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Home My WebLink About98-00795 r- _\ .., .~ ::::: . .. ~ i ~1 , "', \ .~ ...... "- , .. .~ ~ / ~ ... ~ - . .. .:) ~ ~ ~ 1:'-. . ~ ci ~ . . , . . . " .--------------------~~--------~ .. ..._--,-----~- --'-'.-.,. . ~ ~ -. ~ ~ y ~ ,. ,', ~ ~ ~.' ,', ~ IN THE COURT OF COMMON PLEAS ~ ~.' M ,'. ~.~ ~ ~.. ~ Alle.l: {itizt,~~>vllq.b~a.n..i::~~dd... J. * ~ v ~ ~ ~'d~..tn<< .~.~4, ~d .dd'd.. ; ;(. ,/" Prothonotary y ~ ~ ~ ~ ~ - -------_..__.._--._---~._--_..~. ~ ------------------------------ w ~.' ,.; ~ ~ ',' OF CUMBERLAND tv.~1':\" ~!9:'. -' .~~k.:.-'r":, I, "~~'r COUNTY ,', ~ ;', ~ ~ ',' STATE OF PENNA. ,', ~ w ~.~ ~', ~ ~ ',' LIIfWOOD.I3~..PHILLIPS, II I Plaintiff 'I :1 ........-..... !I , , NIl. ...98:::795........ ................. V(l)'SllS MARIE B. PHILLIPS, *- y ~', ~ .j: W '.' Defendant w ~.' DECREE IN DIVORCE ~(1:30,4,W1, AND NOW, ' .. , ..:;:r.~ J,t?.. ,.. .. " 19 ,~<t... it is ordered and decreed that...., .. ~!~??~,~:, ~~!~~!~?!.!!.., .. .. .. .... ....... plaintiff, and, . . " , , , , " , , , , , ,~A.~I,E, ,B.., ,~H,I,I:I:I,~S, ,. , . . , , . . . . , , , , " , . , , . '. defendant, are divorced from the bonds of matrimony. ~ ~.' ,.; ~ ~ to; ~ ~.~ i .. " i ;.~ ~ ~ y ~ ~.~ ~ ~ ~.' ,'. ~ w ~.~ 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; pJ ~ .... ....., .... ...... ......., .... .....,.,., ..,. ..... ........ .... '" ........, Dy The '" .....,...,...... '" ... '" .... ..... ............. ...... ~ ,;> ~ ',' *- ',' * ',' ~ '.~ ~ '.' ~ ~.~ *- ~.' ~ '.' a ... ~ '.' w ~.' a '.' ~ ~.' *- f:; *- ;:~ ~ ;.; *- ~.' ~.~ ~ ~ '. f.' *- ~.~ ;.~ ~ ~ ~.; ,'. ~ *- ~.~ ,', ~ *- ',' ,', ~ ~ a ... ~ '.' ,', ~ ,'. ~ ':'.11.* ti;;/. '"1'/ :';~""~ 4/4~. ~ / /.9f 7l':<<~( /1'/:'.$ -# .::y. . , , , , ~ fl\div\.grmt.ord , LINWOOD B, PHILLIPS, 111;. : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : v. . NO. 98-795 CIVIL . . . MARIE B. PHILLIPS, CIVIL ACTION - DIVORCE Defendant AND HOW, this 16~ day ORDER Of_~ -/... :[[1: et......-r"" . . du-.......- lr"-C~ .~ u...... 5. ~ (,./9- ,. ,- ~ oIL, . ~ q....,-~ --'- property settlement Agreement between the parties dated June 1, 1998, - .-,", " --~,-""'- and attached hereto is hereby incorporated into the Decree in Divorce. J. . 11\aqm\phl11lpa.lln\S-'. . AGRBEMENT / -1/__. THIS AGREEMENT, made this /sr day of ~ , 1998, by and between MARIE B. PHILLIPS, of Cumberland County, Pennsylvania, (hereinafter referred to as "Wife"), and LINWOOD B. PHILLIPS, III, of Cumberland County, Pennsylvania, {hereinafter referred to as "Hus- band") 1 WIT N B S S B T H: WHEREAS, Husband and Wife were lawfully married on August 8, 1986, and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property 1 the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife1 and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. -1- NOW THEREFORE, in consideration of the premises and of 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, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. Disclosure of Assets. Each party asserts that he or she has made a full and fair disclosure of all of the real and personal property of any nature whatsoever belonging in any way to each of them of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each party, and of every other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. Preparation of Aqreement. This agreement has been prepared by the attorney for the Husband. Said attorney at the commencement of, and at all stages during, the negotiation of this agreement informed the wife that he has acted solely as counsel for the Husband and has not advised or represented the wife in any manner whatsoever. The Wife at the commencement of, and at all stages during, the negotiation of this agreement has been told by said attorney that the wife should be represented by his own counsel, but at all times he has refused to do so. The Wife has read this agree- ment carefully and thoroughly, fully understands each of its provi- sions, and therefore signs it freely and voluntarily. -2- ... 