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Home My WebLink About97-06388 , .:.;. .:.-;. ,~+:. .:~. ,~+:. .:+:- .t+;. ':+:0 .:+:. .:+> .:+:' .~+:. .t+;, t. .:~.,.:+;",,~l'> .:+:- .:.:. .:+:- .:.:. .:+;. ':':";4 ".." ,..,,,,..,,,,,..,..,,,'" " ,.."......,,,.. $ $ .:+:- .:.;. .:+:- .:+;. .:+:. .:.:. .i+: ~ I, ,-~-,--- , ,,,. , . ,., , , '.-.' ,', '.' ~\ , \ \1\ IN 1"1 ~I\ ~( ~ THE COURT OF COMMON PLEAS ~ OF CUMBERLAND COUNTY STATE OF '* PENNA, ~I' ~.' , ~ " II ;1 !I ~ I I ,I Ii N (). "~,?:::,6},~,~,,, SJ,y"iL 19 97 , ~ ',' SUSANl,OUrSE KUBA, Plaintiff ~ ',' ~! ',' ~ ',' V lq'KU:i . .HOMER P. KU!3A, Defendant ~ ',' ~. ',' ~I ',' *1 DECREE IN D I V 0 R C E . ~,. IY1 , c:::r ~...;>~,. AND NOW, .. .. .. ,I.Y! ~ ,~ ?.. .. .. , , .. " 19, ~~.. '. It Is ordered and decreed that ." ,~!1,S.l\l'!, }:>.QlI+?fl, ,ISVf3I\, , , , , , , . , , , , , , , , . , , . , . , , " plaintiff, and, , , , , , , , , , , , , JIQt:ll\R ,F,. , KU13I.\, , , , , , , , , . , , . , , , , , , , , , , " , . " defendant, are divorced from the bonds of matrimony, ~ .'. ~ ',' ~ ~ ., ~ ~ ... W 'i The court retains lurlsdlctlon of the following claims which have been raised of record In this action for wh!ch a final order has not yet' been entered; ., ~ ',' ~ $ , , , , , ,T.h~, p,t,tilch.gd ,Prapert,y. ,Set,tleme.nt. Ag,r.eement. is. . . , , , , . , , , . . , , . ,~l)~!J,r:p.9nl.,t,~c;1, p,u t; ,(l!J,t, ,1~'i'~,qEiQ, j:,q ,~tJ~, ,O~C~,E\P. , ~/1, ,OJ. YP.t;G~.,. , . , . . , , , . ~ ... ., ~ ~ ;'1 n y T I ~ ,.. ~ ~. Alle.1I a~dj [' /1::%: Ij}..~..~~, '1~/;f.llld r, >>fb, LJ4 '.. .. . ,/ 'T;J . Prolhonolory * ?, ~ ~ ~- - - -", ' , '. -, :10:, 'lO:' ':.:' ,~:' ':.;. ,',' ';,' ~ ',' $ .;, ill $ $ $ $ $ $ $ $ * ~ S I, .;, ill $ ,;; ill $ ~ ',' ~ ~. ~ ~l ~ ,,' .'. * ~ ',' .', ~ .', ~ ~ ... ., ~ ,', ~ ~ ',' .', * J. .'. ~ ~ ' I~ ',' I"il ',' * , , ". ,_. , " , ",' ~ .:+:- .~+:. .:.:. .:+:. .:+:. .,.;. ':.:. .:.:- .:+:. .:+:. '4"'''''-.. ,. ,- ,- .- ... S';). ~ (Al i/1;',fI ,,;..I!/ ~; ad ~, 5',}:;, :;;r 7fp;;t., I~~J~ .d (;t;rr' " " I " " , , , . " .'. " \, , . . . " it . . I,l ii, " I , 0, , , !; '1 I" 'I ,T~. LAW '11'l~ or '.~ KILL..IAN Ilc GIiIPHAAT , , illl "1'1"- "nUT Ii I II , C:.~T''''I.l) COpY"" "I ' '. 0;; ;,...~; " " ~, i-I.' ~ ), .I, . 1', Dt "oX ... HARRISIIUAG. PENNSYI.VANIA 17 1 Op.0888 , ,.~,:"",~,,,,~_.;~_~,,,,,,,,aHi~#'<HI'-_.' -".", '., " " r" " ". . " 'I I \ . " ,!! " ,. , , ~- '....:..-..."....,...-. .-..........,~...... ,I \: I, " i .' PROPERTY SETTLEMENT THIS AGRBlEMEN'l' made this IJ";' AGRIIlEMEN'l' day of 1II(Jtf?I1JI4@1l. , 1997, I by and betwee~ HOMER P. KUBA of 5~0 Ninth Street, New Cumberland, Cumberland County, Pennsylvania 17070 (hereinaeter referred to as "Husband"), and SUSAN LOUISE KUBA of 510 Ninth Street, New Cumberland, Cumberland County, Pennsylvania 17070 (hereinafter referred to as "Wife"). WITNESSE'rH I WHEREAS, Husband and Wife were lawfully married on November 7, 1986 and, WHEREAS, no children have been conceived of this marriage I and WHBlREAS, differences have arisen between Husband and Wife J.n consequence of which they intend to live apartl and WHEREAS, Husband and Wife desire to settle and determine their rights, and obligations I and NOW THBlREPORE, . the parties intending to be legally bound r f I I i hereby do covenant and agree I 1. SEPARATION, It shall be lawful for each party 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 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. November 6, 1997 2. INTERPERENCEl Sach shall . be from party free interference, authority, and contact by the other, as fully as if he Qr she were single and unmarried exoept as may be necessary to carry out the provisions of this Agreement., Neither party shall molest the <!lther or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with th~ peaceful existence, separate and apart from the other. 