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. STANLEY W. DOYLE,
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.. EVELYN I" DOYLE.
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IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
STATE OF /lJ~..' .1 PENNA.
~'^~~
;\; II, 95-2428
CIVIL TEIlM
1'1iJinlHt
\'('1'-,11"
De fendanl
AND NOW,
DECREE IN
DIVORCE
udtd#- '5 ^
it Is ordered and
19 95
decreed that
HTANLEY W. DOYLE,
, . " plaintiff.
^ . , defendant.
d EVELYNI' L. DOYLE
an ^
ore divorced from the bonds of matrimony,
The court retains jurisdiction of the folluwing claims which have
been raised of ~~~ord in this action for which 0 final order has not yet
been entered; fVl.)k..(7
iBll)l;\J'J1<Irill "'I 11111. I1pl 1!'~'IIJ,:d
the IhllqeB dolel! Hp)l~'i'I,'I).e,r:,)5",
il\t,~l lid", nIVOrc.'YL~:r:ee.
1995
The at t t1ched illJl !!{'lIIl'l1t "et ween
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~RITAL AGREEMENT
II fl.') ) 4 ) J'
THIS AGREEMENT, made th is /~ I ~ day 0 f~;?I.r,n6J( ,
1995, by and between Evelyn L. Doyle, party of the first part,
hereinafter referred to as "Wife", and atanley W. Doyle, party of
the second part, hereinafter referred to as "Husband".
WITNESSETH:
WHEREAS, the parties hereto are husband and wife,
having been married on March 10, 1973, in st. Thomas, Pennsyl-
vanial and
WHEREAS, there has been issue of that marriage, to wit:
Jerry W. Doyle, D.O.B. 9/1/73, and Jaime S. Doyle, D.O.B.
7/23/771 and
WHEREAS, certain differences have arisen by and between
the parties as a result of which they have now separated and live
separate and apart from one another, 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: the settling of
all matters between them relating to the ownership and equitable
distribution of real and personal propertYI the settling of all
matters between them relating to the past, present and future
support, alimony andlor maintenance of Wife by Husband or of
Husband by Wifel and in general, the settling of any and all
claims and possible claims by one against the other or against
their respective estates.
WHEREAS, the parties being fully advised as to their
respective rights, dutios and obligations growing out of their
marital status, particularlY with respect to the relevant sec-
tions of the Divorce code, Act of April 2, 1980, P.L. 63, Act No.
26, as amended, and being fully aware of their right to consult
with or having consulted with their respective legal counselor
advisors, namely Andrew c. Sheely, Esquire, Attorney for Husband,
and/ Rebecca R. Hughes, Esquire, Attorney for Wife, and having
had the opportunity and ability to request a full and complete
disclosure of income and assets from the other, and reviewing
this Agreement, have corne to an agreement as to each and all of
their said matters of property and relations I and
WHEREAS/ Husband has filed a No-faUlt complaint in
Divorce, said complaint being docketed in the cumberland county
Prothonotary's Office at No. 95 - 2428;
NOW, THEREFORE, in consideration of the above recitals
and the mutual covenants hereinafter set forth, each of the
parties hereto intending to be legallY bound hereby by affixing
their hands and seals agree as followSI
1. SEPARATION
It shall be lawful for each party at all times
hereafter to live separate and apart from each other in such
2
place or places as he or she may from time to time choose or deem
fit.
2. INTERFERENCE
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 annoy the other
or compel or endeavor to compel the other to cohabitate or dwell
with him or her, or to in any way harass or malign the other.
3. WAIVER OF CLAIMS AGAINST ESTATES
Except as otherwise provided herein, Husband relin-
quishes his inchoate intestate right and his right to act as a
personal representative in the estate of Wife, and Wife relin-
quishes her inchoate intestate right and her right to act as a
personal representative in the estate of Husband. Each of the
parties hereto by their presents, for himself or herself, his or
her heirs, executors, administrators or assigns, does remise,
release, quit-claim and forever discharge the other party hereto,
his or her heirs, executors, administrators or assigns or any of
them, of any and all claims, demands, damages, actions, causes of
actions, suits, at law or equity, of whatsoever kind or nature,
for or because of any matter or thing omitted or suffered to be
dons by said other party prior to and inclUding the date hereof,
except that this release shall in no way exonerate or discharge
3
either party hereto from the obligations and promises made and
imposed by reason of this Agreement and shall in no way affect
any cause of action in absolute divorce which either party may
have against each other.