3. Lawfulness of Separa~ion. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 4. Freedom from In~erference. Each party shall be free from interference, authority, and 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. 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 exis- tence, separate and apart from the other. 5. Release of Claims. Wife and Husband each do hereby mutually remise, release, quit-claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower -3- l' or curtesy of 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 (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation ! " J: , , or otherwise, 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 thereof. It is the intention of Wife and Husband to give to each other by the execution of this agreement a full, complete and general release with respect to any and l I , I j , . 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 thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. } I l, 'f :;1< I' ,''ill ~"~ \('."~: . .J' !;;;:: (' h'.~ 'rf~~: , .>':-". ...~ l-~~'~ ~.,' " .~~ ,', ..: 6. Warrantv as to Future Obliqations. Each party repre- sents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable, and that except only for the rights arising out of this -4- agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold the other party harmless from and against all future obligations of every kind incurred by them, including those for necessities. 7. AssumDtion of Liabilities. Paragraphs Band 9 below set forth the method for the payment and assumption of the debts and liabilities of the parties. Since the assumption is not binding on the creditor, the party assuming the debt agrees to indemnify the other party in the event the creditor seeks to hold such other party liable. Should the parties wish to bind the creditor and relieve the original debts from all liability, a novation should be executed. B. AssumDtion of Debts. Husband assumes and agrees to pay and hold the Wife harmless against the following debts and obliga- tions: (A) Husband shall assume responsibility for payment of all taxes, past and present, federal, state and local, in his name individually as well as those taxes related to the Lin-Mar Landscaping business operated during the marriage by Husband and Wife. (B) Husband shall Rssume full responsibility for payment of all sums due under the note dated September 25, 1992, wherein Husband and Wife are collectively referred to as maker and Ronald E. B~inhaur and Yvonne M. Beinhaur are listed as payee. (e) Husband shall assume responsibility for any and all debts associated with the landscaping business operated during the marriage by Husband and Wife and known as Lin-Mar Landscaping. -5- (D) Husband shall assume responsibility for p~ment of the Sears charge card, account number C::)':;;~/d1;).'-/.)e:.-Yl.S ./IJ~ If any claim, action or proceeding is hereafter brought seeking to hold the Wife liable on account of such debts or obligations, the Husband will, at his sole expense, defend the Wife against any such claim, action or proceeding, whether or not well founded, and Husband will indemnify and hold Wife harmless from and against such claim, action or proceeding. 