HomeMy WebLinkAbout98-003760
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF iip PENNA.
JENNIFER L. JOHNSON
Plaintiff 11.. g8 .-..3.7.6 .... ................. 1998
;. _ .
Vor.:ns
DAVID LEE JOHNSON, JR•
;:, Defendant
DECREE IN
1 DIVORCE
AND NOW, .... . ...... ?....... , 197 .... it is ordered and
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decreed that ... JENNIF . ER L. JoEUVSON
...................................... .plaintiff,
and . . . . . . . . . . . . . DAVID.LEE . JOHNSON,. JR. ....................... 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; +
Property settlement is incorporated but not merged. 1
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Attest: lr',ilc., .42?l?n.-
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THIS IS AN AGRL'IiML'N'I' made this day of 1998, by and between
Jennifer L. Johnson (Grigg) 01' 1668 Quail Drive, Carlisle. C'umh and County, Pennsylvania
(hereinaller referred to as Wife) and David Lce Johnson, Jr.. 01'36 South 24th Street, Harrisburg ,
Dauphin County, Pennsylvania, (hereinaller referred to as Husband).
WHEREAS, Husband and Wife were married on November 16, 1996, in Carlisle, Cumberland
County, Pennsylvania; and
WHEREAS, various differences have arisen between Husband and Wile, whereby they have
been living separate and apart fir over six months; and
WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the
property rights ofthe parties and to dispose of the rights and obligations ofeach to the other in
respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights
and obligations under the Divorce Code of 1980, as amended, and it is the intention and
agreement of the parties that this Agreement be a full, complete and final settlement of all of
those rights and obligations under said Divorce Code; and
NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound
by the provisions hereof; the parties agree that their recitals lbrm it part of this Agreement and
waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel
fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not
provided for herein and agree as follows:
I. SEPARATION. The parties agree that it shall be lawful fir each party, at all times
hereafter, to live separate and apart from the other, at such place or places as he or she may, from
timo-to-time, choose or deem fit. Each party shall be free from interference, authority or contact
by the other, as fully as if he or she were single and unmarried, except as may be necessary to
carry out the provisions of this Agreement and as may be necessary to exchange infonmation that
pertains to the parties' minor child. Neither party shall molest the other 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 the peaceful existence, separate and apart, from the other.
2. AUTOMOBILES. Wife shall have as her sole and exclusive property, title to and
possession of the 1995 Ford Mustang. Husband shall have as his sole and exclusive property,
title to and possession of the 1997 Hyundai Accent and the 1994 Isuzu 900 RF motorcycle. Each
party shall indemnify and hold the other harmless from and liability on any loan encumbering the
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vehicle(s), cost of repairs. maintenance. registration. insurance and/or inspection of flee vehicle(s)
which each is taking as hiS/her sole and exclusive property.
3. PERSONAL PROPERTY. The parties have divided or have agreed ton division of their
personal property which includes bank accounts, certificates ol'deposit, life insurance policies.
jewelry, clothing, furniture and other personal items. After the albresaid division of the personal
property is complete, any and all properly in the posSCSSion of[ lUsband shall lie his sole and
separate property. Any and all properly in the possession of Wife Shall be her sole and separate
property. Each party forever renounces whatever claims he/she may have with respect to the
property which the other is taking. Each party understands that he/she has no right or claim to any
property acquired by the other after the signing of this Agreement.
4. PENSION/RETIREMENT PLANS. The parties agree that each waives any right to share
in any pension of the other.
5. DEBTS. The parties agree to an equitable distribution of the loans in favor of Members
Ist Federal Credit Union and PNC Bank. The parties agree to release the other party from any
responsibility for any debt a party has assumed and will cooperate in having the other party's
name removed from the loan account.
6. ALIMONY, ALIMONY PENDENI'E LITE, SUPPORT OF SPOUSE. The parties waive
any and all right to receive from the other any payment of alimony, alimony pendente lite, and/or
spousal support.
7. EFFECTIVE DATE. The effective date of this Agreement shall be the date of execution
by the parties if they had each executed the Agreement on the same date. Otherwise, the
execution date of this Agreement shall be defined as the date ofexecution by the party last
executing this Agreement.