4. t\ARI'l'ALJ'ROPEIlTI
The parties hereto acknowledge that during their
marriage they have acquired, individually or jointly, various
assets and property, including but not limited to, the followingl
(A) Marital Residence located at 388 Peach Glen Road,
Gardners, Pennsylvania;
(8) 1994 Oldsmobile Achieval
(C) 1992 pontiac Bonneville;
(0) 1989 Mazda 3231
(E) 1987 Chevrolet 'l'ruck;
(F) civil Service Retirement Pensions/ Thrift Savings
plans;
(G) PNC Mortgage company Mortgage; and
(H) Misc. checking and savings accounts I and
(1) Misc. car loans.
Husband and wife acknowledge that they are aware of their
respective rights pursuant to the Divorce Code of 1980, as
amended, to obtain formal valuatlollll or appralllals of the marital
rSllidsnce, and other Items of marital property. However, the
partlea agree that they will not un<lertake thla expense and
4
acknowledge that no financial disclosures are attached to this
agreement as separate exhibits or schedules. The parties hereby
waive any necessity for completing or attaching any financial
disclosure(s). Each party further acknowledges the opportunity to
attach a full and complete financial disclosure and that such
disclosure is not required to effectuate a fair and equitable
resolution of their marital rights, duties and obligations as
provided in the Divorce Code of 1980, as amended.
5. PERSONAL PROPERTY
The parties hereto mutually agree that they have
effected a satisfactory division of the furniture, household
furnishings, appliances and other household personal property
between them, and they mutually agree that each party shall from
and after the date hereof be the sole and separate owner of all
such tangible personal property presently in his or her posses-
sion, whether said property is heretofore owned jointly or
individually by the parties hereto, and this Agreement shall have
the effect of an assignment or bill of sale from each party to
the other for such property as may be in the individual posses-
sions of each of the parties hereto.
The parties hereto have divided between themselves, to
their mutuul satisfaction, all items of tangible and intangible
marital property. Neither party shall make any claim to any such
5
items of marital property, or of the separate personal property
of sither party, which are now in the posseasion and/or under the
control of the other.
From and after the date of the aigning of this Agree-
ment both partiea shall have complete freedom of disposition as
to their separate 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
real or personal, whether ouch property was acquired before,
during or after marriage, and neither Husband nor Wife need join
inr consent to, or acknowledge any deed, mortgage, or other
instrument of the other pertaining to such disposition of
property.
6. REAL ESTATE
Wife agrees to transfer her right, title and interest
in and to the parcel of jointly-owned real estate with improve-
ments thereon situate at 388 reach Glen Road, Gardners, Pennsyl-
vania, to Husband and to sign all documenta necessary to effect
said transfer of the title to the real estate to his nams in-
dividually.
As consideration for tho aforesaid conveyance, Husband shall
pay Wife an amount of Fifteen Thousand Dollars ($15,000.00) Which
the parties acknowI edge to be the val ue of Wire's equi table share
6
in the real estate. Husband and Wife agree that tho documents
necessary to transfet. title from Husband and Wife to Husband to
the jointly-owned real estate shall be signed simultaneously with
the transfer of title and payment of the aforementioned amount of
rifteen Thousand Dollars ($15,000.00) from Husband to Wife.
Husband further agrees to satisfY and save Wife harm-
less from any obligation which she may be liable as a result of
the mortgage on the jointly-owned real estate in favor of PNC
Mortgage corporation, said mortgage being recorded in the Cumber-
land county Recorder of Deeds Off ice. Husband agrees that upon
delivery of the deed to the jointly-owned real estate, he will
continue to make the mortgage payments and will indemnify Wife on
account of any obligation ahe may have to PNC Mortgage corpora-
tion on account of the mortgage or mortgages, as well as any
other obligation concerning the ownership of the real estate
including, but not being limited to, municipal liens, real estate
taxes, sewer and water assessments, fire and casualty insurance,
and utilities. Furthermore, Husband agrees to satiSfY the
present mortgage or cause Wife's name to be removed from the note
and/or mortgage through refinancing or any other method of
payment within Ninety ('.10) days from the date of thla ^qreement.
