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Home My WebLink About96-05219 ~ ~ ~ ~ -' ~ " . . kl - . 1 I t:: ~ ~ ... ~ t s , /1 . ,', , ' , . . f :" ... i :) , .- i ~ I I b-- ..... ~ . ~ " . ~.~---~-*~~~**.~.*~.**.~~.:.~.***~**.~~~ ~ ~-------~- ..---~-~ _.... ---...- - -.........--....- - -. ',' <,..~ .... ~- "'" ~ . , ~ - . .~ <. w' ",', ,I ~ ;s ,", <. IN THE COURT OF COMMON PLEAS i~ I' I,', ~ ~ i' i~ I: (~ ( , )~ ~~ ~~ I' ),', :~ . .~ " ~~ ~:' .: ! M! , , OF CUMBERLAND COUNTY STATE OF ~ PENNA. !ill ) ,,? , ( 1(; , , , i ~( . Mi , . ,i IIi : I ~. , I 1(' , . !il' , I ) 8j 81 8 ) 8 ~. ~ tI JAMIE M. NIKOLOFF :\0, 5219 II) 96 V,'l'...lh JOHN A. NIKOLOFF .~ ,~ ~ ,I,' ~ OoE,;Rciic'/J:)1J:WfA: , , . .J,h . 19 97 ,it is ordered and ~ AND NOW, decreed that J^,'1IE M. NIKOLOFf '" .; fl; .! ) 8: * _1 wf ~i 81 8! II i -\ II; Il II . . . '\It ~ ~ plaintiff. defendant, ~ ~ ~ loi ;oj JOlIN A. NIKOLOfF and ore divorced from the bonds of matrimony, 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; ~ ~ 'I.lrit~l Scttl._nt -"If.'<......'nt ""ted Augu-_t,. lQ<}'7. ..tt;oched h.:rl'to. <l <l 1:3 tnl"\)r~'!lJf.1tl..~f tut t"Jt !'Mt:Tgt;.~. inlQ t~ Dt..'Cf'-'e in Oi\vr\..~. . . . b; ,.J...,v_.s., J " if '" ,-'" ""-."'" ....~ , _"./.r!' ....".,;~ I .. r..dl:'H"'I'~ ''''\ . . ..,. -, - . ~ ..r_..I'.~' . . . . .. . . , . .. . 16"7/4/ Jvl "'t'~ ,,,~ -t. rff '71"~( /II~N ~ b~ ?~'le:~~~44d/'W~... . JAMIE M. NIKOLOFF Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. v. : HO. 96-5219 JOHN A. NIKOLOFF Defendant : CIVIL ACTION - LAW : IN DIVORCE IWUTAL SE'I"l'LEMEHT AGREEMENT THIS AGREEMENT, made this )" J)t- day of 4u..,~r , 1997, by and between JAMIE H. NIKOLOFF (-Wif.-), of Mechanicsburg, Pennsylvania, and JOHlf A. HIKOLOPF (-Husband-), of New cumberland, Pennsylvania. WITNESSETH WHEREAS, the parties hereto are Husband and IUfe, ..rried on Septellber 28, 1985, in HarriSburg, Pennsylvania, and are the parents of Jordan Elizabeth Nikoloff, born June 19, 1987. WHEREAs, diverse, unhappy differences, dispute. and difficulties have ariaen between the partie. and it is the intention of HUsband and Wife to live aeparate and apart for the reat of their natural live., and the partie. hereto are de.irous of .ettlinq fully and finally their respective financial and property rights and obliqations as between each othu incluc11nq, without limitation by specificaUon: the ..Ul1nq of aU utters betve<tn th.. nlaUnq to the ownenb1p and equitable dbtrib\&t1on of real and personal property, and the settUnq of any and aU clai.. and possible clai.. by one aqlllinst the other vr aqainst their respective ..tat... a. well.. any otller utten related hereto. 0#"""-"'_ '- NOW THEREFORE, in con!::idcration oC the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree a~ follows: 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDING,S This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolut.' divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which ~y occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the teras of Section ))Ol(c) of the Divorce Code of 1910, as aaended February 12. 19ns. 2. IU.IC'T 0' DIVQRCE DECDRR The partieR agree that unless otherwise spociftcally pray i ded herein, this Aqrec\llCnt shall c."Ontinue in full force and etfect atter such tlae as a final decree in divorce aa, be t'nter'@d with respect to the parties. The partin aqree that in th" eV11nt of _bso I utII!' divorce bet_en th.., they shalt nonetheless cOfItlnue to be bound by all tJ\e teraa of thla ^'lNt'..nt. Thlc o\l1f<<!t'lKnt fthdll bt! tU.... wlt.h tM emu-t of , Common Pleas of Cumberland County and incorporated into the final decree of divorce for enforcement purpo~es only. J. DATE OF EXECUTION The "date of execution" Ot- "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Aqreement. 4. DISTRIBUTION DATE The tran~fer 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. 