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HomeMy WebLinkAbout96-04082 " ;, "If~i , ct" ,~ lh:l. I ~,t''i;'I' <ff III":' ltr-;.o.Jj .'t\, , "B"_,I! Ur,h ! I"N1i ci)i/l ,'(. , ,,\i_ ,..,"1," ~'.l~ ',"'. fIil" (l. 1i' ~L- ' l~,-,~r:, 1',:,1"; \-1 (/ I I. ll,'-_':! I, d ~I f,i,:'l. .or.' I i'l , ,~, .' " ,', 'I' 1,.' .,,' , 'I I' I{ .. 11,1,_' ., " I i', " " " " " " ,,: " "'"I , ,,' , , Ii '} , " ,I, ., " I, .,' 'I,,; ,I! , H, " ,',1 1,,-;# ,Ii , , ;, ,i ,'1 ,,:'J1r r'j " 'I .'1' " I I }' I' I ,I t ,I I,: .II' " "1, 11,1 '1 " I II i ,1/) I' ,''1 " ',' ", ., " " \, , " , " ' , . '. ,'-' .1 I '~q ./ ~ H,~ , " 1/1 Ill, , '1,-1 ,J 'I" , ., " I , ." I II I , , " ....,.. ..- " , ) , ,'I' 'I, , " , "J , " , , " ,I , " \ , " '1'1' " I '1' , , II "I' "1'1,.-,- ., '(1 f1? :~ , " , " , '" I, j' " " ," " ,', " , , ,i ,I, ,I II , ..9 0-, , \ " " '1 " 'I ,1' " \! , . ., o < '. " " 'I" 'it-I , :.'" 1 ,',I '.' 'II, . " in ':'1' I ,. 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'. ~~~~~-~-~,.~.~.~.._.~**.~.~>*.~-~~~~-_., ~I'-'''-----''''''-''--'''-'' ..,..",,,~ ",...',.,.."",.,......- ..-"....-....,'-.......-..,,'.. * ~l 8 :i IN THE COURT OF COMMON PLEAS : $ OF CUMBERLAND COUNTY ~ 8 e ~ * ~ ~! STATE OF ~... ", ~ PENNA. 8 8 \, ..r 8 , ~ 8 '" M[CllELL~, L. BUSBEY, " N l) ,96~4.~~2,.. ",~.[.YI~.. It) * ~ l'~llinlHf ~ ~ V,')'SIIS e $ KEVtN R. BUSlIEY,' 8 $ Defendnnt ~ ~ iii ~ , $ iii ~I $1 ~ ~ 8 S 8 $ 8 $ ~ ~ 8 8 ~ ~ 8 8 ~ - -- ----,-" ,... ... '*' .w.. ... . DECREE IN : AND NOW, ...qDIV;~f,~1h ~,!.:~~tP1l! decreed that..... .......... .. tf.[ql~~p: ,.... !1~"!I!:Y..,,,...,....., plaintiff. I~ and. .. . . . . .. .., . . . . .' . . . , , . . .. .KE'JI~ .Il.. ,llUSlIEY . . , ,. . . . . . . . . " defendant. : ore divorced from the bonds of matrimony. ~ The court retains lurlsdlctlon of the following claims which hove been raised of record In this action for which a final ordl9r has not yet been entered; , . . .N,!ll~'. . . Th~ . ~ ~ ~,!~h~d .P'!~ ~ '7N,!~ t i~i . ^~ ~~~~~1! t . i ~ . t~~'!~~'!~~~ ~1 / . ~'f~. ~~~ . ~~~ged , into thi. De~ree. tie ,.,..-< " I )~/-(, ,) J/ ...J J. ~;J't .-t./. ..,,~--' ( {.(...~..,,.. / '''-r~~H.f1c.rt,/ I, -:--' V p' ~ .v./ '1' .-. flt').." ,. ,/'~< t1. ";1''':/.._ rI Prothonotnry .' ... .:<<. .:<<. .:.e. .:+:- .:.;. ':.:.0 -:.;. -:+;. .:+;. .~.> .:+:- .:.:. ~ .:.:- .:.:. .:+:- .:..;. .:.;. .:+;. .:.;. .:.:. .:+:. .:+:. >l ~. $ :~ r I~ I' ,~ I~ '.' ~ ~ I' ,,:, /" :~ .' , .~ ," (~ , ~ , !~ , .' ~ ... WHEREAS, certain differences have arisen betweon the parties, as a consequence of which they have separatad and now live separate and apart from each other, and WUEREAS, on July 17, 1996 Wife commenced an aQtion in divorce dockoted to No. 96-4082 civil Term in the Cour.t of Common Pleas of Cumberland County, Pennsylvania (hereinafter referred to as the >>Oivorce Action>>), and WHEREAS, the parties a0ree that their marriage is irretrievably broken; and WHEREAS, the parties acknowledge that each has had the full I opportunity to be advised independently and represented by separate counsel concerning his or her respective rights, duties and obligations arising out of their marital status and with respect to the terms and provisions of this Post-Nuptial Agreement and the meaning and legal effect thereof; and that each has been so advised and represented or has vol1Jntarily chosen not to obtain such advice or representation; and L.AW o,,,cn SNILIAKER II BRINNEMAN WHEREAS, the parties having a full opportunity to be so advised of their respective rights, duties and obligations arising out of their marital status, and each having a full opportunity to investigate and evaluate assets, liabilities and all other aspects of each other's property and their jointly owned assets and liabilities, have come to an agreement for the -2- .. " tinal settlement of their property and affairs, which they believe to be fair, just and equitable. NOW THEREFORE, in