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HomeMy WebLinkAbout96-06485 \'1 4: ~ ~ 11\ )0. Ii .' I , ~ ~ " " , ili " ,1 ii' , J'l I, I, ,} Iii I Iii I, " ,'JIii I , I ! I " 'I ,I 'I , , Ii " , " " ,. I' ,,' . \ -.-.....--..-. -......."- . il.- 'l,'j ., JAN I.. ""OWN '41 "" THoMAII tlOUIIT, 'UIU 114 I1AA",..U"O. "/lNNBYLY"I'I'" I? 1011 "'.41,"'0 , '. . q ~ . (" "/ g ') ,C." . h'r~"'--'''''~li__il\fI~~l'T: '-....,...r-AiiliWIMIioI\\IllI~ " . . ./ - .' " BIPAaATIOH AHU paOPllTY B'TTLIMI~ AoallMINT TKIB AOUIMBwr made thill ,:2!.l,Iy:. day of .J\k'-.::C' , 1998, by and between ClAlY J. TUMA, hereinafter referl.'ed to BII "KUBBANJ)", and KIlfllaA C. TUMA, hereinafter l:eferred to Il/J "WIrl", ~ WITHIBUTKI WKIIlIAD, HUBBAllP and WIfI were lawfully married on November 8, 19801 and WKlaIAS, there are two minor children of thie marriage/ and WltIIllAS, certaill dif.ferencee, disputae and diHicultiee have arisen between the partiee ae a reeult of which they have eeparated and now live eeparate and apart from one anothor, the partiee being eetranged due to euch marital difficultlee with no reaeonable expectation of reconciliation, and are deeiroue. therefore, of entering into all agreament which will divide their marital property and will provide for their mutual reeponnibilitiee and rights growing out of tha marriage relationehip/ Bnd WKlaIAS, KUBBAND, after being advieed by his couneel. Edward S. Fin~eletein, Eeq. and WIrl, after being advieed by her couneel, Jan L. Brown, Esq" have come to the following agreement. -I- NO", THIUPORl, in oonlliderfttion of the above reoitals and the following oovenants and promise8 mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heira, 8Uooe8sor8, and a8aigna hereby, oovenant, promi8e and agree lIa folloW81 1. lllPAIlATIOlf I It aha11 be laWful fur eaoh party, at all times hereafter. to live aoparate and apart froln the other at auoh plaoe or placea all he or ahe mfty, from time to time, ohoose or deem fit. :I. .t1ttJlUllJil:ll l!:ach party IIha11 be free from interference, authority and oontaot by the other, all fully as if he or ahe were lIingle and unmarried, except IlII may be neoesliary to oarry out the prl?VilJion8 of thill Agreement. Neither party shall molelit the other or attempt to endeavor to molelit the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful exiatence, separate and apart from the other. 3. KIPB'S DBBTSI WIPB represents and warrants to HUSBAND that uince the separation she has not, and in the future lihe will not, contract or incur any debt or liability for whioh HUSBAND or hia estate might be responsible and lihall indemnify and save -2- IIUSlAJfD harmlolll tram any and all olaimll or dOIlUllldll mado againllt him by reason at debts or obligationll inourred by hor .inoo the date at said soparation, 4. UUJJAHD~->>JJ~JI HUSIAJfD roprollonts and warrantll to WI'. that sinoo tho soparation he has not, and in the tuture ho will not, contraot or inour any dobt or liability tor whioh WI'. or hor estate might be rClllponuible and shall indemnity and uve WI,. harmlesll from any and all. claimll or demandll made against her by reason at debtll or obligations incurred by him since the date ot 8aid separation. 5. PIVIIIIOlf 0' IIQ1IJJJiQLD PROPIRTY I '1'h", part ies hereto mutually agree that thoy have etfocted a satisfactory division ot the turniture, houllehold furnillhingll, appliances, and other household personal property between them, and they mutually ague that WU. shall from and after the date herllof be the sole and separate owner of all such tangible perllonal property prellently located in the rellidence at 57 Longview Driva, Meohanicllburg, Pennllylvania, The partiell agree that HUSIAND shall, from and after the date hereof, be the sole and separate owner of all of the items of personal property in hill POllllQlIlIion, and that WI'. hereby releases and relinquishes any right, title or interest she .J. may have in the pallt or now hall in the iteme now poelleeeed by HUSBAlfD . 