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HomeMy WebLinkAbout00-02761 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .u " '" '" '" ;t;;tO - ^ ,~-, ' -~-I ,'-,,;-~,, ' "' - ~ L';. ,'tl i:i i~~: I ji ,.1 I ., ~ i I;! i;-I !" 1'1 1:1 I:: 'j U i' I-I ri ji 11 Ii I' " ,. t! " " H rl " );! ;:1 !~: ~:I [.! i.j Ii [:j \'1 II Ii f: " f! , ' '" '" "'''' ;t;", "'''' '" '" '" '" . "'''' '" "'''''''''' '" '" '" '" '" "'''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF GABRIELE DeWOLF, . . . . PENNA. . . . . . . . . . . . . . . . . . . No. 77h1 7000 VERSUS Pl"intiff WI\VNF. S'f'F.VF.N OpWOT.F . . . . npfpnd~nt AND NOW, . DECREE IN DIVORCE . . . . . . . . -A."."....,(,..r . 7~ , 20..'" , IT IS ORDERED AND . . . DECREED THAT Gabriele DeWolf . . , PLAINTIFF, AND W"yne steven DeWolf , 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 Property Se.~LJement Agreement between the parties dated . . March 2, 1996 is hereby incorporated but not merged. . . . By THE COURT: . . Ad- . ATIr . . J. . ~~~THONOTA" . . . . . . . . . . . . . . . . . . . 1<1 ",,' ,e, . " I" ~ .- -"^ -~-- ~."~'" -,=~, --,=~ .", '--"'111 .,,- '\ . q.g.tJc;7 &7.~ ~ ~ 4~' 9''lf'-cy w~ ~~ G~ . , ~ " -" -~," .._,..,h"""""""l !~.!~ ,~ ,._ mlPi_.-, ~.~~""!I 4 , r PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this J nd day of rfli+f<<...h ~ , 199,$ between GABRIELE DEWOLF, of Mt. Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as Wife, A N D WAYNE S. DEWOLF, of Mt. Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as Husband. WITNESSETH: WHEREAS, in consequence of disputes and unhappy differences, the parties have been living separate and apart from each other; and w~EREAS, the parties desire to confirm their separation and make arrangements therewith, including custody of their minor child, Stephanie Ch. DeWolf (D.O.B. 11/29/86), the division of their marital property and other rights and obligations growing out of their marriage. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and SAIDIS, GUIDO, intending be legally bound it is agreed as follows: SHUFF & to MASLAND (1) It shall be lawful for each party at all times 26 W. High Street Carlisle, PA hereafter to live separate and apart from the other party at suc place or places as he or she from time to time may choose or fit. deer I I , , I i i . SAIDIS, GUIDO, SHUFF & MASLAND ._26 W. Hi~h Street Carlisle. PA , . ii I I I ii II I' i l ~ :1 I (2) Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. (3) The parties are the owners of a mobile home located at 3 Larken Lane, Mt, Holly Springs, Cumberland County, Pennsylvania. Husband agrees at the time of signing of this Agreement to transfer all of his right, title and interest in " ~ I I ! II' , I~ " 1'1 iil " " i~ :il 'I II (I '.'..1 " m I J ~ , ~ said mobile home to Wife. Wife agrees to assume responsibility for the encumbrance on said mobile home with PNC Bank, the lot rent, utility bills, insurance and taxes in connection with said mobile home. With regard to all such expenses, Wife hereby agrees to hold Husband harmless and indemnify him from any loss thereon. (4) In the event that either party contracted or incurred any debts since September l, 1995, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. Husband and Wife acknowledge that they have paid off the Colonial National Bank Mastercard debt. (5) Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Husband to receive the GEO Tracker and Wife the 1993 Ford Escort. Each party shall execute any documents necessary to have said vehicles properly registere in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle and shall hold harmless and - ~ SAIDIS, GUIDO, SHUFF & MASLAND 26 w. High Street Carlisle, PA , . , . indemnify the other party from any loss thereon. (6) Wife hereby releases any and all right, title and interest she may have by reason of the marriage to the Hunting Cabin located in Huntington County, Pennsylvania currently title partially in Husband's name. Wife agrees to execute any documents necessary or desirable to release her claim. (7) The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (8) Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts and retirement accounts. This provisio specifically includes Wife's release of Husband's pension and th 401K plan by reason of his employment by the United States of