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HomeMy WebLinkAbout96-02494 "\ ~ J "\ I " " " j " J )- 0- ;/ , -..) 0- ~ .________~_~________x___~~.__~~ 8 .-,---.--. -~--~ .------.---.-..-.-...--'----~---..-- * ~ 8 * IN THE COURT OF COMMON PLEAS S * ~ * OF CUMBERLAND COUNTY ~ . 8 * ,loLl 8 * STATE OF ~~ PENNSYLVANIA I . s * CHRISTOPHER R, LEADER." 8 8' No,. 2494...... 1996 8 8 Plaint if f . 8 Voro"., 8 . GAIL M, LEADER 8 8 Defendant 8 8 N ~ i 8 ! DECREE IN . ~ DIVORCE g 8 8 . --.. /.. 21 4 h ~ AND NOW, .... \)~,....,..,.., 19,...." it is ordered and 8 , I ~ '" decreed that,. Pl~q1;q~II~~,~, .J:E~Ji:~.."..,.",.,..,.,.",..,. p aintiff, ~ 8 6 and. , . .. .. , , , .. GA~~, M:. !.E~~~, .... , . . .. . . . .. , . . . . , . , . , , , . . . " defendant, ' !I' a . are divorced from the bonds of matrimony. ~ . ~ 8 ~ * ~ . . . 8 . I ll-. "" 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; NONE THIS AGREEMENT OF DECEMBER 19. 1996. [S HEREBY J.NCORPORATEO INTO THE FINAL .,...... ...,.., ...,....... ...,.' ..,......, ,..... ,........" ,........, '. ", ,DIVORCE. DECREE.,.. / )' ,.........,...,..,...."..,.. ,..... I.... .1"",. D y T '-_~ O~j,V/ AII.'t:;;>-~,L.' " ,'J " Iv,p~J /1A.h' --/,' J ' ~(./t<-JlC-~. (. '.' U~..c.;i(--'ef "l-P t~t"'()TCtd-' . '?(!?I.;:r // rlQ~ ~)~. . :.1 ...f..othonotary _------.--....----........-...--_..~~-;-",~-., .'-,.~,~.~_....,-"~ ...., -'~ ._----------~-~~~~~--~ $ ~ ~ ~ ~ .;, (~ ~ " ~ I~ i " I~ , i~ ('" ( . lA I~ " SEP~TXON AND PROPERTY SETTLEMENT ~GREEMENT THIS AGREEMENT, made this lct~\......day o:1Jc.ot\\Der , 1996, by and between GAIL M. LEADER, hereinafter referred to as "Wife", and CHRISTOPHER R. LEJWER, hereinafter referred to AB "Husband". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 2, 19871 and WHEREAS, certain differences have arisen between the pnrties as a result of which they have separated and now live separate and ftpart from one another, and are desirous, therefore, of entering into an Agreement which will provide for support, distribute their m~rital property, and will provide for their mutual responsibilities and rights growing out of the marriage relationship 1 and WHEREAS, the parties hereto, ~fter being properly advised by their reBpective counsel, Husband, by his attorney, Francis M. Socha, and Wife by her attorney, Thomas D. Gould, have come to the following agxeement. NOW, THEREtORE, in consideration of the above recitals and the following covenants and promis{ls mutual;,y made and mutually to be kept, the partieB heretofore, iatending to be legally bound and to logally bind their heirB, Buccessors and assigns theroby, covenant, promise and agree as follOWJ: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or de'ilm fit. 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 110r attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or mali.gn the other, nor in any way interfere with the peaceful existence, separate and . apart trom the other in all respects as it he or she were single and unmarried. J. WIPErs DEBTS: Wife represents and warrants to Husband that since their separation on May 9, 1996, Ihe has not, and in the tuture she will not, contract or incur any debt or liability tor which Husband or hil estate might be responsible and shall indemnity and eave Husband harmless trom any and all claims or demands made against him by reason ot debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wite that since their separation on May 9, 1996, 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: Husband and Wife acknowledge and agree that they have no outstanding debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement, except as follows: a. Members lst Federal Credit Union loan, Account .154650 in the approximate balance of $7,900.00 b. Postmark Credit Union, Account .5164, principal balances in the amount of $5,567.00 and $11,521.46. The parties agree that Wife shall assume the responsibility tor paying the loan to Members 1st Federal Credit union and Husband shall assume responsibility for paying the loans to the Postmark Credit Union. The parties agree to indemnify and hold each other harmless trom and all claims and demands made against the either party by reason of the assumption of the debts and obligations as set forth in Paragraph 5. Both parties agree to use their best efforts to rsfinance the loans in Paragraph 5(a) and (b) in order to secure the release of the party not assuming the respective loan. 2 . 