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HomeMy WebLinkAbout00-00580 , . . . . . . . . . . . . . . . . . . . . . . ~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . __I' , . , , I- - - ~ , . <ti;li :tiff. ;Ii :t. .. . .. . . .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF DECREE IN DIVORCE NOW'~ 2/ JEFFREY R. WHITE, Plaintiff VERSUS SUSAN WHITE, Defendant AND DECREED THAT AND PENNA, NO. 2000-580 CIVIL TERM it. 4; 1-3 P.i1 ~ . . . .. . . 2001 , IT IS ORDERED AND JEFFREY R. WHITE , PLAINTIFF, SUSAN WHITE , DEFENDANT, ARE 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; NONE . '" Of. Of.:f.:f. ff. '" '" '" '" '" '" . . ." """',1 ;F.:F.<+'1f. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~ c , ...' ~c?l.dl' &vr~~~~~ ~W.Cf 71~ /YId ~ 4 ~ . " , , c +_~_' _. ~~_ ___~I'mlf' ". . ,. ""l"""'"".'! ~ ~. _Po "' ,},,-- ORDLk ~L. _, ,-~ -,~! " '''''_I~.iIlI~1iO'~irll''''' "<-;r1-1-"->-,,-,,_lIlillIijlllI~ """= .-""'-.."""'_~ilIliI!IIi!!IIlOB~IiliI.:l_"'.'IL'"_.'<1""''''''''''IIiliif;jJM.......I'U!lll'-",llir.Mr,i~I~f'~ EJilII,llllf,r -" ~~J-"=~~I<'C":ii COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA JEFFREY K WHITE, FAMILY DIVISION PLAINTIFF v. NO. 00-/)7)6 C~v~ \ SUSAN WHITE, DEFENDANT IN DIVORCE ORDER 1\ AND NOW, thi2J day Of~ ,2001, the attached Stipulation and Agreement dated ~ " , lot. , of the paliies in this case is incorporated, but not merged, into this Order of Comi. ~.J . ATTEST: .,,:i{,,':- _,;~:-,,_,<~'L'--.;- III , ;'- -~",-7i".;~l~~~~",i;~~,"";;';;' <,".; ~,' ~ J:;-".;L"''' ,"~~%,">",,,,,_",_. ,',-~-""-_-"' -,'-- - ~-- ._.~,--- I}:: " T'c,TAlif 1"'1 JI''I ?,,, ~ (!h! ~I ... l.., \), ~ J:....... ".! /0" I" ;I'L; . '"' C' '1'",1:':; /, ,\. ""UI "r'y V\i'....-''--..Ili,.r~\:u C.lV 'J PENNSYLVANIA r;-;>o1,CJ/ w- ~ ~ 7;;' 4~ b'd~ C/ >1~"u~;t ci?f ~~ r;~~~l!;I!f_i"l'F~'if"VI' .,_ r" __,,,~_-,~"11'1~"""~I'lJ'"I'i'F<~W'1!''''<''~~~:I_!f"'-'l'!!'' , 'e,'>;~' ~q""'''~'fr'fr'''_'*'I''''''''_"''''!';''''''''''''''"'_'(>''''_'')'''''''' ~''ii''-'''!,1'-'~''~::'''~1;''''''''''f'f'~,!,,~~"''''-''''lF''i'fr!''Jfj!li.t!"'~i[~WMR~' -""""-- -~,-~_:~~~. ,~ .~,-'"~ ~~ J~ ....~'.--~~.~~. ~~""li~." ~." f'''' ""'....~"" ur ' ' ~ _"." J l("''''''iI,';Lhl!ldl'O>i_'''' "&;."'IU,,h" COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JEFFREY R. WHITE, FAMILYDNISION PLAINTIFF v. NO. SUSAN WHITE DEFENDANT IN DIVORCE STIPULATUION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this IIH day of M"l ' 1001, the pmiies, JEFFREY R. WHITE, Plaintiff, and SUSAN WHITE, Defendm1t, do hereby Agree and Stipulate as follows: I. The Plaintiff, JEFFREY R. WHITE, (hereinafter refereed to as "Member") is a member of the Commonwealth of Perm sylvania , State Employes' Retirement System (hereinafter refereed to as "SERS '} 2 ">"""- ~1""_"",,,,,~..,..!olI>~U;:;~U<",,Uw'ilU;;,,,Iw,,JIi"'...Jj"""~ iliIlIIiIil>I!~>'"-'""""'~U<rt"""""~'""""'" ~~" -'-".~""'~~i1<JilIlli~i!JilI.:.K.j;!WM'biil1P.l;'.ia'~_~~~"""",",-"'",'~"">~'IH.Ili~ 2. SERS, as a creature of statute, is controlled by the State Employes' Retirement Code, 71 Pa. C.S. $$ 5101-5956 ("Retirement Code"). 3. Member's date of birth is Feqruary 20,1951, and his Social Security number is 202- 42-6018. 4. The Defendant, Susan White,' (hereinafter referred to as "Alternate Payee") is the fonner spouse of Member. Alternate Payee's date of birth is February 12, 1952 and her Social Security number is: 188-42-9227. 5. Member's last know mailing address is: 4054 Caissons Court Enola, P A 17025 6. Alternate Payee's current mailing address is: 1017 Wooded Pond Drive Harrisburg, P A 17111 It is the responsibility of the Alternate Payee to keep a current mailing address on file with SERS at all times. 