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HomeMy WebLinkAbout97-02409 ::::- ~ .a )( q: ~ ~ - - \l 3 "- 'it ~ / - . - ::J - . t"'- O'" .. . .... . *~~*~~*****~*~*~~.*~.~,~*~.'**ill~'*~*'~ ~' ,--------------------, --.~_._,.--................---...- ..---. -~----.__.~......-....--_."-......- ~ .,., , ~ -, ,.'." .._. '"-_."..,_..-..,. ,-----~-....------.~ ,...........,-~, ~ '.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~~~ rt. '~\ tc.~~_.." ~"~~J,."r ~ ~ ~l .. ~ ~ ~ STATE OF PENNA, ~ ~ ~ '.' s DANA M. MAXWELL, 1'\ ().9.7.:7249,9., "HH'H' ll) ~ Plaintiff ~ '.' ~ '.' ~ '.' ~ $ * ~ '.' $ * ~ '.' .. ~ ~ ~ '.' ~ '.' $ '.' $ DEe R EEl N L( L..r /)1/1 ~ IVORCE~ ~,~rrJ~ , . .~. , . " 19.9.7,.... it is ordered and ;. ~ ~,' ~ $ decreed that ..,'.,....., .~A!".~ ,/-!'. .~~, . . . . . . . . .. , .. . , . . . . '. plaintiff, and..,.. ,. ,.",.,.." .~y,:;;"~".,...,,. .....,. ...", defendant, 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; The Marriage Settlement Agreement dated April 25, 1997, is incorporated into' 'tnt's 'DeCree' 'oy' reference',' . The' Agreement' sh'a'li 'ricit',' 'however',' 'merge 1ft tb , tbis . Decree,. ..,..'.".,'"".,..,."...."....,......"".,....',.., ~ ~ ;{, ~ ;;: ~ ~ ---_.__.--~. - -~,-_..'" . '. "", - , - ~~~~~~~~******~..~**** ~ "t'I'SIIS ~ RANDY S. MAXWELL, * Defendant * ;t: '.' ~ ~ ~l .. ~ AND NOW. ' ,', ~ ~ * * ~ '.' * * ~ jt: .' ~ ~' ~ ~ * $ ~ ~ * ~ J. ~ ,..' I';: I':' i~ 1 :. I~ I,;: I~ I, :~ ~ ," ,~ ~ .:.:. .:.:- .:+:- .:~:. -:.:. .:.:. .:+:. -:~:- .:+:. .:+:. i~ . !'.J 17 ~ &P/1 :-:.!/1) 4 /'~ 'i'rJ '1') '7P-tu"e /'Ia~t?' -6 ~ --J v .. . II . . .. . DANA M, MAXWELL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-2409 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE RANDY S, MAXWELL, Defendant PRAECIPE OF 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)of the Divorce Code, 2, Date and manner of service of the complaint: Acceptance of Service signed by the Defendant on May 15, 1997 and filed August 19, 1997. 3, Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff August 8, 1997; by the defendant August 18, 1997. 4. Related claims pending: All issues have been resolved by the parties' Marriage Settlement Agreement dated April 25, 1997 to be incorporated but not merged with divorce decree, 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 330l(d) (1) of the Divorce Code: N/A. 6. Date and manner of service of Notice of Intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under 3301(c) of the Divorce Code: N/A; or date of execution of Waiver of Notice of Intent: by Plaintiff on August 8, 1997; and by Defendant on August 18, 1997. DIANE G, RADCLIFF 3448 TRINDLE ROAO CAMP HILL, PA 17011 (717) 737,0100 fr: co ~ <t. lr. ,- 8 ~~;; luR CIC I":I~G G:~,. .... "-r: '~.I -':::J C(( , . "- ~rJ .; ~:~ 0', N 1!IL. - -, 0:-1"" C.":"- ~ ,- !iU L., -:~ j:. ..:, II, r- :.:j 1..) G"l U ..... '- . ~ . . . MARRIAGE SETTLEMENT AGREEMENT , THIS AGREEMENT made this u~f'.-. day of ~, 1997, by and between DANA M. MAXWELL ("WIFE") of Camp Hill, Pennsylvania and RANDY S. MAXWELL ("HUSBAND") of Lemoyne, Pennsylvania, WIT N E SSE T H : WHEREAS, the parties hereto are HUSBAND and WIFE, having been married on April 22, 1972 in Harrisburg, Pennsylvania. There were two (2) children born of this marriage: Sophia J. Maxwell born June 15, 1973 and Matthew W, Maxwell born July 11, 1977. WHEREAS, diverse and 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 bf settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the DIANE G. RADCLIFF ATTORN EY.AT.LAW SUII TRINOLE ROAn CAMP 11I1.1., PA 17011 settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and in DIANE G. RADCLIFF ATTORNEY.AT.LAW 5H8 TRINDLf. ROAn CAMP JlIl.t. PA 17011 - ~ .. , general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and 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, WIFE and HUSBAND, each intending to be legally bound hereby, covenant and agree as follows: 1, AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE, The parties agree that the terms of this Agreement shall upon the request of either party be incorporated into any Divorce Decree which may be entered with respect to them, 2, NON-MERGER, It is the parties' intent