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Home My WebLink About97-06680 'I I'! I, 'p I' , , I' ..~ o I~ "~ ,~ " , , ,9,' , '~ ~ ...... 0' ~ I \ ,~, <t" / " 'I ./ , , .,,' " / , " ( " I I " I , , .\' , I ',/ " " ~), , t -..) '-0) ~ (too ~,' , ", ,I ~ ;' '> ;tt, I .:.:, .:.:- .:.;. .:.:. ,;.;. .:+:. .:+;. .:tt:' 'j4 . .. . Iii! iii iii ~ . , . .:<<:- :~~',,'!.~- ~:~~'. ':~~' ,':!:'.~.:' ':+;', ~~. . .:~:. ~:~:. .:.;. ':+;. ~ .;, ~ ~ ,', ~I wI ',' ~ .:.;. .:.;. .;t;' .~.;. .:t;' ,:.;. ':..;' :. .:+:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ ',' STATE OF , PENNA, . ~ "I ~ ~ ',' HOB~;HT E. AHNOLD Plnlntift' 1'1),()(lUIJ (:ivll Terlll Il)~j'( ~ ',' ,~ " :1 ',' ~ \'1'1' ,11 ; CAH/oIA J, ,'dlNOLD Defendant ~ '7' " ~ ~I ~.' I ~I ':'j ~ ~ DECREE IN DIVORCE "J> 19 'l . " .~ ~ ~ ',' AND NOW, ' , ,1""';, ,.2/'", d d th t llOHr:JI'r ,1';,',WNOLlJ, ecrae a, , , and, , , , , , , , r;AllMA ,oJ" ~HN()l,lJ, are divorced Irom the bonds 01 motrimony, " plalntill, ., delendan t, it is ordored and .. ,~ ~ s ~ ~.' ~ The court retains jurisdiction of the lollowing claims which have ~ been raised 01 record in this action lor which a linol ardor has not yot ~ been entered; ~ ',' ,'l'I:lr-, ,M;;\r,r,~G1glJ, ,.',1(J,t,Uouwn t, Agr.eemQntp,nterf?U ,in to be tween, ,the, , , ,~ar,tiefl, ,July 14" y~98 and recordnd to the,nbovPC:IlptlO,ll.!d 1.0,1% numbe i incorjlora ted bu t no t merged in to tnl H decroe, w ',' * ',' ~" !' ~ ", ,', ~ ,~ ~ ~ ~ ill , -..,.... :1t:o -:."... .:.;. By The <:""1'1',/ f.~' / /Lyt'.. 1', nl hlll\t\:"'"y ~ " ~ ~ ~ ~ ~ 1* l~ ~ I~ I: I'; (~ i, 't-. i.' (~ I" I~ ;~ i !~ '~ I' " , ' Ii; I~ (',' I... ~ ~ .:~ , ' )~ ~ lind' :~ , ~ :~ ~ ,/. :~ :, .~ '!i ..*~**~..~,~.,*,.~.:~.~.,~"~.~;':~.~..~~.:.:.~:-~.*. , :, j,/i:; I'~ -',J.. i;',I' " '" ir"t, , ,.( I:'. " " , ,; "I '~ , .,1.1 '''I'l ,I '(, ,., ,!\ .' ", ,\\' " ;",ii." " u '" " " r' ,'I. " , '" ,il"" " " .., .) 11,[; . 1 ~ 1,.Ji' ,; II, (' , , , " "I -) " " / ,j 'I' , 'l,r\:1'1I'1, ,,' , , " " . ,~ ,II: " " "'1; ,I 'I, ',' II' 'I ", !f ,li' , 1 , I ., ;," ',', " " !.' , '" ',,',;1 I,' ! " " , " I , , , I , I I " ,I " , I, " 'r" " , " , " " " , " I' " 'il ',I , ,', , , " , , " " " I' " , " , I': ,', ., I ,> 'II", 'I 1,\' ,,. I ", " ,I', 1 " " " " " " .'I' , ; . , . , . '-"'il " 'I!' ')"'I"j 'I' ;., '." ,',J " ;'; " ,,' i, , 1:1 1'1. I, - I '~j, " I " " I);'t.,' /1, " " L (,':1 " 1 ~r , ,d- I, ,'lor,; 'i'" )1;- , ).'11 'j I-I , " ,..'i ;11, ;1, " " ! I ~ ,I! 1'1/ ,'1' 'i' " ,01 ',),: i r.., ,! i'.i ,t,:, " 'I , ,;"i I II MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT is made this ):s L'c day of:1; \.}'~, 1998, by and between ROBERT E, ARNOLD, 250 Crossroad School Road, Newville, Cumberland County, Pennsylvania, hereinafter referred to as "Husband", -AND- CARMA J. ARNOLD, now of 1916 Spring Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Wife" , WITNESSETH: WHEREAS, Husband and Wife were February 13, 1984 in Shippensburg, Pennsylvania; and lawfully married on Cumberland County, WHEREAS, diverse unhappy marital difficulties have arisen between the parties causing them to believe that their marriage is irretrievably broken, as a result of which they now live separate and apart from on another, the parties being estranged due to such maritill difficulties; and WHEREAS, the parties hereto are desirous of compromising and settling fuliy and finally their respective financial and property rights and obligations as between each other/ including, without limitation by spec if: icat,Lon I the settling of all matters bot~loon thom J:eliJtinq t'l t.ho ownership of real and personal property; and in general, the settling of any and all clailllH and possible claimB by one against tho other or against their respective estate, particularly thoso responsibilit les ilnd rights growing out of the