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HomeMy WebLinkAbout00-04830 ~ ~- .~>" . . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . . . PENNA. STATE OF . Sarah M. Myers . No. 00-4830 Civil . Plaintiff . VERSUS . Jay W. Myers . Defendant . DECREE IN DIVORCE AND NOW,---.J" u.n~ 2.7 t , ~l, IT IS ORDERED AND DECREED THAT Sarah M. Myers , PLAINTIFF, AND Jay W. Myers , 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; . None. Marital Serte] "mpnt- ;" ; nl'nrpnr"I-",<J into J:;",t m"'rgl>Q with Diyorce Decree. . c?v~ r ~ROTHONOTARY . J. . AT ~ -- :.... ,-, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . f'''''''' ,. "~~ /, 7 tv;". ?, ~~~," ~ ~< - c:?3 'N ',' C,_"_~.,. , .. .. ,;,.."'~ Mt~<~z;4 ~ ~~ ~4.., z 47f Y7<~ '"" ~- ""_.~ .W~!lI~l$ m._~_ _.'T .. .. --.- ~- . SARAH M. MYERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JAY W. MYERS, Defendant NO. 00-4830 IN DIVORCE MARITAL SETTLEMENT AGREEMENT AGREEMENT, made this ?re. day of ff.~I<M'f ,2003, between Sarah M. Myers (hereinafter called "Wife") and Jay W. Myers (hereinafter called "Husband"). WITNESSETH: 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; 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: I,,;' '<-' .' 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 which may, has been, or shall be instituted by the other party, or from making any just or proper defense thereto. The parties further agree that they will each sign the Affidavit of Consent and Waiver of Notice after the required ninety (90) day time period has elapsed when such a divorce procedure is instituted. 2. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Karl E. Rominger, Esquire, for Wife, and James K. Jones, 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 2 .. - ; br .~'_p 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 fr~e from all control, restraint,' interference or authority, direct or indirect, by the other in all respect's as fully as if she or he wer~ unmarried. Each may reside at such place or places as she or he may 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 ofthe 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 respecti'lefamiliesofeach other, norcompel 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 Wife and Husband do hereby acknowledge they have heretofore divided the marital property, including, but without limitation, jewelry, clothes, furniture and other I personalty, and hereafter, Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or 3 . - , ~'" .~';:.," .~".-" he may have with respect to any of the above items which are the sole and separate property of the other except as st1ed below: fi Siw\. '1;,.. "11-7/($ , r ~ THe OTHM MI!T~" rfiU 1. Il'Wl'l!Hll! a eejl to waive any claim in '.1.'if@'s401(k) Retirement Account and any and 7/i{1/( l\JIU ~ all accounts now in _ n;&rte: 2. Wife agrees to waive any claim to the marital residence and any and all accounts now in Husband's name including any retirement accounts. 3. Each side will retain the vehicles they are now driving and will agree to execute any paperwork necessary to free the other from any lien that may now exist and/or transfer their names off of the titles as appropriate, to the party who has possession of the said vehicle at the time of the signing of this agreement. 4. Husband and Wife have two (2) burial plots at the Westminister Cemetery. Wife will sell her plot to Husband for an amount of Two Hundred Fifty ($250.00) Dollars in lieu of relocating the plot to another place in the cemetery. 5. Husband shall be responsible for the health insurance coverage for their minor child, Brandon Myers, as Wife is unemployed and attending school, and she cannot afford to carry the child on her COBRA Insurance. If Wife obtains employment which would allow her to carry the child for less than $50.00 per month, she will do so. 5. LIABILITIES Wife and Husband each covenant, warrant and represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and 4 M - 0'- '-" liabilities incllrred by the other prior to or after the effective date of this Agreement, except as may be otherwise provided by the terms ohhis Agreement. 6. 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 disputes or unhappy differences which have occurred prior to or which may occur subsequentto the date, hereof. 