HomeMy WebLinkAbout00-04873
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
Scott J. Sprucebank
Plaintiff
No.
Civil Term .
00-4873
VERSUS
Michelle L. Sprucebank
Defendant
DECREE IN
DIVORCE
AND NOW,
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2000 ,IT IS ORDERED AND
DECREED THAT
Scott J. Sprucebank
, PLAINTIFF,
AND
Michelle L. Sprucebank
, 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;
N~
ATTEST:
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~NOTARY
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~TALSETTLEMENTAGREEMENT
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THIS AGREEMENT, made this ~ day of July, 2000, by and between MICHELLE
L. SPRUCEBANK, of 436 Sioux Drive, Mechanicsburg, Cumberland County, Pennsylvania,
hereinafter referred to as "Wife",
-AND-
SCOTT J. SPRUCEBANK, of 436 Sioux Drive, Mechanicsburg, Cumberland County,
Pennsylvania, hereinafter referred to as "Husband",
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on November 10, 1991, In
Mechanicsburg, Pennsylvania, and there having been no children born of this marriage; and
WHEREAS, diverse unhappy marital difficulties have arisen between the parties, causing
them to believe that their marriage is irretrievably broken, as a result of which they have separated
and now live separate and apart from one another, the parties being estranged due to such marital
difficulties with no reasonable expectation of reconciliation; and the parties hereto are desirous of
settling fully and finally their respective financial and property rights and obligations as between
each other, including, without limitation by specification: the settling of all matters between them
relating to the ownership of real and personal property; the settling of all matters between them
relating to the past, present, or future support and/or maintenance of Wife by Husband or of Husband
by Wife; and in general, the settling of any and all claims and possible claims by one against the
other or against their respective estate, particularly those responsibilities and rights growing out of
the marriage relationship; and
WHEREAS, Husband and Wife declare that each has had a full and fair opportunity to
obtain independent legal advice of counsel of his or her selection. Further, Wife and Husband are
cognizant oftheir right to legal representation, declare that it is their express, voluntary, and
knowing intention not to avail themselves of their right to counsel and choose instead to allow
Anthony J. Foschi to represent them with respect to the preparation and execution of this
Agreement and the fIling and prosecution ofthe Divorce Documents contemplated herein. The
parties acknowledge that they fully understand the facts, and they acknowledge and accept that this
Agreement, is, in the circumstances, fair and equitable, and that it is being entered into freely and
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voluntarily, 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 improper or illegal a!5reement or agreements.
NOW, THEREFORE, inconsideration of the premises and of the promises, covenants and
undertakings hereinafter set forth, and for other good and valuable consideration, the receipt of
which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to
be legally bound hereby, covenant and agree as follows:
1. SEPARATION. It shall be lawful for Husband and Wife at all times hereafter to live
separate and apart from each other and to reside, from time to time, at such place or places
as they shall respectively deem fit, free from any control, restraint or interference, direct or
indirect, by each other. Neither party shall molest the other or compel or endeavor to compel
the other to cohabit or dwell with him or her by any legal or other proceedings. The
foregoing provision shall not be taken to be an admission on the part of either party of the
lawfulness or unlawfulness of the causes leading to their living apart.
2. SUBSEQUENT DIVORCE. The parties acknowledge that Husband intends to file a
Complaint In Divorce in the Court of Common Pleas of Cumberland County, Pennsylvania,
claiming that the marriage is irretrievably broken under the no-fault mutual consent provision
of Section 330l(c) of the Pennsylvania Divorce Code. The parties hereby express their
agreement that the marriage is irretrievably broken and express their intent to execute any
and all affidavits or other documents necessary for the parties to obtain an absolute divorce
pursuant to Section 330l(c) ofthe Divorce Code as soon as possible. The parties hereby
waive all rights to request court-ordered counseling under the Divorce Code. Neither party
to such action shall ask alimony or support contrary to the provisions of this Agreement. It
is further specifically understood and agreed by the parties that the provisions of this
Agreement relating to equitable distribution of property of the parties are accepted by each
party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania
Divorce Code.
