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Home My WebLink About00-01278 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , ~ ,- - , \ . . . '" '" :Ii -"'''' "''''''' "'''' ~"''''''' '" '" '" '" . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MELANIE T. WHITE, Plaintiff No. 2000 1278 VERSUS CHARLES V. WHITE, Defendant DECREE IN DIVORCE AND NOW, ~7 j ,:3.3,.,+1 . 0001 , IT IS ORDE:RE:D AND DE:CRE:E:D THAT MELANIE T. WHITE , PLAINTIFF, AND CHARLES V. WHITE , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THt=: COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BISEN ENTERISD; Marital Property Settlement Agreement incorporated hereto by reference. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '" "'''' if. '" '" "'''''''''' '" '" Of. '" Of. :f. .. f - - ,- - ;'1" ,- ~- - ,- ~ -' ;:.' '-,' ,1-' - "--, -" -" ~- n',' -. . J. . . . . . . . . . . . . ,., "'''' "'if. ~~IIiIi8iiIMci'_lIiia""'""""-'" ,ll ..L~IIU])~n.m_ -'" ~~~. ~ ~ ~, . ,~._ -" :<",., =.=1."''''''-' ~~ . Lid lIo.id - - ~~\!: '\~~ ,,'; .;.. fp , . :,\:" r: .)'\~: 't . . , . . , . . 'if -; .< ~ ~ - l!:'- . .' " ....;.\ !"'t) 'd"-g>.CJ( M ~ ~ ~ 4 ~ . 11il'O/ 7l~ /U4f:~ ~47f<~y~ i , ._._""'=--,,->>.~ "~'.~' . ., _~,I -- " > 't" , . Plain tiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW CHARLES V. WHITE, : NO. 00-1278 Defendant : IN DIVORCE CIVIL TERM MARITAL SETTLEMENT AGREEMENT ,,~ AGREEMENT, made this 13 day of July, 2001, between Melanie T. White (hereinafter called "Wife") and Charles V. White (hereinafter called "Husband"). WITNESSETH: The parties hereto are Wife and Husband, having been married on October IS, 1994, in Carlisle, Cumberland County, Pennsylvania. There were two children born of this marriage: Kelsey B. N. White, born September 17, 1989 Laurel B. L. White, born September 23, 1995 Diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation: (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, ~ "~, ,~ .,>,"'". -7.J'.,- ,,-, .",-." . , >1..', "1 ,<'.., . .. . .. present and future support and/or maintenance of Wife by Husband and of Husband by Wife; (3) the implementation of custody arrangements for the minor children of the parties for the immediate future; and (4) in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for the institution, prosecution, defense or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds, nor to prevent either party from defending any such action 2 ',?!", , '_w _._ """ '. _"" ,"n, _ '., ",'.,' CH, _ ,', '- . '", which may, has been, or shall be instituted by the other party, or from making any just or proper defense thereto. 2. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Paul Bradford Orr, Esquire, for Wife, and Hubert X. Gilroy, Esquire, for Husband. Each party acknowledges that she or he has received independent legal advice from counsel of her or his selection and that each fully understands the facts and has been fully informed as to her or his legal rights and obligations and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 3. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as she or he may 3 -,'lI'II~ ,- ~ '- . ,- ~~ -- '.' ~, ,. . v ~I_' _ 0__ ',' -, '.., select. Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Wife or Husband of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. 4. PERSONAL PROPERTY Except as otherwise provided herein, the parties acknowledge that they have heretofore divided between them, at the time of their separation, all their personal property to their mutual satisfaction, except as otherwise stated. Henceforth, each of them shall own, have and enjoy independently of any claim or right of the other all items of personal property of every kind, now and hereafter owned, or held by him or her, with full power to dispose of same as fully and effectively in all respects and for all purposes as if he or she were unmarried. 