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HomeMy WebLinkAbout98-00539 ~ \ ~ " ~ ~ , "1 j! / ( ~ :--... .... ..:;) ~ ~ ~ ~ \).... ~,~,~,*,~,~_.~'~.*~*~roro~*~*ro.):'*:~~:'*;'***_:~~ '.---- -------. .' ~ M ~.' ?~ n ~ ~ ~.~ : IN THE COURT OF COMMON PLEAS : ,.; ~ " .', ~ ,', ~ ~ ~.~ ~ " ,', ~ ~ ',' ~ ~.~ ~ ~.~ ~ ~.~ ~ ~.' ~ ',' /. ~ ~.~ OF CUMBERLAND COUNTY ~ STATE OF 1. PENNA, William J. Kibe, II., ,............. II N (). ......~}9...,~~.iyi~..,~.~<<;:!:".m. 19 98 ~ ',' ~ ~:: ~ ..~ *- ~.~ ~ ~.~ ~ ',' ,', ~ .', ~ ~ ~ ~.~ *- ~.~ ~ [:. *- ~.~ ,.; ~ $ ~ ~.~ $ ~ ~.~ ~ ~.: .', ~ ~ ,', ~ *- ~.' ~ ~ ~.~ ~ ',' ,', ~ ~ ~ !:~ ~ ! ::;;':Jif;~~' . J. i s .. ,~NlL .k',.J.U/~,~? ,.., '" :<1 i<i j ~P;olhonOlnry ',' ~ ,', ~ ~ ~ - ._..__.._.. ____~~.. _..' _~ __. __.~__~ - .,__..__________.....~~__~ _~_______.. ~..~_~~ ..~.__~~_... .~. I ~ ~~._-~~-~-~-~~~-*-~********~~-~ p.laintiff I :1 VCI'StlS i .... :i " ,I it Michelle Th Kille.'" Defendant ~ y DECREE IN DIVORCE ~ >: ~ ~.~ ~ ~.; ~ ~.~ ~ ~.~ ~ ? ~ :.~ ~ ~.' AND NOW, .. ..Dc.<::C'""L~..\s......,.., 19 ,~~..,' it is ordered and decreed that ,.."." ~~~~~,~II!, '!,', ,~~~~,'. ,!-~:, , . , , , , , , " , . , . , ., plaintiff, and, , , , . , , , , . , , , , , . , ,~~~.~~~~~, ,J;.:, ~~l?~, , , , ., , . . , . , , . . , , , , " defendant, are divorced from the bonds of matrimony. ~ ~.' The court retains jurisdjction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ~.~ ~ fo": ~ ~.~ ~ '.' ...................... .... ................ .... ..... ... ...... ...... ......... .....,......... ...... ...... ...... .... ................ ..... WILLIAM J. KIBE, II, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN. VS, NO. 98.539 CIVIL TERM MICHELLE L. KIBE, Defendant CIVIL ACTION, LAW IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this ,;J'7fiy of .~;;;7"L~v!i.<>/, 1998, by and between William J. Kibe, II of 202 Bridge Street, rear, New Cumberland, Pennsylvania 17070 (hereinafter referred to as "HUSBAND") and Michelle L. Kibe of 401 Erford Road, Camp Hill, Pennsylvania 17011 (hereinafter referred to as "WIFE" ,) WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on August 24, 1990 in Las Vegas, Nevada. HUSBAND instituted an action in divorce to No, 98,539 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania on January 30, 1998, The pleadings in the case requested dissolution of the marriage between the two parties and for such further relief that the Court may deem equitable and just; and WHEREAS, the parties have reached an agreement as to the settling of all matters relating to the divorce and custody of their son, Mark David Kibe, NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: I. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and pUrpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2, The terms of this Agreement and their effect have been fully explained to the HUSBAND by his counsel, Jane M. Alexander, Esquire. WIFE has been adyised by her counsel, Gary L, Kelley, Esquire. The parties acknowledge that they have received independent legal advice from counsel of their choice and have been fully informed as to their legal rights and obligations or have fully chosen not to do so, The partjes understand the facts and acknowledge and accept this Agreement as fair and equitable. 3, The parties have attempted to divide thejr matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights, The division of existing marital property is intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected wjthout the introduction of outside funds or other property not constituting a part of the marital estate, 4. Further, the parties agree to live separately and apart from the other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever, Each party may carryon and engage in any employment, profession, business or other activity as he or she may deem advisable tor his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 5. The consideration tor this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other, The adequacy of the consideratjon for all agreements herein contained is ") \ , ! , I . \ ,I , :", i i ~ " i I. I' " , ,I , '~ t._"' stipulated, confessed, and admiued by the parties. and the parties intend to be legally bound hereby. .