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HomeMy WebLinkAbout96-04016 .. . I ..., .... AGRIIIlMIINT AGREEMENT made this ';)~j day of J!.1>l'..,,6,~), 1997, by and between David J, Crook ( Husband"), of 22 Eastwood Drive, Carlisle, Cumberland county, Pennsylvania and Yvonne L. Crook ("Wife") of 403 Brook circle, Mechanicsburg, Cumberland county, Pennsylvania, lfITNIl881!lTH I WHEREAS, the parties hereto are Husband and Wife, having been married on the 22nd day of June in 1991. There are no children of this marriage. WHEREAS, diverse unhappy differenoes, disputes and difficulties have arisen between the parties and as a result they have lived separate and apart since on or about the Jrd day of May 1996, A proceeding for the divorce of the parties has been filed by the wife in the Court of Common Pleas of cumberland county on July 15, 1996, No.96-4016. It is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of 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 and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony pendente lite, alimony and/or maintenance of Wife by Husband and of Husband by Wife; and possible claims by one against the other and against their respective estates. NOW THEREFORE, in consideration of the above recitals and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the parties . , ' hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as followSI 1. AGREEMINT NOT A BAR TO DIVORCE PROCEEDINGS Wife filed a mutual consent/ no-faUlt divorce pursuant to the terms of section 3301(c) of the Divorce Code of the Commonwealth of Pennsylvania, and this Agreement is contingent upon the wife proceeding with said divorce, and wife filing her Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree thereto upon the expiration of the waiting period. said Affidavi~ and Waiver shall be promptly transmitted to counsel for husband who will immediately file a Praecipe to Transmit Record and Vital statistics form to precipitate the prompt entry of a decree of divorce. 2. EFFECT OF DIVORCE DECREE The parties agree that unless otherwise specJ.fically 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. 3. INCORPORATION OF AGREEMENT IN DIVORCE DECREE The purposes of this Agreement are to effect a complete and final settlement, with reference to each party Ofl a, All of the respective property and property rights of the parties / b. The obligation of each party for the support of each other / and the parties agree that the terms of this Agreement shall be incorporated but not merged into any final divorce decree which may be entered with respect to them. . , , 4. AGRIIHINT NOT TO BIl XIROID This Agreement shall be incorporated into the final decl'ee of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. 5. DATE or EXECUTION The "date of execution" <:>J: "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same 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. 6. DISTRIBUTION DATE The transfer of 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 payments, if any, provided for in this Agreement shall take effect as set forth in this Agreement. 7. FINANCIAL DISCLOSURE The parties ~onfirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. 8. ADVICE OF COUNSEL The provisions of the Agreement and their legal effect have been fully explained to the parties by their respective counsel, Keith DeArmond, Esquire, attorney for Wife, and Michael D. Rentschler, Esquire, attorney for Husband. The part ies acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights a~d obligations and they acknowledge and accept their legal rights and obligations and they acknowledge anQ accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge, and the parties acknowledge that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has been fully advised by his or her resPQctive attorney of the impact of the Pennsylvania Divorce Code of 1980, 23 P.S. se~tion 101 n. ~., whereby the Court has the right and duty to determine all. marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counflel fees and costs of litigation and, fully knowing the same and being fully advised of his or her rights thereunder, each party still desires to execute this Agreement, acknOWledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to have the Court of Common Pleas of Cumberland County, or any other Court of competent jurisdiction, make any determination or order affecting the respective partios' rights to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation, or any other rights arising from the parties' marriage. t. REAL ESTATE Husband shall continue to reside in the dwelling, located at 22 Eastwood Drive, CarliSle, Pennsylvania. Husband shall enjoy sole and exclusive possession of that dwelling to the exclusion of wire. 10, PIR80NAL PROPIRTY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothea, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art al1d other personal property and hereafter Wife agrees that all of property in the possession of Husband shall be the sole and separate property of Husband, and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, relea~e, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of each other. Each waives any claim they may have to the pension, retirement and/or profit sharing plan of the other. 