite acknowledge that
they are aware of their respective rights pursuant to the Divorce Code
at 1980, a. amended, to obtain formal valuations or apprai.ale at the
marital reeidence, any and all pensions, and other items of marital
property. However, the parties agree that they will not undertake
thi. expenee and acknowledge that no financial discloBuree are
attached to this agreement as separate exhibits or Bchedule.. The
partie. hereby waive any neceBsity for completing or attaching any
tinancial disclosure(s). Each party further acknowledgee the opportu-
nity to attach a full and complete financial discloeure and that euch
dieclo.ure iB not desired or required to effectuate a fair and
equitable resolution of their marital rights, duties and obligatione
a. provided in the Divorce Code of 1980, as AMended.
2. Advice of COUD'~~. Each party ha. been repreeented by
an independent attorney, who was selected by the party whom he
repre.ent., in the negotiation and preparation ot thiB agreement.
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Thi. agreement ha. been fully explained to eaoh party by that party'.
attorney. Baoh party ha. oarefully read thi. agreement and i. com-
pletely aware, not only of its content8, but al.o of it. legal effect.
3. ~wfulD... of ..DeratioD. It .hall be lawful for .ach
party at all time. hereafter to live .eparate and apart from the oth.r
party at .uch place a8 he or she may from time to time choo.. or deem
fit. The foregoing provi.ion. .hall not be taken a. an admie.ion on
the part of either party of the lawfulnes8 or unlawfulne.. of the
cau.ea leading to their living apart.
4. P.r.oDel RiGbt.. Each party 8hall be free from inter-
ference, authority, and contact by the other, a8 fully a8 if h. or .he
were .ingle and unmarried except a8 may be nece8sary to carry out the
provi.ion. of thia agreement. Neither party .hall moleat the oth.r 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 exi8tence, separate and apart
from the other, and each of the parties hereto completely under.tand
and agree that neither shall do or say anything to the children of the
partie. at any time which might in any way influence the children
adveraely againBt the other party.
5. ..1.... of Cl.i... Wife and HUBband each do hereby
mutually remi.e, relea.e, quit-claim and forever discharge the other
and the e.tate of such other, for all time to oome, and for all
purpo... what.oever, of and from any and all righta, titl.. and
intere.t., or claima in or against the property (inoluding income and
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gain from property hereafter accruing) of the other or again.t the
e.tate of luch other, of whatever nature and where.oaver .ituate,
which .he or he now ha. or at any time hereafter may have again.t .uch
other, the e.tate of auch other or any part thereof, whether ari.ing
out of any former act., contracta, engagementl or liabilitiel of .uch
other or by way of dower or curte.y, or claiml in the nature of dower
or curte.y of widow'. or widower'. righte, family exemption or .imilar
allowance, or under the inte.tate law., or the right to take again.t
the .pou.e'. willI or the right to treat a lifetime conveyance by the
other a. te.tamentary, or all other righte of a eurviving .pou.e to
participate in a deceaeed epouee'. e.tate, whether arieing under the
law. of (a) Penneylvania, (b) any etate, commonwealth or territory of
the United Stat&., or (c) any other country, or any right. which Wife
may have or at any time hereafter have for pa.t, prelent or future
.upport or maintenance, alimony, alimony pendente lite, counlel fee.,
co.t. or expen.el, whether ariling a. a reeult of the marital relation
or otherwi.., except, and only except, all right. and agreemant. and
obligation. of what.oever nature ariling or which may a~iee under thi.
agreement or for the breach of any thereof. It io the intention of
Wife and Hu.band to give to each other by the eXl/lcution ofthi.
agre.ment a full, complete and general releaee with re.pect to any and
all property of any kind or nature, real, per.onal or mixed, which the
other now own. or may hereafter acquire, except and only except all
right. and agreement. and obligationl of whatloever nature ari.lng or
which may ari.e under thil agreement or for the breach of any thereof,
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,
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eubjeot, however, to the implementation and satisfaction of the
oonditione precedent as Bet forth herein above.
6. WarraDtv as to Future Obli9atioDe. Each party repre-
eente that they have not contracted any debt or liability for the
other for whioh the estate of the other party may be responsible or
liable, and that except only for the rights arising out of this
agreement, neither party will hereafter incur any liability whatsoever
for which the other party or the eBtate of the other party, will be
liable. Each party agrees to indemnify or hold the other party
harmless from and againBt all future obli9ations of every kind
incurred by them, including those for necessities.
