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HomeMy WebLinkAbout97-01990 \ I I i 1 I i .~ I I ~ I , I I i VI I ~ I ~ 1 I . 4< \ ~ j .'.<" .t' " ( \, ~ -:--- - .;) - '-J 1 ~ ' [.;. ' "I . t' ~: . ~ . . *****-********-**--*._-~------~ ~- -~~--~--- -~.~--~ _._~ ,', ',' ~ .. ~ ',' ~ ~.. IN THE COURT OF COMMON PLEAS ~ '.' ~ '.. ~ '.' ~ ~ '.' OF CUMBERLAND COUNTY STATE OF '* PENNA. ~ '.' ~ '.' ~ ',0 ~ ',0 ~\ ',0 ~ '.' ~ ~ '.' s ~ ~ '.' ~ ',0 i'\ I) "p9}::l~~o._ BRENDA K" KING, Plaintiff ..............,.. $ ~ ',0 .', t- ~ ',' ~ Vel":iW; ~, *. '.' HARK C, KING, Defendant $ ~ i~ * $ ~ '.' .' S DECREE IN DIVORCE s ~ '.. ~) ,,' ) !i ~.' AND NOW. ........,. .~fi1.r.ch,. .~. i:" 19 .r~.., it is ordered and decreed that". " "B.~E,N.n.~ ,~.,,~I,~~ " ' , " "" " , . " , , ""," "" plaintiff. and."".".,,"" .~~I.\l~. 9:, l,<~~9"".,...".'''''''''''''''''' defendant, are divorced from the bonds of matrimony. ,', S ~ ~ ~.' ;i. ',0 The court retains jurisdiction of the following c10ims which have been raised of record in this action for which a final order has not yet been entered; ~ '.. $ ~ ',0 ~ The. part,ies.'. Post. <Iadtal, Ag_reemellt, dated, ~la.rch .15", .[,9,97. .:1.s .inc.o.r,por-at.ed . , herein, and the. CDurt, haB_ jur;l.Bdil',t;l.P)1. py,e,r, )1.0. ,o.the,r, ,c,I,aJJ1\S.., ., , . . . , . , . . . . . , s ~ ',0 ~ '.' n y Tee 011; Ii- ^"..,(:~~ l'rothonotnry ~ J, ~ ~ '.. ~ " ~ ~ .:.:- .:+:- .:.:. .:.:. .:+;. .:+> .:~:. .:.:- .:+;. .:.:. .:.:- .:+:. .:+:.' ~ 7- ~ :1 ''''' ~~~***~*~'~'*'*~***** ~ '.. ~ '.. ~ '.. ~ ~ ~l ~ ~.' ~ ',0 $ $ ~ '.' 't: '.' ~ )',0 I~ )", \~ .~ /' ~, ~ , , I~ .~ ~ :!. PROPERTY AND SEPARATION AGREEMENT This Agreement made and entered this.lli:.. day of CY'\,.n' '" ,19D by and between MARK C. KING, hereinafter referrcd to as Husband, and BRENDA K. KING, hcreinafter referred to as Wifc, witnesseth: WHEREAS, the parties hcreto are husband and wife, they having been married on November 18, 1995 at Waynesboro, Franklin County, Pennsylvania; and WHEREAS, the parties hereto have ceased to cohabit togcther as husband and wife; and WHEREAS, both and each of the parties hereto have been advised of their right to seek legal counsel and that said legal counsel would explain to them their legal rights and the implications of this Agreement and the legal consequences which may and will ensue from the execution hereof; WHEREAS, Wife acknowledges that she is thoroughiy conversant with and accurately knows the size, degree, and extent of the estate and income of Husband, and Husband acknowledges that he is thoroughly conversant with and knows the size, degree, and extent of the estate and income of Wife; WHEREAS, each of the parties hereto in the negotiations leading to and in the execution of this Agreement have been advised of their right to be represented by legal counsel and are aware of their right to have their respective legal rights explained to them thereby, Husband being represented by David R. Yoder, Esquire, and Wife having declined any representation. WHEREAS, the parties hereto wish finally and for all time to settle and determine their respective property and other rights growing out of their marital relation; wish to live separate and apart; and, wish to enter into this property and separation Agreemcnt. NOW, THEREFORE, in consideration of the promises and mutual undertakings herein contained, intending to be legally bound hereby, the parties do mutually agree as follows: 1. SEPARATION: The parties may and shall continue to live apart for the rest of their lives, Each shall be free from interference, direct or indirect, by the other as fully as though unmarried. Each may for his or her separate benefit, engage in any employment, business or profession he or she may choose, 2. MUTUAL ESTATE WAIVER: It is the intention of the parties hereto that from and after the date of this Agreement, ncither shall have any spousc's rights in the propcrty or estate of the other, and to that end, both waive, relinquish and forebcar their rights