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HomeMy WebLinkAbout97-00679 '\r ~ \l ~ cJ III '> ~ ':t Q,I ~ ~ ~ iJ .~; . to- . ~ ~ \ .."." " .:+:. .:+:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:. .:+:. .:+:. -:+:. .:+:. .:.:. .:Jj. :..: ":.:' .:+:. -:.:: ::~:- :. ':+::~':!:" '.:+~' . .:~;: .::!~:--'-:.!::_::.:'~'~:~:!::~ .;~ '~ ~ ',' '=, -.'1 ~~ ~:'I ~i -.' ~' ---~--,-..,---,--~- ,---.----,-~-. ,- IN THE COURT OF COMMON PLEAS ~i ~I ~l ~I :\ "'/ ~ COUNTY OF CUMBERLAND ~. .,~,~ 'C~~~~ \. ...~.".,# .-r PENNA. STATE OF Renee Conrad ~ 97-679 ;'\ (), 19 Plaintiff s ~) ~j \'1' 1'."; \L'; Robert L. Conrad ~ Defendant ~ ~I' ~ . , ~i .., 'I ~) " ~ DECREE IN 'IiJ D I Y{! R'~9f~,~:~:A AND NOW, . . . " plaintiff, , defendant, ,', * decreed that and Robert L,Conrad ~I .. ~I .. ~l 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; It is further Ordered that the provisions of the Marriage Settlement Agreement dated July 29, 1997 between Plaintiff and Defendant and filed in this action arc incorpOrated herein and. l1\,dC! apart:. hereof. by. reference thereto, but shall not merge herein. A copy of said Agreement is attached hereto'IlS Exhibit "A" ~ ~ ~ ~ ~ Prolhlll1ol;,ry ~ ~ ~l '.', ~I "', ~( , f ~' 7 .~;. .:.:- <.;. P. J. ~ ~,~~"~-'~"1:~':.:'~:~'~'~:~'~'~~~'~"~"~:"~'*~' ~ 0- I , ~ 1, ~ ~ ~ ~ ~ ~ ',' ~ ',' ~ ~ ~ ~ ~ I, ~ ~ ',' /' (~ I' (~ " ::s '; : .. , -~ ~ ~ I,:. )!i. I,:. ~~ I~ I.., I... ~ :~ ~ ~ ~ ~ ~ ~ ~ ~ :~ f ~ ., IT IS ORDBRED, ADJUDGED AND DBCREED as follows: 1, A portion of the aforementioned Retirement Plan is marital property subject to distribution by this Court. 2. The sum of $7,000,00 from the accounts, plus actual interest earned on this sum from (date of divorce) to the date that the retirement benefit is in pay status, is awarded to the Alternate Payee, Renee Conrad, and is to be segregated to an account in her name. The Participant, Robert L. Conrad, Jr. is awarded the remainder, plus interest earned on the remainder, 3, The term of said payments is for the life of the Alternate Payee, a number of years certain, or a lump sum payment, the term to be as selected by the Alternate payee from any payment option available to her from the Retirement Plan at the time the retirement benefit is in pay status. Payments are to commence at the retirement date chosen by the Alternate Payee but in no event earlier than the earliest retirement date provided under the Plan, or in the case of this defined contribution plan. a date which is not more than ten years before the normal retirement age under the Plan. 4. In the event a Plan provides the option to the participant to elect to obtain benefits at the earliest retirement age, the benefits shall be payable to the Alternate Payee on or after the date on which the Participant attains ( or would have attained) the earliest retirement age, as if the participant had . 0 retired on that date even if the Participant has not actually retired or separated from service. 5. The plan to which this Order applies is the retirement and annuity plan or any successor plan, 6, The Alternate Payee, Plaintiff, shall have the same rights with regard to her portion of the account as are available to the Participant, Defendant, with regard to his remaining portion of the account, These rights include but are not limited to the right to designate beneficiary of retirement benefits, the right to elect from then existing retirement dates and payment options, and the right to such increases in value in the account as might occur as a result of general upgrading of the plan, plan amendments, earned interest, profitability of plan investments, etc. but not from increases in value which result from future increases in the Participant's compensation or his future contributions to the plan. In no event shall the Alternate Payee have greater rights than those which are available to the Participant. The Alternate Payee is not entitled to any