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Home My WebLink About98-00233 \, 11\ .11] .. ~ ~, .~ {:. ,~ ~ ",j If I~ ~ , l. ~ *,~~~~.,~,~*,~,~*~,.~*,*.~.~..~.~.*.},~~..~*~,~***~ ~ '------,-..--... -,..--..-,- -, -' - -- -", -, -,''.' '''' " ., - , . .. ,,-... - ----,------, --'., ,- --- - 'I: ~ Alle.l:fJ ~ ~ Prothonotary :!i ~ i~ ;(, !", ~ ---,_..~- '..'.' ""~ ~-~*~~*~**~~~~**'*'~*'~'~'****~'*~}*~' * IN THE COURT OF COMMON PLEAS ~ ~ OF CUMBERLAND COUNTY ~:f STATE OF i)~~~ PENNA. - '~~""""l ~. ~J:';""'~r ~ ~ ... ~ ~ ',' * BETTY L. MARTIN, PLAINTIFF i'\ (), 98-233 CIVIL * * ~ V(!I':,t1S ~ CHARLES G, I~EISS, DEFENDANT ~ ~ ," * * * DECREE IN D I va R C E 1{:,.S-A.,N1. AND NOW, ' .. ,..0. '1), ~~.. .. .. , .. , " 19 ,~r.., it is ordered and decreed that ,'.""", ,llerrY ,L. ,~.lAnTIN, , , , , , , '. , , , '. , , , , , , , , , , , " plaintiff, and, .. , , .. , , , , '. , , , ~HAR~ES, ~,', ~of!'.I!3!3.. , .. , .. , , , , , , , , , , .. .. , , ", defendant, are djvorced from the bonds of matrimony, ~! ~ ,', ~ ~.. ~ ~ ~ ~.' * ~ The court retains jurisdiction of the following claims which have been raised of record in this action for whjch a fjnal order has not yet been entered; ~ ~.' ~ ~.' * All claims are settled. .. ,."...,',..,....,...,...,....,.......,..,.."..,.,. ... ,." ,.".. ....".. ~ ... ,', ~ ~ " ,'. ~ ~ ily The ~ ',' ~ ',' ~ ~ $ ~ ... ~ $ * $ * $ ~ ... ~ ~:' * * * ~ ',' * ~ ',' ~ ',' * ~ $ * ~ ~ I~ I" ?* ~ ~ I'" i~ I.., ,/, ) , .... t'.- '~ STIPULATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made in triplicate, this 30th day of January, 1997, by and between CHARLES GAYLORD WEISS, SSN 063-40-2419, hereinafter referred to as "the Husband" and BETTY LOU MARTIN, SSN 174-36-6863, hereinafter referred to as "the Wife", WIT N E SSE T H: WHEREAS, the parties to this Agreement were married on the 18th day of December, 1988, in Chesapeake, Virginia, and certain irreconcilable differences have arisen between the parties to this Agreement, and a suit for divorce is imminent; and WHEREAS, there were no children born of the marriage; and there were no children adopted during the marriage; WHEREAS, the parties, deem it desirable and appropriate to enter into a Stipulation and Property Settlement Agreemer.,t and desire to adjust, terminate and settle various rights, interests, and obligations between them; and WHEREAS, this Agreement is made and entered into freely and voluntarily by both parties, each being free from any duress or influence on the part of the other, and each fully understanding the terms, conditions, and provisions of this Agreement, and believing its terms to be fair, adequate, and reasonable. Page 1 Stipulation Agreement (l icJ .~LJl1 NOW, THEREFORE, for and in consideration of the premises and the mutual covenants, obligations, and undertakings in this Agreement contained, to be observed and kept by the parties hereto in accordance with the terms hereof and the benefits of each of them accruing thereunder, it is stipulated and agreed between them as follows: (1) SEPARATION: Each party shall be free from interference, direct or indirect by the other as fully as though unmarried, and each may for his or her separate benefit, engage in any employment, business or profession he or she may choose; and each shall not molest or interfere with the other, nor shall either attempt to compel the other to cohabit or dwell with him or her, by any means whatsoever. (2) WIFE'S PROPERTY: The Husband does hereby assign, transfer, release, grant, convey, and quitclaim to the Wife any and all of his right, title and interest, inchoate, vested or otherwise, which he has or may have or hereafter acquires in