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Home My WebLink About97-06249 ~1 ~i o ! <:..J1 s 't N ... , 11 ",I ~ I . j,,\ o <::.J " / / " , / " / ,/ =" o '<: " ,., .~.~.~.~.~,~,*.~*,~.,~.,*,'~.*,,*,'~"~"~"~,~':"~,~"~'~'~'~'*'~*"~ * ~.,".,-~,.. ,,'",., ~ ,,' -',,-,' is ~ ',' s ~~ "'1 ~( '.'j ~l ~j ~t ~.' \ ~\ ~.' ( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ;~~~~ PENNA. ~ " ~ ',' ,', ~ ~ '.' " ~ ,', * ,', ~ ,', * ,', ~ *- ., ,', * ,', * ~ ,~ ,:" " ~I ',' ~i 'I ~i "'1 ~I .. ~ ., ~ " ~ ',' DECREE IN -f+- (( '32...1 ~ I V 0 R C III iJ... '.J"...l\ : , , , , ~, , " , 191 ", It is ordered and :. ,:, " ~ " ~ ~ ~.' ,', ~, ,:, " " ~ ,', * ,:, " ," ~ , W ':> ;;, ., ,;, ., $ $ ~ , .., jJ .~"~,*,~~.,~,.~,~,,*,.~"~,,*.,~"~:,.~,,*,'~,.~.~.~-~ ~ " " 01 ~ ~ ',' ANJA K. COLON-MENDOZA, PLAINTIFF 97,.6249 NIl. ~ ',' ~ ',' \' I' 1'~1l; ~ ',' JAVIER E. COLON-M~NDOZA, DEFENllA.N T ~ ',' ~ ',' AND NOW"" .. ~ ',' decreed that ,,'" and"""" , , , , , , , , , , " plaintiff, , , , , , , " , , " 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; $ ~ " ~ ',' " ~ """','",.",...."",.,..,.,.."..".".",..... "', ,', to ""."." ..,."" ,.,.,',.,.,.,."'..'..r.'.......,,,.,..,........ ... THE TERMS OF THE PARTIES' SEPARATION AND PROPERTY SETTLEMENT AGREEME TARE INCORPOHATED HEREIN I UT 0'1' ~ ':HGED. n y T 1 ,', ~ ~ ", ~ """h"",,~J jJ " ,:, " ~ ~.' ,1 , ,3 ,.,.JI,I- '1'(" .:.3d. d:l;/ .M,~,.d/1'" a. ':t';~4 j~!/JId-~ .3')I/'~7,F,:t,-;t' /,,;;,.4;/ ~ ,rrjll. , .! SEPARA TION AND PROPERTY SE7TT-EMENT AGREEMENT THIS AGREEMENT made this/d'1t day 0~(1/J F I mb(V , 1997, by and between ANJA K. COLON-MENDOZA, of Carlisle, Cumberland County, Pennsylvania (hereinafter referred to 85 "Wife"), and JAVIER E. COLON-Mt:NDOZA, of Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "Husband"), WITNESSETH: WHEREAS, Husband and Wife were lawfully married on June 22, 1994, in Heidelberg, Gennany WHEREAS, differences have arisen between Husband and Wife in consequence of which they have chosen to live separate and apart from each other; and WHEREAS, the parties acknowledge that they have had the opportunity to review the provisions of this Agreement and further have had the opportunity to secure legal counsel and advicl' relative to the legal effect of this Agreement. The parties acknowledge that they have either received independent legal advice from counsel of their own selection or that they have specitically chosen with full knowledge and on their own volition, to not seek legal advice relative to this Agreement. They further acknowledge that they fully understand the facts that are the basis of this Agreement. They acknowledge and accept that it is being entered into freely and voluntarily, after having the opportunity to receive legal advice and with the knowledge that execution of this Agreement is not the result of any duress or undue influence, and further that it is not the result of the collusion or improper or illegal agreement or agreements, NOW, THEREFORE, the parties hereto intending to be legally bound hereby do covenant and agree: I, .'lepara/loll: It shall be lawful for each at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provision 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. 2. Ifller:/emlce: Each party shall be free ITom interference, authority, and contact by the other, as fully as if he or she were single or unmarried except as may be necessary to carry out the provisions of this Agreement. 3. Wife ',I' Debts: Wife represents and warrants to Husband that she will not contract or incur any debts or liabilities for which Husband or his estate rr'6ht be responsible and shall indemnifY and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her other than those debts incurred pursuant to any sections of this Agreement. 4. Husband's Debts: Husband represents and warrants to Wife that 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 01' demands made against her by rcason of debts or obligations incurrcd by him other ~han those debts incurred pursuant to any section of this Agreement. 