Should a decree, judgment or order of separation or divorce be obtained by either of
the parties in this or any other state, country or jurisdiction, each of the parties hereby
consents and agrees that this Agreement and all of its covenants shall not be affected in any
way by any such separation or divorce; and that nothing in any such decree, judgment, order
or further modification or revision thereof shall alter, amend or vary any term of this
Agreement, whether or not either or both of the parties shall remarry, it being understood by
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and between the parties hereto that this Agreement shall survive and shall not be inerged'into
any decree, judgment, or vrder of divorce or separation. Notwithstanding the provisions of
the Pennsylvania Divorce Code or of any law to the contrary, none of the terms and
provisions of this Agreement shall be subject to modification by the Court or in any fashion
other than as set forth hereinafter. It is specifically agreed, however, that this Agreement
shall be subject to enforcement under the provisions of the Pennsylvania Divorce Code or,
at the option at the aggrieved party, by a suit against the alleged breaching party either in law
or in equity.
3. DEBTS AND OBLIGATIONS. Wife represents and warrants to Husband that, since the
separation, she has not, and in the future she will not, contract or incur any debt or liability
for which Husband or his estate might be responsible, and she shall indemnify and save
Husband harmless from any and all claims or demands made against him by reason of such
debts or obligations incurred by her since the date of said separation, except as otherwise set
forth herein.
Husband represents and warrants to Wife that since the separation he has not, and in
the future he will not, contract or incur any debt or liability for which Wife or her estate
might be responsible, and he shall indemnify and save Wife harmless from any and all claims
or demands made against her by reason of such debts or obligations incurred by him since
the date of said separation, except as otherwise set forth herein.
Each party will assume sole responsibility for payment of all balances due on any
credit cards or other credit accounts in his or her respective individual name. Specifically,
Husband shall be solely responsible for payment of all balances due, if any, on the following
accounts. Said accounts, whether or not Joint Accounts, shall be converted to Husband's
name alone, if applicable. Wife agrees to take whatever steps are necessary to remove her
name from such accounts, if applicable.
A. Shippensburg University Master Card - Acct. No. 5490 9902 4502 3054
B. Discover Card - Acct. No. 6011 0028 10250225
C. Chase - Acct. No. 4225810960037524
D. American Express Blue - Acct. No. 3715 14870831006
E. American Express Corporate Platinum - Acct. No. 37834925993305
F. Members First Credit Card - Acct. No. 4155 3722 2044 3608
G. U. S. Bank - Acct. No. 4190 0508 4712 1070
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Wife shall be solely responsible for payment of all balances due, if any, on the
following accounts. Said ac.counts, whether or not Joint Accounts, shall be converted to
Wife's name alone. Husband agrees to take whatever steps are necessary to remove his name
from such accounts.
A. Wards - Acct. No. 125342027
B. Kohl's - Acct. No. 029 574456900
C. Spiegel- Acct. No. 4211816808
D. Discover Card - Acct. No. 6011 0025 3252 0665
E. Victoria's - Acct. No. Secret 860514751
F. Bon Ton - Acct. No. 051 964823060
. G. Sears - Acct. No. 54 84110 173847
H. PSECU - Acct. No. 4129 3400 0115 7355
Each party shall indemnify and save the other party harmless from any claims,
demands or liability with regard to the debts for which they have assumed responsibility as
set forth herein.
4. MUTUAL RELEASES. Husband and Wife do hereby mutually remise, release, quit-claim
or forever discharge the other and the estate of such other, for all time to come, and for all
purposes whatsoever, from any and all rights, title and interest, or claims in or against the
estate of such other, of whatever nature and wherever situate, which he or she now has or at
any time hereafter may have against such 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 courtesy; or claims in the nature of dower or courtesy, or widow's or
widower's rights, family exemption or similar allowance or under the intestate laws; or the
right to take against the spouse s will; or the right to treat a lifetime conveyance by the other
as testamentary; or all other rights of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory
of the United States, or any other country; or any rights which either party may now 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 provision hereof. It is the intention of Husband and Wife to give to each other
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by the execution of this 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
provision hereof.
5. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. Thepartiesheretohave
divided between themselves, to their mutual satisfaction, all items oftangible and intangible
marital property. Except as otherwise set forth hereinafter, 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 and/or under the control of the other. Should it become
necessary, the parties each agree to sign, upon request, any titles or documents necessary to
give effect to this paragraph. Property shall be deemed to be in the possession or under the
control of either party if, in the case of tangible personal property, the item is physically in
the possession or control of the party at the time of the signing of this Agreement, and in the
case of intangible personal property, if any physical or written evidence of ownership, such
as passbook, checkbook, policy or certificate of insurance or other similar writing is in the
possession or control of the party. Anything to the contrary contained herein
notwithstanding, Husband and Wife shall be deemed to be in the possession and control of
any pension or other employee benefit plans or other employee benefits of any nature to
which either party may have a vested or contingent right or interest, apart from the provisions
of the Divorce Code, at the time of the signing of this Agreement.