3. WIPE' S DEBTS I Wife represents and warrants to Husband that she will not contract or incur any debt or li~bility 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 or obligations incurred by her. 4. HUSBANP' S DEBTS I Husband represen~s and warrants to Wife that he will not contract or incur any debt or liability f~r which wife or her estate might be respbnsib1e 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. 5. OUTSTANPING JOINT DEBTI Wife agrees to be fully r,esponsib1e and further agrees to indemnify and hold Husband harmless for the following marital debtl GE Select QVC Sears Spiegel Bon Ton Boscov's Discover Advanta 1st Card Account #5406-8198-00~7-2870 Account #05-1039-5074080 Account n5484011345155 Account,n19-0105-501~0 ,Aocount n052-167-400 Account #00-358-7460 Account #6011-0028-0551-2449 Account n432~-8351-7000-0234 Account n4250-401-137-564 November 6, 1997 2 $2,570 500 1,200 1,'450 600 800 4,100 4,100 4,000 1st USA Bank Account 11541"-1225-9252-1\068 7,300 Husband agrees to be fully responsible and furtller agreea to indemnify and hold wife harmless for the following marital debtl aapita1 One Sears Montgomery Wards MBNA America Acaount n7812601388337816 Account n51\81\065555089 Account n131\-531-070 Account nI\261\-2900-0762-75&8 $ 8,600 2,600 800 12,000 6 . MU'l'UAL RELBlASE I Subj ect 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, exeouto,rs I 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 causes of action for, termination of the marriage by divorce or annulment and except for all causes of action for bre.ach of any provisions of this Agreement. Husband and Wife specifically release and waive any and all rights he or she might have to raise claims under the Divorce Code of 1980. and the 1988 Amendments thereto including, but not limited to claims for equitable dlstribution of marital property, support, alimony, alimony pendente lite, counsel fees or expenses, should a divorce action be commenced by either of the parties, the moving party shall request the Court, to incorporate, but not merge, this Agreement into any divorce decree. If this Agreement is incorporated into a divorce decree, the parties shall have the right to enforce this Agreement under the Divorce Code of 1980 and the 1988 Amendments thereto in addition to any remedies in law or equity and these November 6. 1991 3 " , enforcement rights are not wa.lved or released by any of the provisions of this Agreement, The fact that a party brings an action to enforce the property agreement 'all inoorporated in the divorce decree, under the Divorce Code of 1980 and the 1988 Amendments thereto, does not give either party the right to raise other claims under the Divol:'ce Code, specifically waived and released by this paragraph and all rights and obligations of the parties arising out of the marriage shall be determined by this Agreement. 7. PIVISION OF PERSONAL PROPIIlRTYI The parties have reached a oral agreement as to th.e distribution of the personalty which is currently located at the 510 Ninth Street, New Cumberland, Cumberland County, Pennsylvania 17070, marital residence. Although the parties have not yet effectuated the division of this personal property, Husband acknowledges that notwithstanding the fact that Wife will be transferring her interest in the 510 Ninth Street pr.operty to him, she retains the right to receive an equitable portion of the personal property which remains in that residence. 8. DIVISION OF REAL PROPIllIrlXI Wife agrees to transfer all right, title and interest in and to the real estate situated at 510 Ninth Street, New Cumber1and/. Cumberland County, Pennsylvania 17070, now titled in the name of Husband and Wife as tenants by the entireties to the Husband and agrees to immediately execute now or in the future any and all deeds, documents, or papers necessary to effect such transfer of title upon request. Wife further acknowledges that she has no claim, right, interest, or title Nov,mber 6, 1991 t\ whatsoever in said property und furtlwr agrees never to assert any claim to said property in tho future. 