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. IN THE COURT OF COMMON PLEAS ·
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. OF CUMBERLAND COUNTY 8
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. STATE OF ..v~. ;:} PENNA. 8
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8 ,I)EBRAK!. 13!'RELA,:! 8
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.....,' ... PJ.,A;IN'l';IFF 8
8 Vl'I'SlIS 8
8~LANS. B"RELA, , ' 8
8 DEFENDANT *
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. DECREE IN :
. decreed that DEB A.K.. BARELA.. .. .. .. .. .. .. . . .. .. .. . .. .. .. ., plaintiff, .
. and . r-.~~~. ~,...~!'~fi~~................................""'''' 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;
,.A.COp~,of..the.enclosed.property.,settlement.Ag~eement,.dated,
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to seek to have this Agreement merged into a decree of divorce, The Parties agree that the tenns
and conditions of this Agreement are to survive any court order or decree of divorce, and are to
be enforceable as the independent contractual obligations of the Parties after the entry of any such
order or decree,
I.O!!. Date of Marriage. The Parties were married on December 28, 1981, in
Muskingum County, Ohio, and ever since that date have been, nod are now, husband and wife.
1.06. Date of Separation. The Parties have been living separate and apart from each
other since October 6, 1995.
1.07. Children of Partle~'. The Parties have no children born to their union as of the
Date of this Agreement, and Wife is not now pregnant.
1.01. Separatloll of Parties alld Divorce Action. The Parties agree that grounds for
divorce from their bonds of matrimony currently exist, nod they are currently living separate and
apart. A complaint for the divorce of the Parties has been filed in the Court of Common Pleas of
Cumberland County, Pennsylvania, (at docket number 95-6237 Civil Tenn) and is now pending.
ARTICLE n.
PURPOSE OF AGREEMENT AND EFFECTIVE DATE
2.01. Settlement of Property. It is the purpose and intent of this Agreement to settle
forever and completely the interests and obligations of the Parties in all property that they own
separately, and III property that would quality as marital property under Section 3501 of the
Pennsylvania Domestic Relations Code and that is referred to in this Agreement as "marital
property", as between themselves, their heirs, and assigns. The Parties have attempted to divide
their marital property in a manner that confonns to a just and fair standard, with due regard to the
rights of each Party. The parties have attempted to divide their marital property in a manner
which confonns to the criteria set forth in Section 3502 of the Pennsylvania Domestic Relations
Code, taking into account the following considerations: the length of the marriage; the age,
health, station, amount and sources of income, vocational skills, employability, estate, liabilities,
and need for each of the parties; the opportunity of each party for future acquisition of capital
assets and income; the sources of income of both parties, including, but not limited to medical,
retirement, insurance or other benefits; the contribution or dissipation of each party in the
acquisition, preservation, depreciation, or appreciation of marital property; the value of the
property set apart to each party; and the standard of living of the parties established during their
marriage.
20f13
.
The division of marital property is not intended by the Parties to constitute in any way a sale or
exchange of assets, and the division is being effected without the introduction of outside funds or
other property not constituting a part of the marital property.
2.02. Support of Spouses. As long as Wife remains in the employ of Husband, the
Parties intend by this Agreement to allocate sufficient property and income to each so as to
provide completely for all needs of each for future support. If Wife is no longer in the employ of
Husband and did not leave such employment of her own volition, Husband agrees to pay Wife a
weekly sum equal to the highest fixed weekly pay rate she received during her employment with
Husband.
2.03. Effective Date. This Agreement shall become effective on the date signed by
Husband, Alan S. Barela.
2.04. Effect of Reconciliation. If, after the divorce of the Parties is final, they reconcile
and resume cohabitation, regardless of whether they subsequently remarry each other, this
Agreement shall remain in full force and effect.
ARTICLE W.
DISCLOSURES
3.01. Warranty of Full Disclosure. Each Party represents and warrants that he or she
hu made a full and fair disclosure to the other of all of his or her property interests of any nature,
including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to
which any property is subject. Each Party further represents that he or she has made a full and
tiir disclosure to the other of all debts and obligations of any nature for which he or she is
currently liable or may become liable, Each Party further represents and warrants that he or she
hu not made any gift or transfer for inadequate consideration of marital property without the
prior consent of the other. No representation or warranty by either Party in this Agreement or in
any writing furnished pursuant to this Agreement contains any untrue statement of a material fact,
or omits any material fact required to make the statement not misleading.