and to any and all property, real, personal or mixed, owned by or titled in the name of the Wife, of every kind and description, and wheresoever the same may be situated or located, and the Husband does renounce, quitclaim and release any and all rights, claims, demands and obligations by way of augmented estate, curtesy, Page 2 ~r11^J ./J'Yt.. Stipulation Agreement inheritance, descent, distribution or otherwise, which he has or may have or may hereafter acquire against the Wife, in any and all property, real, personal, or mixed, now owned and hereafter acquired by the Wife. (3) HUSBAND'S PROPERTY: The Wife does hereby assign, transfer, release, grant, convey, and quitclaim to the Husband any and all of her right, title and interest, inchoate, vested or otherwise, which she has or may have or hereafter acquires in and to any and all property, real, personal or mixed, owned by or titled in the name of the Husband, of every kind and description, .,and wheresoever the same may be situated or located, and the Wife does renounce, quitclaim and release any and all rights, claims, demands and obligations by way of augmented estate, dower, inheritance, descent, distribution or otherwise, which she has or may have or may hereafter acquire against the Husband, in any and all property, real, personal, or mixed, now owned and hereafter acquired by the Husband. (4) PERSONAL PROPERTY: The Husband agrees that the personal property described in the Wife's Personal Property Schedule attached hereto, previously in the joint possession of both the Husband and the Wife shall be the sole and exclusive property of the Wife, and he waives any and all claim to this property, The .' Page 3 Stipulation Agreement ~~ wife agrees that the personal property described in the Husband's Personal Property Schedule attached hereto, previously in the joint possession of both the Husband and the Wife shall be the sole and exclusive property of the Husband, and she waives any and all claim to this property, (5) RESIDENCE: The Wife shall have exclusive use, occupancy, and possession of the parties' jointly owned residence located at 700 South Centerville Turnpike, Chesapeake, Virginia 23320, until the house sells and closes. The Husband and Wife agree to each pay one-half of all mortgage payments, assessments, utilities, and ,.minor repairs on said residence until house sells and closes, The parties agree to place the house on the market for sale through a real estate broker and, upon sale and closing, the Husband shall receive sixty percent (60%')' of any net proceeds and the Wife shall receive forty percent (40%') of any net proceeds. (7) CONDOMINIUM: The Wife agrees to transfer to the Husband all right, title and interest in the condominium located in Hoboken, New Jersey, and the Husband agrees to save harmless the Wife as to all tax liability and any other liabilities that pertain to said property. (7) DEBTS: It is understood and agreed that neither party shall make or contract bills in the name of the other. Further, Page 4 Stipulation Agreement (l~ the part~es agree that neither party shall be liable for any debts, contracts, obligations, or liabilities of the other now existing or hereafter incurred, and shall hold the other harmless, except as provided for in this Agreement, (8) SPOUSAL SUPPORT: The Husband and the Wife expressly waive any and all right they have for spousal support, maintenance, or alimony from the other, imposed or imposable by law, or by any Court order, decree, or judgment, whether temporary or permanent, whether incidental to a proceeding for a divorce, separation, separate maintenance, or otherwise, (9) WIFE'S MEDICAL