Husband and Wife further aqree that they shall each
aBBume liability for his or her rospective share of any capital
7
gains taxes which may be assessed hereafter as the result of a
sale of the above described real estate, and it is further agreed
between the parties that they shall satisfy their respective
liabilities, at their respective options, by qualifying for an
exemption or by paying any taxes due.
7. t10TOR VEHICLES
The parties hereto agree that Wife s~all be entitled to
have the sole and exclusive control, benefit, use and title of
the 1994 Oldsmobile Achieva, and that she shall further assume
full responsibility and liability for the car loan on the 1994
Oldsmobile Achieva with Dauphin Deposit nank and Trust Company.
The partiea hereto agree that Husband shall be entitled to have
the sole and exclusive control, benefit, use and title of the
1992 Pontiac Bonneville, 1989 Mazda J2J and the 1987 Chevrolet
Truck. Husband shall assume full responsibility and liability
for the car loan on the 1992 Pontiac Bonneville with Dauphin
Deposit Bank and Trust Company
a. MISCELI~NEOUS
(A) The parties hereto acknowledge and agree that any
and all savings and checking accounts, as well as certificates of
deposit, owned by them jointly or singlYr have been divided to
their mutual and individual satisfaction.
8
(B) Neither party hereto shall make a claim upon the
other for accumulated pension, profit-sharing, retirement sup-
portr retirement benefits, insurance policies, IRA's, or any
retirement-related benefits.
(e) The parties hereto acknowledge and agree that any
and all life insurance policies owned by them jointly or singlY
have been divided to their mutual and individual satisfaction.
Each party hereto acknowledges that they have in their sole
possession those policy or policies of life insurance which they
intend to keep and retain as their sole and exclusive property
and, further, each party shall have the right to designate the
beneficiaries of said policios.
(0) The division of existing marital property is not,
except as otherwise expresslY provided herein, intended by the
parties to constitute in any way, a Bale or exchange of assets
and the division is being affected without the introduction of
outside funds or other property not constituting a part of the
marital estate. AS a part of an equitabls division of the
marital properties and the marital Bettlement herein contained,
the parties hereto agree tu save and hold each other harmless
from all income taxeS assessed against the other resulting from
the division of the property as herein provided.
9
9. DEBTS OF HUSBAND AND WIFE
The parties hereto agree that any and all obligations
incurred subsequent to the date of separation, said date being
March 19, 1995, shall be the sole and individual responsibility
of the party incurring the obligation.
Husband represents and warrants to Wife that from the
signing of this Agreement and in the future he will not contract
or incur any debt or liability for which Wife or her estate might
be resronsible and shall indemnify and save harmless Wife from
any and all claims or demands made against her by reason of debts
or obligations incurred by him.
Wife represents and warrants to Husband that from the
signing of this Agreement 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.
10. SUI'I'OH'l' fOR CHIlJlli.t1!
The parties hereto acknowledge that all issuee concern-
ing the Bupport of the minor children are presently resolved.
Both parties further acknowledqe ,lnd understand that either
party, or their children, may pursue an action for child support
against either parentr if necessary.
10
11. PENSIONS
Husband and Wife acknowledge that each party is en-
titled to receive a retirement benefit through a civil Service
Retirement system Pension and/or Thrift savings Plan maintained
by their employer, DrAS. After being fully advised of the
contente of the Divorce Code, both parties voluntarily and
intelligently waive and relinquish any right to seck or claim
from the other payment of any form of retirement benefit through
their present employers or otherwise, and it is specifically
intended by the parties that each shall be entitled to the full
value of his or her respective pension upon retirement from DrAB.