6, AIl~lUIJ,J:L.l11 ~'he partiee herllby agree that the 1995 Ford Windetar currently in joint namell shall become the sole property of WIr. and IIUBBAND agreell to execute any documents necessary too effectuate sole ownerNhip in WIrl as 1I00n a~ WIFI refinancee the automobile and thereby Bssumes sole responsibility to payoff the balance due on said vehicle which obligation ahe hereby assumlls. 'rhe parties furLher agrell that HUBBANll IIl1all be the eole owner of the 1991 Chevrolet Corllicll upon which there ill no obligation owing, WIrl agrelllil to execute any and all documente necessary to effectuate tranllfer of ownorllhip in thill vehicle to KUBBAlfD . 7. HlALTK INSURANCII HUBBAND and wn. agree that upon entry of a final decree in divorce, HUSBAND may remove WIn from any health inllurance cClveraglll that he malntaitlll, HUSBAND, however, ehall continue to carry children on lIuch health inllurance coverage as is provided to him, without cost, by his employer. B. RIAL ISTATII HUSBAND her.eby agrees that ho shall make, execute and deliver any and all documents, including a epecial warranty deed, conveying, traneferring and granting to WI'. aU .4. his right, titllt 4nd interest in and to the rod estate alld dwellinq situate at 67 Longview DrivQ, Mechanicsburg, Pennllylvania, 'I'he sllid COllVeyanoe shall be tree "nd clear of all lienll except that of the existing mortgage and any other lionll or encumbrances that currently exist against the property and furthermore under and subjltct to any covenants and restr.ictionll of reoord, '1'hl\l said documflnts lIhall bo executed by HUSBAND and delivered to HI'. or her counsel on the dBto of the execution ot thill AgrOllment. From and after the execution hereOf, HI'. shall be responsible for all mortgage payments and other expenlles, inclUding taxes Ilnd maintenance on the real estate and lWBIAlfD shall have no obligation to indemnify HI'. for any of said payments, However, notwithstBnding the foregOing, lWBIAND agrees to pay one-halt (1/2) the actUal cost of a new roof and refinishing of the driveway the next time the Work is performed. Prior to having the work performed, HI'. shall contact lWBIAND to review the cost elltimates that ahe has obtained for DUch work and, unless lWBIAND call find someone else to do the work at a lower price who i~ acceptable to HI'., lWBIAND agrees to pay one. half (1/2) the actual cost, -5. 9. WlJlAJI~...jllfIRlMIH'LJl1flnl'll lluruuant to Pennsylvania law, the IfIrI hu an intereBt in the IIUSlAlfD' B 1'lItirement benefitB whioh he hu accumulated at both the PittBburgh POBt- Gazette and the commonwealth of VennBylvania and his Individual Retirement Account and WI'I herehy acknowledgeB that Bhe iB aware of thiB right, however, WI'I acknowledgeB her deBire to waive Bny lnteredt Bhe may have in any of these retirement benefits or other retirement benefits of the IIUBIIA1l1l either now or at any time in the future. The lump Bum consideration being paid by IfIrI to IfUBBA1l1l takeB into conlliderat ion thiB wai vur by the IfIrI and the waiver by hel: IfUSBA1l1l of hiB interllBt in her retirement benefita, and the value of other aBBets as well, 10. ~Irl'8 RITIRIMINT BlUll1IIl Purduant to Pennsylvania Divoroe Law, the IfUSBAlfD has an interest in the WIrl's retirement benefits at George M. Leader Family Corp. and her Individual Retirement Account and hereby acknowledges that he is aware of this right, however, HUSBAlfD deBirell to waive any interest that he may have in any retirement benefitB of the IfIrI either now or any time in the future. Furthermore, HUSBA1l1l acknowledges that the lump sum consideration being paid by IfIrl to IfUSBA1l1l takes into consideration thiB waiver in addition to the value of. the .6. Hen4 004. 