7. Alternate Payee's share of the member's retirement benefits is $18,000.00, (Eighteen thousand dollars) which shall be paid in a lump sum amount, which said amount will be paid when Member receives his lump sum withdraw in accordance with Paragraph 10 hereof. 3 ,_~;<<,,~~_'~_o _.....,_~~ . " -"~'~Dll>"~ -~-~ .^, .~" U~ 1i!II!Iii\iIIl--". ..~,~ 1 .~~.,~,- - ~ ~.... . - _I__.__....~,~.~,~._"" . --J__,~_"',. .i,,' 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases, but excluding the disability portion of any disability annuities paid to Member by SERS as a result of a disability which occurs before the Member's marriage to Alternate Payee or after the date of the Member and Alternate Payee's fmal separation. Member's retirement benefit does not include any deferred compensation benefits paid to member by SERS. The equitable distribution portion of the marital property component of Member's retirement benefit, as set forth in Paragraph Seven (7), shall be payable to Alternate Payee and shall commence as soon as administratively feasible on or about the date the member actually enters pay status and SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of Alternate Payee's equitable distribution portion in Member's retirement benefit for any death benefits payable to SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board or his authorized representative, of any Domestic Relations Order incorporating the Stipulation and Agreement. The balance of any death benefit remaining after allocation of Alternate Payee's equitable distribution portion ("Balance") shall be paid to the beneficiaries named by the member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to the Member's death. 4 ',~"_~~I;II,~i,""""~"II!J\lll"ih_dIlL""""--"",,,,=~,,,,liiktMa= '~~~Ir" ~ ~ ,.- . ~ "i~'___ibIIIw'M"'~'~ ="~,- . ....M~' .~~~ - ""__J.....-~'"''';_J....''''''"''''',u: ,__ok. ",:",--~:, (a) If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement; and (b) names the Alternate Payee as a Beneficiary; then: (1) the terms of the Domestic Relation Order shall alone govern Alternate Payee's share of any death benefit; and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased the Member. No portion of the Balance shall be payable to Alternate Payee's estate. (b) In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. Alternate Payee shall deliver the authorization to SERS which will allow the Alternate Payee to check that she has been and continues to be properly nominated under this paragraph. 5 , '--, .-::,:; "- ,~_""'''~,UIli..'';I.I. "-~~ -"-,~,........~ -_or ~" . "........""~..... ~ "'.....<d..........."" "'\iI-V~'.~' ~~ .;."~-"""-~' ~ "~. - .~. -.......,,,-- ..-~~ ~ " _"~,__" I____.-,,"~.......I.."'.~h ,,~.I.__<i.ot<L-, . 10. The term and amounts of Member's retirement benefits payable to the Alternate Payee after SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement is dependent upon which option is selected by Member upon retirement. Member and Alternate Payee expressly agree that, at the time of retirement, Member shall take an Option 4 lump sum withdrawal of his accumulated deductions in an amount not less than Alternate Payee's equitable distribution share of this retirement benefit, as set forth in paragraph seven (7). Alternate Payee shall be paid her entire equitable distribution portion of this benefit from Member's lump sum withdrawal, and no additional amounts shall be payable to Alternate Payee by SERS. II. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Alternate Payee for the amounts paid to each. 12. In the event of the death of Alternate Payee prior to receipt of all her payments payable to her from SERS under this Order, any death benefit or retirement benefit payable to Alternate Payee by SERS shall revert to Member. 13. In no event shall the Alternate Payee have greater benefits or rights other than those which are available to Member. Alternate Payee is not entitled to any benefit not otherwise provided by SERS. The Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Order. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Order are preserved for Member. 6 1"""~..""",~.,;",--~"...""..."",~-..;..,""",,,,,,,,1;-,",~~Idd." '. -~'~"W'''' "1"''''';~'''''''-'''''''''''''~-''''hil~"'"''"'~'''''~Ilt!''-'"I.I;;!l:dill~1_,~'_iib!l.ll&mi~'''_ ' -- """'",- aJJ:lh~i"_="l"''=_o~'''''';' 14. It is specifically intended and agreed by the parties hereto that this Order: (a) Does not require SERS to provide any type or form of benefit, or any option not other provided under the Retirement Code; and (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Order and this Stipulation and Agreement and any attendant documents shall be Member based upon cost of living or increases based on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relation Order. 16. The Court of Common Pleas of Cumberland County Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining is as a Domestic Relations Order; provided, however, that no such amendment shall require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. 17. Upon entry as a Domestic Relation Order, a certified copy of the Domestic Relations Order served upon SERS immediately. The Domestic Relation Order shall take effect immediately upon SERS approval and SERS approval of any attendant documents and then shall remain in effect until further Order of the Court. 7 --",:~,,:~ - ',C_"-;-_,,?: ~J<,.' ' ~~.. "'fI;1 ~ - -.~ ~~....... -~ ~,",,,.;~"...~_.,,,,,,.;-,~,j,,",~-~,,,-,,,,,,,, ,,~...""""~_.... , . ~'I;i",,,,,,,,",,,,,,-.t!U.''''",,-I,,,,,,,,",,-.'''''''~''''-id,,,,,,,,,,,",,,,,,",,,,,,,i,,,,~,,",,,,,,,,~" WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. Dated: ~ - \ ~ - C l Dated: 5- / j-{) / , &M./q}::J/:tv Defendant! Alternate Payee Dated: 15 M'&.l 2.co\ ~ Dated: 5---11'" 01 ;f~ &E~ Attorney for Alternate Payee 8 "~ ~< .,J-.;.,_Ml.,""iJ"""'/., il!1iW1iiliiim~lilli;j_ifi'''*ii,J!dikil'flj~'ii",ihiilii,b~b<dl!",I.;"''o',.U,dA,''. ",;o,,,;,-,,-,,,,-~_,",,,,,.,<;,;:,~'bf~~ilil1~~l\IiiJj>ililo_H~I'J.>I,jje:-RlW-u.;iI"_~"",,",Ji'~"""'" ,I~,. "~"" ."'"""-ti~~,HliIIlI ~ "~, '1IIi'"...~~~.".t . 0 C, 0 C .1 ;;::: '- ~.--- -U c:J r- f~IFl mp-i :e -7.- L.. .._~ -Orn Z"c- en ~<: --- -,,0 -<.<- ?~) l. !<u ;::;:;,U :>>- ~,i ~c :r;: {~5;~ .'7", .' >~.:) ;::''';lTI '- ~ ~ :::> ~ .r:- -< "'"""_._..,.~ ", -..,. ::;" ",'I;'1'~_;j';,"i -c. 10 1lI1!!oat JEFFREY R. WHITE (202-42-6018). Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-580 CIVIL TERM SUSAN WHITE (188-42-9227). Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceotance of Service filed on 23 Februarv 2000 indicatina service on 8 Februarv 2000. 3. Complete either Paragraph (al or (bl: (a) Date of execution af the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by Plaintiff: 10 March 2001 by Defendant: 15 March 2001 (b) (1) Date of execution of the Affidavit required by Section 3301 (dl of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None 5. Complete either (a) or (b): (al Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 10 March 2001. filed on or about 17 March 2001. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: dated 15 March 2001. filed on or about 17 March 2001.. - Date: /4- {)"'7~ ~I By () r\.