7. 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 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 5 ;,1 - , ,- ~-~ Iii if- 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, (b) any State, Commonwealth or territory ofthe United States, or (c) any other 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 lite, counsel fees. costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the exe.cution ofthis Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 8. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectually the terms of this Agreement. 6 - - - - II 9. 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. 10. 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. II. 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 shall not be construed as a waiver of any subsequent default of the same or similar nature. This Agreement shall not be modified or amended in any way except by written agreement executed by the both parties hereto. If either party breaches the terms and provisions of this Agreement, refuses to carry out their duty under this Agreement, or otherwise refuses or fail to act in a way detrimental to this Agreement, then the aggrieved party may file an action in the Court of Equity or at Law to enforce the terms, duties, requirements and 7 . .';"- , provisions of this Agreement. If the aggrieved party is successful, the other party is responsible for the aggrieved party's attorney's fees and all Court costs. Further, if any provision of this Agreement, or its application any person or circumstance, is deemed invalid or unenforceable by a Court of; competent jurisdiction, then the remainder ofthis Agreement or the application of such provision of other persons or circumstances shall not be affected thereby, provided, however, that if any provision or application thereof or unenforceable, then a suitable and equitable provision shall be substituted therefore in order to carry out, so far as may be valid, the intent and purpose ofthe unenforceable provision. 12. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared tel 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 ofthe parties. 13. HEADINGS Any headings preceding the text of the several paragraphs and subparagraphs hereof are i inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, construction or effect. 8 ',,," ?IIU ~. ~"' ' C', , L< _0 ""~ '. >~ ! 14. 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. 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. ~ l(frL /z'O/f/~~.er , Witness ~.o.ACJ\ YYl,TR~ Sarah M. Myers, Wife /,./"j {2 ,/ / -}? ~-d/ ~ Witness /' ~~=~ 9 ~ ,f~ _T' "~.~ ..' ~ . ~U . .::.;" t COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the 7tL day O'f hAlf' tI.IIh / subscriber, aN O'tary Public fO'r the CO'mmO'nwealth O'f Pennsylvania, residing in the CO'unty O'f , 2003, befO're me, the Cumberland, persO'nally appeared Sarah M. Myers and in due fO'rm O'f law acknO'wledged the abO've Agreement to be her act and deed and desired the same to' be recO'rded,as' such. _....~"'-~~l Notar'"" Seal i Undll J. Jumper, Nota.'Y Pub"C , Carlisle Boro, Cumbe~and Coun~i My Commission Expires J# 23. 2006 " Member, Pennsytvqnia Association Of Notaries t~1LtlIL 9. W,'rn..au tY I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND tl-o On this, the I '-( day O'f ) : SS. ) A ,o,r I I ,2003, befO're me, the subscriber, a NO'tary Public fO'r the CO'mmO'nwealth O'f Pennsylvania, residing in the CO'unty O'f Cumberland, persO'nally appeared Jay W. Myers and in due fO'rm O'flaw acknO'wledged the abO've Agreement to' be his act and deed and desired e same to' be recO'rded as such. - - .,.-=--..........-=.,..-~~...--=-=-.1 r: NoIaria! Soal, ! D',,< E. Serf'!, Notary Pl~t:,~~c_ ' , 'J'-' r"'I,,'1" l Harrisburg, D!1UP ,,11 --:-J", ';" "'i' -- ~ My Ccmm,'sSi.nn Exn~103 A.t.A",.. .,',': d' ." ". oJ ' - ~__,,=,- " MembZll P8rniSYlvanf& Assocla:dOf' \. . t,,, 10 '" tiM] "'l:]r,il!liil~mJ~*"~AA.'Iif,ljj~lO~~I~!Iki/ii.~OO~i6.\S\~"",,,~,jii1~~~ma~i41f:-Iii' l ", . ~ . . ~~ '- ;0..."",, ~, " ,""=' ~11r:lli!_H JItil!!i[_Jliil.ilii.fH~l 0 '-" r:; g~; ,~.,~ -11 - , , - :'.1) ~~ ".;J l'::':, -< ~-~i :1 1:1 l , .