that this Agreement does not merge with the Divorce Decree, but rather, it continues to have independent contractual significance and each party maintains their contractual remedies as well as court remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute, 3, VOLUNTARY EXECUTION AND FAIRNESS OF AGREEMENT. Each party acknowledges that this Agreement has been entered into of his or her own volition, with full knowledge of the facts and full disclosure of their separate and joint ~ 1""'"\ .. estates, and that each believes this Agreement to be reasonable under the circumstances, Further, HUSBAND acknowledges that he has been advised of his right to be advised by an attorney of his own choosing prior to entering into this Agreement and that he voluntarily has decided not to retain such counsel, and further acknowledges that he accepts said Agreement and that said acceptance is not based on any advice or representation made by WIFE'S counsel, Diane G. Radcliff, Esquire, nor has any such advice and/or representation been given to HUSBAND by said counsel. 4, FINANCIAL DISCLOSURE. The parties confirm that each has provided the other with a full and complete financial disclosure of their respective incomes, assets and debts and that each has relied on the substantial accuracy of the financial disclosure of the other, as an inducement to the execution of this Agreement, 5. DISCLOSURE AND WAIVE 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 DIANE G. RADCLIFF ATIORNEY.AT.l.AW ~us TRINDI.[ ROAU CAMP 1111.1.. PA 17011 party has the right to have all such property valued by means of appraisals or otherwise, Both parties understand that 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. Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and is in his or her best interests, and that the Agreement is not the result of any fraud, duress, or undue influence exercised by either party upnn the other or by any other person or persons upon either party. Given said understanding and acknowledgment, both parties hereby 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 DIANE G. RADCLIFF A'ITORNEV-AT-I.AW "H8 TRINIlI.t ROAn CAMP 111I.1.. PA 17011 rights, remedies, privileges, or obligations covered by this Agreement, including, but not limited to, possible . . - , " claims for divorce, child or spousal support, alimony, alimony pendente lite (temporary alimony), custody, visitation, and counsel fees, costs and expenses. 6, PERSONAL PROPERTY. HUSBAND and WIFE do hereby acknowledge that they have previously divided their tangible and intangible personal property including, but without limitation by way of specification: automobiles, jewelry, clothes, furniture, furnishings, and other household goods, pension plans, retirement plans, bank accounts, life insurance policies and the like (hereinafter the 'personal Property"), Hereafter WIFE agrees that all of the Personal Property in the possession of HUSBAND or titled in his sole name shall be the sole and separate property of HUSBAND; and HUSBAND agrees that all of the Personal Property in the possession of WIFE or titled in her sole name shall be the sole and separate property of WIFE. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate Personal Property of the other. 7, DIVISION OF REAL ESTATE SALES PROCEEDS. DIANE G. RADCLIFF ATIORNEY.AT.I.AW !Uft TRINIJI.t ROAn CAMP 11I1.1., PA 17011 The parties acknowledge and agreed that they have previously sold their marital residence and equally divided the net proceeds between them to their mutual satisfaction. DIANE G. RAIlCI.IFF ATIORNEY.AT.l.AW !HII TRINIJJ.F. ROAn ('.AMP 11I1.1.. PA 17011 . , ~ The parties hereby waive any right to distribute said proceeds in any manner or percentage different from their previous division, B. MARITAL DEBT, During the course of the marriage, HUSBAND and WIFE have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without ascertaining for what purpose and to whose use each of the bills were incurred as follows: a, The joint obligation owej to ~~~C~fpi PSL approximatelY~6 shall be through and by HUSBAND'S disability with a balance of continued to be paid and HUSBAND shall cooperate therewith and shall execute and