6. REAL ESTATE.
A. The parties acknowledge that they are the joint owners of a marital residence situate
at 436 Sioux Drive, Mechanicsburg, Cumberland County, Peunsylvania.
Contemporaneously with the execution of this Agreement, the parties will execute
and acknowledge a deed transferring sole and absolute ownership ofthe said property
to Husband. Wife hereby waives and relinquishes any further claim, title or interest
she may have in the said property. In consideration of Wife's transfer of the said
home to Husband, Husband will pay to Wife the sum of Sixteen Thousand Dollars
($16,000.00), payable in one lump sum on or about June 1, 200l.
Husband shall assume sole and exclusive responsibility for payment of the
outstanding liens against the marital residence with America' s Whole Lender, or their
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successors and assigns, together with all other mortgages and operating costs of the
marital residence. Further, Husband shall iademnify and save Wife harmless from
any claim, demand or liability thereon.
B. The parties acknowledge that they are the Joint Owners ofa property at 710 W. Main
Street, Mechanicsburg, Pennsylvania. Contemporaneously with the execution ofthis
Agreement, the parties wilt execute and acknowledge a deed transferring sole and
absolute ownership of said property to Husband. Wife hereby waives and
relinquishes any further claim, title or interest she may have in said property. In
consideration of Wife's transfer, Husband will pay to Wife the sum of Thirty-Five
Thousand ($35,000.00) at the signing of this Agreement. Husband will attempt to
remove Wife's name from the mortgage on said property; however, there is no
obligation on the part of Husband to refinance said property. Husband shall assume
sole and exclusive responsibility for payment of the outstanding liens against the
property with Keystone Financial, or their successors and assigns, together with all
other mortgages and operating costs of the aforesaid property. Further, Husband
shall indemnify and save Wife harmless from any claim, demand or liability thereon.
7. VEHICLES. Wife shall retain possession and ownership of the 1994 Corvette, which is
presently in her possession, free and clear of any claim, right, title or interest in said vehicle
on the part of Husband. Wife shall be solely responsible for payment of the remaining
balance due on the encumbrance on the said vehicle.
Husband shall retain possession and ownership of the Lincoln Navigator which is
presently in his possession, free and clear of any claim, right, title or interest in said vehicle
on the part of Wife.
8. STOCK AND OTHER AGREEMENTS. For good and valuable consideration, which
is hereby acknowledged by Wife, Wife agrees to transfer any and all interest which she may
have in D & A, Inc. ("Company") to Husband, free and clear of any claim, right, title or
interest in said Company on the part of Wife. Further, Wife shall, immediately upon
execution of this Agreement, resign as an officer and director of said company. Wife shall
be allowed to continue her employment with said company at her current salary and she
agrees to work between 40 and 50 hours per week. Nothing contained herein shall be
construed as a contract for employment, but rather, such continued employment shall be at
the mutual consent of Wife and Husband. Wife acknowledges that she is an "Employee-At-
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Will" with D & A, Inc. If Wife leaves the employment of D & A, Inc. for any reaSon,
including but not limited to the mutua: consent of the parties, or being terminated by
Husband or Company, said termination may not occur any earlier than one (1) year from the
date of this Agreement, Husband agrees to continue to pay Wife her then current salary for
a period of six (6) months from the date Wife leaves said employment. Such payments shall
be made on the normal pay schedule for D & A, Inc. in effect at that time. Wife shall
cooperate with Husband in any filings required with the Pennsylvania Liquor Control Board
to effectuate her removal as an officer, director and shareholder of D & A, Inc. and her
replacement as Manager on such license.
9. TAXES. By this Agreement, the parties have intended to effectuate and by this Agreement
have equally divided their marital property. The parties have determined that such division
conforms to a right and just standard with regard to the rights of each party. The division of
existing marital property is not, except as may be otherwise expressly provided herein,
intended by the parties to constitute in any way a sale or exchange of assets, and the division
is being effected without the introduction of outside funds or other property not constituting
a part of the marital estate. As a part of the equal division of the marital property and the
marital settlement herein contained, the parties agree to save and hold each other harmless
from all income taxes assessed against the other resulting from the division of the property
as herein provided.
