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I. SEPARATION, It shall be lawful for each party at all times herealler to live
separate and apart from the other party, at such place or places as he or she from
time to time may choose or deeml1t,
2, NONINTERFERENCE, Each party shall be free from interference,
authority and control, direct or indirect, by the other in all respects as fully as ifhe
or she were single and unmarried, Each may, for his or her separate use or
benefit, conduct, carry on and engage in any business, occupation. profession or
employment which to him or her may seem advisable, Neither party shall molest,
harass, disturb or malign the other or the family of said other, nor compel or
allempt to compel the other to cohabit or dwell with him or her,
3, MUTUAL RELEASES, Husband relinquishes his inchoate intestate right in
the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate
of Husband, and each of the parties hereto by these presents, for himselfor
herself, his or her heirs, executors, administrators or assigns, does remise, release,
quitclaim, and forever discharge the other party hereto, his or her heirs, executors,
administrators or assigns, or any of them, of and from any and all claims,
demands, damages, actions, causes of actions, or suits at law or in equity, of
whatsoever kind or nature, for or because of any mailer or thing done, omilled, or
sullcred to be done by said party prior to and including the date hereof; except
that his release shall in no way exonerate or discharge either party hereto from the
obligations and promises made and imposed by reason of this Agreement. and
shnll in no way affect any cause of action in absolute divorce which either pnrty
may have against the other pmty.
4, MARITAL PROPERTY. TIle parties hereto acknowledge and agree that
they acquired various assets and debts during their marringe, whether the snme
wcre held jointly or individually by the pnrties hcreto, including but not
nccessarily limited to:
(a) Household goods, contents, furniture nnd furnishings presently loclltcd
in the family rcsidence,
(b) Wife's 1992 Mazda 626, titled in the names of both parties, presently
encumbered by a 10lln of IIpproximately $3,000,
(c) Husband's 1992 Mazda Protege, titled in Husband's name, presently
encumbered by a loan of approximately $3,400.
(d) A Nashua mobile home, having a value of approximately $2,500,
presently located at 1920 Green A venue, Williamsport, Pennsylvania,
(c) Husband's savings and checking accounts at Citizens & Northern
Bank, Ralston, PA.; Wife's savings and checking accounts at 1st
National Dank of Canton, PA,; and ajoint banking account in
Delaware. Each contained a negligible amount of money at time of
the separation.
<0 Wife's 401(k) Plnnllt Dover Federal Crcdit Union, having a vnlue of
npproxhnntely $5,600 as of Dccembcr, 31, 1995,
(g) Husband's Retircmcnt Plan with thc Pcnnsylvania Stale Employccs
Retirement Systcm, which was not vcstcd in Husband uttimc of
separation, but which had u vulue of approximutcly $6,000, und
Husband's Rctirement Plan through thc Dclawurc Air Nutlonal Guard,
which wus not vested in Husband and which had no cash vuluc attimc
of separation,
(h) Husband's loans and crcdit card debt at the time of scpurationus
follows: with J.C, Pcnney, of approximately $200; with Discovery
Card, of up proximately $500: with Prime Option Card, of
approximately $700; with Maryland Bank, N.A" ofapproximatcly
$12,000; and an automobile loan of approximately $3,400 for thc
automobile described in Paragraph 4[d), above,
(i) Wife's credit card debt at the time of separation as follows: with J,c,
Penney, of approxhnately $200; with 1st U,S,A. Bank, of
approximately $150; and an automobile loan of approximately $3,000
for the automobile described in Paragraph 4[ c j, above,
0) Husband's Servicemcn's Group Life Insurancc (SGLI) tcnn policy,
provided through the Delaware Air Natlonul Guard, which provides
dcath benefits of $200,000, but which hus no cash value,
(k) Husbund's term life insurance policy, provldcd through thc Halifax
Arca School District, which provldcs dcath bcncfits of $1 00,000, but
which has no cash vuluc,
(1) Various hems of personal propcrty of a pcrsonalnnture, including but
notlimhed to clothes, tools, books and photo albums,
5, DlSTIUDUTION OF MARITAL PROPERTY, Thc partics hcrcto covcnant
IInd agrec thlltthe IIsscts describcd in Paragraph 4, above, hnvc becn or IIrc hcrcby
being divided IInd distribnted bctwecn them liS follows:
(II) Husband rclinquishcs IInd disclaims any and all owncrship, right, titlc
and interest in and to thc household goods, contcnts, filmiture and
fumishings remaining inthc fan1ily home liS of the date of the
cxecution of this agreemcnt, with the exception of certain of his items
ofa personal nature,lIs lire further describcd in Paragraph 5(1), below.