consideration of these presents and the mutual covenants, promises, terms and conditions hereinafter set forth and to be kupt and performed by each party hereto, and intending to be legally bound hereby, the partiell mutually agree as follows: I 1. INCORPORATION OF PREAMBLE. The foregoing preamble and I paragraphs are incorporated by reference herein in their I entirety. I 2. MUTUAL SEPARATION. Husband and Wife shall be free from constraint or control by the other as fully as if he or she were unmarried. Neither shall disturb, trouble or interfere in any way with the other or with any person for associating with the other. 3. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION. The parties declare and agree that they have voluntarily agreed to divide and distribute between themselves their personal property, furnishings and furniture in accordance with the inventory attached hereto and incorporated by reference herein as "Exhibit A", with Husband to own and possess those items of LAW a,,.c:.. 8NIL.Al<I.. a IIftINNr,.,AN property listed under his name on the attached inventory and Wife to own and pO$sess those items of property listed under her name -)- .. . thereon, and with each to own and possess such property free and olear of any claim, right or use of the other. It is acknowledged and understood that c~rtain items of property listed as being owned and possessed by Wife shall remain in the marital home at Wife's option, until such time as Wife shall r~move same, but in no event later than March 1, 1997. Husband agrees not to waste or damage any items of Wife's property remaining in the marital home. The parties acknowledge and agree that the division and distribution of property as set forth above has occurr'ed whether or not said property is or would be deemed to be marital property I under the Pennsylvania Divorce Code and subject to equitable distribution. The parties declare and acknowledge that they are fully aware and familiar with all assets and property that each has brought into the marriage and that has been obtained or acquired separately or jointly by them during the course of their marriage and therefore waive any valuation thereof. Each party expressly releases the other of and from any and all right of equitable distribution or claims to assets and property of any kind or nature whatever possessed in accordance with this Agreement by the other party and hereby declares and acknowledges that the voluntary division by them of all property, whether marital or not, is fair and equitable. LAW o"lcn SNILBAKIR a a.n:NNE'MAN -4- . .. 4. MARITAL PROPERTY AT 840 CARDINAL LANE. LEWISBERRY. Husband and Wife acknowledge that they have acquired during their marriage real prope,rty improved with a residential dwell.ing located at 840 Cardinal Lane, Lewiaberry, York county, Pennsylvania (hereinafter the "marital residence"). said property is encumbered by a mortgage held by National city Mortgage (hereinafter "National city"), which mortgage is acknowledged to be a marital debt. Husband and Wife agree that the marital re$idence shall be sold as soon as practicable pursuant to the terms of the Exclusive Sales Listing Contract, or any extension thereof, entered into by the parties July 17, 1996 with M. C. Walker Realty. upon the sale of the marital residence, the net proceeds of such sale shall be divided equally at settlement between the parties. The parties further agree to divide equally any refundable balance remaining in the escrow account held by National city Mortgage. Husband and Wife each agree to contribute and pay one- half of the monthly mortgage and escrow payment until the marital residence is sold. Wife will make her one-half payment to Husband on or before the first day of each month. Husband agrees to timely apply and pay the full monthly mortgage and escrow payment. In the event Husband desires to reside in the marital L.AW O,.,ICII SNI~IIAKE" a