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HomeMy WebLinkAbout97-01895 \ I I I s " " -' ./~ I , I -- / s ~ j - I . . .':l - CJ ~ 2:- ....... . ' C"'-, 0- --------------------~---------~ ~' '~--~~-,~ ,,-. ---~-----~---..~~~~.--,~,~---,..- w ',' ~ ?- ~ ~ IN THE COURT OF COMMON PLEAS ~ ~ ,;, y ~ ~ OF CUMBERLAND COUNTY ~ STATE OF ~~~~ PENNA. ~ '.' ~ '.' $ $ ~ ',' GEORGE F. DAGLE, IfNs- 97-rlHTS- CIVIL TERM N (), "HHH'H 'H"H"HH" 19 ~ '.' ~ '.' Plaintiff ~ '.' Vt'J'.-i!lS ~ '.' DANA L. DAGLE, ~ '.' Defendant ~ '.' " ~ ',' ~ ',' DECREE IN DIVORCE AND NOW, . , . .~~. . . .~,?-:-:, " 19 ~.7" it is ordered and decreed that .,....., ~.e.~~~~. ,~: . ~.~~~e. . . . . . . . , " . , . . . , . . , . , '. plaintiff, and. .,.. ..,.,..,., ,. .~~?~. .~:, ~,~~~~... . .. .... ,. ... . ...,. , ". defendant, ore divorced from the bonds of matrimony, ~ '.' ~ ',' ~ ~.~ .. S ,'. :0. .' ~ ~.I ~ ~.4 ~ ',' w ',' The court retains jurisdiction of the following claims which have been raised of record in this action for which 0 final order has not yet been entered; None. The parties have executed a Marriage Settlement Agreement dated January 5, 1998, which Agreement has been filed of record at the within term and number, and 'wh'fcn' llgreem'erii:' i's . inc'orporatect' 'in' i:'liis' '{iriai' 'Oecr'ee 'in' , , . . . . . . Di.v.orce. but. .is nat .mer.ged. herein. . .. . . . . . . . . . . . , . . , . . . " . , ., ,. . . . , . / ~/ . / ny T~J~ ^th..I: ~t.-~;J 0.J.t;~ : 8 ~<~ ~"'/~' ~ 2" g;J 7 ' '7 Prothonotary ~ '.' ~ ~ ~ '.' ,'. ~ ~ ..' ~ ~. !~ )'- I,:. J. {~ I,:, I~ !'(: I; ': . ,. , '~ -:.;. .:.:- .:+;. .:~:. .:+:. .:+;. -:.:. -:.;. .:.:. -:.:- ~ '.' ~ ~." ~ ~ 7- & fo! 7- '------ '''-' , .. _...... _ ..., _. ....., H . ~~~-~*-~~*~*****~.*** ~ ~ ',' ,', ~ ,~ ~ .'; ~ ~ '.' ~ '.' ~ ~ '.' ~ '.~ ~ '.' ~ !~ ~ ',' ~ '.' ~ '.' ~ ,? .:, ~ ~ ~.' ,', ~ ~ $ ~ ',' ~ ',' * ~ ~ * ~ /.~ 9y dd ~~ A~.A,t ~'a4 ~ /0lC) t'~ 6 J - / // - ~ cr ('d!~ /la~/ zf ~ (//4 / r<< '1" ~J {~if .t<.-bo&' .- .., ~ MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this S "&:. day of ~C'I. "'-J.l to ~ l~ Mechanicsburg, 1998, by and between GEORGE F, DAGLE, of Cumberland County, Pennsylvania, hereinafter referred to as "Husband", and DANA L. DAGLE, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife." WITNESSETH: WHEREAS, Husband and Wife were lawfully married on August 12, 1972; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they are living separate and apart from each other; and WHEREAS, the parties are the parents of two children, both of whom are adults and play no role in this Agreement; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them, NOW, THEREFORE, the parties intending to be legally bound hereby, do covenant and agree: 1. SEPARATION. It shall be lawful for each party at all times hereafter to continue to live separate and apart from the I , , :'~. . ., ,- ~;. I I I', '. f, , other party at such places 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, which "living apart" has existed within the marital household of the parties for a substantial period of time prior to the date of this Agreement. 2, 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 , , I . , , I I I I , I r I. ", !'II carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor , I I.. compel the other to cohabit with the other, or in any way harass ; 1,- or malign the other, nor in any way interfere with the peaceful 110-' existence, separate and apart from the other. 3. WIFE'S DEBTS. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts and obligations incurred by the Wife prior to the date of the delivery of this Agreement, and all further debts incurred by the Wife from and after the date of delivery hereof, shall be the Wife's individual responsibility. 2 '. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Husband acknowledges and agrees that all debts and obligations incurred by the Husband prior to the date of the delivery of this Agreement, and all further debts incurred by the Husband from and after the date of delivery hereof, shall be the Husband's individual responsibility. 5. JOINT DEBTS. The parties have no joint debts, except for the two mortgages upon the marital home, and these items of indebtedness are separately treated in a subsequent paragraph entitled REAL PROPERTY. 