(b) Husband relinquishes and disclaims any and all ownership, right, titlc
and interest in Wife's 1992 Mazda 626 and Husband agrces that Wifc
shall become and remain the sole and separate owner of same, Wife
agrees to take fullllnd sole responsibility for repayment of the debt on
said vehicle,
(c) Wifc relinquishes and disclahns any and all ownership, right, title IInd
intcrestln Husband's 1992 Mazda Protege and Wife agrees that
Husband shall be IInd rcmalnthe sole and scpllratc owner of same,
Husband IIgrccs to takc lilll and solc rcsponsibility for rcpayment of
thc dcbtlln sllid vchiclc,
(d) Wile rclinquishcs IInd disclllims IIny III1lI1111 llIvncrship, right, titlc IInd
intcrcst inllusbllnd's Nllshullmobilc homc prcscntly loclltcd lit 1920
Grecn Avcnuc, Williamsport, Pcnnsylvania, and Wile IIgrccs thllt
Husband shall bc and rcmainthc solc alld SCplll'lltc owncr of sllmc.
(e) Husband rclinquishcs IInd disclaims IIn)' and all owncrship, right, titlc
nnd intcrcst in and to Wile's bank accounts, and Husbllnd agrccs thllt
Wife shllll bc IInd remain thc solc IInd scpllrntc owncr of samc, Wile
rclinquishcs IInd disclaims IIny and 1111 owncrship, right, titlc IInd
interest inllnd to Ilusband's bank accounts IInd Wile IIgrccs tllllt
Husbllnd shall bc and remain the sole and scparntc owncr of samc.
TIle joint bank account has becn c1nsed prior to cxccution of this
IIgreement and any funds have bcen divldcd to thc satlsfllction ofthc
pllrties hercto,
(I) Husband relinquishes and disclaims any and all ownership, right, title
and intcrest or entitlement In or to IIny and 1111 rctirement and/or
pension benel1ts, including death benel1ts arising from Wifc's 40 I(k)
RctircmentPlanllt Dover Federnl crcdit Union and Husband
covcnants IInd agrccs that all such benelits shall bc and remllinthe solc
and separnte propcrty of Wili:,
(gl Wife rclinquishes and disclaims any and all ownership, right, tltlc and
intcrcst nr cntitlcmcnt in or to IIn)' IInd all rctiremcnt andlor pcnsion
hcnclits, including dcath bcnefits IIrising Iromllusbllnd's Rctlrcmcnt
Plan with thc Pcnns)'lvllnill Statc Emplo)'ccs I{ctircmcnt S)'stcmllllll
Wifc covcnants and agrecs that all such benefits shall be and remllin
the sole and separate property of Husband,
(h) Husband agrees that hc shall take fullnnd complcte responsibility lor
paymcnt and satisfaction of the obligations, loans nnd crcdlt card dcbt
assumed in his namc up to thc timc of scpal'lltion, including but not
exclusive to those debts itcmizcd in Paragraph 4 (h) abovc,
(i) Wife agrces that she shall take full and complcte rcsponslbility for
payment and satisfaction of the obligations, loans and credit card debt
assumed in her name up to thc time of separation, including but not
exclusive to those debts Itemized In Parngrllph 4 (i) above,
(/) Wife relinquishes nnd disclaims any and all ownership, right. title IInd
interest in and to Husband's Scrvicemen's Group Life Insurance
(SGLI) tenn policy provided through the Pennsylvania Air National
Guard, with the exccption that Husband agrees that. providing that
Husband remains cntitled to said term policy, Wife shall be maintained
liS beneficiary to receive filly percent (50%) of death benefits until
both children of the marriage shall reach the age of 18 ycnrs, and that
each child shall be maintaincd as beneficiary to rcceive twenty-five
pcrcent (25%) of death benelits until such tlmc as that child shall rench
the nge of 18 ycars, Inthc event thllt cithcr child should cngllgc inn
coilege or othcr formal post-secondary school educatinn, the covcl'llgc
lor both Wile and the child whosc educntion is extcnded shnll he
continucd until the child whose education is extcnded completes his or
her education, or is not engaged in II formul course of education for
one year, or reaches the age of twenty-three (23) years, whichever
occurs first.
