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HomeMy WebLinkAbout96-01738 j ~ ~ j ~ J J i>e ~,1! ...... . i "" . ~. 0- ~ \ " " '\ '" ... ~ . .. "- ':.:' :. ,:.,. ':<<. .:.;, .:<<, .:c- .:.:' .:.:. '*' .:c- .;. , , , . ~ - ..... , ( )i I' *~'*'~~--~--'*'---_._-- ~; ., "., - '" , ". , . -. - -, .., ," a: . , ~:\ ~I ~:' I 11, , . : .~ ~ IN THE COURT OF COMMON PLEAS ~ I, :' ~ I.. I~ (~ ('.' I':; :; l~ ,,~ I.~ I':' 1* I: I~ I::: ~: , ~, . . ',I ~r . ~I ~i . ( ~I ~I , ( ~i , I W.I ~! ~'I ~ OF CUMBERLAND STATE OF ;~~~ PENNA. COUNTY i'\ I). 96-1738 MARCELLA S. POLITO v. 'I','" 1 I." KEI'l'H W. POLITO . ' ~~ DECREE IN DIVORCE ~()r~~ -Z~ 191J:,. , . i~ I::: ,.~ . i ~I '1 ~I ~' I~ it is ordered and AND NOW, :~ decreed that "MJ'.BC;E~J,A S. ,l;>Q~,('ro, ,~ and '" , KEITH, W., POLITO, , , . '. plaintiff, , '. defendant, ~ No claims pending .,.... ,....,. ~ "",.,.,'/..,"',..,....... ,.,... . ^tf(>~t: ~, $/' - _ ~ ./) 7"/ -.L .,,,rd.vli-,<u, ( '~''I r.~",r,;r"H~~r.1.. )" ,..' ;31 ~,4<'~"( J'./-,;~~'ir. ~ / Prothonntnry ,j,' ~ ~ ~ ~ ~ ~ ~ ~ "----,,... --." '.. ... .. -lie. ... ... 1IC' ... .:c. ... .:c. .:.:. .:.;. :~ :~ ~ :.. J. :~ ,'i . . .~*.~*,~"~..~,.~..~.~..~..~~..~.,~.~..~ 'I ~ en >. - I... ... f.. ~ :,1 of(. ~r' , '1'1' :1: "':'': @r a.. i::::j " a. '~ n:~' . f) - , I,;' '-, OI(rJ i!: ~oI .:lu.. ~, . b u, d en '. , .\ . . -. ~ '. .. ., , -, . . . - . . , property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment or order of divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. INCORPORATION IN DIVORCE DECREE: It is further agreed, covenanted and stipulated that this Agreement, or the essential parts hereof, shall be incorporated in any decree hereinafter entered by any court of competent jurisdiction in any divorce proceedings that have been or may be instituted by the .5. . . . ~ - . . . . parties for the purpose of enforcing the contractual obligations of the parties. This Agreement shall not be merged in any such decree but shall in all respects survive the same and be forever binding and conclusive upon the parties. 6. EPPECTIVE DATE: The effective date of this Agreement shall be the "date of execution" or "execution date," defined as the date upon which it is executed by the parties if they have each executed this Agreement on the sam~ date. Otherwise, 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. 7. DISTRIBUTION DATE: The transfer cf property, funds and/or documents provided for herein, shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. However, the support. and/or alimony payments, if any, provided for in this Agreement shall take effect as set forth in this Agreement. .6. . . ~ . . ~ 8. MUTUAL RBLEASE: HUSBAND and WIFE each do hereby mutually remise, release, quit-claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatooever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situated, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or 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 r.ight to take against the spouse's will, or the right to treat a lifetime conveyance by the other aB a t~stamentary gift, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any country or any rights which either party - 7 - . . . . -~ . may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, division of property, coots or expenses, whether arising as a result of the marital relationship or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE to give 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 provis~on thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. - 8 - . - , , . - 9. ADVIC2 or COUNS2L: The provisions of this Agreement and its legal effect have been fully explained to the parties by their respective counsel MARIA P. COGNETTI, E8quire, for HUSBANO and DIANE S. BAXER, E8quire, for WIFE. HUSBAND and WIFE acknowledge that this Agreement is not the result of any duress or undue influeDce and that it is not the result of any collusion or improper or illegal agreement or agreements. 10. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. .9. . , 11. WARRANTY AS TO PUTURE OBLIGATIONS: HUSBAND and WIFE covenant, warrant, represent and agree that with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 12. PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, and neither party will make any claim to any such items which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. - to- . . By these presents, each of the parties hereby specifically waives, releases, renounces and forever abandons whatever claims he or she may have with respect to any personal property which is in the possession of the other, and which shall become the sole and separate property of the other from the date of execution hereof. 