‘Let’s Get Married’: Description of Private Vows Sufficient to Establish Dispute of Common Law Marriage Under Pa. Law
“Moreover, Mr. Zadnik was, from the evidence, the only other person in the room when the purported common law wedding ceremony occurred. There was no officiant. Perhaps I said that too quickly. Let me repeat that. There was no officiant,” Circuit Judge Marilyn F. Bentley said from the bench, according to the opinion, that “There were no other witnesses; whether they be follow [sic] employees of either Mr. Zadnik or Ms. [Conway]; no neighbors; no friends; no siblings of Ms. [Conway]; no anyone.” and that the “‘testimony of one party alone is insufficient to confirm the existence of a valid and lawful marriage.'”
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