7. asswaDtioD of Liabilities. This provision sets forth
the method for the payment and assumption of the debts and liabilities
of the parties. Since the assumption is not binding on the creditor,
the party assuming the debt agrees to indemnify the other party in the
event the creditor seeks to hold such other party liable. Should the
parties wish to bind the creditor and relieve the original debts from
all liability, a novation should be executed.
a. From and after the date of the signing this
agreement through August 31, 1995, or until the parties daughter,
JENNIFER GRABLE, oan aSBume responsibility for payments on her own,
whichever first occurs, Husband assumes and agrees to pay and hold the
Wife harmless against from and against the obligations of daughter,
JENNIFER GRABLE, to PNB Bank, Account No. 2810120010, which obligation
i. secured by Jennifer Grable's Ford Mustang. If any claim, aotion or
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proceeding is hereafter brought seeking to hold the Wife liable on
account of such debts or obligation. through August 31, 1995, the
Hueband will, at his eole expense, defend the Wife against any such
claim, action or proceeding, whether or not well founded, and Husband
will indemnify and hold Wife harmle.. from and againet such claim,
action or proceeding.
b. wife a88ume. and agrees to pay and hold the
Husband harmless against the following debts and obligationel PHB Loan
Ho. 2810120010 from and after August 31, 1995~ and loan to BELeO
Federal Credit Union, the outstanding balance which ie approximately
$8,200.00, aecured by Wife's 1992 Honda wagon. If any claim, action
or proceeding is hereafter brought seeking to hold the Husband liable
on account of such debts or obligations, the Wife will, at her sole
expense, defend the Husband against any 8uch cla1m, action or proceed-
ing, whether or not well founded, and Wife will indemnify and hold
Hueband harmless from and against 8uch claim, action or proceeding.
8. 'ersoDal 'rODerty. Wife and Hueband do hereby acknowl-
edge that they have heretofore divided the marital property including,
but without limitation, jewelry, clothes, furniture and other person-
alty and hereafter Wife agrees that all of the property in the
poeeession of Husband shall be the sole and separate property of Hus-
band1 and, Husband agree8 that all property in the posse.sion of Wife
shall be the 801e and separate property of Wife. Each of the partiee
doee hereby specifically waive, release, renounce and forever abandon
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whatever claima, if any, ahe or he may have with reapect to any of the
above item. which are the aole and aeparate property of the other.
9. IUllIAIID AJlD NIPI .0.10. 'LAIII. Neither party hereto
ahall make a claim upon the other for accumulated penaion, profit-
aharing, retirement eupport, retirement benefite, inaurance policiea,
IRA'a, or any retirement related be~efita.
Hueband apecifically
,
waive a any riqht or claima to any intereat in Wife'a penaion or
retirement with Bell Atlantic of Pennaylvania. Wife hereby apecifi-
cally waivea her righta and claima to any intereat in Huaband'a
penaion with the civil Service Retirement Syetem and hia military
penaion with the United Statee Air Force.
10. Automobile to luaband. The Huaband ahall be the aole
owner free and clear from any claim on the part of wife of the 1987
Plymouth Voyager, Wife ehall deliver executed certificate of title,
aalea and uae tax form and any other document neceaaary to convey
title upon demand by Hueband.
11. Automobile to Nife. The Wife ehall be the eole owner
free and clear from any claim on the part of Hueband of the 1992 Honda
Wagon and 1991 Ford Muatang. Hueband ehall deliver executed certifi-
cate of title, aale. and uee tax form and any other document nece..ary
to convey title upon demand by Wife.
12. Ca.b .av.ent by luaband to Nife. The Wife ahall
receive and the Huaband ahall deliver or caue. to be delivered to the
Wife the aum of $50,000.00 concurrently with the execution of thia
agreement.
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13. .,al ..tate. Concurrently with the execution of thi.
agr.ement, Wife .hall convey, tran.fer and grant to Hu.band her right,
title and intere.t in the real e.tate .ituated and located &t 116
Holly Drive, Mechanic.burg, Cumberland County, penn.ylvania 17055.
Th. execution of thi. agreement and the delivery of the deed to .aid
real e.tate .hall be done concurrently with the refinance of the
underlying mortgage on 116 Holly Drive, Mechanic.burg, Cumberland
County, penn.ylvania by Hu.band .0 a. to remove Wife from any
re.pon.ibility or liability for .aid mortgage payment..
