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Home My WebLink About00-04454 , . .. . .. . . . . ',,1': . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY STATE OF . . PENNA. . . . Pamela ~. Bennett, . . No. 00-4454 . Plaintiff . . VERSUS . . Allen E. Bennett, . . Defendant . . DECREE IN DIVORCE . . . AND NOW, ~ \.C\ ~ IT IS ORDERED AND . . DECREE:D THAT Pamela A. Bennett , PLAINTIFF, . AND Allen E. Bennett , 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; -lbVG2--- . . . Parties' Marital Separation Agreement, dated October 30, 2000, . . is incorporated herein and the Court has jurisdiction over . By THE J. no other claims. . . . ATTEST: . . .. ~ . ~~-~....,........,~ "~ O"~O_ ~"," 'e~" ~'"~,~ "~~.~'~~ / J . dO -tPeJ /,,) - d2.D . Cl:1" "JI'l!IlI!'IFl~, ",-,~ -,~' ~.~,~ h'~,' ,,'<'V:~ 20 ,"",~ " '~\-';-C"'''f1 ", '" .Vl' "r"milTr~~ffif1lnt"mrUJltl"Yr~''>':~:'i,('" <:(""'~':J",,0;-"'~l , ....... , . ,! . , . '~ .' U~~$4~ ~:; ~d-~- ~,~'~i!~1RiI'!lI'IIl"",mo'!IN~!jBl~~IIl1!!ll"!r.~l_~_"~.,,,~.~~JIlIIll!Ift!. *""""" ",o,.~.,,", <'" ";1::: I L " . . oC>.... "I'IS/.{ Ct:"'CL f MARITAL SEPARATION AND PROPERTY DISTRIBUTION AGREEMENT This MARITAL SEPARATION AND PROPERTY DISTRIBUTION AGREEMENT (this "Agreement") is made effective as of this ~"'-tJay of October 2000 by and between Pamela A. Bennett, who resides at 136 Center Street, Carlisle, Cumberland County, Pennsylvania (hereinafter "Wife") and Allen E. Bennett, who resides at 142 North East Street, Carlisle, Cumberland County, Pennsylvania (hereinafter "Husband") as a full and final settlement of their marital rights and obligations. Whereas, Husband and Wife were married on February 17, 1979 in Prince George County, Virginia; and Whereas, a complaint in divorce was filed by Wife in Cumberland County Docket No. 00-4454 Civil Term onJune 27; 2000 and served on Husband on June 29, 2000; and Whereas, the parties agree that the marriage is irretrievably broken, the parties have lived separate and apart since October 22, 1998, and the parties have signed affidavits of consent to entry of a divorce decree dated, by Wife, on October 2, 2000 and, by Husband, on October 3, 2000; and Whereas, during the term of the marriage, the parties acquired certain marital property, as that term is defined in the Pennsylvania Divorce Code, 23 Pa.C.S.A. ~ 3501, et. seq.; and Whereas, the parties wish to settle forever and completely their interests and obligations in and to the marital property. Now, therefore, in consideration of the premises and mutual covenants of the parties and intending to be legally bound thereby, Husband and Wife agree that: 1. Each party has been advised of his or her right to independent counsel and is neither represented by counselor has knovvirl~i)r,_ iI1te1~gently and voluntarily waived the right to counsel. 2. Each party has read completely and understands every provision of this Agreement, has given careful thought to the making of this Agreement, and enters into this Agreement voluntarily, intelligently and under no duress. 3. Husband and Wife shall henceforth live separate and apart from' each other and both parties shall live their lives free from interference by the other. J_e I. , I 4. Husband irrevocably waives, releases and forfeits any rights he has or may have against Wife for spousal support, maintenance, alimony pendente lite, or alimony. Wife irrevocably waives, releases and forfeits any rigjJ.ts she has or may have against Husband for spousal support, maintenance, alimony pendente lite, or alimony. 5. Husband irrevocably waives, releases and forfeits any rights he has or may have in or to Wife's estate, including any right to inherit any part of Wife's estate, to receive property from the estate by bequest or devise, to elect against Wife's will any putative spousal interest or to act as executor of WIfe's will. Wife irrevocably waives, releases and forfeits any rights she has or may have in or to Husband's estate, including any right to inherit any part of Husband's estate, to receive property from the estate by bequest or devise, to elect against Husband's will any putative spousal interest or to act as executrix of Husband's will. 6. Husband irrevocably waives, releases and forfeits any rights he has or may have in or to Wife's separate property, Wife irrevocably waives, releases and forfeits any rights she has or may have in or to Husband's separate property. 