11. MOTOR VIHICLES With respect to the motor vehicles owned by one or both of the parties, they agree as follows: a. The 1995 Pontiac shall property of Husband, encumbrances. become the sole and exclusive subject to its liens and b, The 1994 Pontiac shall become the sole and exclusive property of Wife, subject to its liens and encumbrances. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the date of execution of this Agreement and said executed titles shall be delivered to the proper parties on the distribution date. 12. LIABILITIBS ASSUMBD BY WIrl Wife shall assume individual responsibility for the respeotive debts listed on Schedule A of this Agreement, Wife will hereafter assume and retire the full amount of each respective debt represented on Schedule A due and owing as of the date of exeoution hereof, and shall indemnify and hold Husband and his property harmless from any and all liability with respect to the debts hereby assumed by Wife. 13. LIABILITIBS ASSUMBD BY HUSBAND Husband shall assume individual responsibility for the respective debts listed on Schedule B of this Agreement, Husband will hereafter assume and retire the full amount of each respective debt represented on Schedule B due and owing as of the date of execution hereof, and shall indemnify and hold Wife and her property harmless from any and all liability with respect to the debts hereby assumed by Husband. 14. ASSUMPTION OF ENCUMBRANCES Unless otherwise provided herein, each party hereby assumes the debts, encumbrances, taxes and liens on all the property each will hold subsequent to the date of this Agreement, and each party agrees to indemnify and hold harmless the other party and his or her property from any claim or liability that the other party will suffer or may be required to pay because of such debts, encumbrances or liens. Each party in possession of property to be awarded to the other warrants that all dues, fees, assessments, mortgages, taxes, insurance payments and the like attendant to such property are current, or if not current, notice of any arrearages or deficiency has been given to the receiving party prior to the execution of this Agreement. 15. LIABILITY NOT LISTED Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, , , other than those described in this Agreoment, for which the party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and each party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all such debts, obligations and liabilities. 16. INDEMNIFICATION OF WIFE If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend W He against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her property against any damages or loss resulting therefrom, inc~uding, but not limited to, costs of court and attorney's fees incurred by Wife in connection therewith. 17. INDEMNIFICATION OF HUSBAND If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss reSUlting therefrom, inclUding, but not limited to, costs of court and attorney's fees incurred by Husband in connection therewith. , " , 18. WAIVER or ALIMONY The parties acknowledge that inflation may increase or decrease, their respective incomes, that either may be employed or unemployed at various times in the future, that their respective assets may substantially increase or decrease in value, and that notwithstanding the so or other economic circumstances, the parties acknowledge that they each have sufficient property and resources to provide for her or his reasonable needs and that each is able to support himself or herself without contribution from the other. Therefol'e, the parties hereby expressly waive, discharge and release any and all rights and claims which they may have now or hereafter have, by reason of the parties' marriage, to alimony, alimony pendente lite, support or maintenance and they acknowledge that this Agreement constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. It shall be, from the execution date of this Agreement, the sole responsibility of each of the respective parties to sustain himself or herself without seeking any additional support from the other party. 19. TAX RETURNS AND AUDITS Husband and Wife represent that all federal, state and local tax returns required to be filed by Husband and Wife have been filed, and all federal, state and local taxes required to be paid with respect to the periods covered by such returns are paid. Husband and Wife further represent there are no tax deficiencies proposed or assessed against Husband and/or Wife for such periods, other than that deficiency as is identified in Schedule B of this Agreement and neither Husband nor Wife executed any waiver of the Statute of Limitations on the assessment or collection of any tax for such periods. 