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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
DIANE L. BROOKS
I 97-1639 c97
WAYNE L. BROOKS
t;
DECREE IN
DIVORCE
( .................. 1991. , i ordered and
AND NOW, ..??% it is
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DIANE L. BROOKS
decreed that ..................... plaintiff,
•••
. L. BROOKS ......................... . • , defendant,
and . . . . . . . . . . . WAYNE.
....
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; V OVQ o
......All .claims. have. heen..encompassed. in..a. Se.ttlement.......... ,
e
Agreement which is attached hereto,andJi •oppgr?Lted,..,.., •.:
into the Decree.
By Tl, Co t:
Attest: J.
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Prothonotary
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THIS AGREEMENT, is made this 2-1 day of / Irr'r ,
1997, by and between DIANE L. BROOKS ("Wife") of En a, Cumberland
County, Pennsylvania and WAYNE L. BROOKS ("Husband"), of
Harrisburg, Dauphin County, Pennsylvania.
N I T N B 0 9 B T H•
WHEREAS, Lhe parties, currently Husband and Wife, are in the
process of obtaining a decree in divorce; and
WHEREAS, by this Agreement, the parties have intended to
effectuate and equitably divide their marital property; and
WHEREAS, diverse unhappy differences, disputes and
difficulties have arisen between the parties and it is the
intention of Husband and Wife to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling any and all claims and possible claims by one against the
other or against their respective estates.
NOW THEREFORE, with the foregoing recitals being hereinafter
incorporated by reference and deemed as an essential part hereof
and 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, Husband and Wife, each
intending to be legally bound hereby, agree as follows:
The parties agree that the terms of this Agreement shall be
incorporated but not merged into any Divorce Decree which may be
entered with respect to them. The parties understand that this
Agreement shall survive any final judgment or Decree of Divorce and
shall be independent thereof and the incorporation of this
Agreement into the Divorce Decree is for purposes of enforcement
only.
The parties confirm that each has relied on the
substantial accuracy of the financial disclosure of the other, as
an inducement to the execution of this Agreement. No
representations have been made by either party to the other, or by
anyone else, as to the financial status of the other except as
expressly set forth in this Agreement.
Both parties acknowledge and accept that this Agreement
is, under the circumstances, fair and equitable and that it is
being entered into freely and voluntarily, after having received
independent legal advice or choosing to forego receiving such
advice, 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.
1. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS.
Each party understands that he or she has the right to
obtain from the other party a complete inventory or list of all of
the property that either or both parties own at this time or owned
as of the date of separation, and that each party has the right to
have all such property valued by means of appraisals or otherwise.
Both parties understand they have the right to have a Court hold
hearings and make decisions on the matters covered by this
Agreement. Both parties understand that a Court decision
concerning the parties' respective rights and obligations might be
different from the provisions of this Agreement.
Both parties waive the following procedural rights:
a. The right to obtain an Inventory and
Appraisement of all marital and separate property as defined by the
Pennsylvania Divorce Code.
b. The right to obtain an Income and Expense
Statement of the other party as provided by the Pennsylvania
Divorce Code.
C. The right to have the Court determine which
property is marital and which is non-marital and equitably
distribute between the parties that property which the Court
determines to be marital.
d. The right to have the Court decide any other
rights, remedies, privileges, or obligations covered by this
Agreement, including but not limited to possible claims for
divorce, spousal support, alimony, alimony pendente lite, counsel
fees, costs and expenses.
2. PERSONAL RIGHTS.
Husband and Wife, may and shall, at all times hereafter,
live separate and apart. They shall be free from any interference,
direct or indirect, by the other in all respects as fully as if
they were unmarried.
