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HomeMy WebLinkAbout00-00683 ".,. "Co',",,,,,;,,, ~~ ',1- L ,.< :J ~'38;,:x.;;:,,'xe(:;>>:;::::;~.;(>~.!;::i'a.:(:;::jlxXe;:::::;~{:::,~..~::::~e:(:;,>>:Ci~.;:'::::::~e:(Xe:(:;a.>(,'::::.X:::;>>:(::;a.;:".:!1::;a.:<Wi~:~';':il;~';';::'~ig:~(:;_:::e;c11 ~.t I ~ ~ ^ ~,~,:, i'"~ . ~ IN THE COURT OF COMMON PLEAS ~ I i ~ OF CUMBERLAND COUNTY I b W I ~ ".", M t"; ~ 8 i . I " ..::~;;:).:>~ ):e< ":~ ".". i ~.~ i ~.~ ~ "'.~ ~ "'.~ t "'.~ ~ ~.~ ~ ~.~ ~ i "'.~ ~'s , ~ ~ ~.; ~ ",.,., ~ ~.~ ~.; ~ a ~.~ ~:: I ~ ~'< i.~~ ~ ,",,' ~ ~.t ~ ~.'~ ~ ~.; ~ ",,' ~ ~ ~.~ * ~ - ~.~ ~ ~, 8 ~~ ~ ~ ~.~ ~ ~ ::~::.::.;;:>::.::<::'::.::",:>::.::.'::~:~::.::~,;:}::.::.:. x.::...: ::~::.::.,;:::"::.;< :::.::.::~: STATE OF PENNA. CRYSTAL L. RANDALL, PLAINTIFF N o. uuJ~,~,o.::-,~,83,u,uuuuuuxpg Versus ALLEN R. RANDALL, ..PEFE,N])AN,'J', DECREE IN D I V 0 R C E ...rt: J,,"'~',.,1, AND NOW, ' . . ::4 ~:.-:~. . .1.9, . ,. ., " JlI}{. .~~~~, it is ordered and decreed that.. ~~.>:~f~;r.. ,1;0,. ~~~I?~.~~...........".....,....,., plaintiff, and. . , . . .. .. .. .~~~~!-'l. .~:. .~t:t:l?~.l:~.. ... . .. . ,.. .. . ,. , , , ... . ,., 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; THE PARTIES' PROPERTY SETTLEMENT AGREEMENT DATED JANUARY 8, 2001, .......................................... ............ ................. .., IS HEREBY INCORPORATED, BUT NOT MERGED, INTO THIS DECREE. A COPY .................."................... ............ ......................... OF THE AGREEMENT IS ATTACHED HERET Prothonotary By Attest: .Ct, ".. :.;:: ':~>>::.;:: ';:.:+::( >:.:>:,: ::'.:+::( )a>;!(:':.::.}:,: x.::~;;: :::o:.::{ :::~:.::.:;. ':'.::.::":: "~::.::~'" ,".:.::.... I ~ ~ ~ ~ "'.~ ~ ~ i..~ ~ i.":~ ~ i.~~ ~ ~ "." ~ ~.~ N ~ ,,''>. i.'~ I N ~ a "'.~ ~i i ~ ~ ~.~ ~ i..S * ~ ~." i.'s ~ ,,'., i ~.~ ~ ~ ~.~ ~ ~.~ J. W ~.t N ~ ~ ~.~ ~ '.. Q '.' ~ ~.I . ~' ,- ' " . . ",'>,- , . /-01';;>-01 tW C'~ ,/UA:RV ~ ~'~ /'0?02-0f ~ ~ ~ 4 ~ ..-C:::_ .L. ~ ~-<lI '- " . , " 'l'~ . PROPERTY SETTLEMENT AGREEMENT , ,;III"~ pili;: I QIIK. ':/+.' THIS AGREEMENT, dated the 0 day of JIo/'JO.fl,f~.,! , 200;1, by and between ALLEN R. RANDALL, of2911 Karr Road, Belvedere, Illinois (hereinafter, the "Husband") and CRYSTAL L. RANDALL, of221 S. Washington Street, Apartment 2, Mechanicsburg, Cumber- land County, Pennsylvania (hereinafter, the "Wife"), who agree as follows: WITNE SSE TH: WHEREAS, Husband and Wife entered into a marriage on or about May 10, 1996, in Gaithersburg, Maryland; WHEREAS, Husband and Wife have two (2) children together, namely: Emily E, Randall (Date of Birth: May 23,1996) and Allison N. Randall (Date of Birth: July II, 1997); WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; WHEREAS, Wife filed a Complaint for Divorce on or about February 4, 2000, which is docketed in the Court of Common Pleas for Cumberland County, Pennsylvania at No. 2000-683 (Civil Term); and WHEREAS, Husband and Wife desire by means of the within Agreement to settle and determine all of their rights and obligations to one another under the Divorce Code of 1980, as amended. NOW THEREFORE, in consideration of the promises and covenants contained herein, and intending to be legally bound, it is agreed by and between the parties hereto that: 1. Separation. It shall be lawful for each party at all times hereafter to live separate Page I of9 - Hrl " '" , , ~='"'1 " '. ,. . and apart from each other at such place as he or she from time to time shall choose or deem fit. They shall be free from any interference, direct or indirect, by the other in all respects as fully as ifthey were unmarried. They shall not harass, disturb or malign each other or the respective families of each other. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or lmlawfulness of the causes leading to their living apart. 2. Entry as Part of Decree. An action seeking the dissolution of the marriage is pending in a court of competent jurisdiction. The parties hereby agree to execute the Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree at the earliest possible date, The paliies acknowledge the availability of counseling and both parties have waived their right to counseling. It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree or divorce, temporary, final or permanent, shall affect or modifY the financial terms of this Agreement. This Agreement shall be incorporated, but not merged, in any final Decree in Divorce. 3. Mutual Release. Except, and only except, for all rights, agreements and obligations of whatsoever nature arising under or which may arise under this Agreement or for the breach of any part of this Agreement, Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claim in or against the property of the other or against the estate of the other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against the other, Page 2 of 9 -- Yo', ~, ,-,~'. r. 'l ~ l the estate ofthe other or any party thereof. Except, and only except, for all rights, agreements and obligations of whatsoever natnre arising under or which may arise under this Agreement or for the breach of any part of this Agreement, it is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, whether real, personal or mixed, which the other now owns or may hereafter acquire, 4. Waiver of Claims under the Divorce Code of 1980. as amended. IncludiDl!. but not limited to. Claims for Spousal Support. Alimouy. A.P.L.. Attornev's Fees. etc. Each party absolutely and unconditionally releases the other and the estate of the other from any and all rights and obligations which either may have for past, present, and/or future obligations arising under the Divorce Code of 1980, as amended, including, but not limited to claims for support for himself or herself, spousal support, alimony pendente lite, temporary and/or permanent alimony, counsel fees or expenses from the other party. S. Warranty of Disclosure. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party of every type whatsoever and all other facts relating to the subject matter of this Agreement. The parties waive their respective rights under the Divorce Code of 1980, as amended, to obtain formal valuations and appraisals and to engage in formal discovery to identify and value all property owned individually or jointly by a party. Each party has had ample opportunity to review the financial condition of the other and each party agrees not to challenge the instant Agreement based on an allegation of lack of sufficient disclosure of Page 3 of9 - ~.' . ~ Ii ",",-,. ~ , " 1.' I assets, debts or income. 6. Duty of Coooeration. The parties shall mutually cooperate with each other in order to carry through the terms of this Agreement. Within ten (10) days after demand therefore, the a party shall execute and deliver to the other any deeds, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or cause to be done in any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. 7. Breach of Agreement. In the event that either party breaches any provision of this Agreement, the non-breaching party may seek to enforce this Agreement in a court of law or equity, and, if a breach of the Agreement is established in a court of law or equity, the breaching party shall pay the non-breaching party damages for said breach, if any, and all reasonable attorney's fees, court costs and expenses which are incurred by the non-breaching party in enforcing the Agreement. 