1:1. IAWln-Jll_JfUIJiLillIJJlAlmI Notwitlllltanding the provisions of Paragraphs Band 11, the Peed to the jointly owned residenoe at 57 Longview P~ive, Meohanicsburg, Ponnsylvania will not have to ba dltlivlIred by HUllllAND to WIn until. wnl makes the payment to HUllllAND that iB provided for in Paragraph 11 hereof, Furthermore, If In shall make said payment to HUSBAlfD at which time HUSBAND will convey hill interellt in the real estate to wnl no later than July 31, 199B, 13, ~)gIg!L~UI 'l.'he pat'ties currently own common stook in May Department Storell, Paylells Shoes and Venture Stores as joint tenantll, The partiell IIhall continue to hold thelle shares of IItock all joint t.enants and agree to invest all proceeda therefrom, inclUding dividends, in an educational fund for ~ollege for their children, Caryl and Drew. Since the shares of stock have the taxpayer identification number of Gary J. Tuma, Mr. Tuma will be entitled to be reimbursed from the dividend income the amount of income taxes that he is required to pay on the dividend income or any capital gains that may be distributed. The net funds, however, shall be deposited in the educational fund for the children. sinoe Mr. Tuma may not know what the .8. inoome tax implioation will be on the dividendQ until aft~t they are reoeived, the total dividend cheok will be plaoed into the educational fund and the partioQ hereby agree that Mr. Tuma oan be reimbursed from the eduQational fund for the inoome tax eff.eot on him as a result of the deolaration of theee funde for inoome tax purposOll, federal, Btat~ and local. 14, 1J2l1~mm_llI1il!l The educational fund created above shall be used in a fair and equitable manner towarde the eduoational expenses of Caryl and Prew, APproximately one-eighth (l/S) of tho fund shall be used towards the first-year 00116ge expenses for Caryl, For Caryl's second year, one-seventh (1/7) of the balance should be made availablfl towarde her expensee, Once both children are in college, equal portions of the remainder, in the pattern set forth above, shall be made available to cover some of the children's college expenses from year to year. It is only anticipated that the fund will be used towards four (40) years of poet high school education for each child unless additional funde remain to contribute to further educational nep-ds. Once both children have graduated college and there is no need for further Use of the educational fund, the net prooeeds remaining therein shall be divided equally between Gary J. Tuma and Kendra C. Tuma, The fund and any of the common .9- stooks au set forth in Paragraph 1~ above or subuequent oorporationu effected by mergers or acquisitions, shall be equally divided as well. 15. ~.u..l'ALJlJJIn.1g1LIOJL~JUJ;,.QJ\11f1 lilffective for calendar year 1990 and thereafter, WI'. shall be entitled to claim both children as dependents on her income tax return unlelR an order is issued by a court of competent jurisdiction indicating otherwise. 16, ~->>1~~UAlI Both parties understand that pursuant to the Pennsylvania Divorce Code they have the right to require the other spouse to file in writing a detailed explanation of all of the other spouse's assets and liabilities and income and expenses and each waives their right to require the other spouse to file t.hese documents and is willing to execute this Agreement without full disclosure of those assets, liabilities, income and expenses. 