(k) Wife relinquishes and disclaims any and all ownership, right, title und
interest in and to Husband's term life insurance policy provided
through the Halifax Area School District.
(1) Each of the parties hereto relinquishes and disclaims any and all
ownership, right, title and interest in or to the personal efiects of the
other, Wife agrees that Husband shall have ninety (90) days to remove
his personal belongings now in the possession of Wife, said personal
items to include, but not being limited to, his clothes, tools, books and
photo albums,
6. EOUlTADLE PROPERTY, TIlis Agreement constitutes an equitable division
of the parties' marital property, TIle parties have detennined that the division of
this property confonns with regard to the rights of each party, The division of
existing marital property is not intended by the parties to constitute in any way n
sale or exchange of assets,
7, CUSTODY, l11e parties hcreto covenant and agree that they will share legal
custody of their minor children, ANDREW THOMAS McLAUGHLIN (bom June
8, 1987) and HEA TIlER LYNN McLAUGIILlN (bom Fehruary 7, 1992), and
thutthey will share physical custody of the said children as follows: Wife shull
have primnry physical custody, with thc Husbnnd to hnvc physicnl custody for
two weekends per month, with the particulnr wcckends to bc dctcrmincd in vicw
of his National Guard responsibilities. On weekcnds during which Husbnnd is to
hnve physicnl custody, Husbnnd shnll pick up the childrcnon Snturdny moming nt
9 n,m. and deliver thcm bnck homc nt 8 p,m, on Sundny night. Thc pnrtics shall
seek to rcnch a mutually satisfnctory custody arrangemcntllt Christmns nnd Enstcr,
In the event thnt no other nrrnngement is reached by mutual ngreement, the parties
shall rotate physicnl custody at Christmas, with Husbnnd to have custody on
Christmas Day and Wife to have custody on Christmas Evc dny in cven-numbercd
years, Wife shall have custody on Christmas Day and Husband shall hnve custody
on Christmas Eve day in odd-numbered years. In the cvcntthntno othcr
nrrnngement is reached by mutual agreement, the parties shall also rotate custody
of the minor children on Easter, Husband shall have custody of the childrcn on
Easter Dny during odd-numbered years and Wife shnll hnve custody of the
children on Easter Day during even-numbered ycnrs, In addition, Ilusband shall
have physical custody of the minor children for up to four weeks during each
summer vacation period, ifhe so chooses, However. Husband shall not hnve
custody for more than two uninterrupted weeks consecutively, unless Wili: shall
so ngree, 111e parties shall nlso share physicnl custody ol'thc said children on
holldnys ns the parties may from time to timc hercnller ngree. Ilusbnnd ngrccs to
bc solcly rcsponsible for trnnsportntion,
8, SUI'PORT, Husbnnd ngrecs to providc ninc hnndrcd dollnrs ($900,00) pcr
month for child support, to bc mnde in paymcnts directly to Wifi: in thc nmonnt of
four hundrcd filly dollars ($450.00) on thc tirst day nlllt tinccnth dny of cnch
month, In nddition, Husbnnd ngrees to crcnte nn educntionnl fillld filr thc children,
to which he will contributc tiny dollnrs ($511.00) ench month filr ench child, Snid
child support pnymcnts nnd contributions to thc cducntionnllillld shnll dctinitely
continne while both children nrc under cightccn (18) yenrs ofnge, nnlcss thcrc is u
material change in Husbnnd's circumstnnccs, Whcn n child rcnchcs thc age of
eighteen (] 8) yenrs, or in the event of uny mnterial changc in circulllstunccs, cithcr
pnrty mny scek to have child support paymcnts or cduclltional fimd pnymcnts
modil1ed, either by negotiation or through petition to the domestic relations officc,
In consideration ofthe foregoing support nrrnngement, the Husband shall bc
entitled to claim the dependency excmptions for both childrcn lor fcderal incomc
tax purposes for each and all future years during which thc Husbllnd pnys child