13. DIVISION 0. REAL PROPERTY: WIFE agrees to transfer all her right, title and interest in and to the real estate situated at 419 West Fifteenth Street, New Cumberland, Cumberland County, Pennsylvania, now titled in the ~ame Ot HUSBAND and WIFE as tenants by the entireties, to HUSBAND and agrees to immediately execute now and in the future any and all deeds, documents or papers necessary to effect such transfer of title upon request. WIFE further acknowledges that she has no claim, right, interest or title whatsoever in said property and further agrees never to assert any claim to said property in the future. WIFE agrees to immediately execute a deed conveying her interest to HUSBAND. . II . . HUSBAND hereby covenants and agrees to assume and pay in full the remaining balance of the mortgage now existing and presently constituting a lien upon and encumbering the same premises, such mortgage being owed and payable to First United Mortgage Services, Inc., and further covenants and agrees that he will indemnify and save WIFE harmless from any and all liability, expense, cost, or loss whatsoever as a result of his non-payment of or non-performance of said mortgage and said mortgage conditions. Within sixty (60) days from the execution of this Agreement, HUSBAND shall cause WIFE to be removed as an obligor on the mortgage encumbering the premises known by and located at 419 West Fifteenth Street, New Cumberland, Cumberland County, Pennsylvania, or HUSBAND shall refinance the mortgage in such a manner as to remove WIFE from any and all liability thereunder. 14. BANK ACCOUNTS: HUSBAND represents, acknowledges, and agrees that he has no right, title or interest in or to any of the. bank or brokeragE! accounts presently maintained or registered in WIFE's name. . 12. . WIFE represents, acknowledges, and agrees that she has no right, tit~e or interest in or to any of the bank or brokerage accounts presently maintained or registered in HUSBAND's name. 15. PENSIONS. ANNUITIES AND/OR RETIREMENT BEN.rITS: The parties hereby relinquish any and all claims and rights which either may now have or hereafter acquire or possess to share in any capacity or to any extent, in any pension, profit sharing, stock option, savings and thrift plans, 401(K) plans, annuities and/or any other retirement or deferred compensation plan established for the other party that may exist now or in the future. The parties hereby covenant and agree that they will execute any spollsal waivers that may be required under the Pension Reform Act of 1974, the Retirement Equity Act of 1984, or any similar Federal or state statute that is now in effect or may be enacted. Nothing herein shall be deemed to waive either party's Social Security rights. This paragraph is intended to substitute for any other statement, prepared form, or document which might be required by any plan, fund, trust, administrator, - 13 . trustee, or similar entity or person, so that each party may receive said benefits as if the parties were never married. 16. WAIVER or RIGHTS UNDER ERISAI Each party hereby consents to the other's election to waive a qualified joint survivor annuity form of benefit and a qualified pre-retirement survivor annuity form of benefit under any plan of deferred compensation to which Section 401 (a) (11) (B) of the Internal Revenue Code of 1986 (The Code) and/or Section 205(b) (1) of the Employee Retirement Income Security Act of 1974 (ERISA) shall apply in which both parties currently or hereafter may be deemed a vested participant within the meaning of Section 417(f) (1) of the Code and Section 205 (h) (1) of ERISA. Both parties further consent to the other's current and future designation of any alternative form of benefit and of beneficiaries other than each other under any of such plan(s) and to any revocation and/or modification of such designation(s) including any of such plans referred to in Section 401 (a) (11) (B) (iii) of the Code or Section 2051b) (1) (e) of ERISA. Each party hereby further agrees to execute any and all documents or forms which shall be required, - 14- . at any time, and from time to time, by any or all such plans, including but not limited to, any consents required by Section 417 (a) (2) of the Code or Section 205 (c) (2) of ERISA to effect the payment of benefits in this manner. Each party hereby acknowledges that they understand the effect of the other's elections and they consent thereto. Each party further acknowledges that they understand that, absent the consent contained in this paragraph, they would have the right to limit their consent to the designation by the other of a specific beneficiary or a specific form of benefits, and each hereby voluntarily elects to relinquish both such rights. 17. MOTOR VEHICLBS: With respect to the motor vehicleo owned by one or both of the parties, they agree as follows: (a) The 1995 Mazda Protege shall be and remain the sole and exclusive property of WIFE; (b) The 1978 Volkswagen Bug shall be and remain the sole and exclusive property of HUSBAND. The titles to the said motor vehicles shall be executed by the parties, if appropriate for affecting transfer as herein . 15 . provided, on the date of execution of this Agreement, and said executed title shall be delivered to the proper party on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobile. 