of dower or curtesy, right to inherit, rights to claim or take a husband or wife's or family exemption or allowance, to be vested with letters of administration or testamentary, and to take against any will of the other, The parties further agrce that they may and can hereafter, as though unmarried, without any joindcr by him or her, sell, convcy, transfer, and/or encumber any and all real estate and personal property which eithcr ofthcm now or hcreafter owns or posscsses and furthcr agrce that the 2 , recording of this Agreement shall be conclusive evidence to all of his or her right to do so. And the said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given become necessary, the right and powcr to appoint one or more times any person or persons, whom Husband and Wife shall designate, to be the attomey in fact for the other, in their name and in their stead, to exccute and acknowledge any deed or deeds, releases, quitclaims or satisfactions, under seal or otherwise, to enable either party hercto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waive any right of election contained in Chapter 22 of the Pennsylvania Probate, Estates and Fiduciaries Code, 3, DEBTS: Except as otherwise herein expressly provided, the parties shall and do hereby mutually remise, release and forever discharge each other from any and all actions, suits, debts, claims, demands and obligations whatsoever, both in law and in equity, which either of them ever had, now has, or may hereafter have against the other upon or by reason of any matter, cause or thing up to the date of the execution of this Agreement. Each party hereby specifically agrees to hold the other hannless, and indemnify the other with regard to any debts relating to credit cards in that party's name, whether contracted before, during or after the marriage, Husband specifically releases, holds harmless, and agrees to indemnify Wife with regard to any indebtedness relating to the marital residence at 13808 Harbaugh Church Road, as more fully set forth in Paragraph 5. In the event that either party becomes a debtor in bankruptcy or financial reorganization proceedings or any kind while any obligations remain to be perfonned by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under state or federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor spouse, and the debtor spouse hereby assigns, transfers, and conveys to the creditor spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the creditor spouse as set forth herein, including all attomey's fees and costs incurred in the enforcement of this paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardlcss of federal or state law to the contrary, and each party waives any and all right to assert than any obligation hereunder is discharged or dischargeable, The failure of any party to mcet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of conditions precedent, shall not in any way void or alter the remaining obligations or either of the parties, 4, PERSONAL PROPERTY: The parties make the following disposition and settlemcnt with respect to their personal property: (a) The parties agree that the following itcms of personal property will be distributed to Wife; the television, video cassette recordcr, the compact disc player, and the vacuum cleaner, Husband shall retain thc other personal property currently in the marital residence, and specifically retains the grill, the snowblowcr, and the dishwasher, (b) Joint Bank Account: Wife shall retain all funds currently located in joint bank accounts at lhe First National Bank and Trust Company of Waynesboro, Checking 3 . .