INSURANCE: The Husband agrees to maintain all hospital and medical insurance, comparable to that now in effect, for the protection of the Wife until said marital residence sells and closes, The Husband and Wife agree to share payment of all premiums on said insurance, (1.0) IRA ACCOUNTS: The Husband and Wife agree to waive any and all claim against the other's IRA accounts, (11) MOTOR VEHICLES: The Husband hereby agrees to transfer to the Wife all right, title, and interest in and for the 1990 Ni55an, and the wife is solely responsible for all remaining indebtedness, if any, and all expenses, including insurance related thereto, and holds harmless the Husband, The Wife hereby agrees to Page 5 (d&u I8U'rl. Stipulation Agreement transfer to the Husband all right, title, and interest in and for the 1989 Dodge, and the Husband is solely re5ponaible for all remaining indebtedness, if any, and all expenses, including insurance related thereto, and holds harmless the Wife. (12) SEPARATION: The parties state that at the date of the execution of this Agreement, they were in fact separated due to irreconcilable differences since January 30, 1997, (13) EFFECT OF RECONCILIATION: In the event of reconciliation and resumption of the marital relationship between the parties, the provisions of this Agreement, whether executed or .. executory, shall nevertheless continue in full force and effect without abatement of any provision hereof, except as otherwise provided by written agreement duly executed by each of the parties after the date of the reconciliation. (14) LUMP SUM AND EQOITABLE DISTRIBUTION ACT WAIVER AND FEDERAL LAW: Except as otherwise provided for herein, each party hereby waives, relinquishes and surrenders all of his or her present and future claims, right, title, interest and possession to the other party' 5 military or civilian pension or retirement benefits or annuity whether vested, contingent or non-vested under State or Federal law; real and personal property; and any other assets, whether acquired prior to or during the marriage and Page 6 Stipulation Agreement ~gi~ regardless of whether or not said property or assets is characterized as separate or marital property at the time of this Agreement, (15) COURT COSTS AND ATTORNEY'S PEES: Each party shall pay his or her own respective counsel fees in the negotiation of and preparation of this Agreement, as well as such counsel fees and Court costs in any divorce suit, (16) BUSINESS: The Husband and Wife agree to waive any and all claim or interest in the other spouses sole proprietorship business, (17) NON-DISCHARGEABILITY: It is the mutual intent and bargain of the parties that the monetary payments, obligations, and liabilities assumed and set forth herein for the benefit of the parties, respectively, shall be considered, for the purposes of federal bankruptcy laws, as exempt from discharge and nondischargeable in bankruptcy as support for a spouse or former spouse. The di5chargeability of debts to third-party creditors in bankruptcy shall have no effect on the obligations, liabilities, and debts assumed hereunder for the benefit of the parties, respectively, which are actually in the nature of support, Page 7 Stipulation Agreement ~~(J J !"Iv.... (18) FURTHER DOCUMENTS: The parties hereto each expressly covenant with each other that they will, at all times in the future, upon the request of the other party or their attorneys, execute and deliver to the other all additional or further documents of any nature which may be necessary and desirable to consummate and carry out the intent of this Agreement, (19) REMEDIES AGAINST DEFAULTING PARTY: In the event of any