BRENNEMAN home, he agrees to be solely liable and responsible for all -5- . , expenses, maintenanoe expenses and utilities servicing the merital home until it is sold. In the event Husband moves from the marital home prior to its sale, Uusband and wife agree to share equally all expenses, maintenance expenses and utilities servioing the home from the time Husband moves until it is sold. 5. JOINT BANK ACCOUNTS. The parties agree that all joint accounts of any nature or type have been or shall be closed and the proceeds or balances ot such accounts divided equally between them no later than five (5) days after the effective date of this Agreement. 6. AUTOMOBILES. The parties acknowledge that Husband is leasing a 1996 Ford Ranger and Wife is leasing a 1995 Jeep Wrangler and that Husband is responsible with Wife under Wife's lease contract. Wife shall retain sole possession, use and ownership of the Jeep, free of any claim of possession, use or ownership of Husband and Husband shall retain sole possession, use and ownership of the Ford, free of any claim of possession, use or ownership of Wife. Each party shall be solely liable for all payments, costs and expenses under his or her respective lease agreement pertaining to the vehicle each possesses and shall hold the other harmless and indemnify the other of and from any liability thereunder. LAW O,'ICII SNILBAKJ:A It BRENNEMAN -6- .. , 7. TAX MATTERS. The parties agree to divide equally the mortgage interest deduction associated with the mortgage on the marital home for 1996 and 1997. In the event the marital residence is sold by the parties in 1997 or thereafter, the parties shall share equally the capital gain, if any, as a result ot such sale, each being responsible for roporting one-half (1/2) , ot the capital gain on his or her respective taX return. Each party agrees to hold harmless and indemnify the other of and from ' any tax liability including penalties and interest, as a result of his or her neglect or failing in properly reporting or treating the capital gain allocated hereunder. S. OTHER DEBT AND LIABILITIES. Husband acknowledges that he is solely responsible certain student loan debt incurred by him prior to the parties' marriage. Husband agrees to indemnify and hold Wife harmless of and from any liability tor such debt. LAW O,,"'CI. SNILBAKI" a B"INNEMAH 9. FUTURE OBLIGATIONS. The parties agree that any and all obligations incurred subsequent to July 7, 1996, shall be the sole and separate liability and responsibility of the party incurring the obligation and each party agrees that he/she will not incur or attempt to incur any obligations for or on behalf of the other party and will indemnify and hold harmless the other party ot and from any and all liability arising from such future obligation. -7- " " 10. COUNSEL FEE~. Each party to this Post-Nuptial Agreement shall be responsible for paying his or her OWn counsel fees and related costs, if any, associated with the p~oc.s.ing of the Divorce Action and any matter related thereto as well as th~ negotiation, execution and consummation of ths provisions of this Post-Nuptial Agreement. 11. PENSION. 401K. RETIREME~T PLANS. BENEFITS AND EMPLOYMENT BENEFITS. The parties acknowledge and confirm that neither has prior to separation had, received, or participated in any pension, 401K plan, retirement plan, E.S.O.P. or other retirement or employe. benefit of any nature. LAW O"IC.' SNEL8AKER It BRENNEMAN 12. RELEASE OF SUPPORT AND RIGHTS UNQER DIVORCE CODE. Unless otherwise specifically provided herein, each party waives and forever releases the other party of and fr'om any and all claims which either may have again~t the other for spousal support and for all claims which either may have against the other by reason of and pursuant to the Pennsylvania Divorce Code (and the divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, costs and expenses, except that the performance of any obligation created hereunder may be enforced by any remedies under the penneylvania Divorce Code. -8- . ... 