20. TAXES FOR YEAR OF DIVORCE Husband agrees to be liable and obligated and shall timely pay and hold Wife and her property harmless from any liability of Husband for federal income tax (including penalties and interest) BS shown on his separate United states individual income tax return for the tax year 1997. Wife agrees to be liable and obligated and shall timely pay and hold Husband and his property harmless from any liability of Wife for federal income tax (including penalties and interest) as shown on her separate United states individual income tax r~turn for the tax year 1997. In the event the Internal RevenUe Service determines an allocation between the parties for federal income taxes for the calendar year 1997, different from that computed above in this paragraph 20, then Husband and Wife agree they will allocate liability for their federal income taxes for 1997, between themselves pursuant to the computation under this paragraph. Any difference shall be accounted for between Husband and Wife, and paid for by one to the other, so as to conform to the tax liability allocation herein with any ultimate tax liability determined by the Internal Revenue Service 21, PRESERVATION OF RECORDS Each party will keep and preserve for a period of four (4) years from the date of divorce all financial records relating to the marital estate, and each party will give the other party immediate access to these records in the event of tax audits. 22. AFTER-ACQUIRED PERSONAL PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in a 11 respects and for all purposes, as though he or she were unmarried. 23 . LEGAL rBls Each party will be responsible for their respeotive oounsel fees and oosts involved in seouring a 90-day no-fault divorce to be instituted by wife as Plaintiff. In the event, for whatever reason, either party fails or refuses to execute an affidavit evidencing their consent to the divorce, pursuant to 53301(c) of the Divorce Code, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including aotual counsel fees resulting from any action brought to compel the refusing party to consent. Each party hereby ag~es that a legal or equitable action may be brought to compel him or her to execute a consent form and that, absent any breach of this Agreement by the proceed ing party, there sha 11 be no defense to such action asserted. 24. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, ALIMONY Husband and Wife agree and hereby do release and renounce any claim they may have against the other party for spousal support, alimony pendente lite, alimony and maintenance. 25. HEALTH INSURANCE - HUSBAND' WIFEI Husband and Wife shall be responsible and shall bear the burden of his or her own health insurance. 26, AUTOMOBILE INSURANCE Both of the vehicles identified in Paragraph 11 of this Agreement shall be insured jointly by Husband and Wife until such time as the vehicles are sold or a respective automobile loan is paid in full. In the event that either of the automobiles is sold or the loan is paid in full, the seller of the vehicle shall immediately inform the other of such fact. 27. WARRANTY AS TO EXISTING OBLIGATION Each party represents that he or she has not heretofore incurred or contracted any debt or liability or obligation for whioh the estate of the other party may be responsible or liable exoept as may be provided in this Agreement. Each party agrees to indemnify or hold the other party harmless f.rom and against ani 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. 28. WARRANTY AS TO FUTURE OBLIGATIONS Except as set forth in this Agreement, Husband and Wife each represents and w~rrants to the other that he or she has not in the past or will not at any time in the future incur or contract any debt, charge or liability for which the other's legal representat i ves, property or estate may be responsible. Each hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever incurred in the event of breach hereof. 29, PAYMENT OF SPECIFIED OBLIGATIONS During the course of the marriage, wife and Husband have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without the necessity of ascertaining for what purpose and to whose use each of the bills were incurred, that Husband shall be solely responsible for all bills, obligations and debts as set forth in Schedule B, attached hereto and made a part hereof. Except for any debt or obligation of either party to the other under this Agreement, each party agrees to pay and hold the other harmless from all personal debts and obligations incurred by him or her from the date hereof. wife shall be solely responsible for all other bills, obligations and debts not listed on Schedule B. Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills and which, pursuant to the terms herein, are not the responsibility of the other party. In addition, each party represents and warrants to the other that he or she has not incurr.d any debt, obligation or other liability other than those desoribed in this Agreement on whioh the other party is or may be liable, Eaoh party covenants and agrees that if any ol~im, action or proceeding is hereafter initiated seeking to hold the other party liable for any other debt, obligation, liability, act or omission of such party, such party will, at h is or her sole expense, defend the other against any such claim or demands whether or not well-founded, and that he or she will indemnify and hold harmless the other party in respect of all damages resulting therefrom, 30. PROPBRTY RF.LBABB 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 Aqreement or for the breach of any provision of this Agreement. All property hereunder is transferred subject to all existing encumbrances and liens thereof. The transferee of such property agrees to indemnify and save harmless the other party from any claim or liability that such other party may suffer or may be required to pay on account of such encumbrances or liens. Such party will, at his or her sole expense, defend the other against any such claim, whether or not well founded, and he or she will indemnify and hold harmless the other party in respect to all damages resulting therefrom. The insurance on the property being transferred hereunder is assigned to the party receiving such property, and the premiums on such insurance shall be paid by the party to whom the insurance is assigned. By this Agreement the parties have intended to effect an equitable distribution of their assets, The parties have determined that the division of sa id property conforms to the criteria set forth in 53501 et. ~. of the Pennsylvania Divorce Code taking into consideration the length of mftrriage; the faot that it is the first marriage for Husband and Wife; the age, health, station, amount and sou roes of inoome, vooational skills, employability, estate, liabilities and needs of eaoh of the parties; the oontr ibution of each party to the education, training or increased earning power of the party; the opportunity of eaoh party for future acquisitions of capital assets and income; the sources of income of both parties, inoluding but not limited to medical, retirement, insurance or other benefits; the contributions or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as 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, 'I'he division of existing marital property is not intended by the parties to consti tute in any way a sa le or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the matrimonial estate. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 31, MUTUAL RELEASES HUeband and Wife each do 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, of and from any and all rights, title and interest or claims in or against the property (in.::luding income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now 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 of such other or by law 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 right to take against the spouse's willi 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 other Gtate, Commonwealth or territory of the United states, or any other country, or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, 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 this Agreement or for the breach of any provision of this Agreement. 32. PERSONAL RIGHTS Wife and Husband may and shall at all times hereafter live separate and apart. Each shall be free from any control, restraint, interference or authority, whether direct or indirect, by the other in all respects as fully as if he or she were unmarried, Each may also reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Each party hereto releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred relating to or arising from the marriage between the parties, except that neither party is relieved or discharged from any obligation under this Agreement. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. , ' 33. GIWIRAL PROVI8ION8 This Agreement ehall be effective from and after the time of its execution, however, the transfer of the property provided for herein shall only take place upon the entry of a final deoree in divorce, The support provisions of this Agreement shall take effect immediately upon execution. 34. WAIVIR OR MODIrICATION TO BB IN WRITING No modification, recision, amendment or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature, Any oral representations or modifications concerning this instrument shall be of no force or effect excepting a subsequent modification in writing, signed by the party to be charged. 35, MUTUAL COOPERATION Each party shall on demand execute and deliver to the other party any deeds, bills of sale, assignments, consents to change of beneficiaries of insurance policies, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the prOVisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. 36. LAW or PENNSYLVANIA APPLICABLE This Agreement and all acts contemplated by it shall be construed and enforced in accordance with the laws of the Commonwealth of Pennsylvania. . .., I 37. AGRIIMINT BINDING ON HIIRS This Agreemant shall be binding and shall inura to the benefit of the parties hareto and their respective heirs, exeoutors, administrators, legal representatives, assigns and suooessors in any interest of the parties. 3.. INTIGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreaments and negotiations between them. There are no representations other than those expressly set forth herein. 