()~__(b S~ ~ Attorney for Plaintiff '! ,,,, !.."i_,.._""'?"-'_C_ _::.. ~~i-' -I",' ,:;" -;"-;--,~;.;.~ - I' V' -.- -.", 0 0 (') C -n ;:: <- -OW C n~;g mm -,~ Z:JJ - .~~ ZC;;' .~ (/) <-, -<~C. !;2C ~'" ,",_L'fj -~-'n ~O ~ ~C) >2 0\'1'1 ~ :::> ~ co -< '~ .' ~.'I' JEFFREY R. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000- .5?o CIVIL TERM SUSAN WHITE, Defendant 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 breakdown 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 1 Courthouse Square 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 DO 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 HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 I I ~. J JEFFREY R. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVil ACTION - lAW NO. 2000- SJ>D CIVil TERM SUSAN WHITE, Defend,mt 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 notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handled down by the court. A list of professional marriage counselors is available at the Domestic 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 1this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. I 2 lj , I . \ JEFFREY R. WHITE, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 2000- 5'J'D CIVIL TERM SUSAN WHITE, ) Defendant ) IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, JEFFREY R. WHITE, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is JEFFREY R. WHITE, an adult individual who currently resides at 4054 Caissons Court, Enola, Cumberland County, Pennsylvania. 2. The Defendant is SUSAN WHITE, an adult individual who currently resides at 1017 Wooded Pond Drive, Harrisburg, Dauphin 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 Complaint. 4. The Plaintiff and Defendant were married on 18 May 1974 in Philadelphia, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. I[ II " 3 , ; , I 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: l- ~'-\- ,"0c:>0 ~.~~ el L. Andes Attorney for Plaintiff Supreme Court 10 17225 525 North 12th Street Lemoyne, PA 17043 4 ,,:,~,e~~~~~~:, .~"~;;1~~~;;f~~';;: ;;~~~" "":iIi!"'l.lt",,,,, ~""'c:"~"'" ~, ;>i5.~" .~~;~~, '\:- x ~ " ,',~ , o,:s; (..}~ ,\ i:i '$. '7" ;ij;,:iiJ ~.F;~ I:::! A.tiifJ " ~. '~5 '-'"--~ .~. ,','''0 -~ 'oiV ~ c ~,', :f, ",' '\,; ~ 1', '-... ." 9 .0 a ~ ~-, ..' i~"> ~,.: -. . j,. : l .. ..;-;~: . . <;:>,."'1:: '1'-~- ,;" _ii."":'::; "':~~__"'''''.;;_''~-':'--~'''~_'~;_'''''''''''__''''''"'''_~''''___''''''':~~;;'';'T""","-.,...'C_":;,.,;."~.-....--~,..,..,....,-....-,,, .," ------ ----- ----- --- ----- _0 ._.__ _ ..... .,_~_..__.___~_,. ..__...__._ ___~ ___ __,.____, _..__._._____ .___..___, ._.____,~_,.~~_-'"~___._,,,_.. '~. "_wr~>____ _~_"_~, ~~__~"r___"_"~"_ '_'~ ~~~~~~;~;,~:;~~~~~~~~JiP1~;~'.lrall~~~g~i~~~j.~~t~,-; _, ....__~ __ _..'~_ ___<0____ '_h__ _<_~,_..,~,.. _.< "';',i:'~.~-'--,-,- ,<:~;-, ~",,'h:'::~~':;~~';'~~~:!'F-.i'1"'-:C - - ,.__.,~. -.. .---'--.-,------ ,. ':-'-f~ ~~;~~r:~-:::::t"~_,~-~..""~.<.L..-~,.'b__-~:'f-cEi;:;O~<::~.:;_.F""""'.' , ..' - ~- - -~~.. , .;.-=-~,""''''._----''', . - .-'... '.~U_~ ~,_~ ~~_k_~.'''~~_,__. "~~ _= .c_. _.~'" --, _._~. _~..~~., .=,,,_ "_~,..~~__,~' ___~__~_.~-.. .P. .~ -'.,.__............................"......"_-.....,,_, . """'-_'.__ ."""_~.,_ ._",._.,_~->><>>-"__~_,,,-~_ "_~"""'-'--""'''''''' ....~._. ",,", - ",.. - --"--- - ..-- --- --- --- -.- - - - ------ --- . ~ -- -. - -.. ,- - - ~_ ,___ ..___ "__r______~__. , ^"~ _ ,,__ _" <_' ,.___~._~ .,~_ __~_,__,_, _~ _ .__. _ ~ _~_ .~~ ,. '__7_~ ----------- ---- -- ----- \' "c.}""!If.;.~.~~~l!~iIB~~~ilii};~1il~~nr:'i'''';;;;l'', ..~.;t.'