12. ALIM9N'i. 6UPPQRT AND MAIN1'ENANCE
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 ar~
accspted by them in lieu of and in full and final satisfaction of
any claims or demands that either may now or hereafter have
against the other for support, maintenance or alimony. Husband
and Wife further, voluntarily and intelligently, waive and
relinquish any right to seek from the other any payment for
Bupport, alimony and maintenance and, further, waive and relin-
quish any rights to division of property, other than provided In
this Agreement and, tinally, waive any rights to alimony pendente
11
lite, counsel fees and court costs.
Husband and Wife both agree that they have been
respectively advised and are aware of the contents of the
provisions of the Divorce Coder Act of April 2, 1980, P.L. 63,
Act No. 26, illL.amencteg, in Pennsylvania, whet'ein considerations
are set forth in determining an appropriate amount, if any, to be
paid in the form of alimony. After being fully advised of the
contente of the Divorce Code, as amended, both parties voluntari-
ly and intelligently waive and relinquish any right to seek from
the other payment for support, alimony and maintenance.
13 . MY'l'U A L HE LEMi];;
subject to the provisions of this Agreement, each party
waives his or her right to alimony and further distribution of
property inasmuch as the parties hereto agree that this Agreement
providee for an equitable distribution of their marital property
in accordance with the Divorce code, as amended. subject to the
provisions of this Agreement, each party has released and dis-
charged 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, claimsr rights or demands what-
sosver 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
12
action for divorce or except in any or all causes of action for
breach of any provisions of this Agreement. Each party also
waives their right to request marital counseling pursuant to
Section 3302 of the Divorce Code.
14. SUBSEQUENT DIVORCE
A decree in divorce entered by a court of competent
jurisdiction to either party shall not suspend, supersede or
affect the terms of this Agreement. Both parties agree, if
requested, to enter a Consent Order or Orders concerning the
provisions of this Agreement in the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent
jurisdiction, as a part of a resolution of any divorce action
filed or to be filed. This Agreement, and the terms and
conditions contained herein, as well as the enforcement of said
terms and conditions, shall be contingent upon the granting of a
Divorce Decree to either party by the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent
juriSdiction. Furthermore, both parties hereto agree, if
requested, to execute the appropriate affidavits and consents to
secure a NO-fault Divorce as may be required by the Divorce Code,
as amended. Both parties hereto agree that this Agreement may be
incorporated into a separate Court Order but shall not merge in
such order.
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15. 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.
Husband and Wife acknowledge and agree that the provisions of
this Agreement with respect to the distribution and division of
marital and separate property are fair, equitable and
satisfactory to them based on the length of their marriage and
other relevant factors which have been taken into consideration
by the parties. Both parties hereby accept the provisions of
this Agreement with respect to the division of property in lieu
of and in full and final settlement and satisfaction of all
olaims and demands that they may now have or hereafter have
against the other for equitable distribution of their property by
any court of competent jurisdiction pursuant to section 3502 of
the Divorce Code or any amendments thereto. Husband and Wife
each voluntarily and intelligently waive and relinquish any right
to seek a court ordered determination and distribution of marital
property, but nothing herein contained shall constitute a waiver
by either party of any rights to seek the relief of any court for
the purpose of enforcing the provisions of this Agreement.
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16. VOLUNTARY EXECUTION
The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective
counsel, and each party acknowledges that the Agreement is fair
and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not
the result of any duress or undue influence. The parties
acknowledge that they have been furnished with all information
relating to the financial affairs of the other which has been
requested by each of them or by their respective counsel.
17. ~DDITIONAL INSTRUMENTS
Husband and wife shall from time to time at the request
of the other I executs I acknowledge and deliver to the other party
any and all further instruments that may be reasonably required
to give full force and sffect to the conditions of this Agree-
ment.
18. MODIFICI\'l'ION AND WAIVER
Any 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 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. The
15
waiver of any term, condition, clause or provision of this
Agreement shall in no way be deemed or construed as a waiver of
any other term, condition, clause or provision of this Agreement.
19. BREACH
If either party hereto breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for such breach, or seek other remedies or
relief as may be available to him or her. Both parties agree and
are aware that non-compliance with any provision of this Agree-
ment permits either party to pursue appropriate legal remedies,
including sanctions as set forth in 23 Pa. C.B.A. ~3105.