5. Qlllstanding Joifll Debts: The parties acknowledge that they have various credit card or charge card debts at the time of their separation, Husband hcreby agrees to assume full, sole, and exclusive responsibility for the repayment of the parties' credit card debts, including but not limited to the credit card or chargc card debts due and owing to Oisc.Jver, AOL Visa (2), City Bank Mastercard, Sears, and the opp account. Husband shall indemnifY Wife and hold her harmless from and against any and all demands for payment or collection activity of any nature whatsoever relative to re.payment of the aforesaid credit card or charge card accounts. Husband shall maintain payments on the aforesaid accounts in current status and shall not create any additional debt on the aforesaid accounts that could in any way obligate Wife, In the event Husband fails or refuses to pay the aforesaid credit card or charge card debts in full, and if Wife is obligated to make payment on the aforesaid debts, Wife shall be permitted to file an action requesting alimony from Husband in an amount equal to the amount the Wife is required to pay on account of the aforesaid debts, Husband agrees that he will stipulate to thc payment of alimony to Wife in the amount requircd to pay the aforesaid debt and shall make not present any legal or financial defcnses against payment of the aforesaid alimony, including but not limited to a situation where Wife may have greater income, where Wife may have remarried or cohabited, or any other legal or financial defenses. 6, Mlltl/al Releafe,: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does lor himself or herself, and his or her heirs, legal representatives, executors, administrators, flJld assigns, release and discharge the other of and 1T0m all causes of action, claims, rights or demands, whatsoever in law or equity, which either of the panies ever had or now has against the other, eKcept any or all cause or causes of action for divorce or any action to enforce this Agreement. 7, Alimollv. A/imOl!v PlIlldll/llll Ute. S/1OlIsal SUTiPort alld Malntenal/ce: The parties specifically are aware of, acknowledge and understand their right to demand alimony, alimony pendente lite and suppon and hereby waive their right to these claims against the other party now and in the future, Both panies agree not to make a claim for alimony, alimony pendente lite or support now, during any future divorce proceeding between the panies, or at anytime thereafter. Under no circumstances shall this paragraph be construed to cause Wife to waive her interest in the BAQ payments that are being made to Husband and disbursed to Wife. Husband shall continue to advance to Wife any and all BAQ payments that he receives on a monthly basis until such time as those benefits cease, Husband shall not be entitled to reduce the payments to Wife in the amount of the BAQ payments received by Husband for any purpose whatsoever, 8, Divisioll of Persol/al Prooerly: The panies have agreed to a divi$ion of their personal propeny to their mutual satisfaction, including their personal elfects, household furniture, furnishings, appliances, and all other articles of personal propeny, including automobiles, which have hereto lore been used in common and neither will make any claim to any such items which are in the possession of or under the control of the other party. With respect to any personal property items that have not yet been distributed, the panies shall refer to the attached EKhibit A and EKhibit B which are a listing of the personal property items which shall be retained by each respective party. , , .... J . .,;\\(....."':.~....., "'-._ .