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Home My WebLink About97-01762 , , ~ .:+:. .:.:. .:t:- .:c. .:+:. .:.:. .:+:. .:c. .:<<. .:.:. .:c. .:.:. .:+:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:.':- .:.:....:.:-::.:.:.: ':.:',,':.:' .:+:. .:.:. -:.:-: .:+:-"';4 e- --- -- ~ y , ~ ~ .' l~ ~ IN THE COURT OF COMMON PLEAS ,', ~ ~ '.' ~ ~ '.' ~ '.' ~ '.~ ,'~ ~ ,', ~ ~ ., ~ '.' ~ ~, ~ ~.' w ., ~ ~~ ~ ~ ., w '.' ,;, ~ "" ~ w ~.~ w ~.~ w ~.~ ~ ~ ',' ~ ~.' ~ '.' ~ ',' ~ * i y ~ : n, Th, ~lL t2 of:,) : : An"" eJ.4''',<< l' ~ ~ J.: ~ . -r}~J/~'- r ~k. r:'M ; : ii tI '/~othonotnry;;; " I~ ~ y --.............. _-...-.............~...-------.-.._....,-~~~...- , .......-....-----",.,' ...-~_. -.- ,. '~ . ~> .z. -:t> ~..:. .:+:. ->>:. '.+:' .:.:. .:+:. .:+:. .:to:. .:.;. .:.:. .:.;. .:+:. .:+:. .:.:- .:.:- .:.:- .:+:. -:.:- .:+:. .:+:. .:~:. .:+:. .:+;. .:+:. .:+;. .:+:. .:.:- " ~ '" ~ OF CUMBERLAND COUNTY ~ STATE OF 1~ PENNA, ~ ~.' ~ 0:- ,.~ ~ ,:, ~ ~ 0:- RIIONDA...L~.COOK, :1 ,', ~ N o. ..n::'.~.?E.. c:.i.y.?:.L. ~ ',' . Pl<lintiH w '.. Vl1r:ms ~ '.. TIMOTHY A. COOK, ~ ',' Defendant ,;, " .' w '.' ~ '.' DECREE IN DIVORCE ~ ~l .. ~ ,; ~ ~.' ?- ~ ~ i '.' AND NOW, ..,.. .A. u. O~. ~~.t,. .4..C? ,.,. 19..1.,7,. it is ordered and decreed that."..., .lWP.t-lO,:... ~" .COP.~.,..,..."" .,.,.""" " plaintiff, and,.............,.. :r.l;l19:r.HX ,1;\,., ,G99!<. .., .. .... ""...""., defendant, are divorced frorn the bonds of matrimony. ~ "" ~ The court retains jurisdiction of the following claims which hove been raised of record in this action for which 0 final order has not yet been entered; ~ ~. ~ ~.' ~~~, .~~':"~.t.~~, ~~,~~~~!1',E;~~. !':<:!':"<<;!7~E;~~. .d.~~~? ,~l;I~>" .~!, ,l,~~?, ,i.~ ,~!l~,~J;"E'~.rated ~ but:. )lQt, merged .into, this. ,De(:J:ee, "'.-. .None". ",... .".., ,.""",. ", 8,.)/.?) td. t~ ",;qdb iff a7f d..:.rlh;t" if <..;v,Y) ('~ /X'l<-~ ~",4 df:4/ ,7 '. c:\wp5I\cook\ms.a liIe fS2l1'J.')7.(1l Apnl I".llyn RHONDA L. COOK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 97 - 1762 CIVIL TERM Plaintiff vs. TIMOTHY A. COOK, Defendant IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS Agreernent made this <j'~ day of by and between RHONDA L. COOK, of 912 Petersburg 0 ,Carlisle, Pennsylvania, hereinafter referred to as WIFE, and TIMOTHY A, COOK, of 821 D East Cornpany Farm Road, Aspers, Pennsylvania, hereinafter referred to as HUSBAND, WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been joined in marriage on October 5, 1991, in Boiling Springs, Cumberland County, Pennsylvania; and WHEREAS, a Cornplaint for Divorce has been filed in the Court of Cornman Pleas of Cumberland County, Pennsylvania, to No, 1762, Civil Term; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without Iirnitation, the settling of all matters between them relating to the ownership of real and personal property, I II and in general, the settling of any and all claims and possible claims against the other or against their respective estates. NOW, THEREFORE, in consideration oflhese considerations, and the rnutual promises and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and ,1997 c:\wp51\cooli.\msil file #52lJl).'J1.uI ..\pnll.'.Il)')7 ~ 2, Divorce: The parties agree to the entry of a Decree in Divorce, The parties will sufficiency 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, Advice of Counsel: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreernent with which to consult with counsel. WIFE is represented by Carol J. Undsay, Esquire, and HUSBAND, has been advised that he may be represented by counsel of his choice. Each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge as each has sought from counsel, 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 agreement or agreements, execute, within 90 days of the filing and service of the Complaint in Divorce, Affidavits of Consent and Waivers of Notice