9. Assumption of Debts. Wife assumes and agrees to pay and hold the Husband harmless against the following debts and obligations: any and all credit cards in her name and any and all debts incurred in her individual name. If any claim, action or proceeding is hereafter brought seeking to hold the Husband liable on account of such debts or obligations, the Wife will, at her sole expense, defend the Husband against any such claim, action or proceeding, whether or not well founded, and Wife will indemnify and hold Husband harmless from and against such claim, action or proceeding. 10. Personal Propertv. Wife and Husband do hereby acknowl- edge that they have heretofore divided the marital property including, but without limitation, jewelry, clothes, furniture and other person- alty and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Hus- band; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon -6- ... whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. 11. Cash. All cash presently in the possession of either party shall be and remain their separate property, free and clear of any claim whatsoever on the part of the other. 12. Automobile to Husband. The Husband shall be the sole owner, free and clear from any claim on the part of the Wife, of the 1987 Chevrolet Truck. Wife shall deliver executed certificate of title, sales and use tax form and any other documents necessary to convey title within ten days of the execution of this agreement. 13. Automobile to Wife. The Wife shall be the sole owner, free and clear from any claim on the part of the Husband, of the 1993 Ford Explorer which is titled in Wife's name individually. 14. LandscaDino Business. Wife hereby relinquishes and assigns to Husband any and all right, title and interest which she may have in the Lin-Mar Landscaping business. 15. ProDertv Not Provided For. The parties hereto agree that they have, by the terms of this agreement, settled, to their mutual satisfaction, all rights that either may have in their proper- ty, whether owned by them jointly or separately, real and personal, and wheresoever situated. Any property not specifically provided for in this agreement, which the Husband or Wife owns or has the right to control or possess, shall be and remain his or her property, free and clear from any claim on the part of the other. -7- " ~ IJ' 16. Real Estate. Wife hereby agrees to convey, transfer and grant to Husband all of her right, title and interest in a life estate in the real estate situated and located at 153D Centerville Road, Newville, Cumberland County, Pennsylvania. Wife agrees to execute a deed of conveyance conveying all of her life estate interest in the aforesaid premises to Husband. Husband and Wife agree that the remaindermen for said property shall remain the same. From the date of this agreement, Husband agrees to assume as his sole obligation any and all mortgage payments, taxes, claims, damages or other expenses incurred in connection with said premises, and Husband agrees and covenants to hold Wife harmless from any such liability or obligation. 17. Waiver of Alimonv. The parties herein acknowledge that by this agreement they have each respectively secured and maintained a substantial and adequate fund with which to provide themselves suffi- cient financial resources to provide for their comfort, maintenance and support in the station of life in which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, support, alimony pendente lite or maintenance. It shall be from the date of this agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. lB. Payment of Attornev Fees. Each party of this agreement hereby agrees that each of them will be solely responsible for the full payment of all attorney's fees and other costs heretofore and hereafter incurred, respectively, by each of them in connection with -B- , . the negotiation, preparation, and execution of this agreement, and in connection with any action commenced by either party with respect to the divorce of the parties. Each party further agrees hereby to indemnify and hold the other party harmless from any demand, claim, loss, cost and expense (including additional attorney's fees) arising from a failure to pay all of the aforesaid attorney's fees and other costs. 