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Home My WebLink About98-00797 " , .t '" :> ~ '.( ~ , ~i ~ ' . ' ... ~ Q -...{ t' , ... \~ :--. ~ .::) \S ~ ~.~ ~ ',' ,: ~ ~'; w ~.; .', ,', ~ ;.; ~ ,'. ~ w t'; ~ ~ ~.~ ~ ~.I ~ ~;. ~ w ~.~ .:...;.' .:+:.' ':4'.' .:+:.' .:+:.' .:.:. .:+:. .:+:. .:.:. .:+;. .:+:..:+:. .:+:. .:+:. .:.:. .:+:. .:.:.' .:+:. .:+:- .:+:. :":':+:':>:+;,:;,:+;,:~,:.;.".:+;., .:+:.' ':+:":.:'~~':.:'~:-;<4' '. .-....-....-..._.--------......--.-....-.-_.---_....,~- ....--~ .' ~ ~ y ~ ^ ^ ~ ~ ~ ^ ;:: IN THE COURT OF COMMON PLEAS ~ ~ ~ w ~.' ~ :.~ OF CUMBERLAND COUNTY 1~~~ .\.",.~~.#-....t .'~ * ,', ~ ,'. ~ .'~ ~ ,', ~ ;.~ ~ ~ ~.I ..; ~ ~ ~.~ ~ '.' ~ ~.' ;', ~ ,', .'~ ~ .'~ ~ ~ ~ ~.~ STATE OF PENNA. ..,Dexter..,R ,..,Loving. Plainq ff ....... II N (), ....~J!,"',....,..,.. 7,9.7........., 1998 d .".. !I VeJ'.>.:lis $ ~ ~ ... l, ~ ~.' :1 ..... .......... il 'I II .,l)e!)c:>:r:al1..M,..Loying. ,D,efe,ndant ~ ~.~ ,', ~ ~ (.~ ~ ~.~ ,', ~ " ~ ',' DECREE IN DIVORCE AND NOW, ....~,~....U....,' 19~,'1" it is ordered and decreed that", " ,,~~l,(t~.J:; '~'" .~9Y~.l19, , . ,... '" , '." " ,., " " plaintiff, and, , , . . , , P~I;>l?:r,<1i}, \'I", ,1;o9)1,i.'19., , , . , , . , , , , , , , , , , , , , , , , . , , , '. defendant, are divorced from the bonds of matrimony, ,', ~ $ ~ ~.~ ~ ~.: ~ :.; ~ ~.' The court retains jurisdiction of the following claims which have been raised of rr~ord in this action for which a final order has not yet been entered; WO~ ,', ~ ~ ~.' ,', ~ , .r:t;, ~,s, .~1,1F.t,I1E?F, ,qI;9~:r,~q. !=)1,<11;, j:)1.~ . t!=.r.l1)!?, 9,1; ,t!1~. ,'ltj:p,c;i)~p, .Q<;!~~,Il]Q<;!F 24 I ,,1,~~~,I, .r:1<:i:r,i,t;'!-~,~E!t.:t,l,~I1)~!l,t. .~9:r~,~I1)~!1,t, ,C!-F~, MF~qy): .l1C;9FP,qI;<:i!=~,q I, ,!mt not merged into this final decree. ' /~ ~~. ~ ',' ~ ... ~ ~-: ,', ~ ~ r-~ ~ ,,~ W :.~ ~ ?, <: ~ ~ ~ /.;t;.,-:,:-.o:.;. .=+;. .:.:. . $ ~ ',' ~ * Dy The ~ * .... ..... AlIesl: J, ~ '.' $ Prothonotary * --'--~-~--'~--'--~- .,-- ....-,.-.... '--..------. .........~......~ .......---~....~,. ..~_ ~ _,._,...,_~ ~ ,--..._,..,. _ i ~ ..' .:.:. .:+;. .:+;. .:+:. .:+;. .:.;. .:+:. .:.;. -:+;. .:+;. .:.;. .:.:. .:+;. .:+;. .:~:. .:+;. .:.:. .:+:. .:.;. .:+:. .:+:.' '. " MARITAL SETTLEMENT AGBE.EMEtll THIS AGREEMENT, made this .N day of JprP",1~r(', 19~, by and between Dexter R. Loving, hereinafter called "Husband", and Deborah M. Loving, hereinafter called "Wife", WHEREAS, Husband and Wife were lawfully married on April 12, 1990, In Cumberland County, Pennsylvania, and were separated In August, 1997; WHEREAS, differences have arisen between the parties and It Is the Intenllon of Wife and Husband to live sepprate and apart, and the parties hereto desire to settle 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 equllable distribution of real and personal property; 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 Wife; and In general, the settling of any and all claims and possible claims by one against the other or against their respective estates, 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.. SEPARATION AND NON INTERFERENCE: It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. The foregoing provision 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. Each party shall be free from Interference, authority and control 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 or attempt to endeavor to molest the other, or In any way harass or malign the other, nor In any other way Interfere with the peaceful existence, Lovlhg Agtccmcht,w~~ . '. separate and apart from the other, Neither party shall say or do anything to negatively Influence or alienate the minor child from the other parent. 2.. RECONCILIATION: This Agreement shall not be deemed to have been waived, extinguished, discharged, terminated, Invalidated or otherwise affected by a reconclllallon between the parties hereto, cohabltallon between the parties, a living-together or resumpllon of marital relations between them, They shall not be deemed to have reconciled with the Intention of vltlallng or termlnallng this Agreement unless they make such actions through a written Instrument, executed and acknowledged In the same manner as this Agreement. a.. ENFORCEMENT: The parties acknowledge that Husband flied to Cumberland County Court of Common Pleas, Cumberland County, Pennsylvania, Docket Number 98.797, a no-fault divorce action pursuant to Title 23, section 3301 (cl of the Pennsylvania Divorce Code and amendments thereto. It