10. COUNSEL FEES. Each party to this Post-Nuptial Agreement shall be responsible for paying his or her own counsel tees and related costs, if any, associated with the processing of the Divorce Action and any matter related thereto as well as the negotiation, execution and consummation of the provisions of this Post-Nuptial Agreement. 11. PENSION. 401X. RETIREMENT PLANS. BENEFITS AND EMPLOYMENT BENEFITS. The parties acknowledge and confirm that neither has prior to separation had, received, or participated in any pension, 401K plan, retirement plan, E.S.O.P. or other retirement or employee benefit of any nature. 12. RELEASE OF SUPPORT AND RIGHTS lmDER DIVORCE CODE. Unless otherwise specificnlly provided herein, each party waives and forever releases the other party of and from any and all claims which either may have against the other tor spousal support and for all claims which either may have against the other by reason of and pursuant to the Pennsylvania Divorce Code LAW o,,'lcn SNIILBAKIEA II BRENNEMAN (and the divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, costs and expenses, except that the performance of any obligation created hereunder may be enforced by any remedies under the Pennsylvania Divorce Code. -8- I.AW O,,.CII SNlEL8AKIA II el'tENNIMAN . . 13. DIVORCE. The parties agree that their marriage shall be terminated on the basis that it is irretrievably broken. Both parties agree that they will, immediately atter October 15, 1996, which date is 90 days after service ot the Divorce Complaint upon Husband, execute any and all necessary affidavits, waiver., consents and documents in order to obtain a divorce by consent under S3301(C) of the Divorce Code. 14. GENERAL RELEASE. Husband relinquishes hi. inchoate intestate right in the estate of Wife, and Wife relinqui.h.. har inchoate intestate right in the estate of Husband, and .ach ot the parties hereto by these presents, for himselt or herselt, hin or her heirs, executors, administrators or assigns, doe. hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or a..igns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity ot whatsoever kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such other party prior to the date hereof, except that this release shall in no way exon.rate or di.cha~ge either party from the obligations and promi.e. made or imposed by reason of this Agreement. 15. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post-Nuptiftl Aqroement shall survive any action in divorce which may be lnatitlltocl or pro..cuted by either party, II -1)- .. and no order, judgment or decree of divoroe, temporary, interlocutory, final or permanent, shall affect or modify the terms of this Agreement, but said Agreement may be enforced by any remedy at law or in equity, including enforcement proceedings I under the Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a Beparate order of court to be entered in the Di,vorce Action, but this Agreement shall not be merged into said order or decree in divorce. 16. COOPERATION. The parties agree to cooperate with each other and to make, execute, acknowledge and deliver such instruments and take such further action as may hereafter be determined to be requisite and necessary to effect the purposes and intention of this Post-Nuptial Agreement. UW O,,,CII SNi:LIIAKE" III BRENNEMAN 17. ~REACH: INDEMNIFICATION. If either party hereto breaches any provision hereof, then the nonbreaching party shall have the right, at his or her election, to sue for damages for said breach, or seek such other remedies or relief as may be available to him or her, and the defaulting party shall be responsible for payment of all reasonable legal fees and costs ircurred by the other party in enforcing his or her rights under this Agreement. Each party agrees and covenants to indemnify and hold harmless the other party from any and all liability and/or claims and/or damages and/or expenses (inClUding attorneys' fees and expenses of litigation) that the indemnitee may sustain or -10- ,I . . may become liable or answerable in any way whatsoever, or shall pay upon, or in the consequenoe of, the indemnitor's breaoh of any obligation, term or covenant of indemnitor under this Agreement, including, but not limited to, indemnitor's Obligation to make any payment provided for herein. 