8. Personal Pro\>ertv. Husband and Wife have previously agreed to the distribu- tion of all items of personal property, including, but not limited to, accounts and household goods, Except as provided herein, Husband agrees that all such property in the possession of Wife shall be the sole and separate property of Wife. Except as provided herein, Wife agrees that all such property in the possession of Husband shall be the sole and separate property of Husband. Each of the parties does hereby specifically waive, release and renounce any further claims with respect to said items. 9. Waiver of Right to Share in Retirement Benefits. The parties hereby waive, Page 4 of9 ~~ . , ,. ' relinquish and release any and all claims and rights either may have or ever had, presently has, or may in the future acquire, in and to any and all retirement benefits titled in either parties' individual name, whenever acquired, including, without limitation, any and all pension and profit sharing plans, Keoughs, 40 I (K)'s, LR.A.s and any and all other assets ofIike kind and character, and any appreciation in the value thereof, whether due to market conditions or the direct or indirect contributions or efforts of either party. 10. Marital Debts. Except as otherwise provided herein, each party agrees to assume full responsibility for any and all debts in their individual name, regardless of whether the debt(s) is/are marital or non-marital. Each party agrees to indemnify and hold the other party harmless from any liability, cost or expense, including attorneys' fees, which are incurred in connection with such debt(s). 11. Other Debts. Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and ail claims or demands made against her by reason of debts or obligations incurred by him, 12. Medical Insurance. Each party will be responsible for his/her medical insurance. 13. Waivers of Claims Against Estates. Except as herein otherwise provided, each Page 5 of9 ~ ~ ~" - " 'j': , . . , party may dispose of his or her property in any way, and each party hereby waives and relin- quishes any and all rights he or she may now have or hereafter acquire, under the present 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, curtesy, 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's estate, and each will, to the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 14. Tax Returns/Credits. Wife agrees to apply fifty (50) percent of the parties' 1999 Federal tax refund towards Husband's current child support arrears on the aforesaid,minor children. For tax year 2000, the parties agree to file their taxes under the designation of "married, filing jointly" and equally divide any refund therefrom. Beginning in tax year 2001, and continuing thereafter, the parties agree that each shall be enti~led to claim one (I) child as a dependent on their respective tax returns, provided that Husband is current on his child support obligations. If Husband is not current on his child support obligations, then Wife is entitled to claim both children as dependents on her tax return for the tax year in question. 15. Motor Vehicles. Husband agrees to transfer to Wife all rights, title and interest he may have in the 1992 Chevrolet Lumina. Wife shall be solely and exclusively responsible for any loan or encumbrance thereon, and that party agrees to indemnify and hold the other party harmless from any and all claims. demands, actions or judgments arising therefrom. 16. Advice of Counsel. It is recognized by the parties hereto that Wife is represented Page 6 of9 ~. '. , ~ . , ,. . by Michael A. Koranda, Esquire, It is recognized by the parties hereto that Husband is repre- sented by Keirsten Walsh Davidson, Esquire. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement is fair and equitable, that it is being entered into freely and voluntarily and that it is not the result of any duress or undue influence. 