benefit not otherwise provided under the plan. 7, In the event that actuarial computation is necessary to determine "actuarial equivalents" and/or the difference between benefits actually accrued, non-subsidized benefits, or employer subsidized benefits, for the purpose of the earliest retirement age option by the Alternate Payee, or otherwise, the Plan Administrator . , shall obtain the services of any actuary who is enrolled under subtitle C of title III of the Employment Retirement Security Act of 1974, 8, Any reasonable costs incurred by the Plan Administrator to effectuate the terms and provisions of this Qualified Domestic Relations Order shall be assessed against the parties such that the Alternate Payee pays 1/2 or 50% of the costs and the Participant pays the balance of the costs, 9, The Alternate Payee shall have the right to rollover the benefits distributed to her pursuant to the terms and provisions of this Order to an eligible retirement plan such as an Individual Retirement Account or to an Individual Retirement Annuity. This transfer will be considered a tax free rollover of the benefits distributed provided that the balance to the credit of the Alternate Payee is distributed or paid within one year of receipt, 10. The parties shall promptly notify the Retirement Plan administrator of any change in their addresses from those set forth above in this Order. 11, The parties shall promptly submit this Order to the Retirement Plan Administrator for determination of its status as a Qualified Domestic Relations Order. were single and unmarried, Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 3 . MUTUAL RRLRASR Subject to the provisions of this Agreement, each party has released and discharged. and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce, 4 . FULL DISCLOSURE The provisions of this Agreement and their legal effect are fully understood by each party to this Agreement, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence, Husband and Wife each represent and warrant to the other that he or she has made a full complete disclosure to the other of all assets of any nature whatsoever and of all other facts relating to the subject matter of this Agreement. Both parties represent that the terms of this Agreement have been fully 2 'I' I . Initials'::' ,/ ( :~~' explained to them by their respective counselor that both parties have had the opportunity to have legal counsel review and fully explain the terms of this Agreement. Wife is represented by Michael J, Pykosh, Esquire of the Law Offices of Darrell C, Dethlefs. Husband is unrepresented in this matter, but has had the option and opportunity to have this document reviewed by an attorney, Husband acknowledges that Wife's attorney has not advised Husband on this matter or any other matter. 5. EOUITABLE DIVISION By this Agreement, the parties have intended to effect an equitable division of their marital property, This division is not intended by the parties to constitute in any way a sale or exchange of assets. 6 . SUBSEOUENT DIVORCE A. AGREEMENT NOT PREDICATED ON 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 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 3 Initials { i ( ~, actions for divorce, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto, It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waives any and all possible claims that this Agreement is, for any reason, illegal of for any reason whatsoever, unenforceable in whole or in part, Husband and Wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be stopped from asserting any illegality or unenforceability as to all or any part of this Agreement. B. ENTRY AS PART OF DECREE - It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purpose of enforcement only. 4 ;' / / 'Q'",,,, Initials ~ -~ 8. DIVISION OF MOTOR VEHICLBS with respect to the motor vehicles owned by one or both of the parties, they agree as follows: Both parties shall retain the motor vehicle presently in their possession, more specifically husband shall retain the 1984 Ford. wife shall retain the 1986 Chevrolet, The titleS to the said motor vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided, on the date of execution of this Agreement or at any time thereafter at the request of either party. 