18. LIPE INSURANCE I WIFE is cognizant of the fact that HUSBAND has maintained and paid premiums on the State Farm Life Insurance Policy Number LF-0756-7251. WIFE hereby expressly relinquishes, waives and renounces any and all proprietary, statutory, distributional, and beneficiary rights and options to the aforesaid insurance policy. WIFE herewith agrees and warrants that HUSBAND has full and complete discretion to change the designated beneficiaries on the aforesaid policy and to exercise any and all additional rights he may have as owner 'of the policy. 19. ArTER-ACQUIRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or rig~t of the other, all items of property, be they real, personal or - 16. mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 20. LUMP SUM PAYMENT TO WIPEI As and for WIFE's further distributive share of marital property, HUSBAND agrees to pay to WIFE the total sum of $15,000.00 free of any and all taxes, within 60 days of the signing of this Agreement. 21. ALIMONY AND SPOUSAL SUPPORT: HUSBAND agrees to pay to WIFE the sum of $500.00, as alimony, on the 15th day of each month, for a period of 12 months commencing November 15, 1996, and terminating on October 15, 1997, with the last payment to be made on October 15, 1997. HUSBAND shall prepay alimony in the amount of $3,000.00 which represents payment of alimony for the months of November and December, 1996 and January, February and March, 1997, on or before December 31, 1996. This payment is intended to be included in WIFE's income and deducted from HUSBAND's income pursuant to Federal tax laws. WIFE agrees that . 17. all of the said payments shall be included as income of WIFE in her applicable tax returns and she shall pay such taxes as may be required by reason of such inclusion. The parties further agree that they specifically intend this amount to be non-mod.ifiable either upward or downward by either party. said payments to WIFE shall cease upon the earliest to occur of WIFE's remarriage, cohabitation, the death of either party, or October 15, 1997. WIFE agrees to withdraw her claim for spousal support which is presently pending with the Cumberland County Domestic Relations Office, DR No. 25,773. Said claim shall be withdrawn effective as of the date of its filing. If necessar.y, WIFE agrees to sign any and all documentation required by the Domestic Relations Office to effectuate the terms of this paragraph. 22. COUNSEL PEES: Except as provided herein, each party hereby indemnifies and agrees to indemnify and hold the other free and harmless against the claims of any attorney or person who rendered or claims to have rendered services to him or her in connection with the divorce proceeding and the negotiation of this Agreement or otherwise. - 18 - 23. ~ AMENDMENT TO PREVIOUSLY PILED JOINT TAX RETURN I The parties hereby acknowledge that they have previously filed an amendment to their 1995 joint Federal tax return. HUSBAND has paid to WIFE, and WIFE acknowledges receipt of, an amount equal to the refund due the parties as a result of the jointly filed amendment. 24. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint Federal and state tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate .income on the aforesaid j oint returns. .\9. . " 25. APPLICABILITY OP TAX LAW TO PROPERTY TRANSFERS: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act per~aining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of the said Act. 26. WAIVER OF ALIMONY: HUSBAND and WIFE recognize and acknowledge that the foregoing provisions for their individual benefit are satisfactory with regard to their support and maintenance, past, present and future. The parties release and discharge the other absolutely and forever for the rest of their lives from all claims and demands, past, present or future, for alimony or for any provision for support or maintenance, except as specifically provided for herein. The parties further -20- acknowledge that in consideration of the transfers made herein each completely waives and relinquishes any and all claims and/or demands they may now have or hereafter have against the other for alimony, alimony pendente lite, spousal support and counsel fees, except as specifically provided for herein. 27. EPFECT OP DIVORCE DECREE, The parties agree that except as otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 28. 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 or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. .21 . '. 31. PINANCIAL DISCLOSUBI: The parties confirm that they have relied on the completeness and substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no formal discovery conducted in their pending divorce action and that neither party has filed an Inventory and Appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owned by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly r.eserved. In the event that either party, at any time hereafter, discovers such an undisclosed asset, the party shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of said asset. .23. HARCILLA 8. POLITO, Plaintiff, IN TBI COURT O~ COKKON PLIAS CUJlBIRLAHD COUIITY, Pl1OI8YLVlUIIA 1 1 1 1 1 1 1 1 1 1 _I CIVIL ACTION-LAW IN DIVORCII va. NO. 1(. / Ii J' (I I "l e_ Ll-')('--J KIITH W. POLITO, Defendant. HOTICI TO DI~IHD AND CLAIM RIGHT8 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 may lose money or property or other rights important to you, inc.luding custody or visitation of your children. 