- account #00902039, Savings account #010-654754, Christmas Club Acct. #1804120, and at the Patriot Fcderal Credit Union, Savings Account #4000758460. (c) Stock: Wife shall rctain all shares of stock purchascd during the marriage from Financial Trust Corporation. (d) Except as otherwise hereinabove provided, each of the parties shall hereafter own, have and enjoy, independently of any claims or right of the other party, all items of real and personal property, tangible and intangible, now or hereafter belonging to him or her and now or hereafter in his or her possession, with full power to him or her to dispose of the same as fully and effectually, in all respects and for all purposes, as though he or she were unmarried. As to all such property, each party transfers all his or her right, title and interest therein to the other, respectively. 5. REAL PROPERTY: The parties hereto acknowledge and agree that the residence located at 13808 Harbaugh Church Road, Waynesboro, Pennsylvania, which is an improved tract of real estate situate in Washington Township, Franklin County, is held by Husband in his sole name, and more specifically described in Franklin County Deed Book Volume 1163, Page 417. Wife hereby agrees to release any interest she may have in that property, in consideration for the Husband's assumption of all indebtedness related to that property, whether recorded or unrecorded, and in consideration of the other mutual covenants and agreements herein contained in the body of this Agreement. Husband specifically releases, holds harmless, and agrees to indemnify Wife with regard to any such indebtedness, This shall specifically include the indebtedness to Husband's parents Glenn King and Ina Mary King, of 12139 Snyder Avenue, Waynesboro, Pennsylvania, under the tenns of the Note dated November 18, 1995. 6. DIVORCE: Neither party has commenced an action in divorce, but both parties intend through their execution of this Agreement to signal their intention to effectuate such a divorce, Neither party is bound to bring such action by this Agreement; both parties agree not to present a defense to any divorce action which may be brought. Both parties agree that such divorce action shall be brought in a Court of Common Pleas of any county within the Commonwealth of Pennsylvania, and specifically agree not to present any objection to venue for any action so brought. (a) Each of the parties agrees that this Agreement represents a complete and final agreement as to their respective property rights which arose from the marital relation and therefore mutually waive any and all rights they may have under Section 3502 (Equitable Distribution) of the Pennsylvania Divorce Code, Act No. 1980-26, 4 . '- (b) This Agreement may be offered in evidence in the action for divorce and may be incorporated by referencc in the decree to be granted therein, Notwithstanding such incorporation, this Agreement shall not be mcrged in the decrcc, but shall survive the same and shall be binding and conclusive on the parties for all time, 7. ALIMONY PENDENTE LITE AND ALIMONY: Husband and Wife do hereby waive, release and give up any rights they may respectively have against the other for alimony, support or maintenance, It shall be, from the execution date of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party, 8, VEHICLES: Husband will retain the Chevrolet Cavalier, Wife will retain the Chevrolet Lumina. 9. VEHICLE INSURANCE: Beginning with the second quarter of 1997, each party will be responsible for their own insurance, 10. COUNSEL FEES AND COSTS: Each party shall be responsible for their individual counsel fees and costs. 11. MEDICAL COVERAGE: Each party shall obtain their own, neither shall be responsible for the other party's medical coverage from the date of execution of this document forward. 12, EQUITABLE DISTRIBUTION: By this Agreement, the parties have intended to effect an equitable distribution of their marital property. The parties have detennined that an equitable distribution of such property conforms to a just and right standard with due regard to the rights ofHusband and Wife. The distribution of existing marital property is not intended by the parties to constitute, in any way, a sale or exchange of assets, and the distribution is being effected without the introduction of outside funds or other property not constituting a part of the marital estate, 13. APPLICABLE LAW: This Agreement shall be governed by the laws of the Commonwealth of Pennsylvania. 