39. INTIRE AGRBBMENT El\ch party aoknowledges that he or she has carefully read this Agreement, including all Schedules and other documents to which it refers; that he or she has discussed its provisions with an attorney of his or her own choice, or has waived the opportunity to do so, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument exprasses the entire agreement between the parties concerning the subjacts it purports to cover. 40. INCORPORATION OF SCHEDULES All Schedules and other instruments referred to in this Agreement are incorporated into this Agreement as ~ompletely as if they were copied verbatim in the body of it. 41. OTHIR DOCUMBNTATION Wife and Husband covenant and agrea that they will within thirty (30) days after damand therefore execute any and all written instruments, assignmants, releases, satisfactions, deeds, notes or such other writings as may be necassary or desirable for the propar effectuation of this Agreement. . .., , 42. HO WAIVIR or DIFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement, The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be constructed as a waiver of strict performance of any obligations herein, 43, SEVERABILITY 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 this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. If any provision of this Agreement is held to be void or unenforceable, all of the other provisions hereof shall nevertheless continue in full force and effect. 44. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solp.ly for the convenience of reference and shall not consti~ute a part of this Agreement nor shall they affect its meaning, construction or effect, ... , SCHEDULE A Mellon Bank credit: Card (Maat:ercl$rd) Account 115417 5990 5059 5815 Balancer $7,000,00 GMAC Auto Loan 1994 Pontiao Grand Am Balancer $7,000.00 I , , , I " , , , , , I I' , , .... I 1st Federal S&L of Rochester VA Insured 1st Mortgage commercial credit corporation 2nd Mortgage Sears Credit Card Discover Credit Card Sunoco Gasoline credit Card Sunoco Mastercard Credit Card Exx~n Gasoline Credit Card Dell/Associates Charge Account Montgomery Wards credit Card Preis Consumer (Note) Lowe's Credit Card Nationsbank Visa Internal Revenue Service Taxes owing Pennsylvania National Bank SCHEDULE B Aaaount I .alanae $104,000.00 1252652 11232-6 9,000,00 05-54654-52116-6 1,300.00 6011-0020-2013-9322 950.00 5001-8967278 20.00 5417-0613-1736-3297 750.00 310-018-054-0 50,00 8-480-003-000011760 1,700,00 262-113-000 550,00 650.00 822-2039-079231-3 450,00 4356-2100-0519-1793 500,00 1995 Joint Return 1,700.00 1995 Pontiac Grand Am 13,900.00 . ~ . . I . EXBCUTBD in triplicate on the day anrl year ri rat above written. Q,,,;,t9 fl,>tf( , J. C ok #i.~>i:'~ :I tiJ-< " nne ,Croo " " 'I 'I " , ' " " , ,'j " , ' , , , ' \F -- _. ".. r.. ~ r ,I '. .~ ~~ .~ i l.': r."') ('. , ~ll. 'J' \.:)'., .~.. J;'I. ~ " ~ .... I', , IL. i'.':\'j ()I J' If') ;'5~'::: f' I I' f~u .. ,IiI) I' " ,Ii '1- . ' ..I.. , fl~ 1 11- m u 0' (, , Jl , , , I! I " , " , II 'j ': , , J, , ' :J " 1.-. " ;1. " , ,I , , , I , , Itl I, I I " ;( il i , " , " il 'I ,I, '>. -. r>. ir: C'J I.: ,'. r,,', 1/: ' ,1,. 1,1',1, ',.1' (_J' '1-:; " Ie, 11.. ~ I ~. 1 ')1 '" 'r , \n I '; ,:,~: Fd: I 1 " 1,'lf'I i.J;I: ~' i,. 1,",1(,'..1 \' .... I"'-~ II. m d () (.'" " '" " ,I :1 'I 't " I L , " ", " I I' 'I , , "I 1 I II ;.\ I, 'I , " " :1, I, 'I ,', ,1-; ,', I, '. I,~ , j':,: (' c 1 ., f'.. ,:.. .' ,I, \;: 1 '. J', 1'- ,. ,I , . " 't:.~ . , 1 I ,'. \''': " ""1 , I I J' i' .. , '!(l, ,t-,I, ...'1 '~, I;; ;.... I' "- "1 '. (,J' 0 " " f " " " , , " ", , I' I, " , I , " , ' " '," ),,: " Ii " " , ., I, , ' I , , " II " I" ., " , " , J , .. ,,, ,. " " " I, IJ " , I ,- j'J'. .' ,r.... I iT: t;; ;) 1 i,' .. ':'u " I. ...., I I. I,' I-i," ~ ' J , U I-'} I 'J ,II ( , l:l~l , i' , l'! ,'.. ,,j lIt it.!.. ~.I ' I ,~ , , \.J f.;)' 1,..) , I ',I , ,'I , , 'II ;! " " " ,I , I " .. , I, ,', " , " " i " , , .. , \I " " , I , I, , " " I , I " , , , " , ," " " , , , , , , 1,\ , , , " " , , i' YVONNE L, CROOK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNSYLVANIA CIVIL ACTION vs, DAVID " CROOK" Defendant NO, 96-40t6 Civil IN DIVORCE I AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce code was t1Ied on July IS, 1996, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of tiling the Complaint. 3. I consent to the entry of a tinal decrec of divorce after service of notice of intention to request entry of the decree, I verify that the statemcnts made in this aftidavit lire true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S. ~ 4904 relating to unsworn falsitication to authorities, Dated: j~:;,/:'-") / / I j ~ / j/ CU""'~. ~t ~DJ,CROO , Defendant SWORN TO AND SUBSCRIBED BEFO - ME THIS L-:://' DAY OF ".",t.. / 1997 "". ,,,, I' My Commission Expires: .,.--..-- ~'" ,I.i-,,",; , '. ' II;; I ('I j, I I ;;11'11 1~'_llJllly l,,'.. ,11' '.. :" ',_ ',,,,, In') " ' 'I,""-I,'rl[(\l,'ir',-,(' ..,jJ. IllY""',) I."'" I - , I' , q , , , I I i " I I ,I , I , I' ~ - ?,: /I t"l ~~ , c:, ~ ~ " ,'J . " ," ('" ~ ' .( .~ 0.- (P,:'j r., 'fn C' ,.~ r- ')~ ~i I ,1 I" -, \.l,i 1:\ " ... I, " ..r. 1-' -) ~ ~ a:: 'Ii' el' I , " , " Itll 'I '1,'1' I, ,I >J,' I' " , I " , I , i\