9. HUMP SUM PAYMPlN'l' '1'0 WIFE, Husband agrees to pay Wife a lump sum of party-two Thousand pive Hundred ($42,500.00) pollars within thirty (30) days of the date this Agreement is fully executed by the parties. to. E~CH PARTY RPlTAINS OWN PENSION PU^Ni1 Each of the parties does specificallY waive, release, renounce and forever abandon all of his or her right, title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan; profit Sharing Plan, 401-K plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee benefit plan of. the other party, whether acquired through said party's employment or otherwise, and hereafter aaid Pension plan, Retirement Plan, Savings plan, Tax Deferred Savings Plan and/or any employee benefit plan shall become the sole and separate property of the party in whose name or through whose employment said plan is carried. As clarification for the foregoing, Husband acknowledges that Wife shall receive the State Employee Retirement System Pension which she has accumulated through her employment with the commonwealth Court. A copy of the statement of account as of December 31, 1996 is attached hereto, marked Exhibit "A" and made a part hereof. Husband further acknowledges that he waives any and all right, title and interest to said pension. Wife acknowledges that Husband shall receive the 401-K he has with Harley Davidson and his.IRA Mutual Fund held with Oppenheimer. ., 5 November fI, 1991 Wife further acknowledges that she waives any and all right, title and interest to said 401-1< and mutual fund. 11. VEHICuESI Husband agrees to transfer all h,j.s right, title and interest, whatever it may be, in a 1995 Ma:!da 626 which is currently titled in Wife's name alone. Wife agrees to be fully responsible for any and all payments on said vehicle. Wife agrees to transfer all her right, title and interest, whatever it may be, in a 1984 Porsche and a Harley Davidson motorcycle which is currently titled in Husband's name alone. Husband agrees to be fully responsible for any and all payments on said vehicles. 12. 1997 INCOMPl TAX RE'1'URNI The parties hereby agree ~hat they shall file a joint federal income tax return for tax year 1997. 13. SUBSEOUENT DIVORCE, Both parties agree to execute Affidavits of Consent to Divorce and Waiver of Notice of Intention to Request Entry of a Divo;:-ce Decree pursuant to Section 3301 (c) of the Divorce Code and any other doc\lments necessary to effectuate a divorce when so requested by Wife's counsel but in no event more than one hundred twenty (120) days after the filing of a Divorce Complaint. Both parties further agree to deliver said documents to . counsel for Wife upon request. Wife agrees that she shall direct her counsel to promptly file a Divorce Complaint in the Court of Common Pleas of Cumberland County and shall further dl:t;-ect her counsel to take the necessary' steps to finalize the'Divorce within 6 November 6, 1991 one hundred twenty (120) daYB of the filing of the Divorce Compl!lint. 14. aRI~' If either party breaoheB any provision of thiB Agreement, the other party Bhall have the right, at his or her election, to sue for damageB for such breach or seek such other remedieB or relief as may be available to him or her, and the party breaching this contract shall be responBible for payment of legal feeB and costs incurred by the other in enforcing their rights under this Agreement. 15. ADDI'1'IONAu INS'1'RUMEN'l'SI Each of the parties shall fr~m time to time, at the request of the other, execute, acknowledge, " and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of thiB Agreement. 