17. ~UAL WAIVI~I The parties hereto expressly waive any olaim or right which either party may now have or at any time hereafter have for paot, present or future Rupport or maintenance, alimony, alimony ~ndente lite, counoel fees, costs or expenses, whether arising as a reuult of the marital -10. relatiollship or othnwhe, specifically in connection with the present or any future divorce proceedil1gs, ,ither in the Coltlmonwealtll of l'ennsylvania or in any other lftate or jurisdiction, except, and only except, any rights, dutieB or obligations ariBing under the terms and conditionlf of thiB Agreement 01: out of the bnach of any pOl:t iOI1 hereof. 'rhe parties further expreuuly waive any rights they may have in the future to seek modi~ication of the provisionlf of this Agreement relating to alimony, alimony ~ml.!1nJ;e lite, counsel feelf, ooots and expenoes or spousal support or maintenance 011 the basis of changed circumstanoes, purouant 1:0 the Oivorce Code or the law of any other state or jurisdiction. lB. HAIVIR or CLAIHR AGAINST .S~II Except as herein otherwise provided, each party may diapoue of his or her property in any way, and each party hereby waives and relinquishes any and al.l righto he or she may now have or hereafter acquire, under the preoent or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other'a estate, and -II- each will, at the requeat of the other, execute, acknowledge and deliver any and all inatrumenta which may be necessary or adviaable to carry into effect thia mutual waiver and relinquiahment of all auch intereat, righte and claima, 19, I).lUlaJ_,Q'._lLLlriAllJ:'1')UfA1Vn, IIUIlIlAml and IfIrI eaoh knowingly and underatandingly hereby waive any and all posaible olaima that thh Agreement ia, for any rllaaon, illegal or for any reaaon whatsoever violative of public policy, or unenforo~able in whole or in part, HUllBAml alld IfIrI each do hereby wal:rant, covenant and agree that, to the extent legally possible, he and she are And ahall forever be eatopped from asaerting any illegality or unenforceability aa to all or part of thia Agreement, 20, RlLIASI or CLAJHSI SUbject to the proviaiona of thia Agref.lment, each party haa releaaed and dhcharged and by thia Agreement doea for himaelf or heraelf, and hia or her heira, legal repreaentativea, executora, adminiatratora, and aaaigna, release and diacharge the other of and from all caUaes of action, claims, right, or demanda whatsoever, in law or equity, of whatsoever kind or nature, which either of the parties ever had or now haa againat the other, except any or all caUae or caUaeB -12- of aotion for divoro~, whioh either party may have aguinst the other, and exoept that this release shall in no way disoharge or exonerate either party hereto from the obligations and promises made and imposed by reason of this Agreement. 21, 1I11JaJ.QI,/J1fLDly..oGII 'rhe part ies hereby acknowledge t.hat; the IfIrI has Hl~d a Complaint in Oivorc" claiming that the marriage ie irretrievably broken under the No-Fault provision o~ Becl:ion 3301 (cl of the Oivorce Code, IIUSBAlfD hereby expreuu his agreem"ut that the marriage h irretrievably broken and expreeses hie intent to execute any and all affidavits or other documents necQeaary for the partiee to obtain an abeolute divorce pureuant to Section 3301(C) of the Oivorce Code, The part;iee hereby waive all rights to request court ordered couneeling under the Divorce Code, The partiee further covenant and agree that the terme and conditione of