support amounting to nine hundred dollars ($900,00) per month lInd un cducation
fund contribution amounting to tilly dollnrs ($50.00) per month. nnd Wifi: lIgrccs
to execute nnd dcliver to Husbnnd, uponthc cxccutlonllnd delivery of this
Agrecment, IRS Form 8332 rclcasing that c1nim of cxelllplionlor the yellrs 1996
through 1999, Wife furthcr lIgrees to cxccute nnd dcliver to Ilusbnnd IRS Fonu
8332 for uny fillure YCllrs into which Ilusbllnd's puymcnts fin child support nnd
the education fund contormto thc pJ'llvisions of this I'lIrngraph,
9, INCOME TAX IU~TlmN, Inthc c\'cnlthntnny fcdcrnl incomc tnx is owcd filr
nny ycnrs in which n jointli:dcrnl incolllc tnx rcturn wns filcd prior tothc
cxccution of this ngrccmcnt. thc pnrtics hcrcby ngrcc thntllusbnnd shnll pny thc
totnlnmount owcd, Inthc cvcnt thntllllY Ii:dernl incomc tnx rcfund is duc for IIlIY
)'cnrs in which njoint fi:dcrnl incomc tnx rctulll wns IiIcd prior tothc cxccutionof
this ngrecmcnt, the partics hcreby ngrcc thnt cnch shnll bc cntitlcd tonnnmount
cqunllo filly perccnt (50%) ofthc totnl refillld duc,
10,IN()EMNIFICATION FOR PAST ()EIITS, Exccptns othcrwisc provided in
I'arngraph 5, nbove, cach of the partics hcrcto covenants nnd ngrces to nssume full
responsibility for and to pay all debts and obligations of whatsocver kind or naturc
incurred individually by that party prior to the day nnd date of this Agrcemcnt, nnd
each ofthe parties hereto hereby covenants nnd agrees to indemnify the othcr
party nnd save him or her hannlcss from all liability or claim on account of said
debts and obligations from nnd aller the date hcreof,
II. FUTURE OWNERSHIP OF 1'lWl'EltTy, Each of the parties hereto may
herealler own nnd enjoy, Independently of any claims or rights of the other, nil
items of personal and real property, tangible or intangible, herenller ncqulred by
him or her. with full power in him or her to disposc of thc snmc ns fillly nnd
effectively In all respects and for nil purposcs ns though he or shc werc unmnrricd.
12. MUTUAL RELEASES, Thc partics ncknowlcdge thntundcr pre\'nillng
I'cnnsylvnnin Inw thcy cnch hn\'C cCl1nin possiblc f1scnl rights, including bUlnot
limited tothc tilllowing: spousnl support, nlimony pcndcntc litc inthc c\'cntof n
divorcc, pcrmancnt alimony snbsel]ncntton divorcc, rccovcr~' of connscllccs,
costs and expenscs inthc evcnt of a divorcc, nnd clJuitnblc distribution of nlUritnl
property, It is the intention ofthc pnrtics hcrctothat all ofthc forcgoing rights nnd
rcmcdics, with the cxccptlonof thosc othcrwisc prllvidcd In this Agrccmcnt, nre
hereby waivcd and forevcr rclcnscd nnd thntthis Agrcemcnt shall hnvc thc cllcct
of n Iinal Ordcr of Court relicving cnch pnrty of thc obligationtothc othcr fiJr any
and all of the forcgoing possiblc rights and rcmcdics, The pRl1ics havc cfTcctcd
an equitable distribution ofthcir mnrital property nnd neithcr will scck further
distribution by any action at law or in equity,
13, EFFECT OF DlVOncE IlECREE. Thc parties coveuaut aud agrcc thatuulcss
otherwise spccil1cally provided hercin, this Agrcement shall continuc in full forcc
and effect after such time as a Iinal decree in divorce may be cntercd with respect
to the parties,
14, INIlEMNIFICATlON Fon FUTURE IlEDTS. Each ofthc partics hcreby
covenants and agrces with the other party not to make, incur or allemptto make or
incur any debt or obligation for or on behalf of the other party hereto, or for which
the other party may be held liable, from and ater the date hereof, and each of the
parties hereto hereby covenants and agrccs to Indemnify the other pRl1y and savc
him or hcr hannless from all liability or claim on nccount of said debt or
obligntions from and after the date herco[
15, OTIIEn nOCUMENTS, Ench of the partics hereto shall, fhllntimc to time, at
thc rClJucstofthe olher pRl1y, cxccutc, IIcknowlcdgc nnd dcliver unln snid othcr
..