Is specifically understood and agreed by the parties that the provisions of this agreement relating to equitable distribution of property and all other matters contained herein, including but not limited to support, alimony, alimony pendente Iile, counsel fees, costs and/or expenses are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Upon execution of this agreement, the parties agree to execute their respective Affidavit of Consent and Waiver of Notice and proceed with entering same to said docket for the purpose of finalizing the divorce action. Each party shall execute any and all documents which may require his or her signature for the purpose of effectuating all of the terms and conditions of this Agreement so as to give full force and effect to this Agreement. Should a decree, judgment or order of separallon or divorce be obtained by either of the parties In this or any other st~te, country,or jurisdlcllon, 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 LovIng Aglccmcnt,w~~ 2 separallon or divorce; and Ihat nothing In any such decree, JUdgment, order or funher mOdlflcallon or revision IhereOf shall aller, amend or vary any lerm of this Agreemenl. II Is specifically agreed, however, that a copy of this Agreement or Ihe substance of Ihe provisions Ihereof, may be Incorporated by reference Inlo any divorce, JUdgment or decree, This Incorporallon, however, shall not be regarded as a merger, 11 being the specfffc Intenl of the panles to permit this Agreement to survive any JUdgment and to be forever binding and conclusive upon the panles. L :'J"::p~:,'~USA" 'UPPOR"A< '"ONy"..."o." P'.OF." ""F. CO,,, HUsband and Wife hereby acknowledge that Ihey have been advised that each may h,,, 'h, righ' " """ , ."01 r" "'"'" "'PI''''. '''01''',. '''moo, "'""'.,, III.. ,". '"di" expenses. Funher, HUsband and Wife aCknoWledge thaI they understand that said rights are available In the divorce acllon. HUsband and Wife funher aCknoWledge that they are aware of 'h. '''00''. ""00"'". '"~m. po'''''''. ,"d ,~. ,"d ""."" "'h, "h" " h". h'd '"" and ample OPPOr1unlty to become familiar with SUch Items. Nevenheless, HUsband and Wife aCknowledge that they are able to suppon and main lain themselves ComfOr1ably, without '''''''''., "'01 'h. oIh" b.,,,,,, 'h" " proWd.d r" " 'h. P",""", S""'m.", A'''.m.''. upon the Income and assels oWned by each of them. Husband and Wife hereby accepl the mutual covenants and terms of this Agreement and the beneffls and prOper1les passed to them hereunder In lieu of any and all funher rights 10 sUppon or alimony for Ihemselves, COunsel fees, and alimony pendente lite al this lime and d,'''' '"' ,"d ," ,""""" '01'. "''"' " ""~ "'"gh' b, '''h"" ., ''"'" h."" '''' 'h. ",,,,, d, h."by "01'". "'''''. '""' ."01. 'od "'""''''h ,,,""" '"' '"' '" IIgh' " SUPPOr1, alimony, alimony pendente IIle, Counsel fees and expenses beyond those provided for h,.". d",,,, 'h. '"'''',,'' " " " , """ 0' '0> ""' ""'"'. " pro""d b, 'h, 0'_ Cod. " P"","","" " '"' 'Ih" ''''00",. """'. " ''''' "01' ,"d " .., "01' " Ih. M"". Loving Agleement.IIIIJ~ g " ~ E;QUITABlE DISTRIBUTION: A, WAIVER OF PERSONAL 1) MARITAL, TANGIBLE AND INTANGIBLE, ASSETS AND 2) NON.MARITAl, TANGIBLE AND INTANGIBLE, ASSETS: Husband and Wife do hereby acknowledge that they are aware of the assets In the possession and control of the other and the relative value thereof and further have heretofore divided to their mutual satisfaction all non.marital and marital assets Including, but without IImllatlon, business Interests!, partnershlp(s), Inheritance(s)2, jewelry, clothing, pensions, brokerage accounts, stocks, bonds, life Insurance policies or other securities, Individual Retirement Accounts, checking and savings accounts, mutual funds, and other assets whelher real, personal or mixed, tangible or Intangible. Husband and Wife further acknowledge and agree that the assets In the possession of the other spouse shall be that spouses sole and separate property, each party hereto specifically waiving, releasing, renouncing and forever abandoning whatever claim, If any, he or she may have with respect to any of the foregoing Items which are the sole and separate property of the other. B, AUTOMOBilES: 1997 Ford F250 . Husband; 1991 Nlssan Maxima. Wife The parties agree that the vehicles In their possession at the time of execution of this agreement shalt remain the possession of the party and each shall cooperate If necessary In executing any and all