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HomeMy WebLinkAbout00-00775 ~~.~':'X.~''',X.~':::X.~'':X.X':''~}:::X.X)a;:>.::':,3C'::::'~c~".,::,~.x ::'~C"""<+~":::'~.~"':"~C.,"'a;:.':-'~.x:'<+~',"a;:'c,)::::-,a;:,:x.}:l'x.}::xC!':';~.~":'~.}:::Kc';:>~.}::::>~ell ~.~ ~ #', ~'~ ~ ~ ~ ~'S ~ i ~.~ "-,' ~ ~.~ ',,' i';'~ ~ '/< to; I ~ ' . !i! lM>.::x,,:,. )3C":'>>~"-:+~...::' .,:,,':', .,:.::.a;::;,~.x:.~c";:::,~.x,a;:.:.<+:,,,<+:. X.:', :,.~.;.,.~.;.-:.~., '-:.:., '~.:', ii ~.~ f.':.~ , ~-.s ~ +,; ~.; ~ ~.~ ~\ ~ ~'S ~ 8 ~~ ~ ~.~ ;'+s ~ N ~ ~~ ~ ~.~ ~.; jl;"s I ~'~ ~ ~'S I f~ I ~.~ ~ I ~~~ ~ ~ ',,' ts ~ ~ ~.~ f.'~ ~ ~.~ ~ ~.S * ~', ~ ,~ ~"' . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .~. ~ PENNA. Lydia K. Hurley Versus ummuum,uu I II II I Civil-Tewm 2000-775 No. uuuuuuuu....u. Plaintiff John M. Hurley Defendant DECREE IN DIVORCE AND NOW,.. ..iM..O't... L.~.........., ~, it is ordered and decreed that ............ ~y<:l;i.".I,Z,. l1\lrJ.H. . . . . . . . . . . . . . . . . . . . . . " plaintiff, and. . . . . . . . . . . . . . . . . . . . .J.o.~n. .~'. .~,,:r.~e'y. . . . . . . . . . . . . . . . . . . . . . " 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; -.JJ 0 II\SL... .1;I1~ .I:"'r:t.:i,~~ '. .}ja,r:r::i,,,,g~ .q~t;q~lI)~"t; ,.'~gr:,!,!lI),!"t; . 44t;'!4 .'1" .If'!I?r:\l4J;J.' . ~, .?QQQ.:j.~ . . . .~~~~~~~~~~~~ .~~~~i~.a~~ .~~~.~~~~~.~~~.~~~~~d~~~i / By Attest: .. n. .............. Prothonotary ~ ;;.::.::.-:: :::.::+x ::.::+> - ::'.::ct::.:: :::~::.::.-:' :::.::.;.', ."::.;'..::' .::+::.,::::-.::.;.--: :-:-::+::::: -", ~.:s ~ ;..; ~ ~ ~.~ .,' ,'s ~ N ~ ~.~ ~'S ~ ;.'~ ~ ;,Oi ~"<;~ ~ ~ ~.;.; I ~ ~.~ ~ ~ ; ~ ~.~ ~ ~ ~.'~ - ~~~ ~ ;.~ ~ ~ ~.~ ~~';; ~ ;'s ~ ~.; ~ ~.~ ~ ~ ~.~ ;.~ ~ ,..,; ~ ~.~ a ~i ~ ~ ~.~ J. ~ ~.~ ~.~ ~ ;.; ~ ~ '.. ~ ~.~ ~ ~.~ ~ ~.~ , . '. 7.;1.&tJ ~~~ ~4~ /,/t/.t1t1 :J1~ /U~ ;?f.; ~- . L ~';, " _" _ "'~ _~, ,~-y~_" ' _,_ n ,'r_" - - , "_Ill'! __ "~ ~ . ," ,~, ' ~~ , ,.!Il'1 -~ .-" iI. - ~'."'c''''- LYDIAK. HURLEY, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA No. :l.ooo- "77 S CIVIL TERM JOHN M. HURLEY, Defendant CIVIL ACTION - LAW IN DIVORCE MARITAL PROPERTY AND SETTLEMENT AGREEMENT This Agreement, made and entered into this ~ day of "lhlAA I!v.^ , 2000, I between LYDIA K. HURLEY of 1096 Centerville Road, Newville, Cumberland County, Pennsylvania, hereinafter referred to as "Wife," and JOHN M. HURLEY, of 12 Subdivision Road, Newville, Cumberland County, Pennsylvania, hereinafter referred to as "Husband." WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on September 24, 1994, in Newville, Cumberland County, Pennsylvania; and, WHEREAS, certain differences have arisen by and between the parties as a result of which they have now separated and the parties hereto are desirous of settling fully and fmally their respective financial and property rights and obligation as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband of Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates; and, WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof, and each has had the opportunity to consult with his or her own competent legal o~->~"~ ~. ~- ..... 2 -.-~ " .~ - v.. ~". . L -~"'''J.; of any improper or illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has had the opportunity to be fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and having the opportunity to be fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to have the Court of Cornmon Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order effecting the respective parties' rights to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 2. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 3. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 4. Mutual Property and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties 3 ;- ,~-.~- ~~ ~ ~ ~ .