3. MUTUAL RELEASES.
Husband and Wife each do hereby mutually remise, release,
quitclaim and forever discharge the other and the estate of the
other, for all time, and for all purposes whatsoever, of and from
any and all rights, title 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 he or she now has or
at any time hereafter may have against such other, the estate of
such other or any party thereof, whether arising out of any former
acts, contracts, engagements or liabilities of such other or by way
of dower or curtsey, or claims in the nature of dower or curtsey 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 (a) Pennsylvania, (b) any State, Commonwealth or
Territory of the United States, or (c) any other Country, or any
rights which either party may have or at any time hereafter have
for past, present or future support or maintenance, alimony,
alimony pendente lite, counsel fees, equitable distribution, 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 thereof. It is
the intention of Husband and Wife to give to each other by the
execution of this Agreement a full, complete and general release
with respect to all property 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 thereof.
4. PERSONAL PROPERTY.
a) Husband and Wife acknowledge and agree that they have
previously equitably divided all their personal property to each
party's satisfaction. The parties each waive all rights to any of
the personal property already divided between them unless
specifically mentioned otherwise in this Agreement.
b) Husband shall pay and/or reimburse to Wife the sum of
$2,000.00. This sum shall be paid as soon as Husband finishes the
Bethlehem Steel job he is currently working on or by December 31,
1997 whichever is sooner. This payment represents payment in full
for amounts that were garnished from Wife's paycheck, babysitting
expenditures and back support. The parties acknowledge that this
amount is fair and acceptable.
3
C) AFTER-ACQUIRED PERSONAL PROPERTY.
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, hereafter acquired by
him or her, 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 not married.
5. RBAL ESTATE.
The parties acknowledge that there exists no marital
real estate. The marital home has been foreclosed upon. Both
parties acknowledge tnat tney have confirmed that no deficiency
judgment exists with regard to this real estate.
6. ALIMONY, ALIMONY PENDENTE LITE SPOUSAL SUPPORT.
The parties do hereby waive and surrender any rights
and/or claims they may have to interim or final alimony, alimony
pendente lite and spousal support.
ATTORNEY'S FEES AND COSTS.
The parties do hereby waive and surrender any rights
and/or claims they may have to interim or final attorney's fees,
costs and expenses.
8. PAYMENT OF MARITAL DEBTS.
a) Husband shall be responsible for the debt owing
to PP&L which was reduced to judgment against both parties. In the
event PP&L forces Wife to pay any part of this debt, Husband shall
immediately indemnify Wife and reimburse her for all monies spent.
b) Each party represents that he/she knows of no
other bill or debt for which the other is responsible, in full or
in part.
9. WARRANTIES TO EXISTING OBLIGATIONS.
Each party represents that he/she has not incurred
or contracted for any debt, liability or obligation for which 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 such debts, liabilities
or obligations which may have heretofore been incurred, including
those for necessities, except for the obligations arising out of
this Agreement.
Husband and wife agree that each will now and at all
times hereafter save harmless and keep the other indemnified from
all debts, charges and liabilities incurred by 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.
11. WAIVER OR MODIFICATION TO BE IN WRITING.
No modification or waiver of any of the terms hereof
shall be valid unless in writing and signed by both parties and no
waiver of any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
12. BREACH.
It is expressly stipulated that if either party
fails in the due performance of any of his or her obligations under
this Agreement, the other party shall have the right at his or her
election to sue for damages for breach thereof, to sue for specific
performance, or to seek any other legal remedies as may be
available and said other party shall have the right to recover his
or her reasonable legal fees and costs for any services rendered by
his or her attorney.
13. MUTUAL COOPERATION.
Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge and
deliver to the other party any and all further instruments and/or
documents that the other party may reasonably require for the
purpose of giving full force and effect to the provisions of this
Agreement.
14. LAW Or PE SSYLMIA APPLICABLE.
This Agreement shall be construed in accordance with
the laws of the Commonwealth of Pennsylvania.
15. AGREEMENT BINDING ON HEIRS.
This Agreement shall be binding and shall inure to
the benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
5
16. INTEGRATION.
This Agreement constitutes the entire understanding
of the parties and supersedes any and all prior Agreements and
negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
17. NO WAIVER OF DEFRULT.
This Agreement shall remain in full force and effect
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 in no way affect the right
of such party hereafter to enforce the same, nor shall the waiver
of any breach of any pro,?isicn hereof be aonatrued as t 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.
