HomeMy WebLinkAbout96-01611
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81 IN THE COURT OF COMMON PLEAS .
81 8
81 OF CUMBERLAND COUNTY 8
8 ~ 8
:' STATE OF ~~ PENNA. :
* 8
8 8
8 CARLA A. COOK Plaintiff Nil. 1611 CivllTermll) 96 8
8 8
8 V"!".;!I; 8
8 PEnRY A. COOK 8
8 Defendant 8
8 8
~ ~
8 8
: DECREE IN ,
8 0. I V 0 R C E .A 'IJ:;I("'~ :
! AND NOW, ",..... .~-:-3...7.,.,.,. 19~,f(. it is ordered and *
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" 8.
!II decreed that.. .. . , (~AR~.A ,~.. ,cq9f-.. . , .. . ... ... , ..... . ... ..'. plaintiff,
~ PERRY A. COOK *
, and . , . . . . , . , . . . . , , . , . . . . , , . , , , . . , ' , . . . , . , . . . . . . . , . , , . . . . . . . '. defendant, ~
. are divorced from the bonds of matrimony. ~
. $
: The court retains jurisdiction of the following claims which have 8
" been raised of record in this action for which a final order has not yet 8
'" been entered; rJ ~ .
III 8
8 '!'!'1e, ,1:l?!,rJ,?ge. .$l!tql!me~t Ag:reeml;!!1t .fi!1,t.e.Z:l"\l.~I:I~O. ,1)l!.t.lo/el!I1, .tl:ll!. .IlfJ.rties 8
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_ ( ProtJlOnotary
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parties being estranged due to such marital difficulties;
and
WHEREAS, the parties hereto are desirous of
compromising and 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 of real and personal property; the implementation
of custody and visitation arrangements for the minor
children of the parties; and in general, the settling of any
and all claims and possible claims by one against the other
or against their respective estate, particularly those
responsibilities and rights growing out of the marriage
relationship, inter alia past, present or future spousal
support or maintenance, alimony pendente lite, alimony,
counsel fees and expenses, and equitable distribution,
whether or not the parties reside together; and
WHEREAS, the parties have made full disclosure to each
other of their assets and liabilities and have agreed on a
2
'--".'.'"-~"'.I
settlement of all property rights and differences existing
between them; and
WHEREAS, the parties intend this Agreement to be a full
and complete Marriage Settlement Agreement, providing for
the absolute and final settlement of all their respective
marital and property and all other claims.
NOW, THEREFORE, in consideration of the premises and of
the promises, covenants and undertakings hereinafter set
forth and for other good and valuable consideration, the
receipt of which is hereby acknowledged by each of the
parties hereto, Husband and Wife, each intending to be
legally bound hereby, covenant and agree as follows:
1. SEPARATION. It shall be lawful for each party, at
all times hereinafter, to live separate and apart from the
other, at such place or places as he or she may, from time
to time, choose or deem fit. Each party shall be free from
interference, authority or control by the other, as full 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 or attempt to endeavor
3
thereof, may be incorporated by reference into any divorce,
judgment or decree. This incorporation, however, shall not
be regarded as a merger, it being the specific intent of the
parties to permit this Agreement to survive any judgment and
to be forever binding and conclusive upon the parties.
2.
EFFECTIVE DATE.
The effective date of this
Agreement shall be the "date of execution", def;.ned as the
date upon which it is executed by the parties if they have
each executed the Agreement on the same date. Other wise,
the "date of execution" or "execution date" of this
Agreement shall be defined as the date of execution by the
party last executing this Agreement. Transfer of property,
funds and/or documents shall occur on the effective date
unless otherwise specified herein.
3 .
AGRJI!rnnrN'1' NOT A BAR TO DIVORCE.
This Agreement
shall not be considered to affect or bar the right of either
party to a divorce on lawful grounds as may be now or
hereafter available to either party. This Agreement is not
intended to be and shall not be a condonation on the part of
either party of any act or acts of either party hereto.
5
Both parties hereto agree that the marriage is irretrievably
broken and agree at tha time of execution hereof to execute
any and all affidavits or other documents necessary for the
parties to obtain an absolute divorce pursuant to Section
3301(c) of the Divorce Code. Each party waives the right to
request Court ordered counseling.
4.
DEBTS AND OBLIGATIONS.
