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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF * PENNA.
JEAN M. DREHOBLE,
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Plaintiff
Versus
DAVID W. DREHOBLE,
Defendant
DECREE IN
DIVORCE
ANDNOW,.,\~..~.....,......, 19.?~.... it is ordered and
decreed that ... ,~~~..~ ~ , P,~~~o.~~~. , .. , , .. .. .. .. . .. .. .. .. .. .. plaintiff,
and. "" ",?~V:l,o. ~.', .,?~~,1!9~~,~." '. '. ........... ............ defendant,
are dj'lOrced from the bonds of matrimony.
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; ~O~
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SEPARATION AND PROPERTY SETILEMENT AGREEMENT
THIS AGREEMENT, made this :).71l(day of .)JtJ~ ,1996, by and
between Jean M. Drehoble. hereinafter referred to as "Wife", and David W. Drehoble,
hereinafter referred to as "Husband".
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on January 24, 1969;
and
WHEREAS, certain differences have arisen between the parties as a result
of which they separated on or about May 31, 1996 and now live separate and apart from
one another, and are desirous, therefore, of entering into an Agreement which will
distribute thsir marital property in a manner which is considered to be an equitable
division of all joint property, and will prOvide for the mutual responsibilities and rights
growing out of the marriage relationship; and
WHEREAS, there has been a complete disclosure of the earnings and
property of each party, and each understands hislher rights under the Divorce Code of
the Conunonwealth of Pennsylvania; and
WHEREAS, the parties hereto, after being properly advised by their
respective counsel, Husband by his Attorney, Philip H. Spare and Wife by her attorney,
John W. Purcell, Jr. have come to ths agreement, which follows:
NOW, THEREFORE, in consideration of the above recitals and the followingI
covenants and promises mutually made and mutually to be kept, the parties heretofore,
intending to be legally bound, covenant, promise and agree as follows:
Separation and Property Settlement Agreement
1. Separation. It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place that he or sl'.e may from time to
time choose or deem fit. The foregoing provision shall not be taken as an admission on
the part of either party of the lawfulness of the causes leading to their living apart.
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 nor attempt to endeavor to molest the other, nor compel the othor to cohabit
with the other, nor in any way harass or malign the other, nor in any way interfere with
the peaceful existence, separate and apart from the other.
3. Wife's Debts. Wife repres'ilnts and warrants to Husband that since the
separation she has not and in the future shs will not contract or incur any debt or liability
for which Husband 01 his estate might be responsible and shall indemnify and save
Husband harmless from any and all claims or demands made against him by reason of
debts or obligations incurred by her.
4. Husband's Debts. Husband represents and warrants to Wife that since
the separation 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
Wife harmless from any and all claims or demands made against her by reason of debts
or obligations incurred by him.
5. Outstanding Joint Debts. The parties aclmowledge and agree that they
have no outstanding debts and obligations incurred prior to the signing of this
Agreement, except as follows; none
In the event that either party contracted or incurred any debts since tbs
date of separation, the party who incurred said debt shall be responsible for tbs payment
thereof. regardless of the name in which the account may have been charged, and such
party shall indemnify, defend and hold the other party harmless from any claim or
demand made against that party by reason of such debt.
6, Equitable Distribution of Marital Property. The parties have attempted
to distribute their marital property in a manner which conforms to the criteria set forth
Page 3
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Separation and Property Settlement Agreemont
Page 3
in !i3501 et. seq. of the Pennsylvania Divorce Code and taking into account the following
considerations: the length of marriage; the fact that it Is the first marriage for Husband
and Wife; the age, health, station, amount and sources of income, vocational skills,
employability, estate, liabilities and needs of each of the parties; the contribution of each
party to the education, training or increased earning power of the other party; the
opportunity of each party for future aCquisitions 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 the marital property, including
the contribution of each spouse as a homemaker; the value of the property set apart to
each party; the standard of living of the parties established during the marriage; and the
economic circumstanr:es of each party at the time the division of property Is to become
effective.
The division of existing marital property is not intended by the parties to
constitute In any way a sale or exchange of assets, and the division of being effected
without the introduction of outside funds or other property not constituting marital
property. The division of property under this Agreement shall be in full satisfaction of all
marital rights of the parties.
A. Distribution of Personal Property.
':'he 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 possession, 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 possession of each of the parties hereto.