19. Informed and Voluntarv Execution. Each party to this agreement acknowledges and declares that he or she, respectively: a. Is fully and completely informed as to the facts relating to the subject matter of this agreement and as to the rights and liabilities of both parties. b. Enters into this agreement voluntarily after receiving the advice of independent counsel, free from fraud, undue influence, coercion or duress of any kind. c. Has given careful and mature thought to the making of this agreement. d. Has carefully read each provision of this agree- ment. e. Fully and completely understands each provision of this agreement. 20. Headinas. The headings or captions preceding the paragraphs in this agreement are inserted for convenience of reference only and shall not be construed in interpreting this agreement. -9- . .' 21. Mutual CooDsration. The Husband and the Wife shall each concurrently herewith, or at any time hereafter on the demand of the other, execute any other documents or instruments, and do or cause to be done any other acts and things as may be necessary or convenient to carry out the intents and purposes of this agreement. Further, Husband and Wife agree to execute such documents as are necessary to have a no-fault divorce decree entered in the Court of Common Pleas of l . , Cumberland County, Pennsylvania, as soon as legally possible. 22. Ssverabilitv. If any provision in this agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired in invalidated in any way. 23. Reconciliation. If there should be a reconciliation of ~ , I the parties after the date of execution of this agreement, this agreement shall nevertheless continue in full force until it is modified or abrogated by another written instrument to that effect signed by each of the parties hereto. 24. Future Earninqs. All income, earnings or other property received or acquired by either party to this agreement on or after the date of execution of this agreement shall be the sole and separate property of the receiving or acquiring party. Each party, as of the effective date of this agreement, does hereby and forever waive, release and relinquish all right, title and interest in all j ~ t' ",' "".j ~~ ~ I ~. i I . -10- such income, earnings or other property so received or acquired by the other. 25. Waiver of Riqhts. Each of the parties hereby irrevoca- bly waive all rights which he or she may have to request any court to equitably distribute the marital property of the parties or to have alimony, alimony pendente lite or counsel fees awarded to either party, it being the express intention of the parties hereto to fully settle all claims which they have with respect to each other in this agreement. Each of the parties further agree to consent to the entry of a Decree in Divorce. 26. Waiver of Breach. The waiver of any term, condition, clause or provision of this agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this agreement. 27. Survival of Aqreement. If any term, condition, clause or provision of this agreement shall, by its reasonable interpreta- tion, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the parties hereto, said term or terms, condition or conditions, clause or clauses, provision or provisions, shall be so construed, being the express intention of both parties hereto to have this agreement govern their relationship now or hereafter, irrespective of their marital status. 