3.02. Continued Validity of Marital Property. Between the date of separation and the
date of this Agreement, neither Party has:
(a) Incurred any obligations or liabilities except current liabilities incurred in their
individual capacities,
(b) Mortgaged or encumbered nny marital property, tnngible or intangible.
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(c) Canceled any debt or claim or sold or transferred any marital property.
(d) Suffered any damage, destruction, or loss, whether or not covered by insurance,
aft'ecting marital property, business, or prospects, or waived any jointly held right
of substantial value.
(e) Entered into any transaction in any way related to any marital property other than
in the ordinary course of business.
Since the date of separation, there has been no event or change in condition, financial or
otherwise, materially alfecting the value of any marital property, other than changes in the
ordinary course of business.
3.03. Access to Tax RetunlS. Each Party acknowledges that, to the extent desired, he or
she has had access to all joint and separate state nnd federal tax returns filed by or on behalf of
either or both Parties during marriage.
3.04. Litigation. There are no actions or proceedings pending against either Party or
invo1vins any marital property at law or in equity or before any tederal, state, municipal, or other
governmental body. Neither Party is aware of any facts that might result in any action, suit, or
proceeding lpinst either Party or against nny marital property. Neither Party is in default with
respect to any order or decree of any court or of any governmental body, and no marital property
is liable for the payment of any obligation by order or decree of any court or governmental body.
3.0S. Filing of Tax RetunlS. All federal, state, and local tax returns required to be filed
by the Parties have been filed, and all federal, state, and local taxes required to be paid with
respect to the periods covered by the returns have been paid. Neither Party has been delinquent in
the payment of any tax, assessment, or governmental charge. Neither Party has had any tax
deficiency proposed or assessed against him or her, nor has eKecuted any waiver of the statute of
limitations on the assessment or collection of any tax.
3.06. TItle to Properties "lid Assets. All marital property has good and marketable title.
No marital property is subject to any mortgage, encumbrnnce, or restrictions, eKcept as disclosed
heretofore as securing specified liabilities.
ARTICLE IV.
CONFIRMATION OF SEPARATE PROPERTY AND SEPARATE DEBTS.
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4.01. Husballd's Separale Properly. The Parties confirm that the following property is,
at all times during marriage was, and shall after divorce remain, the separate property of Husband:
(a) Sundry items of personal property that are not specifically enumerated in the instant
Agreement.
(b) Ford pickup truck
The Parties funher confirm that nny income from and increases in value in this separate propeny
that accrued during marriage were solely due to reasons wholly independent from any
contribution made by Wife, and that this income nnd appreciation in value is the separate property
of Hushand.
4.02. Wife's Separale Properly. The Parties confirm that the following property is, at all
times during was, and shall after divorce remain, the separate propeny of Wife:
(a) Sundry items of personal propeny that are not specifically enumerated in the instant
Agreement.
(b) Two (2) motorcycles
The Parties further confirm that any income frc n and increases in value in this separate property
that accrued during marriage were solely due to reasons wholly independent from any
contribution made by Husband, and that this income and appreciation in value is the separate
property of Wife.
4.03. Separale Property of Husballd with Marltallllleresl. The Parties confirm that the
following property is, at all times during marriage was, nnd shall after divorce remain, the separate
property of Husband:
(a) None
However, the Parties confirm that the wnount of SO represents appreciation in value of this
separate property that accrued because of the contributions of Wife to the marriage. This wnount
is to be considered as marital propeny and subject to the equitable division of marital property as
set forth in Article Y of this Agreement.
4.04. Separale Properly of Wife with Marital III/eresl. The Parties confirm that the
following property is, at all time during marriage was, and shall lifter divorce remain, the separate
property of Wife:
(a) None
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However, the Parties confinn that the wnount of $0 represents appreciation in value of this
separate property that accrued because of the contributions of Husband to the mBJTiage. This
wnount is to be considered l\S marital property and subject to the equitable division of marital
property as set forth in Articles V of this Agreement,
".OS. Release of Interest In Separate Property. Except as set forth in Paragraphs ".03
and ".04, each Party releases forever any claim to or interest in the separate property of the other
as set forth in this Article IV, whether the interest might arise incident to the marital relationship
or otherwise.