.. " -,-:~,~_~rl:fi~:,::;;.,,~~~~~,~",_~J:-,:-'f_ ~_- ("'J ~ ~ 0 Ul ~ !:: f'1 . ,. . < A :;; b Z ~ Z H . ;:' <<:: . ... t ~ < H H ~ ~ >- >- " 0 tI] '" ~ ~ z H z b 0 Z ;; '" . '" ;:J 0 ~ ,; 0. :;: ... ~ ",- ~ 0 "'1 z z ~ ,. [j] N 0 ~ :>: ~ H ',,' 1. ] , t.... '. " . , ! f''':' , J .1 , I : t;~~' ,-'''''-, ;.- ,-. i ,b-, ~.~.~" ,- - ~~{E:.~ ~-~~~~~i1~~,~~~'~~~~:-;~!~-~;fl: ,.;,--""''''',.",.- ~------- ,,------=: ~:~~~:m-~~:(~:.- ,1'0 '_,i . . , . , JEFFREY R. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-580 CIVIL TERM SUSAN WHITE, Defendant IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Susan White, in the above- captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant. Date: J.-- y- (JU Nora. Blair Attorney for Defendant 5440 Jonestown Road P.O. Box 6216 Harrisburg, PA 17112-0216 Supreme Court 10 # 4.!J:".'7 _ II ~, " ) r < ,,;.:;1"< ,>" 'I . , - ~'- '-I -~'"~. , "'"k,' ".k, , " .. . c: };{=~, ~-:~; c.~ -'1 ,"7'] ~.:O ::! I I"...1 L~, '~ :....-_,~ ~.., 9 ~ 1',' cr' . ,~, . . . ., . JEFFREY R. WHITE, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 2000-580 CIVIL TERM SUSAN WHITE, ) Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 1 February 2000 and was served upon the Defendant on or about 8 February 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require " my spouse and I to participate in counseling and, being so advised, do not request that the I I" Court require that my spouse and I participate in counseling prior to the divorce becoming i final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. II 3-\S--01 " DATE II ~- "'F ,,' ., . ""'''''''1- , ,. ..,,~ "".' ~ - _c~ ._.'. .. ", " - , (") 0 0 C -'I ? ~ -.",- ~ -Om :;::J.1' mrn ;;;v j= Z;:J:: 1'.) -.-'01 ~~= ,i~~9 U)~;:::. 0 ~l5 ,-,Q ~ ;I:Jn ~8 ~. "-)Cl a -:::'..nl Pc 0 Z w 'b! =< "lJ <.11 =< . . . . " JEFFREY R. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-580 CIVIL TERM SUSAN WHITE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 Ic) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 divorce 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 Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. .5 -15 -01 Dated: II ~,~;, ;.:",-~,I'-<'-' c~, ~.... ~",.",,", . . ",,"'" Q s:;; -nUs ri1 !..1-; Z-C" Z__ ~:~, ~c..., ;Zo -0 )>C Z =< -, , C,) o -=it - -~ ~:O N o :~ -:':Jt:0; ---<-~~ " , ~~~ "-' -". ~ ;po ::;~ cs .. ,J) U'J . - . .._ K, . JEFFREY R. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-580 CIVIL TERM SUSAN WHITE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 1 February 2000 and was served upon the Defendant on or about 8 February 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I com;ent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. . .J;/o-IJI DATE . ... AubUP~. .:...... , ' - , : -, '. . , . '- . SUSAN WHITE. .. . ... .. .... .." ... ".. II '" ,,"J . - '--.-:'.....:-~" -~..." ~ '" . ~ "';,- (') 0 0 c:: .... $: :::lC v 0:; "'" ~ nl'm ::0 Ie :z: :r:..' N :'~~d ZS: en """ q <.5)., -<C' c::c.~ :0,,, ~~I; =R ~n ~g,: {g'~g 55:0 S' c j;! ,~ 1"..0 ::q (J1 -<; ~ 1IiIiIliIi!1'ii! ... 'JIll. . .....,\ ~ JEFFREY R. WHITE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-580 CIVIL TERM SUSAN WHITE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 divorce 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 Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4H04 relating to unsworn falsification to authorities. $-; O-l) I Dated: ~~/~ SlJSAN WHITE /I WilIiii ,,;_1" '.,J . .- ~'"' ,- u~,:".;.._.,. "" " ._ "':''"'~"--"ill.f'.'' . " - ~. . ~.. ~4 0 C 0 C " -~ ::!I: :;. "UC'- > :n nlrn ;'::0 Z::r:: N -r-~h, LC i:j6 U),c"" c::> ~ " ~o > -......: ~,.,..; >0 3': ~~6 z:~ -0 S' (Srn Pc -j :z: w ~ =< (J1 ~