Each party hereto
represents and warrants that he or she has not, and in the
future will not, contract or incur any debt, obligation or
liability for which the other party or his or her estate may
be responsible or liable, except as provided for in this
Agreement. Each party hereto agrees to be solely
responsible for the prompt and timely payment of the debts
now or hereafter incurred in his or her name and
specifically any debts secured by any automobile, motor
vehicle or other property distributed to her or him
hereunder. Each party hereto agrees to indemnify and hold
harmless
the other from any and all claims, debts,
obli3ations or demands made against him or her by reason of
debts or obligations incurred by him or her or identified to
be paid by him or her in this Agreement.
6
5. MUTUAL RBLKASBS. Husband and Wife hereby mutually
remise, release. quitclaim and forever discharge the other
and the estate of such other. for all time to come, and for
all purposes whatsoever, from any and all rights, title and
interest, or claims in or against the estate of such other,
or whatever nature and wherever situate, which he or she not
has or at any time hereafter may have against such other,
the estate of such other or any part thereof, whether
arising out of any former acts, contracts, engagements or
liabilities or such other or by way of dower or curtesy, of
claims in the nature of dower or curtesy, or widow's or
widower's rights, family exemption or similar allowance or
under the intestate laws; or the right to take against the
spouse's will; or the right to treat a lifetime conveyance
by the other as testamentary or all other rights of a
surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of Pennsylvania, any
state, commonwealth or territory of the United States, or
any other country; or any righ~s which either party may now
have or at any time hereafter have for past, present or
future support or maintenance, alimony, alimony pendente
7
lite, counsel fees, costs or expenses, whether arising as a
result of the marital relation or otherwise, except and only
except all rights and agreements and obligations of
whatsoever nature arising or which may arise under the
Agreement or for the breach of any provision thereof. It is
the intention of Husband and Wife to give to each other by
the execution of this Agreement a full, complete and general
release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or
may hereafter acquire, except, and only except, all rights
and agreements and obligations of whatsoever nature arising
or which may arise under this Agreement or for the breach of
any provision thereof. It is further agreed by each party
that this Agreement constitutes a full and final resolution
and settlement of all claims of any kind, and especially and
claims arising under the Pennsylvania Divorce Code, which
either party may have against the other.
6. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The
parties hereto agree that they have effected a mutually
satisfactory division of the furniture, household
furnishings, appliances and other personal property and
8
motor vehicles between them and neither party will make any
claim to any personal property now in the possession or
control of the other except as herein provided. Husband
hereby releases and relinquishes any right, title or
interest he may have t.ad in the past or now has in the
property in Wife's possession. wife agrees that Husband
shall, from and after the date hereof, be the sole and
separate owner of all personal property in Husband's
possession.
Wife hereby releases and relinquishes any
right, title or interest she may have had in the past or now
has in the property in Husband's possession. Husband agrees
that Wife shall, from and after the date hereof, be the sole
and separate owner of all personal property in Wife's
possession.
7.
PENSIONS AND RBTIREMENT ACCOUNTS.
The parties
hereto waive any and all interest or claims which either may
have in any individual retirement accounts, Keogh accounts,
existing pensions or similar accounts of the other,
including any retirement type accounts of Wife arising from
her employment with Harrisburg Academy, and any retirement
9
type accounts of Husband arising from his employment with
Big Bee Boats.
8. ALIMONY. Each party waives, releases and gives up
any claim, now or in the future, for any spousal support,
alimony, alimony pendente lite, or maintenance from the
other.
9 . BANK ACCOUNTS.
HUSBAND and WIFE each acknowledge
that they each own or possess certain bank accounts and
similar accounts of
financial
instruments
in their
respective names. They hereby agree that each shall become
sole owner of their respective accounts for financial
instruments and each hereby waives any interest in or claim
to any funds, instruments or accounts held by the other in
such instruments or accounts.
10. MOTOR VESICLES.
With respect to motor vehicles
owned by HUSBAND and WIFE, both of the parties agree as
follows:
The 1987 Chevrolet Celebrity shall be and remain the
sole and exclusive property of Wife;
\0
Each party shall be solely responsible for and debt
secured by any vehicle listed as his or her property. Each
party shall be solely responsible for any insurance and any
other costs, including license, for each motor vehicle
listed above as his or her property.
11. RIAL PROPERTY. The real property at 348 North 2nd
Street, Wormleysburg, Cumberland County, Pennsylvania, shall
become the sole property of husband, and wife shall forever
quit and release any current or future claim or right of
ownership or title.