6. MInITJAL RELEASE. 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 and except for any or all causes of action for breach of any 3 provision of this Agreement. 7. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that each has made a full and complete disclosure to the other of all information pertaining any marital property or non-marital property which each or both of them may own, possess and/or which may be controlled or possessed by each other at the time of the separation of the parties, and each is hereby satisfied with the disclosure made, and each does hereby waive the necessity of the filing by either of them in the pending action in divorce of a formal Inventory and Appraisement. 8. DIVISION OF PERSONAL PROPERTY AND BANK ACCOtmTS. The parties acknowledge that they have already agreed upon a division of banking accounts which had previously been shared by them during their marriage, and they have agreed upon a division of the articles of personal property which had heretofore been utilized by them during their marriage. Attached hereto are two Exhibits. Exhibit A sets forth a list of items of personal property prepared by Husband. Exhibit B is a list of "Tools Retained By Wife." Wife agrees that t.he items set forth upon Exhibit A shall be, from this day forward, the sole and exclusive property of Husband. Husband agrees that all other articles of personal property of the parties remaining in the marital home, including those items identified on Exhibit B, shall, from this day forward, be the sole and exclusive property of Wife. 4 9. AUTOMOBILES. The parties agree to dispose of automobiles owned by them as follows: A. The 1993 Toyota Camry, presently titled in the name of Husband, shall be and remain the sole and separate property of Husband, with Husband solely responsible to pay the loan encumbrance associated with the acquisition of that automobile; and, B. The 1997 Toyota Carney, presently titled in the sole name of Wife shall remain the sole and separate property of Wife, with Wife solely responsible to pay the loan encumbrance associated with the acquisition of that automobile; and, C. The J.9BB Hyundai automobile and the 1992 Hyundai automobile, both presently titled in the sole name of Husband, shall be and remain the separate property of Husband, subject, however, to the Stipulation and Agreement that the two adult children of the parties shall continue to have the exclusive right to operate whichever of the foregoing vehicles is presently in the possession of such adult child. 10. REAL PROPERTY. The parties are the owners of a parcel of property known as 11 Wheatland Drive, Silver Spring Township, Cumberland County, Pennsylvania, said property being the former marital home of the parties. Said marital property is 5 encumbered by a first mortgage and a second mortgage, both of such mortgages being held by Members First Federal Credit Union. The parties agree to the following disposition of the marital home and its encumbrances: A. Husband shall execute a deed, conveying to Wife sole and exclusive title and ownership to the former marital home, said execution and delivery of deed to occur at a settlement at which the following shall also occur, to wit: (i) Wife shall refinance the present first mortgage upon the premises, as the result of which a new first mortgage, solely in the name of Wife, shall be secured, and, (ii) Husband shall, at the time of the settlement, pay, in full, the second mortgage upon the premises. B. In addition, at the aforementioned settlement, Husband shall deliver to Wife a judgment note, in proper form, in the sum of $10,000, with interest computed thereon at the rate of nine (9%) percent per annum, which judgment note and interest thereon shall be paid by Husband, upon the demand of Wife, on or after 2 years from the date of the aforementioned settlement. C. Wife agrees that Husband may continue to reside in the marital home, beyond the date of the aforementioned settlement, but no later than March 31, 1998, conditioned, however, upon the payment by Husband of the following: $500 per month rental, one- half of the monthly charges for electricity, water, sewer, trash 6 ; and basic telephone charges, and the entirety of any long distance telephone charges made or billed at the initiative or direction of Husband, and unless terminated by Husband or Wife, Husband shall pay the entirety of the monthly charges for TV cable service. In addition, and upon the execution of this Agreement, Husband shall deliver the sum of $500 to Wife as a "security deposit" to secure his faithful compliance with the provisions of this sub-paragraph. 