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HomeMy WebLinkAbout97-00120 \ .J It U q., >- ~ - . . ') - I t'- <:3'"' <:) '< ~ ~' , ' ~:; ~:' '''1 ~I '..1 ~ .'. ~ :1' .. ~ ~ ~ .~.~..~..~.~..~.~.*,~.~.~~..~.~..~..~..~.,~..~..~~.~..~.,~.~.~.~.~.~.~.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~' ~~~~! \. ~~.#,;,.( STATE OF PENNA. JOANNE C. BABAIAN, Plaintiff ;'\(), 97-120 ~ \'~'J'.';II:; "'i ~ ROBERT C. CYPCAR. ~ Defendant ~ ~l' .. ~, , , ,',I ~I ') ~, ') ~I .. ~ ~ ~ ~ ~ DECREE IN DIVORCE AND NOW", ,;J,.".I.)- ,l~""""""" 197,'7". it is ordered and decreed that" , " ' , " " , ,J,OANNE ,c,, ,BABAIAN., , , '" , ," , , '" ' .". plaintiff, and..,..",....,..,...., ,ROBERT, C:, CYPCAR",.."""....,.., 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; '.. ~ ~ No claims raised. ~ ~ ~ ~ ~ n v T h. C" 1I r t :~ fi.' ~ I p' }' ;~ .(,.{/c....o / C.,C r ( ^lh'~I:. '"-':.. . . /1 .,.' ,,}. _ /" J, f/~'''' l_oi"-,, ! <../(;/"". /:''''''' (:',< .,-;'....._ tl. .. - 1 / (' '-~...~/:L~/Itl- ,r _-?--~. .(...... ,,'-t~ " ,..' Prolh()I1(lliH~' ~ ~I ~I ~, . , '.~:, .~:' -:.:' ,:.:- .:.;. -:.:- .:.:- -:.:. .~.~.,~.~,~..~.~~,.~..~.~..~..~.~..~..~,~.~..~:.~:'~. ~ \ ,\ ,... i~ ~ , I~ /'.' I... ," I~ i'.f I~ * S ~ ~ S ~ .. ~ ~ '.' ~ .. ~ " ~ )~ i~ ".' I... ~ ( . I S I , ~ , ~ , ~ ;~ ) i~ I,., I~ i :!. ~ , ~ ~ :~: ~ :~ ~ e f. ~ :~ ,:.:- t.l\d1Y\a9l1lll.0rd JOANNE C. BABAIAN, IN THE COURT OF COMMON PLEAS Plaintiff . CUMERLAND COUNTY, PENNSYLVANIA . v. NO. 97-120 IN DIVORCE . . ROBERT C. CYPCAR, CIVIL ACTION - DIVORCE Defendant ORDER AND HOW, this IS tl. day of Jelll , 1997, the property settlement Agreement between the parties dated June 19, 1997, and attached hereto is hereby incorporated into the Decree in Divorce. BY THE COURT: { ~ , - .. . _. j TO \'aU ARB "SREBY IlOTIPlBD TO PlU! " ftITI'IIll REIll'OIlBB TO TIIB SIlCLOBBD wmtIN 1WIlNfY (1Ol DAYS FlUJIo\ BBIlVICB HBREOf OR "JUDOMBNI' MAY BB BNl'BRED AOIJIlST \'aU BY LAW OFFICES HAHAllS liI KOUNOUPlS "PROPBBB'iOllAL cORPORATIOIl PARK p\.\ZA MOO BATH PllCll . Burrn 100 BBTII1.BHBM. PBIlNSYLVANIA leD17-2@ (b10) 1Ib5.2(:D8 NOV 1 6 199~~ WllDO HJlRBIIYCBJmpYTHAT ~ TIIB wrnuN IB" TRUB AIlD CXllIIlIlC\'CXlI'l'oPTHB()llI(lIIlAL PIUID IN THIS ACI101l BY "TTORIlBY "TTORIlBY tl\.qm'b.b~l.n..b.\~M'l ^GRE~~MENT qr(t THIS AGREEMEHT, made tllis I - day of ,,-)7', N t.- , 1997, by and between JOANNE C. BABAIAN, of Cumberland County, Pennsylvania, (hereinafter referred to as "Wife"), and ROBERT C. CYPCAR of Cumberland County, Pennsylvania, (hereinafter referred to as "Husband"); WIT N E SSE l' II: WHEREAS, Husband and Wife were lawfully married on April 22, 1995, in Mechanicsburg, Cumberland County, Pennsylvania, and, WHEREAS, no children have been born of this marriage. HOW 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: 1. Disclosure of Assets. Each party asserts that he or she has made a full and fair disclosure of all of the real and personal property of any nature whatsoever belonging in any way to each of them of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each party, and of every other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consider- ation made by each party for entering into this agreement. -1- 2. Preoaration of AQreement. This agreement has been prepared by the attorney for the Wife. Each party has been represented by an independent attorney, who was selected by the party whom he or she represents, in the negotiation of this agreement. This agreement has been fully explained to each party by that party's attorney. Each party has carefully read this agreement and is completely aware, not only of its contents, but also of its legal effect. 3. Lawfulness of Seoaration. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 4. Freedom from Interference. Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. Release of Claims. Wife and Husband each do hereby mutually remise, release, quit-claim 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 -2- 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 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 curtesy, or claims in the nature of dower or curtesy of 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 willi 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 of the 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 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 obliga- tions of whatsoever nature arising or which may arise under this -3- agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 6. Warrantv as to Future ObliQations. Each party repre- sents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable, and that except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold the other party harmless from and against all future obligations of every kind incurred by them. 7. Personal Prooertv. Both parties herein agree that any of Wife's and/or her children's household goods, personal effects, clothing, kitchen appliances, kitchen ware, washer and dryer and other personal items that were brought into the marriage still remaining in the marital home after this agreement is signed will be removed within thirty days of the signing of this agreement. Husband agrees to provide ample time for the removal of Wife's property from the home during this time period. Husband further agrees not to hinder, harass, or in anyway, or at anytime, prevent Wife from removing her property from the home. Husband agrees not to destroy, discard, remove, hide, give away, donate, sell, or deny wife of any of her personal property. Husband is to allow Wife full and free access to those areas of the marital home where items may be stored to remove Wife's property. Husband agrees to cooperate with the removal of anything that may block Wife's access to -4- and removal of her personal property from any stored area. Any property that should remain in the marital home after said date will become the sole and separate property of Husband. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. B. Cash. All cash presently in the possession of either party shall be and remain their separate property, free and clear of any claim whatsoever on the part of the other. 9. Prooertv Hot Provided For. The parties hereto agree that they have, by the terms of this agreement, settled, to their mutual satisfaction, all rights that either may have in their property, whether owned by them jointly or separately, real and personal, and wheresoever situated. Any property not specifically provided for in this agreement, which the Husband or Wife owns or has the right to control or possess, shall be and remain his or her property, free and clear from any claim on the part of the other. 10. Real Estate. Wife hereby agrees to convey, transfer and grant to Husband her right, title and interest in the real estate situated and located at 224 Ewe Road, Mechanicsburg, Cumberland County, Pennsylvania, contemporaneous with Husband's payment in full of the sum of THIRTEEN THOUSAND AND FIVE HUNDRED DOLLARS ($13,500) to Wife, and Wife's full release from the existing mortgage on said property. From the date of this agreement, Husband agrees to assume as his sole obligation any and all mortgage payments, taxes, claims, damages or -5- f ( I r i other expenses incurred in connection with said premises, and Husband obligation. Husband shall deliver to wife this same sum of THIRTEEN r I I I I , , , I I I I ! agrees and covenants to hold Wife harmless from any such liability or THOUSAND AND FIVE HUNDRED DOLLARS for said property simultaneous with Wife's execution of all papers necessary to have a final decree in divorce entered in the Court of Common Pleas of Cumberland County, Pennsylvania. Husband shall be solely responsible for all maintenance and repair, mortgage payments, insurance payments, taxes, claims, demands or other expenses including but not limited to water, cable television, electric, trash and sewer incurred in connection with said premises and Husband agrees and covenants to hold Wife harmless from any auch liability or obligations. 