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HomeMy WebLinkAbout00-01575 ~:...:~.~ >::C( '::~>>::( ):C~'~::~>>::(':'.~}<}::.:}~:):C{:~~";:)::"'~~:'::.::.::';:: ::!::c.;:- ',.::+}(":.::+::<:':.>>::o:.: ':.::c~:::'!::.::.~:>::c;<;:!::.::!:-;.:!~::-::{c.;:xecxc!;;:,;:!::.>:~,!::.::{'-,!::C<:~!>>),:::".::~X.::~~t:,1 ~ ~ ~ " ~ ~ " . ~.~ ~ ;..~ * ~ ~.; ~ I ".~ ~.~ ~ N ~ N ~ ~ ~.; ~ ';0; ~ ~ S ~.~ ~ ~~t ~ ~.~ ,~.,. i-' -, " ~ -"" ,." ;_,' '"' ~>>'" <<. _, :1,. IN THE COURT OF COMMON PLEAS ~.~ ~ ~. ~~' If ~. I~, If !ii' W , ~: ~i: .1,1 ~.~ I OF ~.~ ~ CUMBERLAND COUNTY STATE OF ~ ~.~ ~ PENNA. ~ ~.lI! ~ ~.~ ~.~ ~ DARYL WOLFE ~.~ I No. 2000-1575 Civil Versus ~.; ~ ~ I ~.~ ~:; W,' ~" I' "i, , " LINDA WOLFE ,,~,<, W !0?- j ~.lI! t; ".,' ~ '.' ~.;; ~ ~.; ~) ~ l" ";~" ~ ~.~ DECREE IN D I V 0 R C E~/(: 31C..A. AND NOW, ..........~~..F.....~..... it is ordered and decreed that ......,............ p~~ .~~~(~ . . . . .. .. .. .. .. . . . " plaintiff, and.....................,.... . Liooo.WoHe. .................., defendant, are divorced from the bonds of matrimony. .;.~ W ~!~ ~ i ! N ~ t'. ~.~ ~ ~.~ ~ ".$ W ~.~ ,; f..~ I ~ t.~ ~ ;,.; I $'" ~.'~ ~ ~ ~ ~., ~ ~.~ ~ ~ ~.~ ~.; ~ ~.~ ~ ;.'" ;..; ~ ,.. ~.~ ~ "'.'~ ~.~ 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; ~ ".s ~ ~ ~.~ ~ ~.~ . ~~. <;\~~<;\~~<;l. ~~'?~~Y. ~!=!=~~!l!=. ?\SP.'~n!=. ?~!=!"? ;J')J!1!". .2;1.,. .2999.,. .s!1~;1.1. P!"., incorporated into this Divorce Decree. . . . . . . . .. .. ..... - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ ~.~ ~ ~.! ~ ~.~ f..~ ~ Attest: J. ,'. ~ ~ ~.~ ;..~ . ~'I',; ~ t.,;, I1l ~ I ~~~~~~~~~~~~~~~~.~~~.'~ rd ~.~ ~-~ ~ ~ ;:-::.::0::: :::-::.::";:::.::+;.': ::-::.::.':: :::-::+::<>3:,: ,"::.:< ':.::+::.,:: ':-::+:< :"-::+;0:: Prothonotary I l!ij,_ " ~~ ,,~ 7-5.eo ') "s-.co ,~, - . MC'~~ //4~ )1~ ~ IZ ~. , ,.....~" ,,""",' J':,~- /" ,~7__",~_~'~1!lI'il!i~~_...., _"'......,~_MImiI!l~q~~tlW: ~'^' . PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~ day of ~ , 2000, by and between DARYL L. WOLFE residing at 422 North Enola Drive, Apt. H, Enola, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND," and LINDA WOLFE, residing at 46 West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE." WI TNES SETH: WHEREAS, the parties were lawfully married on September 7, 1991, in Mechanicsburg, Pennsylvania; and WHEREAS, in consequence of disputes and unhappy difficulties, the parties have agreed to live separate and apart during their natural lives; and WHEREAS, the parties are desirous of settling their existing property rights including an amicable equitable distribution, assignment and division of their property, which property is considered to be "marital property" as defined in the Divorce Code known as Act 26 of 1980, and amendments thereto enacted into law on February 12, 1988; and NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained and for other good and valuable consideration, the parties, intending to be legally bound, agree as follows: 1. SeDaratiDn. The parties shall hereinafter live separate and apart. Each shall be free from authority, and control, direct and indirect, by the other as if he or she were single and interference, unmarried. 2. Control of Agreement. The provisions of this Property Settlement Agreement shall govern all past, present, and/or future claims for alimony, support, counsel fees and costs, alimony pendente lite, equitable distribution, or other property rights, and all other claims which the WIFE or HUSBAND has or might have against the other except as set forth hereinafter. ~,I I.. 11;"(;. ,. 