default of either party hereto to the terms of this Agreement, the cost and expenses of any litigation or other action of any nature necessary to compel compliance will be the responsibility of the party who fails to comply or defaults, Further, if either party breaches this Agreement by listing for bankruptcy discharge obligations which the defaulting party has promised in this Agreement to pay, then the non-defaulting party may, at his or her option, notwithstanding the entry of a final decree of divorce approving this Agreement, either rescind this Agreement in its entirety or assert his or her rights in Bankruptcy Court to contest the di5chargeability of said debts. (20) ENTIRE UNDERSTANDING: The parties have incorporated in this Agreement their entire understanding. No oral statements or prior written matter extrinsic to this Agreement shall have any force or effect, The parties are not relying upon, and Page 8 Stipulation Agreement C{'Yp , LIllA specifically herein repudiate, any representations other than those set forth herein, All prior written or oral agreements between the Husband and the Wife are hereby revoked and held for naught, (21) CHANGING OP AGREEMENT: It is the intention and agreement of the parties that no change of any provision of this Agreement shall be effected in any manner whatsoever, except by subsequent written Agreement of the parties, executed with the same formality and in the same manner as the execution of this Agreement, (22) RATIPICATION: It is understood and agreed that any ,. action for divorce between the parties shall be subject to and governed by the terms of this Agreement, and the terms and conditions set forth in this Agreement shall be incorporated into any decree of divorce or separate maintenance agreement which may be entered into between the parties hereto, but this Agreement shall survive independently of any decree as well, It is mutually agreed that in the event either party hereto shall institute proceedings for a divorce or separation, that such moving party shall submit this Agreement to the Court of competent jurisdiction in which divorce proceedings are instituted with the request that this Agreement, being fair, just, and reasonable, be approved, ratified, and affirmed by the Court. / I Page 9 (I /Jfi,~. Stipulation Agreement " STATE OF VIRGINIA CITY OF CIIESAPEAKE , to-wit: I, COLLEEN P. WOLTER , a Notary Public in and for the City and State aforesaid, do hereby certify that BETTY LOU MARTIN, whose name is signed to the foregoing Agreement dated the 30th day of January, 1997, has this day personally appeared before me and has acknowledged and sworn to her act, deed and signature, GIVEN under my hand this 27th 1997, day of February Cd~~/~L , NOTARY PUBLIC My commission expires: January 31, 2000 Page 11 Stipulation Agreement (j brA ) I?J L I.. Following is nlisl of items nt 700 South Cenlerville Turnpike nnd who is to get which: WIFE'S PERSONAL PROPERTY SCHEDULE DEN DEN GUEST ROOM GUEST ROOM GUEST ROOM GUEST ROOM HALL KITCHEN KITCHEN KITCHEN KITCHEN KITCHEN KITCHEN LAUNDRY .. LAUNDRY LIVING ROOM LIVING ROOM LIVING ROOM LIVING ROOM LIVING ROOM LIVING ROOM LIVING ROOM LIVING ROOM MBR MBR MBR MBR MBR MBR MBR MBR PORCH DEN DEN DEN DEN DEN DEN DEN DEN DEN Page 12 STAMATY PRINT KIMONO WICKER ROCKER KNEEHOLE VANITY TABLE LAMP QUEEN BED MITEY MITE VACUUM 4 OAK CHAIRS CHAGALL PRINT OAK TABLE BREADMAKER WALL PHONE STEP STOOL WASHING MACHINE DRIER LARGE RUG WOVEN BASKET SCRATCHING POST 5 PC COUCH ELEPHANT STAND DOORS PRINT CERAMIC VASE CAT TREE WICKER CHAIR OVAL PORTRAIT OAK DESK TREADMILL SEATED NUDE WHITE PHONE MIRROR MATISSE PRINT 2 ADIRONDACK CHAIRS NAD TUNER NAD PRE-AMP BLACK RUG PANASONIC VCR NAD POWER AMP CARVER AMP TECHNICS TURNTABLE WALL PHONE 2 POLK LOUDSPEAKERS B B B B B B B B B B B B B B B B B B B B B B B B B B B B B 8 B B C C C C C C C C C HUSBAND'S PERSONAL PROPERTY SCHEDULE (con't. on next page) Stipulation Agreement C!ht/ RLf'u.. >- ", ". <r. r~~ ~', ..