~ -"; SARAH M. MYERS, Plaintiff : IN THE COURTOF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JAY W. MYERS, Defendant : NO. 00-4830 CIVIL TERM : 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. Grounds for divorce: irretrievable breakdown under S 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail and Certificate of Service. 3. Date of execution of the affidavit of consent required by S 330l(c) or The Divorce Code: by the Plaintiff, May 21, 2003; by the Defendant May 22,2003. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in S330l(c) Divorce was filed with the Prothonotary: May 21,2003. Date Defendant's Waiver of Notice in S330l(c) Divorce was filed with the Prothonotary: May 22,2003. Date: ::JrJ1fl- / '1 ,2003 ~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 ~.."'" . '.'~jli\ll-!l!i-j<llm~Hl!l~:!I!!l!l!1l1!W!~li@l!1r,~;i(lJflmhii!iM~1ili~wbf.l. ~w ,..,~ MH ~~ J _'. .. _~ H. ~ -- d!I ","~ lilIllS!Ill'iJIl!lllllllilllW!l:.m- o c. s' -0\:[; Q)~:;::, '~_C ~:'~:- ~(:. -;Y'C: .~ ~ . ~ c:::; (..;) ,- (- ,..0 .,-,1 -""-0 o ~','\ ~.:: ,) l? , -'_. -, , ~ _ ' I '" ,,,,'. ' - '.of..., _" '(.-~,'.~:~" "',' - ",,,-,,--,-'-,,"'i~,,'L--:"--, -.-~. '-b,;i::""~'\-'i SARAH M. MYERS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA Defendant : CIVIL ACTION - LAW : P3u : NO.OV - 'f CIVIL TERM : IN DIVORCE v. JAY W. MYERS 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. Ajudgment 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, P A 17013 Phone: (717) 249-3166 ,- ~~ -.'" ,,'.,. ' 'C. c- -;.__J___+::+"i"~"-,, '.' -~-~~ <j SARAH M. MYERS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JAY W. MYERS, Defendant : NO. CIVIL TERM fJv- 'fF30 : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaintiff is SARAH M. MYERS, who currently resides at 600 North Baltimore A venue, Apt. E, Mt. Holly Springs, Cumberland County, Pennsylvania 17065 since February 2000. 2. Defendant is JAY W. MYERS, who currently resides at 42 Seavers Road, Newville, Cumberland County, Pennsylvania 1724l since 1992. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 27,1981, in Loysville, Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. ~. ~ .', -< ,~ " ~ ,. ,""",,' --,,~ _i 'i . ~--- '" .~ .~;,"" , . ;., :' ,,' n_' .'>..':' ' 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. S 4904, relating to unsworn falsification to authorities. Date: 80 AQ ~ rYl. m~^ n..- Sarah M. Myers, Plaintiff BY:?~~ ./' Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 ( , ,- ,_'" -,-- -',,- ~". . -~~ ,,'-.-k . "..-,-, ""-_,,,. "'0' __" ,-_ _" ',_" o,,,,~', ,_;, '.'~"" . '. '-1:, ,__,_ - ,,;:-;'~''''', .... SARAH M. MYERS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA Plaintiff v. : CIVIL ACTION - LAW JAYW. MYERS : NO. 00 - 4830 CIVIL TERM : IN DIVORCE Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Sarah M. Myers, do hereby certifY that I served a copy of the Complaint in Divorce upon the following by depositing same in the United States Mail, first class postage prepaid, certified mail, return receipt requested, deliver to addressee only, (See attached Exhibit "A") at Carlisle, Pennsylvania, on July 7, 2000, and signed for by the defendant on July 8, 2000, having been addressed as follows: Jay W. Myers 42 Seaver Road Newville, PA 17241 Dated: July 10, 2000 ?/ "--~ /' Karl E. Rominger, Esquire Attorney for Plaintiff ~",;-, ,- , "IM _,_.,'. ,~-; ,'">',',, -, o'L'" ,__' '.. ".',- '~,,- ,-, "~;""<- ~"_i"'.' tI;/ , ".a " ~. "" "C 'in " In ~ l!! $.ENDER: " ".:Complete items 1 and/or 2 for additional services. .J-Gomplete items 3, 4a, and 4b. . Print. your name and address on the reverse of this form so that we can return this . c:at:d to you. II! Attach this form to the front of the mailplece, or on the back if space does not 't!ennit. CD . Write. "Return Receipt RequestedP on the mailpiece below the article number. .c . The Return ReceIpt will show to whom the article was delivered and the date ... delivered. S 3. Article Addressed to: "C" ~ ;:;. 6 u I also wish to receive the following services (for an extra fee): 1. D Addressee's Address~ 2,.%1 Restricted Delivery Consult postmaster for fee. 4a. Article Number !i .~ " '" a '" u a. d'/lY LJ HYeRS q d-- Sect lie. I'" ~ac/ /l!ewtJ,'J!.e... PA /7;)..'-/1 066 -D{g{)~ - :H -'j'gl,s-3 4b. Service Type D Registered D Express Mail D Return Receipt for Merchandise 7, Dat1 eliv db 8. Addressee' Address (Only if requested and fee ispaid) ~Certified D Insured D COD ~ " 'Gl 0:: '" c: 'in " ~ 2 " g, ? .. .c .... 