marriage relationship, j,nter aHa past, present or future spousal support or maintenance, alimony pendente 1.i. te, aLimony, counsel fees and expenses, and equitabl'iJ distribution, whether or not the parties reside together; and WHEREAS, the parties have made full disclosure to each other of their assets and liabilities and have agreed on a settlement of all property right.s and dIfferences existing between them; and WHEREAS, the parties intend this Agreement to be a full and complete Marriage Settlement Agreement, providing for the absolute and final settlement of all their respective marital and property and all other claims, NOW, THEREFORE, in consideration of the premises and of the promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, the 2 .J ,.. , roceipt of wil !ch [,. horoby ilCknow lod<J(!d by (!C1ch of the " pil rtios hereto, Husband and Wife, Gach intending to be legally bound hereby, covenant and agree as fa l lowll t 1, SEPARATION, It shall be lawful for each part.y, at all t ilnes hereinaft'lr, to liv,~ separate and apart from the other, at such place or places as he or she may, from t [me to time, choose or deem fit. Each party shall be free from interference, authorIty or control by the other, as full as if he or she were sIngle and unmarried, except as may be necessary to carry out the provIsIons of this Agreement. NeIther party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit wi th the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, The foregoing provision shall not be an admisSlon on the part of either party of the lawfulness or unlawfulness of the causes leading to their separation, A reconciliation will not void the provIsions of this agreement, Should a decree, judgment or order of separation or divorce be obtained by eIther of the partIes in this or any other state, country or jurisdIction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected In any way by any such sep,lrat: ion or divorce; and that nothing in any such decree, 3 jlldglll(Hlt, order or fllrth'lt' mmllfi.cal;!.oll OJ: rev!.s.loll thereof shall altot.', <lm'Jljd or vary allY term or th!.s Agreement, whether or not e!.ther or both of tile pilrt!.os shall remarry, it beinq un(j,]rstood by and IJutween tile parties hereto that this Agreelll<:nt tlhal J. b" I.n,:orporal."d In but shall not be merged into and decre/e, judgment, or order of divorce or separation, It ls speclfically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or decree. This incorporation, howev<1r, shall not be regarded as a nwrger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties, 2, EFFECTIVE DATE. The effective date of this Agreement shall be the "date oJ.' execution", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date, Other wise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing thls Agreement, Transfer of property, funds and/or documents shall occur on the effective date unless otherwise specified herein, 4 3, AGREEMENT NOT A BARTO DIVORCE, This Agr8ement shall not be considered to affoct or bar the right of either party tl) a divorce on lawful (J1:ounds as lJlay be now or hereafter avaLlablq to eith<lr party. This AgrO(Hllent is not intended to be and shall not be a condonation on the part of either party of any act or acts of e lther party hereto. Both parties hereto agree that the nwrriage is irretrievably broken and agree at the time of exocution hereof to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 330l(c) of the Divorce Code, Each party waives the right to request Court ordered counseling, 4, DEBTS AND OBLIGATION/! , Each party hereto represents and warrants that he or she has not, and in the future will not, contract or incur any debt, obligation or liability for which the other party or his or her estate may be responsible or li<1ble, except