11. Waiver of Alimonv. The parties herein acknowledge that by this agreement they have each respectively secured and maintained a substantial and adequate fund with which to provide themselves suffi- cient financial resources to provide for their comfort, maintenance and support in the station of life in which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, support, alimony pendente lite or maintenance. It shall lJe from the date of this agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 12. pavment of Attornev Fees. Each party of this agreement hereby agrees that each of them will be solely responsible for the full payment of all attorney's fees and other costs heretofore and hereafter -6- incurred, respectively, by each of them in connection with the negotia- tion, preparation, and execution of this agreement, and in connection with any action commenced by either party with respect to the divorce of the parties. Each party further agrees hereby to indemnify and hold the other party harmless from any demand, claim, loss, cost and expense (including additional attorney's fees) arising from a failure to pay all of the aforesaid attorney's fees and other costs. 13. Informed and Voluntary Execution. Each party to this agreement acknowledges and declares that he or she, respectively: a. Is fully and completely informed as to the facts relating to the subject matter of this agreement and as to the rights and liabilities of both parties. b. Enters into this agreement voluntarily after receiving the advice of independent counsel, free from fraud, undue influence, coercion or duress of any kind. c. Has given careful and mature thought to the making of this agreement. d. Has carefully read each provision of this agreement. e. Fully and completely understands each provision of this agreement. 14. Subsequent Divorce. The parties hereby acknowledge that Wife has filed a complaint in divorce in Cumberland County to Docket No. 97-120, claiming that the marriage is irretrievably broken under Section 330l(c) of the Pennsylvania Divorce Code. Husband hereby expresses his agreement that the marriage is irretrievably broken and expresses his -7- intent to execute any and all affidavits or other documents nocoooary for the parties to obtain an absolute divorce purBuant to SBction 330l(c) of the Divorce Code at the samo time aB ho oxocutoo thio agreement. The partieB hereby waive all rightB to requeBt court ordered counseling under the Divorce Code. It is further specifically under- stood and agreed by the parties that the proviBions of thio agreement ao to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatooever aD contemplated by the Pennsylvania Divorce Code. Should a decree, judgment or order of divorce be obtained by either of the parties in this or any other otate, country or juriudiction, each of the parties hereby consents and agrees that thia agreement and all of its covenants shall not be affected in any way by uuch aeparation 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 partieD uhall remarry. It is the specific intent of the partieD to permit thiu agreement to aurvive any judgment and to be forllver bi nding and conclusive upon the partiea. 15. Mutual Coooeration. The lIuaband and the wife ohall each concurrently herewith, or at any timo hereafter on tho demand of the other, execute any other documento or inotrumenlll, and do or cauoo to bo done any other acts and things au may be neceaoary or convenient to carry out the intents and purpoaea of thia agreement. -8- 16. Severabilitv. If any provision in this agreement is held by a court of competent jurisdiction to be invalid, void, or unenforce- able, the remaining provisions shall nevertheless continue in full force and effect without being impaired in invalidated in any way. 17. Reconciliation. If there should be a reconciliation of the parties after the date of execution of this agreement, this agreement shall nevertheless continue in full force until it is modified or abrogated by another written instrument to that effect signed by each of the parties hereto. lB. Future Earninqs. All inco.ne, earnings or other property received or acquired by either party to this agreement on or after the date of execution of this agreement shall be the sole and separate property of the receiving or acquiring party. Each party, as of the effective date of this agreement, does hereby and forever waive, release and relinquish all right, title and interest in all ouch income, earnings or other property so received or acquired by the other. 