17. Bankruptcv. In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceeding of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor-spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby assigns, transfers, and conveys to the creditor-spouse an interest in all ofthe debtor's exempt property sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorney's fees and costs incurred in the enforcement of this paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contrary, and each party waives any and all right to assert that any obligation hereunder is discharged or dischargeable. 18. Effective Al:reement. This Agreement shall bind the parties, their heirs, executors, administrators and assigns. 19. Entire Al!'reement. This Agreement contains the entire understanding of the Page 7 of9 - .' . parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 20. Prior Al!reement. It is understood and agreed that any and all property settle- ment agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 21. Modification and Waiver. Any modification or waiver of any provision of this Agreement shall be effective only if made in writing executed with the same fonnality as this Agreement. The failure of either party to insist upon strict perfonnance of any ofthe provisions of this Agreement shall not be constmed as a waiver of any subsequent default of the same or similar nature. 22. Governinl! Law. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 23. Contract Interpretation. For purposes of interpretation and for the purpose of resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly by the parties. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals on the day and year first above written. Page 8 of9 - WITNESS: ? ,. . ALLEN R. RANDALL C~dD~ C ,-- 'l ~~DT.1\mN. ~':,~;\l lO~l it Pub!io MGfjh?,iihtb~}:~:~ (;t:::"t; rl;'1 My CI,"lrr;miGf,l>;:~l f;(pl/iZ,;S JUiJ~ @, 20G3 J --.- , ---~..._'"',.,- ,..", . Page 9 of9 ,.:1.., , ],:; ~'~~ ,I ~ > . COMMONWEALTH OF PENNSYL VANIA ) ) ss: COUNTY OF CUMBERLAND ) On this, the ~ ....-.-- day of Jt::VuutlJV , 200~, before me, a Notary Public, personally appeared CRYSTAL R. RANDALL, known to me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ------..--, i'.':"'t'~' !:-tl ~, Q"",l' I 11l~...IM" K~vl:.":,L. 1 lO~1 A. T~'''''''r.: f,k,"~",-, P'.;-;':'i~ ! M~~h~it~i~~l~~~~ r.~~~i!);~~ ~~~;";'~<i{'~ J My Commifl~i(\fl E~~11rG$ ji(~i~~ ['.:! r"~!:.J ~ Notary Public "i;, . . .. . STATE OF ILLINOIS ) (l. ) ss: COUNTY OFUtrn6uhl1cf- ) On this, the ?ItA day of 4J1Litl,''V ,20M, before me, a Notary Public, personally appeared ALLEN R. RANDALL, known to me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WI1NESS WHEREOF, I hereunto set my hand and official seal. r--= .t;:';;;:;.;:':;::"~.~-:,".'i -'---,~ ",1,i,;:P..."' ,\'.':'.d ! Mz{;hJ.nj::,'~bi}~:; (.J~::~'::-: ;~;:..! :~'.-~; 1 My Ccrfm~l~r!gn E~(n~l.:~ J;~;;.z: ~.:.~~l2..J Notary Public ,~ . ~ IlIillI:llr~ - .....""'" .. "~ do',",;. _ '" .~'~ o ~~ -rJ.,_', 1"Tl r- ~ -, 2:1.'; ZC ~~~: r:: (.) <- J>,.-- ~.~('"-; Pc ~ C:) ,C -, (,:;', ~';', r'-...J .. , :i::! - 'D ,. ~ ~''''"''-~1'' '. CRYSTAL L. RANDALL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs. No. 2000-683 ALLEN R. RANDALL, Defendant. CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD TO TIffi PROTHONOTARY: 1. Ground for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code, 2. Date and manner of service of the complaint: February 9,2000, by Certified Mail - Return Receipt Requested (~ Affidavit of Service attached). 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff, January 8, 2001; by Defendant, January 8, 2001. 