as provided for in this Agreement, Each party hereto agrees to be solely responsible for the prompt and timely payment of the debts now or hereafter incurred in his or her name and specifically any debts secured by any automobile, motor vehicle or other property distributed to her or him hereunder. I;;ach party hereto agrees to indemnify and hold harmless the other from ilny and all claims, debes, 5 obliqatiolJll or (h'llland/l made a'lill.nHt hl,m or h(n by rGa/Jon of: debt/J or obl i<]ilt iontl inclIrrod by him or 1101: or idonti tiod to be paid by him or her in this ^'lromllont, 5, MUTUAL RELEASES, Husband and W,if:e hereby mutually remise, release, qu.ltclaim and torever discharge the other and the estate of: such other, for all tlme to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other., or whatever nature and wherever situate, which he or she not has or at any time hereafter may have aqainst such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engaqements or liabilities or such other or by way of dower or curtesy, of claims in the nature of dower or curtesy, 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 or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commomlealth or territory of the United States, or any other country; or any rights which either party may now have or at any time hereafter have for past, present or ~uture support or maintenance, alimony, alimony pendente I; 6 ,lito, counsel f'~es, costs or expenses, whet/lor arising dS a result of the marital relation or otherwise, except and only except all rIghts and agnHlIllents and obLigations of whatsoever nature arisIng or which may arise under the , Agreement or for the breach of any provision thereof, It is the inten tion of Husband and Wi f8 to g I v" 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 provision thereof, It is fur ther agreed by each party that this Agreement constitutes a full and final resolution and settlement of all claims of any kind, and especially and claims arising under the Pennsylvania Divorce Code, which either party may have against the other. 6, DIVISION OF HOUSEHOLD AND PERSONAL PROPER!!, The parties hereto agree that they have effected a mutually satisfactory division of the furniture, household furnishings, appliances and other personal property and motor vehicles between them and neither par.ty will make any claim to any personal property now in the possession or control of the other except as herein provided, Husband 7 hereby interest ru I (~ilHI'!tJ dnd /'0 I in'I" illlJ'!:J hold ill Lho dny riqlJL, t Ille or he IIJdY hilVlJ past 0/: now h,HJ ill the property in Wif'~'lJ pOBlleslrion, Wlf'o ol'lrt1<JS t1loclt lIusband shall, frollJ dnd ilftor the dato horeot, bo th,~ sole ilnd sGparate ownor of all 1,J(1I:lJOllill property ill IIlllJband's possession, Wit,! heroby roloillJes ilnd rol inquiBhes any right, titlo or interest she may hilv" had in the past or now has in the property in lIusband'u pOllsesuion, Husband agrees that Wife shall, from and afto/' Ull! ddt.,! twreof, be the sole iJnd sfJparate owner of all penJollal property in Wife's possession. 7, PENSIONS AND RETIREMENT ACCOUNTS, The pa rties hereto waive any and all interest or clilims which either may have in any individual retirement accounts, 401(k) accounts, Keogh accounts, existing pensions or similar accounts of the other, including any retirement type accounts of Wife arising from her employment with Masland Industries and/or Lear Corporation, and any retirement type accounts of Husband arising from his employment with Masland Industries and/or Lear Corporation, 8, ALIMONY. Each party waives, releases and gives up any claim, now or in the fut.ure, for any spousal support, II illlmony, ,i1lmony p,mdt)/Ite lit,!, or midntonilllce fro/l\ the othor, ~), BANK ACCOUNTS, IIU~m^ND and W I FE odell ilcknow led<Jo that tlloy ,),\ch own or POtIHO'iS corti\ i.n bank ilccount,; ilnd si.milar accounts of financial instrumonts in their reupectlve nameu. 