~~ '=' :1 - UJ~.:! I.: " 0-, -, r" ' .' f;: O_ n ',: }C,; "I , ':~ f: L:, " II 1.1. i;"'": -, , >- , cry, -~ r-l.. :2 ~;~ ::t... '. -. u. 0.:'1 ::.J 0 <1' 0 >- Cl .- c.~ f; ,"- I- N ..) 1J1~~ .' r) .... f.) fi:\' .".. , , ~r:' L~ " i , ' . QI.- L,;) U11. , --II . -- .j o:.;.!.: , I [', .._r.: - > ,:.. (.., ::) U C" U ~i~ . ~ !il u . 0 ~ :$ ~~B ~ . :t I<~ fI.l ~ ~ ,.. i~~~ E-l ~ "' z !OJ u. ~ 0 ~ lJl U uI 8~~~ fi: ui'~ w 0 is 0 i~ u: fI.l ~ ~O !i: . ~~ ~ u. ~ !! g) 0 ~u ~es ~ ;:: ~ .. ~ ."-l -' 8~~~ C-' H g ...:1 i ~ fI.l a: ~ '" I ~ ~ ~ ~ ,. ~ .~ " ~ ~;:!l ,. P'l " ~ ~ ..--. ...-:> ....... ....--,.. ~---;.'" '- - BETTY L. MARTIN, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 98-233 CIVIL CHARLES G. WEISS, DEFENDANT CIVIL ACTION - LAW ACTION FOR DIVORCE . . PRAECIPE TO 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 Ii 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: On January 26, 1998, via U.S. Mail, First Class, Certified, Return Receipt Requested, Postage Prepaid. (Please see attached proof of service marked as Exhibi t "A".) 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff, April 30, 1998; by Defendant, April 30, 1998. 4. Date of signature of the Waiver of Notice of Intention to Request Entry of Divorce Decree: by Plaintiff, May 10, 1998; by Defendant, April 30, 1998 (see attached Waivers of Notice). 5. Related claims pending: None. GATES & ASSOCIATES, P.C. Susan K~ andiello, Esqui i , Attorne f r Plaintiff Sup. Ct. L #64998 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 DATED: May 14, 1998 ,..J '" ~to \/'''1 -~ ~ f'- "'" " ,~ C'I\ ~ C ~ ...... 8 ,~ r-.\ IJ: ~ ~ J'.. l:x:> ()~ ~~ '<: - ~ ..:t ..... [.. - ,. ,.- c.; -:-J .1" UI~) f); :; (.~Cl:) :r.: l':' ~~~ [t.., a.. (~! ~.~ ~r: C\ In :.;; ~:~ (,I.: . (..I.. - " .X EEl..-' - ~, ~dlU ; "1: .;.\ !...f.~ c.l- f.- -J . . ~5 u. (C Q 0' U ~) ~ ~: ~ ~ B SS .~ fLot.J!:!! ~~~~ ;~~~ E:lgg~~ .1 ml ~~ c..? I J . ~ i ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ gg <>:: ...... ~~ .... ~; ~ ~ o g t.J t.J l..i ~ iii ~ ~ OJ) U ~ 0 u. II) ~~ :5~ II) ~ J ~ :$ :t ~ ~ ~ "' 5 ~ ~ ~ Ii! c:i < !i! < '" '" => '" M i'! " ~ " 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 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 Prothonotary at: Office of the prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania, 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER' S FEES OR EXPENSES, BEFORE A 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. CUMBERLAND OOUNI'Y BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Dated: January 13, 1998 ~ GAT S & SSO Susan Kay Sup, Ct, Id, No. 64998 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 Attorney for Plaintiff BETTY L. MARTIN, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 5/Y-.J3JCIVIL CIVIL ACTION - LAW CHARLES G. WEISS, DEFENDANT ACTION FOR DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Pennsylvania Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. divorce. 8. Plaintiff and Defendant have been advised of the availability of counseling, and of the right to request that the Court require the parties to participate in counseling. 