HomeMy WebLinkAbout00-01202
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IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
STATE OF
PENNA.
LISA A. RUNDALL,
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No. 2000-1201 CIVIL TERM
Plaintiff
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CIVIL ACTION - LAW
VERSUS
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MARK A. RUNDALL,
IN DIVORCE
Defendant
DECREE IN
DIVORCE
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AND NOW, 2001 , IT IS ORDERED AND
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. DECREED THAT LISA A. RUNDALL PLAINTIFF, .
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AND MARK A. RUNDALL , 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 Marriage Settlement Agreement dated July 23, 2001 and signed by the
parties is hereby incorporated into this Decree, but not merged.
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PROTHONOTARY
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MARRIA GE SETTLEMENT AGREEMENT
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THIS AGREEMENT made this 2.3 ~ day of
,2001, by and between
MARK A. RUNDALL,
LISA A. RUNDALL, (hereinafter referred to as "
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on May 5, 1996, at the
Churchtown Church of God; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties ofthe parties while they continue to live apart from each other.
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2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be [mal and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, armoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
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(I) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: WIFE is represented
by Douglas G. Miller, Esquire of Irwin, McKnight & Hughes; HUSBAND
chooses not to be represented by counsel, and by initialing this page
acknowledges his right to be represented by counsel
(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agre~ment;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualifY as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
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It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marrIage.
7.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay support to WIFE and that WIFE will not provide any financial support to HUSBAND. The
parties also waive any right they have to receive alimony payments from the other following the
entry of the Divorce Decree in this matter.
8.
REAL ESTATE: WIFE agrees to transfer all right, title and interest which she may
have in the real estate situate at 302 Third Street, West Fairview, Cumberland County,
Pennsylvania to HUSBAND and release all claims which she may have regarding said real
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estate. HUSBAND agrees to pay the outstanding mortgage payments and hold WIFE harmless
from any obligations on any mortgage on said property and indemnifY her if any claim is made
against her.
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest which
she may have in any personal property of the HUSBAND. HUSBAND likewise waives any
right, title and interest which he has in the personal property of WIFE. Henceforth, each of the
parties shall own, have and enjoy independently of any claim or right of the other party, all items
of personal property of every kind, nature and description and wherever situated, which are then
owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to
HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all
purposes as ifhe or she were unmarried.
10.
AUTOMOBILES: HUSBAND hereby waives all right, title and interest in any vehicle
that WIFE currently owns or may own in the future. WIFE shall hold HUSBAND harmless for
any and ~llliability associated with the use and purchase of any vehicle she may own, and shall
be solely responsible for all insurance and other fmancial responsibility associated with said
vehicle. WIFE hereby waives all right, title and interest in any vehicle that HUSBAND
currently owns or may own in the future. HUSBAND shall hold WIFE harmless for any and all
liability associated with the use and purchase of any vehicle he may own, and shall be solely
responsible for all insurance and other financial responsibility associated with said vehicle.
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11.
MARITAL DEBTS: HUSBAND shall assume all liability for and pay for and
indemnify and hold harmless WIFE against the following credit cards and/or loans:
1. Ford Motor Credit Corporation (Acct. #JJN480H.. .);
2. Capital One Bank (Acct. #4121741484382...); and
3. Capital One Bank (Acct. #5291071474880...).
Furthermore, HUSBAND hereby agrees to assume all liability for and pay for and
indemnifY and hold harmless WIFE from all other debt, whether individual or joint, incurred by
HUSBAND, and further remove WIFE'S name from any and all joint accounts within sixty (60)
days of the execution ofthis Agreement.
It is mutually agreed by and between the parties that WIFE shall assume al1liability for
and pay and indemnifY the HUSBAND against all debts incurred by WIFE after the date of
separation. WIFE represents and warrants to HUSBAND that since the parties' marital
separation she has not contracted or incurred any debt or liability for which HUSBAND or his
estate might be responsible and WIFE further represents and warrants to HUSBAND that she
will not contract or incur any debt or liability after the execution of this Agreement, for which
HUSBAND or his estate might be responsible. WIFE shall indemnifY and hold HUSBAND
harmless from any and all claims or demands made against him by reason of debts or obligations
incurred by her.