4 -',':f.:II! , - "'-',,', . .,-, - ,I, -r ~ -' ,., , ." '", 5. REAL PROPERTY Husband hereby agrees to convey, transfer and grant to Wife his right, title and interest in the real estate situated and located at 801 North College Street, Carlisle, Cumberland County, Pennsylvania. From the date of this Agreement, Wife agrees to assume as her sole obligation any and all mortgage payments, taxes, claims, damages or other expenses incurred in connection with said premises, and Wife agrees and covenants to hold Husband harmless from any such liability or obligation. 6. SUPPORT Child support has already been established by way of an Order of Court. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, support or maintenance. It shall be from the date of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 7. LIABILITIES Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable, and that except only for the rights arising out of this Agreement, neither 5 0,011 , ,~---,. -,," ,-~ ,.' . '" ':1", ,'-' " - ~ ""', '," party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold the other party harmless from and against all future obligations of every kind incurred by them, including those for necessities. Wife agrees to pay all of the mortgage payments and to indemnify Husband and hold him harmless for any claim by the mortgage company for the real estate located at 801 North College Street. 8. LEGAL FEES Wife hereby agrees to waive any right to alimony pendente lite and each party agrees to be responsible for her or his own legal fees and expenses. 9. NO BAR TO FURTHER PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available. It is agreed that this Agreement shall not be impaired by any divorce decree which may be granted but shall continue in full force and effect notwithstanding the granting of any such decree. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the 6 . ,,,,," . ", -, '_." c' ,,"_~ "" -!,." ,< ~" ,., " ., disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 10. MUTUAL RELEASE Wife and Husband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain I ! i -1 , 1 1 .;[ ij Ii ,~ 'I II lj :1 'I J !'l ,: \1 , ~ 't,\ 11 from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, LI 'i! (-I :'j (b) any State, Commonwealth or territory of the United States, or (c) any other " i ;'1 , -, I 'I I I I j j ii j country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente 7 >--. .~ ~ ,~ -~< "- .'. -. . '-'" . ,,-""---_., ",' " - ,- 12. SUCCESSORS' RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 13. ENTIRE AGREEMENT Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed to be considered a waiver of any other term, condition, clause or provision of this Agreement. 14. BINDING EFFECT OF AGREEMENT This Agreement shall remain in full force and effect unless and until terminated pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement 9 0;'1l, " , ,,~, ,. - o._,~""_ ._ '\ '"0 ~-<__" '_ , _" ,. _ '" " ,. '. ,-. '", shall not be construed as a waiver of any subsequent default of the same or similar nature. 15. SEPARABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law, or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 16. HEADINGS Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, construction or effect. 10 ':'9!'I " "~ ,"_ '-~ ,^ '0 . ,~- ." ,- -- -, ~ , ( .' 17. EFFECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless otherwise indicated. The support provisions of this Agreement shall take effect as indicated. Notwithstanding the foregoing, if a final decree in divorce shall not have been obtained within four (4) months from the date of execution of this Agreement, this Agreement shall be null and void. 18. CONTROLLING LAW This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. 11 "1!!l7' ~-~.. ,_.. ~ ,,-., ,'-'" .. ". _~ r-.. ,-,' " This Agreement is executed in duplicate, and in counterparts, and Wife and Husband, as parties hereto, acknowledge the receipt of a duly executed copy hereof. iJ ~- GL Witness ~ Melanie .. White, Wife pf'~ Charles V. White, Husband COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the R day of --- .j L..~ ,2001, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared Melanie T. White and in due form of law acknowledged the above Agreement to be her act and deed and desired the same to be recorded as such. L~~~ CQf('D((~M-. Notarial Seal Bndgel Ann Corcoran. Notary Public Canisle Bora, Cumberland County My Commission Expires June 10, 2002 12 ',' .-"', .' .' .. .') COUNTY OF CUMBERLAND On this, the \~ day of ) : SS. ) <j~ , 2001, before me, the COMMONWEALTH OF PENNSYLVANIA subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared Charles V. White and in due form of law acknowledged the above Agreement to be his act and deed and desired the same to be recorded as Notarial Seal Bridget Ann Corcoran, Notary Public Carlisle Bora, Cumberland County My Commission Expires June 10, 2002 The undersigned, Paul Bradford Orr, Esquire, and Hubert X. Gilroy, Esquire, have carefully reviewed the contents of this Agreement. We agree that each of us will act as an Escrowee under the terms of this Agreement and that each of us will perform all of the obligations required to be performed as an Escrowee under this Agreement. OJ#- Dated: 7/;9/d/ 13 "" '=..,,, , ,,~ ~ -.= I', !'l ",. "'W' .>. '. , .~ ""T"'!' "." ." ~~ .~, ~~^~ - - ~ ~. .' n c: '-' S ~~ , [I :~"") ~) " -- -, ~~,.j -<. , .Ci '11ili"lilTL '~:'l ~~~,,-- .BI!I~,,,'"~"""l!~~I_ ... , .... , ... Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW Defendant : NO. 00-1278 CIVIL TERM : IN DIVORCE CHARLES V. WHITE, 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 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: March 14,2000 by U.S. Mail, postage prepaid, certified, return receipt requested, restricted delivery. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff, July 20,2001; by Defendant, July 18, 2001. 4. Related claims pending: None 5. Date Plaintiffs Waiver of Notice m S3301(c) Divorce was filed with the Prothonotary:July 3~ 2001. 6. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: J u 1 y 3 i 200 I. Paul Bradford Orr, Esq. 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID No. 71786 Date;f\v j \,2001 By: ",Jr,1 ~, -- '" , , I ~- "< "'-. . ,. , ''"'1''~-"~.'''-"~" " ~" ~. " ,"'.,"^ W._ ,.I !IlI~,-""""~~~~,-,,,. ...,...."~, on ~ '0_ 0", c::- ":;:;;0 ~~-) ---I :.,..) c} -.it~I~~_ ., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW Defendant : NO. 00-/37'/ CIVIL TERM : IN DIVORCE CHARLES V. WHITE, NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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, PAl 70 13 Phone: (717) 249-3166 . .;, ,,_ h"~_"'_ '0'-"_= Date: .'" , . . 8. Plaintiff requests the Court to enter a Decree in Divorce. By: (jJJ 6, Out Paul Bradford Orr Attorneys for Plaintiff 50 E. High Street Carlisle, P A 17013 (717) 258-8558 Supreme Court ID# 71786 3/7 /00 'I . . . . , VERIFICATION I verify that the statements made in the foregoing Petition 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\'ro 4vvtlcw1~ Melanie T. White, laintIff ,n_.c; ! 