".06. Separate Debts of Husballd The Parties conlinn that the following debts and
obligations are, at all time during mBJTiage were, nod after divorce shall remain, the separate debts
of Husband:
<a> None
".07. Separate Debts of Wife. The Parties conlinn that the following debts and
obligations are, at all times during mBJTiage were, and after mBJTiage shall remain, the separate
debts of Wife:
<a> None
".01. bJdemnlty for Separate Debts. Each Party agrees to pay his or her separate debts
as set forth in Paragraphs ".06 and ".07 of this Agreement, Each agrees to hold the other
hann1eas from any and all liability on account of these separate debts and obligations. If any
claim, action, or proceeding seeking to hold the other Party liable on account of these debta and
obligations is instituted, the responsible Party will at his or her sole expense defend the other
Party, and indemnifY the other Party against noy loss that he or she incurs as a result of the claim,
action, or proceeding.
".09. Exemption from Equitable Distribution. Except as set forth in Paragraphs ".03
and ".04 of this Article concerning appreciation in value of separate property during marriage, the
Parties acknowledge that the existence of and value of all separate property, and the existence of
and wnount of all separate debts, as set forth in this Article, were not considered in detenninins
the division of the marital property of the Parties as set forth in Article Y of this Agreement or the
allocation of the joint debts of the Parties as set forth in Article VI.
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ARTICLE V.
DIVISION OF MARITAL PROPERTY
!5.01. Marital Property. All marital property of the Parties is subject to division in this
Agreement.
!5.02. Sundry Items. The Parties mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances, tools 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 property presently in his or her possession
whether said property was heretofore owned jointly or individually by the Parties hereto. 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 possession of each of the Parties hereto.
!5.03. Property to Wife. Wife shall receive from the marital property, to own and enjoy
as her separate property, the following described properties, rights, and interests:
(a) Olds Calais
(b) ~ of personal checking account
(c) ~ of joint savings account held at Mutual Federal Savings Bank
(d) $4,800 to payoff charged items relating to automobile and Olympic tickets
!5.04. Property to Husballd. Husband shall receive from the marital property, to own
and enjoy as his separate property, the following described properties, rights, and interests:
(a) Ford Escort
(b) Travel Trailer
(c) ~ of personal checking account
(d) ~ ofjoint savings account held at Mutual Federal Savings Bank
!5.0!5. Assumptlo" of E"cllmbra"ces and l"dem"lty. Each party assumes all
encumbrances and liens on all of the property transferred to him or her pursuant to this
Agreement as specified below. Each Party agrees to indemnify and hold the other Party harmless
from any claim or liability that the other Party may incur because of any encumbrances or liens. If
any claim, action, or proceeding seeking to hold the other Party liable on account of any lien or
encumbrance is instituted, the responsible Party will at his or her sole expense defend the other
Party, and indemnify the other Party against any loss that he or she incurs as a result of the claim,
action, or proceeding.
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Agreement. If any claim, action, or proceeding seeking to hold the other Party liable on account
of future debts and obligations is instituted, the responsible Party will at his or her sole expense
defend the other Party against it, and indemnitY the other Party against any loss that he or she
incurs as a result of the claim, action, or proceeding,
ARTICLE VII.
PAYMENT OF TAXES
7.01. Tax' Deficiencies and Refundsfor Prior Years. It is agreed that the Parties shall be
jointly liable for and shall pay any and all deficiencies in state and federal income taxes, including
penalties and interest, related to the joint income tax returns of the Parties for all years prior to
1995, and shall jointly be entitled to any refund due to the Parties for those years. Parties shall
jointly pay any and all costs of def~nding the Parties against any asserted deficiencies, or of
prosecuting any refund claims. Parties agree to cooperate fully in filing any and all necessary
pleadings and documents, including protests, petitions, refund claims, and powers ofattorney.
7.02. Tax' Returns for Year of Divorce. The Parties will file a joint return for calendar
year 1995, and shall jointly be responsible for the payment of taxes as reflected by the tax return.
Each Party agrees to continue to make all books, records, tax returns, journals, ledgers, and any
other bookkeeping or financial infonnation of any nature that pertain to the marriage available to
the other at any time after the judgment of divorce. Each Party shall be allowed to consult with
the accountants or tax counsel of the other for the purpcse of gathering any information necessary
for the preparation and filing of any tax return.