16. VOuUN'l'ARY EXECU'l'IONI The Wife has employed and had the benefit of the counsel of Killian & Gephart aB her attorney. The HUBband has been informed of his right to counsel but has decided to not employ an attorney. The Husband acknowledges that his decision to not employ counBel waB voluntary and understands that Wife' B counsel has solely represented the Wife. The Husband acknowledges that counsel for Wife has, in no way, advised or undertaken to repreBent him in this matter. Pinally, Husband agreeB that his decision to not employ counsel will not be used as a defense to the enforcement of this agreement and agrees that he iB entering this agreement being fully aware of his 'rights under the laws of PennBylvania and.the Pennsylvania Divorce Reform Act. November 6. 1997 7 Sach party acknowledges that he ~r she fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the , circumstances, fair and equitable, and that it is being entered into freel.Y and voluntarily, and that execution of this Agr~ement is not the result of any duress or undue influenoe and that it is not the result of any collusion or improper or illegal agreement or agreements. Each party hereto acknowledges that he or 'she understands the impact of the new Pennsylvania Divorce Reform Act, whereby the Court has the right and duty to determine all marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees an'd cost-.s of litigation and, fully knowing the same, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties and waives their respective right to have the Court of Common Pleas of Cumberland County or any other 'Court of competent' jurisdiction to make any determination or order affecting the respective parties' right t.o a divorce ,alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 17 . ENTIRE AGREEMENT, This Agreement contains the entire understanding of the parties, and there are no representations, November 6, 1'97 8 warranties, covenants, or undertakings other than those expressly set forth h~rein. . 18. MODIFICATION AND WAIVI!l.B' A modifioation or waiver of any of the provisions of this Agreement shall be effeotive only if made in writing and exeouted 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, 19. ,DESCRIPTIVE HEADINGS ,I The descript i ve headings used hereill are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 20. ,MU'l'UAu ACCEP'rANCE 1 The parties acoept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now or hereafter have against ea6h other for their support and maintenance, and also alimony, alimony pendente lite, counsel f~es or for any other provision for their 'support and maintenance, and '*lso alimony, alimony pendente lite, counsel fees, costs and expenses and any other charge of any nature whatsoever pertaining to any divorce proceeding which may have been or may be instituted by the parties in any court in the commonwealth of Pennsylvania or any other jurisdiction and/or any divorce proceeding which may be instituted by either party in any court in the Commonwealth of Pennsylvania or any other jurisdiction or any other counsel fees, costs or expenses incurred or to be charged by any counsel ,arising in any manner whatsoever for breach of this Agreement. 9 Nov~mber 6, 1991 21. INDJ!lP~NDEN'l' SIllPARATJ!l cOVIllNAN'l'S I It is specifioally understood ,and agreed by und between the parties hel:"eto that eaoh paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 22. APPuIcABuE uAWI This Agreement ahl.\ll be construed under the laws of the Commonwealth of Pennsylvania. 23. PRIOR AGREEMJ!lN'l'SI It is understpod and agreed that any and all property settlement agreements which mayor have been, executed prior to the date and time of this Agreement are null and void and of no effect. 