1- !I I' II I, ~ II II ii II II il II r! II if " ii :~ ,~ i~ I'i 1:1 l~ ill '..1 !; i: ,- ii, i! 11 !:j i~ I;i I:i IJ l~ :~ if' Iii i~ Ii! :1'; I~ i~ i,~ 'it ['I: ~: t: ~i ~;i ,j' ~ 1:~~ . _ Plaintiff : IN THE COURT OF COMMON PLEAS ,OF : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW CHARLES V. WHITE, : NO. 00-1278 CIVIL TERM : IN DIVORCE Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 20th day of March, 2000, I Paul Bradford Orr, Esquire, attorney for Melanie T. White, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of tQe Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested, restriCted delivery. The original return receipt card signed by the Respondent on March 14,2000 indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated: 3/20{eo LAW OFFICES OF PAUL BRADFO By PJ Paul Bradfor 0 ,Esquire Attorney for Plaintiff 50 East High Street Carlisle, PAl 7013 (717) 258-8558 LD. # 71786 . --"d~ ,,,"'I'r _ '... ".", " - ,~ '."" ,~ " -' "". , , ^ . ',~ ~,- r. ~ ~ :1 ,j ~, m " 'Uj m .. ~ m .r: ~ -.., o " ~ "ii E o " -'.,'~- 'iRltf;-_, ' ...",,'.""""'- - '. .~. ---"~;",--.-_- --->------~--- ~NDER: I also wish to receive th"Jl!lIow- ing services (for an extrl:r~e): o Complete items 1 and/or 2 for additional services. -"Gampleteitems 3, 4a, and 4b. ~;~nt your name and address on the reverse of this form 80 that we can return this '-eard to you. [J Attach this form to the front of the mailpiece, or on the back if space does not -permit _ o Write "Rf#um Receipt Requested" on the mailpiece beJowthe_articfe number. .0 The Return R,eceipt will show to whom the article was dellV!'lred'sntl=UJe date delivered. ._,' 3. Article Addressed to: _ 4a. Article Number ~ lJiP CH-MLES WHITE - ,,' L 33'1 D " :L,?-:J-- nl\ . /l 0T1i!EET 4b. Service Type eol rVor<.n-l (,.,oUEG[. '0 Registered 110 1:3 0 Express Mail C A r2.L 'I.~ ~ J m Return Receipt for Merchandise 1. 0 Addressee's Address 2." Restricted Delivery 'I i n , ,1 ~ Certified o Insured DCOD :\ ~~, Receipt , ) 7. Date of Delivery , [; i j; it ,-,1- i! 102595-99-8-0223 Domestic R "'_..,,"'-,.'"~: .'-' , ,I . ',' .t " ;:~l ':i 'I .i I "'I i-:I EXHIBIT "A" -'..,.- '..'., ~I - " .~~ ",. ,- -' , .. " - ~ J1 oj " 'E m Ul li Qi " m. 0:. E ~ 1ii 0: ~! oi: ~ li. -, ", 0" >0' -"i c' !! !-' . / ""'-.' , ',' i!il ...., - !II! ~. ,_ ,. ,~ -~. ,- -,. ,";' i:'~ >. - ,. "~ -,'^ _ We _ ,"~ , .,.. '.-~, "-~.. -.jJUllliill!J ~ . - . .. (') C) ,'--, -o~ 0 ~"'i 1 ~ ~'{:'l '\ ~fB ;tu :;;:0 'p= " ~?; N ::r"p:4 <::> /9 r ,..) . J,-.~c: ' .'0 JIQ ~" -T1 5~=~ :x 05 - i5m ~ .. ?5 ....... -< ~, ~~ ~,' - " "- ~"' ,,,.,..., - '.' .;"'~-,. -'- IWilflm ~ !F":," ~~~~l I "j I , I i I I i .'; j I ~ . j 1 I ~ , '~ c; :;, ~ '11 II , ~i ~! ,: -, '11 I 'Yo: .~-i I J I ;j < .1 , , '1 , .- ... -<< MELANIE T. WHITE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW CHARLES V. WHITE, : NO. 00-1278 Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 7, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. S 4904, relating to unsworn falsification to authorities. Date: 1\;}O \0~ ~a.~ t~~ Melanie . WhIte, Plamtiff , - - , F _~ ~_ ,,~ . 0" III ~. ~ " """" . ,. . <' ,. ~" . "..H. ....-- '1 ,v'n'n-" "" ,0< \ C:) ::'_1 "-c) ,', ,_.,' ~ ~~! ,_~I"""~~.",,.,,",__O .~. ~,,".IlI~_II..I.f I .... --~ Plain tiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW CHARLES V. WHITE, : NO. 00-1278 Defendant : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO ~EQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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 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. !'j4904, relating to unsworn falsification to authorities. Date: ,l ~C)) 6\ ~~ ~Plffintiff ",ilJ!ij . -,,~ "~' .,.. ",' "~, ,. - ,- .""0 c' _ ~,_ ^ ,," .'A,'" ~ ~. " f"?L.,. _c<".