11. RETIREMENT BENEFITR. Husband is presently employed by the Commonwealth of Pennsylvania and is a member of the Pennsylvania State Employees Retirement System, as well as being a participant in a deferred compensation program offered by the Commonwealth of Pennsylvania. Wife is self-employed and has established or has made arrangements to establish a retirement program which will provide benefits to her following her years of active employment. In consideration of the economic provisions otherwise set forth within this Agreement, each party does hereby release, relinquish and waive any interest which he or she may have in any retirement account, retirement program, pension plan, or any other form of retirement planning which is owned or sponsored by the other party, or is sponsored or maintained for the benefit of the other party, by any public or private agent or agency. Furthermore, in the event the employer of any party to this Agreement, or the sponsor of any retirement account of any t 7 party to this Agreement requires formal evidence of release and waiver of the retirement account by the other party, said other party hereby agrees that he or she shall execute such form of release and/or waiver as may be required. 12. SPOUSAL SUPPORT, ALIMONY. ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES. In consideration of the mutual Agreement of the parties to all of the terms of this Agreement, and, particularly, in view of the equal, and equitable, nature of the division of property between them, both parties agree that each of them has and does hereby waive and relinquish any right to claim from the other any spousal support, any alimony, any alimony pendente lite, or any claim to payment of any counsel fees or expenses incurred in the drafting of this Agreement or in the prosecution of an action of divorce. 13. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or may seek such other renedies or relief as may be available to him or her. 14. ENTIRE AGREEMENT, This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly 8 set forth herein. The terms of this Agreement shall become binding upon the parties hereto, upon the execution by the second party of this Agreement, and the rights and responsibilities hereunder shall thereupon be binding upon the parties, their respective heirs, executors, administrators and assigns. 15. MODIFICATION AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 16. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only, They shall have no effect whatsoever in determining the rights or obligations of the parties. 17. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and Agreement. 18. APPI.ICABLE I,AW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 19. VOID CLAUSE. If any term, condition, clause, or 9 , 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 all other respects this Agreement shall be valid and continue in full force, effect and operation. 20. ENTRY AS PART OF THE DECREE. Husband has initiated an action in divorce under ~3301(c) or (d) of the Pennsylvania Domestic Relations Code, filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 97-1895. It is the intention of the parties that the within Agreement shall survive the aforementioned action for divorce, and that no order, judgment or decree, temporary or interlocutory, final or permanent, shall affect or modify the financial terms of this Agreement. Simultaneously with the execution of this Agreement, both parties agree to execute Affidavits of Consent for the purpose of entry of a Divorce Decree under Section 3301(c) of the Pennsylvania Domestic Relations Code. This Agreement shall be made part of any such judgment or decree of final divorce, but shall not be merged therein. Husband agrees to provide to Wife, at his expense, a certified copy of the final Decree in Divorce. 