18. 8EVERABILITY.
V
If any term or provision of this Agreement shall be
determined to be void or invalid in law or otherwise, then only
that term or provision shall be stricken from this Agreement and in
all other respects this Agreement shall be valid and continue in
full force and effect. Likewise, the failure of any party to meet
her or his obligations under any one 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.
19. HEADINGS NOT PART OF AGREEMENT.
Any headings preceding the text of the paragraphs
and subparagraphs hereof are inserted solely for convenience of
reference and shall not constitute a part of this Agreement nor
shall they affect its meaning, construction or effect.
IN WITNESS WHEREOF, the parties, intending to be legally
bound hereby, have set their hands and seals to this Agreement.
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Witness
Witness
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D ANE- L. BROOKS
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WAYNE L. BROOKS
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DIANE L. BROOKS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 97 - 1639 CIVIL TERM
WAYNE L. BROOKS,
Defendant IN DIVORCE
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 section
(x) 3301 (c) [ ) 3301 (d) (1) of the Divorce Code.
2. Date and manner of service of the Complaint:
April 7. 1997 by Acceptance of Service 0
3. (Complete either paragraph (a) or (b)).
(a) Date of execution of the Affidavit of consent required by
Section 3301(c) of the Divorce Code: by the Plaintiff on
August 8. 1997 _; by the Defendant on August 28. 1997
(b)(1) Date of execution of the Plaintiff's Affidavit
required by Section 3301 (d) of the Divorce code:
(2) date of service of the Plaintiff's Affidavit upon the
Defendant:
4. Related claims pending: None. All claims encompassed
in settlement Agreement incorporated into divorce decree.
5. Date of execution of the Waiver of Notice of Intention to
request Entry of Divorce Decree: Plaintiff on 8/8/97; by Defendant
on 8/28/97.
) ?7 jwi. 9/jolf1
KENNETH'F. LEWIS,' ESQUIRE
Attorney for Plaintiff
I.D. 169383
1101 N. Front St. , Hbg, PA 17102
(717) 234-3136
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KENNETH F. LEWIS, ESQUIRE
1101 North Front Street
Hbg., PA 17102 (717) 234-3136
Attorney for Plaintiff
DIANE L. BROOKS,
Plaintiff
V.
WAYNE L. BROOKS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. (l '7 - /L 311 04- . Q -la,
CIVIL LAW - DIVORCE/'
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend
against the claims set forth in the following pages, you must take
prompt action. You are warned that if you fail to do so, the case
may proceed without you, and a Decree of Divorce or Annulment may
be entered against you by the Court. A judgment may also be
entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or
other rights important to you, including custody or visitation of
your children.
When the ground for 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:
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 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. 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.
COURT ADMINISTRATOR'S OFFICE
FOURTH FLOOR
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
DIANE L. BROOKS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 97- /1.39 0cacF 7-e--
WAYNE L. BROOKS,
Defendant CIVIL LAW - DIVORCE/,
COMPLAINT IN DIVORCE
1. Plaintiff is DIANE L. BROOKS, who currently resides
at 23 Pine Ridge Circle, Enola, Cumberland County, PA 17025.
2. Defendant is WAYNE L. BROOKS, who currently resides
at 5015 Utah Avenue, Harrisburg, Dauphin County, PA 17109.
3. The parties have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on August
25, 1990 in Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
i
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.
WHEREFORE, Plaintiff respectfully requests this Court to
enter a Decree of Divorce pursuant to S 3301(a) of the Domestic
Relations Code.
8. Plaintiff hereby incorporates Paragraphs 1 through
7 of her Complaint as if fully set forth herein.
9. The parties are owners of marital property subject
to equitable distribution.
10. Plaintiff requests the Court to equitably divide,
distribute or assign the marital property between the parties and
the marital debts of the parties without regard to marital
misconduct in such proportions as the Court deems just after
consideration of all relevant factors.