__. ,.. [n particular relative to vehicles, Wife will retain her 1996 Chevrolet Cavalier and shall retain sole and exclusive responsibility and liability for the repayment of the debt due and owing to Dauphin Deposit Bank and Trust Company on the aforesaid vehicle. Wife shall indemnifY Husband and hold him harmless from and against any and all demands for payment or collection activity of any nature whatsoever on account of the aforesaid automobile loan. With respect to vehicles, Husband shall retain his 1996 Chevrolet B1azar shall retain sole and exclusive responsibility and liability for the repayment of the debt due and owing to the First Federal Credit Union on the aforesaid vehicle, Husband shall indemnif'y Wife and hold her harmless from and against any and all demands for payment or collection activity of any nature whatsoever on account of the aforesaid automobile loan. [n addition, the parties acknowledge that their two dogs, a long haired Dachshund, and a cocker spaniel mix, shall be retained by Wife and Husband shall make no claim to ownership or possession of the dogs, 9, Divisiol/ of Rea/ Properlv: The parties do not have any interest, either legal or equitable, in any real estate either individually or jointly and, therefore, there is no real estate to distribute. 10. II/sural/ce. Reliremelll. alld Olher Rellefils: The parties agree that neither party shall make any claim of any nature whatsoever conceming any insurance benefits, retirement benefits, profit sharing accounts or other similar accounts or benefits that available to or accruing to either party, II. Waiver ofe/aims Al!ai/lsl Eslate.l: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of . the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into elTect this mutual waiver and . , '''~l , '~'",". _';..... , relinquishment of all such interests, rights, and claims. This Parallraph shall not lllTcct either party's right or power to expressly include the other party in any will or other document, whether written In the past or in the future. 12. Breach: If either party breaches any provision of this Agreement, the other party shall have the nght, at his or her election, to sue for damages for such brCllch, or seek such other remedies or relief as me.y be available to him or her, 13. Coul/sel Fees: The parties agree that should a divorce action be maintained by either of the parties to dissolve their marriage, neither party shall milke a claim for counsel fees from the other party, Both parties have been tully informed of and acknowledge their right to make a claim tor reasonable counsel fees in the presently pending divorce proceedings, but hereby make a full, complete and voluntary waiver of that right. 14. Ell(orclllt!!lll1: The parties agree that this Agreement may be made a part of any final divorce order or decree entered in this case, This Agreement may be incorporated in but shall not be merged with any such order or decree, In the event either party falls 10 comply with the terms of this agreement, the other party may enforce this agreement by filing a Petition For Contempt if a party breaches this agreement the other party, in pursuing enforcement of the agreement, shall be entitled to altomey's fees from the breaching party, IN "ITNESS WHEREOF, the parties hereunto set their hands and seals the day and year first mentioned above, WITNESSES: A!(}.! Iv /q?1 I Dale AN (~(/ .;L.-<.. K. COLON.MENDOZA /,// ~. ."'''''.' '~' , /' .~/.' .y MW 11J I W~, _ ~~- .......,.1". t- '---- Date MVl~ E. COLON.MENDOZA . . COMMONWEALTH OF PENNSYL VANIA COUNTY OF A unlNr /;11. ,I ss On this the )j'lA day o~(//JtI(/)i)(r ,1997, before me,the undersigned officer, personally appeared ANIA K. COLON.MENDOZA, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and otlicial seal. ,Jfld'A /! ~ltt~1, NoliHinl SMI Lash A Mlllor. I""tmy Pobllc Carllslo Boro, Cllmberlnnd County My Commission ~.plr.' April 17, 2000 COMMONWEALTH OF PENNSYL VANIA COUNTY OF I?{,n!xr/A ld On this the /IJ ~j day of /{iN!/);!.)("y , 1997, before me, the undersigned officer, personally appeared lA VIER E. COLON-MENDOZA, known to me SS (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,J1jAA/l Y!