~'..;, I", '! -,r ". ~~~ - , _,,,., H,_' , , "\' - . ".,",~o _ ,_^ "'< M_ < , C~. '. . ...co;. , - .--....-. "m" 1:1," c; ~ ~-'.:;.- (.,) i):) :- ~;. I 2 , t ';1 1"1 "",,,,.""llJ'11l11~"~'~ ,,~,~, _ w.~A~"""I~~!Pff'! , " Q '.- t '" Plain tiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW CHARLES V. WHITE, : NO. 00-1278 Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT t' ;'1 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 7, 2000. :, , 2. The marriage of Plaintiff and Defendant is irretrievably broken and " , 1 1 1 , I I I I I l ninety (90) days have elapsed from the date of filing 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 . ! " 11 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 1i j; 18 Pa. C.S. !'j 4904, relating to unsworn falsification to authorities. ~: Date pr ~~ffk0 Charles V. White, Defendant ;! u, 11 'j' 1 ; 1; ~'i , ':: ,! I .i , I I I I ',I U ,I I -:.j 'I j':,!'jjI ~ ~ ,-, . ,~, " . , , , - ~,' " !II ..,,=", '" "'J u" ," _'k ~, "' ."" ... .. _.._.i!!!>!~__'I!"'m "' ~ ".,~, ~~ """",'~ -, ~..;.- ""--.' -'-",:w-'-N"-.~ni1!: -1-, ~'-"_';-'(t~ - o ~ .:: , ;~~,) '-....; IlIlRUlU ~\ JkJ <'..7", :.;;, Ii I I ~ ' 1 II I: , I~ I , II!!I~I,,..," :"-r...4ll~ ~_""mf, .'1 . .. " .. I ... - .r .. j , ! i I I ! ! ~ .j iI i I "I 11 ;-! ii 1 ~ II :1 :'1 Plain tiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE T. WHITE, v. : CIVIL ACTION - LAW CHARLES V. WHITE, : NO. 00-1278 Defendant : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. l,j ~l 2. I understand that! may lose rights concerning alimony, division of property, ;j r1 'I ::: 11 \1 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 1;: the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I'j ," ,'"' I verify that the statements made in this Affidavit are true and correct. I i 'I ~, 11 ! understand that false statements herein are made subject to the penalties of 18 Pa. "'; ,: C.S. !'j4904, relating to unsworn falsification to authorities. , -ti Date: r;zt ~~/;.: Charles V. White, Defendant - J ~ ,~. 't lJl ., "- .~,~o,"o '.0" ...'o,...'-".....h' " . ,- ~ ' ~. O' _~, . '" ,.. _'"'"-"_ ,,~N .. .::::) , I <"_J .w_ ',.. oUIliluL 'h '," _'I" . <,'~ ~ .,-, """""',~^' .,~~-~~'-"'"'~,-."!""~_,~~.,...,~~J!!l!I~~~! " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .. : Melanie T. White ","r; Plaintiff : "" File No. 11001278 : vs. : IN DIVORCE Charles V. White : : Defendant : NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the I 7 day of Au&ust prior surname of this written notice pursuant to the provisions of 54 P.S. S 704. , '19" 2001 , hereby elects to resume the ,Fetter , and gives DATE: September 28, 2001 , being COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERL.~D On the III-A.. day of O~-hb(JC ,~;i.De/, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name as subscribed to the within document and aCknowledged that he/sqe executed the foregoing for the purpose therein contained. SS. seal. In Witness Whereof, I have hereunto set my hand and official ~ t1.~~ Notary 1>ubh.c NOTARIAL SEAL MA)'l{1Aj;lgTA. KIERES, Notary ~~, . Milffi$burg, Dauphin County MY'C(lmmi&$iQo e~plres Dec. 23, 2003 ",.:olP1l!Il .J, ~~ - ... !Ill e ~ ~,,,,.,..,,, ___~_~_ "r",_~ _ 'Ii ~"" ^,"" " "'~'_ w _, ~~ -~,",'",n.n"',,"" ~ "'" ,"..... - ,~ 'ff -'--'1f'j~ 0 C> 0 *l. c: -n /;:J ~ a ~ ."tHL n ~ mn-~ ..... - 8 Z'T" f- zr". -e-7, --...... ~~~ co --~ j C') - ~C) ~,:~:~ C) ~ -0 -,-'r~ r )> :3: ::~}i!J zO "",0 C" C'V~ """'c ~ ~ .. -'-I 0 ?b (j) CT\ -< ~ ,'''~lW!'llfu1till,l] ~,_~ ;11"mII!l!!!!ffl1!l;lli"I!~'W/"~lmWilll$!Jlqrill~~~