7.03. Tar on Dlspos/lions. Each Party agrees to bear his or her respective share of the
income tax consequences resulting from the sale or disposition of property to third parties
pursuant to this Agreement.i
ARTICLE VIII.
FEES AND COSTS
8.01. Allomeys' Fees and Other Costs. Husband agrees to pay the following fees of
counsel and other costs incurred in connection with the complaint for divorce and this Agreement:
. Costs associated with his own counsel.
. Filing fees.
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Wife asrees to pay the following fees of counsel and other costs incurred in connection with the
complaint for divorce and this Agreement:
. Costs associated with her own counsel.
. Filing fees.
The Parties agree that the following costs incurred in connection with the complaint for divorce
and this Agreement shall be divided equally between them:
. None
'.02. Limitation of Parties' Liabilities. Except as provided in Paragraph 8.01, neither
Party ahaI1 be liable to the other for any costs or fees incurred by the other in connection with the
negotiation, preparation, and execution of this Agreement and in connection with any action
initiated by either Party for the purpose of obtaining a decree of divorce of the Parties.
'.03. In the Event of Breach. In the event that either Party breaches any provision of
this Agreement, and the other Party retains counsel to assist in enforcing the tenns thereof, the
Parties hereby agree that the breaching Party will pay all attorney's fees, court costs and expenses
incurred by the other Party in enforcing the Agreement.
ARTICLE IX.
GENERAL PROVISIONS
9.01. Release of All Claims. Except as specifically set forth in this Agreement, each
Party to this Agreement releases the other from all claims, liabilities, debts, obligations, and causes
of action that have been incurred during the marriage between the Parties.
9.02. General Duty to Indemnify. Each Party represents and warrants to the other that
he or she has not incurred any debt, obligation, or other liability, other than those described in this
Agreement, on which the other Party is or may be liable. Each Party covenants that if any claim,
action, or proceeding is initiated seeking to hold the other Party liable for any debt, obligation,
liability, act, or omission related to the marriage of the Parties for which that Party is responsible
under the tenns of this Agreement, the responsible Party will, at his or her sole expense, defend
the other against the claim or action. In addition, each Party covenants that he or she will
indemnifY and hold harmless the other Party with respect to all damages resulting from the
proceeding.
Damages, as used in this Agreement, shall include any loss, cost, or their liability without
limitation that results from the prosecution of any claim, action, or demand. Damages shall also
include reasonable attorney fees nod other expenses incurred in the investigation or in the attempt
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to avoid the litigation, or in enforcing any right of indemnity. In addition, the damages must result
from any inaccurate representation made by or on behalf of either Party to the other in or pursuant
to this Agreement, or from a breach of any of the covenants, promises, or obligations made by or
incurred by either Party in or pursuant to this Agreement. Each Party agrees to give the other
prompt written notice of any demand, claim, or litigation that is threatened or instituted against
him or her and that might constitute the basis of a claim for indemnity pursuant to the terms of
this Paragraph.
9.03. Credit Cards and Accoullts. All existing charge accounts and credit cards in the
namea of Husband and Wife, or in the name of either of them under which the other may be
extended credit for purchases, shall be closed or surrendered to their issuer as of the effective date
of this Agreement.
9.04. Right to Live Separately and Free From Interference. The Parties shall live
separate and apart from each other. Neither Party shall interfere with the other Party in any
respect. Each Party may carry on and engage in any employment or their activity as he or she
may deem desirable for his or her sole use and benefit. Neither Party shall interfere with the use,
ownership, or disposition of any property now owned or subsequently acquired by the other.
9.05. Acts Prior to Entry of Divorce Decree. Each Party agrees that neither shall enter
into any transaction or perform any act that would constitute a breach of the representations,
warranties, or promises contained in this Agreement. Each Party will afford to the other, or his or
her representative, reasonable access, during normal business hours, to the books and records of
all marital property, and will cooperate in the examination. No examinations, however, shal1
constitute a waiver or relinquishment by either of the right to rely on the covenants,
representations and warrantieE of the other as provided in this Agreement. Each agrees to hold in
confidence all information so obtained, and any document or instrument obtained pursuant to this
Paragraph sha11 be held on an express trust for and on behalf ofthe other.