18. VOLUNTARY EXECUTION. The parties declare and acknowledge that they have had the opportunity to have the provisions of this Post-Nuptial Agreement and their legal effect fully explained to them by independent counsel of their choosing and each party acknowledges that this Post-Nuptial 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 furnished with all information relating to the financial affairs of the other to the extent same has been requested by each of them. 19. ~RE AGREEMENT. This Post-Nuptial Agreement contains the entire understanding of the parties and there are no L.AW O"ICU SNILI"KER II S"INNIMAH representations, warranties, covenants or undertakings other than those expressly set forth herein. The parties acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of I their marriage and other relevant factors which have been taken -11- into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect 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 jurisdiction pursuant to I the Pennsylvania Divorce Code or any amendments thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 20. WAIVER. The waiver of any term, conditions, clause or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. 21. ~ICABLE LAW. This Agreement shall be construed, inter.preted and enforced according to the laws of the Commonwealth of Pennsylvania. 22. MODIFICATION. This Agreement shall not be modified unless in writing signed by both parties hereto. UW o,"c.. SNILBAKER a S.nNNIMAN -12- " " I " " " 1 , , " 'I,I , ," Ijl, , "11,J1 " II - I:: " " " Ln -, " ~ ,I.'l~ )1 " e" "~ '5'ii: ~' ::.i! ~~ .Q ,I'll) " W I ,t~ " , ' ~ III " . ,~, ;;1:, ~ 'i' ~ ~ , ,,' " ,', , ., I', t , " " " , , , , , , , II , ,I, " " " , , " " " ill " LAW a....u.:c. 6NI!:I.DAI<ER II BmHiNEMAN MICHELLE L. BUSHEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'ry, PENNSYLVANIA NO. -/ r. - '/u \"..L c:.(;"f I;.." CIVIL ACTION - LAW v. KEVIN R. BUSHEY, Defendant IN DIVORCE NOTICE 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 Rgainst you by the Court. A judgment may also be entered against you for any other claim for relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, inclUding custody or visitation of your children. I I When the ground for divorce is indignities or irretrievable breakdown of the marr.iage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and I you are not bound to choose a counselor from the list. AU ! necessary arrangements and the cost of counseling sessions are to i 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 DECREE OF 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 FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator One Courthouse Square CarliSle, Pennsylvania 17013-3387 (717) 240-6285 SNELBAKER & BRENNEMAN, P.C. LAW O"IC~' SNILBAkl!" . BRENtU'MAN MICHELLE L. BUSUEY, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBER~ND COUNT~, PENNSYLVANIA I va. I NO. I CIVIL ACTION - LAW KEVIN R. BUSHEY, I Defendant: I IN DIVORCE COMPLAIN'r 1. Plaintiff MICHELLE L. BUSHEY, is an adult individual residing at 22 East: Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant KEVIN R. BUSHEY, is an adult individual residing 840 Cardinal Lane, Lewisberry, Yorl: County, Pennsylvania 17339. 3. Both the Plaintiff and Defendant have been bona fide esidents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in arriage on November 5, 1994 in Mechanicsburg, Cumberland County, ennsylvania. 