process all documents necessary to secure said disability payment, In the event HUSBAND'S disability payments terminate so that there no longer is any coverage or payment for said obligation, then the parties shall equally contribute to the repayment of the said obligation until it is paid in full. b, The joint PNC obligation having an approximate balance of $4,700.00 shall be paid by WIFE transferring $2,000.00 of the balance to another loan or credit arrangement held in her sole name and HUSBAND paying the remaining balance owed to PNC in the monthly or other periodic installments required by PNC, all of which DIANE G. RADCLIFF ATTORNEY-AT-I.AW SHS TRINOl.F. ROAIJ CAMP JlII.L. PA 17011 r"', shall be paid in a timely fashion so as not to adversely affect WIFE'S credit rating, c. All other credit cards, loans and obligations that are held or were incurred in the individual name of a party shall be paid by the party in whose primary name the account, loan or obligation is held. Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills which pursuant to the terms herein are not the responsibility of the other party. Any joint debt shall be frozen, closed and canceled so that neither party can make any further charges or incur any greater liability thereunder and if said charges are made or liability incurred in violation of this Agreement than the party incurring said charge shall immediately repay the same, 9, BANKRUPTCY. The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein, In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by DIANE G. RADCLIFF AlTORNEY.AT.LAW HIli TRINIH.[ ROAn CAMP 1111.1'0 1"'\ 17011 . .. ,..... . this Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 10, WAIVER OF ALIMONY. SUPPORT AND COSTS The parties agree and hereby waive any right and/or claim each may have, both now and in the future, against the other for alimony, alimony pendente lite, spousal support, maintenance, counsel fees and costs, 11, MUTUAL RELEASES. HUSBAND and WIFE each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of any 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 part 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, f , r-'\ or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) the Commonwealth of Pennsylvania, (b) State, Commonwealth of 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, any 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 any and all property of any kind or nature, real, personal or mixed, 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 provisions thereof. 12. 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. 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 document that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement 14, 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, 15, 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 warrantied other than those expressly set forth herein, 16. BREACH. If for any reason either HUSBAND or WIFE fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies, all of which shall be deemed to be DIANE G. RADCLIFF ATTORNEY.AT.LAW UCS TRINOI.[ ROAD CAMP 1IIL1., PA 17011 cumulative and not in the alternative, unless said cumulative DIANE G. RADCLIFF ATIORNEY-AT-l.AW !UK TRINIH.r. ROAn CAMP 1111.1.. PA 17011 r'I effect would have an inconsistent result or would result in a windfall of the other party. (a) the right to specific performance of the terms of this Agreement, in which event the non-breaching party shall be reimbursed for all reasonable attorney's fees and costs incurred as the result of said breach and in bringing the action for specific performance, (b) the right to damages arising out of breach of the terms of this Agreement, which damages shall include reimbursement of all attorney's fees and costs incurred as the result of the breach and in bringing the damage action, (c) the right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 Pa, C.S.A, 3502(e), an any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said Section or replacement thereof by any other similar laws, which remedies shall include, but not limited to: (1) the entry of judgement; (2) the authorization of the taking and seizure of goods and chattels and collection of rents and profits of real and personal and tangible and intangible property; (3) the award of interest on any unpaid installment; >- r--. , n; Ir: r:; ',' ,,- -. r.... to . .l~~ Id.... ,');'; c.)