7. The marital property shall be divided between the parties as described herein. Husband shall receive from the marital property, to own and enjoy as his own separate property Husband's motorcycle and Husband's tools. WIfe shall receive from the marital property, to own and enjoy as her own separate property Wife's automobile (encumbered by a loan from Members First Federal Credit Union), the parties' Jayco featherweight pop-up camper, the parties' inoperable van (located on Fairgrounds Road) and the right to receive any refund of the $350.00 security deposit placed by Wife on Husband's apartment. S. Husband irrevocably waives, releases and forfeits any rights he has or may have ----,--- - - - - ~-- --,-,------ in or to Wife's pension and retirement plans. Wife irrevocably waives, releases and forfeits any rights she has or may have in or to Husband's pension and retirement plans. From this day forward, each party's pension and retirement plans shall become the sole and separate property of the party in whose name or through whose employment such plan or account is held, titled or carried, If either party withdraws any amount from his or her pension or retirement plan or I,j " " " , account, that party shall be solely responsible to pay any taxes or penalties that may result from such withdrawal. 9. Husband and WIfe have no marital debts. Neither PartY will incur any debt in the name of the other. From this day forward, Husband shall be solely responsible for any debt that he incurs and Wife shall be solely responsible for any debt that she mcurs. 10. Wife agrees to pay for the costs of this divorce action, excluding Husband's attorney fees. Except as provided for in this Agreement, neither party shall be liable to the other for any costs, fees or expenses, 11. This Agreement shall be submitted to the Cumberland County Court of Common Pleas for its approval. The parties intend that this Agreement will be incorporated into a decree in divorce and understand that this Agreement is subject to the continuing jurisdiction of the Cumberland County Court of Common Pleas. IN WI1NESS WHEREOF, the parties set their hands on the day and year first above written. ~'~~~ ~J2 Pamela A. Bennett (Wife) ~~ Witness . . "- ",'~' " . I" " ,~",', I" '-',---, "'" .. PAUL K. CHRENCIK and REBECCA S. CHRENCIK, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-5084 CIVIL TERM DAVID RUSSELL, Defendant CIVIL ACTION - LAW ANSWER TO DEFENDANT'S COUNTERCLAIM AND NOW come Plaintiffs, Paul K. Chrencik and Rebecca S, Chrencik, by and through their attorney, Law Offices of Craig A. Diehl, and files the following Answer to Defendant's Counterclaim: II. Denied. No responsive pleading is required. 12. Denied. The Lease is a writing that speaks for itself. By way of further answer, Defendant previously testified that he operates a commercial activity out of the leased area. 13. Admitted. 14. Admitted with clarification. Plaintiffs did not draft the Lease and were merely the assignees of the Lease when they purchased the commercial property on June I, 2000. 15. Admitted with clarification. Plaintiffs did not procedurally confess judgment against Defendant which would have given cause for a Counterclaim. Plaintiffs served Defendant with a Complaint only after Defendant's appeal from a District Magistrate award. 16. Admitted, I '1,. I-''' !,' ;0''':'"- ~-~-" _' '.. ~" ~ . - 17. Denied. Plaintiffs have not utilized the confession of judgment language in the lease. Suit was instituted by Complaint. Plaintiffs' request for attorney fees is to reimburse them for Defendant's unwarranted actions. 