Wife shall execute a Quitclaim Deed
upon the execution of this agreement, and further agrees to
sign, execute or acknowledge any additional documents,
instruments, or papers required for or necessary to the
transfer of title to husband. Wife agrees that she gives up
any and all right, title and interest to and in the
identified property, and agrees never to assert any claim to
said property in the future. Husband shall defend,
indemnify and hold harmless wife against any and all claim
or obligation that may result from a certain mortgag~
against said property that was executed by both husband and
wife.
Husband shall, at husband's expense, within sixty
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(60) days of the signing of this agreement, cause the
current mortgage that was executed by husband and wife to be
retired or to have Wife released from obligation by the
Mortgagee. All debt currently or in the future that
encumbers said property shall be the sole responsibility of
husband.
12. LIPE INSURANCE.
It is further understood and
agreed by the parties as follows:
(a) Husband shall maintain and keep in full force and
effect life insurance policies upon his life in the amount
of Sixty Thousand Dollars ($60,000.00), wherein the wife
shall be named irrevocable beneficiary until their youngest
child attains the age of eighteen (18) years of age.
(b) Husband shall provide proof of insurance coverage
as per this section on an annual basis to wife.
In the
event of the failure of husband to keep and maintain
coverage as provided above, wife may obtain coverage and
shall have the right to enforce repayment as provided for in
this agreement.
(c) Husband shall and hereby does surrender any and
all rights, title and interest is said policies on his life
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for the period herein designated, including the right to any
cash surrender value, the right to borrow thereon or any
other pecuniary right herein and husband covenants and
agrees not to impair the value of said policies upon his own
life in any way.
13. COUNSBL PEBS. Each party individually covenants
and agrees that he or she will individually assume the full
and sole responsibility for all other legal expenses for his
or her attorney, if any, and Court costs in connection with
the pending divorce action and shall make no claim against
the other for such costs or fees except as set forth in this
paragraph.
14. CUSTODY. VISITATION AND SUPPORT The parties agree
that Wife shall have primary physical custody of the
children, Perry Alexander Cook and Nicholas Allen Cook, and
the parties agree that they shall share the legal custody of
the children. However, Husband shall have liberal temporary
physical custody according to a schedule to be agreed upon
by the parties which shall be consistent with the best
interest and welfare of the said children.
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As a minimum, Husband shall have physical custody
according to the schedule set forth hereinbelow:
(a) Alternate weekends from Friday at 6 :00 p.m.
to Sunday at 6:00 p.m., and should Husband work during these
times, Husband will provide for the appropriate care of the
children.
(b) Husband shall have custody of the children
one evening during the week, from 4:00 p.m. through the
start of school the next day. Husband shall provide all
necessary care and transportation, and deliver the children
directly to the school, should it be in session.
(c) Husband shall have custody of the children
one evening during the week, from 4:00 p.m. until 9:00 p.m.
(d) Husband and Wife will alternate custody of
the children on the following holidays: Fourth of July. ,.
Labor Day, Thanksgiving Day, New Years Eve, Easter and
Memorial Day. The rotation will begin with Wife retaining
custody on July Fourth, 1997, New Years Eve, 1997, Memorial
Day, 1998 and Easter, 1998. When Husband has custody for
these holidays, it shall be during the following times:
(i) Thanksgiving from Wednesday 6:00
p.m. until Friday at 8:00 p.m.
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(ii) Labor Day weekend tram Friday 6:00
p.m. until Monday at 8:00 p.m.
(iii)Memorial Pay weekend tram Friday 6:00
p.m. until Monday 8,00 p.m.
(iv) Fourth of July tram 8:00 a.m. until
10,00 p.m. and tram 8:00 a.m. until
10,00 p.m. for each ot the weekend days
that is "art at the .July 4th weekend.
(v) New Years Eve from 5:00 p.m. until 8:00
p.m. New Years Day.
(vi) Easter weekend trom 5:00 p.m. until
Sunday 8:00 p.m.
(e) Husband and Wire will alternate custody of
the children on Christmas and Christmas Vacation as follows.
Wite sh~ll retain custody for Christmas 1997. Husband will
obtain custody tor the next Christmas beginning December 25
at 1:00 p.m. until December 26 at 8:00 p.m. The balance of
the custody tor the children's Christmas vacation shall be
divided evenly so that each parent will have custody and
provide for the children during those times.
(f) Holiday visitat ion will take precedence over
regular visitation.
"
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(g) Husband may have custody of the chi.ldren for
vacation for a period of fourteen days throughout the year,
such period to be scheduled with Wife at least three weeks
in advance, and if during periods where the children are to
be in school, with the prior approval of the school.