28. Jurisdiction. This agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and both parties consent and agree to the jurisdiction of the Court of Common Pleas of Cumber- -11- . - . , '. , , /'. ;,:";j /t\;t r', 1":1 \" ~,: (', ! \ :, J I"'j " .;' . " 'r> ,- ~ ,. 'I.', C, .\. . :{i or: (') LD 0 c:: CO ,., ~. r_ =ji I)e.... c:: niflJ nO'ill :.:: ..~ -i J I -.~ ~~,: .. ')~ ~:J ('.', . i:J, ....~ ". i;:;CJ -<.' .~ ,... ~~ ~() =.: ,,, ( ) '!? (5ii1 >f.:';; ;1 :;''j ~...., ~ -. ..... -< i , ., fl\div\ltrnlm1t.pcp\7M97 LINWOOD B. PHILLIPS, I~ Social Security No. 208-38-6559 Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 98-795 CIVIL MARIE B. PHILLIPS, Social Security No. 204-46-9894 Defendant ACTION 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 S (330l(c)) (330l(d)(I)) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint:Februarv 13. 1998. Certified Mail. Restricted Deliverv. Postaqe Prepaid . 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by Plaintiff June 1, 1998 ; by Defendant June 1, 1998 . (b) (1) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: . , (2) A. Date of filing of Plaintif.f's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: . 4. Related claims pending: NO CLAIMS RAISED . 5. Complete either (a) or (b): (a) Date and manner of service of the notice ot intention to file praecipe to transmit record, a copy of which is attached: . (b) Date Plaintiff's Waiver of Nqtice in with the Prothonotary: Jr~ 8, Iqy~ , S 3301(c) Divorce was filed . Date Defendant's with the Prothonotary: waiversof Notice in S 3301(c) Divorce was filed Jl....V'I<. (y~8 . '~ . Attorney ~~BIl!t!.l) Supreme Court No. 40486 ( ,'I ,~ )1 , '. '. .... (') aLl ~ !=: co gJi!:: t- o, ::;J 101 c= _:1) :2; m:n G.r- I ~~ (/111- c:> ~... . ?.~, n ...~C., '-=1 ~" :I.... :Cj3 ....;n :I: ~~ q~ If? '~I Z ~ =< c:- ~ :.0 -< jj :\ , ! I j t I r n ,1(".." I' ,)::',~ 'j .. I i. j , .~ l!.l,; . , . . :Ii~.1+';:'t,-:" ~.;~;j~/},~t~.e'!~ -);:1~1i'i!;;~~(ol"!';~-i~~ii~~~.~_t;_~~:/'@.' ,~.~"t~:r~~~,1<.l'~~,_S.,"<;"~. ':':-:~~" ~',(~",:~' "J,', ~. ;::~..'iJ'fl".<:Yli l!$t:;I'!I;,::i!i:'f?':f!!'i\~~! ' l :.r. ''''1'' ti',r.'Ii:i/l...rn.'if.rt\,;.;:l;(l",r.1:....',...r":ib:-Ei\..~.. ..~'? ,i . :trm :~~ :ff''tl~\~,\.1:;,/.t{!'';~''';';Y~STONB~MR-&''~AvBR"a;~. 0 ~~; lJl- ~~r}iy~,I'~~;'.~...~: :....p ~ '~..,;.~'...\k;/~::"~"'-I:'':.;..,',I''.ld' <~t""'1 "'" if;/, .l(-4J tl"~ ~'J~~h\l!,;,.".,~~..,.J-. "';'''''f'ti'':'!A:' EYe'AT;. :j!;'. 1f~~r."'\~';'-~.~'l'~~".l,I;"\,,, 'Sf1(N{:'I~q.^~",~. ";J)~:l"~""'J,,,,.,,,..a;~1. "" " ~t.._~ IV;'1 ~" r1!ll.J"tf*"''1~\.'''~('" ,-,,'1.f:;t4'~"loal:~.:T1'lEft '~~"'; '.: ~~t'H",,q:~;jo.~'t~~JM:~:~i:;. ;,(~1"'!"~'~\t.: ,. .....:......:;:,:; t .....,.;;~iJi1.~l.'h1~ ~. "',\ '\h ..f..',. ":'..' l;Jfl:.ft;"" '~l.t~"'N'8W~OUICDBlUoAftu',PA~' gJ ~ ~ ,~,,.; ~\~t~i:;r.~ftir{l:ws.U~,;~~~;,~,,-:t4~\~~t-;'M\:.\otIJ,~~Jti:t:;~~n.~. LINWOOD B. PHILLIPS, III, Plaintiff IN THE COURT OF COMMON PLRAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98 1q5 CIVIL TERM MARIE B. PHILLIPS, Defendant CIVIL ACTION - LAW 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 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 the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. IN 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 Countv Bar Association 2 Libertv Avenue Carlisle, PA 17013 Telephone: 1717\ 249-3166 fl\div\phl11ip..lin\2-98 LINWOOD B. PHILLIPS, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. q ~ - 7 q S MARIE B. PHILLIPS, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is Linwood B. Phillips, III, an adult individual, who currently resides at 1530 Centervil1e Road, Newville, Cumberland County, Pennsylvania, 17241. 