Each party further hereby agrees to save and hold
harmless the other party from any and all attorneys' fess, costs
and legal expenses and expenses that either may sustain, or incur
or become liable or answerable for, in any way whatsoever, or
shall pay upon, or in consequence of, any default or breach by
the other of any of the terms or provisions of this Agreement by
reason of which either party shall or shall be obliged to retain
or engage counsel to initiate or maintain or defend proceedings
against the other at law or equity or both or in any way what-
soever, provided that the party who seeks to recover such
attorneys' fees, costs and legal expenses and expenses must first
be successful in whole or in part, bofore there would be any
16
liability for attorneyu' fooo, conts, logal expenses and
expenses. It In tllo upeclflc ngreoment and Intent of the parties
that a bronching or wrunlJdolnlJ IJlU"ty ohnll boar the burdon and
obligation of any nnd all COOILl and expensos and counsel fees
incurred by tho othor p"rty In enuollvorlng to protect and enforce
his or her rights und01" this ^<Jrooment.
All romodlen provided by law and all remedies provided
tor in this Agreomont for onfurcement of the Agreement shall be
deemed to be cumulative and the exercise of one remedy shall not
bar or prevent the pursuit of any other remedy and either party
may elect to pursue such remedies simultaneously and the exercise
ot a remody ono or more tlmos shnll not exhaust its use or
prevant furthor pursuit of such romody.
20 . u.EJ,l.J;:lUf1'.1'lJLlillADllim2
The descriptive hendlngs uood heroin are for
convenience only. They shall not have any effect whatsoever in
determining tho dghts or obi igations of the parties.
21. illD~l'ImULl!'l:JiLI'ABA'rE COVENAlITfi
It In specifically understood and agreed by and between
the part IDS heroto that each paragraph hereof shall be deemed to
be a lIoparato nnd indopendent covenant and agreement.
17
EVELYN L. DOYI,E,
Defendant
IN TilE COURT Ot' COMMON PLEAS O~.
CUMBERLAND COUN1'Y, PENNSYLVANIA
CIVIL ACTION - LAW
(It;- .:l'+).~
NO. CIVIL TEllM
IN IJI VORCE
STANLEY W. DOYLE,
plainti ff
VB,
JiQf1.CILTQ,.j)H!ND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the
claims set forth in the following pages, you must take prompt action.
You are warned that If you fail to do so, the case may proceed against
you and a decree in divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other
claim or relief requested in these papers by the Plaintiff. You may
lose money or property or other rights important to you, inclUding
cuetody or visitation with your children.
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A list
ot marriage counselors is available in the Office of the Prothonotary
at the Cumberland County courthouse, carlisle, Pennsylvania.
It' YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION Ot' PROPER1'Y,
LAWYER'S t'EES OR EXPENSES IlEt'ORE A DIVORCE OR ANNULMENT IS GRANTED, YOU
MAY WSE TilE nIGII1' '1'0 CLAIM ANY ot' TIIEM.
YOU SIIOULD TAKE '1'1118 PAPER 1'0 YOUR LAWYEH AT ONCE. 11' yOU DO NOT
IIAVE A LAWYER on CANNOT AFFORD ONE, GO '1'0 on 1'ELEPIIONE 'I'IIE OFFICE SET
t'ORTII DEWW TO FIND OUT WIIERE YOU CAN GET LEGAL IIELP.
court Administrator
~'ourth Floor
Cumberland County Courthouse
carlisle, Pennsylvllnla 1701)
(717) 240-6200
('/17) 6V7-0J'/l
uy I ^~hw~~:. 'Ilh~e~l y:~ ~~;ii\i J----- ---
PA. ) .D. Uo. 6246'.1 -
1 West Main utreet
!lhlremllnliltown, PA 1'7011
( ., 1 '/) '/ J'/ -II ., (, 1
Attorney tor PI/llntlff
STANLEY W. DOYLE, I IN 1'IIE COU/lT OF COMMON PLEAS OF
plaintiff I CUMnERLAND COUNTY, PENNSYLVANIA
I
vs. I CIVIL ACTION - LAW
I f~ - ,J 'f ,).,)
EVELYN L. DOYLE, I NO. CIVIL TEI{M
Defendant I IN DIVORCE
~LAtNT
1. Plaintiff is stanley W. Doyle, who currently reeides at 3BB
Peach Glen Road, Gardners, Cumberland county, Pennsylvania.
a. Defendant is Evelyn L. Doyle, who currently residee at 4717
Brian Road, Hechanicsburg, Cumberland county, Pennsylvania.