The parties acknowledge that they have filed various joint income tax returns during
the course of their marriage. In the event that any additional taxes, penalties or interest are
assessed as a result of any such j oint return, the party responsible for under-reporting income
or claiming any improper deduction shall indemnify and save the other party harmless from
such tax liability, penalties, interest, attorney's fees or accountant's fees. The parties agree
to file such tax returns for the tax year 2000 as is most beneficial to the parties.
10. DISTRIBUTION OF CASH ASSETS. The parties acknowledge thatthey equally divided
their cash accounts at their separation. Each party shall retain any funds received from said
accounts as their sole and separate property, together with any balances currently held in any
bank, credit union or other depository accounts in his or her individual name.
11. PENSION, PROFIT-SHARING, RETIREMENT, CREDIT UNION OR OTHER
EMPLOYMENT -RELATED PLANS. The parties hereto expressly waive and relinquish
any right, claim, title or interest in any pension, profit-sharing, retirement, credit union or
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other employment-related plans in which the other has any interest by virtue o'fhis or her
pasi or present employment, Vi hether vested or unvested, matured or unmatured. The pa.ties
agree that they shall immediately upon request execute any waivers or other documents as
required by the other party s Plan Administrator to effectuate the provisions of this
Paragraph.
12. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time to time at the
request ofthe other, execute, acknowledge and deliver to the other party any and all further
instruments or documents that may be reasonably required to give full force and effect to the
provisions of this Agreement.
13. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing and executed with the same
formality as this Agreement. The failure of either party to insist upon the 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.
14. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties,
and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
15. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience
only. They shall have no effect whatsoever in determining the rights or obligations of the
parties.
16. INDEPENDENT SEPARATE COVENANTS. It is specifically understood and agreed
by and between the parties hereto that each paragraph hereof shall be deemed to be a separate
and independent agreement.
17. BREACH. If either party breaches any provision of this Agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach or to seek such other
remedies or relief as may be available to him or her, and the party breaching this contract
shall be responsible for payment oftegal fees and costs incurred by the other in enforcing his
or her rights under this Agreement, or in seeking such other remedies or relief as may be
available to him or her.
18. APPLICABLE LAW. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
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19. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then unly 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.
20. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding on and shall
inure to the benefit of the parties hereto and their respective heirs, executors, administrators,
successors and assigns.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and
year first above written.
WITNESS:
(SEAL)
SCOTT J. SPRUCEBANK
9
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
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On this day of July, 2000, before me, the undersigned officer, personally appeared
Michelle 1. Sprucebank, known to me (or satisfactorily prove to be the person whose name is
subscribed to the within Agreement, and acknowledged that sh ecuted the same for the purposes
therein contained.
NOTARIAL SEAL
ANTHONY J, FOSCHI, Notary Public
e.mp Hill Bcro.. Cumberland County
My. e.>mmission Expires August 11, 2001
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
Notary Public
My Commission Expires:
SS.
On this rf'^ day of July, 2000, before me, the undersigned officer, personally appeared Scott
J. Sprucebank, known to me (or satisfactorily proven) to be the person whose name is subscribed to
the within Agreement, and acknowledged that he executed th e for the purposes therein
contained.
NOTARIAL SEAL
ANTHONY J, FOSCHI, Notaty Public
Camp Hill Boro" Cumberland County
My Commission Expires August 11, 2001
0120193
My Commission Expires:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
SCOTT J. SPRUCEBANK
Plaintiff
v,
DOCKET NUMBER: 00-4873 Civil Term
MICHELLE L. SPRUCEBANK
Defendant
ACTION IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO TIm PROTHONOTARY:
Kindly transmit the record, together with the following information, to the Court for entry of a Divorce
Decree:
L Grounds for divorce: Irretrievable breakdown under 23 Pa.C,S,A. ~330l(c) of the Divorce
Code,
2, Date and manner of service of the Complaint: Personal Acceptance of Service by: Defendant,
on July 17, 2000, a copy of which is attached hereto and incorporated herein.
3, Date of execution of the Mfidavit of Consent required by ~3301(c) of the Divorce Code by
Plaintiff October ~ 2000; by Defendant October 2.D ,2000,
4, Related claims pending: Post Nuptial Settlement Agreement which is to be incorporated but
not merged into final Decree.