15. MODIFICATION AND WAIVER: No modification or waiver of any ofthe terms hereof shall be valid unless in writing and signed by both the parties, No waiver of any breach hereof or default hercunder shall be deemcd a waiver of any subsequcnt breach or default of the samc or similar naturc, 15. BANKRUPTCY: The respcctive dutics, covcnants and obligations of each party under this Agreement shall not be dischargeable by bankruptcy, but if any bankruptcy court should discharge a party of accrucd obligations to the other, this Agreement shall continue in full force and effect thcreaftcr as to any duties, covenants and obligations accruing or to be performed thereafter. 5 16. RECONCILIATION: The parties shall only effect a legal reconciliation which supersedes this Agrcemcnt by their signed agrcement containing a specific statement that they have reconciled and that this Agre~ment shall be null and void; otherwise, this Agreement shall remain in full force and effect, Further, the parties may attempt a reconciliation which action if not consummated by the aforesaid agreement, shall not affect in any way the legal effect of this Property and Separation Agreement or cause any new marital rights or obligations to accrue. 17. ENFORCEABILITY AND CONSIDERATION: This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties, and independent legal action may be brought to enforce the tenns of this Agreement by either Husband or Wife until it shall have been fully satisfied and perfonned. Consideration for this contract and Agreement is to be found in the mutual bencfit to be obtained by both parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for the mutual undertakings herein set forth is stipulated, confessed and admitted by the parties, and the parties intend to be legally bound hereby. ,;0 , .i' i I ,I 18. DUTY TO EFFECTUATE AGREEMENT: 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 assurances that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. In addition, the parties hereto agree that within ten (10) days of the date of submission by the other party, either party shall sign any document neccssary for the completion and effectuation of the terms of this Agreement. Any costs, including attorney's fees, necessitated by enforcement of this Agreement shall be borne by the party refusing to honor the terms and conditions of this Agreement. 19. NOTICES: Any and all notices given hereunder shall be in writing and shall be sent by registered mail, return receipt rcquested: (a) To the Husband at 13808 Harbaugh Church Road, Waynesboro, PA 17268. (b) To the Wife at 534 Third Street, Carlisle, PA 17013. (c) If either party shall move they shall provide the other party with a forwarding address for notification purposes. 20. WHOLE AGREEMENT: This Agreemcnt constitutes the entire understanding of the parties. It supersedes any and all prior agrccments betwecn them, There are no representations or warranties othcr than those cxpressiy herein set forth. 21. CAPTIONS: The captions of this Agrecment are inserted only as a matter of convenience and for refercnce and in no way define, limit or describe the scope and intent of this Agreement, nor in any way affect this Agrecmcnt. 6 22. DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date, Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. ' AND further the parties hereto covenant and agree that this Agreement shall extend to and be binding upon their heirs, devisees, executors, administrators and assigns, of both and each of the parties hereto, AND the parties hereto state that he or she, in the procurement and execution of this Agreement, has not been subjected to any fraud, concealment, overreaching, imposition, coercion, or other unfair dealing on the part of the other, or on the part of the other's counsel. IN WITNESS WHEREOF, the parties have set their hands and seals to two counterparts of this Agreement, each of which shall constitute an original, the day and year first above written. WITNESS: ~,,:fi- (SEAL) ~(,./11~ ~~Ct. t ~ (SEAL) Brenda K. King ~ 7 -. . ., ...... COMMONWEALTH OF PENNSYLVANIA: : SS 6~ . ~ . lSt/I\. ~ J fet\er.