documents to reflect such ownership, inCluding but not limited to titles, Insurance documentation and registration forms. Husband and Wife do hereby waive, release, and relinquish any and all claim to or Interest in the motor vehicle in the possession of the other. If the title to any vehicle Is encumbered by any debt or obligation, Husband and Wife agree that they shall each be solely responsible for and shall pay and satisfy said obligation. in accordance 1 2 Husband is self employed - Gustom Concrete Works. Husband acknowledges that Wife's potential inheritance(s) are considerable. lovlhg Agleemeht.w~~ 4- The parties hereby agree that, as to all assets not specifically mentioned herein which are presently titled In the sole name of one of the parties herelo or, If untitled, are presently In the sole possession of one of the parties herelo, Ihe party not having title thereto or possession thereof hereby waives, releases, relinquishes and forever abandons any and all claims therein, and acknowledges that the party having tllle or possession of such Items shall be the sole and exclusive owner thereof. z.. DEBTS: A. Wife's Debts: Wife represents and warrants to Husband that since the parties' separation she has not and In the future she will not conlract or Incur any debt or lIabllily for which Husband or his estate might be responsible and shall Indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations Incurred by her. B.. Husband's Debts: Husband represents and warrants to Wife that since the parties' separation he has not Gnd In the future he will not contract or Incur any debt or liability for which Wile or her estate might be responsible and shall Indemnify and save harmless Wife from any and alt claims or demands made against her by reason of debts or obligations Incurred by , him, ~ Indemnification: All further debts Incurred by the parties shall be their Individual responsibility. Each party represents and warrants to the other that he or she has not Incurred any debt, obligation, or other liability, other than described In this Agreement, on which the other party Is or may be liable. Each party covenants and agrees that If any claim, action or proceeding Is hereinafter Initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other agalnsl any such claim or demand, whether or not welt-founded, and that he or she will Indemnify and hold harmless the other party In ~espect of: all damages as resulting therefrom, Damages as used herein shall Include any claim, acllon, demand, loss, cost, expense, penally, and other damage, Loving Agleement.w~~ 6 Including wllhout Ilmllatlon, counsel fees and olher costs and expenses reasonably Incurred In Investigating or attempting to avoid same or In opposing the Imposlllon thereof or enforcing this Indemnity, resulting to Husband or Wife from any Inaccurate representallon made by or 011 behalf of ellher Husband or Wife to the other In this Agreement, any breach of any of the " " ( , " / warranties made by Husband or Wife In this Agreement, or breach or default In performance by Husband or Wife of any of the obllgallons to be performed by such party hereunder. The Husband or Wife agrees to give the other prompt written nollce of any litigation threatened or Instituted against either party which might constitute the basis for a claim for Indemnity pursuant to the terms of this Agreement. .8... FUll DISCLOSURE: , The parties acknowledge that each of them have had a full and ample opportunity to consult with counsel of their choice regarding their claims arising out of the marriage and divorce and that they have specifically reviewed their rights to the equitable distribution of marital ] ) property, Including rights of discovery, the right to compel a filing of an Inventory and Appraisement, and the right to have the court review the assets and claims of the parties and .... I \ , I decide them as part of the divorce action. Being aware of those rights, and being aware of the' marital property owned by each of the parties, the parties hereto, In consideration of the other ! terms and provisions of this agreement, do hereby waive, release and quitclaim any further right to have this court or any other tribunal equitably distribute or divide their marital property. The parties acknowledge that they have been fully advised and Informed of the wealth, real and/or personal property, estate and assets, earnings and Income of the other and are familiar with and cognizant