21. VOI,UNTARY EXECUTION, Husband acknowledges that Carl G. Wass, Esquire, has acted as legal counsel to him in connection with the negotiation and preparation of this Marriage Settlement ]0 HAND TOOLS RETAINED BY WIPE I I I I , I Garden shovel Garden rake Lawn rake Coal shovel Snow shovel Pick Hose and hose reel 1 hand saw Shop vacuum machine Stepladder Quantity of tools purchased by wife at auction 2 pitchforks Weedeater Some screws and nails I, EXHIBIT B AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF /J~ SS: ..~J-. On this, the 5~ ~ day of 1998, before me, a Notary Public, the undersigned officer, ., personally appeared GEORGE F. DAGLE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ 10-: )1. y~' ~ry Public NOTARIAL SEAL NANCY L. BRESKI, Notary Public Hanlsburg, Dauphin COunty My Commission Expires March 16,2000 I I I. 12 - "~"~. ~','::~,;1' . O'_~"'j ~ ~J.~~~' . .. H~ ._._ ._,;;....l~~-~,,_"" " _. .' . . 11I"0:.. '.:' .1: .1':1.:.: III":. .... . 11'_' .'. .' !III;..". "11I'-"; f. ....11I.. II.... ........ "IlII' '11'_'."" ~ -',.,,11I,".,: ....,. ..... 1I11111111. . . .... '.' ell>..............................; 1...._:.:......._<;.:iII.III:._:.~>;1 . -.' .11I.. '. "', '11 .' '......:............'::..11I.11II..... ..;:'-..,:11I.,\ ;':;'..:" ........::.:. 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Ill.......... ..... ........... .........'....; ..........._......11........,....;..11.....:. _. .........,...11I.......... .................1..,. .........~:.....I......',.......; ..11I.......'...11III.. ...IIiII./......,.<.. .i. .:...... '.'.:.;;: !I._'IIII.,.: :.'; .11III' .11I, II: -.' ... ." ........_.". .... ;11II......,..... '. .;"ii'"...'..'''.''' . ...... ........ 11III'.' ..,;.:.. '1"1'":''' ... III.' . ;..~III..II..-....._.:.....:.IIlI.IIII:II..L...IIIl...II._...III,... ,-."..:!III...:....:....:.:..ii....f..IIII..IIII:......._,.IIIII;~III...............,:11III"..,...11II,:..11I..:.._..'...11I..;.._............-,...-..8._.......11II111II........, .';.....:II.III.......I';_ill,(:_....III.....~;.III11.II..=....'.,-.lll;.:~.f_..;;~.;.."ilI!:~..:_...IIlI....-...;.,I!l....1IIl...IBII'~.IIIIiI......;_:-._._..:_,..'c:....IIII;~..............:1I....'I...!iII.I.I.. ---., ~ GEORGE F. DAGLE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 97-1895 CIVIL Plaintiff vs. DANA L. DAGLE, CIVIL ACTION - LAW IN DIVORCE 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 Section 3301(c) 3301(d) (1) of the Divorce Code. (Strike out inapplicable section. ) 2, Date and manner of service of the Complaint: April 16, 1997, by certified mail, restricted delivery, return receipt requested, and by first class mail, postage paid. 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 Plaintiff, January 5, 1998: by Defendant, January 9, 1998: (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. ",~-. ,~ " , 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (check one) (a) Decree to be entered under 3301(d) (1) (i) of the Divorce Code; (b) Decree to be entered under 3301(c) of the Divorce Code; x (c) Not applicable. See Waiver filed with the Court. 6. The parties have executed a Marriage Settlement Agreement, dated, January 5, 1998 , which Agreement has been filed of record at the within term and number, and which Agreement is requested to be incorporated in the final Decree in Divorce, but not merged therein, Date: 'JD...~ \<.,\<l.ct~ ~ 96056-1 I I, GEORGE F. DAGLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. tN, n''?\' (lUK.-I T.u.v CIVIL ACTION - LAW IN DIVORCE vs. DANA L. DAGLE, Defendant COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DOMESTIC RELATIONS CODE 1. Plaintiff is George F. Dagle, an adult individual who resides at 11 Wheatland Drive, Silver Spring Township, Cumberland County (Mechanicsburg), Pennsylvania, 17055. 2. Defendant is Dana L. Dagle, an adult individual who resides at 11 Wheatland Drive, Silver Spring Township, Cumberland County (Mechanicsburg), Pennsylvania, 17055, 3. Both the Plaintiff and the Defendant have been bona fide residents of the Conunonwealth of Pennsylvania for at least six months inunediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 12, 1972 in Northumberland County. 