party nny and all filrthcr documcnts or instrumcnts which muy bc rcusonubly
rcquircd to givc nllllorce nnd effect to the lerms nnd provisions of this
Agreement,
I (), mVOnCE, '111is Agreement shall not be construed to ullect or hur the right of
either Ilushund or Wife to nn ubsolute divorce onlegulund trulhlill grounds of
they now exist or may herenller urisc, '111is Agrcement is not Intended 10 condonc
nnd shnllnol be dccmed 10 he u condonntion on the part of eithcr pllrty hereto of
any aCI or acts on the part of the other party which huve occurred prior to or which
may occur subscquent to the date hereof, It is underslood, however, thnt Wile will
pursue nn action in divorce pursuant to Section 3301 [c) of the Divorcc Code of
Pennsylvania, on the grounds that the marriage is irretrievably broken, nnd that
both parties ngree to execute nnd file the nppropriate nffidnvits of conscnt
necessary to complete said action in divorce on the basis of mutual consent,
17, SEVERADlLlTV, TIle waiver of any tenll, condition, clause or provision ofthis
Agreement shall in no wny be deemcd or considered n waiver of any other tenll,
condition. clause or provision of this Agreement, nnd ifany provision of this
Agreement is held to be invnlid or unenforcenble by a court of compelent
jurisdiction, all other provisions shllllnevel1heless continue to be In full force nnd
effect,
18, LAW OF PENNSVL VANIA APPLICABLE. Both purties covenantund ngree
thutthey huve hlld ample nnd sulTIcicnttime to cure fully und nllly review the
terms und provisions of this Agreemcnt lInd 10 scck nml obtllinlhc lIdvice nnd
counsel of an attomcy with rcspcct to the samc, Wile hus cngagcd thc scrviccs of
Patrick Darrett, Esquirc, and Ilusbaud has eugaged lhc scrvices of G, Patrick
O'Counor, Esquire, and cach purty has clIrefully revicwcd thc tcrms and
conditions of this Agrecment with his or her rcspcctivc counscl. Buth partics
covenaut and agrce that they fully undcrstand thc fuels upon which this
Agrccmcut is premised and bascd, thutthey bclicve this Agrccmcnt to bc filir lInd
equitable, that said Agrccmentls being cntercd into frccly and voluntarily by each
of them, and that the cxccution of this Agreement is not the result of any durcss or
undue influence and that it is not the result of any collusion or improper or Illegal
agreement or agreements.
19, INTEGRATION, TIlis Agreement constitutes the entirc understanding between
the parties and supersedes any and all prior agreements and negotiations between
them, Doth parties further agree that there are no covenants, conditions,
rcpresentations or agreements, ornl or written, of any nature whatsoever, other
than those contained herein,
20, AGREEMENT BINDING UPON HEms, 111is Agrecment shall be binding
upon the parties hereto and their respectlvc heirs, executors, administrntors and
assigns,
IN WITNESS WHElmOF, the plu1ies hcrcto, intcnding to hc Icgally bound
hcrcby, huve hereunto set their hands lIud sCllls thc day lInd ycnr first lIbovc writtcn,
. "
COMMONWEALTH OF PENNSYLVANIA)
; SS.
COUNTY OF ~l~ll" )
On this, the I -1 day of ~I 'L \, ,
1998. bcfore mc. n Notnry Public inllnd for the stntc nnd county aforcsllid, thc
nndcrsigncd oOkcr, personlllly IIppcllrcd GERALD L. McLAUGHLIN, known to
me (or satisfllctorily provcn) to be thc pcrson described inthc foregoing instrumcnt,
IInd IIcknowlcdgcd thllt he executcd the snme for the purposcs therein containcd,
IN WITNESS WHEREOF, I hcreunto set my hnnd and oOicial seal.
~'\'~\.,,~ " (I cCJll'r, I\. (SEAL)
Not pu[,c
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COMMONWEALTH OF PENNSYLVANIA)
~ . I : SS,
COUNTY OF t .-0 rUe rr )
Onlhis, the f1'ff!1 dnyof ,
1998, before me, n Notary Public inllnd lor the stnte d county aforesaid, the
undersigned officer, personally nppcared KIMBERLY A, McLAUGHLIN, known
to me (or satisfactorily provcn) 10 bc thc person described in the foregoing instrument,
nnd acknowledged that she executed the same for the purposes thcrein contlllncd.