3. Divorce. A Complaint in Divorce was filed by HUSBAND in Cumberland County, Pennsylvania on or about March 16,2000, which action is docketed to No, 2000-1575. Simultaneously with the execution of this Agreement, the parties shall sign any and all documents necessary to obtain a Divorce Decree under !i3301'(c) of the Divorce Code, including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of Notice of Intent to Seek Divorce under !i 3301(c) of the Divorce Code, and cooperate with the prompt filing of the same. The parties intend that this Agreement shall be incorporated but shall not merge into any forthcoming Decree in Divorce. 4. Real Prooertv. The parties acknowledge that there is no real property in existence that can be considered marital property subject to equitable distribution. 5. Personal Property. The parties have acquired certain personal property during the course of their marriage, all of which has been divided to the parties mutual satisfaction. It is agreed that each party shall retain all items of tangible personal property currently in their possession as if it were their sole and separate property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party which are now in the possession or under the control of the other. Furthermore, each party agrees to waive any right, title, and/or interest they may have to the property in the possession of the other, and not specifically referenced above. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph. 6. Automobiles. The parties agree that they shall each retain the vehicles they are currently driving and/or that are in their possession as their sole and separate property. More specifically, WIFE shall retain the jointly titled Van, subject to the encumbrance with Pennsylvania National Bank, as her sole and separate property and she shall assume full responsibility for the balance owed to the above-referenced creditor. WIFE agrees to indemnify HUSBAND and hold him harmless with respect to any non-payment or non-performance of any obligation in connection with the Van and/or the debt to Pennsylvania National Bank and/or its successors. As soon as possible, WIFE agrees to refinance this vehicle into her individual name. Until that occurs, WIFE agrees that HUSBAND shall be absolved of any and liability in connection therewith. HUSBAND'S automobile is held in his name individually and is free and clear of any lien or encumbrance, which automobile shall become his sole and separate property, free and clear of any right, title, claim or interest of WIFE. I: L_,~. , Each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and cooperate with the signing of any and all documents necessary to transfer title to the appropriate party and/or effectuate the provisions of this paragraph. 7. Employee. Pension and Retirement Benefits. Each party shall retain as his or her sole and separate property, any individual retirement account, and/or retirement benefit plan (including but not limited to pension or profit sharing plans, deferred compensation plans, defined benefit plans, 401 (k) plans, employee savings and thrift plans, IRA's, or other similar benefits), whether vested or non-vested. Furthermore, each party shall specifically and forever waive any right, claim, interest, and/or title they may have in the retirement plan of the other. The above shall specifically include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. The parties understand that they have the right to request formal discovery, however agree that they are satisfied with all financial disclosures that have been made, and specifically waive their right to request additional documentation regarding the above referenced retirement plans. HUSBAND shall assume full responsibility for repayment of the loan against his Excel 401 (k) Plan which approximates Sixteen Thousand ($16,000.00) Dollars. Furthermore, each party shall be and remain the sole owner of any other asset in his or her control not specifically covered by other provisions of this Agreement. Should it become necessary, each party agrees to sign any other title or documents necessary to give effect to this section upon request of the other party. 