24. DISCLOSURE 1 The respective parties do hereby warrant, represent, and declare and do acknowledge and agree 'that each is and has been fully and completely informed of and is familiar with and cognizant of the wealth, real and/or personal property, estate and assets, e,arnings and income of the other and that each has made a full and complete disclosure to the other of his or her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto furtj1er covenants, and agrees for himself or herself and his or her heirs, executors, administrators and assigns, that he or she will never, at any time hereafter, sue the other party or his or her heirs, executors, administrators 'or assigns, in any action o,r contention, direct or indirect, that there was an'y absence or lack of full "NoVl!Imbl!lr6, 1!)!)7 10 '., 'r '1\ !:~ ~ n ,:-- " ",00, " " " ,. Ii , i (--., \ I~ n " 1'1 " ,I 'I ) I JI) " , I ; , )' ,j ..:1, :"") ," ~ ;;J ",> '-- - -.;..:.~, TIll LAW PIIlM OP KILLIAN & GgPHART . I.' II II. "I~. .'"'IT !=IRTlI'IEL'l COpy . .. tJ uo..1IIt ~u_.._ A HA'~'W!lQUl'la. PINNQYLVANIA .?IOIl'OQUll It----._.,I SUSAN L.OUlSE 1<lJJ3A, Plaintiff I I r: v, IN THE: COUR'l' OP COMMON PLEAS OP CUMI3E:RLAND COUN'l'Y, PENNSYLVANIA No. 97-6388 civil Term CIVIL ACTION - LAW IN DIVORCE HOMER P. l<UJ3A, Defendant fFAECIP~ '1'0 '1'RANSMIT RECORD TO THE PROTHONOTARY I 1. Ground for divorce I Irretrievable breakdown under Section 3301(c) of. the Divorce Coda. Transmit the record, together with the following information, to the Court for entry of a divorce decree I , 2. Date and manner of service of the Complaint I By certified mail, restricted delivery, return receipt requested, to defendant, HOMER P. KUBA, on November 21, 1997, as evidenced by the attached affidavit of acceptance of service which is being filed contemporaneously herewith. 3. Date of execution of the affidavit of .consent required by section 3301 (c) of the Divorce Code I by SUSAN LOUISE KUBA,plaintiff, on May 18, 1998; by HOMER P. KUBA, defendant, on May 15, 1998. 4. Related claims pending I The attached Property Settlement Agreement is incorporated but not merged to the Decree in Divorce. 5. Date of execution of Waiver of Notice of Intent by plaintiff on May 18, 1998, which Is being filed contemporaneously herewith, by defendant on May 15, 1998, which is being filed contemporaneously herewith. ,~f) ~/ . Paul Helvy, Es illian & Gephort 218 pine Street P.O. Box 88G Harrisburg, PA 17108-0886 (717) 232-1851 Attorney ID #53148 Attorneys for Plaintiff Dated: May 21, 1998 II), d i " fFow. ~ .', . ,. ,,1 <! """oM:, I,i .'1 ,i;;""~, 'I ,ri , it ) I' ), it 'if ~_':'__.L..j.. , , !l 1"-, I' 'I":: '}' ... " ";', ';1 ,') " " ,'tj 'f;) 1,1.) U "I') ./il i ':-:1 '. " Ii:' I' "'J "" I, ,} .. - '.','1 " , , \ ~ " " ,,' , , , .. " {I ,'I , " j J . , ,~ " " , , , , " 'TH.i '""W ~I"M O~ . 1<1L.:L.IAN 'Sf GEPHART '"i I" 'INIl "hU,T ,,101,"0)1 "'1 HARRISBURG. PENNSVI.VAI'l,IA ,17106.0S66 ORIGINAL CIERTII'uic COpy , '" ,I " ~ , i..i,';!l1 , I' 1'11,/,; ,~;}\I ,~;,:./J!;\JU,~'-' , , i_li~ ,I " " '" .\ 'i , . I \ . , . c , .- ,.,..- ",ro'", . , SUSAN LOUISS KUSh, Plaintiff J IN THSCOUR'l' OP COMMON PLSAS OP I PUMBSRLANP COUNTY, ~ENNSYLVANIA 'J J No, 97-I...U)'P civil Term J J CIVIL ACTION - LAW J IN DIVORCE v, HOMSR P. l<USA, Defendant cOMPuAINT IN DIVORCE AND NOW comes SUSAN uOUISm KUBA, by and through her counsel, Killian & Gephart, who represents as followsl 1. Plaintiff, SUSAN LOUISE !tUBA, is an adult individual, who I currently resides at 510 Ninth Street, New Cumberland, Cumberland County, pennoylvania 17070. Her date of birth is May 24, 1952. 2. Defendant, HOMER P. KUBA, is an adult individual who , currently resides at 510 Ninth Street, New cumberland, Cumberland County, Pennsylvania 17070. His date of birth is November 22, 1957. 