5. CONS~ OF P1)RTIES Husband and Wife' acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. HUSband and Wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it Ie boinq ontC'r<'d into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal aqrecmcnt or agreements. r. . tllWU;1A1._DlSCJ.QSURE The parties confi~ that each has relied on the substantial accuracy 01 the fin~ncial disclosure of the other, except as set forth herein art an induceaent to the execution of thin Aqr"lIIent. 7. PERSONAL PROPERTY Except as set forth hereto, Husband and Wife have agreed that their personal property, including the parties' automobile, has been divided to the parties mutual satisfaction and neither party will make any claims to the property possessed by the other. 8. REAL PROPERTY The parties hereto aqree that the marital residence located at 293 Bradley Circle, New Cumberland, Pennsylvania, shall become the sole and separate property of Husband: and the property located at 2010 Market Street, Camp Hill, Pennsylvania, shall become the sole and separate property of Wife. Each shall be responsible for any and all mortqage payments, insurances, taxes or any other expenses related to their respective property, and shall hold each other harmless and indemnify each other in the event of any default of the mortgage, taxes or related expenses on their respective property. 9. HEALTH IXSURAHCI!:. LIFE INSURANCE. Co\SILSP.TTT J1IENT Husband hereby agrees that through and/or until September 1, 1998, he shall continue to: A. .aintain Illedkal insur:tncc covcraql.'! on Wi fe: 8. maintain life insurance in the amount of $100.000.00, with Wife as sole beneficiary: C. aaintain Wife as a aelllber of the COlonial Country Club: and I). P"\' to Wi f e '$l. :tlO. \111 per l!I<:lnth. 4 1U. 1996 FEDERAL INCOME TAX The parties hereto that the parties shall file jointly for tax year 1996, and turther agree to evenly divide any tax refund on a 50-50 basis. The parties anticipate divorcing during 1997 and filing separately in 1997 and thereafter. Husband shall also have the child tax exemption in 19?7 and thereafter. 11. AFTER ACOUIRED PROPERTY As of September 1, 1996, each of tho parties shall own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, and/or real property, acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried. 12. WIFE'S DEBTS Wife represents and w:1rrantl:l to Husband that since september 1, 1996, she has not contracted or incurred any debt or liability for which Husband or his estate Jliqht be responsible and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution o( this ^qrQQlIlcnt tor which lIur:b."lntl or his estate might be responsible. Wile shall indcanify and save harmless Husband from ."lny "nd all clai_ or de"and::: lIlado "q"inst llusband by reason of deht!!: or obliq3tlonll H\currcd by Wife. " 1:1. HUSBAND I S DEm Husband represents and warrants to Wife that since September 1, 1996, he has not contracted or incurred any debt or liability for which Wife or her estate'might be responsible and Husband further represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indemnify and save harmless Wife from any and all claims or demands against wife by reason of debts or obligations incurred by Husband. 14. MARITAL DEB'l'S Husband and wife agree that lIusband shall be responsible for the American Express, PSECU-VISA, CoreStates Account number, 04-20-212548-2, and CoreStatos account number 10-00-115348-4, Texaco and Hobil credit Card debts incurred as of September 1, 1996: and Wife Shall be responsible tor the JCPenney, MDNA-VISA and Lowe'c credit card debts. and the Corc5tates account number 04-20-189833-7, incurred as of ~pteaber 1, 1996. The parties further agree that except as otherwise set forth hereto, Husband shall be responsible tOf any debts solely in his naae, incurred as of Septeaber 1, 1996, and Wife shall be responsible for any debts solely in her naae, incurr~j as of Septeaber 1, 1996. 