/dj~_ NolarloJ Seal Leah A. Miller, Notary Pobllc ' Carlisle Ooro, Cumborland County My Commission E,pli'e. April 17, 2000 1. beige loveseat 2. microwave 3. small TV 4. boom box 5. toaster oven 6, bedroom carpet and living room carpet 7. bedroom furniture: headboard and dresser with mirror 8, daybed 9, kitchen utensils & dinnerware (as separated) 10, dining room table and 4 chairs 11. coffeetable 12. rocker 13, camera 14. light color bookcases (2) 15, coo coo clock 16, washer & dryer 17. phone bench 18, bicycle (1) 19, 1996 Chevy Cavalier 20, ha:1ging bookshelves (2) 21. chest in bedroom 22. lamps 1.21 If 1ft" ;fife... 23. picnic table and benches 24. lawn chair AN.IA COLON EXIIIBIT "A" JA VIER COLON 1. Brown bookcase 2. Big bookcase 3, 2 endtables 4. dL'esser (6 drawers) S. entertainment center (new) 6. stereo 7. speakers 8. TV 9. VCRs (2) 10. video camera and stand 11. desk 12. computer -, 13. printer 14. blue couch 15, kitchen utensils and dinnerware (as separated) 16, cooler 17, German bed 18, bicycles (2) 19, 1996 Blazar 20, CD racks 21. HaJogenJamp 22, lamp. m !1Wc. #- 23. old entertainment center '. 'J;; EXHIBlT:. "B" ANJA K. COLON-MENDOZA. Plaintitl' IN THE COURT OF COMMON PLEAS OF CUMOERLAND COUNTY. PENNSYVLANIA VK, CIVIL ACTION - LAW 97.6249 CIVIL TERM JAVIER E, COLON-MENDOZA, Del~ndant IN DIVORCE I'ltAECII'.: TO TnANSMIT ItECOIm TO THE PROTHONOTARY: Transmit the record, together with the following information. to the Court for entry of a divorcc dccrcc: \. Ground tor divorce: irretrievable breakdown under 3301(c) of the Divorce Code. 2, Date and manner of service of thc Complaint, Scrvicc madc on Novcmbcr 20. 1997. by certificd mail, rcstrictcd delivery to Defendant, Javicr E, Colon-Mendoza, 3, (Completc cithcr paragraph (a), (b) or (c),) (a) Datc of e~ecution of thc Affidavit of Conscnt required by 9 3301(c) of the Divorce Code: by the Plaintitl': 3/10/98 by the Defendant: 3/11/98 (b) (1) Date ofc~ccution of the Plaintill's Affidavit required by 9 3301 (d) of the Divorcc Code: (2) Date ofscrvtcc of the Plaintiffs Allidavit upon the Dcfendant: 4, Relatcd claims pcnding: none 5, Indicatc datc and manner of service of thc Noticc of Intention to Filc Praecipe to Transmit Rccord, and attach a copy of said Noticc under 9 330 I (d)( I) of the Divorce Code, 6, Datc of e~ccution of thc Waivcr of Notice of Intention to Filc Divorce Decree as requircd by 9 3301 (c) ofthc Divorce Codc: by thc Plaintifl': 3/10/98; by thc Defendant: 3/11/98,.""--' \. '.. '- C'l :- b-; ..:J /.. ., '-; I -. ,'j:.:. lI.'t' l t' .,. , "1.0'1 : , 1< Lt.. l"I.. l.[., '.. C,),_ M '.~n CI ('.J ",\1 I'jl l 0' , : LU C;;, .~. '!" u.. r -. ". ,- " , , W ;1 (,) Ol U ANJA K. COLON-MENDOZA, Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA vs, CIVIL ACTION - LAW 97- 1.;;"1..11 Ctult '-7Crl...'i IN DIVORCE JAVIER E, COLON-MENDOZA, Defendant NOTICE TO nEFF-ND ANn CLAIM RIGHTS You1have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You arc warned that if you fail to do so, the case will procccd without you and a decree in divorce or annulment may be entered against you lor any other claim or rclief requested in these papers by the Plaintiff, You may lose money or property 01' other rights important to you, including custody 01' visitation of your children, When the ground for the 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 Franklin County Courthouse, 157 Lincoln Way East, Chambersburg, Pennsylvania, 17201, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, Pennsylvania Lawyer Referral Servicc PCllnsylvania Bar Association 100 South Street; 1',0, Box 186 Harrisburg, I' A 17108 (800) 692.7375 ANJA K. COLON-MENDOZA, ('Iaintitl' IN HIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION. LAW. 97. /,,:J.,.l../9 CUr' { '/( fL;'1 IN DIVORCE JAVIER E, COLON-MENDOZA, Defendant COMI'LAIN1' IN DIVORCE I. Plaintill~ Anja K. Colon-Mendoza, an adult individual currently residing at 139 South Pitt Street, Carlisle, Cumberland County, Pennsylvania, 2, Defendant, Javier E, Colon-Mendoza. an adult individual currently residing at 1420 Bradley Drive; Apt. F313. Carlisle, Cumberland County, Pennsylvania. 