HUSBAND shall assume all liability for and pay and indemnifY WIFE against all debts
incurred by HUSBAND after the date of separation. HUSBAND represents and warrants to
WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and warrants to WIFE that he will not contract or incur any debt or liability after the execution
of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall
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indemnifY and hold WIFE harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him.
The parties also specifically agree that the payments called for in this Agreement are not
intended to be a debt which is affected by a discharge in bankruptcy. They further specifically
intend that HUSBAND'S obligations under the terms of this Agreement shall not be subject to
discharge in bankruptcy because they acknowledge that such are necessary for WIFE to meet her
fmancial obligations and to support and maintain her standard of living. HUSBAND represents
that there are no bankruptcy proceedings presently pending in which he is involved. HUSBAND
expressly agrees not to file a bankruptcy action prior to the completion of his obligations
pursuant to this Agreement. This debt shall not be discharged in a bankruptcy action filed by or
on behalf of HUSBAND. If HUSBAND files for bankruptcy, this Agreement shall constitute
conclusive evidence of the parties' intent that the obligations of this paragraph are in the nature
of maintenance and are not dischargeable under current bankruptcy law or under any amendment
thereto. Further, if HUSBAND institutes any action in bankruptcy or any other bankruptcy
proceeding is instituted in which WIFE'S right to any monthly payments becomes a matter for
judicial review, HUSBAND agrees to consent to any motion filed by WIFE with the bankruptcy
courts, wherein she may request that the bankruptcy courts abstain from deciding the
dischargeability of this obligation and any other obligations to her hereunder in order to allow the
appropriate Court of Common Pleas to rule upon this issue.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own,
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WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND
waives all right, title, and claim to any of WIFE'S employee benefits.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
MEDICAL DECISIONS FOR MINOR CHILD: In the event that WIFE shall be
declared incapacitated by any court of competent jurisdiction by virtue of a medical or life
threatening emergency, HUSBAND shall be the responsible party to make medical decisions for
the parties' minor child, Benjamin T. Rundall, born October 5, 1994. The parties will keep each
other advised immediately relative to any emergencies concerning their minor child and shall
take any necessary steps to ensure that the health and well being of the child is protected.
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16.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
17.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any aJ).d all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
18.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it is not the result of any duress or undue influence. It is the
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
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fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
19.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
20.
APPLICABLE LAW: This Agreement shall be construed under the:Laws of the
Commonwealth of Pennsylvania.
21.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
22.
PAYMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
23.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
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relinquishes 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, at 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.
[THE REMAINDER OF THISP AGE HAS BEEN INTENTIONALLY LEFT BLANK]
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IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
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~I A A. RUNDALL .
(SEAL)
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, thisJ. tltCday of !2t<.r.Jk1~ ,2001, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, LISA
A. RUNDALL, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
zriJlvfM
Notarial Seal
Martha L. Noel, Notary Public
Carlisle BOlO, Cumberland County
My Commission Expires Sept. 18, 2003
Member, Pennsylvania Assoclauon 01 Notafles
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COMMONWEALTH OF PENNSYLVANIA
ss:
COUNTY OF CUMBERLAND
3JtL
PERSONALLY APPEARED BEFORE ME, this L day of 5Ul-'{
,2001, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
MARK A. RUNDALL, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
NOTARIAL SeAL
MAlTHEW J. RUTKOWSKI. Notary Pub
Lemoyne, Cumberland County
My Commission Expires May 13, 2002
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LISA A. RUNDALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000.1201 CIVIL TERM
MARK A. RUNDALL,
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:
I. Ground for Divorce: irretrievable breakdown under Section 330 I (c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Mark A. Rundall, on March 6, 200 I, and is evideuced by the Acceptance of Service signed by him
and filed with the Prothouotary.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by plaintiff: Augnst2,2001; by defendant: July27,2001.
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) 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: Augnst 7, 2001.
Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: Augnst 7, 2001.