15. ~ lIu~b.'n<.I anrl Wife 'lqf~,' th.lt the they shall MVC joint 1eqal custody or the ~rties' child, Jordan Elizabeth Nikolotf, born Ju_ 1'), l'}!H. T~ p.uti.'s furth"f ,.'trlM> th.lt said chlld '!Il'ql! r~r;hk Vlth Ih,I-l:.t4n..l. 'l"J Wl!<' <11\<\11 1\4..." eu""tody tt_ .' periotl~ each week on 'l'ue~day <lnll other weekend from Frid<lY evening shall h<lve custody in nddition parties. Wednesday evenings: and every until sund<lY evening. Wife hereto as agreed upon by the 16. BUSINESSES-QF PARTIES Husb<lnd <lnd Wife agree that lIusb<lnd's ownership share of C<lpit<ll Associ<ltes, Inc., sh<lll become his sole <lnd separate property: and Wife's business, Eclectic Gatherings, shall become her sole and se~rate property. Ench shall be responsible for any and all debts for each respective business incurred before and after September 1, 1996: and shall hold the other harmless <lnd indemnify the other for any default of said debts of the respective businesses. l7. IfAll'QLQLRIGHT$ The parties hereto fully understand their rights under <lnd pursuant to the Divorce Code, Act of 1980, No. 1980-26, as ;,:. Amen<Jpd t'ebru;:lI'Y J;', 1'lllU. particul;,rly the provisions for alimony, aHllOny pendente lit.... spousal support, equitable distribution of .~rital property, attorney fees and expenses. Doth p':lI:ties agree that this AtJrcellent shall conClusively provide lor the distribution of property under th<.' s;,id law and thi:! parties hereby waive, release and forever relinquish any further rights they aay r~spectively have against the other for allepny, ,\1 illOny pendente I ite, spousal support, Cl!quitallle dhtributlon of Marital property, attorney f~~ ami expenses. III . eJ;;BStlNAJ".JlliiIITS Husband and Wire may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They. may res ide at such place or place!: as they 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. Husband and wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabitate or dwell by :lny IIlcans or in .:lny ..,nncr whatso<'ver with hilll or her. I'} . HtmlML..REl.V.SE Ilusband <Inn Wife each do hereby lIlutually remise, release, quitclaim and forever discharge tho other and the estate of each other, for all time to 1:0_, an" for all j-Jurposes whatsoever, of and trOll any and all riqhts, title and interests, or claims in or aqainst the property (includinq incolIIe and gain frOll property hcrcaftQr itccruinql of the oth.'r or iUlain!1t th@ estate or &3ch nt ht'"'r. of w-h,ttpvc',. n",turp .,,,....1 wht-'t't"~-:;n"v....t~ .~ i t tI...,t<, , wh ich he or ~he now has or at any tiae her~a(ter 1I\.1Y have: or any riqhts Which either ~~rty ~y ha~~ or at any ti_ hereafter have for I'.",t. pr...~"'nt or tutUH' '~p'''l".\l "uI't'''t! ur Lltntcn;tncE>, alllk>ny, ,Ill""n., ro-rn.htntl," lit..... :l1)<lu:;"l !:ul1ptlrt, ""'t\lit.lbl" <listribt.itlOl'\ of '''''fit.') propt'fty. .lttOtncy h'e::. ,.~,!"\t!'. ".. eltpttn'llH. wt\~thor ;.. ~ricing ~c ~ rccutt of the marit~l relation or otherwise, except, and only except, ~ll riqht~ and agreements and obligations of whatsoever nature arising or which m~y arice under this Agreement or for the breach of any provision thereof. It is the intention of Ilusb~nd and Wife to give to each other by the execution of thic Agr,!ement 0 full, complete and general release with respect to ~ny and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 20. KA1YElLQlLH9.Dll:lCAn.OlL~-1lJ;: IN WRITING A aodiCication or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties and executed with the came formality as this Agreement. No waiver of any breach her~o[ or default hereunder shall be deemed a waiver of any subs~uent default of the same or similar nature. 21 . Mt!IlJM....CQOeBMT.1QK r:,l<.:h p.nty !:h,.lll. .It ,my t ill(' and from tillCl to ti_ hereafter, ti1ke .1ny a",! ;.\11 steps and execute, llcltnowledge and <It\'liver to the othel' piuty, any ,lnd .:Ill future instruments and/or \lo'~\llllcnts U\4t the other party IUY re.uon,lbly rt>quire tor tn.:lt purpo~... of qivin'l fut \ for,~('< "",I ,'Cfeet to the provisions of this .',~:~tt"'e_p"t. _ " 22 . lll..T.EGR.UlON 'l'his Agreement cOn!.t i tllte~; the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There arc no representations or warranties other than those expressly set forth herein. 