9. lHUl.T. BSTATE The parties agree that the marital residence has been sold and all sale proceeds and obligations associated with the sale of the residence have been divided to the parties' mutual satisfaction. 10. llFTBR-ACOUIRlID PBRSONAL PROPRRTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her after November 20. 1996, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 11. DISPOSITION OF PROPBRTY From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant. Initials l / ( "U-'Q,~ I-~ 6 against the other for support, maintenance, alimony pendente lite or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for spousal support, maintenance, alimony pendente lite or alimony, 15. PENSION PROGRAM Husband and Wife are the owners of certain pension plans and/or retirement plans and/or employee stock or savings plans, which they have accumulated during the course of their employment. It is hereby specifically agreed that Husband shall transfer the sum of Seven thousand ($7,000,00) Dollars to Wife in connection with Husband's retirement account with EXEL Logistics. Wife shall prepare a Qualified Domestic Relations Order (QDRO) to effect the transfer of these funds, and said QDRO shall be entered along with the entry of the Decree in Divorce. Wife's counsel shall file said QDRO with the plan administrator of Husband I s retirement plan, Husband and Wife each shall forever relinquish to the other his or her right, title and interest in all other pension plans and/or retirement plans and/or employee stock or savings plans, as well as all other employment benefits, of the other, The parties agree to execute any and all documentation necessary to effectuate the terms herein contained. 8 Initials r;. ( ~ '~,~ ~~ 16. MISCBLLANEOUS All assets including, but not limited to, savings accounts, checking accounts, certificates of deposit and life insurance policies shall be the sole and separate property of the title holder of said asset. The parties believe and agree, that the division of property hereto made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property, Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. 17. GBNBRAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement, Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities, or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at 9 Initials tii.. ~~ all times hereafter save harmless and keep the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. c. SBVERABILITY 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 only that term, condition, clause, or provision shall be stricken from this Agreement and in al other respects this Agreement shall be valid and continue in full force, effect. and operation. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. D. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they will forthwith execute any and all written 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 effectively the terms of this Agreement. B. 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. 10 Initials'i , "\".... ....' "- ,.--~. ,..... -'-' hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. K. HEADINGS NOT PART OF AGRBBMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction, or effect. L. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, curtesy, their statutory equivalents, widow's allowance, homestead rights. right to take in intestacy, right to take against the will of other, and right to act as administrator or executor of the others estate. and each party will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. M. A'I"l'ORNBY'S FEES FOR BNFORCBMENT - In the event that either party breaches any provision of this Agreement, and the / 12 Initials' ' ~'-,:,,,,~ ('1 '.n ,,> c; -, .,1 .... , t. , .. ~ - ) ":':1 , .;n ., ".".1 , " ) ):n .