The parties hereto have divided between themselves, to their mutual
satisfaction, all items of tangible and intangible marital property. Neither party shall
make any claim to any such items of marital property, or of the separate personal
property of either party, which are now in the possession and/or under the control of the
Sepor alion and Property Settlement Agreement
other, Should it become necessary, the parties each agree to sign, upon request, any
titLes ur documents necessary to give effect to this paragraph. Property shall be deemed
to be in the possession or under the control of either party if, in the case of tangible
personal property, the item is physically in the possession or control of the party at the
time of the signing of this Agreement and, in the case of intangible personal property,
if any physical or written evidence of ownership, such as passbook. checkbook, polley
or certificate of insurance or other slmllar writing is in the possession or control of the
party. Husband and Wife shall each be deemed to be in the possession and control of
their own individual pension or other employee benefit plans or retirement benefits of
any nature to which either party may have a vested or contingent right or interest at the
time of the signing of this Agreement, and neither will make any claim against the other
for any interest in such benefits, except as stated herein.
From and after the date of the signing of this Agreement, both parties shall
have complete freedom of disposition as to their separate property and any property
which is in their possession or control, pursuant to this Agreement, and may mortgage,
sell, grant, convey, or otherwise encwnber or dispose of such property, whether real or
personal, whether such property was aCquired before, during or after marriage, and
neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage,
or other instrument of the othsr pertaining to such disposition of property.
B. Distribution of Real Estate.
Wife shall transfer to Husband upon the entry of a Decree in Divorce all of
her interest in and title to their jointly owned real estate at 103 Hogestown Road,
Mechanicsburg, Pennsylvania 17055. in exchange for which Husband agrees to be solely
responsible for the mortgage obligation to Avstar (Husband agreeing to refinance the
current mortgage within 90 days of the entry of a Decree in Divorce) as well as for the
payment of all current and future taxes, insurance and utility bills relative to sald real
estate. Husband covenants and agrees to pay and discharge said obligations on said
premises, and agrees to indemnify Wife from any loss by reason of his default in the
payment thereof. and agrees to save Wife hannless from any futuro liability with reqard
Pogo 4
Separation and Property Settlement Agreement
Page 5
thereto, including the cost of defense and actual cOWlSel fees incurred to defend against
an action brought against her by virtue of his default.
C. Cash Distribution.
In addition to the transfer of the above referenced real estate, Wife shall pay
to Husband the sum of $17,500.00 upon the entry of a final Decree in Divorce.
7. Vehicles. Notwithstanding Paragraph 6 of this Agreement. Husband
shall retain possession and ownership of the 1987 Ford Aerostar Van presently in his
possession. Wife hereby transfers all of her right, title and interest in said vehicle to
Husband. In consideration thereof, Husband shall assume full responsibility for payment
and eventual satisfaction of any and all liens presently encumbeting the vehicle, and to
indemnify, defend and hold Wife harmless for the same. Wife hereby agrees to sign any
title or other documents necessary to transfer ownership of said vehicle at any time,
upon demand, and further shall indemnify Husband for any costs, including actual
cOWlSel fees, incurred by Husband to enforce this provision.
Notwithstanding Paragraph 6 of this Agreement, Wife shall retain
possession and ownership of the 1994 Geo Prism presently in her possession. Husband
hereby transfers all of his right, title and interest in said vehicle to Wife. In consideration
thereof, Wife shall assume full responsibility for payment and eventual satisfaction of any
and all liens presently cncumbeting the vehicle, and to indemnify, defend and hold
Husband harmless for the same. Husband hereby agrees to sign any title or other
documents necessary to transfer ownership of said vehicle at any time, upon demand,
and further shall indemnify Wife for any costs, including actual cOWlSel fees, incurred by
Wife to enforce this provision.
8. Alimony. Both parties acknowledge and agree that the provisions of this
Agreement providing for equitable distribution of marital property are fair, adsquate and
satisfactory to them, and are accepted by them in lieu of and in full and final settlement
and satisfaction of any claims or demands that either may now or hereafter have against
the other for support, maintenance or alimony. Husband and Wife further, voluntarily
and intelligently, waive and relinquish any right to seek from the other any payment for
support or alimony. Each party shall indemnify, defend and hold the other harmless
Separation and Property Settloment Agreement
Page 6
against any future action for either support. or alimony brought by or on behalf of the
other, such indemnity to Include the actual counsel fees of the defendant In any such
future action.