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UG S G. MILL ESQUIRE
Attorney or Plaintiff
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LISA A. RUNDALL, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff, :
vs. CIVIL ACTION - LAW
MARK A. RUNDALL, NO. 00 - 1;).01 C-w~L Ytfi-Yn"
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 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 9ther 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 grounds of the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counselling. A list of marriage counsellors is available in the
Office of the Prothonotary, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LP5NYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE TBE 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 Lawyer Referral Service
1 Courthouse Square
Carlisle, PA 17013
Telephone No.: 717-240-6200
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COMPLAINT
NOW COMES the Plaintiff by her attorney, Robert E. Myers, and
brings the following Complaint:
COUNT I - DIVORCE
1. Plaintiff is an adult individual who resides at 8 Dulles
Drive, Apt. l2H, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant is an adult individual who resides at 302 Third
Street, West Fairview, Cumberland County, Pennsylvania 17025.
3. Plaintiff and Defendant have been bona fide residents in
the Commonwealth of Pennsylvania for at least six (6) months
iwnediately previously to the filing of this Complaint.
4. The parties were lawfully married on or about May 5,
1996, at the Churchtown Church of God, by Pastor Kenneth Wodmer.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff avers that the grounds and Sections of Domestic
Relations Code upon which this action is based are as follows:
A. The marriage is irretrievably broken.
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B. At the appropriate time Plaintiff will submit an
Affidavit alleging that the parties have lived separate and apart
for at least two years and that the marriage is irretrievably
broken.
7. Plaintiff has been advised of the availability of
counselling and has further been advised that Defendant may have
the right to request that the Court require the parties to
participate in counselling.
8. This action is not collusive.
9. Plaintiff requests the Court to enter a decree in divorce.
10. Neither Plaintiff nor Defendant is in the military
service of the United States within the provisions of the Soldiers'
and Sailor's civil Relief Act of the Congree of 1940 and its
Amendments.
WHEREFORE, the Plaintiff prays your Honorable Court to enter
a Decree of Divorce, divorcing the Plaintiff from the bonds of
matrimony heretofore contracted between the Plaintiff and the
Defendant.
RESPECTFULLY SUBMITTED this 2nd
March, 2000.
RS, ESQUIRE
Attorney fo Plaintiff
Attorney I.D. No.: 09729
100 Old York Road
New Cumberland, PA 17070
(717) 774-3163
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COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF YORK )
I, LISA A. RUNDALL, Plaintiff in the foregoing action, being
duly sworn according to law, depose and say: That I certify 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
.uthorities~, ~~
LISA A. RUNDALL
Subscribed and sworn tp before me, the undersigned Notary Public,
this /).7Jv[, day of ~-e--'A. J J ,. d ' 2000.
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NOTARY PUBLIC
My Commission Expires:
NOTAFlIAL SEAL
MARY D. VER HAGE, Notary Publloo
Falrvtew Twp.. York Coonl}'
Mv Commission Exp;ro. Mav 7. 2OCl2
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LISA A. RUNDALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 2, 2000.
2. The marriage of plaintifLand defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses in do not claim them before a divorce is granted.
I verifY that the statements made in this affidavit 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.
Date: (\11~ l..l~ \-;;z.. ,2001
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LISA A. RUNDALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 2, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verifY that the statements made in this affidavit 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.
Date:
7-}7
~A
,2001
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 in 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: \\u.'3u.~-t ~
,2001
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Y LISA A. RUNDALL
Plaintiff
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LISA A. RUNDALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
7 ..-~1
,2001
MARKA.
Defendant
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LISA A. RUNDALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being du1y sworn according to law, deposes and says:
1. 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.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. 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.
I verifY that the statements made in this affidavit 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.
Date: -~'3u. s \- ~
,2001
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Y LISA A. RUNDALL
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. 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.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. 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.
I verifY that the statements made in this affidavit 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.
Date:
1--- ~7 -0 '-,2001
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LISA A. RUNDALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2000-1201 CIVIL TERM
MARK A. RUNDALL,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Mark A. Rundall, the defendant in the above-captioned divorce action, hereby verifY
that I accepted service of the Complaint in Divorce filed under Section 3301 (c) of the Divorce
Code on March 2, 2000.
MARK A. R
Date: July 27. 2001
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.SA SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: August 7, 2001
DOCKET NUMBER: 2000-1201 Civil Term
PLAINTIFF~SS# 177-54-7968
NAME: Lisa A. Rundall
DEFENDANT~ SS # 192-50-1424
NAME: Mark A. Rundall
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