6 . MUTUAL RELEASE: Subject to the provisions of this Agreement, each party waives his or her right to alimony and any further distribution of property inasmuch as the partiBs hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980, aB amended. Subject to the proviBions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and hiB or her heirs, legal representatives, executors, administrators and assignB, release and diBcharge the other of and from all causes of action, claimB, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling purBuant to Section 202 of the Divorce Code. 7. EOUITABLE DISTRIBUTION OF MARITAL PROPERTY: The parties have attempted to distribute their marital property in a manner which confirms to the criteria set forth in Section 40 1 of the Pennsylvania Divorce Code, and 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 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 limi tad 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 circumstances 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, 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: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, 3 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 pOBsession. 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 other. Should it become necessary, the parties each agree to sign, upon request, any titles or 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 prop.}rty, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the Cdse of intangible personal property, if any physical or written evidence of ownership, such as paBsbook, checkbook, policy or certificate of insurance or other similar 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 his or her own individual pension or other employee benefit plans or retirement benefits of any nature with the exception of Social Security benefits 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. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her separate property and any property which is in their pOBsession or control pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise encumber 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 other pertaining to such disposition of property. B. MARITAL HOME: The parties own, as tenants by the entireties, improved real property located at 304 James Street, Mechanicsburg, Cumberland County, Pennsylvania. The parties agree that they will sell the marital residence at a price mutually agreed upon. proceeds agreeing Husband shall receive the first $2,000.00 of from the sale of the marital home with the to split the remaining net proceeds equally. the net parties 4 9. MOTOR VEHICLES: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (a) The 1988 Dodge Caravan shall become the sole and exclusive property of Wife. The title to the Baid motor vehicle shall be executed by the parties, if appropriate, for effecting tran3fer as herein provided, on the date of execution of this Agreement and the said executed title shall be delivered to the proper parties on the distribution date. (b) The 1993 Dodge Dakota Sport shall become the sole and exclusive property of Husband. 9 . CUSTOlU..L The parties shall share legal custody of their minor child, Spencer Leader, born November 12, 1987. Both Wife and Husband Bhall have full access to all information concerning the minor child including, but not limited to; medical information, educational information, counBelors, teachers, etc. Both parents shall be informed of important medical, educational, religious and other matters affecting the minor child and shall have input into decisions affecting such matters. The parties shall have equal shared physical custody of the minor child. Such alternate custody shall be on a week-to-week basis commencing at 5:00 p.m. on Sunday with alternate parent and concluding at 5:00 p.m. the following Sunday. The parties shall mutually agree to visitation on holidays and birthdays. The parties agree that they shall alternate naming the minor child as a tax deduction on a year-to-ye^r baBis. They further agree to execute all IRS documents necessary to confirm such agreement. 10. PENSION PLAN: Parties release any interest in the opposite spouse's Pension accumulated during the course of their marriage. 5 11. COUNSEL FEES AND EXPENSES: Busband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth 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 provisions for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. 12. INCOME TAX RETURNS: The parties have heretofore filed joint federal and state tax returns. The parties agree that for 1996 and all subsequent tax years, they shall filed individual 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 joint returns. 13. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party 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. 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. 6 14. SUBSEOUENT DIVORCE: Husband has filed a no-fault complaint in divorce against Wife. Husband and Wife each agree to sign an affidavit of consent to be filed in Baid divorce action. The parties further agree that each party will be responsible for their respective attorney's fees. In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agr.eement which may be incorporated by referenced into the Divorce Decree, shall not be merged in such Decree, and shall not be modified, but shall in all respects survive the same and be further binding and concluBive upon the parties. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement may be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. 15. BREACH AND ENFORCEMENT: If either party breaches any prov~s~on 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 rolief as may be available to him or her, and the party breaching this Agreement should be responsible for payment of legal fees and COBts incurred by the other in enforcing his or her rights under this Agreement. A. It is expressly understood and agreed by and b~tween the parties hereto that this Agreement may be specifically enfor.ced by either HUBband or Wife in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that thBre is an adequate remedy at law. The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and in such event it is specifically understood and agreed that for and in specific 7 , , consideration of the other previsions and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay. C. Each party further hereby agrees to pay and to save and hold harmlesB the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any way whatsoever, or shall pay upon, or in consequence of any default or breach by the other of any of their terms or provisions of this Agreement by reason of which either party shall be obliged to retain or engage counsel to initiate or maintain or defend proceedings against the other at law or equi.ty or both in any way whatBoever; provided that the party seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or in part, before there would be any liability for attorney's fees and costs of litigation. It is the specific agreement and intent of the parties that a breaching or wrongdoing party ~hall bear the burden and obligation of any and all costs and expenBes and counsel fees incurred by himself or herBslf as well as the other party in endeavoring to protect and enforce his or her rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisionB of this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have 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 furnishBd with all information relating to the financial affairs of the other which has been requested by ,each of them or by their respective counsel. 8 18. ENTIRE AGREEMENT: This Agreement containB the entire understanding of the parties and there are no representations, warranties, covenants or 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 Beparate 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 reBpect 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 juriBdiction pursuant to Section 401(d) 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 diBtribution of marital property, but nothing herein contained shall constitute a waiv~r by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 19. DISCLOSURE: Husband and wife each represent and warrant to the other that he or she has made a full and complete dieclosure to the other party of all assets of any nature whatsoever in which such party has an interest, the sources and amount of the income of such party or every type whatsoever and of all other facts relating to the subject matter of this Agreement. The partieB hereto acknowledge that they were aware of their right to pursue discovery, including issuing interrogatories, and with this knowledge, they parties have waived their right to undertake discovery. 20. 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 perfo~nce of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent defaul t of the same or similar nature. 9 21. PRIOR AGREEMENT: It is understood and agreed that any and all property lettlement agreements which mayor have been executBd prior to the date and time of thia Agreement are null and void and of no effect. 22. DESCRIPTIVE HEADINGS: only. rights The descriptive headings used herein are for convenience They shall have no effect whatsoever in determining the or obligations of the parties. 23. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a Beparate and independent covenant and agreement. 24. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 25. 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 this Agreement and in all other respects thia Agreement shall be valid and continue in full force, effect and operation. 26. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure benefit of the parties hereto and their respective executors, administrators, successors, and assigns. to the heirs, 10 '", ....... j CHRISTOPHER R. LEADER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA : v. : NO. 96-2494 Civil Term : GAIL M. LEADER : CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: TranBmit the record, togdther with the following information, to the court for entry of a divorce degree: 1. Ground for divorce: Irretrievable breakdown under .ection 330l(c) of the divorce code. 2. Date and manner of service of the complaint: May 7, 1996 - CERTIFIED MAIL 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit Of Consent required by Section 330l(c) of the Divorce Code: by the Plaintiff: December 19, 1996; by the Defendant: November 22, 1996. (b) (1) Date of execution of the Plaintiff's Affidavit required by section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: N / / -- --~ . / ( ". " . i:; ..0 r C 1-,':- t .. r.j <.