3. Plaintiff avers that she has been a bonafide resident in , the Commonwealth of Pennsylvania for, a period of at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 7, 1986 in Cumberland County, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of '18. Datedl November 14, 1997 " VIllR Il" IcA'1' ION I hereby verify that ~he statements of faot made in the foregoing Complaint in Divoroe are true and correct to the best of my )tJ'lowledge, information and belief. I understand that any false statements therein are ~ubject to the penalties oontained ih 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. '~"'-<f/I? 'x /&J-- Susan Louise Kubs' , Datedl November 14/ 1997 , I.' 'I " \' " ' 0'/) ",\ , , II 1'1 . , . " .- _::'~~';ll,""- ~. ':~-'''-'~--~.r-''.... .:.:..~:~' ,', I~.~ 1". , I ., , '" .' " i1 f'Ji I \;"1 , I t,.i , , I , ! " ,'Ld IiI I ' I . It} , I i\ . , '~ I ~ ) " 1-" , " , SUSAN LOUISE KUaA, Plaintiff , IN THE COURT OF COMMON PLEAS OP CUMBElRI,AND COUNTY, PENNSYLVANIA No. 97-6388 civil Term CIVIL ACTION - LAW IN DIVORCE v. HOMER P, KUBA, Defendant AFFIDAVI'1' OF cQNSENT 1. A Complaint in Divorce under Section 3301 (c) of the pivoroe Code was filed on November 17, 1997. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree ~f divorce after service, of notice of intention to request entry of the decree. ' I verify that the statements made in this affidavit are true and correct. r understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to .uth~rities. Dated; IJ71Uf 2", 9, /6,18 , I - 1998 " ., , , , , " " 'I) , , , " (-, ',11 r~ ~, ~ ~ .:,'..) -. , "' , n :) '-'. " n , 'J , \...,) , ,I :1",: , 'it , :';,,",) ,\ "'1"'1 'I " ."c. '>"'1- I )"') " ~;'.J .: :~ 1'1 I , I ~7:' , J ::l :J~ ,..... CO:> .... ,-I q " !, " . . SUSAN I,OUISE lUISA, Plaintiff IN 'rfIEl COUR'r OP COMMON PLEAS OF CUNBaRLAND COUNTY, PElNNSYLVANIA No. 97-6388 Civil Term , v. HOMER 1'. KUBA, CIVIl, ACTION - LAW IN DIVORCE: Defendant WAIVER OF NOTICE OF IN'l'ENTION '1'0 RIgUES'1' ENTRY OF A DIVORCE DECREE UNDER 83301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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 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 18Pa.C.s.A. Section 4904 relating to unsworn falsification to authorities. , ~4?4.4tei!- ~ ~san Louise Kuba Dated: ..5'. ",f' , 1998 , , " , , , , I. I,' I ~ " , , I I ! C.l, , n, I \ '; " i , , I It\ , \ :' I') " " " , I, \",'/ .llI .. I ~ I I~d_ ;,~ ". I r 1.,'1 IdqU SUSAN LOU!SE l<UBA, Plaintiff v. IN THE COUR'I' O~. COMMON PLEI\S Qlr CUMBERLAND COUNTY, PENNSYLVANIA No. 97-6388 Civil Term CIVIL ACTION - LAW IN DIVORCE I, ,I HOMER P. KUBA, Defendant WAIVER OF NO'1'IC~ OF INTENTION '1'0 REQUES'1' ENTRY OF A DIVORCW DECREE UNDER 13301(0) OF '1'HE DIVORCE CODE 1. I consent, to the entry of a final decree of divorce without notice. 2. I understand that I may lose r~ghts 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 ver~fy 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.A. Section 4904 relating 'to unsworn falsification to authorities. Dated: IJI!1f, /5 . , 1998 ., " "......., v. IN THE COURT OP COMMON PLEAS OP CUMBERLAND COUNTY, ~mNNSYLVANIA No. 97-6388 Civil Term SUSAN LOUISa KUBA, PJ.aintiff HOMER P. KUBA, Defendant CIVIL ACTION - LAW IN DIVORCE AlFIDAVIT OF ACCEP'1'ANCE OF SE~ I, HOMER P. KUBA, Def.endant herein, do hereby swear and affirm that I accepted service of a true and correot copy of ,the Complaint in Divorce, on iJtnl P./ , 1997. ~4 'I , '; '" ..-, r', . , . P 1.il Ii ).1,'1 2lji' ~ l1uUlllllt 1m , Cl1rllllod Moll _,~ Nil IlltjljlHlll1I CIIVIIHIIlI! P,.,vulllll ~",I~"'I'l' Illl nnl 111111 II1I 1111'11111111111I111 MIIII ,..,.,.1, I I!lllll IIIlY"_lhll .....' _ ,.ui.. ji., 11()IP.o..r.P' Kupa ",.., " at t 510 Ninth "r9f3..M.._ ~~~'~~~l;b~~i:~.n..~ .,P!U7.~.1 ,,,~_~.__'h_' $ 5:) ..._..... .,... L_.....,... 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Kuba 4!!. Service Type " 510 Ninth street 0 RIgl.'ered Dln.urld " 'New CUl11b~rland PA 17070 Xl Cerlllled 0 COD o bpI..I Pt.1ell r.1 Rttuin Rlcllp' for <. M.rchlll'ldl.. D.,e 01 Dlllvlry , .tyre IAdd'l. ~ Ignllurl IAglnll 11.1;; f I [ , ~ 8. r Declmber 11~1 """'_, , 114 , DOMESTIC RETURN RECI,'" , ' ,