thia Agreement repreeent a fair, final and equitable reeolution of any and all ieeuee, with the exception of child cuetody, that might properly be r.aiDed in any euch divorce proceeding, specifically agreeing that the provieionll of thiu Agreement rolating to division of marital property constitute an equitable distribution of eaid property as contemplated by the Penneylvania Divorce Code. .13. If consistent with the rules of practice ot the Court of Common Ple4B of Cumberland County, the providons of thh Agreement, or the substance I:hereof, IIhall be incorporated in any decree of absolute divorce, but, notwithstanding such incorporation, I:his Agr.eemenl: shall nol: be merged in lIuch decree, but IIhall in all respects survive the lIame and be foraver binding and conclullive upon the partiee. 22, IlH~.IV. DAT.LJlI~JlJIIlI1nI 'rhe effective date of this Agreement shall be the date upon which it is executed, lEach party agrees that in the event thaI: this Agreement expires or terminates, neither party may use any portion of thie Agreement, nor any prior negotiations, in any manner, including as evidence, in any subllequent proceeding in law or in equity between the partiesl this Agreement reprellenting an amicable aettlement of the issues of distribution of marital property, alimony, alimony pendente lite, counsel fees and expenses, and/or apousal support or maintenance. Thia aubparagraph regarding the non-availability of this Agreement for use as evidence or otherwiae in any subllequent proceeding is effective all of the date of execution of this Agreement, and is effective between the parties, notwithstanding the expiration or termination of this Agreement, in whole or in part, and survives any such expiration or -14- terminllt ion, ~J, AJlJUUDlf;\1. IlIIflJJUIIUUI lEaoh at the partiell lIhall tram time to time, at the request ot the other, exeoute, aoknowledge and deliver to th~ other party any and all turther inlltrumentu that may be reallol1Bbly required to give tull torce and etfeot to the provillionll of thiu Agreement, H . Y..Q.Lll1fl'ABI...I.1IC~Jf I IIUSBANP and IfIrI each repruent and warrant to the other that ho 01.' ahe hall made a tull and complete diaclollure to the othel: of all /llllletll ot any nature whatlloever in which lIuch party had an interellt ao ot the date of sepal.'lltion, the Bourceo and amount at the income of. lIuch party of every type whatlloever and at all other tactll relilting to the subjeot matter of thio Agreement. Rach party acknowledges that the Agreement ill fair and equitable, that it ill being entl!lred into voluntarily, and that it io not the reoult of any durellll or undue influence, 25. INTIRI lORIIMINTI Thio Agr"ement containo the entire underotanding of the partiea and there are no reprellentationll, warrantieo, covenant II or undertakinga other than those expreosly Bet forth herein, 26, BRIACHI It io expreooly otipulated that if either party -IS- faill in the due performanoe of Any lI1atlll:iAl obliglltion under this I\greement, the other party Ihllll hilve the right, 1St hils or her election, to lue for damagel for buach thereof, to IUe for Ipecific performance, to rellcind thil I\greemenl:, or to leek Iny other legal remedies au may be available, and the defaulting party ahall pay the reauonable legal fees for any servicel rendered by the nondefaulting party'u attorney in any Aotion or prooeeding to obtain such remedy elected hereunder. 27, n.mUlfJLIW~1 'rhia Agre"ment shllll be binding on, and inure to the benefit of the heirs, executors, administrators, lIuccessors and BBsigns of the resp"ctive parties hereto. 