under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce. 3. Personal Property: The parties acknowledge that they have equitably and satisfactorily divided all of their personal property, and that, with the exception of that property listed on Exhibit "A" attached hereto, all personal property shall be the sole and individual property of the party in whose possession it is as of the date of this Agreement. HUSBAND will transfer to WIFE those items listed on Exhibit "A" within 10 days of the date of this Agreernent. l c:\wpSl\rook\mi.1 file IS2W.'J7..ul ~tay 2".1')")7 . WIFE will retain the 1994 Jeep Wrangler four-wheel drive vehicle which is titled in her narne. WIFE will pay the balance of the loan for the purchase of said vehicle to the Bank of Hanover and shall indemnify and hold HUSBAND harmless against any loss as a result of said loan. Within ten days of the payrnent described in Paragraph 4 below, WIFE will transfer to HUSBAND all her right, title and interest in her pre-marita/1990 Toyota Corolla. HUSBAND will retain the 1991 Toyota four-wheel drive truck which is titled in his narne. HUSBAND will also retain the four wheeler which is jointly titled. Within ten days of the date of this Agreement, WIFE will execute any documents provided to her by HUSBAND and required for the transfer of her right, title and interest in the four-wheeler to HUSBAND, Each party will retain his or her own accounts in banks and employee benefits including IRAs, 401-Ks, and pension plans, 4, Real Property: The parties are owners of a residence at B21 0 East Company Farm Road, Aspers, Pennsylvania, Upon refinance of the home by HUSBAND, WIFE will transfer to HUSBAND all her right, title and interest in said home, HUSBAND will obtain such a refinance within 90 days of the date of this Agreement. Pending the refinance, HUSBAND will make the mortgage payment on the marital horne each and every month as it cornes due, At the time the home is refinanced, or prior thereto, HUSBAND shall pay to WIFE $20,000,00. 5, Alimony: The parties waive any claim that they may have one against the other for alimony or spousal support. The parties acknowledge that each has sufficient assets with which to maintain themselves after divorce. .1 c:\wpSl\cook\msa me '52(,').<)7"'1 ,\pnll~.I'm J 6. Marital Debt: The parties have, in their own narnes, certain credit card accounts which may include some marital debt. WIFE will pay her own student loans and indemnify and hold HUSBAND harrnless against any claim on account of those loans, HUSBAND will pay all charges on WIFE's AT&T Master Card which are rnade through Decernber 15, 1996. Said payrnent will be made within 30 days of WIFE's providing to HUSBAND docurnentation of said charges. Each party will incur :10 debt for which the other rnay be liable and will indernnify and hold the other harmless on account of any debt so incurred, 7. Income Tax Refund: The parties jointly filed their 1996 Federallncorne Tax Return and have received a refund of approxirnately $5,400,00. The refund shall be the sole and separate property of HUSBAND subject only to his obligation for rnarital debt as set out herein, B, Modification: No modification, rescission, or amendrnent of this agreement shall be effective unless in writing signed by each of the parties hereto, 9, ApplIcable Law: All acts contemplated by this agreement shall be construed and enforced under the laws of the Comrnonwealth of Pennsylvania, 10. Agreement Binding on Parties and Heirs: This agreernent, except as otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs, executors, administrators, legal representatives, assigns and successors in any interest of the parties. 