~',*,w"",J hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of dower or curtesy, rights to inherit, rights to claim or take the Husband or Wife's or farnily exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator.. The parties further agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution of married property ordered by the Court pursuant to Section 3502 of the 4 ~ "~ -'. ~lIIi:h"r~' Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenances, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 5. Division of Personal Property. The parties agree that their personal property has been or will be divided to their mutual satisfaction, with Husband taking the furniture he is satisfied with and premarital property including the tractor, tools/cabinets and items from the barn. Husband may store items in the barn for a reasonable period until he locates appropriate storage. Wife shall retain possession of all of the animals presently located at 1096 Centerville Road. AUTOMOBILES: Further, the parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property, including motor vehicles. Wife shall hereinafter own the 1991 Ford Picknp, 1985 Buick Rivera, and 1977 Chevrolet Monte Carlo. Husband shall hereinafter own the 1979 Ford Pickup Truck. The parties further agree to execute whatever documents are necessary to transfer title to the vehicles, if necessary. BANK ACCOUNTS: The parties hereby acknowledge that all bank accounts have been split to the mutual satisfaction of both parties. Wife shall hereinafter own and be responsible for the F&M Trust line of credit. Wife shall also be the sole owner of the savings and retirement account at Member's First Credit Union, Fort Pitt Consolidators, Inc. and any other accounts that were put in Husband's name when the parties were married. 5 J llh",,~ From and after the date of the signing of this Agreement both parties shall have complete freedom of disposition as to their separate property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, conveyor otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. POWDER PLUS, INC.: Wife agrees to waive any and all right and interest she may have in Powder Plus, Inc. 6. Debts. Wife agrees to assume the debt incurred in connection with credit cards that are in Wife's sole name. Husband agrees to assume the debt incurred in connection with the GM credit card. The parties agree to be responsible for any other individual debts which are presently in their individual names and to indemnifY and hold harmless the other for the aforementioned debts.. 7. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will indemnifY and hold the other harmless from any and all liability thereof. 8. Real Property. It is hereby acknowledged by both parties that they are the co- owners of real property located at 1096 Centerville Road, Newville, Cumberland County, Pennsylvania, which has a mortgage thereon in both parties' names. Husband hereby agrees to transfer his interest to the real estate to Wife by executing a deed upon request of Wife. Wife agrees to be solely responsible for the payment of the mortgage and hold harmless Husband for any 6 M~~ ' ;-... ~'"'" mortgage payments, taxes, utilities or other assessments. 9. Support, Alimony and Alimony Pendente Lite. Both parties agree to waive any and all rights either may have to support, alimony and/or alimony pendente lite from this time forward into the future. 10. Pension. Each party agrees to waive any right they may have in the others' pension or retirement plan. II. Taxes. The parties agree that all 1999 income taxes shall be filed jointly. Any refund shall be paid to Wife. 12. Counsel Fees and Court Costs. The parties agree to be responsible for their respective legal fees and court costs incurred in the process of any divorce action or separation agreement. Wife agrees to initiate the divorce and pay the cost of the filing fee. 13. Divorce. The parties acknowledge their intention and agreement to proceed in an action in divorce to obtain a final decree in divorce by mutual consent on .the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in any divorce action. The parties agree to execute any and all documents necessary for the entry of a final divorce decree. 14. Breach. In the event that either party breaches any provision of this Marital Property and Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of ,the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 7 ,-,'.< '. llllf. ""o~. 15. Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any court of competent jurisdiction. 16. Applicable Law and Execution. The parties hereto agree that this marital settlement agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 17. The Entire Agreement. The parties acknowledge and agree that this marital settlement agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 18. Incorporation and Judgment for Divorce. In the event that either Husband or Wife at any time hereafter obtain a divorce in the action for divorce presently pending between them, or otherwise, this agreement and all of its provisions shall be incorporated into any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this marital settlement agreement. 19. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurreq as a result of such failure. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first 8 ~ 'iIodi .. ~I .'. _~_""",' written above. &Z;w #fo~ 6J~~~ 9 '.:." "~4 S, Ht..Nt.%'[:t;: ~,"f .. ~:A,i",t-'t!0, t.A, I ;;'(l~1 Hj,l): """"~'",, ... " ~ .~~~ ~"v< ....-J J__ ~"..",--,it'_ .0. LYDIA K. HURLEY, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY,PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - 775 CIVIL TERM JOHN M. HURLEY, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following inforrnation to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c),3301 (d)(l) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Cornplaint: Certified maiL return receipt requested, restricted delivery, made on February 11, 2000. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by sec. 3301 (c) of the Divorce Code: by plaintiff Tune 16, 2000; by defendant Tune 7, 2000. (b) (1) Date of execution of the affidavit required by sec. 3301 (d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff's affidavit upon the defendant 4. Related claims pending: None 5. Cornplete either (a) or (b). -+..--- - -. ~ I , "~ T- ....."'..". (a) Date and manner of service of the Notice of Intention to file Praecipe to transmit record, a copy of which is attached D2l Date plaintiffs Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: Tune 23, 2000. Date defendant's Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: Tune 12, 2000. 1-svcv 7h,~ tto ey for Plaintiff Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 ...... ...... .'" -:"F ~ ~' .~ - -I ~.. ""']~ LYDIA K. HURLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, ENNSYLV ANIA vs. : CIVIL ACTION - LAW : NO. 2000-775 CIVIL TERM : IN DIVORCE JOHN M. HURLEY, Defendant 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 will proceed without you and a decree in divorce or armulment may 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 or 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 (717) 249-3166 ~ " _ ~ c .,,1 ~- -,I LYDIA K. HURLEY, Plain tiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2000- 7'75 CIVIL TERM JOHN M. HURLEY, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (0 OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Lydia K. Hurley, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following: I. Plaintiff is Lydia K. Hurley, an adult individual, currently residing at 1096 Centerville Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is John M. Hurley, an adult individual, currently residing at 12 Subdivision Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 24, 1994 in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or armulment between the parties. 6. The 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. - Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, ~%.i J cqu ne M. Verney, ESqUi~ Supreme Ct. 10. 23167 44 South Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Plaintiff ~ " "~ - J -",- ,,,' ~ VERIFICATION I verifY that the statements made in the foregoing divorce complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ,;2. -10 - 0 0 Date ,",.,_. ,,'" ..~'....", '~ i ':'1""\ ~~i (AR-U::l-ir', 11,1., r /{J!j .. \/""', ;;':, . ,~ i:: LYDIA K. HURLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO.2000-775 CIVIL TERM JOHN M. HURLEY, Defendant IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1930.4 (c) COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Jacqueline M. Verney, Esquire, being duly sworn according to law, deposes and says that she is the attorney for plaintiff, Lydia K. Hurley, and that she did serve a true and correct copy of the divorce Complaint that was filed in the above matter, by U.S. mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the defendant, John M. Hurley, on February 11,2000. The receipt form is attached hereto as EXHIBIT "A". ~~"~67 44 S. Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Plaintiff Sworn to and subscribed before me this ~ day of rY\ ~ (-- C (~~~~ ,2000. N TARIAL SEAL DENISE PINAMONTI. Notary Public Carlisle 8orouQh, Cumberland County M eofl'M", '.Expires Nov, 20, 2000 ,-_._-"."