2B. ~ODlrIC~iIO~AIY.J11 A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and eXftcuted with the Bame formality af,\ this Agreement. The failure of either. party to insist upon lItriot performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or f.\imilar nature. 29. DISCRIPTIVB HIADIlfGSI The descriptive headingll ulIed herein are for convenience only. They ahall have no effect whatsoever in determining the rights or obligationll of the .\6. - . \ " .', _l-' '.. .,'~, "f4.';;.., .;."--....- . JAN L. l!lrtOWN UI "" TI~OMAI counT, '~In IIA 'HAARlIIDUIHI,I'IfNN8VLVAN'A 1710IJ llM~'.lh. ., . , .iliHjh";'~"i'i(l'~"""""I1I.1f'~M~Il~il"1l\1Io~!i.<~1~:I",i;\'W"..".,I,;,~i (1<,;,:,,;,.';,'I\III!t;)J!i\ltlit'"J.\\l1ld.tll_IM~W,liIDIj -' " ,., )0.." J' ", J~ l"I' 'I, ' I; " j , , I' " ' i ~ " , , . , ,fIt JI, I,', , , (,' .'j \.t- i,'. i I 0 () ,. ~ , . l.iI l,j .~ , ,,' , , ' ,,' ' , . . , ~ 1..,1..1 & 'Ii t'" 'b,.- ... r.:i -e,. s ~ E I PI ~ ..q ~ ~ ~ ,g " : I .' O/lHY J. 'I'UM/I I)efundllnt HI 'l'lll!; COlll~'l' Of' coMMOtl 1>LJl;/lB CUMBJl;HL/ltlD COUtlTY, PEtltlBYLV/ltll/l CIVIL I\C'I~IOtl - 1,/lW tlo. -9/,.,/,.111'1;' (I"" ( Kfl.I'l ltl I) 1 VOHCll: 1{Jl;tlPI~/I c. 'l'UM/I Plllinttff v. COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) ,.or. .'IIII_ D I VORCE.-J;ODIli /ltlP tlOW comes till/ ObOVll t'llllntUf, I<endra C, 'l'Ulnll, by Jlln L. Brown, Esq., al1d 11001\15 to obtotl1 Ii docrell in divorce from the IIbove"named Defendllnt, UpOIl thu grounds horoinBftor sot forthl I. Tho Plaintiff, Kondra C. TumB, is an adult indivtdual who res ide~1 at &'1 Longvtew nri ve, Mechanicsburg, cumberland county, Pennsylvania. 2. The Dofendant, Gary J. Tuma, is an adult individual who res idee at &'1 Longview Drive, Mechanicsburg, cumberland county, Pennsylvania. 3. '1'he plaintiff has been a pona fide resident of the Commonwealth of Pennsylvania for at least eix (6) months immediately prior to the filing of this complaint. 4, 'rhe plaintiff and Defendant were married on tlovember 8, 1980. 5. plaintiff avers that there are children to the parties under the age of 18, to witt caryl M. Tuma, born September 30, 1983, and Drew C. Tuma, born August 6, 1985. 6. 'l'he Plllintiff IInd D!lfllndllnt Ilrf.l lJoth citi~f.lnl'! o( the unitod Statol'! o( Amurica. 7, Thoro have l1uol1 no prior /Ictions in divoroe lJatwoon the parties. u. 'I'he Plllil1tiff Ill1d Dofondllnt 8ro not mombors of tho Armud SlJrvicaa of tha Unitlld Stlltas 01: IIny of I,ta 811ies, 9. PlaintiU huu houl1 Rdvhwd of the Rvallal:Jility of counael1ng /lnd thllt Bho may hav'd tho right to ruqueBt that tho Court raquira tho partioa to particlpata In counBf.lllng. 10, Tho caUBaR oJ: acl:lol1 and ooctions of Divorce Codo undar Which Plail1tiff ia proclludil1g lIrol A. SoctJ.on 3301(c). Tho marriage of the pllrties is irretnovllbly brol<oll. I\fter ninety (90) days have elapsed from tho date of the service of thi$ Complaint, Plaintiff intends to fila an Affidavit consenting 1:0 a divorce. Plail1tiff helieves that Defendant may also file auch IIn Affidavit. B. Section 3301(d), 'rhe marriage of the parties ia irretriovalJly broken, 'I'he Plaintif( and Defendant separated on NovomlJer 26, 1996. WHEREFORE, the Plaintif( prays your Honorable Court to enter a Decroe in Divorce from the lJondn of mlltrimony. \1''") By I" -- V\ :..~t1Jl,__ (Ja L. Brown, Esq. Att rney No. 67993 845 Sir Thoman Court Suite 9 Harrinburg, PA 17109 (717) 541-5550 Attorney for Plaintiff JAN L, l!lROWN ..... "" lltotMu I.;QIIIIT, IlIlIl. IIA 111l1l1l'~UIJIIOj, ri'f'/NIIVLVIlf'/IA 1710Y '1I7.1041,IUII,U KI~Nl>lt^ C. TUM^. 