America, New Cumberland Army Depot. This provision shall also include Husband's release of Wife's 401K by reason of her employment by Corporate Distribution Limited. . SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle. PA .j , . (9) The parties agree that they shall have joint legal custody of their minor child, Stephanie eh. DeWolf (D.O.B. 11/29/86) with both parties having the right to make major parenting decisions effecting the child's health, education and welfare. Wife shall have physical custody of said child subject to periods of physical custody by Husband at the times and places t be mutually agreed upon between the parties. (10) Husband agrees to pay to Wife for the use, benefit, support and maintenance of their minor child, the sum of ~e ..:H'f. cc ~'M~red ($Ja8.~0) Dollars per month which payment shall be made on or before the first day of each month in advance. Husband shall provide Blue Cross/Blue Shield, major medical or equivalen coverage for the benefit of the minor child so long as he is obligated to contribute to her support. Husband and Wife also agree to be equally responsible for any noncovered or extraordinary medical and/or dental expenses for said minor chil provided that the decision to incur extraordinary or noncovered medical and/or dental expenses shall be joint. The parties agree that in the event of a material change in circumstances of either party, or a change in the custody arrangements set forth herein, the amount of support payments shall be subject to an appropriate adjustment by agreement or, i the parties are unable to agree, by order of a court of competen\ jurisdiction, and the amount ordered by any such court shall be deemed to be the amount due hereunder. Husband agrees to pay one-half the cost of the child's post i. , SAIDIS, GUIDO, SHUFF & MASLAND .26 W. High Street Carlisle. PA - :d.'; , . secondary education including but not limited to room, board, tuition, books, activity fees, travel expenses and spending money. Husband, Wife and child all must agree on a mutually acceptable institution which agreement will not be arbitrarily withheld. (11) Except as otherwise provided herein, Husband shall not pay to Wife nor Wife to Husband any sum whatsoever as alimony, alimony pendente lite, or for his or her support or maintenance. (12) Wife is now represented by counsel of her choice, Robert C. Saidis, Esquire and Husband has been advised of his right to secure counsel of his choice. Husband and Wife agree t split equally the legal fees incurred in preparation of this Property Settlement and Separation Agreement as well as a no- fault divorce. (13) Neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (14) Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provision of this Agreement. (15) The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is , SAIDIS, GUIDO, SHUFF & MASLAND ..26 W. High Street Carlisle. PA . . . i ! , I I i I i I i I . , I , familiar with, the wealth, real and personal property, estate anc assets, earnings and income of the other and that each has made c full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. (16) Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities undel this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (17) It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims which have been raised or may be raised in an action for divorce. (18) Except as may be otherwise specifically provided in chis Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect co the following: A. All liability, claims, causes of action, damages, costs, contributions, expenses or demands whatsoever in law or in equity; , . B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of curtesy and dower and all claims or rights in the nature of curtesy and dower; D. All widow or widower's rights; E. All rights, title and interest or claims in or to the other's estate, whether now owned or hereafter acquired including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and I obligations arising out of or in connection with the marita~ relationship or the joint ownership of property, whether SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Street Carlisle. PA real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the pennsylvani Divorce Code, Act 26 of 1980, as the same may be amended from time to