'rhey hereby agreo that each shall become sole owner of their respective accounts for financial instruments and each hereby waiveu ilny interest in or claim to any funds, instruments or accounts held by the other in such instruments or accounts. 10. MOTOR VEHICLES, Wi th I:espect to motor veh icles owned by HUSBAND and WIfE:, both of the parties agree as follows: The 1994 ford f-150 shall be and remain the sole and exclusive property of Husband; 'rhe 1993 ford Explorer shall be and remain the sole and exclusive property of Wife; Each party shall be solely responsible for and debt secured by any vehicle listed as his or her property, Each party shall be solely responsible for any insurance and any other costs, including license, for each motor vehicle listed above as his or her property, l) 11. REAL PROPERTY, '1'11" J:'t~al property at 880 Heservoi,: Drive, Carlisle, Cumberland County, ponnsylvania, has been listed for sale on tho op"n market and sold to a disinterested buyer, 'rhe Wife h,lS received $11,500.00 as her share of the net procfJods uf tho sale of the real property, and Husband has n,cel.vecl $27,919,30 as his share of the net proceeds from the salo of the real property, 12. COUNSEL FEES, Each party individually covenants and agrees that he or she will individually assume the full ancl sole responsibility for all other legal expenses for his or her attorney, if any, and Court costs in connection with the pending divorce action and shall make no claim against the other for such costs or fees except as set forth in this paragraph, 13, ADVICE OF COUNSEL, The provisions of this Agreement and their legal effect have been fully explained to Husband by his counsel, WILLIAM L, GRUBB, ESQUIRE, Wife having knowingly and intelligently waived her right to be represented by cqunsel, Husband and Wife <Jach covenants that he or she has made a full financial disclosure to the other of his or her respective property, holdings and \0 incol11<l, l!uHIJdnd dnd Wife ,}ach acknow ledqe tha teach ful ),y underHtdnds the far;ts or thiH ilqroemont and haH be,"n fully informed as to h'J1: or hIs le'Jdl riqhtH and obUgat.ionH and each party ,.1cknowledqos ilnd accepts that this Agreement in, in the circumstances, fair and equitable Ilnd that it in being entered into freely and voluntarIly, with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that tt is not the resutt of any collusion or improper or illegal agreement or agreements, Wife, being advised that she has the right to obtain independent advice from the attorney of her choice, hereby waives her right to obtain counsel. 14. ADDITIONAL INSTRUMENTS, Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments, deeds, titles or documents that may be reasonab:y required to give full force and effect t,) the provisions of this Agreement, including all papers necessary to transfer title, 15, AFTER-ACQUIRED PROPERTY, Each party shall hereafter independently own all property, real, personal or mixed, tangible or intangible, of any kind, acquired by him or her, with full power to d Lspose of the same in all II rellpl~cts ilnd for ,.11 purpoBeS, ilS though he or Bhe were unmarried, 16. APPLICABILITY OF TAX LAW TO PROPERTY TRANSIl'ER, The particll horeby agree and expresll their. interellt that any tranllfer of property under thill Agreement shall. be 'o'Iithin the Ilcope and applIcation of the Defidt Heduction Act of 1984, hereihafter referred to as "the Act,H and specifically the provisions of the Act pertaJ.ning to property transfers between spouses and former spouses, 'I'he part1es agree to sign and file any elections or other documents