8. Credit Card Debt. There are several jointly titled credit cards in existence. The following represents the parties agreement with respect to satisfying those debts in full: DEBT Sears Credit Card Equality One Account (windows) Goods Furniture Account PA National Bank (van) A VCO Finance Account Fulton Bank Account Shaw's Account (carpeting) RESPONSIBLE PARTY HUSBAND HUSBAND WIFE WIFE WIFE WIFE WIFE I liit"<!~;~' T The "Responsible Party" agrees to be solely responsible for timely repayment in full of the above referenced obligations, specifically including but not limited to any and all late fees, interest charges, and/or penalties of any kind, and agrees to indemnify and hold the other harmless with respect any non-payment on the above referenced debts. If any of the debts referenced above are jointly held, the parties agree that the Responsible Party shall transfer that debt into his or her name individually as soon as possible, and until that transfer is done, shall assume sole responsibility for repayment in full of the debt. 9. Spousal SUDDort / Alimony Pendente Lite / Alimony. Except as inconsistent herewith, each party specifically waives any past, present or future claim for spousal support, alimony pendente lite and/or alimony against the other party. 10. Bank Accounts. Any and all joint bank accounts in the parties' names which existed at separation have been previously divided to both parties' mutual satisfaction. Furthermore, each party agrees to waive any right, title or interest he or she may have in the individual bank account of the other. 11. Miscellaneous Debt. Any debt not specifically listed in this Agreement and incurred after the date of separation (February 1, 1999) shall be the sole and separate responsibility of the party who incurred it. Likewise, any assets acquired and not specifically referenced in this Agreement after the date of separation shall be the sole and separate property of the party who acquired it, unless marital assets were used to acquire it, and such assets have not been disclosed. 12. Agreement Executed Voluntarily and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: A. If fully and completely informed as to the facts relating to the subject matter of this Agreement, and as to the rights and liabilities of both parties; B. Enters into this Agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind; C. Has given careful and mature thought to the making of this Agreement; D. Has carefully read each provision of this Agreement; ~ ~ ,~~". ,~ i, I ~_.c , E. Acknowledges that there has been a full and fair financial disclosure by both parties, and fully and completely understands each provision of this Agreement. 13. Release of All Claims. Each party releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be Incurred. Moreover, neither party is relieved or discharged from any obligation under this Agreement or any Instrument or document executed pursuant to this Agreement. 14. Holding Other Party Free and Harmless. HUSBAND hereby warrants to WIFE that he has not incurred and he hereby agrees that he will not hereafter Incur any liability or obligation on which she Is or may be liable. If any claim or action is brought attempting to hold WIFE liable for any such liability or obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or not founded, and he shall hold her free and harmless therefrom. WIFE hereby warrants to HUSBAND that she has not incurred and she hereby agrees that she will not hereafter Incur any liability or obligation on which he is or may be liable. If any claim or action Is brought attempting to hold HUSBAND liable for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether or not founded, and she shall hold him free and harmless therefrom. [' J " 15. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any document, 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 Incurred as a result of such failure. 16. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each is satisfied with the financial disclosures made from the other. The parties acknowledge that although within their right to request, no formal discovery was done in this case, and that they are satisfied with and cognizant of the wealth, Income, real and/or personal property, whether jointly or '" Indlvidually'titled, estate and assets of the other, and an{furtfierenumerafion OY statEmlent thereof In this Agreement Is hereby specifically waived. The parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and agrees for himself or herself that his or her heirs, personal representatives and assigns, that he or she will never at any time hereafter sue the other or his or her heirs, personal representatives or assigns, in any action or contention, direct or .....--~...,~=-~~I -J.,..,ioili<:;""*-,II , indirect, that there was any absence or lack of full and proper disclosure. The parties specifically acknowledge that they have been advised by their individual counsel of their right to seek such discovery, however have elected to waive the same. Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto, and understand that this Agreement shall not be subject to modification by the Court. 17. Representation of the Parlies. HUSBAND is represented by Johnson, Duffie, Stewart & Weidner, in connection with the negotiation and preparation of this Agreement. WIFE has been given the opportunity to consult with independent legal counsel of her choice. WIFE understands that Johnson, Duffie, Stewart & Weidner has represented HUSBAND only throughout this matter, and that Johnson, Duffie, Stewart & Weidner cannot and did not render any legal advice on WIFE'S behalf. Each party has carefully read this Agreement and is completely aware not only of its contents but also of its legal effect. Each party acknowledges and accepts that this Agreement, in the circumstances, is fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal Agreement and/or Agreements. 18. Waiver of Rights to Other Parly's Estate. Except as provided for herein, HUSBAND and WIFE each waive any and all right: A. To inherit any part of the estate of the other at his or her death, except as provided herein; B . To receive property from the estate of the other by bequest or devise except under a Will or Codicil dated subsequently to the effective date of this Agreement; C. To act as personal representative of the estate of the other on intestacy unless nominated by another party legally entitled to so act; D.UToaCt as thepersonarrepresentative under the Will of the other unless so nominated " by a Will or Codicil dated subsequently to the effective date of this Agreement; E. To claim a family allowance in the estate of the other. -~"""'-'I _" I L ~, " ij ,; r 19. Containment of Entire Agreement Herein. This Agreement supersedes any and all other Agreements, either oral or in writing, between the parties relating to the rights and liabilities arising out of their marriage. This Agreement contains the entire agreement of the parties. 20. Partial Invalidity. If any portion of this Agreement is held by a Court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue in full force and effect without being impaired or invalidated in any way. :-J ,j j~ 21. Effect of Reconciliation. Cohabitation or Divorce Decree. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to the parties. This Agreement shall survive any such final judgment or Decree of Divorce. Both parties shall have all rights and enforcement under applicable law including the Pennsylvania Divorce Code. This Agreement shall also remain in full force and effect even if the parties effect a reconciliation, cohabitate as Husband and Wife, or attempt to effect a reconciliation. ii [' l: ~ I Ij ~j [-j , , " , , , 22. Modification. This Agreement shall not be subject to modification except as in accordance with Pennsylvania law and with a writing between both parties evidencing their intent to modify the Agreement. ~( " 23. No Waiver of Default. This Agreement shall remain in full force and effect unless and until terminated under and 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 shall not be construed as a waiver of any subsequent default of the same or similar nature. 24. Attornevs Fees and Exoenses. Each party shall be responsible for their own attorneys fees and expenses. 25. Mutual Cooperation. Each of the parties shall, on demand, execute and deliver to the other, any deeds, bills of sale, quit claims, assignments, consents, tax returns, and other documents and do or "cause t65edoneanY 6ttlerac;ls or ttlingsas maybe necessary ordesirabletoUeffeCluale-U'i6 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 incurred as a result of such failure. "" ~.- . 1._ I I ! 26. Bankruptcy. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay under the provisions of this Agreement, each has the ability to fulfill his or her respective obligations from income or property not reasonably necessary to be expended for such party's maintenance and support or for the maintenance and support of such party's dependents. Should either party file a Petition under Title XI of the United States Code, or should a petition be filed against either involuntarily, each party acknowledges and agrees that the discharge of the debtor party's obligations under this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to the non-debtor party. I': I I I ~: i.' 27. Law of Pennsylvania Applicable. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 28. Date of Agreement. The effective date of this Agreement shall be the date on which the last party executes the Agreement if the parties do not execute the Agreement on the same date. Otherwise, the effective date will be the date that both parties execute the Agreement if they execute on the same date. 29. Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding on and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors and interest of the parties. IN WITNESS WHEREOF, the parties hereby have hereunto set their hands and seals the date and year first above written. WITNESS: OCo-.;;lI-OO Date D 9" Jr$ DARVt1. WOLFE ~ja w!!#= LI WOLFE 10-/1/- ro Date : 135056 iij;~1IliIiim~~b~lliMtlilli:'>U;!lI&jl;lii;ill,.!!gk'~lili:.~&~,):j""',"";~1,,,,",-' ",e"";""'''''(i';;'''''M'f'''''$~Ji.~liWIldl.~'' ~,.<<,,,,,,.~~,,",,,~~~-,.... . - ~. >-Ifnl~~' ~ ~, () c::' C) C C\ -n :z:- ~ '--j -r:.~G:.' S2~L -".:- "i;g , ~;~~ i"\.,J: ~ '1"'1 \.c,; --'''-C'3 -~(2 r:O --U ~ :x ;~)f~ ZO )>0 r...:; lSrn C =< U1 'i;! :D -< r..:> -< , ,- ~~-- > , .~ --~- ,-^ ,- . --< . '''-'"j Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- /S'''IS CIVIL TERM I; I; [i I; Ii [; i 1; I; I i j; Plaintiff v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS i I I , I I I I r Ii 'J I il I' I': 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 pages 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 , ~ -'-',' --" ,,-."-,,-,-,' ,,-~~ ,u- <'" _'~.l '---~ ~-,,, ,j-,~ Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2000- /5'l~ CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(cl OR 3301(dl OF THE DIVORCE CODE AND NOW; comes the Plaintiff, Daryl Wolfe, by and through his attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Linda Wolfe: 1. The Plaintiff is Daryl Wolfe, an adult individual, residing at 422 N. Enola Drive, Apartment H, Enola, Cumberland County, Pennsylvania. 