1'llIhull1' IN TJ IE COllIn OF COMMON 1'1.1!Mi CUMllElU.AND COUNTY, I'ENNSYL VANIA CIVIL ACTION. LA W v. (lAItY J, TllMA, NO. 2.6:(l1~ IN LJIVOIKE P~len{11l1ll m;JJMY.rLO,Jo:,-'!)l'i~.t;JIT I. A COlllplnllllln nlvur~c IIndcr SC~lllIn 3]OI(~) oflhe I>lvor~e Codc WIIS IlIcd UII Novumbcr 26. 1996, 2. 'I11C IIlnlTIIIgc of Plnlntlf1' nnd Dcli:ndllllll~ Irrclrlcvllbly bl'llkcn IInd nlnely (<JO) dllYi hllw clllllscd Ihlll1lhc dllle 'lfl1l1ng uflhc CUlIlplnlnt. J, I ~uniCnll!ll;lC cnlry ufll I1nlll dccrcl1 ufdlvurcc lIf1cr icrvlce ofnoll~c oflntcnliulI lu rcqucKl cnlry uf thc dc~rcl, 4. I ulldCrillll1d lhnlllllny 10iC l'ight~ cunccl11ln!! nlllllony, dlvlslolI ofpropCl1y,llIwycri fcci or CXpClliCS If I do l1ut c1nhl1lhclll bcforc n dlvorcc Is grnl1lcd, I verily Ihnllhe ~Inlelllcnt~ IIlnde 111 thl~ ^l11dllvllnre Iruc Dnd correct. I undcrslnnd IlulllilliC stnlelllenl~ hercll1nre IIlndc slIbJcctto Ihe pellllltlc~ of \8 Pn,c'S.A. Section 4<J04 relnlln!! 10 un~wul1I fnlilf1cnllonto nUlhorllle~, Dnle:~ By, ~,-(i~~ KE ORA c. rUM , . \ ..--.....-.--- .___j~~oL'4~ ...~, _........-.~ ~- JAN 1.., III'lOWN UI II" THOI>l~1 C'Ii'.'r, IIJIU II~ '1r\I'II'1I11SUI'IQ, ,.IINN. VAtM 171011 117,ul:'iuo , , - , I, ......tt~'W ~ ~i>fl '1;1.:J"f,tI'I~.~Ii"",\,6ftt' po' t,j',IJ I, I" " ';:11- ;...\ ~(IJ_. 'Ill j (ll' j !l~,I""-i.\11 !;, ~ \\)1 L t.j~ liil!.fi "', 'U'l"'rrJlh 1114'''' '''..-,,'''11I'.... l""".'~~'r'~lt" f...J...,\ "'ilNt~ ,I ...' . --.;...~ JAN L, SROWN UI "" TIt"M~' ~OImT, "j,U 110\ 1~"I1J1ll1I1UI1Q, "'!NNBYI-VAN'" 1710IJ 111,14.,..." -. -,. ...... KUNORA C, TUMA, l'lulllllfl' : IN TIlE COURT OF COMMON I'LEAS : CUMIIEIlI.ANI> COUNTY, IIENNSYI.VANIA : C1VII.ACTlON.I.AW v, GAilY J, TUMA, : NO, !lCHl!!J1..5. : IN IJIVORCn DelclldUlI1 AFIII J)AY-tLOfi'Ol'/1i.ENr I. A COlllplulllll1l Divorce ullder SecllolI J)OI(c) of the Divorce Code WIU llIed Oil NovcllIber 26, 19l)O. 2, '111e Illarrlllge ofl'llIlutltrlllld Detimdlllltls hrelrlevllbl)' brokelllllld IIll1et)' (90) da)'s huvc clapsed fTollllhe dllte of 11 illig oflhe CO/llpllllllt, J. I COllsenl to Ihe elltr)' ofll 1111111 decree of divorce IIller service ofllollce ofllltenlloll 10 request ellll')' of Ihe decree. 4, lunderslJmd Ihlllllllll)' lose r1H111s cOllcel1llng IIlhllon)', dlvlsloll ofpropel1)', luw)'e~s fees or expellses If I do not c1ahnthelll before II divorce Is grllllled, I, verity thlllthe Sllllel1lellts mllde Inlhls AfJ1duvll ure true IInd con'Ccl. I understund Ihut fillse slatcmenls herelllllre made subJect to the penahles of 18I'II,C,S,A, Section 4904 relallng 10 unSWOnl falslflcallolllo outhorllles, Datc7~ t?~ I ~ f By: JAN L.. l!IROWN I'. "" T1tlJM,-. CUlmT. .'1111 IIA , " tiArmIS13UIIO, "I!NNIIVLVANIA 1110U 717,UI,'UO . , KENl>ItA C;, TLJMA, IN TIlE COUll'!' OF COMMON l'l.I!Mi OF CLJMIIEI~I.AND ('OUNTY, PHNNliYI,VANIA Plullllll1' Nu, I/().MH~ v, (IAIW J, TUMA, CIVil. ACTION. I.A W IN IJIVOltCE lJelimdulIl WAIVER OF NOTICE OF INTENTION TO I~EQLJEST ENTRY OF A l}lVORCE DJ.;rHEE UNDEIUJ..1!lJJ.i;J..uLHU! DIVORCE mOil I. I COIISCIII tu Ihe CIIII')' uf II FIIIIII Decrce uf Divorce WlthullIlIUllcc, 2. IlIlIdcrsllllld 111I'111I101)' lusc rl~hls cUllccmlll1! IIlhnulI)', dlvlsloll ufprupcI1)', IlIwyel's fces or cxpcnses If I do lIul dllllll thclII beliJre II dlvorcc Is I!rnllled, 3. I ulldersllllld lhllll will 1101 be dlvurced umllll dlvurce decree is elllered by lhe COUlt IInd Ihlllll copy uflhc dcercc will bc SCllt 10 lIIe IlIIlIIedllllely Illlcr It Is flied wllh the Prulhullulllry, I vcrif)' t111lllhc ullllclllcnlsllludc IlIlhls Allidllvlt 1111: truc IIl1d ClJITccl. IUJI{lerslllnd tllllllillbc slnlclllclIls hcrcln IIrc Illlldc subjcct IU Ihc pClllllllcs of I H I'll. c.s. ~4lJ04, rclllllnl! Iu UIISWOnl flllsll1cllllon to lIulhorltlcs, DUIC:~1- 24/.1i_ )7 _ (~%'--(---"-'Z:~'- ~" i!.'>~ ~..... ", ..,. . . . . . .. ..