required by the Internal Hevenue Ser.vice to apply the Act to transfers under this Agreement without recognition of gain and subject to the carrY-Over basis provisions of the Act, 17, MODIFICATION AND WAIVER, A modification or waiver of any of the provisions of the Agreement shall be effective only if made in writing and executed with the same formality as this Agreement, The failure of either party to insist upon the 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, 18, ENTIRE AGREEMENT, This Agreement contains the entire understanding of the parties, and there are no 12 2(., DISCLOSURE or rINANCES. 1';'I(;h party horoto confirms that he or she hilS r"lied '1n I;ho COlllplotlJlWIHl dnd substant La 1 accuracy of fin'lIleLa l dLw:losllrell of thl) othor iH3 an inducement to enter into tho ^<JrO()IJ\(Hlt. Tho parti.oll acknowledge that there h,lIl bO(!11 no formal dLIJcovory conducted in their pending divorce action and that neLther has f lled and Inventory and Appra LSlllent all roqu L red by Section 3505(b) of the Pennsylvania Divorce Code, The rights of either party to pursue a claim for equitable distribution of any interest owned by the other party in an asset prior to the date of execution hereof whi.ch interest was not disclosed or known by the other party or his or her counsel prior to the execution of this Agreement is expressly reserved, 23, APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, 24, VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid i'1 law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and, in all other respects, this .l\greement shall be valid and continue in full for.ce, effect and operation, 14 IWIIEH'!' I.;, f,!INU!.J1 Plnintiff I N TilE COlIII'I,' OF COMMON PI.EM; CUMlllwr.^NIJ COUNTV, PBNNSVrNI\N 11\ V'- o. CIVIl. DIVISION (:Am'A ,T, AllNO],J) NO, '.l'1-i'(:HO CIVIL 1'BIlM J)n f.'r!l1,lnn t I'III\ECII'B '1'0 '1'II^NSH.,I'1' IlES-OIl1J To tho I'rothonotary: Tranomit the record, together with the following information to the court for entry of a divorce decree: 1. Ground far divorce: irretrievable breakdown under S330l(cl :l1ttll(ldt)J(~ 01' the Divorce Code, (Strike Ollt irwpplicable sect",)n). 2. Date and manner of survicQ of the complaint: 1 ','-')-'J'I U.,'l.Jnai1, n",'tlfir>d,rpturn rr>c,~illi.,~J,r-D;J;nd tlt)livnry. Jd.otltn{~l'epniu 3, Complete ei ther paragr,1ph (a) 0:' (b), (0) Date of execution of the affidavit of consent required hy S3301(c) of the Divor'ce Code: hy pl.i1inliff .,-Jul,y-14,--1.9-9B--,--; hV del'endant Jul,y 14, 19<)B (b)(l) Date of execution of the l,ff!Javit required by 53301(d) of the Divorce Code: _________________,; (7.) Date of filing and ,wr.vice of the plaintiff's affid.1vi!: upon the r'lupondent:: 4. Related claims pending: non" 5, Complete either (alar (b), (a) Date and manner of Bervlce of the notice of intention to file praecipe to transmit record, a copy of which io attached: (bl Date plaintiff'o Waiver of Notice in 53301(c) DivOJ:ce was fHod with the I'rathonolat'y: ,TU'~_~~ 1998 Date defendant'o Waiver' of Notice in 53301(cl Dlvarcc wao filed with the Prothonotary: July 14, 199B h \Cb_ !\~ .<:~>,_ ~- ^ttorncy for (P1aintiff)(8A!<<"4am~) , 1,,'1 I, If ,,, /1,1" . 1<'1: I ~' . ," ,", " " 'I I'), 'Ii t I)' : "',', "-. 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'~ Ji' :~' '~ "nl'" , '-,', 'I' ' I " , , 'l,i " , ,I "II ~ ~' ...... "I , , " " " " , ,I " I' ,'I , " '"I I, , i,' 1 I " " , , ,:.', t,:_I,' , ft I,'i'" 1":'" I,' ',';1:';1; I ; ~ ;,:'I;~ 1_' jl I' 1"',1 \~ ,.$ ',' }',. 'I'.,.., .rl';', ,,'.,'}l 110-' "~I " "'-. ,11';1 'I \. I', .,. ,~ ~ ;" -I ; I, ~ .-1-, ,'I 'i " , ,'1. ,,,,)\, , ' 1,',\. i"I:' , , " ~ " H-~ ' " "."':1;-,'1 '1'1",-1' , ,'i' ", , :' ',;' ,: I'" I" .. ,'L- , 1',)"',, "':,",';'); "'I 'I , " jl__,1 , , , ;i,;' ", " "', ", I, 0\' ",J , ! " " " " ,-I, " , '11,' " , , ;) '" " ," , , ': " "'1 ( \,1: , , " ;1' .', "J, I"~ IJ" i'i,' , ;;;.