(h) Husband may have custody of the children at
such other times as husband and wife may agree upon.
Wife shall retain custody of the children on Mother's
Day weekend, and Husband shall have custody of the children
on Father's Day weekend, these weekends taking precedence
over regular visitation.
15. CHILDREN'S COLLEGE EDUCATION EXPENSES
If at the
time a child graduates from high school and said child is
accepted to attend a college or similar institution of
higher learning, Husband and Wife agree to share the costs
of such education, less scholarships and grants obtained by
the children, according to the following formula. If both
parties are working at full time employment at the time such
expenses are incurred, then the expenses shall be paid by
the parties in an amount proportionate with their respective
incomes. However, should one of the parties not be employed
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-petcent.ages,
t.ne
ot: det.ettl\ining
-pl.1t'POses
, inCotl\e
I.1netl\-plOyed -patt.Y s
t.he abO"e
Shall
be
t.hen tor t.he
at. t.he t. itl\e.
t.htee yeatS of
an a"erage of. t.he last.
obt.ain legal
t.O see\(. and
o'P'Pot:t.l.1nit.'1
1,1">.
"9teetl\ent. and
ot: t.his ...
t.ne 'PtO"isions
and t.neit
1'-9reetl\ent.
ell'Planat. ion ot
legal eHect..
legal et tect.
,..tLLtp.lo\ L. G\l.1Jl!Ia.
col.1nse 1. ..
~ ~SQtJW~'
counsel v.l'\tL't LOtlG l\O~~ '
he ot she haS tl\ade
co"enant.6 t.hat.
a
t:Ull
finanCial
res-pect.i"e -ptO-pert.'1'
each ac\(.no~ledge t.hat.
haS
diSClosute
of hiS 0" he"
t.o t.ne ot.het
l\USband and 'IIife
legal tight.S and
ot: t.his a9teetl\ent. and
holdings and inCotl\e.
underst.andS t.he faCt.S
each t:ullY
t.o het
t,,1.1.'1 int:ottl\ed as
been ~
and acce-Pt.S t.hat.
ac\(.no~ledgeS
patt.Y
0" hiS
fai" and equit.able
t.he citCUtl\st.ances,
and "olunt.a"ilY'
ent.eted int.o f teel Y
f t.his 1'-gteetl\ent. is
t.hat. ellecut.ion 0
it.
undl.1e influence and t.hat.
and eacn
obl igat. ions
t.nis ~gteetl\ent. in, in
and t.hat. it. is being
~it.h Sl.1ch \(.no~ledge and
dl.1"eSs ot
~eSult. of anY
nOt. t.he .
\1
"nus'OO 0< """o.e< 0< ,negat
is not. t.he result. of anY
agreement. or agreement.s.
Each of t.he part.ies shall,
1,1.
at. t.he request. of t.he ot.her,
ellecut.e,
fUll force and ettect. t.o t.he
reasonablY required t.O give
including all papers necessarY
provisions of thiS ~greement.,
t.o t.ransfer t.it1,e.
Each part.y shall
oV" att .<0.e<t1' <eat, .e<souat 0<
hereaft.er independent.1Y
b him
of any ~ind. acquired y
milled. t.angible or int.angible,
1,8.
or her.
'<Iit.h
fUll pO'<ler t.o diSpose of t.he
same in
and for all purposes,
respect.s
as t.hough he or she '<Iere
unmarried.
all
d ellpress t.heir in~erest. t.hat. any
~he part.ies herebY agree an
h 11 be '<Iit.hin
fi~Ofie~t.Y under t.his ~greement. 5 a
t.ransfer of ..~ .. .
ann" tatiOO at toe DefiCit .eMttiOO .tt a.
t.he scope and .....~
1,9.
\8
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d to as "the Act." and specificallY
1984. hereinafter reterre
. .. "ct "ertainin9 to property transfers
the provisions o~ t..e ~ r
between spouses and former spouses.
'the partieS agree to
h documentS required bY
.,go and ,no any .,.e,'n" " " "
,h' ,n"'''' .e.enue ..,v'e' ,n apP'Y ,h' .e' ,0 "an.f'"
i i f gain and subject
und., ,h" .g,....n' .,'hnu' ,.e,gn , nn n
,n ,h' ea'<V-aV" ha'" p,n.",nn. nf ,h' .e'.
VCR A modification or waiver
20. 19DIV'I.C..ort9l1..1m "..1 .
t shall be effecti~e
n' anY nf ,he p,n.,.'nn' nf ,he ."ee..n
d t d with the same formality
onlY if made in writing an e~ecu e
as thiS Agreement.