9. The marriage is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a Divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, Plaintiff respectively requests if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of filing of this Complaint, this Honorable Court enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code, Respectfully Submitted, GATES & ASSOCIATES, P.C. DATED: January 13, 1998 ~ us an Kay c~ello, Esquire Sup. Ct. Id, ,64998 Attorney for Plaintiff 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 Telephone No. (717) 731-9600 Facsimile No. (717)-731-9627 VERIFICATION I, BETTY L. MARTIN, verify I am the Plaintiff in the foregoing action, that the attached Complaint for Divorce is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of the Complaint is that of my counsel and not mine. I have read the Complaint and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Complaint is that of counsel, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities for any false statements that I have made in the foregoing Complaint. DATE: January 13, 1998 1~-~7/~~~ BETTY . MARTIN ~ C\J -- ~ r:.~ .. .'- P.30 - -, :.<: l";'):':'~ ~(5 ~- (.") :;.. '-2:: 0:: ' - ", ..:. lC' . . ,..J C:. '" .' .>- I ,/'-'- -: ;.:? / If'" )- C:'.';Bj IE "'"' --, l....:JCt- ~ '. u.. ro "-- 0 .:1 en U tIl I>:: < 0 . ~ ril l> (,,) ...:l H . "" i:1J A ll. :S ~ :l! Z Z fIl ~ 0 -H ~ ~ >< ril f-l l) u. ~ 0 E5 t3:...:l H 0 l) <H ..... - '-' l>...:l tJl (,,) uI 0 ...:ll> - ..... tIl l:: I>::H w 0 5 r<t U H Z '0-1 tIl co ril<1l tl ~ 0 IU H .... H 't:I U):f: u. fIl ~ f-l l:: ril l:: u. fIl g f-l Z I>:: '0-1 t3: Q) r<tA 0 ;< I>:: 0 ;1 co ..... Oril 3 ~ 0 ...:l H<'l ...... . Q) H '" Qid iil 0 I>:: f-l<'l "" . t)) ~ f-lr<t ..J l) ril UN . Ul HH ci .. I<l <I ...:l > U) l>~ fIl 0 ril S CO ril <I>:: a: :>:: ...:lC1 >< ...:l Aril 5 ~ f-l U H ~ po: Hl) ::I => l> . ~ ;3 r<t ::I Z r>< HO ril r<t " ~ H 0 uZ I<l U < ~ ril . . SS: COUNTY OF CUMBERLAND Be it known, that on the ,'?lV.~ day of II~ before me, the subscriber, a Notary-public, personally SUSAN KAY CANDIELLO, who, being duly sworn according to depose and state as follows: 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania, and I am employed by the law firm of Gates & Associates, P.C., Lemoyne, Pennsylvania. , 1998, appeared law, did 2. My law firm represents Betty L. Martin, in connection with the above-captioned matter. 3. On January 22, 1998, I personally delivered to the U.S. Postal Service in Camp Hill, Pennsylvania, as certified mail (Receipt No. Z 296 317 561) return receipt requested, addressed to the Defendant herein, a true and correct copy of the Complaint in Divorce filed in the above-captioned matter, 4. showing Exhibit The return receipt card signed by a date of service of January 26, 1998 flAil. the Defendant herein is attached hereto as 5. Service by certified mail meets the requirements of Pa. R.C.P. 404(2) and Pa, R.C.P. 403. this ~1(J fh a~ sworrl TO /},ND SUBSCRIBED day of wJI~~/ , 1998. otary Public My Commission Expires: Notarial Seul JAnel C, NAclorio, NOlary Public Lemoyno 80ro, Cumberland County My Commission Expires April 19, 1999 Member. Penn~ylvani" A.ssOOation of Noli:m..$ '. I i _COmpIllllt;ml1 anctior2 tor addItIonII HMC". "I _Complltlltlme3, .... and 4b. .Plint your"amt and addml on thl rlVI,.. 01 IhI, form 10 that on can return tN, I also wish 10 rec.lv. the following servlc.s (lor an .xtralo.): 1, CI Addra...a's Addr... :KXXR.st~eted o.lIv.ry eonsull poslmast.r for 10., 4a, Arllet. Numb.r Z296317561 4b, S.rvlca Tvp. o Roglst.r.d X~Ca~ifled o Expr... Mall 0 Insur o Aelum Aecelplfor Merchanclse 0 COO 7. oal. of oollv.ry 8, Addr....o'. Addr... (Only II requ.sted snd fe. Is poldl f I j f .!!, " , eo !: !l o .. .!l '''''95-97.0-0179 Domestic Return Receipt Exhibit "All >- C\l '- rr; '" f:; to' U:i~~ .. "- - ::"J.r ( . r )=..: H'(~; .,- '-):.~ ~i\ u: ,.")