18. Denied. As an innocent assignee, Plaintiffs should not be held liable for the prior Landlord's actions. Furthermore, Plaintiffs have given Defendant an ample opportunity to raise any alleged defenses. WHEREFORE, Plaintiffs/Counterclaim Defendants respectfully request that Counterclaim Plaintiffs counterclaim be dismissed with prejudice. Sincerely, LAW OFFICES OF CRAIG A. DIEHL Date: November 27, 2000 By: ~,(1 Craig . Diehl, Esquire Attorney ID No. 52801 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Counsel for Plaintiffs 2 , 1-'" ^,^"j - ~ , /; .. . PAUL K. CHRENCIK and REBECCA S. CHRENCIK, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-5084 CIVIL TERM DAVID RUSSELL, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this d ~-I'h day of November, 2000, the undersigned hereby certifies that a true and correct copy of the foregoing ANSWER TO DEFENDANT'S COUNTERCLAIM was served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Stephen J. Dzuranin, Esquire WIX, WENGER & WEIDNER 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 LAW OFFICES OF CRAIG A. DIEHL B~~ Helen E. Rasmussen, Legal Assistant 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 _,I; - '. . . . Pamela A. Bennett, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : v. NO. 00-4454 CIVIL TERM Allen E. Bennett, Defendant IN DNORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for the entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under ~330l(c) ofthe Divorce Code. 2. Date and manner of service of the complaint: June 27, 2000, Certified Mail, Restricted Delivery, Return Receipt Requested. 3. Date of execution of the affidavit of consent required by ~ 330l(c) of the Divorce Code: by the plaintiff on October 2, 2000; by the defendant on October 3, 2000. 4. Related claims pending: Property Distribution. The parties have agreed to distribute marital property in accordance with the Marital Settlement and Property Distribution Agreement dated October 30, 2000 and filed in this Docket on November 29, 2000. The parties intend that the Court will incorporate the Agreement into a Decree of Divorce. Please transmit the Agreement to the court for this purpose. 5. Date plaintiff's Waiver of Notice in ~330l(c) Divorce was filed with the prothonotary: October 12, 2000. Date defendant's Waiver of Notice in ~330l(c) Divorce was filed with the prothonotary: October 13, 2000. ~Cl'L~}..l\.\C)A~ A orney for Plaint """..n.' tiilliiW:~~l!I!IllilIlli~Ir~~~~'>ll~,"l>l'\!I!li1itjW,-d~Ill;;'-1lfiIt~,:r~.,.:ru.,~:<'di!I<Iiliii;:I:~~j&- .IIldl.lll:JH:_' " "~"""""Il . .......-'",-, " ". _~ ,"~,~~,,~. ~'" ~_ . ~.,~. ~>>>< ~>, .I,,,,..,=,, '.,. ",' ' ^, ~, '-' ,~^ .' .. " ..~'N ~ > _ n L .' .......~ ~...~- - (") c:::J () C (".-':II -:'1 :;" el' .- ~- -0,[0 (""1 - -'jj mni ';',,",:1 2:1J h-l :z :J> .t:.- S2 , :;~: ()- ~C::: J::'"' ~~~ ::e:C -J!'~ -,,,", ~6 -- 0 en -- c: -I ~ C:, 'J> :::0 .< -"~"<- ~ ." '-. "~,' 1 ~ - '''.~-, j~~ ,,- ,,'~,I, I , '~, '''-'''''~' '" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pamela A. Bennett PLAINTIFF V. } } NO. en - .1'1/5~CIVIL TERM } } } IN DIVORCE } } Allen E. Bennett DEFENDANT COMPLAINT 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 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PORPERTY, 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 FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 Telephone (717) 249-3166 J,,'.J '0' - .~, .~,' ",", "'J --, '~ ~ ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pamela A. Bennett PLAINTIFF v. } } NO. HJ - <I <f1J~'1 CML TERM } } } IN DIVORCE } } Allen E. Bennett DEFENDANT COMPLAINT IN DIVORCE UNDER SECTION 3301 ( c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Pamela Bennett, by and through her attorney, Richard C. Gaffuey, Esquire, who files this complaint under Section 3301 ( c ) of the Divorce Code and who, in support thereof, respectfully represents that: 1, The Plaintiff is Pamela A Bennett, who presently resides at 136 Center Street, Carlisle, PA 17013 since October 22; 1998. 2. The Defendant is Allen E. Bennett, who presently resides at 142 North East Street, Carlisle, PA 17013 since November 10,1994. 