8. DIVORCE. Wife has tiled a divorce action No. 98-376 Civil Term. It is agreed and
understood that the Husband shall not contest, but instead consent to such proceedings and shall
execute any and all documents necessary so as to proceed with and obtain an absolute and final
divorce.
9. INCORPORATION INTO DECREE. 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 separation or divorce; and that nothing in any such decree,
judgment, order or further modification and revision thercofshall alter, amend or vary any term
of this Agreement, whether or not either or both of the parties shall remarry, it being understood
by and between the parties hereto that this Agreement shall survive and shall not be merged into
any decree,.judgmcnl, or order ofdivorce or scpnralion. It is specifically agreed, however, [hilt a
copy ul'this Agreunncn[ or the substance ol'the provisions ther•eol, may be incorporated by
reference into any divorce, judgment or its decree. This incorporartion, however. shall not be
regarded as an merger, it being the specific intent ol'the parties to permit this Agreement to
survive any judgnnent and to be litrever hinding and conclusive upon the parties.
IQ MU'T'UAL RELEASE. Husband and Wilc do hereby nwtunIly remise, release, quit claim
or firrever discharge the other and the estate ofsuch other, I' or all time to come, and fin' all
purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate
of such other, of whatever nature and wherever Situate, which he or she now has or at anytime
hereafter may have against such other, the estate ofsuch other or any part thereof, whether
arising out of any Rnnner acts, contracts, engagements or liabilities ofsuch other or by way of
dower or curtesy of claims in the nature ofdower 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 or
other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising
under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any
other country or any right which either party may now have or at anytinnc hereafter have for past,
present or future support or maintenance, alinnony, alimony pe ndente lite, counsel fees, costs or
expenses, whether arising as a result ol'the marital relation or otherwise, except and only except
all rights and agreements and obligations oflvhatsoe'er nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife
to give to each other by the execution of this Agreement a full, complete and general release with
respect to any and all property of any kind or nature, real, personal or mixed, which the other
now owns or may hereafter acquire, except and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or f'or the
breach ol'any provision thereof'.
It. COUNSEL PEES. Each party individually covenants and agrees that he or she will
individually assunnc the fill and sole responsibility for legal expenses for his or her attorney and
court costs in connection with any divorce action which may be brought by either party and shall
make no claim against the other for such costs or Ices.
12. 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 or documents that may be reasonable required to give full force and effect
provisions of this Agreement. to the
13. MODIFICATION OR WAIVER. A nnodification or waiver of any of the provisions of
this 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 Shull not be construed as a waiver of any subsequent dclhuIt of the
same or similar mature.
14. ENTIRE AGREEMENT. This Agreement contains the entire understanding ofthe parties
and there arc no representations, warranties, covenants or undertakings other than those expressly
set forth herein.
15. SEPARATE" PARAGRAPHS. It is specifically understood and agreed by and between
the parties thereto that each paragraph hereol'shall be deenmed to be a separate and independent
agreement.
16. BREACH. If either party breaches any provision of this Agreement, the other party shall
have the right, an his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her and the party breaching this Agreement shall
be responsible for payment of legal fees and costs incurred by the other in enforcing the rights
wider this Agreement, or in seeking such other remedies or relief as may be available to him or
her.
17. CONTROLLING LAW. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
18. INVALIDITY OF PROVISIONS. If uny term, condition, clause or provision of this
Agreement shall be determined or declared to be void or invalid in law or otherwise, then only
that term, condition, clause or provision shall be stricken from this Agreement, and, in all other
respects, this Agreement shall be valid and continue in full lbrce, effect and operation.
19. BINDING NATURE. Except as otherwise set forth herein, this Agreement shall be
binding and shall inure to the benefit of the parties hereto and their respective heirs, executors,
administrators, successors and assigns.
IN WITNESS WHERHOF, the parties have hereunto set their hands and seals the day and year
first above written.
WITNESS
J nnlfcr L. Johnson (GrAgg)
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
On this, the 2i?)70 day of l.(?? 1ua 1 , 1998, before me Niven J. Baird,
the undersigned officer, personally appeared Jennifer L. Johnson (Gragg), known to me
(or satisfactorily proven) to be the person whose name Is subscribed to the within
instrument, and acknowledged that she executed the same for the purposes therein
contained.