4. Related claims pending: None. 5, Date Plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: January 8, 2001. Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: January 8, 2001. Respectfully submitted, TOMASKO & KORANDA, P.C. 219 State Street Harrisburg, Pennsylvania 171 0 1 T""hMoNo., 7~ By,d~p 'MICHAEL . KORANDA ~1IIiIiiiiI""""_"~~""'-.iiIiI .' 0 0 0 c- d ~ :'::,,~ V GJ :-C';' ,. :;g. n'l m :2.:: Z ."!; , Z i';'~ '" ~ ~-. CI> .'c',-. -::1 () I- e) -::! ~- ~ ~i" )> 0 -,~.. . C) Z C) IT; > l'.) i,::J; c .. Z; :--.:> ....e'. =< :D C) -< m ". .' J 10 ~ '" ". . , CRYSTAL 1. RANDALL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. cXW - !/i'3 ~ ALLEN R. RANDALL, Defendant. CIVIL ACTION - 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 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 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, Cumberland County Courthouse, 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, P A 17013 Telephone: (717) 249-3166 ..... ' ..... "'. J CRYSTAL L. RANDALL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. ALLEN R. RANDALL, Defendant. CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Crystal L. Randall, who currently resides at 200 East Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Allen R. Randall, who currently resides at 2911 Karr Road, Belvedere, Illinois. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing ofthis Complaint. 4. 5. parties. 6. 7. 8. Plaintiff and Defendant were married on May 10, 1996, Gaithersburg, Maryland. There have been no prior actions of divorce or annulment of marriage between the Defendant is a member ofthe Army National Guard. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. ~........... "', - """ ". '-.-~ . . ..- WHEREFORE, Plaintiff prays that a Decree be entered divorcing the said Plaintiff and Defendant from the bonds of matrimony heretofore contracted between them. I verify that the statements made in this Complaint 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 falsifications to authorities. Date: OJ Fe13 DO Cutt4/~Y Cryst L. Randall Respectfully submitted, TOMASKO & KORANDA, P.c. 219 State Street Harrisburg, PA 17101 Telephone: 717-238-1100 By: ~$~~ MICHAEL A. KORANDA Pa. I.D. #58808 LL o C~ LtJ u... = J;,".:J (:::: 7 ~~ -" ~~~ i~~~ ___I..JJ ~r~ (.) ..::l' ).), "\ ~ \r)~ f'..\A ...... ~ \ ~ Q " ~ ~"> ~~ ~ ~\: 101 C >- ~ '-' j-~ ~~~ ~,f: ell r--.: _:1 -.~ 0... ~ u ~ 0 ~ ~ 0 r-- 0 .; ~ :::0 " Q E- Z , 0- '" 00 ~ '" z '" 3 <'l'D '" ~ '" N ' " E- 00 '" ,. ~<'l G:: 0 '" ~N "- ~ '" z ~ z r--~ Cl ~r-- " ~ E- '" wt:: ",0.. "" <5 z ~ -l 0 0- 0 ~ '" x ~ N " :I: '" '" ~ " ..: '" ::J'" ::;; " '" '" f-< 0 " ..... :r: " ,~ ' 10'_',>, ",_" '. LA W OFFICES TOMASKO & KORANDA, P.C. 219 STATE STREET HARRISBURG, PENNSYLVANIA 17101 TELEPHONE: (717) 238-1100 FAX: (717) 238-6190 . Certirie<l !obellITUeatldcurrcctcnpyofrccor<l. .......---...- -. ,'~ ~ ~~,,~ ,& '''=~ .~ ~~ ~ ~" ,. L J. '; CRYSTAL L. RANDALL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs. No. 2000-683 ALLEN R. RANDALL, Defendant. CIVIL ACTION - DIVORCE AFFIDAVIT OF SERVICE I, Michael A. Koranda, Esquire, served the Complaint in Divorce on February 9, 2000, in the above-captioned matter on the Defendant, Allen R. Randall, by regular and certified mail restricted delivery to the Defendant at his address of291 1 Karr Road, Belvidere, IL 61008. On February 14, 2000, the Defendant accepted delivery of the Complaint, as evidenced by the return card attached hereto as Exhibit "A" and incorporated herein. 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, ~ 4904 relating to unsworn falsification to authorities. -~f " . ~ ~ J ... E DR: :I .'Complete items 1 and/or 2 for addltIonalssrvices. .. _Complete ftems 3. 48, and 4b. I .