IN WITNESS WHEREOF, I hcrcunto set my hand and oOicial scnl.
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IN TilE COURT O~' COMMON Pt.~;AS OF CUMn~;Rt.AND COUNTY, P~;NNSYI.vANIA
GERAI.D t.. McI.AUGIlI.IN.
Plaintiff
CIVIl. ACTION - I,^W
VS.
NO. qfe, AjJ 3
(JL l~l L J lLn'-
KIMBERLY ^. McLAUGIlLIN,
Defendant
IN DIVOIICI':
NOTICE TO DEFEND AND Ct.AIM RIGIITS
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 fall 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 relief requested in these papers by the
Plaintiff. You may lose money or property or other rights
Important to you.
When the grounds [or 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 Court House,
Carlisle, Pennsylvania. 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'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE TilE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT nAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE THE
OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL IIELP.
Court Administrator
Fourth Floor
Cumberland County Court House
One Court House Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
.'
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of
the foregoing document upon the person(s) and in the manner
indicated below, which service satisfies the requirements of
the Pennsylvania Rules of Civil Procedure, by depositing a
copy of same in the United States mail, Camp Hill,
Pennsylvania, with first-class postage prepaid as follows:
Kimberly A. McLaughlin
23 S. Minnequa Avenue
Canton, Pennsylvania 17724
DM'E:
'14~/
Esq.
IN TilE COURT OF COMMON I'LEAS OF CUMIlEIU,ANU COUNTY,
PENNSYLVANIA
GERALD L. Mc1.AUGHLlN ,
I'lllintill'
CIVI1. ACTION -1.AW
\'s,
NO, 96-2583 Civil Terlll
KIMIlERLY A. Mc1.AUGHLlN,
Delcndllnt
IN DIVORCE
AFFIDAVIT OF SERVICE DY MAIL I'UnSUANT TO
I'A, Il, CIV,I', 1920,4
Patrick O'Connor, Esquire, being duly swom Ilccording to IIII\', deposes Ilnd SIl)'S
thllt he lIlailed a copy of the Complaint in Divorce tiled in this lIluller by certilied lIluil,
retum receipt requested, Ilddressee only, to the Defendant lit 23 S, Minnequll Avenue,
Canton,I'A 17724, llle retum receipt signed by the Defendant is evidence of delivery to
hilll and is attached as Exhibit "A".
jl2a~' t&~Hf
/Plltrlck O'Connor, Esquire
1.D, No. 64720
3105 Old Gettysburg ROlld
CRlnp HIli, I'A 17011
Phone 717-737-7760
Allomey for Plllintifl'
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
GERALD L. McLAUGHLIN,
Plaintll1.
CIVIL ACTION. LAW
vs,
NO, 96-2583 Civil Tcnn
KIMBERLY A, McLAUGHLIN,
Delcndant
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Seclion3301(c) of the Divorce Codc was liIed on
May 10, 1996.
2. TIle marriage of Plaintiff and Defendant is irrctrievably brokcn and ninety (90)
days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final dccree of divorce aller service of notice of
intention to request entry of the decree,
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before n divorce is granted,
5, My social security number is: /17 - 5 d. - 0 /7lf
I verify that the statements made inthl5 affidavit are true and correct. I understand
that false statements herein ore mode subject to the penalties of 18 Po, C,S, Section 4904
relating to unsworn falsification to authorities.
D^TE:~G(1f
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IN TilE COURT OF COMMON I'LEAS OF CUMIJEI{LAND COUNTY,
PENNSYLVANIA
GERALD L. McLAUGHLIN,
Plnintiff
CIVIL ACTION - LAW
\'S.
NO, 96-2583 Civil limn
KIMBERLY A, McLAUGHLIN.
Defendnnt
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DEClmE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
I, I consent to the entry of a final decree of divorce without notice.
2, I understand that I may lose rights concerning nlimony, division of property,
lawyer's fees or expenses if I do not claim them before n divorce is granted,
3, lunderstnnd that I will not be divorced until n divorce decree Is entered by the
Court and that n copy of the decree will be sent to me immediately aner It is filed with the
Prothonotary,
I verify that the statements made in the foregoing nre true nnd correct,
LUldersland that false statements herein nre made subject to the penalties of 18 Pn. C,S,
Section 4904, relating to unsworn falsification to authorities,
I)Al'E:~
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A, McLnughlin, Defenda~
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