In witness whereof, I hereunto set my hand and official seal
I I L? I DAA J'L' (Seal)
Notary Public
NDTAP.IAL SEAL
NIVEN J. BAIRD. Nouty Pubic
Sculn M'ddlelon Twp.. Cumberland CO
My Commispmi ErLyes Nov. 2. 1998
1, .h.
,- yid LW -ill.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
On this, the --9'7,6fi day of AW051 , 1998, before me, the undersigned
officer, personally appeared David Lee Johnson, Jr., known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purposes therein contained.
In witness whereof, I hereunto set my hand and official seal
Notary Public r w?he?i.ag1
lawn P¢Ison. Notary Public
HampdsnTvp., Cuml:ad:ind County
My Connnh!ion Er,piroa July 27.2070
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JENNIFER L. JOHNSON, IN THE COURT Of COMMON PLEAS Oh
I'lointiff CUMBERLAND COUN'T'Y PENNSYLVANIA
V. : CIVIL DIVISION - LAW
DAVID LEE JOHNSON, JR. : NO. 98-376 CIVIL TERM
Defendant
IN 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 Section 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: January 23, 1998, Certified Mail - Return
Receipt Requested, restricted delivery.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
By Plaintiff: October 19, 1998; by Defendant: November 7,1998.
4. Related claims pending: none
5. (Complete either (a) or (b).
(b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary:
September 11, 1998.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: September 11, 1998.
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L ndsay Dare Baird, Esquire
Attorney for the Plaintiff
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JENNIFER L. JOHNSON,
Plaintiff
DAVID LEE JOHNSON, JR.,
Dclcndant
IN TI IE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
98- J74, CcutF' -rccf1v
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
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.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
I '
JENNIFER I.. JOHNSON, IN TI IE COURT OP COMMON PLEAS OP
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. :98- 31! (o CA. a-.J ( T c,..,.
DAVID LEE JOHNSON, JR., IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
Plaintiff, Jennifer L. Johnson„ by her attorney, Lindsay D. Baird, Esquire, sets forth the following:
Plaintiff, Jennifer L. Johnson, is an adult individual residing at 1665 Quail Drive, Carlisle,
Cumberland County, Pennsylvania.
1)
Defendant, David Lee Johnson, Jr., is an adult individual residing at 26 South 24th Street,
Harrisburg, Dauphin County, Pennsylvania.
3
The parties were married on November 16, 1996, in Carlisle, Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least
six months prior to the commencement of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this or any other jurisdiction within the
knowledge of the Plaintiff.
.
7
In accordance with Section 3301(e) of' the Divorce Code, the marriage between the parties is
irretrievable broken.
8
Plaintiff has been advised that counseling is available and that Plaintiff may have the right to
request that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced
from the Defendant.
indsay D. B d, Esquire
Attorney for the Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243-5732
I verify that the statements in the foregoing pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification
to authorities.
J nifer L. J hnson
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JENNIFER L. JOHNSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DAVID LEE JOHNSON, JR.
Defendant
NO.98-217(a CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Lindsay Dare Baird, being duly sworn according to law do depose and stale that a coand pyaof the
Complaint filed in the above-captioned matter along with a copy of a Notice to Plead
Notice of Availability of Marriage Counseling was served on the Defendant, David Lee Johnson,
by Certified Mail - Return Receipt Requested, restricted delivery, a copy of said return receipt
evidencing delivery being attached hereto. Said service on January 23, 1998.
ndsay D. B d, Esquire
Attorney for Plaintiff
1252 Holly Pike
Carlisle, PA 17013
717 - 243-5732
Sworn and Subscribed to
before me this I I TH day
of$q?*m6er , 1998.
(.t.12>ti
Notary Public
NOTARIAL SEAL I
NIVEN J (3AIHD. Notary Nbhc
South FAdUlelon Twp. CmnbatanU Co
rnv.Chmrne ,, n P.pires Nov 2. 19913
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moor s for adddlund ee1VIC68. 1 also wish to receive the
4on„d 4b• following services (for an
d address on the reverse of this la that we can rotmo lhie extra too): w
IM hors of the rnallixem. or on Ilw beck If spew does nor 1, ? Addressee's Address Z
Ipf nernmefed'on the m 4plen below the article number. 02.,k Restricted Delivery IY1
1 was show to whom the adids was dellvated and Iho dale
David Lee Johnson, Jr.