The ,anu," nf ei'M' pa<'Y " ,,,,,,
f f the "rovisions of thiS
upnn ,he ."ie' ,.,'noaane' n any n ·
~greement
d as a ..'aiver of
shall not be construe ft
any
default of the same or similar nature.
subsequent
21.
1lJ'1'11l1r. ..t:l.1l1l:-att.
'thiS Agreement contains the
and there are nO
.n"" und.,.,anding n' ,h' pa,,'e..
. ntS or underta~ings other
representatiOns. warrant~es. covena
,han ,hn.e ..o,e."Y ..' fn,'h he,.,n.
\q
22. DBSCRIPTIVE HBADINGS. The descriptive headings
used herein are for convenience only. They shall have no
effect whatsoever in determining the rights or obligations
of the parties.
23. INDBPENDENT SBPARATB COVENANTS. It is specifically
understood and agreed by and between the parties hereto that
each paragraph hereof shall be deemed to be a separate and
independent agreement.
24. BREACH. If either party breaches any provision of
this Agreement, the other party shall have the right, at his
or her election, to sue for damages for such breach, to
terminate any further payments required to the other
hereunder or seek such other remedies or relief as may be
available to him or her, and the party breaching this
contract shall be responsible of payment of legal fees and
costs incurred by the other in enforcing their rights under
this Agreement. or in seeking such other remedies or relief
as may be available to him or her.
20
25.
DISCLOSURE OF FINANCES.
Each party hereto
confirms that he or she has relied on the completeness and
substantial accuracy of financial disclosures of the other
as an inducement to enter into the Agreement. The parties
acknowledge that there has been no formal discovery
conducted in their pending divorce action and that neither
has filed and Inventory and Appraisment as required by
Section 3505 (b) of the Pennaylvania Divorce Code. The
rights of either party to pursue a claim for equitable
distribution of any interest owned by the other party in an
asset prior to the date of execution hereof which interest
was not disclosed or known by the other party or. his or her
counsel prior to the execution of this Agreement is
expressly reserved.
26. APPLICABLB LAW. This Agreement shall be construed
under the laws of the Commonwealth of Pennsylvania.
27. VOID CLAUSES. If any term, condition, clause or
provision of this Agreement shall be determined or declared
to be void or invalid in law or otherwise,
then only that
term, condition, clause or provision shall be stricken from
21
this Agreement, and, in all other respects, this Agreement
shall be valid and continue in full force, effect and
operation.
IN WITNESS WHEREOP,
the parties have hereunto set
their hands and seals the day and year first above written.
Jj~8 >i
qdoj!o.~
rIa A. Cook
~'-~~
~u ff-
Perry A. Cook
22
.
ACDlOtfLBDGKlDIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS
On this the
_} L.
Of' >lIdAcX
, 1998, before me,
the undersigned officer, personally appeared PERRY A. COOK,
known to me ( or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and
acknowledged that he executed the same for the purposes
therein contained.
;") I
dnrL/deL ill ~!
Notary Public
MycortmLisaion expires:
Notarial Seal
,.I'Chena A. Crovle, Notary PubUc
Penn Twp" Perry County
'"I. commission Expires April 2. 2001
24
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IN THE COURT OF COHHON PLEAS
Carla A. Cook, .
.
Pllllntiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. : CIVIL DIVISION
:
Perry A. Gook, : NO.9li-1n11 CIVIL TERM
De fendiln t .
.
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
TrGnsmit the record, together with the following information to
the court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under S3301(c)
jjR~kt~<<kof the Divorce Code. (Strike out inapplicable section).
~. Date and manner of service of the complaint: 4-1-96
U!_~..-1'lail, certified, restricted delivery, return receipt, postage .prepaid
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit
by 5])Ol(c) of the Divorce Code: by plaintiff
by defendant 3-26-98
(b)(l) Date of execution of the
of the Divorce Code:
of consent required
3-16-98
affidavit required by
: (2) Date of filing
S330l(d)
and
service of the plaintiff's affidavit upon the r~spondent:
4. Related claims pending: None
5. Complete either (a) or (b).
(a) Date alld manner of service of the notice of intention to
fj1e praecipe to transmit record, a copy of which is attached:
(b) Date plaintiff's
filed with the Prothonctary:
Date defendant's
filed with the Prothonotary:
Waiver of Notice in S330l(c) Divorce waB
4-;)-98
Waiver of Notice in S330l(c) Divorce waa
4-2-98
, /\,.