2. The Defendant is Linda Wolfe, an adult individual, who is currently residing at 46 W. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania, 3. The Plaintiff and Defendant were married on September 7, 1991, in Mechanicsburg, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. . ~ '.' ~-" ,~,-"~ i ",./__ ... _,-" ,'"j, C,,'.+~' "~--"mj-.." __,,_,~' '._._"" ',1 :~ 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301 (c) of the Divorce Code. JOHNSON, DUFFIE, STEWART & WEIDNER By: Keirsten W. Davidson :130391 VERIRCA TlON I verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A 114904, relating to unsworn falsification to authorities. Date: 03_02._0':> )~ry~w~e~ , . Johnson, Dnffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000- CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant AFFIDA vir DARYL WOLFE, being duly swom 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 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. 94904, relating to unswom falsification to authorities. Date: cD-a? -00 )airyl~!d~ 0\,.=.. "i:',._ .""--";,~, I' ,,'" "'f_~,' ,. >.~ ,,_~,.._"", -<,-"~",, , . "~rY>:' ~~,,- - -~-'--: .,~' <"^'~-"' ,^-" '~<~~~.,"- --'-'~","",--"". ,- , _J. )~f.,:! ;:;~ ~ 9~ ~ ~ lr' L fr~ JT ,,' '0 o c: "2" -nOS fT1fn Z:D t1~ \:; ~";L. ~Cl '):->:-r, ;:';0 :Pc ~ , "'" " C> C> . . o -n ~ :J.~ ::xJ .--1 T..." rnr:: -nfTl -h(:) 9b -.- -r, ~,- -n C)O Zrn o -'-' ~ '< - CT' -0 :::;: :.f! o ...1 ..' '.' B Ij ~-~ , Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-1575 CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant CERTIFICA TE OF SERVICE I hereby certify that on the 20.h day of March, 2000, I served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant, Linda Wolfe, by certified mail, restricted delivery, to her mailing address at 46 W. Locust Street, Mechanicsburg, PA 17055, return receipt requested, attached hereto and made a part hereof. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By:~t~51L Keirsten W. Davidson :130391-6 , : : ~ ;' : ...--" t Z 200 146 473 01 Pas \ Postage $ Certified Fee Special Delivery Fee Restricted Delivery Fee III 0] Return Receipt Showin ..... Whom & Data Deli .~ RebJm ReceiptShowi <( Dale, & Addressee's Q Cl CO .., IE If '" ll. il:~ ;~:, ' PI'iji~-:tieri)~ 1-and/or.2 fpr additional services. 41, "-PIE!tei;~e,:rn{:'t 4a;,anQ 4b. r! c, __ 'YOl.lr_name-:a:rid addresS: on the reverse of this form 60 that we can return this ~: 'I;~ -. [].~~~ri~fsUj~rn,;o thE; frQ'Ot of the mailpiece; or on the back if_ space dOelJ"riot ~ D W:\~etUrii ~pt Requested" on the mailpiece b~iq_w-tfu~,article nUmber. C [] The Return Rece!pt will show to whom the article was del~vered and the date W' delivered. .- ~ 3. Article Addre~~ed to: . ~ LOdd- Wd / Ie ~ 1~ w.u 01S,[ St" i ((ed>> i tSJiL/UJl ~A if tJ I i= 5. Received By: (Print.Name) w 1. 0 -Addressee's Address 2.,lfRestricted Delivery 4a'Aze;roo /1fJ 173 4b. Service Type o Registered o Express Mail /7() 55 0 Betum Receipt::~9:r'~ '-Y':: Date Of DeliverY - B. Addressee's Addr fee ;s paid) ,:, liP '1' 102595-99-S,om _~o'''__~ "....._~.,_...:';;, __ ______L___~_~____________ ... .. ,"" "> \. i, 15. oil 'm 0: c' 3. 1ii 0:' m! .E I ~! ~ 0' -, gi ,., ... ' C' .., .c . .... ~~~IIlIil~~~""""'iJiaI'WI""'-""~""~ ~w ~ ,,,""":'-:'~'~\' - -,<,,;),"'-;-s,-;k,"," -",,- ~. I 8 :s:: -0 ~]) mfT' 2f~; ~~~ 0, r- r 2:'~-j ~b >c ~ , ~~ c:::> c:::> ~ :1t :~ :'0 '1 Co ,-~ ~:!J r- .-,',fT; -:~jO :'~(l.J -\:;;~~ ",),0 '::;-.. ):;; ::D -< ~ (J"; -' I, , ' ,",. ~ "-~ -'. ~'" ~ '~,"", ""~, --" .'~'" ,"_<, "_";,"'0'",,,, ,~- -<"",~,=,:"',.._~~>;,"-'~ '-,",,,",b;-." "',_r . 'P~'V<_" ,k'.:.}i.