3. Plaintiff and Defendant are sui iuris and both have been bona fide residents of the Commonwealth for a period of more than six months immediately preceding the filing of this complaint. 4. The Plaintiff and Defendant were married February 17,1979 at the Fort Lee Army Post, Prince George County, Petersburg, Virginia, 5. The parties to this action separated on October 22, 1998 and have continued to live separate and apart since then. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the court require the parties to participate in counseling. ^ .l ,"r ~. ,,~'" I" , '" I ~ ,,: . 9. Neither the Plaintiff nor the Defendant is in the military or naval service or in any branch of the armed forces of the United States of America or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 10. The Plaintiff requests the court to enter a decree of divorce under Section 3301 (c) ofthe Divorce Code. Wherefore, if both parties file affidavits consenting to the divorce after ninety ( 90) days have elapsed from the date of filing of this complaint, Plaintiff respectfully requests this Honorable Court to enter a decree of divorce pursuant to 23 P.S. Section 3301 ( c ) . Respectfully submitted, P.O. Box 627 101 Front Street Boiling Springs, P A 17007 Phone (717) 213-6755 Attorney for Plaintiff ." f:.r. ',> ,', I~ I,] IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pamela A. Bennett PLAINTIFF v. } } NO. CIVIL TERM } } } IN DIVORCE } } Allen E. Bennett DEFENDANT VERIFICATION I verifY that the statements made in the foregoing complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904, relating to unsworn falsification to authorities. Date 0{ t. 9-~ /J'b ~~a/~ Pamela A. Bennett, Plaintiff ~~- ~ "~~~_~~m'''lfJ=~1t/,,,",~,,,,,,,~~'lBNllliiiUii?' ,I_c. ~-r-- '~'~~ -"'"'~IiiI~~'-- ~ ~ (') 0 0 ~ CI "I' ~ "- t- .--., Y\~ "Om c :r: ---n t ~ mn' -, Cf1p - ~ z::rJ N .'c':'iTt z:c ;:"5'~ ~ ~~ ~6 -.!i tl ""l:' =1"1', --:n ~ ~o :3=- ~:?o ~ ~ \ \~ ~2 r:- om -'-l '-I ~ c:> ~ ~ ' ~ t;::> ~ , ~ ~ ,<~"",_, """.y__,.,__"","~,,,. .~~<~,".. ~,~"",,,,~,J~ ."C, ~',"'-~,",,~,'~~. ,~"c'oe~~",',.',O-~,V ",I, . . .' ~. ^ ,~ " fR ~ ,,' ,'" Pamela A. Bennett PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-4454 CIVIL TERM Allen E. Bennett DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF CUMBERLAND Richard C. Gaffuey, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff in the above captioned divorce action; that on June 27, 2000, he mailed a true and correct copy ofthe Complaint in Divorce, duly endorsed with a Notice to Defend, to the Derendant, by certified mail with restricted delivery, postage prepaid, return receipt requested and evidenced by return receipt card No. Z 7000 0600 002138559415 to Defendant's last known address; that on June 29, 2000, Defendant did personally receive said Complaint in Divorce as evidenced by the signed Acceptance of Service form attached hereto; and that the mcts set forth ~ tile witiJil:1fd'lidavit are true and correct to the best ofhis information and belief. ,If " Richard.C. Gaffuey Attorney for Plaintiff Sworn to and subscribed before me this IJ...IV Day of ~OOO. 4~/A. ))~.M '\ <r Nolarial Seal Sue A. Gaffney, Nolary Public South Middleton Twp., Cumberland County My Commission Expires Oct. 13, 2003 Member, Pennsylvania AssoctatlOn of Notaries ~~ "" -i.'9~iM.lL'~, ,..J.e i U1 .-'I .:r lr Certified Fee U1 U1 CO m .-'I ru CJ CJ Return Receipt Fee (Endorsement Requiret:l) Restricted Delivery Fee (Endorsement RequireD) , CJ CJ CJ I"- c ; ~ # c .fi11fa~~.n:t~tedbYmaJJer) ....: '. :>._r:'1 .~i4a.^b{PO~;;'Lb+....nn......n''''.hnn.............. ,OtSn.......n.... Total Postage & Fees 'Q; SENDER: 'C . Complete item9'1 anQJol",2 for additional setvices. Ii . Complete items 3, 4a, and 4b, CD . Print your name and address on the reverse of this form so that we can return this ~ card to you. , CD . Attach th~ form to the front of the maJJpiece, or on the back if space does not e: permit. ; . Write "Return Receipt Requested"on the rnailpiece below the artide number. ! . The Return Receipt will show to whom the article was delivered and the date .... delivered, c o " ~ ii. E o u R\\~dd~S~&n(\d:t \40 N. fu5\- a Cb.