Hu.band and Wife further agree that the tran.fer of the
marital re.idence may re.ult in a capital gain. tax a..ociated with
.uch tran.fer and di.tribution. of proceed. from .uch tran.fer of real
property. Bach party ha. been advi.ed of their right to review thi.
matter with an accountant prior to signing thi. agreement and agree.
to a..ume any capital gain. tax which may re.ult in accordance with
the term. of thi. agreement.
14. ProDerty .ot Provided Por. The partie. hereto agre.
that they hav., by the term. of thi. agreement, .ettled, to their
mutual .aU.factioll, all rights that either may have in their proper-
ty, whether owned by them jointly or separately, real and per.onal,
and wher..oever .ituated. Any property not .pecifically provided for
in thi. agre.ment, which the Hu.band or Wife own. or ha. the right to
control or po....., shall be and remain his or her property, fr.e and
clear from any claim on the part of the other.
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15. Child SUDDort. Hu.band agree' to pay to Wife for the
.upport of the partie. minor child, NICHOLAS GRABLE, Four Hundred
($400.00) Dollar. payable on the 1.t ~ eagh month, which payment.
0", '/pr," I J 1'I1S""wl0J1 1:i1~
.hall commence a' the ....~t1~of tlli. 4~W".'R~_ Support .hall be
paid for the minor child through the Court of Common Plea. of
Cumberland County, penn.ylvania, and the partie. agree to execute a
.tipulation for the payment of .aid .upport a. afore.aid. Hu.band
further agree. to con.ent to the entry of a wage attachment for .aid
amount payable in accordance with Husband's pay schedule. "Said child
.upport .hall be modifiable upon order of the Court.
16. Colleae Iducation ZXDen.e. of the Children. The
partie. agree to pay for the college education of the children ae
fQllowe.
JENNIFER GRABLE - wife agrees to pay for all future college
education and related expenses for Jennifer Grable.
SHERI GRABLE - Hueband agrees to pay for all future college
education and related expense. for Sheri Grable.
NICHOLAS GRABLE - Hueband and Wife agree to contribute to
the higher education expen.e. of Nicholae Grable including but not
limited to tuition, room and board, booke, eupplies, feee, tran.porta-
tion and olothing. The oontribution of Hueband and Wife ahall be
datarmined pur.uant to the then relevant college .upport guideline.
applioable in the Commonw.alth of P.nneylvania.
17. Con.ultatioD. Th. partiee agree to oonfer 011 all
matter. of importance relating to the children'. health, maintenanoe
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and .ducation with a view towards obtaining and following a harmonious
policy in the children's best int.r.sts and shall k..p each other
informed of the progr..s of the children's education and .ocial
adjustlll8nts.
18. .nforc."nt. If either party shall bring an .ction or
oth.r proceeding to enfox'ce this aqr.elllent, or to .nforce any judg-
I118nt, decr.. or order IllAde by a court in connection with this agr..-
I118nt or the divorce of the parties, the pr.vailinq party .hall b.
entitled to reasonable attorney'. fees frolll other party.
19. ,~nt of Attorney r.... Each party of this agr....nt
b.r.by agree. that each of thelll will be solely responsible for the
full payment of all attorney's fees and other co.ts heretofore and
h.r.aft.r incurred, respectively, by each of tbem in connection with
the negotiation, preparation, and execution of this agreem.nt, and in
conn.ction witb eny action commenced by either party with re.pect to
the divorce of the parties. Each party further agree. hereby to
indemnify and hold the other party harmless from any demand, clala,
loss, cost and expen.e (including additional attorney'. fee.) arising
frolll . failure to pay all of the aforesaid attorney's fee. and other
cost. .
20. Jnfo~d .nd volunt.rv .x.cutiOD. Each party to this
.gr....nt acknowledqes and declare. that he or .be, re.pectiv.1YI
a. 1. fully and completely inforlll8d a. to the f.ct.
rel.ting to the subjeot matter of tbis agreelll8nt and a. to the right.
and liabiliti.. of both parti.s.
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b. Bnter. into this agreement voluntarily after
receiving the advice of independent coun.el, free from fraud, undue
influence, coercion or dure.. of any kind.
c. Ha. given careful and mature thought to the making
of this agreement.
d. Ha. carefully read each provi.ion of this
agreement.
e. Fully and completely under.tand. each provi.ion of
this agreement.
21. .eadinG.. The heading. or caption. preceding the
paragraphs in this agreement are in.erted for convenience of reference
only and .hall not be con.trued in interpreting this agreement.