., r. , r~;; !. " 11- , ..-:;: ,- CJ' , , J ' , CJfj if") , ~....? Ui~. N -' I ~ ;.~ L~: ~ ",d i' ..-; .'.iLl. ,. ,... ::.1 c:' en U !:: ::: ::l~"'O ~j a~ ~< ~~~ '" . ,~ ~~a v ~f-o:I: ~ ~'" c.. ~<3;~ ~ RANDY S. MAXWELL, DEFENDANT CIVIL ACTION - LAW IN DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DANA M. MAXWELL, PLAINTIFF V, No.9), eJl/of t~J~~m NOTICE 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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. Court Administrator 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 DIANE G. RADCLIFF A1TORNEY-AT,LAW .H18 TRINDLt ROAn CAMP 11I1.1.. PA 17011 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DANA M. MAXWELL, PLAINTIFF NO. q'/. .]'/09 (!,vJri-.- V. RANDY S. MAXWELL, DEFENDANT CIVIL ACTION - LAW IN DIVORCE COMPLAINT AND NOW, this e~day of ~'1997' by her attorney, comes the Plaintiff, Dana M, Maxwell, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: 1, The Plaintiff, Dana M, Maxwell, is an adult individual residing at 337 E, Crestwood Drive, Camp Hill, Pennsylvania, 2. The Defendant, Randy S. Maxwell, is an adult individual residing at Lemoyne, Pennsylvania. 3, Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 22, 1972 at Harrisburg, Pennsylvania, DIANE G. RADCLiff' ATIORNEY.AT.1.AW ~UI TRINIJI.r. ROAn C.AMP 1111.1.. PA 17011 2 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7, The Defendant is not a member of the Armed Services of the United States or any of its Allies, 8, The Plaintiff avers that the grounds on which the action is based are: (a) That the marriage is irretrievably broken. Or in the alternative, (b) That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this action is not collusive. Or in the alternative, (C) That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. DIANE G. RADCLIFF ATIORNEY.AT.I.AW '448 TRINnLE ROAD CAMP 111I.1.. PA 17011 3 WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, DIANE G. RADCLIFF ATTORNEY.AT.LAW '448 TRINDLE ROAD CAMP JlIl.L. PA 17011 4 :-- Q) u; ;~ ('\.: uJ':'; W (,.' li': ~'. I t.fJ ~~ ~f' CJ:) 'iJL" I fLl,,' >- r~. .- ~:.; tl.. r- ~. U 0\ (3 , ," < .'1.( .J".; ;:.: : ::j ./Ji '",. '1_' ;' ," ....l!~ 'f-.. ,I . ~ \1'\~~ ~1S ~ ~ \'- ~ ' l.1 ~ Y\ \' ~") ~ { .:.. "\~ " j \~ l, ~~ ''- 1~ tt ~ '-l J{ ~J . . ~ ~ .~ ~ ~ls~ ~ ....:..: ~ < U~ :a . . ~"q- t:l ~j!:S ~~U' o U ,':' I f." ,,,,.,. /, " t~t\;s.;',':;!~' ~ . . ~;~( ?::~ :p V:+,,<', , (,;Fi ~,i{~;}:r>!' , i' t,>,..,'," ' "ii, ~~!i,;~:' . '. r .' F;')~l~,< .. 1!),ri,ifi;C;' · r~;'\~"~'; , l,Ji./;:"i' pt;/Ur?,,;c' " j-Z;'i.",',..,", r,;i ff~fJ'.i'\;f'?' .. (';,',:,~',;'. ,,~.: [~:;'?::f h<~ :{':: :;,;'~"-,\" [,W:;...::"i:' ' i ,I p---' " .. _,i-'- p" 11!.1 'i9 ~" . :~U :8 ~ S ' . ;hl ' ~ '.",J "j' , ~ ... tl~]~ S ~~~ ~cifi~~ JB!J,.,. '. ' , .' f: I, I." ~~I;. .; .-! \ ~ .: ?; '" I-' co ::5..~ ~lIQ ~-=!"~ .)(~i - .~ ...... :~.:. !:E', ~"'t ,,~-:.j of': ~?2 ',-5= CT\ ~~k'l ~ :,.!j G:!l"-' ~ :-UlW -, ::;J !,'ja.. r::.: .,; ..->.: U, r- :::l .0 C' U "- ." >- r- ~ IT, lr.. j;:: 1.L,r-,~ W :'1,'" ,-...:, ( )-':; - .-/ i.~' :' ;;l., '-};l~ I"... "'" 9\ ' --I ~...i C~I.' of) ':;-'J C'J ,-' U'~; ,- _I., c.'-, ,-,- -.... u.." "iil1 r-'. ---' .: ~ '-'- "'" ...~ ,. r- ::,) Cl CJ' CJ .... r- ~ i.r; lJ". ~L /- ,-- Ci:J :J< UIQ ():,: 0(' ..-.-, :~;: ....... n:. -" l'_". .,....J 9' .~- - e- m ~~.~ ~~~ 0' N U-'C. !":"ll'. c..') I L~J u. ., ;:::; ,:_!u- , I ...:;;: I', r- ';5 () a' u . . , .' , . '. - DANA M, MAXWELLL P AINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 97.2409 CIVIL TERM : CIVIL ACTION. LAW : IN DIVORCE RANDY S, MAXWELL... D~FENDANT I, I consent to the entry of a final decree in 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 immediatcly after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. Dated: ~-1?-1 J- ~w~~ >- r-. (;. (r;, u: _I. .'- ~- fi:; . ),r. Ulf:; i '-, ~:l , .101:. C) :=.". :r;. .. " (i:':." ..: l'-r- ~, , .: :..,~ 9(, In ;'~: ~.? .:,y: N " , ll.!.... -'" ~ ";I(i) [j,;' : u.. F~ ." .. 1', r-- :j c... CT\ u . .'