2. The Defendant in this action is Marie B. Phillips, an adult individual, who currently resides at 1422 Bradley Drive, Apt. C-211, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on August 8, 1986, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the mar~iage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. -1- I. :1 i '. ~I fl\dlv\con..nt..ff " . LINWOOD B. PHILIPS, I~ Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-795 CIVIL MARIE B. PHILLIPS, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on February 10, 1998. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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 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. S 4904 relating to unsworn falsifica- tion to authorities. ell/1'6 ~~~Q..~~ LINWOOD B. PHILLIPS, II, Plaintiff Date 1 ~ \D 0 OJ -n ""- r- 7jl ~';.p C nlt\1 Z hi:n z:n I .,hi 7-\- :~'? CJ ,~: c" .<' \_.~ c.:> ~('.J ::>- 7i:~11 - -:!J ?~8 :J!: .;~,) \!? .__rn ><- SOl ?j -~ l:"" ?:1 -, t::l '-< s ) i , I j ( !( I V IS j 1'-' '1" , .,'j n:; 'I.. /:r I' f: I ". ~!. " .. fl\div\con..nt.aff " . LINWOOD B. PHILIPS, lIt Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-795 CIVIL v. MARIE B. PHILLIPS, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 330l(c) of the Divorce Code was filed on February 10, 1998. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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 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. S 4904 relating to unsworn falsifica- tion to authorities. {L... /, 10;'18 Date (f/ft/JU..,. ~~f5Q.MI.(~ MARIE B. PHILLIPS, Defendant . \ , I , ! \ . 'I i I . I " .:.:." , ."' (') .0 0 C OJ ~ "r1 .,,- L- 'i'! n".{jJ r::: zQ) ~ j-Ji:n 2'('-:'" I r- U) ~" 'tJIT1 ~~" CO .~uO ,.-l.:; '-'6 ~c' :tb :i'!jj ".. , -,.. 1.-)- ~o -. $c: 't? ';';y 0' :2 .:.,:1 =< c- ~ c:> fl\div\l-walve.not .. . \1 .. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-795 CIVIL " , , ,) I I LINWOOD B. PHILLIPS, 11+ Plaintiff MARIE B. PHILLIPS, Defendant CIVIL ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S 3301(0) OF THE DIVORCE CODE , 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them \ , I 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 j , to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsifica- tion to authorities. ~y~~. ~~ LINWOOD B. PHILLIPS, II, ~aintiff , \ ~ r .( , . Date: (pi /1' 8" , 1 ~. (") 1.0 (") C CO -., -- .~ '- :;!-n -0[-11 <= ~cr: :J.: 111- ~_..o :8~ ::?:c. I Uj.> <XI _. ,-.1, '.J :, r-C ;-'1' .". :1:'.. ;1.33 Jt;o ::r: 5:; C:a ':)0 .....9 ('3rrl S -I ~ ~ -. 'D 0 ::.: fl\div\l-waiv..nat .. . LINWOOD B. PHILLIPS, I~ IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 98-795 CIVIL . . MARIE B. PHILLIPS, . CIVIL ACTION IN DIVORCE . Defendant WAIVER OF NO~ICE OF IN~EN~ION ~O REQUES~ EN~RY OF DIVORCE DECREE UNDER S 3301(c) OF ~HE 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, la'iYer'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. S 49D4 relating to unsworn falsifica- tion to authorities. ~ ~ /!J cpuei~ MARIE B. PHILLIPS, Defendant Date:-1'II/Ir I. ,Q9B ~~, \ 'f .~ . , ) ~ . I I f, I I . I~ I' 'I . \ , I i ! . ~ , I t, .'., r~ j;,'1 Ii;: r (J ~! , . "i, n 0.0 0 I: c: CO 'n .~ c._ :.~J I.: ... ,JO') c:: -::n 92~H z "'~ -~- I ,J "'. CO -J ~j:: 6 i:1l:' =r!~ :.:: .- :Do ~; C') ::JC Cl~ -~ :;;0 'R <:5 c -, -.... .,.. ;1> ::;i C;:) ~ -, '...., -I' , I '.n. ;" ,i.' " y .,l~i .'.' ',' ";i";: , .~ l:,) f' i" J::, ';- ~~', ..... , " ~ ". o r; 4] t;~~ ~-::I! . ~ .~" r-: . .--..-.... -,'" ~.:; (-~ j:'~}~ '-'j -. " ..0 ::J:J ."'1 '.'1 :.;;) 10,;> ''::> o ~q 'lJ ~l'l:n ,-- 'n(;' "'9 :,!6 "'It:!] ~,1?5 oi'n --, ;> ;D -:; 5: ~) CJ1 I ! i I I I ~, ,'- .. ~ - ...... .. " -. . (") ,0 0 c ~ -n ......~~. ~, --J ..". rl"l : 1.:oJ L~) L~ , .:;;, ..1,.- :.:~ f' N ""'!) ~" J.... lJ:,o, 0 "6 r~'~ L-, -. .7':, i ~;:r] ~;'; c' 5~ :h~r) :~: r~ - (ji'n ~ .. --, ( ::'! :..) " :Xl l Ul -< 7 . I ...""'?' =-, ....--.....-