11. Agreement Not to be Merged: This agreement shall be incorporated into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree, The parties shall have the right to enforce this agreernent under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity ~ '. d c:\"t'5I\<ook\.... file 11269.'17.111 ,\pnI14.1'1l7 . under this agreement as an independent contract. Such remedies In law or equity are specifically not waived or released, 12. Documents: The parties hereto agree that they will execute and deliver one to the other any docurnents necessary to give effect to the terrns of this Agreernent. 13, Full and Final Settlement: WIFE and HUSBAND each do hereby rnutually rernise, release, quitclaim and forever discharge the other and the estate of such other, for all tlrne to corne, and for all purposes whatsoever, of and frorn any and all rights, titles, Interests or clairns in or against the property (including incorne 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 tlrne 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 c1alrns in the nature of dower or curtesy, or widows' or widowers' rights, farnily exernptlon or sirnilar 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 other State, or any other Country, or any rights which either spouse rnay have, or at any tirne hereafter have, for past, present or future support or rnaintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the rnarital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which rnay arise under this Agreernent or before the breach of any thereof. It is the intention of HUSBAND and WIFE to give to each I I II '. other by the execution of this Agreernent a full, complete and general release with respect to any ~ RHONDA L COOK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO, 97 - 1762 CIVIL TERM Plalntllt va. TIMOTHY A. COOK, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the foil owing Informalion, to the court for entry of a divorce decree: 1, Ground for divorce: Irretrievable breakdown under Seclion 330 1 (e) 3301 (d)(l) of the Divorce Code, (Strike out inapplicable section). 2, Date and manner of service of the complaint: U.S. Mail, Flrsl Class. Certllled. Return Receipt - dated 4/16/97 3, (Complete either paragraph (a) or (b)). (a) Date of execulion of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plalnlif! Julv IB, 1997 ; by the Defendant Julv 30. 1997 (b) (I) Date of execulion of the PlaintiH's aHldavlt required by Seclion 3301 (d) of the Divorce Code: (2) Date of service of the Plalntiff's affidavit upon the Defendant: 4. Related claims pending: None 5. Complete either (a) or (b). (a) 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's Waiver of Nolice In 3301 (c) Divorce was filed with the Prothonotary: August 14, 1997 Date Defendant's Waiver of Nolice In 3301 (c) Divorce was flied with the Prothonotary: August 14, 1997 '-- Attrne!. . r Rh nda L. Cook. Plalnliff >- M E;: ~ 0 ....- .. .'J wO .::r r)~ ., (~;;[ 0'.. x: 0 -' fE_. c._ q;j ~~ )=, ...:I' :"0 r. .::J::. u. .~iO c.<J .- III UJl :L ::> (;)0... F ..:r :::! 1I... l- n 0 a> r:\~p51\cook\romrlainI.lJiv rile 152W.'J7-U1 ApnI4.1')lJ7 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 97 .17(,~ CIVIL TERM IN DIVORCE RHONDA L. COOK, VS. TIMOTHY A. COOK, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the clairns 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 annulrnent may be entered against you by the Court, A judgment rnay also be entered against you for any other claim or relief requested in these papers by the Plaintiff, You rnay lose rnoney 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 rnarriage counseling, A list of rnarriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, ,I COUnT ADMINISTRATOR, FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: arcl J. Li say, Esquire 10 1/ 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 D", 1jfl c:\Wp51\l'Ook\cnrnplainl.l.llv HIe 1152m.I',7.1I1 I\pnl ~,II)lJ7 RHONDA L. COOK, PlaIntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 97. /'7t..'J..... CIVIL TERM IN DIVORCE vs. TIMOTHY A. COOK, Defendant COMf.lAINT IN DIVOIlC.E RHONDA L. COOK, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P,C" respectfully represents: 1, The Plaintiff is RHONDA L. COOK, who currently resides at 912 Petersburg Road, Carlisle, Cumberland County, Pennsylvania, where she has resided since February 15, 1997, and has been a bona fide resident of Pennsylvania for at least six months prior. 