5. There have been no prior actions in divorce or annulment between the parties, 6. The Defendant is not a member of the armed forces of the United States or any of its allies. 7. The Plaintiff avers that the marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court I ! I I I \' ". require the parties to participate in counseling. The Plaintiff does not desire counseling. 9. Plaintiff requests the Court to enter a Decree of Divorce. CALDWELL & KEARNS Date: ~f~ 7,lq,?? By Carl 3631 North Fro Harrisburg, PA (717) 232-7661 1. D. 1107268 Attorney for Plaintiff , f I , I, i I I'. VERIFICATION By: C~~~~ /Gt:ORGE . DAGLE I, George F. Dagle, verify that the averments in this Complaint in Divorce 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. Dated: 4-/4- / 'i 1 , , I !;i ,.\, III I .' II '::11,. .1:.,....',.1.; 'I>..'. ,'.'" .11, II,.:'.,'.' II,.,.,.".. "II""".":I,I,! I . I....,.' ,.".',..;..;.'.".;:...,..,....:.;. III III':'.' ,...;".:.:., ..,.'~;lIIII;IIl,1 .'..'., . .', ":' ...,......... '.'... .lIIIIll ; ...>ii.,:...II.".->,IIIl~=.,7.;;...;1Il..~:..IIl...1, .'..,7.1II.'...i.;III".III,III...-. .IIII......! ' .: "II',III'll.'lI!:II",III'''. "'. ", ,: .,. ."'. .' '.'.".11I....; .'..' , '.:; .,. .,...... ,,' .",.'. .....'.. >II!'II'''; ,...,..",.._:: ,';::, .,IiII',.:," ".,"..,.,.' ,,' ;.}~ I, .,' , '.:" '.11IIIII'.,..11I: 1IlII...,...IIII,IIII:, L "'_~-~~~"""".-- _,.,...,...'1."....'.'..'1'... . 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'...',:..;.....::.....,...... ,.'..,..._.-'....,'.,. ..',:".II~III,...,..:,',.".....,',_,<."...II,"_...,-,..','.11,...",....( :',.,.....'..,; .'_.'.'.:..; III,.,'.,.'.' ,11III,.".'..,.'...,.., .'..'......" "II':, I, '.'. 'iii." . 1.,,_,.. ,. ".,.1...,.,... " II '._.1.,.,.,."'" ..!.II"..II.......'.."..:" ."11,11I",.,,., '.-, , lIB..." _"..".:.,'.._..'_' ,.,..11II.,'..",'.,..,;'.-.,'.' .':'" ',,' .'11II,';11III.',_,' ',I'.."IIIIIIIIII",:..""_:."'.':;': ",11I.... _.,,:.:'..' '...11:..:,..:.."...11II:....; :,..1".., .:... .......,..,.......;..-.;,.,.,.... - '"'f~'-.'''''"''"'.~~".".''''''''''' :! '.11';.;", , ....~ " ..: ., GEORGE F. DAGLE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 97 - 1895 CIVIL DANA L. DAGLE, Defendant : CIVIL ACTION - DIVORCE ,- , _c> (') '- " -. I ~. I (' I ,'q "..- " , " , J , .' /1 , ,., " ., , : ~ I ! . ~ -) ~I n .. " :'1 " I" PRAECIPE TO ENTER APPEARANCE TO TIlE PROTIlONOTARY: Please enter my appearance as attorney for the Defendant in the above-captioned divorce case, DATED: April 23, 1997 o F. Blair Sup me Court ID #45513 5440 Jonestown Road P,O. Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 l' ::': " , ,\ -;-:- \ -:: ;l .~, ( : J , , ,- , ~,l \,p , f; S.j ~ ).{~ r: :-,. ,\ .-,1 -.' ( -' ::_-) , '-,' '\ \\ i ;.. \:l ) I \ I '_r1 I, t.t' --. GEORGE F. DAGLE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 97-1895 CIVIL Plaintiff vs. DANA L. DAGLE, CIVIL ACTION - LAW IN DIVORCE Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE C~ 1. A Complaint in Divorce under Section 3301(C) of the Divorce Code was filed on April 10, 1997. 2. Plaintiff acknowledges that a copy of the Complaint was served on the Defendant on April 16, 1997. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed, both from the date of the filing of the Complaint, and from the service of the Complaint. 4, I consent to the entry of a final Decree of Divorce without notice. 5, 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, 6. 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, 7. I have been advised of the availability of marriage GEORGE F. DAGLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 97-1895 CIVIL vs. DANA L. DAGLE, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE 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 10, 1997. 2. Defendant acknowledges that a copy of the Complaint was served on April 16, 1997. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed, both from the date of the filing of the Complaint, and from the service of the Complaint. 4. I consent to the entry of a final Decree of Divorce without noticp., 5. 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. 6. 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. 7. I have been advised of the availability of marriage