time, and under the provisions of any similar , . , SAIDIS, GUIDO, SHUFF & MASLAND 26 W. Hi~h Street Carlisle, PA ~~,~ I I I I ! statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (19) This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreemen is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (20) In the event that either of the parties shall recover final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (21) In the event that either party breaches any provision I the other party retains counsel to assist of this Agreement, and in enforcing the terms thereof, the parties hereby agree that th breaching party will pay all attorney's fees, court costs and expenses incurred by the other party in enforcing the Agreement. (22) This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (23) This Agreement shall bind the parties hereto, their respective heirs, executors and assigns, , . SAIDIS, GUIDO, SHUFF & MASLAND 26 w. High Street Carlisle. PA IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day an year first written above. Witness {)I'dz- Q).tW U4 riele DeWolf Witness ~ jD~ a~ !S. DeWolf RCS/Renee/Draft/DeWolf.Agr./1-9-95 LfIM... '1, ',:,,-,..,-- ,",",^" ~d~ll.!llti:~IJ!~~~J;lM:Ii~iMn r' T1i!!il1illl ~ ~I "-,,,- . , ",= "",~ . -~" ~- , ~~ ~~-. V'~Hl-"" , . . 0 Cl 0 c: (;2) '11 ~ ~-,. ~ -U f-'J '- rn j:----: ~~, ~:J z ~U Z r- LJ \1"1 (f' ,;~',: y " -< 0 C) r:;; ,-, .....'0 -- ,., ~ (.;~ -n ( )- ~.~ (5 )> 0 :~5 m c..:: --I Z -:...) :Jc- =< ::rJ fX) -< rillllllilJl," ~ ";- GABRIELLE DeWOLF Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. 2761-2000 FAMILY DIVISION WAYNE STEVEN DeWOLF 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: 1, Ground for divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Certified Mail, Restricted Delivery, dated 5/10/00, copy attached. 3. Date of execution of the Affidavit of Consent and Waiver of Notice required by Section 3301 (c) of the Divorce Code: By the Plaintiff: 08/25/00 By Defendant: 08/05/00 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 the Records, a copy of which is attached: *********** (B) Date Plaintiff's Waiver of Notice in ~ 3301 (c) divorce was filed with the Prothonotary: 08/31/00 Date Defendant's Waiver of Notice in ~ 3301 (c) divorce was filed with the Prothonotary: 08/31/00 Robert C. Saidis, Esq. Attorney for Plaintiff ~ ~. v t !: I [ '~ Ii :i' i: t !' iiillt ~"~'~~""~"""'.<--~ ~~...~o~ ,~,-> ~~ _v _ ~~" "--'-'" _i~IIHWil~jjl"--' , " -,..; - - -~ ~~ "iRI'~ o c:: u~ Tn;:: ;:-::i:' "'755:', I~ '7' :<:J -" " Cl- c} ~ c: :';-) (-_c) --1.:" . c:' -,~_S '--~; :i:i ~,.. ~ j {~~;rTJ _:-1 :D -< -:.) CD ~. il 1I S:7? ,. " !i SAlOIS, SHUFF & MASLAND ATI'ORNEYS'ATlLAW 26 W. High Street Carlisle, PA '''-I' , " ~ ' ...-,.". 'h. i' f; GABRIELE DeWOLF, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-';; /fpl CIVIL TERM WAYNE STEVEN DeWOLF, Defendant IN DIVORCE 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 Street, 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, PA 17013 (717) 2~;~ SAlOIS, SHUFF & MASLAND ATrORNEYSIATlLAW 26 W. High Street Carlisle. P A -d- _'~ c' .", , -,~ - - ',o!.:,-.. '~,:, GABRIELE DeWOLF, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO. MJ-;17tl CIVIL TERM WAYNE STEVEN DeWOLF, Defendant :IN DIVORCE COMPLAINT UNDER SECTION 3301(cl OR 3301(dl OF THE DIVORCE CODE 1. Plaintiff is Gabriele DeWolf, who currently resides at 3 Larken Lane, Cumberland County, Mount Holly Springs, Pennsylvania 17065. 2. Defendant is Wayne Steven DeWolf, who currently resides at 66 Lone Oak Drive, Marysville, Pennsylvania 17053. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 25, 1984 in Germany. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. L II SAlOIS, SHUFF & MASLAND ATIORNEYS-AT.UW 26 W. High Street Carlisle. PA .--.' " -. " .'", ,- ~,~', .:.;.-~",-~,;" -,,"- .. ..,-- ':. ~-",;- , I~'j WHEREFORE, Plaintiff prays Your Honorable Court to enter a decree of divorce. y submitted, obert C. Saidis, Esq. Attorney for Plaintiff SAlOIS, SHUFF & MASLAND A'ITORNEYS-AT-LAW 26 W. High Street Carlisle, P A I: ~- -",' ,,, "" , ~c 'C_ ""_' H_' ~' i I I i , , COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND :SS I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 5 - d-- - J,060 intiff \JWuJ ,.