~ ' , 6. DEBTS OF THE PARTIES: It is further mutually agreed and understood by and between the parties that all joint debts have been paid including open accounts, credit cards, and bank liabilities except as , hereinafter set forth: 6,1) The HUSBAND shall assume all liability for and pay and indemnify the WIFE against liability for all debts and bills in his name alone, particularly those incurred since date of filing Complaint in Divorce, 6.2) The WIFE shall assume all liability for and pay and indemnify the .I<ov' HUSBAND against liability for all debts and bills in I)f1; name alone, particularly those .- , ~ incurred since date of filing Complaint in Divorce, j ) ) '1 I , I 6,3) HUSBAND shall be responsible for and has paid or will complete payment of the following marital debts and shall hold WIFE harmless from any obligation thereof; I , i ~ Keystone Fjnancial Account No, 30804320015 Balance as of date of separation $6,000,00 I . ! I , I ! I i ~ ' ~ j , , j I Navy Federal Credit Union Account No, 1639018.017 Balance as of date of separation $16,000.00 Marine Air Federal Credit Union Account No. 4060690000832656 Balance as of date of separation $2,350,00 Harvey McCorkle Balance as of date of separation Household Finance Corp. Account No, 212 302 20 946824 $1,300.00 " Balance as of datc of separation $3,000,00 SignetfCapital One Account No, 4121741306567442 Balance as of date of separation $500,00 Dauphin Deposit Bank & Trust Account No. 6893546-8001,001 Balance as of date of separation $7,678.46 (Husband will pay December, January, February payments,) 6.4) WIFE shal1 be responsible for payment of the fol1owing marital debts and shal1 hold HUSBAND harmless from any obligation thereof; Dauphin Deposit Bank & Trust Account No. 6893546-8001,001 Balance as of date of separation $7,678.46 (Wife will pay balance of payments beginning March 1999) 7, PERSONAL PROPERTY: As to al1 items of personal property which the parties have divided to their mutual satisfaction, henceforth, each of the parties shal1 own, have and enjoy independently of any claim or right of the other party, al1 items of personal property of every kind, nature and description and wherever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE, with ful1 power to the HUSBAND or the WIFE to dispose of same as ful1y and effectual1y, in al1 respects and for all purposes as if he or she were not married, Specific disposition of major items or personal property is as fol1ows: 7.1) Vehicles: (a) HUSBAND shal1 retain ownership of the 1995 1/2 Isuzu Rodeo, and shal1 be solely responsible for any debt relating thereon, if any. (b) WIFE shal1 retain ownership of the 1989 Chevrolet Barretta and shal1 be solely responsible for any debt relating thereon, if any, '. 7,2) Dank..1l.ccuUlllS: Each party will opcn or has opencd their own hank account. Neither party will make a c1ajm against those funds. 7.3) Pensions: Both parties agree to release any interest they may have in the pension plans, 401(k), profit sharing or IRA accounts of the other, if any exist, and agree to execute any documents that may be required to confirm said release. 8) REAL ESTATE: The marital residence located at 401 Erford Road, Camp Hill, Pennsylvania, 17011 is a leased premises. At the termination of the lease the deposit shall be paid to the HUSBAND. 9. SPOUSAL SlJPPORT/AI.IMONY: Neither party will make a claim for spousal support and/or alimony. Spousal support will be paid per the current order until December 31, 1998. 