19. waiver of Riqhts. Each of the parties hereby irrevocably waive all rights which he or she may have to request any court to equitably distribute the marital property of the parties or to have alimony, alimony pendente lite or counsel fees awarded to either party, it being the express intention of the parties hereto to fully settle all claims which they have with respect to each other in this agreement. Each of the parties further agree to consent to the entry of a Decree in Divorce. -9- 20. Waiver of Breach. The waiver of any term, condition, clause or provision of this agreement shall in no way be deemed or considered a waiver of any other term, condition, clauoe or proviaion of this agreement. 21. Survival of Aqreement. If any term, condition, clauoe or provision of this agreement shall, by ito reaoonable interpretation, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the partieo hereto, oaid term or terma, condition or conditions, clauue or clnuDeD, provision or provisions, shall be so construed, being the exprlluU intention of both parties hereto to have this agreemont govern thoir ro14tionahip now or hereafter, irrespective of their marital utatuu. 22. Jurisdiction. This agreoment uhali be construed under the lawa of the Commonwealth of Pennoyl\'ania, and both parties consent and agree to the jurisdiction of the Court of COllunon Pleao of Cumberland County, Pennsylvania, on account of any uuit or action brought with reapect to this agreement or any provioionD or maltero referred to in any provisions thereof. 23. Aqreement BindinQ on Partie. and Heir.. This agreement shall be binding in all !to terms, conditionu, clauaes and provisions of the parties hereto and their reapective heira, administrators, executors and assigns. IH WITNESS WHEREOF, the partieD have hereunto set their hands and seals the day and year above firat written. -10- IH WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year above first written. (~t'&VH t ( OANNE C. 3, , L ,J.,n, tJ.--,J BAaAIAN (SEAL) ROBERT C. (SEAL) . I ~. -11- .rOANNE C. IlAIlAlArl, IN TIII~ COURT OF COMMON PI.I::^~; Pinlntil'r : CUHOERl.^ND COUNTY, PENNSYI.V^NI^ VS. CIVIL DIVISION : NO. ')7-120 CIVIL TERM ROBERT C. CYPCAR, : Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S3301(c) XlJM:kt!!~)(x},(k of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Jan. 10, 1997, Certified Mail, Restricted Delivery, Return Receipt Requested, postage prepaid. J. Complete either paragraph (a) 0" (b). (a) Date of execution of the affidavit of consent required by SJJOI(c) of the Divorce Code: by plaintiff June 19, 1997 by defendant .Tune 19. 1997 (b)(l) Date of execution of the affidavit required by of the Divorce Code: : (2) Date of filing S330l(d) and service of the plaintiff's affidavit upon the r~spondent: 4. Related claims pending: NO CLAIMS RAISED 5. Complete either (a) or (b). la) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff'o filed with the Prothonctary: Date defendant's filed with the Prothonotary: Waiver of Not.ice in 9 -II' ~'1-- S3301(c) Divcrce was Waiver of Notice in 7 - /1 7' T- S3301(c) Divorce was ------:. .------'- , - ' --; Elizabeth B. Stano, I ./ Attorney ~~~~l!~) !i -,." <' :;i.. ~ 1 ~ ..0 ~ <:l ~j . t..\ ....... r\ \' ..... f'l. '::r- (:: . ~ ~ \:. "YO ~~ !.,l....t ~ ~ c;>z '-:! ',),'t. e. l--;1;;~ 'I;:) ~ e. :''In 'i:) . ':J~ ~ 'lrJ !S (,.... .so f~i ......o~ ill '. - ti ...... ~ .. .iT",-'--,c ,-; ,''C) ..', fr. :=; "~~':~''- ~ ~ ,..' .~. ~ ,~ r 2;l;'-,-: :; ~, ~ ",:" ",~ -. .~ r- ",' Q' "_;:..~'f:--J/-.-' , ".--",,;.' )-i~.~-t,fi:<~: ~~~~~1t:,~ ":;~;~ \ ~ \ .... ~ ~\i\~ .... .... \ ~ 1 \\\\\ J .... ~~ ~P< ~ <.) t Ole .~ ~ ~. \ p;l . \> . . .., .., i i 0' ~ . ... "ifHlJ~.~~:- ,-,'- ' 1:i?,~.~ :,'-, :'<~.' 'Ji,\',. ~i: . r~~;; ~~ . ,\'5 ..~~~~...H i\1,~ l ,,', ' I,~A :i.'~'-:? ~ ~"~ "", I'u\ I '0," Q . ~ .~ ",' , ,,'l' ~ ;'1,::-,::' ~ ~ {~?'~'_"_; I ,..".' 1l!!l 0 ;;,i~>-' H \Z1 0 'J;;'::'.':"" ;,?~.(,,__.,A" c::.. . . --_.' - 4 . JOANNE C. BABAIAN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 97 - /20 Cu.A-it. ~-t-~ ROBERT C. CYPCAR, Defendant . . CIVIL ACTION - LAW IN DIVORCE HOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pageo, 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 requeat marriage counaeling. A list of marriage counselora is available in the Office o~ the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. IN YOU DO HOT 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 HOT 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. Court Administrator Fourth Floor Cumberland Countv Courthouse Carlisle. PA 17013 Telephone: (7171 240-6200 tl\dlv\b.