> "S~ Cl. CO-l :~(,J .I.L - ..J ."lj.;~ u:tl.l, >- T (J'b (-; ~.r ,!!::t: ~ L1. eu ;j C,l en U . ~ u !:l~~ . 110 :5 ., ~ ~~~ rn i ~ ; ;h~ u. ill 0 Go :::: ... ~ Ul U uI '... ~ w 0 S ... u 0 !!l o ..I A ~ ,~ ., u. rn ~~~~ rn OJ !:l u. rn g rn .... 0 ~ Eo! E:l ~ 2l Eo! ;= ~ ~ . ~ " ~ ~UU~ OJ .... > d ~ 8~~e A rn ~ ~ a: I ~ ~ ~ cb ' ~ '" "'I => '" .:3; " P'l i'i or> '" ~<'-.. .___-J / BETTY L. MARTIN, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 98-233 CIVIL CIVIL ACTION - LAW CHARLES G. WEISS, DEFENDANT ACTION FOR DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 15. 1998. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) day have elapsed from the date of filing the Complaint, 3. I consent to the entry of a final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. I have been advised of the availabili ty of marriage counseling, and under5 tand tha t I may reques t tha t the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the prothonotary's Office, which list is available to me upon request. 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 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: April jliL, 1998 '--&Cz:t~1 ;/./ }/ tLctD.\ ' BETTY ',' MARTIN ~ 0' ~ r:: ... :"j...( ,: c~ CI UJ~-.. (."J-.; (~~C' ." ();.'; f"-( c- L.. ' i:~ :.:.1 ~(.; ,. .n ,/J r;'. "I>': UIl:- I;: ;: _JUt ~- 1,lu.J a::-. ';.,1. :.1~U" r.= :;i; IJ. {"(1 :::> 0 el' l.) I g/lllil . ~ (".l ~ ~~8 . llo :S ~ 5 H ~ ~ ~tH5 (f.l ~ ""<<lil <>::<>:: ~ ~ I ~~S ~ ~ ..., ~~ u. ili 0 0. !ii "' ~~ I7%.QQ OIl (".l S 't:l w o UQ ~ 0<17%. <.l 0 U ...:l ~ lill7%.O u: (f.l ~ 17%.0~<>:: . en u. (f.l OU ~ 1Il en ~ uo,..., 0 ~ If I > ~ H () ~ H~UZ !::><~ ;:: z~~ .. old iil g5 ",,:=1 -' . 0 o ""fj L'l I7%. "" .. U N ...:l OHZ (f.l li! ~~~~ I 5 .. fi ~I~ '" '" :> ..... ,. ~~f@~ ~ en ~ !;! :;! ~~ ~~ .._~ ._.~.__.I WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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 18 Pa.C.S. ~4904 relating to unsworn falsification of authorities. DATED: t1~ /0 ,1998 ~ba;tecA If}{~\.- BETTY . MARTIN rr. "I E .', 1- u.lq .. : ~J . ". - B~t~ r) .. -.. :...; ,: if. "- \.-' : .- 'J.lc: c:.. :~') :::'. f._Ii." <',J '~', I.;: I.I'.!... - ..1", fi! -. ~,t! >- It-.;; , 'it,; "'" ..:; C)," ,,- ,.--1.. IJ. - :5 u c:l U'I 0 ~~ ~ . ~ v . ll. :$ fIi ~ ~ ~ ~ '" z ; ~ ~ u. ili 0 ... v u1 8~ ~~ u OJ) 5 ~ w 0 'H Ul ,j.J r.. 0 ~ I ~ Ul ~ 0 u. (I) ~i ua u. (I) ,j.J ~ C E-< 0 ;< ~ ~ M~ ,~ OJ ~ ;: ~ .'H .. ~ ~ ~ t.!l ~ Q ..J o M . ~ cS U N . ~ I .. ~~ ~ I ~ (I) 0 "' ~ ~ ;l J '" sj~ :> ~[:; '" ~ p S! ~~ , ~......c .-. / ~~. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 15, 1998. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) day have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 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, fJ . , y"'--''''/ CHARLES G. WEISS DATED: April ~, 1998 ir: ('\J '- ~ l- 010 .. .....: ( )~: - :-')-.[' 1~2! -,- f...J:.,. ,:1; ;;..J :..~ ~ (' ~~! ~~ LJf::: ", :')!) Ei: LI.J >- . r ~'.= r.!.: 'j ') Mt :i1t.1 ..,- lL - ~_c.l.. " U ~ =3 en U ~Ii" . ~ es ~ \.J I ,...., ~ I u :s '-" ~ ~ ..... III a ; z~~u '" '" z ...: u. ~ ~~U~ rz.. rz.. es 0 <Il \.J u1 8 p :t:l a a ~ w 0 ~ ~ ... t3 ~ 0 rz..a~~ i€ CIl lii u: III ~ 'M CIl aU ~ ... i 1l ~ ; u. III 8 ~ ,~ 0 ;< ~~~es 01 ~ ;: ~ pj d ~ rz.. H ~ .. ~ iil -' a ",H . ~ U N Ej ~ Ul i~a (!3loill > I III ~r3~ I '" ~ 5 .. '" '" ~~si~ :> :30 ~ P '" " t:! :;! _.-...:0 -.,,...,, -"" ..... "'" --.- ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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, I I 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. !l4904 relating to unsworn falsification of authorities. DATED: April~, 1998 c ( I ~ CHARLES G~' WEISS