Date: OctoberZA> , 2000
By:
J20577
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SCOTT 1. SPRUCEBANK
Plaintiff
v.
DOCKET NUMBER: IJ-1J - lj l' 7 3 ~ I-RA.-
MICHELLE 1. SPRUCEBANK
Defendant
ACTION 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 armulment 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 counseling is available in the Office of
the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania 17013.
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. IFYOU
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.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 240-6200
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SCOTT J. SPRUCEBANK
Plaintiff
v.
DOCKET NUMBER: &0. <.f SO 7 3 ~-J T ~
MICHELLE 1. SPRUCEBANK
Defendant
ACTION IN DIVORCE
COMPLAINT
COMES NOW, the Plaintiff, Scott J. Sprucebank, by and through her attorneys, Anthony
J. Foschi, Esquire, and Shumaker Williams, P.C., and respectfully files this Complaint requesting
the Court to enter a Decree of Divorce and in support thereof avers as follows:
1. Plaintiff is Scott J. Sprucebank, who currently resides at 436 Sioux Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is Michelle 1. Sprucebank, who currently resides at 436 Sioux Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
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 the Defendant were married on November 10,1991, in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6, The marriage is irretrievably broken.
7. Plaintiff and Defendant have been advised that counseling is available and that
Plaintiff and Defendant may have the right to request that the court require the parties to
participate in counseling.
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WHEREFORE, the Plaintiff requests that this Honorable Court enter a decree of divorce
pursuant to 23 Pa. C.S.A. ~3301(c).
Date: 1#;0 - 00
By:
th . oschi, 1. 895
P.O. Box 88
Harrisburg, P A 171 08
(717)763-1121
:120125
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VERIFICATION
I, Scott 1. Sprucebank, hereby affirm that the information contained in the foregoing
Complaint is true and correct to the best of my knowledge, information and belief. I hereby
acknowledge that the facts set forth in the foregoing document are made subject to the penalties
of 18 Pa. C.S. 94904 relating to unsworn falsification to au
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
SCOTT 1. SPRUCEBANK
Plaintiff
v.
DOCKET NUMBER: 00-4873 Civil Term
MICHELLE 1. SPRUCEBANK
Defendant
ACTION IN DNORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 3301(c) of the Divorce Code was filed on July 10,
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.
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.
I, Scott 1. Sprucebank, hereby affirm that the information contained in the foregoing
Affidavit of Consent is true and correct to the best of my knowledge, information and belief. I
hereby acknowledge that the facts set forth in the foregoing document are ma
penalties of 18 Pa.C.S. 94904 relating to unswom falsificatio t a
Scott 1. Sprucebank
Date: October ~, 2000
: 120572
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
SCOTT J. SPRUCEBANK
Plaintiff
v.
DOCKET NUMBER: 00-4873 Civil Tern
MICHELLE 1. SPRUCEBANK
Defendant
ACTION IN DNORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 3301(c) of the Divorce Code was filed on July 10,
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.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses i[l do not claim them before a divorce is granted.
I, Michelle 1. Sprucebank, hereby affirm that the information contained in the foregoing
Affidavit of Consent is true and correct to the best of my knowledge, information and belief. I
hereby acknowledge that the facts set forth in the foregoing document are made subject to the
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penalties of 18 Pa.C.S. g4904 relating to unswom falsificatiolf~'authorities. /, //
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Date: October '""Z.f), 2000
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
SCOTTJ.SPRUCEB~
Plaintiff
v.
DOCKET NUMBER: 00-4873 Civil Term
MICHELLE 1. SPRUCEB~
Defendant
ACTION IN DNORCE
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 in do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S 4904 relating to unsworn
falsification to authorities.
ScottJ. Sprucebank
Date: October ~, 2000
:120576
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SCOTT J. SPRUCEBANK
Plaintiff
v.
DOCKET NUMBER: 00-4873 Civil Term
MICHELLE 1. SPRUCEBANK
Defendant
ACTION IN DNORCE
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 in 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.
Date: October Z-O, 2000
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 re . g:le1Iflswom
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SCOTT J. SPRUCEBANK
Plaintiff
v.
No,: 00-4873 Civil Term
MICHELLEL.SPRUCEBANK
Defendant
ACTION IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint. I certify that I am au . zed to accept service
on behalf of defendant.
or Authorized Agent
J/zk~
103 Green St., Mechanicsburg, PA 17055
:120595
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