\lallq"'.\l,."O~ ~~in~I~.,f:~7;9,~1 WCO~~ - COUNTY OF FRANKLIN On this, the t:L. day of 9Y; If ~ ,l1.:t7 before me, a Notary Public, the undersigned officer, personally appeared Mark C. King, 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 han~ and official seal. Not COMMONWEALTH OF PENNSYLVANIA: : SS COUNTY OF FRANKLIN On this, the K day of lY7 ~ , 192.;>before me, a Notary Public, the undersigned officer, personally appeared Brenda K. King, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. a..~~ll?'~ C, yV7~. Notary Public /...,----- ~'.' ,.... r.c'r,'\;:',':',!.;,r.. - ....."'11.\ (' 1""" """" . ",' .'.',' 1., ... \'. ,.~. ,WI." ,",: ,.".:: .1.:~.:. t. t,'.lr'~R'" PU',j /("'1] '::~>:.~,~: ... ,-~~~'~';"~~~.,L:,;:/t1,\;Z}, 8 " n ,.0 ,'") (' O"J ." -~ ,-I ~ ~- ri"l - . -,' " ',~ ' \:!I ~~ ,:" ro- N "8 " "- t...l ::,I~ _'f. r I .-' ~j(- ~~l.; _. 0, :H :- "'0 ~~~~: -:-...c ~.) ;_~Vn -;' );! ~ :J1 ~ ..... , BRENDA K KING, PlaintilT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 97-1990 MARK C. KING, Defcndant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decrec: I. Grounds for divorce: irretrievable brcakdown under Section 3301 (c), ~f the Divorce Codc. (Strike out inapplicablc section). 2. Date and manncr of service of the Complaint: Certificd Mail. return receipt re ucstcd rcstrictcd dclive madc on A ril 18 1997. 3. Complete either paragraph (a) or (b). W Date of exccution of the affidavit of consent required by sec. 330 I (c ) of the Divorcc Codc: by plaintilTMarch 20, 1998; by defcndant Februarv 25, 1998. (b) (I) Date ofexeculion of the affidavit required by sec. 3301 (d) of the Divorce Codc: ; (2) Date of filing and service of the plaintiWs affidavit upon the defcndant 4. Rclatcd claims pcnding: None 5. Completc either (a) or (b). (a) Date and manncr ofservicc ofthc Noticc oflnlention to filc Praccipe to transmit record, a copy of which is attachcd I . ,j, >- en ~ ~ lJ') i~ N ::J< x: 8~,l 0- ~ &? r.)~ M 3~ Q, N ~~ p,: (~(5 IL, c. no.. ~ a t; ex) 0" \,. ~ . '" .' r " lAW OffiCE Of Jacqueline M. Verney " ~ '., 445. HANOVER ST. . CARUllE, PA 17013 . (717) 24],9190 . fAX (71 n 24],]518 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , II I f ! i , BRENDA K. KING, Plaintiff t'" v. CIVIL ACTION - LAW IN DIVORCE MARK C. KING, NO, 97./q<fO Civil Tenn Defendant COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, this nJrday of April, 1997, comes the Plaintiff, Brenda K. King, by and through her attorney, Kathleen D, Keating, and files this Complaint in Divorce, and states as follows: 1. Plaintiff is Brenda K. King, an adult individual, who currently resides at 534 Third Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Mark C, King, an adult individual, who currently resides at 13808 Harbaugh Church Road, Wayncsboro, Franklin County, Pennsylvania, 17268. 3. Plaintiff and Defendant have bcen bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately prcvious to the filing of this Complaint. 4, Plaintiff and Defendant wcre married on Novcmber 18, 1995 in Waynesboro, Franklin County, Pennsylvania. 5. There have bcen no prior actions of divorcc or for annulment between the parties. 6. The marriage is irrctrievably broken, Thc foregoing facts are averred and brought under Sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 7. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court rcquire the parties to participate in counseling. Having been so advised, the Plaintiff docs not desire the Court to order counseling. WHEREFORE, Plaintiff rcquests Your Honorable Court to enter a decree in divorce, divorcing Plaintiff from Defendant. Respectfully submitted, athleen D. Keating, Esqu' e Attorney I.D. # 66271 44 South Hanover Street Carlisle, PA 17013 (717) 240-0145 Attomey for the Plaintiff il I, i I I I I I I :1 'I " i' VERIFICATION , ~ I I I i. I , '~'I I verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual avcrments contained herein, and not to legal conclusions and averments authored by counsel in her capacity as attomey for the party or parties hereto. 