\ .., :..1 . l;:' -~ 6. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. 7, plaintiff has been advised of the availability of counseling and that she and Defendant may have the right to request that the Court require the parties to participate in such counseling, 8. The parties may enter into a written agreement with regard to support, custody, visitation of children, alimony and property division, In the event that such an agreement is executed by the parties, the agreement may be incorporated by the court into the Final Decree of Divorce, COUNT I Request for Divorce Due to Irretrievable Breakdown Under 3301 (c) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full, 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint. Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit, 12, Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling, NHBRBFORB, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing af this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301 (c) of the Divorce Code, COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301 (d) of the Divorce Code 13, The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 14. The marriage of the parties is irretrievably broken, 15. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate an apart, 16, Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to anticipate in such counseling, WHBRBFORB, if two (2) years have elapsed from th~ date of separation and Plaintiff has filed her affidavit, Plaintiff respectfully requests the Court to enter Decree of Divarce, pursuant to 3301 (d) of the Divorce Code, '., "1 '.~ . ,::':?:;/',.~':{~..~ . . .':;;!';i;;:~tt;~t' ,', ','''' "''''''; """'k"~~,""!,\",, . : o~,.:~t;~i;~;~l~ti~;;;I -:"" 'j" "', '" ;.~ ''''::,, i.:~'-f'A.-'c!f.:,:'.~,' ;.' ;':'::,;:..,1,. . ~'" "i:;::;.-:.~;':i,~f:~~~~:~l~::::l~~~:'" '," ','. "'" ""." ""'" : , i ,}'..".,.;> m ."., '.'. "".-' , ~",,,,::. "',("':>:.::',r,~' , ~,'..: '<;:"t~.: .' I.,.r, '''''''''''''', ,,', .,':h,;J"..'j" ",. ,,' . " . 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" '.; '.;. \ , " -\ :, ::.:~.- ;'-:;". .~.~;, ':' lGl.:s;;. .~,;;"~,~,, .' , ' I . " .~; '.. ,:.' .-;>::, " ~'! 'f:..' " ", ,':~ :;-:{~t ',~ i~~~V~~"i.r~~::~~~( j~~,fi1~f~t"';~. .......,./ ".1' "! I ,. _ d .t,-,,; , . . . . .. ": FEB 1 2 1997~ t r v. IN THE COURT OF COMMON PLRAS CUMBBRLAND COUNTY, PENNSYLVANIA NO. 1'1- I. '11 CIVIL TERM RENEB CONRAD, Plaintiff ROBBRT L. CONRAD JR., Defendant DIVORCB AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCBED IN FORMA PAUPBRIS 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceedings, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation, 3, I represent that that information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Renee Conrad Address: 308 North Enola Drive Enola, PA 17025 Social Security Number: 245-33-5603 (b) If you are presently employed, state Employer: Address: NIA income. Mortgage alone is S51Q,QQ per month t .. r , (g) Persons dependant upon you for support (Wife) (Husband) Name: Children, if any: Name: Ashley M. Conrad Age: 5 4, I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 1:; , ~T~ ; ~.~. (i~ .. ',"., . , . ~ .-,- "",,;,;,,.' ;'-\ I """', I. \ .. .,\' :,. ., , ',,', ..,' <' t':. ,~. '~, '/,,'l';i"'I'} pl'" r~ ,p.t"....~":'j!le ,,,'" '"'~ ..; ,! ,'". ,M _' .:. "f:i"k;""'<-;:";:f:.~t'"\r''Jti. \"t\.~\ ./,. ;'0.\': .jil" '. J>, \1't~""! 'l";""",~~....~,,'i. ,..1- " .,; ';~ >~~tc \O~.:r'Ji;~ I"~ ".... .: ","". ~"",'\.p,,,...-::"'::;r ~",.l) j" 'it', ":;-'..., '~.r"'~ h, ; ?...- ~'l;' v'< 'Jetl;,..... e ' ""'" '"0';;, 'r;1 . 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" ~ !,~" ..,; ". ,!it ""..", ... ...,.,;t "if./ ,"""', ,.. ....,-, l.