9. Business. Husband presently Is the sole owner of a wholesale crafts
business known as DWD Wholesale Distributors, located In his home, which includes
equipment, inventory, and related accessories for the conduct of business. Husband
shall keep the business as his own propeny exclusively, including all of tlle assets. Wife
hereby relinquishes all claim and right she may have to the business and all of the assets
under and pursuant to the Pennsylvania Divorce Code, and shall Indemnify, defend and
hold Husband for any future claims she may assen to said business and property located
therein and incidental thereto, such Indemnlflcatlon to include actual counsel fees
\'.)'i"'\~ _Incurred by Husband In defense of said claim. Husband shall be solely responsible for
'~ '" ~ all past, ~ present and future liabilities of the business, including tax liabilities and
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, .~ ~~eficlencle~and shall indemnify defend and hold Wife for any claims made against her
j on account of said business liabilities, such Indemnification to include actual counsel
fees Incurred by Wife In defense of said claims.
10. Alimony Pendente Lite, Counsel Fees and Expenses. Husband and
Wife aclmowledge and agree that the provisions of this Agreement providing for the
equitable distribution of marital property of the parties Is fair, adequate and satisfactory
to them. Both parties shall accept the provisions set fonh in this Agreement In lieu of
and in full and final settlement and satisfaction of all claims and demands that either
may now or hereafter have against the other for alimony pendente lite, counsel fees or
expenses, or any other provision for their suppon and maintenance before, during and
after the commencement of any proceedings for divorce or annulment between the
parties. Each party shall be responsible for his or her own counsel fees, and each agrees
to indemnify, defend and save the other harmless from any action commenced again6t
the other for alimony pendente lite, counsel fees and/or expenses.
11. Divorce. A Complaint in Divorce has been filed to No. 96-915 In the
Coun of Common Pleas of Cumberland County, Pennsylvania. and either party shall be
free to proceed without funher delay to secure the divorce. Both parties shall sign an
Separation and Property Settlement Agreement
Page 7
Affidavit evidencing their con.~ent to the divorce, pursl..lant to g3301@ of the Divorce
Code. In tt.e event, for whatever reason, either palty fails or refuses to execute such
affidavit upon the other palty's timely request, that palty shall indemnity, defend and
hold the other ha.tmless from any and all additional expenses, including actual counsel
fees resulting from any action brought to compel the refusing palty to consent. Each
palty hereby agrees that a legal or equitable action may be brought to compel him or her
to execute a Consent form and that, absent some breach of this Agreement by the
proceeding palty, there shall be no defense to such action asserted.
12. Time of Distribution. The assets and interests to be transferred under
and pursuant to this Agreement shall be conveyed and transferred to the respective
palties immediately upon the exectltion of this Agreement. All spousal support and
other such obligations, including alimony, shall immediately terminate. The parties shall
cooperate by executing whatever documents are necessary to effectuate a divorce under
g3301@ or g3301(d) of the PennsylVania Divorce Code, and this Agreement to cooperate
shall be enforceable by an assumpsit action for specific performance. However, upon
refusal to consent, all distributed property shall be returned to the palty originally in
possession, until the time of final Decree.
13. Release. Subject to the proviSions of this Agreement, each party has
released and discharged, and by this Agreement does for himself or herself, and his or
her heirs, legal representatives, executors. administrators and assigns, release,
indemnity (including actual legal fees) and discharge the other of and from all causes of
action, claims, rights. or demands, whatsoever in law or equity, including equitable
distribution, spousal support, alimony, counsel fees, alimony pendente lite, and expenses
which either of the palties against the other ever had. now has, or may have in the future
under the PennsylVania Divorce Code, as amended, or under any other statutory or
common law, except any and all causes of action for divorce and all causes of action for
breach of any provisions of this Agreement. Each party also waivss his or her right to
request marital couns~ling. pursuant to g3302 of the Divorce Code,
14. Waivers of Claims Against Estatss. Except as herein otherwise
provided, each palty may dispose of his or her property in any way. and each party
Separation and Proportv Sottlemont Agrooment
hereby waives and relinquishes any and all rights he or she may now have or hereafter
acquire under the present or future laws of any jurisdiction, to share in the property or
the estate of the other as a result of the marital relationship, Including without limitation,
dower, coUrtesy, statutory allowance, widow's allowance, right to take in intestacy, right
to take against the Will of the other, and right to act as administrator or executor of the
other's estate, and any right existing now or in the future under the Pennsylvania Divorce
Code, as amended from timo to time, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable
to carry into effect this mutual waiver and relinquishment of all such interests, rights and
claims,
15. Rights on Execution. Immediately upon the execution of this
Agreement, the rights of each party against the other, despite their continuing marital
status, shall terminate and be as if they were never married.