23. A.GRUMENT BItfiUHLON HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, su.:cessors and assigns in the interest of the parties. 24. QDIER~ Wife and Husband covenant and agree that they will forthwith and within thirty (30) days after demand or due date, execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Aqnlt'mcnt, and.:l~ thei r respective counsel Ghall mutually .1<Jrec, ,,:huultl tJ<. ,:" cx.'cuted ill order to carry out fully and effectively the terms of this Agreement. 25. II(LNALVEtLj;,lLDUAUI.T This Agreement shall reaain in full force and effect unless and until ter.inat~t under and pursuant to the teras of this Aqrec_nt. The t.:lilure of either p.:lrty to insist upon ,:tri.:t perfor.",n"" ,n ,Illy 01 th.. l'l'"",inilm,.; of thu: Aqr~elk~nt ~hall In no vay aff~~t th~ right of ~uch patty h~reafter to ,~nforCl' th<:> sallie. nor sha II thO' .,r;, 1 ........ of '\")' '5ul)$4I!q\l~nt ,!C'[.1ul t 1\) of the ~:amc or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 26 . ImEACli If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorney fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 27. SEVERABILITY If any term, condition, clause or provisions 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 his or her Obligations under anyone or acre of the provisions herein, with the exception of the satisfaction of the conditions precedent, shall in now way avoid or alter the remaininq obligations of the purties. 28. UN or PRCMSlLVANIA APPLJ.~ 1"his Agreelllent shall be construed in accordance with the laws of th. Co-.onw.alth of ~nnsYlvania. i1 .... to, - t.: ; . .- UJC, (-) " ", ft. '.. y: ,.... r f t.l ... ! .. - .' "'" . ~ ,... "i C'" u JAMIE M. NIKOLOFF Plaintiff v. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 96-5219 JOHN A. NIKOLOFF Defendant CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the followinq information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section (xl 3301(cl l I 3301ldl of the Divorce Code. 2. Date and manner of service of the Complaint: an 9/30/96. by certified mail. see attached Acceptance of Service. 3. (Co.plete Paraqraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: by Plaintiff on 8/5/97: and by Defendant on 8/5/97. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce Code: NIA (2) date of service of the Plaintiff's Affidavit upon the Defendant: NIA 4. Related clai.. pending: None pursuant to Marital settle..nt Aqreeaent, filed with Decree in Divorce hereto. 5. Date and .anner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which i. attach4ld if the decree ia to be enter4ld under section 3301(d)(i) of the Divorce Code: MIA . 6. Date and sanner of service of Notice of file Praecipe To Transmit Record, a copy of lIhlch is the decr.. is to be enterd under section nOI(c) of Code 1 OR, date of execution of Waiver Intention 1151t71 date of filing Waiver 115/97. Intention to attached, if the Divorce of tlotlce of --.~~~- J.... W. Abraham, Esq. At~orney for Oefeft6ent .... - '. it. . .. tv!~' 0, f:~~~ .~ <:5 -. ' . L' f '"' t . . ...~ ~J , ,.. <> J' j-' . " ~ JAMIE M. NIKOLOFF. I IN THE COURT OF COMMON Plaintiff I PLEAS OF CUMBERLAND COUNTY. I PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 96-5;"'CIVIL TERM I JOHN A. NIKOLOFF. I Defendant I IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you. including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable bfeakdown of the marriage, you may request marriage counseling. A list of marriage counselors IS available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House Carlisle. Pennsylvania 17013 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 THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HUP Court AdmI"'ttraIOt. Fourth floor Cumbettand County Court HouH Carttsle. Pennsytv~ 17013 T~ t7l11 2406200 ~ JAMIE M. NIKOLOFF. ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY. ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) I NO. 96- ,21'1 CIVIL TERM JOHN A. NIKOLOFF. ) Defendant ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This nQtice is to advise you that in accordance with Section 33021dl of the Divorce Code. you may request that the court require you and your spouse to attend marriage counseling prior to . divorce being handed down by the court. A list of professional marriage counselors is available at the Dom&stic Relations Office. 13 North Hanover Street. 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 thIS list. AU necesnry arrangements and the cost of counseling IUsions are to be borne by you and your ~. If you desn to pursue counseling. you must maka '(OUf request for cO\lnMling wtthm twenty days of tbl data on whl<:h you re<.wa this nota '...e to do so WtIl conabtute a WelVt' of '(OUf rJOht to ~t eounMtlnt , . i, " !i " Ii Ii ii P ., Ii Ii Ii d Ii I! JAMIE M. NIKOLOFF, II Ii Plaintiff I' il L '! [I vs. li Ii Ii ,. H ;: JOHN A. NIKOLOFF, i:' " Defendant u .- I I I I I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 96. ,;:Hi CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff. JAMIE M. NIKOLOFF. by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is JAMIE M. NIKOLOFF. an adult individual who currently resides at 2010 Market Street. Camp Hill, Cumberland County. Pennsylvania. 2. The Defendant is JOHN A. NIKOLOFF. an adult individual who currently resides at 293 Bradley Circle. New Cumberland. York County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common. wealth of Pennsylvania for at least six months immediately previous to the filing of this Compfaint. 4. The Plaintiff and Defendant were married on 28 September 1985 in Harrisburg. Pennsylvania. 5, There have been no prlOf acbons of dtvon:e Of annulment between the parties. 6. This mamaoe IS irretrievably broten. 7. Ptantiff hft been advtMd of the avllll4ltMty of ~ ~ and the PtIMt,ff m.r; Nrnt the nght to teque$t that the COUtt requn the PIIftift to t*1'cipete In counnfinV. l >. ,..." ... ~; - ~ :: t..~' , , ~.! , .'.: <.,.r( !'''. , :.., . -. ! -.- .,,~ - .' ,... :.:, --'.,J C" (,J &: ('OJ E - t! .. 9... r - trJ:' - ,.."-, ~-?; ,~ - ~j l' ... c:.:': y: ,.... ~',1 C"l.-. I , l.n-,-, ~ .J t: ";0 (L!, ~ '(J. !". t- ~ V C. 0 JAMIE M. NIKOLOPP Plaintiff v. IN THE COURT OP COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 96-5219 CIVIL ACTION - LAW IN DIVORCE JOHN A. NIKOLOPP Defendant WAIVER OF NOTICE OF DmwrIOH TO RBQUBST BNTRY OF A DIVORCE DBCRBB UNDER SBCTION 3301(c) OF THE DIVORCE CODB 1. I consent to the entry of a final decree of divorce without notice. 2. I understand 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. 3 . I understand that I will not be divorced until a di vorce 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 STATEMENTS MADE IN THIS AFPIDAVIT ARB TRUB AND CORRECT. I UNDERSTAND THAT PALSB STATBMBHTS HBRBIN ARB MADa SUJlJICT TO THB PENALTIES OF 18 Pa.C.S.A SBCTION 4904 RELATING TO UNSWORN FALSIFICATION TO AtrrHORITIES. , . 'I .// (i . f / 1 / .~t{ ~"rY-(') ! DAD: ltu-(fLrl ~ 19'2/ , I . f ,... ~~" !e'. '- JOJDr A~'NIKOtoPF ( \.. "0- .:: -- io. - \-:. .~ ~ .. -.', :,...., H"~ - L)~ I::' :':i: c..';) , .- .' - , C:~.,. -, , '" ::.~ E , ,~ '~ " . ;':; Ii r- ,'":,, Cl cr 6 JAMIE M. NIKOLOFF Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 96-5219 : CIVIL ACTION - LAW : IN DIVORCE v. JOHN A. NIKOLOFF Defendant AFPIDAVIT OP ACCBPl'AlfCB OP SERVICB I, JueB W. Abraham, Esquire, Attorney For Defendant, John M. Nikoloff,in the above-captioned action, hereby accept service of the Complaint in Divorce filed September 20, 1996, which was tiaely served upon Defendant by certified _il, on or about Septeaber 30, 1996. DATIl 8/7/97 ,~ JANIS II. ABIWWI, ISQ. " ,.. ~J '- ic:; - .. "1' C. , \.~.. { " C i..... , I !, . .. ';; . . " , ... ~. .-,; C~ C' ,~