3, Plaintill' and Defendant are bonalide residents ~f the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintifl'is a German citizen and a legal resident in the United States of America, 4, Plaintiff and Defendant were married on June 22, 1994, in Heidelberg, Germany, 5, There have been no prior actions lor divorce or annulment between the parties, 6, The Defendant is a member of the Armed Forces of the United States of America or its Allies, Defendant claims his legal residence in Pennsylvania, 7, Plaintiff has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling, Knowing this, Plaintiff docs not desire that the Court require the parties to participate in counseling, 8, Plaintlll'and Delcndantare citizens of the United States of America, 9. The parties' marriage is irretrievably broken, 10. Plalntitf desires a divorce based upon the belief that Defendant will, ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P,S, Section 3301(c). Respectfully submitted, GRIFFIE & ASSOCIATES By p'" rilli, Esquire , orth Hanover Street arii~le, I' A 17013 (717) 243-5551 (800) 347-5552 YIlillHCAIJQN I verilY that the statements made in the loregoin!! document are true and correct, undentand that false statements herein are made subject to the penalties of 18 Pa,C,S, Section 4904, relating to unsworn lalsiticatiolls to authorities, DATE:~()v' lu;lijr:J1 C/( CJ:? jl--e ANJ . COLON.MENDOZA " " " , , '" P'; I,. " , ,,,- , , I' , , " ) t " :":J I. " ,,, .,) j,' " ~ ',.1 - ! ~'( j 'h.. r-. d <. " ANJA K. COLON-MENDOZA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL.VANIA CIVIL ACTION. LAW 97-6249 CIVIL TERM vs, JA VIERE, COLON.MENDOZA. Defendant IN DIVORCE IlrrlbllVIT or 5J:RVIC.~ AND NOW, this 25th day of November, 1997, comes Bradley L, Griffie, Esquire, Attorney for Plaintifl: Anja K. Colon-Mendoza, and states that he personally mailed a copy of the NOTICE TO DEFEND AND CLAIM RIGHTS and COMPLAINT IN DIVORCE to Javier E. Colon-Mendoza at 1420 Bradley Drive; Apt.F313, Carlisle, Pennsylvania, by certified mail, restricted delivery, return receipt requested, A copy of said receipt is attached hereto indicating service was made on November 20, 1997, .-;7/' ./ :;./' /' // riffie,.-Esquire FI & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 Sworn and subscribed before me, a notary public, this 25th da)' of.Nove~nb~~p97. '. ;/;r!I{/; /L 1/ !rift,!? , _ f ~-'-'. .. Normlill ~tJtll oJ LOfll1 A MUhtr NCllmy PUblic M Cmlls)r Bow, ClJmUHrlww COUIlI Y COmml!HlIOtl E-,xplrllt. Apllr,: :?~r.' I. P 433 104 591 us PO'lul Bo"le.. Receipt for Certified Mall No Insuronco COv13faOlJ Pr.lVhIOl'J. 00 /lal Ufln lor l/ltllffllllll)nl~! l-4u!L1.~Q/J (t)V!!.-'~!!L 6""'J{IIJtJ.:.~l;) ?;II/'~~ t~7J"~dk'{' / Ir' /~,I ;-. 'J p('U],2';:f}~c,?oi I!L'LL';/)/}. l)rl~l/jau $ J ~,J"J _.-...._~. /. 3 5- 'K I., ..____.._ ~ Spcdlll DlllivQr)' F lilt ~ nll&rl1l~.) Foo ._ ~- ..)!. . /) . .~ ~ ~ nlttol,IlfihoVtinQlu / / tJ " .... v.nlOlIIAI)8rIlOCr~e''''' . ~.~.~ n~lljmJ\{fIt1Jt5lkNl~l\IlO.WhoJm , :( Dole, A ^"liI~~eo', At"eu o ;::- r I. " , ~ TOTAL P')~lll!Jo'" tll~" $ ~. r \-> '" ~ \ (') PIJMfllf\lk I)t 01111, :,,, E \~lf' "IX' C/lrtJllllllFlllt ,... f I , ,IComplet. lI;ml 1 80"'0' 2 lor addition., ..MC'I. lCompltttltlml 3, "e, Ind 4b. 'Pl1nl your name and Idd".. on Ih. rIVII", ollhl. tonn 10 th,t WI can retum till, C&ldIO~u, 'Att.ch Ihl, 'onn 10 thl front oll~ maUpltce, or OIllht bide if Iplce dot. 1'10I pem;l, 'WIIII "R<<um R~/pt Rlqu.,'Id' on the mallpllce below Ihe .nlcle number. 'The Allum RiM.'elpl wtltlh\)w 10 whom lhe Inldl WI. delivered and the dale delivered. I also wish 10 recolve the fOllowing servlcos (tor an extra 100): 1. 0 Addroll8oe's Addroll8 2. 