-I\ ;~\e I ~ . .0< ~ .' .I:l)fW' .""",' '\ ,'" ' I also wish to receive the following services (for an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery Consult postmaster for fee. 4a. Article Number ,COO (j.JfiJ 4b. Service Type o Registered o Express Mail o Rstum Rereipt for Merchandise 7. DateofD e ai u e ell a .. i: a: c $ ~ Certified ~ o insured g> o COD .~ dJ ~ o - :> o >- ... c .. '" ....1 1 02595-9&-15-9229 Domestic Return Receipt ~" ................"""-'''''''~I~~~!I!lI...H.lii._ ~, " ,~,~',TJ2;LJ,_ "-"__,,,,,,,, ""~"""!"""'_'" ,_" '" . ~ol.' ',~e'.", .,~ "~"~ ,_,,,... _~~, .' -~'." ..~,,",' liIIllilI_ ~'~' ",",",oj,",'.,,- w "= ",,,",<,"""<. Iird~~ ,~-" o. ~ '" -'~_iliiIllI"-~" -.'-- 52L,,' (,::;r. r:: j...:: ('~:.) -:;.., ~ ~. " !~ ',~) ,'V C:::. .= (~ 5 i::J ~::~ o q -, ~-! :;~T) r-': , !~'l ,~:'~? :,.1 ~,,..) ..~i ;'i,J ..J 1-"jiT; ~Ej '::;~J -<; J\.) c) =? If:: I' """,~ '.-, ~ l> .. ~ , , i r Pamela A. Bennett PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4454 CIVIL TERM Allen E. Bennett DEFENDANT IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 27,2000. I:' 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date offiling and service of the Complaint. ,;, , " 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. it' I verilY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ fJ2d b-o ~~~ Pamela A. Bennett, Plaintiff W"'< "'."M '" ~,' 1lia..i~~I.~~,,,",,",\W.tti~~!UiIU_"""'" -~.~ =- - -. ~~~.. . " o c: -o~E miD :?_.' ~;f ~~~ ~ -~ f~ c::> C'J' -I !~~ <-,,} :E~ -".. >'f? ~;;"" rv "~.<-,<i ~ \, . . , - Pamela A. Bennett PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~:i Ii, ij,i ~'; ii 1,: v. NO. 00-4454 CIVIL TERM ;" " i!'~ Allen E. Bennett DEFENDANT IN DIVORCE , ;h PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE ",: ,. I. !i: i ,. I I (' 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 I 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 fulsification to authorities. Date: ~ dJd- /nJ ~L~ Pamela A. Bennett (PIaintift) ~~. ~-~"-~~.='~ ~.~~"" ~.- ..-""..- ~ ^-i$)- "~" .............iiIIIIiIIlIIiiI~ . " 0 C) t;, C C) +1 :s: c=' "0 CO <:? n1 JT~ --I Z ::n ,--- ,,,,- i~.._ :.~q (j) " (~,~, , -< /- ~;) ~ ," '~. ~n: >? .Ti Z 1----":: ~~~ 5> I~ '0 {:j , , 2 .--1 ,:- -0 --< IJ .-:: fv -< I, ~ ., . . , . Pamela A. Bennett PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : v. NO. 00-4454 CIVIL TERM ABen E. Bennett DEFENDANT IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 27,2000. 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service ofthe Complaint. 3. I consent to the entry ofa final decree of divorce after service of notice of intention to request entry of the decree. I veritY that the statements made in this affidavit are true and correct. I understand that :fulse statements herein are made subject to the penalties ofl8 Pa.C.S. Section 4904 relating to unsworn fulsification to authorities. Date: '<( ~ DC) ~~- F~ Allen E. Bennett, Defendant I I,", ,. I I I:; ,c,-- '" ~"""f.di " -'j ,-,;;. ~"'';''_Iii!lll~~N!>\!IUjISat.~w.I~~_MID>~" . . l~ (tl jUt. - UJIl!IIL . -....." ~- t.l!iilIiIl" . ......._~"'- . ,. 0 c.-:-) r- {"~, ,- <' C) -r] cP C? [!Jr'i::j -.... ~,-; L..:r Zr.c-, "I ci5 ')> (..,J --'\ CJ -(Z 1 r-:'-', "..' <'--" ;lt~ -- -1"\ PC' -~~. --:.) --n Z-:! -,~ () j>U >' C '>.;9 ('-";:; rn .-j Z -, ~,.. b :< :D r,,) -< ~~"t, .. ~(, . "" H ,) Pamela A. Bennett PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4454 CIVIL TERM ADen E. Bennett DEFENDANT IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(e) 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 fulse statements herein ate made subject to the penahies of 18 PaC.s. Section 4904 relating to unsworn falsification to authorities. Date: J~ 00 tf-f2A ~ . €.9fL Allen E. Bennett (Defendant) -.,~--._,,,,. '''. . ~"' .," ,L". -,;.~ ~~." 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