-" ,I '" . '-1,',-'_::,,". .':.\",['\1 . 'i' " '. . .,lff ,'i' , " ;',,/1 "I "-I, . , "I 1-,' ~- p' " ij, Plulllllff hus been Ill.lvlseu thlll cllllllsellllg Is UVullllble UIlU thut Plullltlff l11ay huve the I'Ight to request that the Cuurt requlrc thc parties tu purtlclpule In counseling. 9. Plulntlff requests the Courttu cnter u Decree uf Divorce, !. Respectfully submitted. L IIlul1l L. Grubb. Esquire I.D,1I72661 3105 Old Gettysburg Road Cump Hili. PA 17011 (717) 763-5580 Atwrney for Plullltlff Date: 17.i{.q, , " ROIlERT E, ARNOLD, Plaintiff : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 97-66110 Civil Tcrm CARMA j, ARNOLD, Dcfcndant : IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 4, 1997. 2, The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing t.\e Complaint, 3, t consent to the entry of a final Decree in Divorce after service of notice of intent to request entry of decree, 4, alimony, I do not I understand that I may lose rights concerning division of Property, lawyer's fees or expenses if claim them before a divorce is granted. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, ~4904 relating to unswo~n falsification to authorities, 1 / Date: /' [; y~/ \ , ' , , " , , " " \;)11 C, , , , , to .. \ - \, ,~1 lJ 0\ '...J , , , , , " IWBERT E. ARNOl.D, 1'111111111'1' : IN TilE COURT OF COMMON I'l.EAS OF : CIIMBERLAND COUNTY, I'ENNSYl.V ANIA v. : NO, 97-66KO Civil Tl.!rl1l CARMA J, ARNOl.D, Dl.!fl.!l1dlllll : IN l.AW - DIVORCE WAIVER OF NOTIC~ INTEHIION TO REOUEST 1UY9.RC1. DECREE .YNDER 3301lcl OF ..1JiLDIVORCJi; CQI2E 1, I consent to the entry of a final decree of divorce without notice, 2, al imony, I do not I understand that I may lose rights concerning division of property, lawyer's fees or expenses if 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, ~4904 relating to unsworn falsification to authorities, ,),1 L (~'/. /' ~..(,~( .../,'" " if,/ /{.:.: , ~~ Carma J,/ Arnold, Defendant Date: lIS' -i', . .' , . " ROBERT E, ARNOLD, Plnlnllff : IN THE COURT OF COMMON PLEAS OF : CUMBEl~LAND COUNTY, PENNSYLVANIA v, : NO, 97-6680 Civil Tcrm CARMA 1. ARNOLD, Dcfcnd1l11l : IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 4, 1997. 2, The marriage of the p.laintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint, 3, I consent to the entry of a final Decree in Divorce after service of notice of intent to request entry of decree, 4, alimony, I do not I understand that I may lose rights concerning division of property, lawyer's fees or expenses if claim them before a divo~ce is granted, I verify that the statements made in the Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 pa, C,S, ~4904 relating to unsworn falsification to authorities, /lM ).'Il,<-..f)~i Robert E. Arnold, plaintiff Date: 7- t'l-'-; '';: I, , " , , I ., 'i 'I 1 " \',1':'1' "I j '~"', 1:I'i ..,i.'cll,\'; I ., , ;. 'r . ,~'I 1;/1'1., 'r' 't 'l '.,11 ./1,..1" ," 1\' " .': ',' j /,',1 "d." "" I, .,') ROBERT E, ARNOLD, Plaintiff : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 0.., __ /- /- 80 " J'" -r ( l.P lJl .;, II'..... w.", CAI~MA J. ARNOLD, Defendant IN LAW. DIVORCE AIIFIDA VIT OF MARRIAGE COUNSELING ROBERT E, ARNOLD. being duly sworn according to law, deposes and says: 1, I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling, 2, I understand that the court maintains a list of marriage counselors In the Office of the Prothonotary, which list is available to me uJlon request, 3, Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court, I understand that false statemcnts herein arc made subject to thc penalties of Pa, C,S, ~4904, relating to unsworn falsification to authorities, j(,J..j <{', ,4_ aJ Robert E, Arnold Date: /2,- v- 'i ?