........,...".~-""._~_.._,,~--- ... S ER" ,. ','. ',..,".,"""",""'"' , J "C<>mplete ~ms 1 +or2 fmAClMDm~-" TO. - ~.. D. I .. _complete items 3. . and 4il-~" I , I _Print your name and address on the reverse 0 t 18 nnso we can retumthis I _~a:~:fonntotHelr.ontoftDiU~space~not ~ "~Retum R_Pl~iniSI"'onlh._jl1~Cll'blllilW1II'I8Il!CI6'il.l/lIl8r. . "1118 Return Receipt w1111lJjilw to Whomth8anld......dellV1l..ltsn_ date i delivered. I 3. ,i~:8sed;, ~l(LL(1 I 12. Sdil3bd/"ru.I\.JlCd Nf.vJ ill !! [. { (A 172.. Y I !; ~ .!! 5. EXHIBIT A I-,': ~Cerlifi"" Domestic Return Receipt f .'\.\"';' r.;H'-i_~. (~I- . Jacqueline M. Verney 4c<f 5. H~r'1:q'{,rER) r Cil,RU~H_j."A. i"jrJi.'.l fA.';; i:n!) :~4,~,,:':;1.ffi. , ....::J.... -:i.IiIlR.II,wililiill~ ~ "" - ~-~-~' , , , LYDIAK.HURLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA v. CIVIL ACTION - LAW JOHN M. HURLEY, Defendant : NO. 2000-775 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) ofthe Divorce Code was filed on February 10, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe 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. 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. Date: -ir J~ -t"AOU\l ;,.- en c: ?:: ~.~ ~~~ ~;!~ ;'~-';;9 :-F:~ ~~c... .::) o (,1 .>J :::::~) (~} C) 'i Jacqueline M. Verney LAW OFFICE OF . 44 S. HANOVER ST. . CARLISLE, PA 17013 . (717) 243-9190 . FAX (71 7) 2'43-3518 I - ~ .. '~IIirI'~ -......~.". '== ~ ~. . ' lr-,' LYDIA K. HURLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA V. CIVIL ACTION - LAW NO. 2000-775 CIVIL TERM JOHN M. HURLEY, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 ofthe 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. Date: (rJb-'J..fJfJO ,. .. "",": 44:S. HAN\'.'J'./ER .~T .. (AI(lt:,~t.. . . .. ~ " , .J-lil!lllll._ ,,,,,,,,,",, - ilIi~ "-''/'rI1\1ili;;;l\MJ!O LYDIA K. HURLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA v. CIVIL ACTION - LAW JOHN M. HURLEY, Defendant : NO. 2000-775 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 10, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety . (90) days have elapsed from the date offiling 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. 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. Date: (, - 1 - {)() LAW OFFICE OF eline M. Verney :>0- n:; ~~ ~J UJ~;:, ~~ ~~:::~ ~1)j~_:: "T I..' o~~-,,- LUL'" :::-;-;d,,1 w.. ~~~ lL o ~1: ) <::2 . -- 44S.HANDVERST. CA ISLE tA17013. (717)243-9190. FAX (717) 243-3518 I "-- ~ --- . , LYDIA K. HURLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW : NO. 2000-775 CIVIL TERM JOHN M. HURLEY, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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! 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. Date:Ls,' '7-00 efendant - '-~~~!!-:-i >. C) ~ cO' t.r:; <<::(' -~ ~_: L_ LUS::;? 9 :::l<( ,....."',;. 0= G~ ~~~:, ;1:: 0/"" oZ '..L _.L q:;,<: C)~ "p~ ,..~ ;:rJC e'J '7>- .~ LL '7 (/) iJJC_ ..JZ ~~}c_' ~~ CC7 LUtD ~,,,. -~ (0 n.. ,-- -, :;z u. <::) :::l 0 C, (.) ,~ , ~ . . LAW OFFICE OF ( Jatquelhie M. Verney " 44 S. HANOVER ST. . CARLISLE, PA 1701 3 . (717) 243-9190 . FAX (717) 243-3518 ~ LYDIA K. HURLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA : CIVIL ACTION - LAW : NO. 2000 - 775 CIVIL TERM V. JOHN M. HURLEY, Defendant : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a final decree in divorce on the i1ty of j~ ,2000, hereby intends to resume and hereafter use the previous name of Lydia K. Kaiser and gives this written notice avowing her intention in accordance with applicable law. yjul 'ill MA,~ Lydia . Hurle ' T"~r"~ ' l ~ ~)/ Ly la~aiSer ':/fa COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND On the J ~day of ~~ ' 2000, before me, a notary public, personally appeared Lydia K. Kaiser (formerly known as Lydia K. Kaiser), known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. cf:!:~~ NOTARIAL SEAL LISA ANN HIGHLANDS, Notary Public Borough of Carlisle, Cumberland County My Commission Expires Aug. 20, 2001 ~ , iIlII""'-'~~-"i!' ,I I ;j , i ) I j i il j , III~ ~,- f_= .~.."'......" (") c::~ r_ C C') o_J '''''' 7':l V -o~ -, () ~ fTj~";';i ;.:.".:.: :~-! I;t: k- ~~i :\\:: 0~~ \"0 ~\) -..r c:o ~L 0\\ -1J :--;C~ ~ ~ ~ :::=:C" 0 Pc ' ' '" Z -;:'! ~-::~ ::6- :< ~ -;-- ,- 5::! --7 -, .~, ,.,.,...~ 1.-- 11'!'1M!llIl~ ~._"~ -T' ' ","_~~Ml