-, - '-~ ' GABRIELE DeWOLF, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. . :NO.OV.27tlcIVIL TERM WAYNE STEVEN DeWOLF, Defendant :IN DIVORCE AFFIDAVIT I, Gabriele DeWolf, being dUly sworn according to law, depose and say: (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 understand that false statements herein are.made !: I'i i i I Ii SAlOIS, 'il SHUFF & Di',1 ted' 5- d- MASLAND 1ft ' AT\'ORNEYSOAroLAW II 26 W. High Street 'I i Carli.le, PA I Ii il ii " I: subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. - ~OOD ui& .'. ~':-"Y, --~ " ;\;.-n" 'Ii. ~,; , r Vi ~ ,:r~. :iil ;j I "" ~.- =i~.i.~~~I,,*-'''fi~.''"'Jillf1r''';''''' In,~ ul '1 \S " '& ~ ~ fA Cj \ ~ " t.1 ~ ~ ~ \ \\J '\ \ . ~ , ,'^ .' ,'" -,"'~ () C ?-.: -or~ fn _,'J .z: rn _,. :t"~ tJj); -<-0' ~O ~.: r~ <':. --.. ~ $fO C 2: :< \D -'-ro"--_-,_,_,,,, ~ o a ::JI: h -< I o -~ ".-J fI~ :iY. .. i---- -d'fo,.. ~bO~ , '") ::'"<~.... ;J:::t'I: '~FN.. 7 ,'- o ~ -<;: .;..- -0 :x - h _.~ ~ ,I .' '66"':~7f.o( i .. ~ ! ~ c a ... f -a.::" E a .. Ill. , '~ 1 ~~f? fur a_onal,sElrvices. ~,;: ; .:.t~j . , " ,r'ns 3. 4a, and 4b. ,...' ,._'~,;' -Print your name and'address on the reverse 'of this tonn so th~1~,oc;:liln-~um' this card to you: ' ".:'_: ,:'!':,,)-.,~'" -Attat:.h this fonn to 1he front of the mallpiece, or on the back if ~"~not ponni'. ..,~. -Write-Return RSC8ipt Rsquestsd~ on the mailpiBfOe below the article number. 1iTh9~DetUm Receipt will show 10 whom the artide was deIlvered and the date dEiIi~. I also wish II> ~lhe following services (for an extra fee): 1 . KI Restricted DellvalY Con B. 4a. Article Numbe, P 433 109 779 4b. Service Type o Registerad lC Certified o Express Mail nsura o Retum Receipt for Men:hendlse 0 COD 7. Date of 0 'velY ~ 0 0""> 8. Addr 's AdlIress (Only If requested and fee is paid) .e " g. ! i I e ,.-::1 3. Article Addressed to: Mr:. Wayne steven DEW:::>lf 66 Lean Oak Drive Ma1:ysville, PA 17053. j\ d ~ I ,i l ; 102595,97,."'179 Domestle I!A t P 433 109 779 '-",," US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mall See (everse Sent to Mr:. Wayne SI:evBn DEW:::>lf Street & Number 66 Loan Oak Dri Post Office, State, & ZIP Code il e P Postage Certified Fee Special Delivery Fee Restricted Delivery Fee '" ~ Return Receipt Showing to r Whom & Date Delivered a Return Receipl Showing to Whom, < Date,&Adclressee'sAddress ./-~:/ h J b I -t fA II i TOTAL Postage & Fees C'2 Postmark or Date g u. (J) ~ Q. , . .'" /."..,.~......... ~>~~ '\ .. ~~ 10 \. ,~'I", 1i1'~ ~"'l;;y 1\ Ii Ii, 11 Ii "i L i-,I ri ~. fe' I; ! !~: 11 ki t: r:: [-' l' t Ii " ji " f: I, I; I' Ii ~~ I'~ IIlIIlIliliIiGln- '~~~.lI;~iliiH~~k"~~i!lM~~-"-' -.~" .d"'liIiIiitui. .~ .~ (') 0 () c <::) "T1 ~ :;:". ~ -el [1: ~ mr'f: v") r- 2:;:-1 ~3~ ;:'.:J ri, -',e! ~l(~ (CC' v g,~ :''1> '-', -,-" zl..~ ~C) >c -.; , z ,~ ~ :<! 00 =< "",, !!t~_~. ... ,. ",,~" .~ ~,".~ 1~" ._. . ~,I . - SAlOIS, SHUFF & MASLAND ATIURNEYS.AT.LAW 26 W. High Street Carlisle, PA ",'. GABRIELE DeWOLF Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2761 of 2000 v. WAYNE STEVEN DeWOLF Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREEE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 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 of divorce without notice. 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. 5. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. DATED: <:6-)5;-00 G riele DeWolf Plaintiff II ,Ill. ',' ~ ,.; . .",,0 ,- 'J.' ,I,"~.i,'> ':'LiW'"" ., _-";;:""'';''''''-'_;';'''''-);(''0, .- o c z: -OeL! rnrTi Z-:_I :z~ ::?~~: ":0 <. 5:0 52 z _oj -" ,. ',- ,,:,"~ , I q o ". .- (;:) CoJ ~~." 1:") ,-, -" ,~ ~~~~ '- -T"' ,:A) CO ~s~~ ~~ ::b -< ~ SAlOIS, SHUFF & MASLAND A'ITORNEYS.ATeLAW 26 W. High Street Carlisle, PA . . . GABRIELE DeWOLF, Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2761 of 2000 v. WAYNE STEVEN DeWOLF Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREEE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 2, 2000. 2. Defendant acknowledges and accepts service of the Complaint on May 10, 2000. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: YIhC7 dOOe-J '/ 1i1~1lIIii!iI '"~ . .....1 ,dIiiiI, ,',- ~:iJ~Il~ I .dfiati . I~" ~.. _Ar'- t__",,-- do' '101 . o C <<:': l:'rf, nlm ;~ :l' Z. Go:r-e --' ",- ~C~ :>c--. z' ~-C) PC: Z =< ,,' _'_-~"L,i" ,"" ,~i -c,) C) :',~ c:: :n /,-:-:) ., (.".) -'''I ~j '-~-::;() ::::,! ....,... ,*,' ':..:> CO .) (') ;:-'"-;;;rTI ~::.::j 0- :n -<