16. Breach. In the event of breach of any of the terms of this Agreement,
the nonbreaching party shall be paid, as part of any award or judgment against the
breaching party, all costs, including actual counsel fees paid to his or her attorney.
17. Incorporation in Final Divorce. The terms of this Agreement shall be
incorporated but shall not merge in the final divorce decree between the parties. This
Agreement shall swvive in its entirety resolving the spousal support, alimony, property
and other interests and rights of the parties under and pursuant to the Divorce Code of
the Commonwealth of Pennsylvania. This Agreement may be enforced independently
of any support order, divorce decree or judgment and its terms shall take precsdence
over same, remaining the primary obligation of each party. This Agreement shall remain
in full force and effect regardless of any change in the marital status of the parties. It is
warranted, covenanted and represented by Husband and Wife, each to the other, that
this Agreement is lawful and enforceable and this warranty, covenant and
representation is made for the specific purpose of indUCing the parties to execute the
Agreement.
18. Additional Instruments. Each of the parties shall from time to time, at
the request of the other, executa, aclmowledge and deliver to tho other party, any and
Page 8
SeparatIon and Property Settlement Agreement
Page 9
all further Instruments that may be reasonably required to give full force and effect to the
provisions of this Agreement.
19. Separability. In case any provision of this Agreement should be held
to be contrary to, or invalid under, the law of any country, state or other jurisdiction, such
Illegality and invalidity shall not in any way affect the other prOvisions hereof, all of
which shall continue, nevertheless, in full force and effect, and each paragraph herein
shall be deemed to be a separate and undisputed covenant and agreement.
20. Entire Agreement. This Agreement contains the entire understanding
of the parties and there are no representations, warranties, covenants and 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 claims 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 other laws.
Husband and wife each voluntarily and intelligently waive and relinquish any right to
seek a Court ordered determination and distribution of maritai 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.
21. Modification 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 insist upon strict
performance of the provisions of this Agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
22. Intent. It is the intent of the parties by this Agreement to fully and
finally foreclose any resort to the Courts for relief on the basis of any statute or case law
presently existing or which may exist at some time In the future within the
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Separation and Property Settlement Agreement
Page 10
Commonwealth of Pennsylvania, including but not limited to equitable distribution,
alimony and other relief under the Pennsylvania Divorce Code, as amended. This
Agreement has been drafted and accepted on the basis that such resort would
constitute a breach under this Agreement, entitling the nonbreaching party to
reimbursement for actual counsel fees. Other than as provided by the terms of this
instrument, it is intended that the Court shall treat the parties as If they had never
entered into a marital relationship. This Agreement shall be interpreted and governed
by the laws of the Commonwealth of Pennsylvania and, where such law Is inconsistent,
the terms of this instrument shall govern.
23. Voluntary Execution. The provisions of this Agreement and their legal
effect hav~ 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 financiai affairs of the other which hail been
requested by each of them or by their respective counsel.
24. Descriptive Headings. The deSCriptive headings used herein are for
convenience only. They shall have no effect whatsoever in detennining the rights or
obligations of the parties.
25. Agreement Binding on Heirs. This Agreement shall be binding and
shall inure to the benefit of the parties hereto, and their respective heirs, executors,
administrators, successors and asSigns.
OF, the parties hereto have hereunto set their hands
t above written.
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J M. DREHOBLE
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VB.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
JEAN M. DREHOBLE,
Plaintiff
DAVID W. DREHOBLE,
Defendant
NO. 96-915
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
THE PROTHONOTARY:
Transmit the record. together with the following infonnation, to the Court for entry ofa Divorce
Decree:
1. Ground for divorce: Irretrievable breakdown under Section (.I) 330 \( c) ( )330 1 (d)(1 ) of the
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Divorce Code.
2. Date and manner of service of the Complaint: Certified mall, February 22,1996
3. (Complete either paragraphs (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce
Code: by Plaintiff: June 28,1996
by Defendant: June 27,1996
(b) (I) Date of execution of the Plaintil1's Atlidavit required by Section 3301 (d) of the Divorce
Code: December 10.1995: N/A
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(2) date of service of the Defendant's Atlidavit upon the PlaintllT:
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of
which is attached, if the decree is 10 be entered under section~3 oflhe Divorce Code. N/A
C
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JOHN W. PURCELL. JR. ESQ.