9.06. Nature and Survival of Representations and Warrallties. All statements of fact
contained in any document delivered by either Party to the other for information or reliance
pursuant to this Agreement shall be considered representations and warranties under this
Agreement. All representations and warranties of the Parties shall survive the entry of the divorce
decree.
9.07. Records of Marital Property. For a period of three (3) years following the date of
entry of the divorce decree, the books ofaccount nod records of all marital property pertaining to
all periods during marriage nod prior to the date of entry of the divorce decree shall be available
for reasonable inspection by e:ther Party or their representatives for use in coMection with any
lawful purpose.
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9.IS. Successors alld Assiglls. This Agreement, except as it otherwise expressly
provides, shall be binding on and shall inure to the benelit of the legatees, devisees, heirs,
executors, administrators, assigns, and successors in interest ofthe Parties.
.
9.16. Specific Performallce. This Agreement may be enforced by no action for specilic
performance.
9.17. Law Govemillg Agreemelll. This Agreement shall be governed by, and shall be
construed in accordance with, the laws of the Commonwealth of Pennsylvania.
IN WITNESS of this Agreement, the Parties set their hands and affix their seals on the
date(s) below, with the intent to be legally bound.
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DEBRA K. BARELA, Wife
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Witness 4"
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.<LAN S. BARELA, Husband
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSVL VANIA
DEBRA K. BARELA,
PlaintitT
CIVIL ACTION - LAW
IN DIVORCE
v.
ALAN S. BARELA,
NO. 95-6237
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record, together with the following infonnation, to the Court for
entry of a divorce decree:
1. Groundfor divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: certified mail, restricted delivery,
return receipt requested on October 31,1995. Signed for by Defendant on November 6, 1995.
3. Date of execution of the Affidavit of Conse'" required by Section 330J(c) of the
Divorce Code: by the PlaintitT -- March 19, 1996 (filed March 19, 1996); by the Defendant-
March 19, 1996 (filed March 19, 1996).
4. Related claims pending: No claims raised.
, ,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBRA K. BARELA,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
ALAN S. BARELA,
NO. 95- (, .:J " 1 Civil Tenn
Defendant
~91\WJ..\JNT UNDER SECflON >>Otic) OR
330tldl OF THE DIVORCE CODE
AND NOW, this 31st day of October 1995, comes the Plaintiff, Debra K. Barela, by
IIId through her attorney, Kathleen D. Keating, and files this Complaint in Divorce, IIId
ltItes u follows:
1. Plaintiff is Debra K. Barela, an adult individual, who currently resides at 190
Brownstone Park, Hummelstown, Dauphin County, Pennsylvania.
2. Defendant is Alan S. Barela, an adult individual, who currently resides at
Western Village Campground, 200 Greenview Drive, #235, Carlisle, Pennsylvania, 17013.
3. Plaintiff and Defendant have been bona fide residents in the Co~ of
Pennsylvania for at lcut six (6) months immediately previous to the filing ofthia ComplaInt.
4. Plaintiff and Defendant were married on December 28. 1981 In NoIwIoh.
Musldngum County, Ohio.
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5. There have been no prior actions of divorce or for annulment between the
parties.
6. Plaintiff has been advised that marriage counseling is available and that
PII1ntift' may have the right to request that the Court require the parties to participate in
CQUIIMIins. Having been so advised, the Plaintiff does not desire the Court to order
CQUIIMIins.
7. The marriage is irretrievably broken. The foregoing facts are averred and
brought under Sections 3301(c) or 3301(d) of the Divorce Code of 1980, u amended.
WHEREFOllB, Plaintift' requests Your Honorable Court to enter a decree in
divorce, divorcing Plaintiff from Defendant.
Respectfully submitted,
~~) ~,
thIeen D. Keating, Esquirl
Attorney J.D. II 66271
44 South Hanover Street
Carlisle, PA 17013
(717) 240-0145
Attorney for tbe Plaintiff
. .
VERIFICATION
I veritY that the statements set forth in the attached document are true and correct to
the best of my knowledge, information and belief. This Verification is made only as to the
fictual averments contained herein, and not to legal conclusions and avennents authored by
counsel In her capacity u attorney for the party or parties hereto. I understand that false
lltatements herein are made subject to the penalties of 18 Pa.C.S. fi4904, relating to
unsworn falsification to authorities.
f)d-. k kL
Debra K. Barela,
Plaintiff
. "
. II .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSVL VANIA
DEBRA K. BARELA,
Plaintiff
v.