4itAeslrtcted Oollvo'Y Consult postmaster lor lee. 4a. Artic 0 Number j f VCertlned W o Express Mall 0 Insured f' o R'turn Recelpl 'or Merchaodlse 0 COO ~ 7,00IOO'/O)V Je q" I O. Addrssseo's Address (Only I requested 'I and lee I. paid) ~ ' 3, ArUc e Addressed 10: Javier R. Colon-Mendoza 1420 Bradley DriVe; ^~~f3 Carlisle, PA 17013 5, Received By: {PrlnI Neme a .II PB Fonn 11, [locember 1994 , i ) (I) l) ~ " I' , I' I , -Ii, .,,1: " :,,1 ,.~ C,'\ ) u , " ANJA K. COLON-MENDOZA, Plalntiff : IN THE COURT OF COMMON PLEAS OF : CUMnERLANDCOUNTY, PENNSYLVANIA : CIVIL ACTION. LAW vs, JAVIER E. COLON.MENDOZA, : NO, 97-6249 CIVIL TERM Defendant : IN DIVORCE AFFIDA VlT OF CONSENT 1. A Complalnt in Divorce under Section 3301(c.) of the Divorce Code was filed on November 12, 1997. 2, The marriage of Plalntiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complalnt. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decrees, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa,C,S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, DATE: O?)lOjql , , /} {/... C.c? La ~LON-MENDOZA , ANJA K. COLON-MENDOZA, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAVIER E. COLON-MENDOZA, Defendwlt NO. 97-6249 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ~TRY OF A DIVORCE QECRE~ UNDER SECTION 330Hd OF TilE DIVORCE CODE 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[ do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it Is filed with the Prothonotary. I verity that the statements made in this affidavit are true and correct. I understand " that false statements herein are made subject to the penBlt1es of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities. DATE: 03!IO/Q; , v (j" ;( 0 - . COLON-MENDOZA ANI . " ANJA K. COLON-MENDOZA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLANO COUNTY, PENNSYLVANIA vs. : CIVIL ACTION -tAW JAVIER E. COLON.MENDOZA, : NO, 97.6249 CIVIL TERM Defendant : IN DIVORCE ,A.~'FmA VIT OF CONSENT I. A Complaint in Divorce under Section 3301(c.) of the Divorce Code Wl\lI filed on NOVtlllL.:r 12, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing ortlle Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decrees, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~E -, -~ . (j;2 ~ JA 'l1 R E. COLON.MENDOZA . DATE: /tll/tltllll, I'If/J " ' , .., 'I " I. ANJA K. COLON.MENDOZA, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMDERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAVIER E. COLON.MENDOZA, Defendant NO. 97-6249 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUESl: ENTRY OF A DIVORCE DECREf; UNDER SECTION 330J(c.) OF TilE DIVORCE CODE I. I consent to the entry of a final decree in divorce without no lice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. DATE: MI/-K!1..11 /~ 199~ -- E ce /-<- JA~R E. COLON.MENDOZA , .. '-.! ., ., I I \ .~ ' ..1 I I I I I .11.'11 "-'l ANJA K. COLON-MENDOZA, Plaintill' : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JAVIER E. COLON-MENDOZA, Defendant CIVIL ACTION - LAW NO, 6249 CIVIL 1997 IN DIVORCE NOTICE OF f,LECTION TO I~.:TAK.~ FOI~MER NAME Notice is hereby given that the PlaintllT in the above maller, having been granted a Final Decree in Divorce from the bonds of matrimony on the 25011 day of March, 1998, hereby elects to retake and hereafter use her previous name of Anja Karena j~nze. /) i< L.t' 1-.--<- ~RENA COLON.MENDOZA , if'( ?rLL.-/ ARENA KUNZE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF CUMBERLAND On the C(/_IJ day of 0H<.'I.... , 1998, before a Notary Public, personally appeared Anja K. Colon-Mendoza, now known as Anja K. Kunze, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. '~~ii*~bt~1 ~/L!d"L~~\-/_ NotMtII Soil Robin J. Goahom. Nolary Pu!llIo CirUlli BolO, Cumbo~.nd CounlY .~\/ Commission E~plr'l~!prn 17. 1099 , I! t,'} , ',1 I, 'I,' , ,', \~~t ",.~11 ",' :\.:)':'# ~; I " '.- i , ", I ...~ ,:-: i 1I , .. I ~' , \ I \ I " , i i I i"i' " I, I I' I , I , . "1', e c-) " c:') ~l ,l tJ " ~... ," ~ -!" ' :~ \ . ~ ~~~ ~., ... . < ' > I,J " '1- .) f ~ ':~.' :.'~ <-~ ',~ " , i i I ., , I " ,,. '. '" . T