~.l.n.com\l-'l v. I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA NO. c,')./.Jv <ll~JJU''1 JOANNE C. BABAIAN, Plaintiff ROBERT C. CYPCAR, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is Joanne c. Babaian, an adult individual, who currently resides at 224 Ewe Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant in this action is Robert C. Cypcar, an adult individual, who currently resides at 224 Ewe Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both the Plaintiff and the Defendant have been bona fide residento of the Commonwealth of Pennaylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on April 22, 1995, in Mechanicsburg, cumberland 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 Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. -1- I U\d1v\1lu,llu'V.dt JOANNE C. BABAIAN I I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. NO. 97-120 ROBERT C. CYPCAR, CIVIL ACTION LAW Dsfendant IN DIVORCE .AFFIDA vrr OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) ss. COUNTY OF CUMBERLAND ) I, ELIZABETH B. STONE, of Stone LaFaver & Stone, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Robert C. Cypcar, at 224 Ewe Road, Mechanicsburg, PA 17055, by United Stateo Certified Mail, postage prepaid, restricted delivery on January 10, 1997, as evidenced by the attached Certified Mail return receipts. ~7'- ELIZABETH B. STONE" ESQUIRE / , ....... ! ,/~/ ." SWORN TO AND SUBSCRIBED befQ~e me this /~~ day of \J.1""A"r-- I 1997. 'I / ,/ IG1ve R. ~..1ri:! [...1,11 ~~l.J.x>L;:I'o:,'YPt.!k My "'~_~.' ElotO. ell.' -.cOiro Carlt, VUlIIlIIl:o:Dl GcpIC:: 'f~-....dl ~7. 1997 'lmJer.F~~ ~ '1/1 '/: ~' I 1'''f,J, Notil Y pubhc r) '""IAlOS Idl"'IU wnl'U DUlin JO, noA ~UI~i ~~ I'J ~J8 I H 'jJi1 ~D~ g lh~J~ ~ isi Hi~~j!Cl) Jl~ h --; ~~!~ilrtp i ~ u i d } Jl J i ~~ ~ ~ ~Z ~ 0.. ~ ODD...: oi ~ ! H II i ~i j z !; I ~ ~ II I j i fi H 6 ~ )i ~~I R i ; ~~~ ~ h ~ ..lEi j ~lt ~ ffi.:~~! ~~I G Q!l~Q'i' ~ II ffiHn~ h ~ en... . .. M P 305 515 87~ \RECE~~~. \~"~~ ~~~~I~!~~ ,MAIL \ ,r ILIl :'!l ~ ~,1' .',\11 IJ l I ISf't-' nl'H'f~I'! ~ i '"'""" Mr. Robert C. CYPcllr " : ~ 212',; 'IE~~1 Road ____~_ o ~ M~ch~~r~i~~(rg',_.!'.~ 17055 _ , 1',,\1.11" !;;!:J ,/0 C.'ft,!,-" 'PI' SI'/'( "I: [J('I,.l'r~ r I'" Rt'~~~;; Ot'I'~f'r~ f~- ----;;---.- .,( , ) ____.________ _---f_._ fl,'T"ttlHI'(P!,I',ho,rO'f'lj I ' IfI ~~~,::~r~,~~_ _:/, , .. .. - IIl'Tl.'''"I'll'I'! \!'Olo'I"jT.> Ilf',.'''' [),Ih' ,1"l1 A't'!'l",', ill n.",.l"', . ~ lOTAII'Il\l'I~~,'fl,~::, ~i'.. !J L;(} g l"l~I"',IP~ ~f tN!' :!l E o !. ... '" Q , \' t') ,,'~.h" . " " " 0.. >. u '" '" o t-- ~ ( ,< i5. '~ II: E :J Qj II: ,II 1ii ~ o o / ), ~l'::) t1-1 t/ j LIPI" '"JIA" '11\ uo Plllldwo. SS3UOOV NUni3U JnoA "I <: <l. I .~ i!:. >. .. CD ..,1... ip-~ ~ ilI)( u. Ifi rO ~ . "" o '0 ~ " :J "'0.0 ,,~ Ul III tJ .0 CD.~ o =' <: ~"1'" .<: . " tJ ,bNIll _'. N ~ t.l\d1v\lMw~iv..not JOANNE C. BABAIAN , IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. NO. ROBERT C. CYPCAR, CIVIL ACTION IN DIVORCE Defendant WAIVER OF HOT ICE OF INTEHTIOH TO REQUEST ENTRY OF DIVORCE DECREE UHDEK S3301(c) OF TH~ 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'a fees or expenses if I do not claim them before a divorce ia 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 IB Pa. C.S. S4904 relating to unsworn falsifica- tion to authorities. ~t" {!. ~- JO E C. BABAIAN, Plaintiff Date: ~1I/1\1 / ?i/QCj 7 tl\d1v\1.~1v..not JOANNE C. BABAIAN , Plaintiff ~ I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : I NO. 97-120 : ROBERT C. CYPCAR, Defendant CIVIL ACTION IN DIVORCE . . WAIVER OF NOTICE OF INTENTION TO REQUP.ST. ENTRY OF DIVORCE DECREE UHDER 53301(c) OF THE DIVORCE CODE I. 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'a 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 thio affidavit are true and correct. I understand that false statements heLein are made subject to the penalties of IB Pa. C.S. S4904 relating to unsworn falsifica- tion to authorities. Date/It-: lr~) ( I .//11 , Defendant