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.Cj.lj-, ~lc-.. ~ ~ Brenda K. King, Plaintiff ~ ~, :3 n (.l ." c: I ~ "69- ","" ""Q. . " or- ") ~, -' <n ~ --- '" B'':' ~ t", ;. ,- ;6 0 !..\. . ,-J !31 ~ (". >'. ~1. r;; ~ '. . :-" p~ ; '~l) a e ~ '- ", .rn ~ ~ .: I" ~9 l:~ 0 ~; 'J' 4Q ~ '. :.D. ~ ~; \ I'" '< ff!~ -'. w ~ - , I ". IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. KING, Plaintiff CIVIL ACTION - LAW IN DIVORCE v. MARK C. KING, NO.97-1990 Civil Tenn Defendant CERTIFICATE OF SERVICE AND NOW, this 21st day of April, 1997, I, Kathleen D. Keating, Esquire, hereby certifY that the following person was scrved with a Truc and Correct copy of the Divorce Complaint filed in the above-refcrcnced matter. The Divorce Complaint was mail cd on April 17, 1997, but actual service. took pl'ace on April 18, 1997 by Dcfendant signing for a copy of the Divorce Complaint which was mailed in the United Statcs Mail, Certified Mail -- Return Reccipt Requested, Restricted Delivery, Postagc Prcpaid. addressed as follows: Mr. Mark C, King 13808 Harbaugh Church Rd Wayncsboro, PA 17268 A copy of the signed Domcstic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated hercin and made a part hereof. //' t.- 1) , ~~n D. Keating, Esqui e Attorney I.D. # 66271 PO Box 1103 Carlisle, PA 17013 (717) 240-0145 ~ co ~~ In 6 N ~~ ::t: u~ 0... o~ ~~ M 3~ N ,;?- -J~II 0:: n-?;j ti:iE < 1:1" roc.. :c a u.. . C). 0 en , , ""'" ""'" -GJ,<;;7,. . . , ~-;::, lAW OHIC! OF , '",~ Jacqueli.ne M,. Verney , , . . . 441, HANOV!A IT. . CAWII.!,PA 17015' (111)24).9190' FAX (117) 24).H1S IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. KING, Plaintiff CIVIL ACTION-LAW IN DIVORCE V, MARK C, KING NO, 97-1990 Civil Tenn Defcndant AFFIDAVIT OF CONSENT 1. A Complaint in divorce undcr Scction 3301(c) of the Divorce Code was filed April t 7, 1997. I I I i I. I , 2. The marriage of the Plaintiff and Dcfendant is irretrievably broken and ninety (90) days have clapscd from thc date of the filing of the Complaint in Divorce. 3. I conscnt to thc cntry ofa final dccree of divorce aftcr scrvice of notice of intention to rcquest entry ofthc dccree, I vcrify that the statements made in this Affidavit are true and correct. I ','c'c' undcrstand that fa1sc statcmcnts hcrcin are made subjcct to the penaltics of 18 Pa, C, S, ';':',',j"' .d.,' ,<','.-,,,,' ~~~ >>~N '11~ .~~~ i ~~~ .' seetion 4904 rclating to unsworn falsification to authoritics. Date:~ ~L~ BRENDA K. KIN ~ a) ~ ~~ In .. ::J.,. N )6 ::c 8~ ~~ u. ~~ M "- N rH~ ~ Cf': Kt m :;: a ~ cD C'l 9~ I .' . , ' ..z:?'7 ~~. lAW OIfIC! OF Jacqueline M. Verney , 'I . , , -.'. 4H,~OV!AlT,. CAAUlu,IA170n' (117) 24J.9190 . fAX (117) 24J,1S18 IN THE COURT OF COMMON I'LEAS OF CUMBERLAND COUNTY, I'ENNSYLVANIA BRENDA K. KING, Plaintiff v, C1VtL AcnON-LA W IN DIVORCE MARK C. KING NO, 97-1990 Civil Tenn Dcfcndant WAIVER OF NOTICE OF INTENTION TO REQllEST ENTRY OF A DIVORCE llNDER 330t(C) OF TilE DIVORCE CODE L I consent to the entry of a final dccree of divorce without notice. 2, I understand that I may lose rights conccrning alimony, division of property, lawyer's fces or cxpenses if I do not claim thcm before a divorce is granted. 3, 1 understand that I will not be divorccd until a divorce dccrcc is entercd by the Court and that a copy of the decrce will be sent to me immediately after it is filed with the Prothonotary. I verify that the statemcnts made in this Affidavit are true and corrcct. I understand that false statcments herein are made subjcct to the penaltics of 18 Pa. C. S. section 4904 rclating to unsworn falsification to authoritics. Datc:-..5'.I ~ 0 19. r ~.f't'01c. Y Y'J~ BRENDA K. KING, Plai Iff ~ en ~ In II N 8 ::c t.J~ ~, Cl.. ~~ M m~ N 0:: ' tQsE ~ x: a t;; ,CC 01 .;e' ~ '" . ~~' . 