-Pllnt your name and address on the I8V8rse of this form 80 that we can returri this card to you. -Attach this form to the front of the mallpJece, or on the back if space does not perm". " ._Write-Retum R8Q8/pt Requested-on the mailpfece befow the article number. ti ,~e Retum Receipt will show to whom the article was deliV8l8d and the date I: '--:tf~red. o I .' Arllcle Addressed to: .l~ IJI(&I 1:. kfJtJd>ltU- ?7 /1 KHa t2 c>lt-O Bdvld~ -:lL (P160~ 5. Received By: (Print Narne) !5 6. signatuJl')f~Pf "!IrA t X \~'p-\l 1\\ .!I PS Fonn 3811. December 1994 I also wish 1ll_1he fallmwlng eervlces (for an extra fee): 1. 0 ~"'ssee's Address j 2~llStricted Delivery ConsuR pos1Jl1aster for fee. I 4&'2: Num~ (c66 '. 4b. Service Type I o Registered' , Cel rtIDfled ,. o IOXpress ,,!ell , o Retum Receipt for e 'lo 7. Dale of Delivery .: I J n\j \\ i.\iHttil ii Hi\ t\\\i,l 102595-97.B.{)179 Domestic Return Receipt EXHIBIT A !lliI1iJIIIj ~~ ~~ ..uw-- 1iI/il''- - ........~' MiIli..il_f l.liI~ ~-. 0 c c:' " i';J ~ ".' ',1;;;'~ r, 'j" :.c.::. ,,-" . 5:') , 0" r-~ C' -n :::,> / " -:7 (:5 )> c !'Cl z: =< '0 -~ '" '" . CRYSTAL 1. RANDALL, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-683 (CIVIL TERM) ALLEN R, RANDALL, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on February 4, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of 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 have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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. S 4904 relating to unsworn falsification to authorities. Date: l}a}O J P::t!~~ ~ CR YS ~L 1. RANDALL ;llij.iP"'iff Jliilllil' -- ,~ . "'""" ~"'~li''''' " Ji_~'.."""'" ...._.w -- . ~^! . 0 0 C -o? -OfTJ .~ mr-:::'i 'l~ Z::J:" ,~ ~~:. c-, r:'~-' ~<'--) "TJ ..,J>C'; _..;o,.w Ze' >) N C ~ :;-.00: '0 :n ""' ~~ ~ , .. . " CRYSTAL L. RANDALL, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-683 (CIVIL TERM) ALLEN R. RANDALL, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCKDECREE UNDER l\ 3301(c) OF THE DIVORCE CODE 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! 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, S 4904 relating to unsworn falsification to authorities. Date:~ ~~~ CRYS AL L. RANDALL II~' ".liiIil ~"-~~ -. ,j , --;,.",;,"~., ,.i;. ~~ .~ ","."" , , ,,... ... () c:> C $. , ~~~! :.':;"~ ." Z (f):c.:, 0' -<:L (~) ~C; --0 .--. --i-] y.....,-.-. ~,~~ 2~r~ Z>.,< )> .- ;'\.) C..:: z -~ ."V ""' =< ->J a -< . i._ " -0 .' - - CRYSTAL 1. RANDALL, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 2000-683 (CIVIL TERM) ALLEN R. RANDALL, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on February 4,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of 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 have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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. S 4904 relating to unsworn falsification to authorities. Date: f J'IM O( /lJLt~ ALLEN R. RANDALL lIli;lO." .' " '.~, i., , > ,."-' "'"', '~ , ," "".'", o S; "", 1:)fj:"' [I1 L~ Z--:,;; ~~, r:::---1 ~t; >r ~ " , " .. j:::'''' ",., ", :~; ",,-:.- 0> -0- ~_,c_ ~,_,.a ~) ~') '0 , ~ . .. , . " . . . , ," , - CRYSTAL 1. RANDALL, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA , vs. : NO. 2000-683 (CIVIL TERM) : CIVIL ACTION - LAW : IN DIVORCE ALLEN R. RANDALL, Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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 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, S 4904 relating to unsworn falsification to authorities. Date:OX :!tiP\. Of (l~ ALLEN R. RANDALL ii'.""~ ~ ,~ 100 .,' .J-:"'l"", . ,,' ""'" " . , o c <, -Ocr ~~f; Zl.,~' ~~, Pc Z; =< "".' '~ ~', '-' ~l "nD " 0" ,~; ~~~'; -;.: ~~ . --2~~ Q' -~i ""'r> -,,; =-< -'0 r::~ :'., (,::;.