>""":;>;(: Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pemlsy1vania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 -1575 CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on March 16,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~904 relating to unswom falsification to authorities. Date: 0" -c)./ -0 cJ ~L~ :135509 i......iIIlIli.l~lit.Qi '-'''~''. ""~~- - .~~ ~-,I!Il.- .<~~, "~=--.~.,~- .~ ~ " , - ,L. .",' n , "~-'- ~ ~. - " a (::::J c) C <:::) 'n :5: ~ -o-co c: mo'") ;z=: :':~~~~ Z::v ze- N (/)i"> \D .,J........' -<5?: ,.---.. 1 ~c: " ~:~S;: ~o ::Jl: --.,:;---n L_,};:::::': -0 N '---'-'-'..)- >c om ~ :n );! ::0 -< " , II ._,_" . ~'-. '-"-'.-"~" o' ~'"""__ ,,~~~.,-_ _~.__=_ . ,'",- o~",..,._ \''';'-'-''';-..;.'--'o<i,,~;-''h.'i;.--- <,"'0""_"'_ _"""'';'',l, .,.;"", ~...b,,~:~~!L,-"-'~,.;?;-o..-..;:_' ., " ~I,~ _.,. '<-.:;;"--1:' ' Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pemlsy1vania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 -1575 CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: O(rdl ~OO '> n ';/. J4. ~I W~lfe, P~ntiff :135509-2 iilib:ild"-.........~Iil'....... r,ff~ ~~""&,,,.,",~~.~,, ""~ .~" _v,~ -"".. o''''''''',;;.~..lilitllliillilMn ''- ,- -- - " ~~~ .'" '-~'" ,-" :liliIIIIilIi.-~""""~""'-'>">.'-.-.' --'. - ~, -. ,-, ~" " ,- " ' "~" ,,-, ~~ i (') <;-::> () C 0 ~ ~TJ -OeD c r;)2m '.-..... :LJ :z I'i1i~ ~~ N ~':;d \.D ...<:.. ~.-:~o KG ""t) ''''--T, ~(") ::il: g~ )>0 r;? c ~ '"-l Ul ~ -< --^ II , >c...'"",---," ...,"' -,-.- '-;s" ,~-; - ., ---L~ '-.'. _o-"-~. "---~"> ',j" - ,'>i"""h Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 -1575 CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant AFFIDA VlT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on March 16,2000. , 2. , The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. i verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: {;-;;;.-{ --(.90' :135509-3 i~.lliliIij.ililthIiUiIiUll~~~!diII'~'""~-~"~-~ , ~-.~, ~" ~ ... _, h" () c ~ "Ufi! !pm,,' ""-:0 z:c Cr.> ',." c<<"' r-:~':'" :;:::0 :2;0 ;$:0 ~ ,~. '" --'" o a () '" ;~-= .;;n: f'\j \D '"'0 :Jl: r:-p :.n " ,--.: '-,-JfT1 .~)O ~* -~o Om :;;! :u -< - I, ., '";, . "'- ,,,~ ,'- -'. . . L. -.',' ,;, , "'~ _oj -';--'_1"'" Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff DARYL WOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 -1575 CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice, 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. , verify that the statements made in this Waiver 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. ~af'-' ~~ . nda Wolfe, Defend t Date: (.; cU -o-v :135509-4 !lllli~"""~lHillr ~~.<lii/illiII ~ ..~~ w. ~'. . ~~IL ~~ .II...... '-' 0 0 a c c:> -n 5:: !- ""'OOJ C (ll:~ rtlfTl - Z:o - Zlj;' N :09 <.0 ~z j~() kO -0 ~~ ~o :x --0 ~ Zrll >c 9 ~ U1 ?G -< Ii .--~, "<, "":''''- - = - .' .~",,"","'~,V~""""-""''''~-_''b_,'_O>~''~'''iM'.l'''''~.'"~____~'''''''''' -'. '.',,"_0.. Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 . '""""1 Attorneys for Plaintiff DARYL WOLFE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000 -1575 CIVIL TERM v. CIVIL ACTION - LAW LINDA WOLFE, IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: certified copy, restricted delivery to Defendant, on March 20, 2000, and received by the Defendant on March 22, 2000. 3. Date of execution of the Affidavits of Consent required by Section 3301 (c) of the Divorce Code: By the Defendant, June 21, 2000; By the Plaintiff, June 21, 2000. 4, Related claims pending: None. See attached Property Settlement Agreement. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER BY:~ (J, O~ Keirsten W. Davidson :135953 -.'';' 0" , ~ iI1iiMlliiiMillllilillll.iiiIIlI.l.='-~ .., - ,~ ~,.,. ~- ~~~ . , " - ; -~, . ~-- "'"'- ',,, -~,,- ,n, _ _~"_. ,', " o c: ~S:; urn (fI n- i Z'.f) 2f,-." Cf.)J:~ :<.Z ~C' ~() :E;O ~ =< o o L c: ;e C) '1'"1 ~-/-;'~ -~-\ J ~i~; ?)2::J ?~() Om 35 -< N '.D -0 ::ll: I)? Ul I.