2, The Defendant is TIMOTHY A. COOK, who currently resides at 821 D East Company Farm Road, Aspers, Adams County, Pennsylvania, where he has resided since April, 1992. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six rnonths immediately prior to the filing of this Cornplaint. 4, The Plaintiff and Defendant were married on October 5, 1991, at Boiling Springs, Cumberland County, Pennsylvania. 5, That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction, 6, The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code, '.............- c:\....ll.~l\l'ntlk\l'lImrl;lint.div file IS26lJ.l},7.(JI "rnl -I,JI),J7 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling, 8, Plaintiff requests the Court to enter a decree of divorce, FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Carol J. Lindsay, Esquire 10 # 4 93 11 East High Street Carlisle, PA 17013 (717) 243-5513 0'" 1fl I I, 2 1\~/1Ct/LA ~?-L I 'I I ~ I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are rnade subject to the penalties of 18 Pa. C.S, ~ 4904, relating to unsworn falsification to authorities, Date: ~/ . .s . 'J'7 .-]:- ~ + "- ,... - ~~ Iv') G (': tr. \....., j', .. '. ~ IJJr' Co'" .,..... 8 u. I,.' J G! r.' , :c },"., .I.., . " ~ '.r n. !:-".j r'6 ~.. ill ~ it) I, _'I" ,-'.. ~ ". I ... ~ 0.:. .., /:' 11.: . -;(,J ~ r. IJ. . c; u.. - .. ... ~ ~ '''' ,... 'j il9- c;::) U t/'I U Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO, 97 - 1762 CIVIL TERM RHONDA L. COOK, VB. TIMOTHY A, COOK, Delendant IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complalnlln Divorce under ~ 3301 (c) of the Divorce Codo was filed on April 4, 1997. 2, The marriage of plalnlill and defendant Is Irretrievably broken and ninety days have elapsed from the date of filing and service of the Complain!. 3, I consent to the entry of a IInal Decree In Divorce aller service of nolice of Intention to request entry of the Decree. I verify that tho statements made In this Aflldavit are Irue and correcl to the best of my knowledge, Information and belief. I understand that false statements herein are made subject to Ihe penal lies of 18 Pa.C.S. 4904 relaling to unsworn falslllcalion to authorllies. ) . L'1 ~\LlLL ( Co/v Rlionda L. Cook. Plalntlll Date: f=jIQ"c,,'f 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 IInal Decree of Divorce without nolice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's lees or exponses If I do not claim them before a divorce Is granted. 3. I understand that I will not be divorced unlil a Divorce Decree Is entered by the Court and that a copy of the Decree will be sent to me Immediately aller It Is filed with the Prothonotary, I verify that tho statements made In tills Allldavlt are truo and correclto the best of my knowledge, Informalion and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to Buthorllies. 2\\{,,\~ l C;( v- Rhonda L. Cook. Plalnlilf Dale::/ \'~ -1'1 ~ <"l ~ 0 t-' .. w9. ~ :5,,.. u-:. C)i-'! u:L' ..- ~ ):j ~~ tl_ #:)~ , & .:r '" Ii) -' .1:-<:: u.:lll <.!' ;+;6 iE' ;::l ~ju. ..;; LL. 0 r- ';:l Cf' 0 J (' f III:RI'Jh' l.TH.TII:Y I'll liE 7L1)i1ClJlIl ,((am!!.' It! mON. ^ Tll.tJE^Nl> nIRIU:("T~. ?///()m,'Y' al Bail' L WILCOX, JAMES III COOK 2J.f 7JaltiJ1/()N dlNel IIY r r7) r. AI"IURNU' nlR .9l'/IyJOarj. [l!lInJ!I (lanic111J2J ."..-1 M~ \.:UUKT UI' tUMMON PLEAS OF CUMBERIANDCOUNlY, PENNSYLVANIA CIVIL ACTION. LAW RHONDA L. COOK, PLAINTIFF NO, 97-1762 VS. TIMOTHY A. COOK, DEFENDANT AFFIDA JIlT OF CONSENT ACTION IN DIVORCE Timothy A. Cook, Defendant, being duly swom according to law deposes and says that: I. A Complaint in Divorce WIder *3301 iO of the Divorce Code was filed on April 4, 1997, 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 conscnt to the entry ofa fmal Decree in Divorce after scrvice of notice of intention to request entry of decree. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or 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 also waive any request for marriage counseling, 5. I verify that the statements made in this Affidavit are true and correet. I wlderstand that statements herein are made subject to the penalties of 18 Pa. C,S,A. *4909 relating to WISWOIll falsification to authorities. DATE: 7-30'-97 ~~(}t~) TlMOTH 1\. COOK i'" C"l r.:; ~ 0 .,. ~'j~ UJO ..:z (10-' U"~ J. (j~ rr:g u.. ..,~ I... . g~ . J ~ ~:1~ w.l. IJ. -...... -'II' C!) IdlE G:-C ::l tfl r= ..:r ...; 0. r- :::; 0 C1' 0 ...- r...--." -, - tr. ('") ~ .;: c .... '"" .. -.., , u./") .:J r1;~. (.):-": ~:: C):'l e:g c... -., (~('":! ~~2 .:r .'..tn ..'2 u. r-~.4 -~ re~' ! (,., ~iiCJ ~ : ('Iu.. r!: :ci -: l1. .- ::; 0 0' U ,... -, ;....~ ., #""- ....... .. . RHONDA L. COOK, PlaIntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97 - 1762 CIVIL TERM VS. TIMOTHY A. COOK, Defendant IN DIVORCE PROOF OF SERVICE i .~~,_z...__. laJlOwtthtortCllvelhl .~......"... and 'b. following 1I1'IIce. (lor an 1.:::-you.......ondlddMlonlhomollOollhll_lOlI1Il...can....."tNl .xtrafll): j .M.d"N'_lolho_oIlho"",IjlIoco...onlhobldl~Ijl__"'" 1,0 Addr.......Addr_ . .er';;;~RIIUm RocaIpt Roq_'1</' on Iho moJpIeco btIow Iho ItIIclo _. 2, Q: R..tJ1cted D.llvery 'Ii -The R.hm Receipt.... Ihow to whom Iht artldt WIt lStIvtrId and lhI dall I & - DELIVER T ADDRESSEE ONLY ConlUltpozlmllllrfotf.e. 13, Mcle Addressed to: 4e, Mde Number P 282 3~8 771 HR. TIMOTHY A. COOK 4b.SeMceType i 821 D EAST COMPANY FAIUoI R egllt.red ~rtItIed I ASPERS, PA 17304 D ExpresaMaIt D Inltnd f D R.1um RlOIipIfor Meld1andae D COD 10 7, Date of .1 ary . l J .... (') .. cr~ .. , .' " M ( I... , .. ,~, (.... r.. :-, . -, '; r- , <7' \'.J '. RHONDA L. COOK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plalnt"f V9. CIVIL ACTION -LAW NO. 97 - 1762 CIVIL TERM TIMOTHY A. COOK, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint In Divorce under ~ 3301 (c) of the Divorce Code was filed on April 4, 1997. 2. The marriage of plaintiff and defene/anl is Irrelrievably broken and ninety days have elapsed from the date of filing and service 01 the Complaint. 3. I cons en I 10 the enlry of a final Decree in Divorce aller service of notice of intention to request entry of tho Decree. I verify that the slatements made In this Affidavit are true and correcllo the besl of my knowledge, Information and belief. lundersland thaI false statemenls herein are made subject to lhe penalties of 16 Pa.C,S, 4904 relating to unsworn falsification to authorities. e~ l CceL Rhonda L. Cook. Plaintiff C' Dale: '1 '.;2.3' q If WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301(c) OF THE DIVORCE CODE 1, I consenl to the entry of a final Decree of Divorce without notice. 2. I understand thai I may lose righls concerning alimony, division of property, lawyer's fees or expenses III do nol claim them before a divorce is granteet. 3. I understand thaI I will not be divorced unlil a Divorce Decree is enlered by the Court and that a copy of the Decree will be sent to me Immedialely after it Is filed Wilh the Prothonotary, I verify that the statements made in this Affidavll are true and correct to the best of my knowledge, Information and belief. / understand that false statements herein are made subject to the penallles of 16 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~L. l ('(1)L honda L. Cook. Plaintiff Date: If -d2>. ')If- ~ to '- (;~ (,: ~~ .. ...., 11.10 r': ; ,.~ ().' , f -( <:i l.. U._ ) . , 61- .- @' '.") . ./} , . ~.... . , N . .l:i:; ,.. ~=!L' ...J .,m fL. ::.J '-'IU- (. -; " -.0 t3 ..... .:J cr ()