10. The property seulement as provided herein between the parties shall be considered an equitable distribution of marital property and both parties waive any and all rights or claims which they may have been entitled to raise with respect to the issue of equitable distribution under the Provisions of the Pennsylvania Divorce Act. II, CUSTODY OF CHILD: (a) The HUSBAND and WIFE shall have joint legal custody of their son, Mark David Kibe. (b) WIFE shall have primary physical custody of the child and HUSBAND shall have temporary custody for purpose of visitation as follows: (i) As long as WIFE continues to live in Pennsylvania HUSBAND shall have visitation every Tuesday and Thursday evening from 5:00 P,M. until 9:00 P,M.. (ii) HUSBAND shall have vjsitation every other weekend from Friday at 5:00 P,M, to Sunday at 9:00 A,M.. (iii) Parties shall alternate the following holidays of Thanksgiving, New Years, Memorial Day, Fourth of July and Labor Day with the visitation beginning at 9:00 A,M. and concluding at 9:00 P,M.. HUSBAND shall begin the schedule by having the child Thanksgiving 1998. (iv) Christmas shall be shared with HUSBAND having the child from 5:00 P.M, on December 23rd to noon on Christmas Day; WIFE shall have child from noon on Christmas day to 9:00 P.M. the day after Chrjstmas in odd numbered years the times periods will reverse. (v) Should WIFE desire to move from Pennsylvania she must give HUSBAND thirty (30) days written notice. HUSBAND has no objection to WIFE moving to California. (vi) Should WIFE move such a distance from Pennsylvania to make the above schedule impractical then HUSBAND shall have the child for sixty (60) days each summer. He shall give four (4) weeks written notice of when the vacation is to begin, (vii) Every odd numbered year HUSBAND shall have the child for the Christmas vacation beginning December 23rd at noon and continuing to 5:00 P,M, on New Years Day, In even numbered years HUSBAND shall have the child from Wednesday at 5:00 P,M. to Sunday at 9:00 P,M, for the Thanksgiving vacation and for the Easter vacation beginning with the first vacation day and returning at 9:00 P.M. Easter Monday, (viii) HUSBAND shall pay the cost of transportation for the Thanksgiving, Christmas, and Easter vacations but cost of Transportation for the summer vacation shall be shared equally. Because of expense and scheduling, if HUSBAND is unable to make arrangements for any of these vacation he shall notify WIFE at least four (4) weeks prior to the holiday of his plans, I' ;. , ) i , I , l I 10, L ,'. i\ ~ (ix) HUSBAND shalllmve a lixed time for phone contact with his child being 10:00 p,m, Monday evening EST; 7:00 p,m. PST and at such other times as the parties may agree, (c) HUSBAND will pay the sum of $250.00 for the wife for the period from January 1999 through August 1999 for the supervisory care of the child, (d) Both parties shall refrain from making unkind, or derogatory remarks about the other to each other in the presence of the child and shall at all times avoid any confrontations that may upset the child. (e) INCOME TAX DEDUCTION: It is agreed that HUSBAND shall claim the child as a dependent for 1998, WIFE shall c1ajm the child in subsequent years unless other arrangements are made by the parties, (t) If the child seeks education beyond the hjgh school level HUSBAND agrees to contribute in so far as he is linancially able to do so with the understanding that child shall seek scholarship or other linancial aid for which he is eligible. 12, The parties agree that simultaneously with the signing of this Agreement they will sign the necessary aflidavits of consent and aflidavits acknowledging notice of marriage counseling in order to conclude the divorce action tiled by HUSBAND under the no, fault provisions of the Pennsylvania Divorce Act. 13. The waiver or unenforceability of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered to be a waiver of or forfeiture of right to enforce any other term, condition, clause or provision of this Agreement. 14, This Agreement shall be construed and interpreted according to the laws of the Commonwealth of Pennsylvania. r'\ WILLIAM J. KIBE, II, . IN THE COURT OF COMMON PLEAS . ss#176-62-8196 Plaintiff OF CUMBERLAND COUNTY, PENNA. VS. . NO. 98-539 Civil Term . . . Michelle L. Kibe, : CIVIL ACTION - LAW ss#556-81-5442 Defendant . . 