01 , ~~, . ' lAW Ollie! 01 Jacquel~n~.~. Verney '. , . 441, HANO'IEA ST, . CAWILl, PA 17011 . (717)10.9190 . lAX (711)I4J.lll! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. KING, Piaintiff CIVIL ACTION - LAW IN DIVORCE v. MARK C. KING, NO, 97-1990 Civil Term Dcfendant AFFlDA VIT OF CONSENT 1. A Compliant in divorcc undcr Scction 3301(c) of thc Divorce Code was filcd April 17, 1997. 2. The marriagc of the PlaintilT and Dcfcndant is irrctricvably brokcn and ninety (90) days have e1apscd from the datc of thc filing of thc Complaint in Divorce. 3. I consent to thc entry of a final dccrcc of divorce after scrvice of notice of intention to requcst cntry of the dccrce. I vcrify that thc statcments made in this Aflidavit are true and corrcct. I undcrstand that falsc statemcnts hcrein arc madc subjcct to the pcnaltics of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities, Date: 1 - zs - '\ lQ ,.--f ..~.. 1 ~ IX) ~ ~~ In .. ..- , N (3~ :c <.1; 0- ~1~ ~r.) M ::s~ ~ N -\II 0: lC~ III if or.< ((J x: ~ b CO 0' ',f,,', ...'/: ~- . f. '. . . 'f;1 ~- .- --- --. lAW OIllC( OF Jacquel~nI?M. Verney , . .. 441,HANOVUIT,' CAWllf,PA1101l' (111) 24J.9190 . rAX(711)Z4I,IlIB IN THE COURT OF COMMON I'LEAS OF CUMDERLAND COUNTY, PENNSYLVANIA BRENDA K. KING, Plaintiff v. CIVIL ACTION - LAW IN DIVORCE MARK C. KING, NO.97-1990 Civil Term Dcfcndant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l330/(c) OF THE DIVORCE CODE 1. I consent to thc entry of a final decree of divorce without noticc, 2. I understand that I may lose rights conccrning alimony, division of property, lawycr's fees or cxpenscs if 1 do not claim them bcforc a divorcc is grantcd. 3. I undcrstand that 1 will not bc divorccd until a divorce dccrce is entercd by the Court and that a copy of thc dccrce will bc scnt to mc immcdiatcly aftcr it is filed with the Prothonotary. 1 verify that thc statcn!cnl~ madc in this At1idJvit lIrc truc ann ':orr~cL I m:dcrsl:md that false statemcnts hcrcin are made subject to thc pcnaltics of 18 Pa,C,S. ~4904 rclating to unsworn falsification to authorities, Date: Z-ZS-q~ tJ/,J; C~' , r ,King, ~ DcCcndant .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. KING, Plaintiff v. CIVIL ACTION - LAW IN DIVORCE MARK C. KING, NO. 97-,Q90 Civil Tenn Defendant AFFIDA VIT I, Brenda K. King, being duly swom according to law, deposc and say: 1. I have been adviscd ofthc availability of marriage counscling and undcrstand that I may request that the Court require that my spouse and I participate in counseling, 2. I undcrstand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon requcst. 3. Being so advised, I do not rcquest that thc Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I undcrstand that false statemcnt hcrcin made arc subject to the penalties of 18 Pa. C,S, 94904 relating to unsworn falsification to authoritics. Dated: I././~. G 7 $y.....ck~ L I~~ Brenda K. King, Plaintiff " . ( \.') t') ,. -I "'I ::.~ .. , --C "1.' ~J t-;' :'1 , .-.) .j" ,-. :6 -'" -q '.n :i') " r"J ,rll - ~~3 ~n .~.~ ", , ; .:") ,--1 ---I -" "':<0 I .' ~:-' , , , ',-- " ',} ,J ~ :.:..' :,!') . "1 I , 1__. .() );1 I I ',) .<.1 \{'J ..;. t-.. :TaC{l'teIt/l~o../U: 1Je/YIfY' . '. ~ --. 441. HANOVU IT. . CAAUll.l,PA170U' (717)24].9190' FAX (717) 24J,Il18 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. KING, Plaintiff v. CIVIL ACTION - LAW IN DIVORCE MARK C. KING, NO. 97-1990 Civil Ternl Defendant PRAECIPE TO THE PROTHONOTARY: Pleasc cntcr my appearance for thc Plainliff, Brcnda K, King, in thc abovc-captioncd mallcr, Respcctfully submittcd: v{-.-( L- ftl I!u~_u J . qucl eM. Verney, Esquire Attorney I.D. 1123167 44 South Hanovcr Strect Carlislc, P A 17013 (717) 243-9190 TO THE PROTHONOTARY: Pleasc \\;thdrnw my appearancc for thc Plaintiff, Brcnda K, King, in thc abovc-captioncd mallcr. Rcspcctfully submittcd: <-I>.L I. ~ :<: thlecn D. Kcati g, Esq4ire Attorney I.D, 116627\ PO Box 1103 Carlisle, P A 17013-6103 (717) 240-0145