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 Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, carlisle, Pennsylvania 17013-3387. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER I 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 ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 TELEPHONE: (717) 240-6200 RICCI & TANEFF Dated: April 1, 1996 By: t Paul Taneff, Esq. Attorneys for PIa IlUCILLA .. POLITO, I I Plaintiff, I I va. I I "IT. W. POLITO, I I Defendant. I I I II T.I COURT or COIucOIt PLIIU CUllBIRLUD COUllTY, P......YLVAIIIA ~ " " ,} /. MO. , (". I ~ . J.1 t..' L 'I..~ .1 t. '-" CIVIL ACTIOIl-LAW II DIVORC. COIIPLAIIIT NOW COMES, the Plaintiff, MARCELLA S. POLITO, by and through her attorneys, Ricci & Taneff, and files this Complaint. In support of her Complaint, the Plaintiff states as follows: 1. Plaintiff, Marcella S. POlito, is an adult individual, who resides at 129 South River Street, wormleysburg, Cumberland County, PA 17043. 2. Defendant, Keith W. POlito, is an adult individual, who resides at 419 Fifteenth Street, New Cumberland, Cumberland County, PA 17070. 3. The parties have been bona fide residents in the Ccmmonwealth of Pennsylvania for at least six (6) months immediatoly previous to the filing of this Complaint. 4. The parties were married on November 26, 1993 in New Cumberland, Cumber~and County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availabiJ.ity of counseling and that she may have the right to request the Court require the parties to participate in counseling. 8. This action is not collusive. COUJIT I DIVORCI 9. Plaintiff incorporates paragraphs 1 through 8 of this Complaint as if set forth here in full. 10. Plaintiff states that she is entitled to a divorce on the ground that the marriage is irretrievably broken, and Plaintiff is proceeding under S 3301(c) or, alternatively under S 3301(d) of the Divorce Code. 11. Plaintiff, the innocent and injured spouse, states that the Defendant, in violation of his marriage vows and the laws of the Commonwealth of Pennsylvania, has committed such indignities to the person of the Plaintiff so as to make her condition intolerable and life burdensome, and Plaintiff is proceeding under S 3301(a)(6) of the Divorce Code. WHEREFORE, Plaintiff requests this honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant. COUJIT II IOUITABLI DISTRIBUTION 12. Plaintiff incorporates paragraphs 1 through 11 of this Complaint as if set forth here in full. 13. The parties have legally and beneficially acquired property, both real and personal, during their marriage from November 26, 1993, which property is marital property. 14. The foregoing property is subject to equitable distribution under S 3502 of the Divorce Code. -2- WHEREFORE, Plaintiff requests this honorable Court to equitably divide all marital property and to enjoin the Defendant from removing, disposing, alienating or encumbering the real and personal property of the parties. COUIIT II r ALIIIOIIY-PBRMUlBII'1' AlII) PIIIDIII'1'B LITB 15. Plaintiff incorporates paragraphs 1 through 14 of this Complaint as if set forth here in full. 16. Plaintiff requires reasonable support and alimony to adequately maintain herself in accordance with the standard of living established during the parties' marriage. WHEREFORE, Plaintiff requests this honorable Court to enter an award of reasonable temporary alimony, and such additional sums as they become necessary from time-to-time hereafter, until final hearing and permanently thereafter under 55 3701 and 3702 of the Divorce Code. COUIIT IV ATTORIIBY ..BS. COSTS AND BXP.NIII 17. Plaintiff incorporates paragraphs 1 through 16 of this Complaint as if set forth here in full. 18. Plaintiff has employed the firm of Ricci & Taneff, as her counsel and, because of the anticipated protracted litigation expenses and limited income, is unable to pay for the reasonable and necessary expenses of counsel and litigation. WHEREFORE, Plaintiff requests this honorable Court to enter an award of temporary counsel fees, costs and expenses, and such additional sums as they become necessary from time-to-time -3- ._J> IUUtCILLA .. POLITO, I I naintUf, I I v.. I I anTB .. POLITO, I I Defendant. I I I I. TBI COURT or COIOlO.. PLIA. CUllBIRLAJID COUIITY, lII....YLVAllIA .0. CIVIL ACTIO.-LA. I. DIVORCI UrIDAVIT I, MARCELLA S. POLITO, the Plaintiff in the above titled clluse, being duly sworn according to law, depose and state as follows: 1. THAT, I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. THAT, I understanc that the Court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. THAT, being so advised, I do not request that the Court require my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that any false statements herein are made subject to the penalties of lB Pa. C.S. S 4904 related to unsworn falsification to authorities. Dated: April 1, 1996 \ ( I /i it I Marcella S. 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