'j ~ " o '" .!; 1p2595-98-B-02'29 DOOl~9tiGfleturn Ipl -- -rn'---'-.- EXHIBIT "A" ,~" - ~,<I~ ' 1'& SARAH M. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA v. : CIVIL ACTION - LAW JAY W. MYERS, Defendant : NO. 00-4830 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on July 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: ~d., \\,.:) N; ~ ~~A.Q/), m. l\;Jl JO/ Sarah M. Myers/Plainti ~~lliiII_~iiUima~MIT"'iHW.i;j.,"".bilo!r#&~'iL~"i",~W~.It.\~ldK.lM~~ ">--u.i'j-'i Ji!j >-',--:,. ,"v:,..;,~.-~ ""'._' o ~ -OCt; ~~r ZC cO '"-;,~ ~C~- "" d::';(~-, L_C-' )>C 2~ -< , It:-~ ,- '- c -, '---' . __~ l --< ;"-..,) :.) f0 ~ ~- ,- " L~" SARAH M. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JAYW. MYERS, Defendant : NO. 00-4830 CIVIL TERM : IN DIVORCE 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. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 ofthe 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 of18Pa. C.S. S4904, relating to unsworn falsification to authorities. Date:~dlalJ ,;Loo3 ~J. C) \)" YY\A~ A 1t~ ~ Sarah M. Myers/Plainti ~~'lf4~!lil~WI"I~W<~j1~~,IiW*,,",~.li,,"1Il~~'lW'~~ . '"", illI"It' .,~~W} ill: L~~ ,--.., ( "I" Q c 7' t)r- r'nrl ?> "<-,.: CO -< ~, ,<e__ , j; ~~:--: ~.:J :..) --< 1'>.-' ",.J >'-, "" ~:;~ , '-.---. " '< I" ^-'" I ,",;- -',~~~_' ~r._'__v"-_,,-.'__~" 0 ;,:;;,:., c-", _^ ,,,-,,"'u~- "-~,,;:,";,_'-,;,~ -_, ""'J SARAH M. MYERS, Plaintiff : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA : NO. 00-4830 CIVIL TERM v. : CML ACTION--LA W JAY W. MYERS, Defendant : IN DIVORCE I AFRIDA VIT OF CONSENT 1 1. A complaint in divorce under 9330l(c) of the Divorce Code was filed on July 07, 1 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. 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. S4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:~ '2.- z.. 1[00;3 ~~~ JA . MYERS .!IlI '::""~_~IilIiW~ _-__.~"": ~hoO' ::C,_ -, ,<;"-" ;;::,' .~-.;.-~ ,,-, .--,..',~- L" :~<" \" ,-" ;, ,,\ -~-,; "'" " ""^'~i e c:l 0 W "i1 ~ :J: --l --.,crl "'" I:n rTlm -< rnf-- Z::o N -TIm Z:i "0 UI . w 56 ~C' ._A -0 ,..,-J..-, ~--n ~.; :x ''70 C' ;3m :;O;c ~ :z w ~ CJ1 ~ , ^, ,'. , _ 'F. ~_~'_ ',~ _ _ '" " d ',' :.>'---d,;'''.' n>_"" .-,: ,_ -, . ",_0 '--i" -;., -,-W"",,",' .,"""""'~, <~ __ ' SARAH M. MYERS, Plaintiff ; IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA I : NO. 00-4830 CIVIL TERM v. : CIVIL ACTION--LA W JAY W. MYERS, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER l3301 ~) 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 e~penses if{ do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I ,VERIFY THAT THE ST'1TEMENTS 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. S4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ('Af\tI z. ~ z.003 JAYW~~ ,..~-, ',';;, ' ~ 'iiiI"""--"~ ,,"' - n1l"-'U""" ~1IlIMim1iii;l- ~ ". ~ ~~,w -" '....' :_:" ,'~'--'.-"''''A';...-\.,,,:,,,, _-"'""'-_,:'_,,,_-'i ",',. ,'<''''''_ ;n_-,' ,-- '"iill~"- ,h --,-', ,,~",<' ,,' :,--,;;.~"':',, , I I I ... . I ',~.. 1.1 I .. 1_ , ~,,; 'I', 0 Gl ~ c: (,,;) il': :% -j ~.H\ ". :,~ ::: -< rn r~~ ::rJ N .'Dm ~> cDO ....,. L ()A :.:;:c; -j - -0 -.~"'T, ,j:JJ )>c :::It 20 ~g ::Jm ~ J.) s;! <.11 ~ . ." ,-~.~ ,'~~ SARAH M. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JAY W. MYERS, Defendant : NO. 00-4830 CIVIL TERM : IN DIVORCE AFFmA VIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 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"/-3- 03 i:i. ~rt[~~ -~'IiIll"~I~~o;M;i"m;~~;,\;;cl't~fu"*~i1%-'!')j,,~~~~ ~~ ,~ ~' -:11 ~ 'u11 .lj ~..'iiOII._.-.lllilllli!illiIU c"" ~; .g/t}~': '.~r -:.~~ '" :'iifr;'1 :.:(1 -".,) en -.'''" , ,"".) J:c- ;'''' ) <-j ::q , .!Ii - .~~ I' ~ ,". 0"-;,\,;, SARAH M. MYERS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JAY W. MYERS Defendant : NO. 00 - 4830 : 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. 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 ofl8 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: I.{ ~ 3 -03 ~.~l~~ "e' tBIJ1~ iJlfI.J[Jl:litW;;ilffif11ill_>Nilm~';J'AAililli~bill,';ml0.~,,:.~l~MI~..V._"~.eI~---"~~' n....~"l' '_~Wili..ll.,j1.!'liiIiii!iflI!l._fi~~1~1!.~8IIi' ,. ", .,.,. I _~:_T ~~cv S~::,: [:::c 4 C', ~~~ ~", -( (") c: <:;) [",,:' <, .~~\ ~.) ~,') en .,~~ :;~~ ::'-=~ 5~ -, .