22. Mutual coo,.ration. The Hu.band and the Wife .hall
each concurr.ntly herewith, or at any time here~fter on the demand of
the other, .xeoute any other document. or in.trument., and do or oau.e
to b. done any other aot. and thing. a. may be nece..ary or conveni.nt
to oarry out the intent. and purpo.e. of this agreement.
23. ..v.r.bilitv. If any provi.ion in this agreem.nt i.
held by a court of competent juri.diction to be invalid, void, or
un.nforoeable, the remaining provi.ion. .hall neverthele.. continu. in
full forc. and .ffect without being impaired in invalid.ted in any
way.
24. Future l.rninG.. All income, aarning. or other
prop.rty reo.iv.d or acquired by either party to this .gr....nt on or
.ft.r the date of .x.cution of this agreement .hall be the .ole and
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..p.r.t. prop.rty of the r.ceiving or acquiring party. Bach p.rty, ..
of the .ff.ctiv. d.t. of this agreement, doe. hereby and for.v.r
w.iv., 1'.1.... and r.linqui.h all right, title and inter..t in .11
.uoh income, .arnings or other property so received or acquir.d by the
other.
25. W.iv.r of Riqht.. Each of the par.tie. hereby irrevoc.-
bly w.ive all rights which he or she may have to request any court to
equitably distribute the marital property of the partie. or to have
.limony, alimony pendent,o lite or counsel foe. awarded to either
party, it being the expre.s intention of the partie. hereto to fully
s.ttle .11 claim. which they have with respect to each other in this
agreement.
26. Divorce. A decree in divorce entered by a court of
competent juri.diction to either party .hall not .u.pend, .uper.ede or
affect the term. of this agreement. Both parties agree, if reque.ted,
to enter a consent order or orders concerning the provision. of this
.greement in the Court of Common Pleas of Cumberland County, penn.yl-
v.nia, or any othor court of competent juriSdiction, as a part of .
resolution of any divorce action filed or to be filed. Thi. agree-
ment, and the terms and condition. contained herein, a. well a. the
enforcement of .aid terms and conditions, .hall be contingent upon the
gr.nting of a Divorce Decree to either party by the Court of Common
Ple.. of Cumberland County, Pennsylvania, or any other court of
comp.tent juri.diction. Furthermore, both parties hereto .gree, if
reque.ted, to execute the appropriate affidavit. .nd con.ent. to
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s.cur. a no. fault divorc. as may b. r.quir.d by the Divorc. Cod., as
.....nd.d.
27. waiv.r of Br.ach. Th. waiv.r of any t.=m, condition,
claus. or provision of this agre.m.nt shall in no way b. d....d or
consid.r.d a waiver of any other term, condition, claus. or provision
of this agr.em.nt.
28. 8urvival of Aar....at. If any t.rm, condition, clau.e
or provision of this agreement shall, by its reasonable interpreta.
tion, be int.nd.d to survive and extend beyond the termination of the
marriage relationship presently existing between the parti.s her.to,
said t.rm or terms, condition or conditions, clause or claus..,
provision or provisions, shall be so construed, being the expr.s.
int.ntion of both parties hereto to have this agreem.nt govern th.ir
relationship now or hereafter, irrespective of their marital .tatus.
29. J~risdiotioa. This agreement shall be construed under
the laws of the Commonwealth of Pennsylvania, and both partiee con.ent
and agree to the jurisdiction of the Court of Co_on Pleas of
Cumb.rland County, Pennsylvania, on account of any suit or action
brought with r.spect to this agreement or any provisions or matt.r.
ref.rred to in any provi.ions thereof.
30. Aar....nt BiadinG on 'arti.. and I.ir.. Thi. agr.emen~
.hall b. binding in all its terms, conditions, claus.s and provisions
of the parties her.to and their respective heirs, administrators,
executors and .ssigns.
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I. WI twill WKlRlOr, the parti.. have hereunto ..t their hand. and
..al. the day and year above fir.t written.
4JcdL ~ x!iuM
LINDA . GRABLB
4,{).~JJ;:/~, '
W. L GRABLB
(SIAL)
(SIAL)
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COMMOHWBALTH OF PENNSYLVANIA:
: aa.
COUNTY OF t1vmb.'-~..L :
On thh, the "jJ,A.J day of
~
, 1995, before me,
a Notary Public, the underaigned officer, peraona11y appeared LINDA J.
GRABLE, known to me (or aatiafactorily proven) to be the peraon whoae
name ia aubacribed to the within inatrument and acknowledged that ahe
executed the aame for the purpoeee therein contained.
IN WITNBSS WHEREOF, I have hereunto aet my hand and aeal the day
and year firat above written.