26 South 24th Street
Itarrinburg, PA 17103
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INITED STATES POSTAL SERVICE
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JENNIFER L. JOHNSON,
Plaintiff
DAVID LEE JOHNSON, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 98 - 37(a CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 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.
DATE: __ ' I nX `/ !f L l (l ? ?/L?Li/C ?lJC
laintiff
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JENNIFER L. JOHNSON,
Plaintiff
DAVID LEE JOHNSON, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 98 - ,37(a CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 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.
u ,
DATE: Cl %• ?y f 50
Defendan
cn
JENNIFER L. JOHNSON,
Plaintiff
v
DAVID LEE JOHNSON, JR.
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 98-0376 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 21, 1998.
2. The marriage of Plaintiff and Defendant is Irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. 1 consent to the entry of a final decree in 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. 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: LL 1- 0 y Ac. L F ?. l
P intiff
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JENNIFER L. JOHNSON,
Plaintiff
v
DAVID LEE JOHNSON, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 98-0376 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 21, 1998.
2. The marriage of Plaintiff and Defendant Is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. 1 consent to the entry of a final decree in 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. 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:
Defendant
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JENNIFER L. JOHNSON
V.
DAVID LEE JOHNSON, JR.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-0376 CIVIL TERM
ORDER OF COURT
AND NOW, this day of SEPTEMBER, 1998
the Court that Defendant's , It appears to
affidavit of consent under 3301(c) of
the Divorce Code was filed more than thirty (30) days after it
was executed. Pursuant to Pa. Rule of Civil Procedure 1920.42
(b)(2) said affidavit of consent is no longer valid. The Court
will entertain entering a final decree when a timely affidavit is
filed.
By the Cou
Edward E. Guido, J.
Lindsay D. Baird, Esquire
For the Plaintiff
David Lee Johnson, Jr. ?`????" r,.?aS?`(?/JS?gB•
26 South 24th Street
Harrisburg, Pa. 17103
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JENNIFER L. JOIINSON, IN'1'I11's COURT' Oh COiviMON I'LL•AS OP
I'luintil'I' C'UM13ER1-AND COUNTY PENNSYLVANIA
v. : CIVIL DIVISION - LAW
DAVID LEE JOHNSON, JR. : NO. 98-376 CIVIL TERM
Defendant
IN 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 Section 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: January 23, 1998, Certified Mail - Return
Receipt Requested, restricted delivery.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
By Plaintiff: August 12, 1998; by Defendant: August 4,1998.
4. Related claims pending: none
5. (Complete either (a) or (b).
(b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary:
September 11, 1998.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: September 11, 1998.
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V Lind e pare aird Esquire
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Attorney for the Plaintiff
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JENNIFER L. JOHNSON,
Plaintiff
v
DAVID LEE JOHNSON, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
: NO. 9%-37(Q CIVILTERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 21, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. 1 consent to the entry of a final decree in 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. 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: ELI ? - II
Defendant
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JENNIFER L. JOHNSON,
Plaintiff
v
DAVID LEE JOHNSON, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
: NO. 96'37 (c CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 21, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. 1 consent to the entry of a final decree in 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. 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: Ild-C? ! ,f 1 l 1,O- r ?Z,
Plaintiff ? p
-lit
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
Vs File No. q 3 - - j CC.
IN DIVORCE
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
prior to the entry of a Final Decree in Divorce,
or ,f after the entry of a Final Decree in Divorce dated I a I ?q
hereby elects to resume the prior surname of _),t v)n „ a L?j n (- MOO , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704.
Date: C'
Signatur6
ignature of name being ru6med
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF -Cumberland-)
On the alp day of jy(0.y , 200 $ , before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
s K.
NOTARIAL SEAL. Prothonotary or N tary Public
PROTHONOTARY, NOTARY PUBLIC
CARLISLE CUMBERLAND COUNTY COURTHOUSE
MY COMMISSION EXPIRES JANUARY 4, 2010