CIVIL ACTION. LAW
IN DIVORCE
ALAN S. BARELA,
NO. 95-6237
Defendant
AFFIDAVIT OF CONSENT
1. A Compliant in divorce under Section 3301(c) of the Divorce Code was filed
on October 31,1995.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and more
than ninety (90) days have elapsed from the date of filing the Complaint in Divorce.
3. I COJllellt to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree,
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 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. fi 4904, relating
to unsworn falsification to authorities,
Date: J//"j 9 ?
, ,
~ A- &.(L
Debra K. Barela,
Plaintiff
t '. ~
. ,. .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSVL VANIA
DEBRA K. BARELA,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
ALAN S. BARELA,
NO. 95-6237
Defendant
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER 0330Ud OF THE DJVORCE CODE
1. I COlllellt to the entry ofa final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expensea in 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 veritY 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 Ps,C.S. fi4904 relating to unaworn
falsification to authorities.
Date: 1/19/ fj'~
C
1/d.. k ~
Debra K. Barela, .
Plaintiff
. .. .
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
\
\
DEBRA K. BARELA,
Plaintiff
CIVIL ACTION. LAW
IN DIVORCE
v.
ALAN s. BARELA,
NO. 95-6237 Civil Tenn
Ocfendant
CERTIFICATE OF SERVICE
AND NOW, this ~day of November 1995, I. Kathleen D. Keating, Esquire.
hereby certitY that the following person was served with a True and Correct copy of the
Divorce Complaint filed in the above-referenced matter.
The Divorce Complaint was mailed on October 25, 1995, but actual service took jllace
on November 6. 1995 by Ocfendant signing for a copy of the Divorce Complaint which was
nWIed in the United States Mail, Certified Mail -- Return Receipt Requested, Restricted
Delivery. postage Prepaid. addressed as follows:
Alan S. Barela
Western Village Campground
200 Greenview Drive, #235
Carlisle. P A 17013
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incolpOrated herein and made a part hereof.
~~ /JJ{~~
athleen D. Keating. Esq re
Attorney I.D. # 66271
44 South Hanover Street
Carlisle, PA 17013
(717) 240-0145
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Exhibit A
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ALAN s. BARELA.
NO. 95- 0,)31-
Civil Term
h
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBRA K. BARELA.
Plaintiff
CIVIL ACTION. LAW
IN DIVORCE
"
v.
Defendant
~FFlDA vrr
I, Debra K. Barela, being duly sworn according to law, depose and say:
1. I have been advised of the a... _l1ability of marriage counseling and understand that I
may request that the Court require that my spouse and 1 participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the
ProthonotarY's Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being hnnded down by the Court.
I understand that false statement herein made are subject to the penalties of 18 Pa. C.S.
fi4904 relating to unsworn falsification to authorities.
Dated: 1~.If''''
.G~ k A,;,~L
Debra K. Barela,
Plaintiff
. -......-
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBRA K. BARELA,
Plaintiff
CIVIL ACTION - LAW
IN DIVORCE
v.
ALAN S. BARELA,
Dcfendant
NO. 95-6237
Civil Tcnn
NOTICE OF ELECTION TO RETAKE PRIOR SURNAME
Notice is hereby givcn that thc Plaintiff in thc above-titled matter, having been granted a Final
Decree in Divorce from the bonds of matrimony on the 16th day of April, 1996, hcreby elects to
retake and hereafter used her previous name of Debra Kay Shepherd and givcs written notice
avowing her intention in accordance with the provisions of the Act of April 2, 1980, Pa. L. 63, No.
26 fi 702.
f)k I-: ~
Debra K. Barela
To Be Known As:
fJd- k,~lsJ
Debra Kay Sh6pherd
Commonwealth of ennsy1vania
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COUllty 0
On this, the 1J:rlldsy of~~ 996, before me, the undersigned officer, personally appeared
Debra K. Barela, known to me orsiltl~factorily proven to be the person whose name is subscribed to
the within instrument, and acknowledged that she executed the within instrument for the purpose
herein contained and with the intent to be legally bound,
NcunalSe.aI
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&.\'6tIraTVoI>.O...,.m
My Com"lsoIon E>p:r,~ Jon, 12. .
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