# ..:r ',~~ -" ~~", ~ ~'.I~ [. .'~ 0, r. w.. '. ~J c- CT' :Gi (, .1 ",. ~ l.. , :~(.) l~ u ~ ( ... I'" ~ ~ .0 :::) O"l () " r, , I , ~~: \~ ~~ ...1:2 ~~ Z>t O<:ll ~~ O~ U~ r..>t O~ E-t::J 1>:0 ::>U 00 ~~ E-t~ Z~ H? ~ ~ i ~ ~,,", ~ .~ ~ . ~ 1'\ ~ ri (\ ,~ \>';I tv ~ ~ n vi (\J l~ \. \.J V) . , " r::"J '-~ Q f5 ~ ~ ~ 0 > H . Cl I>: f5 I>: Z W ~ H :t: E-t ~ . ...1 Z 0 > H E-t . ~ <:Il :E H ~ I>: ...1 a is H ..: u ~ - < = = . - ~ ~ :: :;: o ~ ~ - I. ,,. 'f. :l i ill \#J C .~ (': ;" . 1. ~ ~ ;;: .... : .. - ~ ~ ~ :. !: .. 1. 1. roo ~ (f. . ~ ; ~ ,.. .. ": 1- - W · .. . ~I ~ ~ Ii ~ . ... ;. ~ - . " "r. = r. ,; ~ N .. ;.: .. N : l- f;!. :i! ~::':.:;"""l~"..... '.1 I . 0') . I.;.l"~ '''')',1 'I~ ~~~ ~I,I/' I." .' . , , . u) C ~~ .... ~~t" or. c ri;i, i~ ~ (.. ~, c V"l (,I' >,.., , ~, I::,:,:, .';..i . .f:) '., l"~} . ~'\in " :jL\.o :5 <..) " ~ .- b:: a' - f I I, I. ., " , CHRISTOPHER R. LEADER I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY PENNSYLVANIA I v. I NO. 96-2494 Civil Term I GAIL M. LEADER I CIVIL ACTION - LAW Defendant I IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301C of the divorce Code was filed May 7, 1996, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days hav~ elapsed from the date of the filing of this Complaint. 3. I consent to the entry of a Final Decree in Divorce. 4. I underBtand 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. 5. I understand I may request that the Court require my .pouse and I to participate in marriage counseling, being so advised, I do not request that the Court require my spouBe and I to participate in marriage counseling. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unBworn falBification to authorities. DATE: ~2 \ ly \q V 1/ /~fL /' /~- ~TOPHER R. LEADER ~ 11) ~ ,>. c;;; ~- .. f ..,. .:1_,= l'" - ..J .;;~ ).', ii ", ~.,~ "'. I":.; (' a. --,.; (. "Ii) I. l~:- - 'J :~ t.;J '.: ;-.. 11L1J ~.. au 0; Co, ". " ~ ~ a , " . . , .. , . .' . CHRISTOPHER R. LEADER I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY PENNSYLVAlIIA I v. I NO. 96-2494 civil Term . . GAIL M. LEADER . CIVIL ACTION - LAW . Defendant IN DIVORCE WAIVER 0' NOTICE 0' INTENTION TO REQUEST ENTRY 0' A DIVORCE DECREE UlDER 3301(c) 0' THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I underBtand that I may lOBe rightB concerning alimony, division of property, lawyer'B fBes or expenseB 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 Btatements made in this affidavit are true and correct. I understand that falBe BtatementB herein are made subject to the penaltieB of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Datel \L. - \C\ - Cil; C"':"~L" , " "..--r_ OPHER R. LEADER i; V) r:~ Q '.? If .. '~< ..:z .l? .... J:'# " 0:: -,' r, 'l':".'i ........ c <:7\ ,'<~'1 (, \, J",'. LJ' u :i~ 'j' I.lJ il.' 1-, 1::1 .-.~ U. \.f) ~j U cr> U , , ~ I I t ( I I I r f , I, I '. . '. , -,,'..... ,I .' . CHRISTOPHER R. LEADER I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY PENNSYLVANIA I v. I NO. 96-2494 Civil Term GAIL M. LEADER CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301c of the divorce Code was filed May 7, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of thiB Complaint. 3. I consent to the entry of a Final Decree in Divorce. 4. I understand that I may lose rights concerning alimony, diviBion of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 5. I understand I may request that the Court require my BpouBe and I to participate in marriage counseling, being so advised, I do not request that the Court require my Bpouse and I to participate in mar.riage counseling. I underBtand that falBe statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unBwora falBification to authorities. I / DATE I /: . I' . I I , I I' / / . ,; '/, (,/ / GAIL '~~ LEADER i :,111 L._ . .. . . . , .... CHRISTOPHER R. LEADER I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY PENNSYLVANIA I v. I NO. 96-2494 civil Term I GAIL M. LEADER I CIVIL ACTION - LAW Defendant I IN DIVORCE "AI\~R OF NOTICI OF INTINTION TO REQUIST INTRY OF A DIVORCE OICRII UNOIR 3301(0) OF THI OIVORCI COOl 1. I consent to the entry of a final decree of divorce without notice. 2. I underBtand that I may lose rightB concerning alimony, division of property, lawyer's fees or expenseB if I do not claim them before a divorce iB 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 immediatBly after it is filed with the prothonotary. I verify that the statements made in thiB affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Datel / / J' . , ,- 1:1, - - -; , /,) /'/1 GAIL M. LEADER , . .. .// . ,,' /lllt -t. / - , ~ In .. ". c:; ., r .. r-<r:' -'7 JI'~ ~: .- '>:;,11 0: <: f, '. ~.J ... Q'l ;i3 (I' lL ,J~ It: W :i;e ~; Lll ,,'If c:. .:r. tt5 "" ~) 0'" ..:..> . . . . .. .