~'7 < -:t . .,.,. '1;'31~::'" l' ,,"{,;h;?,.,'i;t::'!<, :"'l,.'-') ~j.",:.;;- " , :, ,~ ',': .~~ I:~~~ ;;,:;t......;;;.~..:r..-..,,~'V['''','f'!'';X.;.,f~1i;' ~': >>.., i{ , '~('f' -$"'_"~'!' ,I. ~:;:;;..I~1;-'L?~,.;;.4j q":;'" ;".1\' ,~ ..' l"~~:.}:f.~/"{;:~"'t :'''<:,-:~''':~~1~' \,'t.,,:y~"!ff::.~<-\..: ~ -"':::<,""" ,~i:1 H:;', €t>..i,~;~~~:;:'."! ::J.~'::tii.;:trf,rit..:.~~[;I.-: ~ \..,' " L t:: ~~'" > .~, ~ (, 'l" ~:\>~#~' -~?i;;.:...; :..;:t~.. 'i.:'~,~};~'~.~:;~:' , ': t !l"'~ ~.!..":1.i ''1>V:....''''i;.:..:_,. ,~~r~'+,".J,~1>... l~""" ,'< " ' ,'~ '- ; ,>;", ';\<, ..'.- Tf,' ,."' "' \,' /-,' --:,j f;. 'l, , .", " .",-;:.,' ,-,,:i' . .. '"; '-' .:' - ~.~ , , ~. - " .}", -'r: -.- --, ,-',.. : -- ~-; -. '~:'~~? " -. "- -"" n., '."-: ,.',: ~ ,', , ~ .'.; :",' ~ . . . ,~ . . - ..' Ji:j~;...,,-:...._~,,...,..t':_~t.,,,.c _', .,__.' .' l",,~~~:!~.!';~~:l\";';' t'!tli:"":l~'~t,"'1't", "-~~'~V.~'~'h : ,if' ' ,-', < " ,,:, ''',' - ,7' "', ,""-' ' \"'-.~' "<".- ~' , ' . " : ',~~";f~~~ "\~f~'~ ?tJt..~,:'t;,~,~~-~:~?J'-,::' 7 t,'",~"~:",~, t."':':' " ~:~~:.:.,~,~~.!"'~~~';'~;:~,~:-' " . \. FEB 1 Z rh 1991, .' ,;r,,;, " , ;"~, ,.. ,..." ft t " \ RENEE CONRAD, PlalnUff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Y. ROBERT L. CONRAD, JR., Defendant NO. 97-679 ACTION IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint In Dlyorce lJ'lder Sectton 330 I (c) of the Dlyorce Code was flied on May 6. 1996, 2, The marriage of PlatnWf and Defendant Is irretr1ey/lbly broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3, I consent to the entry of II final decree of divorce. 4, I understllnd that If II claim for al1mony. alimony pendente llte, marital property. counsel fees. or expenses has not been fi led with the Court before the entry of a ftnal decree In dlYorce. the right to claim any of them will be lost. I yer1fy that the statements made in this AffldaYlt are true and correct. understand that false statements hereIn are made subject to the penalties of 16 PaC,S.A. Section 4904 relatlng to unsworn falsification to author1ttes. Date: \....,\ ',,;\ \ '\l ~ . ('\ 6y'~' ,,,,, -.;.;,.....\ .." .,~ RENEE CONRAD. PLAINTIFF t RENEE CONRAD, Plllintlff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIV IL ACTION - LAW NO. <1;1 I E> 199E> Y"I- (//1 ACTION IN DIVORCE ., I . ,~ Y. ROBERT l. CONRAD, JR., Defendllnt WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1, I consent to the entry of 0 flnlll decree of divorce without notice, 2, I understllnd thlltl mey lose rlg,ts concerning llllmony. dlY1s10n of property. lllwyer's fees or expenses if I do not cl11lm them before 0 divorce Is grllnted, 3, I understllnd thllt I will not be divorced unltl II divorce decree is entered by the Courtllnd thotll copy of II decree will be sent to me lmmedilltely lifter it Is filed with the Prothonotllry. I verify thllt the stlltements mllde in this llff1dllvit ore true llnd correct understllnd thllt flllse stlltements herein lire mllde subJect to the penllllies of 16 Po. C,S.A. Section 4904 reI olt ng to unswom flllslflcolton to lluthorities. Dllte:~';)'').\~\\ , '-'I. \'<, '" r-rl',~,,,,...... ry~ ~'j'..:0--_~~ RENEE CONRAD, PLAINTIFF ~ r RENEE CONRAD, Plaintiff IN THB COURT OF COMMON PLBAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ; v. ROBERT L. CONRAD, Defendant NO. 97-679 ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 11, 1997, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4, I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: \ I \l \ :1,) ~ \<.\ I. ) \ \ By.: ,_.'/ " .-, Robert L, Conrad, Defendant ,-, ,0 n ~:: _I , . - , ~J t' ,- , . " :.n , . \.'~, : , , >. , ..~ " , .,j , . ,l ,- :;-;1 I , , ::> :J'! . ~ -, <:") .0 'J C -J '" .' .1 ,>.' , ..... .q l " - > ..- ,q ;1';'1 " ',f, ;(,"J >- ~ ,") : -, :", -" , ,..., i ,111 ., I =-, :.J -, '0 ", ~ 0 1.':1 0 (:..~ -.I -11 ..." ~:, ~~i I., j:'!') ", ,:'"J , ,) ;~ C~ .' '.:> " . ~1 ~ () ~.:J ,m ~ .~ '" :"j' ., . (.> ."