5. There have been no prior actions of divorce or or annulment between the parties hereto in this or any other urisdiction since the date of the marriage averred in Paragraph LAW Ol"t'ICl.:' SNELBAKEA a BRENNEMAN MICUELLE r,. BUSHEY, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I 'll"lfo~J-, vs. I NO. I CIVIL AC'rION - LAW KEVIN R. BUSHEY, I Defendant I IN DIVORCE AFFIDAVIT MICHELLE L. BUSHEY, being duly sworn aocording to law, deposes and saysl 1. I have been advised of the availability of marriage oounseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do ~ 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 false statements herein are made subjeot to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Datel 1\\\~~ LAW o"..ca;. SNILBAKIER II BnlENNEMAN MICHELLE L. BUSHEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-4082 CIVIL TERM CIVIL ACTION - LAW VB. KEVIN R. BUSHEY, Defendant IN DIVORCE AHIDAVIT OF SERVICE COMMONWEALTH OF PENNSYrNANIA) : CUMBERLAND) ss. COUNTY OF Keith o. Brenneman, Esquire, beinq duly sworn aocording to law deposes and says: that he is a prinoipal in the law firm of Snelbaker & Brenneman, P. c., being the attorneys for Michelle L. Bushey, the Plaintiff in the above captioned action in divorce; that on July 17, 1996, he did send to Defendant Kevin R. Bushey by certified mail, return receipt requested, restrioted delivery, IS duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. P 231 861 962; that both the Complaint and cover letter wore duly received by Kevin R. Bushey, the Defendant herein, as evidenced by the return receipt card for said certified mail dated July 19, 1996; that a copy of the aforementioned cover letter dated July 17, 1996 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B"; and , I , , 1 6' , ., r', ,I ~ p," ,I , , , ('I, , l' ~i! , , 1 {:,r I , , I. " " I,. , , , , 1 , , " l.'. ,;, ~I , , "I.: , , , , " 'I , ' " , , " 1 " i " I , , " , , " " " " .' " " , , , '.1 , I' , , , I " , " LAW O"ICU 6NILIIAKftA II BRENNIMAN , . f t . I J f MICHELLE L. BUSHEY, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS. I NO. 96-4082 CIVIL TERM I CIVIL ACTION - LAW XEVIN R. BUSHEY, I Defendan~ I IN DIVORCE illIDAVIT XEVIN R. BUSHEY, being duly sworn according to law, deposes and saysl 1. I ~ave been advised of the availability of marriage oounseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do HQI 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 falsa statements herein are made SUbject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date I 10 /'J.f( I"}~ ,I , ' " " I' ;} !, ,I ", if , 'I ,. 'I r; , " Ii' ,. i' " , , . Ii' , I, ," " , I It ,I ~ - (,:; '" . , ...: In t db 4- ,l,.r. ., ")~ e,) :r: ',J~ ~. oq: " (, ')~ , II' " ! 1.0 'I. , (J, , rq FE . , (I' :>- " ,1:: !it .,. & tJ:l ~ Ol I' " I, " 1, " " " 'J '-II' " . . . . il .., " LAW OP'I'ICIt. SNILBAKER . BRENNEMAN . .. ., .. , .. MICHET.LE L. BUSHEY, I IN THE COURT OF COMMOlf PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I No.9" ~ 'f(J /J <- vs. I I CIVIL ACTION " LAW XEVIN R. BUSHEY, I Defendant I IN DIVORCE DEFeNDANT'S AFFIDAVIT or OONSENT UNDER SECTION 33011Cl OZ-jHE DIVORce OODE 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on the 17th day of July, 1996. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) daya have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made oubject to the pennltieG of 18 Pa. C. S. 54904, relating to unsworn falsification to authorities. Datel Nt)\J ;) I I cnC IL '" - /1 II j}~ ~, t~~~/) Kevin R. B~S~ (Defendane) 1,1 , , I' I! , "1 I' " 'I " 1, ,'I , .11 , , , " " " 'I; , ,Id I , , , , II " , , I.; , , , " ~ -. ,':: In ~I I~ 6!l 'Ii :li I " l.J II (, .0 '~m r', ,,' g: I " :> , '" " [J/ , ~~~ ~ ~ ~ lD 0'\ 'I " , " 'I' " , " I " 'II , , , , 'I , \ I " 'I I , , , I, " , " , , , , '" " I" , , " \ , , , I , , , , ., " .. . . ~ .. ~ .