, ',,' fL, {j\, Ie
\ u \." ~' 1 ".- .- f- .-:> .
Attorney for (Plaintiff)(oefendantJ
.
.
.
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CARLA COOK,
Plaintiff
v.
I IN THE COURT OF COMMON PLEAS
I CUMDERLAND COUNTY, PENNSYLVANIA
I
NO. 910 ~ /(.,/1 (',UI'( /( /L"/
I
I CIVIL ACTION - LAW
I IN DIVORCE
PERRY COOK,
Defendant
COJCPLAINT
COUNT I
DIVORCE UNDER SECTION 3301 (C) OR 3301 (D)
or THE DIVORCE CODE
1. Plaintiff is Carla Cook, an adult individual who is sui
juris and residea at 348 North 2nd Street, Wormleysburg, Cumberland
County, Pennsylvania 17043.
2. Defendant is Perry Cook, an adult individual who is sui
juris and resides at 348 North 2nd Street, Wormleysburg, Cumberland
County, Pennsylvania 17043.
3. Both Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 24,
1986 in Murrysville, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
WHEREFORE, Plaintiff requests the Court to enter a Decreel
A. dissolving the marriage between the Plaintiff and
Defendant;
B. equitably distributing all property owned by the
parties hereto; and
C. for such further relief as the Court may determine
equitable and just.
Respectfull submitted,
Datel
.1./Q - ?(,
ATTORNEY FOR PLAINTIFF
3
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VERIFICATION
Upon my personal knowledge or information and belief, I hereby
verify that the facts averred in the foregoing Complaint are true
and correct to the best of my knowledge, information and belief.
I understand that false statements or averments therein made will
subject me to the criminal penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Datel
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I verify that I have reviewed this form with my client and to
the best of my knowledge the allegations herein are true and
correct.
JAY , ESQUIRE
1.29'L cust Street
P:O. ox 965
Harrisburg, PA 17108-0965
Attorney for Plaintiff
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CARLA COOK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
v.
NO. 96-1611 Civil Term
PERRY COOK,
Defendan1
CIVIL ACTION - LAW
IN DIVORCE
TO THE PROTHONOTARY:
Please en1er my appearance on beh:alf of Defendant, Perry Cook, in the above-
captioned action.
BY:
L
EMILY L. HOF AN, ES UIRE
Supreme Court 1.0. llI66307
METTE, EVANS & WOODSIDE
P.O. Box 5950
Harrisburg, PA 17110-0950
(717) 232-5000
Please withdraw my appearanca on behalf of Defendant, Perry Cook, in the
above-captioned action.
BY:
DATED: \ hell (1"'1
81239-1 ~
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CARLA A. COOK,
Plainriff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 96-1611 CIVIL TERM
PERRY A. COOK.
Defendanr
: CIVIL ACTION. LAW
: IN DIVORCE
AP'IDAVIT 0' SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
I, PERRY A. COOK, being duly sworn according to law,
depose and say that I am the defendant in the above
captioned action, and that I was served and accepted copy of
the Complaint in Divorce filed in the above matter, by
certified mail, return receipt requested, deliver to
addressee only, on April 1, 1996. I acknowledged receipt of
the same on April 1, 1996, as shown by the return receipt
card attached hereto as Exhibit "A".
~I () (;~
Perry A. Cook
Sworn to and SubscJ'ibed
b~~hiS ~0 day
of ~,WLf
Notary
(\
Notarial Seal
Mlc:/1e11e A. Crovle, Nolill'f Public
p",," Twp" Pe"V County
MV Comml;slon Expi,OI Apti12, 2001
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Plaintiff
: IN HIE COURT Of COMMON PLEAS Of
: CUMBERLAND COUNTY, PENNSYLVANIA
CARLA A. COOK.
v.
: NO. 96-1611 CIVIL TERM
Defendanl
: CIVIL ACTION - LAW
: IN DIVORCE
PERRY A. COOK.
WAIVBR 0. NOTICB 0. INTENTION TO RBOUEST
DIVORCB DECRBE UNDBR 3301(0) 0. THE DIVORCE CODB
1. I consent to the entry of a final decree of divorce
without notice.
2.
alimony,
I do not
I understand that I may lose rights concerning
division of property, lawyer'S fees or expenses if
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. ~4904
relating to unsworn falsification to authorities.
Date: .?;!fv~k~
L-
Cook. Plaintiff
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