NclsliaI Seal
Kaye R. Lucl<ey Nrtury P\tlIIc
New Curnbc:'rlond eorO, Cum..I~r1c~ ~~ty
~ Commic:'Jon E).pf\.~ Mnr :tl .7, 1 J91
~,-r;lnsylvdniii.~~:':;'~:i.~i
7(7J'- ~. ~,~ J,ig'
Notary Pub1
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF e,l..V1l<1~' I ~ ,.,1 :
a..
On thb, the ~.l day of 'tY1t1//cL
, 1995, before me,
a Notary Public, the underaigned officer, peraonal1y appeared W.
DARRYL GRABLE, known to me (or .atisfactorily proven) to be the peraon
whoa. name i. subscribed to the within instrument and acknowledged
that he executed the same for the purposes therein contained.
IN WITNBSS WHEREOF, I have hereunto set my hand and aeal the day
and year fir at above written.
~OL 'R /~L~
Notar Pu c
'k~nn.1 Senl
f(,.1YaA. L.UfJl8\,'. "'JOlilry Pt.t.Jftc
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LINDA J. GRABLE,
Plaintif f
IN THE COURT or COMMON PLEAS OF
CUKBERLAND COUNTY, PENNSYLVANIA
NO. 94-6114
CIVIL
1994
VI.
W. DARRYL GRABLE,
Defendant
PRAECIPE TO TRANSMIT RECORD
To thl Prothonotary:
Tranamit tha record, together with the following information, to the court
for entlY of I divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c)
Ulk(al)
of the Divorce Code.
(Strike out inapplicable section.)
2. Date and manner of service of the complaint: October 28, 1994, Certified
Mail, Remtricted Delivery, postage prepaid,
3. (Complete either paragraph (a) or (b) .)
(a) Dati of execution of the affidavit of consent required by Section
33Ql (c) of the Divorce Code: by the plaintiff
by defendant MARCH 23 1995
(b) (1) Date of execution of the plaintiff's affidavit required by
MARCH 23, 1995
Sectton 3301 (d) of the Divorce Code:
(2) date of service of the plaintiff's affidavit upon the defendant:
4. Related claw pending:
NO CLAIMS RAISED
DAVM
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LINDA J. GRABLe,
Plaintiff
I IN THE COURT OF COMMON PLeAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 94 lo 1/4 CIVIL TBRH
I
I CIVIL ACTION - IN DIVORCE
I
v.
W. DARRYL GRABLE,
Defendant
.OTIC. TO D.PI.D AMD CLAIM aIGH~.
You have been sued in court. If you wish to defend again.t the
claim. .et forth in the following pages, you must take prompt action.
You are warned that if you fail to do eo, the case may proceed without
you and a Decree of Divorce or annulment may be entered again.t you by
the Court. A judgment may also be entered against you for any other
claim or relief requested in theee papers by the plaintiff. You may
lo.e money or property or other rights important to you, including
cuetody 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
li.t of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013.
I. WOU DO .OT PILII A CLAIM poa ALIMO.Y, DIVI.IO. OP .aO..aTW,
LAWY..'I PI.. OR .X...... ..PO.. A DIVOaCI oa AIMULMI~ I'
GIUUI'l.D, YOU MAY LOSI TI. RIGHT TO CLAIM AMY OP THIN.
WOU ..OULD TUI TlIS .APla TO YOUR LAIfYIR AT O.C.. IJ' YOU DO
.OT ...n A LAWYIR oa CAIIJIOT AFPORD 0.1, GO TO oa ULIl..OIII
TH. OPPIC. '.T POaTH .ILON TO PI.D OUT WlIRI YOU CAN alT
J.IOIU. "loP.
Court Admini.trator
Fourth Floor
Cumberland County Courthou..
Carli.l.. PA 170.3
TeleDhonel /117\ 240-6200
'1\~1.\.."1..11.\IO-'.
LINDA J. GRABLB, I IN THB COURT OF COMMON PLBAS or
Plaintiff I CUMBBRLAND COUNTY, PENN~YLVANIA
I
v. I NO. 94 - ~ \\~ CIVIL TERM
I
W. DARRYL GRABLE, I CIVIL ACTION LAW
Defendant I IN DIVORCB
COIIPLArMT
1. The plaintiff in this action is LINDA J. GRABLB, an adult
individual, who currently resides at 116 Holly Drive, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
2. The defendant in this action is W. DAR~YL GRABLE, an adult
individual, who currently resides at 116 Holly Drive, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
3. Both the plaintiff and the defendant have been bona fide
resident. of the Commonwealth of Pennsylvania for at least .ix 16)
month. immediately previous to the filing of this complaint.