3. plaintiff and Defendant have been bona fide residents of the
CO\lll1lonwealth of Pennsylvania for at least sl)( (6) months immediately
previous to the filing of this complaint.
4. Plaintiff and Defendant were married on March 15, 1973, at
saint Thomas, ponnsylvania.
5. There have been no prior actions of divorce or annulment
between the parties.
6. Plaintiff has been advised of the availability of marriage
counseling and understands that he may have the right to request that
the court require the parties hereto to participate in counseling.
7. Plaintiff avers as the grounds upon which this action Is based
18 that I
(A) 1'hat the marriage hotween tho partiee hereto Is
irretrievably hroken and that the Plaintiff IInd lletondant have lived
separate IInd IIpart nltlt'1! Mlltch l'l, 199'> or, In Ull! IIlternalive,
(II) That l'llllntl fI' ilml Iletonllilnt ato now Ilvln(J separate and
i
t
r
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I
I
I
STANLF.Y W, OOYI,E, I IN TilE COUHT OF COMMON PLEAS OF
Plaintiff I CUMBEHLAND COUNTY, PENNSYLVANIA
I
VS. I CIVIL ACTION - I.J\W
I
EVELYN L. DOYLE, I NO. CIVIL TEIlM
Defendant I IN DIVOHCE
AUlDAVIT
S1'ANLEY W. DOYLE, being duly sworn according to law, deposes
and says:
(I) 1 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 Helations office, which list is available to
me upon requeet.
(l) 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 undsrstand that false statements herein are made subject to
the penalties of 18 l'a.C.S.A. Section 4904 relating to unsworn flIlsi-
tication to authorities.
I '
IJt~n{i~y: l~t'i,~Yl: )A.J I,
OWORN to al1\l suIJlH:r1bed before
me this, i'.L tiny of ),",f'l , l\llJ~.
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My comml.sion Explresl
NOIAHIAI ~IAI I
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EVELYN L. DOYLE,
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STANLEY W. DOYLE, I IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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vs. . CIVIL ACTION - LAW
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EVELYN L. DOYLE, . NO. 95-2428 CIVIL TERM
Defendant . IN DIVORCE
AFFIDAVIT OF IIRVIMa OOKPLAIMT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
ANDREW C. SHEELY, being duly sworn according to law depose. and
says that he caused the Complaint in the above-captioned matter to be
served by Certified Mail, Restricted Delivery, Return Receipt
Requested, as indicated by the attached receipt cards,
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An re c'. Sheely
SWORN to and subscribed before me
this, "Nil day of ~;~ ,,(;/01(/, l , 111115.
( ?l.J'J!i".'I .J
Notary Public ('
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NO 1 ARIAl L1Al
My COlllllliss1on EKpi res. CAflURINE J BARRA NOlARYPUBLlC
SHIREUANS'OWN BI\~I) ('Iil,l~ERl ~NO CO PA
W COMl,IlWON PI~Eb ~WI i.1I199
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vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-2428 CIVIL TERM
IN DIVORCE
STANLEY W. DOYLE,
plaintiff
EVELYN L. DOYLE,
Oefendant
AFFIDAVIT or COMSBNT
1. A Complaint in Oivorce under section 3301(c) of the
Divorce code was filed on Hay 5, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) 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's fees or expenses if I do not claim them
before II divorce decree 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 l'a.C.B.A. section 4904 relating to
unsworn falsification to the authorities.
DATE:
.7)~ /c;?-
/
JIc."f.t1 (J 'L)'~
STANLEY W. DOYLE