WHEREFORE, Plaintiff respectfully requests that this
Honorable court enter an Order of Equitable Distribution of marital
property and marital debts pursuant to 53502 of the Domestic
Relations Code.
COUNT III
REQUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT
AND INCORPORATION THEREOF IN DIVORCE DECREE
11. Plaintiff hereby incorporates Paragraphs 1 through
10 of her Complaint as if fully set forth herein.
12. The public policy of the Commonwealth of
Pennsylvania encourages parties to a marital dispute to negotiate
a settlement of their differences.
13. While no settlement has been reached as of the date
of the filing of this Complaint, Plaintiff is willing to negotiate
a fair and reasonable settlement of all matters with Defendant and
is hopeful that Defendant may also be willing to enter into a
marital settlement agreement.
14. To the extent that a written settlement agreement
might be entered into between the parties, Plaintiff desires that
such written agreement be approved by the Court and incorporated in
any divores decree which may be entered dissolving the marriage
between the parties.
WHEREFORE, if a written settlement agreement is reached
between the parties prior to the time of hearings, Defendant
respectfully requests that this Honorable Court approve and
incorporate any agreement in the final divorce decree.
DATE:.3/3`/ /? X" ?"
KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
I hereby verify that the statements made in the foregoing
document are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsification to authorities.
Dated:
DIANE L. BROOKS 3?Iq
KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
r
DIANE L. BROOKS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
WAYNE L. BROOKS,
Defendant CIVIL LAW - DIVORCE/d•.
ACCEPTANCE OF SERVICE
I accept service of the ComRlaint in Divorce.
11 ? _
DATE:
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KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 069383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
DIANE L. BROOKS,
Plaintiff
V.
WAYNE L. BROOKS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1639 Civil Term
CIVIL LAW - DIVORCE
AFFIDAVIT OF CONSENT UNDER SECTION 3301 (c)
OF THE DIVORCE CODE
1. A complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on April 1, 1997.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date of
service of the Complaint.
3. I consent to the entry of 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.
0
DATE: P11? ) LX F
DIANE L. BROOKS
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KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
DIANE L. BROOKS,
Plaintiff
V.
WAYNE L. BROOKS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1639 Civil Term
. CIVIL LAW - DIVORCE
AFFIDAVIT OF CONSENT UND -R H-LUTON 3301 (c)
OF THE DIVORCE CODE
1. A complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on April 1, 1997.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date of
service of the Complaint.
3. I consent to the entry of final Decree of Divorce
after service or 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:
WAYNE L. BROOKS
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KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 069383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
DIANE L. BROOKS,
Plaintiff
V.
WAYNE L. BROOKS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1639 Civil Term
CIVIL LAW - DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(a) 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.
4. 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.
DATE: lA?'Z \CC? ) Rte( ` > 1
DIANE L. BROOKS
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KENNETH F. LEWIS, ESQUIRE
Attorney I.D. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
DIANE L. BROOKS,
Plaintiff
V.
WAYNE L. BROOKS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1639 Civil Term
CIVIL LAW - DIVORCE %
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 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.
4. 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.
n J
DATE: 7-? L
J WAYNE L. BROOKS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
Vs : File No. J
IN DIVORCE
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Defendant
44,411) 14
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking'Yj
prior to the entry of a Final Decree in Divorce, G?
or .after the entry of a Final Decree in Divorce dated c
hereby elects to resume the prior surname of CN' ?--? - N C-1rZ , and gives this
written no 'ce avowing his / her intention pursue to the provisions of 54 P.S.
Date: ?g a r
Signature
Signature of name being resumed
COMMONWEAL OF PPRISYLVANIA )
COUNTY OF w /o c ?9
On the ?-4 day of 200j before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal. n
Notary Public
NOTARIAL SEAL
PROTHONOTARY, NOTARY PUBLIC
CARLISLE CUMBERLAND COUNTY COURTHOUSE
MY COMMISSION EXPIRES JANUARY 4, 2010
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