4. The plaintiff and defendant were lawfully joined in marriage
on Augu.t 26, 1972.
5. There have been no prior actione of divorce or for annulment
between the partiee hereto in this or any other jurisdiction.
ti. The Plaintiff avers all the grounde upon which this action is
ba.ed i. that the marriage between the partie. hereto i.
irretrievably broken.
-1-
7. The Plaintiff ha. b.en advi.ed that coun.eling i. available
and that the Plaintiff may have the right to reque.t that the oourt
require the partie. to participate in coun.eling.
8. The Plaintiff reque.t. the court to enter a decree of
divorc..
I verify that the .tatement. made in thi. complaint are true and
oorreot. I under.tand that fal.e .tatement. herein are made .ubjeot
to the penaltie. of 18 p.e.s. 54904, relating to un.worn fal.ification
to authoritie..
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LINDA J. GRABL!, I IN THB COURT OF COMMON PL!A8 OF
Plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA
I
v. I NO. 94-6114 CIVIL TBRM
I
W. DARRYL GRABLB, I CIVIL ACTION LAW
Defendant I IN DIVORCE
AFFIDAVIT OF CO...~
1. A complaint in divorce under Section 3301(c) of the Divorce
Code wae filed on October 25, 1994.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer'. fees or expenses if I do not claim them
before a divorce is granted.
I verify that the statements made in thiu affidavit are true and
correct. I understand that false statemente herein are made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authoritie..
.4JJdl e.)U ..1 3, / '19.5
Oat.
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LE, Plaintiff
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LINDA J. GRABLB , I IN THE COURT OP CONNON PLlAS OP
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. I NO. 94-6114 CIVIL TERM
I
W. DARRYL GRABLB, I CIVIL ACTION LAW
Defendant I IN DIVORCE
AFFIDAVIT or CO....T
1. A complaint in divorce under Section 3301(c) of the Divorce
Code wa. filed on October 25, 1994.
2. The marriage of plaintiff and defendant i. irretrievably
broken and ninety day. have elapeed from the date of filing the
complaint.
3~ I con.ent to the entry of a final decree of divorce.
4. I underetand that I may 10e8 right a concerning alimony,
divieion of property, lawyer'a feee or expenees if I do not claim the.
before a divorce ia granted.
I verify that the atatementa made in this affidavit are true and
correct. I underetand that falae atatemente herein are made aubjeot
to the penal tie. of 18 Pa. C.S. Section 4904 relating to unaworn
faleification to authoritie..
~3h,-
Date, '
tl'diy~11"WYI."
,I '
. .
LINDA J. GRABLB,
Plaintiff
I IN THB COURT OF COMMON PLBAS OP
I CUMBERLAND COUNTY, PBNNSYLVANIA
I
I NO. 94 - 6114 CIVIL TBRM
I
I CIVIL ACTION LAW
I IN DIVORCE
v.
w. DARRYL GRABLE,
Defendant
AFFIDAVIT OF SERVICB
COMMONWEALTH OF PENNSYLVANIA)
) ee.
COUNTY OF CUMBBRLAND )
I, DAVID H. STONE, of Stone LaFaver , Stone, attorney. for the
plaintiff hereby certify that I eerved the Complaint in Divorce in the
above captioned matter on the defendant, W. Darryl Grable, at 116
Holly Drive, Mechanic.burg, PA 17055, by United State. Firet Cla..
Mail, poetage prepaid, Certified Mail, reetricted
28, 1994, ae evidenced by the attached
ivery on October
i1 return reoeipt..
(,-
E, BSQUIRE
SWORN TO AND SUBSCRIBED
befone!:J this.JiM!;. day
of ,. .PIV , 1994.
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I<aye R, u.dw,' NoIury P\hJIIC
Now Cllmb<>t1iJr<l Bon;. Cumb<l,1t111d County
My ~"'"",on E'I-'''''' ~'orcl121. '001
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P 305 515 354
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. po.. St.tle JrXlIIP Code
~ echanicsbur PA 17055
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tECEIPT FOil CEIITIFIED MAIL
NO IH5URAACI COV[IlAGi PROIJIDED
Nor ~OR INTERNATIONAL MAil
(Sfte RS'IIsr.'iflJ
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- 116 Holl
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W DARRYL GRABLE
Drive
Certlher1 f,,~
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