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JEAN M, DREHOBLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9~' It / J- (I( ','I'C \) I P"\.__
CIVIL ACTION.LAW
IN DIVORCE
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VS.
DAVID W. DREHOBLE,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
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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 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 rnay lose money or
property or other rights important to you, including custody or visitation of your children.
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When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available
in the Office of the Court Administrator, Cumberland County Courthouse, Hanover Street,
Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
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, Fourth Floor
1 Courthouse Square
Carlisle, PA 17013 3387
(717) 240-6200
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VS,
DAVID W. DREHOBLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION-LAW
IN DIVORCE
i
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t,
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JEAN M, DREHOBLE,
Plaintiff
COMPLAINT
1. The Plaintiff is Jean M. Drehoble who resides at 103 Hogestown Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
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2. The Defendant is David W. Drehoble who resides at 103 Hogestown Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055,
3. The Plaintiff and Defendant have been bonafide residents in the Commonwealth
of Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 24, 1969, in Boise, Idaho.
5. There have been no prior actions of divorce or annulment between the parties.
6. Neither of the parties in this action is presently a member of the Armed Forces.
7. The Plaintiff and Defendant are both citizens of the United States.
8, The Plaintiff has been advised of the availability of marriage counseling and that
she may have the right to request the court to require the parties to participate in such
counseling, Being so advised, Plaintiff does not request that the court require the parties
to participate in counseling prior to a divorce decree being handed down by the court.
9. The Plaintiff avers the ground on which the action is based is that the marriage
is irretrievably broken.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
Purcell, Krug & Haller
BY
Uc-(~
J~h,/W. Purcell, Jr.
UY- #29955
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
,./
VERIFICATION
I verify thai the statements made in the foregoing Complaint In
Divor('!1!!!
are true and correct.
l understand thai false statemellts herein are made subject to the penalties oj'
18 Pa. C.S. 14904 relating to unswomfalsification to authorities.
Date: Feb. IS. 1996
199
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JEAN M, DREHOBLE,
Plaintiff
IN THE COllRT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 96 - 915 CIVIL TERM
VS.
DAVID W. DREHOBLE.
Defendant
CIVIL ACTION-LAW
IN DIVORCE
AFFIDA vrr OF SERVICE
COMMONWEALTH OF PENNSYLVANIA:
) ss:
COUNTY OF DAUPHIN
I. JOHN W. PURCELL, JR., Attorney for the Plaintiff in the above action, hereby swear and
affirm that on the 22 day of February, 1996, I sent, by flJ'st class, regular mail and certified mail,
return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce,
containing Notice to Defend and Claim Rights to David W. Drehoble, the Defendant in the above
action, The return receipt, duly signed by the Defendant is attached hereto and made a part hereof
as Exhibit" A". The Complaint mailed first class, regular mail was not returned.
J
Sworn and subscribed to
before me this _1 b day
of :L (~ ,,~, ~ ,1996.
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~Nolary Public
NOTAR1Al SEAl.
JANET n. WOLfE, NofaJJ f".bllc
Harrisburg, p.~ [\'Juph,n Coonty
My Comlnl,~i"r fxC,f,n s.;pl.., 1997
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EAhibil "A"
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JEAN M. DREHOBLE,
Plaintiff
VI.
DAVID W. DREHOBLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-915
CIVIL ACTION.LAW
IN DIVORCE
AFfiDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 Ie) of the divorce Code
was filed on December 2, 1 994.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of filing the Complaint.
3. I COMent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRV OF A DIVORCE DECREE UNDER
13301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is
entered by the Court and that a copy of the Decree will be sent to me immediately
after it is filed with the prothonotary.
I verify that the statements made In this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. 1 4904 relating to unsworn falsification to authorities.
Date: ~/.t1g/(n~
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(~~ tvl 'c.'-~
n M. Drehoble
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JEAN M. DREHOBLE,
Plaintiff
vs.
DA VID W. DREHOBLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-915
CIVIL ACTION-LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the divorce Code
wao filed on December 2, 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 after service of
notice of intention to request entry of the decree
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
!3301lc) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I 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 protl>onotary.
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. ! 4904 relating to unsworn falsification to authorities.
Date:
June 27. 1996
,~~
David W. Drehoble
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