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. (Strike out inapplicable section.) Sent 2. Date and manner of service of the complaint: Certified mail" Restricted D~li'!er~' February 3, 1998 and ',.,as 1s1i'lersd to the Derenctant on February 10, 199~ 3. (Complete either paragraph (a) or (b).) (a) Date of required by Section November 27, 1998 November 27, 1998 (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N i i', execution of the affidavit of consent 3301(c) of the Divorce Code: by plaintiff ; by defendant ; (2) Date of service of the plaintiff's affidavit upon the defendant; NIA 4. Related claims pending: All claims are settled and satisfied by Marriage Settle~ent Agreement dated November ~7. 19~8 s~qned by both Pla~ntlff and Defendant 5. Date file praecipe the decree is Divorce Code. and manner of service of the notice of intention to to transmit record, a copy of which is attached, if to be entered under section 3301(d)(1)(i) of the NIA 6. Date file praecipe the decree is Code Ni A of Notice of and manner of service of the notice of intention to to transmit record, a copy of which is attached, if to be entered under section 3301(c) of the Divorce , or, date of execution of waiver Intent P-November 27. 1998. D-November 27, 1998 and date of filing of waiver ,1998. D - December 9.,. 1998. yF' ;i~ _ a.) J ne M. Al ander ~jittorneY fr Plaintiff/toot~~ P - December !"""'\ \' L:; c' I C j.':: .:.....~ ~~ I.' I ,.....: - " C' () -' i-I.': --., -> ", C; r: ~ Cl ~,~~ , " " c\ U, i .'; 1.1.1 I I --, , c.~ - f.l:': i I.'j : , L, n~ c; '.1_ 0~J - , Cl c; . 1':\ WILLIAM J. KIBE, II, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY', PA : VS. : IN DIVORCE : MICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant . NO. qp-!::19 Ci<.'t'( 'tfn.~ . 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 of property or other rights important to you, including custOdy or visitation of your children. When the ground for the divorce is indignities or irretriev- able breakdown of the marriage, you may request marriage counsel- ing. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPER- TY, 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 COUNTY BAR ASSOCIATION 2 LIBERl'Y AVENUE CARLISLE, PA 17013 717-249-3166 WILLIAM J. KIBE, II, : IN THE COURT OF COMMON PLEAS 0: I , Plaintiff : OF CUMBERLAND COUNTY, PA ..... : VS. : IN DIVORCE MICHELLE L. KIBE, : CIVIL ACTION - LAW ! Defendant . NO. . I , I NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion reclamados por el demandant. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court house, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, US TED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. US TED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOICATION 2 LIBERTY AVENUE CARLISLE, PA 717-249-3166 WILLIAM J. KIBE, II : IN THE COURT OF COMMON PLEAS plaintiff : OF CUMBERIJ\ND COUNTY, PENNA. : NO. 9P- SJ9 Ciutl'tf f2..~ VS. : : MICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301 (e) OF THE DIVORCE CODE /" /1, /11 COUNT I AND NOW, this ~Iday of January, 1998, comes the Plaintiff, William J. Kibe, II, by his attorney, Jane M. Alexander, Esquire and files this Complaint upon a cause of action of which the following is a statement. I. Plaintiff is William J. Kibe, II, 28 years of age, who currently resides at 59 W. Vine Street, Shiremanstown, PA 17011 (Borough of Shiremanstown, County of Cumberland). 2. Defendant is Michelle L. Kibe, 27 years of age, who currently resides at 401 Erford Road, Camp Hill, PA 17011, (County of Cumberland). 3. Plaintiff and Defendant have both resided in the commonwealth of Pennsylvania for at least six (6) months prior to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on August 24, 1990, in Las Vegas, Nevada. 5. There was one (1) child born to the parties during this marriage, Mark David Kibc, born, February 23, 1994, age four (4) years old. 6. There has been no prior action in divorce by either party. 7. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. While the parties were domiciled within the commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indigni- ties to the person of the Plaintiff as to render his condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT II 9. The allegations of Paragraph one (1) through eight (8) are incorporated herein by reference and made a part hereof. 10. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT III II. The allegations of Paragraph one (1) through eight (8) and Paragraphs nine (9) and ten (10) are incorporated heroin by reference and made a part hereof. 12. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem equitable and just. Respectfully Submitted, .. . ~ ILLIAM J. KIBE, II. , : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA. : VS. : NO. 98-539 CIVIL TERM : ICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ~iay of February, 1998 personally appeared ane M. Alexander, Esquire, who swears according to law, that a rue and correct copy of a COMPLAINT IN DIVORCE was caused to be erved by certified mail with return receipt requested upon the aid, Mrs. Michelle L. Kibe 401 Erford Road Camp Hill, PA 17011 n February J. 1998 by leaving the same at the Di11sburg Post ffice with postage pre-paid thereon as evidenced by the mailing and return receipt hereto attached and made a part dJ Notarial Seal Halvard E. Alexander. Notary Public Dlllaburg 80ro, York County My Commlssron Expires April 23. 2001 1m ar, ennsylvanla Assoclallon 01 NOlarles .\ .. ILLIAM J. KIBE, II. , : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA. : VS. : NO. 98-539 CIVIL TERM : ICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant : IN DIVORCE PROOF OF SERVICE ... . -8 .Complel.lt~ml1 an<UOf 2 for additional aeMce'. Ii _Compfete Ittms3. 4a. and 4b. I .Print your name and Iddrnl on thl revert. 01 INt form 10 thai we ean relum thl, card 10 you, tAttach tN_ form 10 the front 01 the mal1p1lce. or on the back It 'Plce do.. not .=~.rLlm R.c.Ipf RtJqlJNtecr on the mailplece below the a,,1de number. 'The A'llm Rtcelpt Md show to.mom the ertlde WI' deHv_red and the dall doIlver8d, II ~ Ii ~-m:~:;l~~U~ JlJibL ~ l-JDI 8)f.cJ)d ~ , ~p Nt}J I PH J70J) ,'k y: (Pifnt Name) )( Certlfted ~ >0 .!! Domest c Return Receipt -" Q.Cl ~ ._'1:1"' Q) .- <<;; u ~:: Q)a:~ a:: Cl,g "'- ~ ~ -II :=....c: ns QJ Qj ru ~ ~c ru u- ~- -0 CD 0 III u- '" ...J m Q.l C III ... 0 LtJ :; e ~ ~ ~ ~ ..,J ,- " "" 1:: :go<< u ~~-..J ~ Q)_CI\) _ - ~ .-'I 00 Cl ~ u::::z: ~ ru ~f . ,\\ , ~ ~ ~ -II j: ~ ~ al V1 Z . 2i Q .., ..,_Ill ~ a. 1, 2 Q( - 0;;; E' ~ ~ , ~ !I ~::i: b- ~ ~ ~ . l i: . u . WILLIAM J. KIBE, II, . IN THE COURT OF COMMON PLEAS . 'I Pldintiff : OF CUMBERLAND COUNTY, PENNA. : ,I VS. NO. 98-539 civil Term : MICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE S3301(c) 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 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. --:1/" Date:/I/?/-'-?7 ;ljpt I .~ "':n,\'~h~ ~J ~{l.l1.~ Michelle L. Kibe, Plaintiff , ILLIAM J. KIBE, II, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA. : VS. : NO. 98-539 Civil Term : ICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant IN DIVORCE .AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the ivorce Code wan filed on January 30, 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the ecree. 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. 2;' DATE:,. ~,v? ~ /f'yp '-~JJ \\~ ~~;K\~ MLC elle L. Kibe, Plaintiff ,- - .-..... - ILLIAM J. KIBE, II, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA. VS. : NO. 98-539 Civil Term : MICHELLE L. KIBE, CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE S330l(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce ithout 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 to authorities. Date: il/'nhF , . Plaintiff ILLIAM J. KIBE, II, IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA. : VS. : NO. 98-539 Civil Term : ICHELLE L. KIBE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 30, 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. ~4904 relating to unsworn falsification to authorities. DATE: 11/..l7htP I , ((),.tL.. U K:'./" SZ;;:.. 14illia;P"J. I<ibe, II, Plaintiff