of such and the value thereof, or has knowingly waived such advice and/or Information. The parties hereto have been fully advised and Informed of all rights and J, . n },,' ! , 'J-'. j ( , i Interests which, except for the execution and delivery hereof, have been conferred upon or vested In each of them by law with respect to the property or estate of the other by reason of their marital status, or has k~owlngly refused or waived such advice or Information. .8... RELEASES: Loving Agtccrncnl.w~~ 7 Except as othelWlse herein provided, each party releases and discharges completely and forever tho other from any and all right, tille, Interost or claim or past, present or future support, division of property Including Income or gain from property hereafter accruing, right of dower and courtesy, right to act as administrator or executor In the estate of the other, right to distributive share In the other's estate, right of exemption In the estate of the other, or any other property rights, benefits or privileges accruing to ellher party by virtue of said marriage relationship, or othelWise, and whether the same are conferred by the statutory law or by the common law of the Commonwealth of Pennsylvania, or any other state, or of the common law of the United States of America. It Is further specifically understood and agreed by and between the parties hereto, that each party accepts the provisions herein made In lieu of and In full settlement and satisfaction of any and all of said parties' rights against the other for any past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims' of each party, Including all claims raised by them In the divorce action pending between the parties, 1Jl. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach. The party breaching this c:ontract shall be responsible for the payment of legal fees and costs Incurred by the other In enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her, 11. REPRESENTATION: Both parties have been given the opportunity to obtain the advice of counsel regarding the provisions of this Agreement and their legal effect In advance of the date set forth above to permit such Independent review, In the event either party elects to execute this agreement without the advice of counsel, he/she shall nevertheless be bound hereby and he/she specifically , . lo~l"g Agteernellt.wp~ IS' '"' " and knowingly walvos his/her right, If any, to utilize his/her lack of legal represenlallon as a basis 'I to attack the validity of this Agreement. Each party acknowledges that he or she has had the opportunity to receive Independent legal advice from counsel from his or her selecllon, and that each fully understands Ihe facts /1 ..~ i , and has been fully Informed as to his or her legal rights and legal obllgallons, and each party acknowledges and accepts that this Agreement Is, and the circumstances, fair and equitable, and that It Is being entered Into freely and voluntarily, after having had the opportunity to receive such advice and with such knowledge, and that execullon of this Agreement Is not the result of any duress or undue Influence, and that it Is not the result of any Improper or Illegal agreement or , agreements, .u. VOLUNTARY EXECUTION: The provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement Is fair and equitable, that It Is being entered Into VOluntarily and that it Is not the result of any duress or undue Influence, Further, each party acknowledges 1 I , I that he or she has the mental capacity to understand the terms provided herein and has not been placed under duress, coercion or any physical or mental stress, i , , 11. ENTIRE AGREEMENT: This Agreement contains the enllre understanding of the parties and there are no representallons, warranlles, covenants or undertakings other than those expressly set forth herein, ti. fBlOR AGREEMENT: It Is understood and agreed thai any and all property setllement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 1R. MODIFICATION AND WAIVER: Any modification or ~aiver of ,any provision of this Agreement shall be effective only If made In wrlllng and executed with the same formality as this Agreement. The failure of either Loving Agleement.wlls 9 party to Insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent defaull of the same or similar nature. 16... GOVERNING LAW: This Agreement shall be governed by and shall be construed In accordance with Ihe laws of the Commonweallh of Pennsylvania. 1L INDEPENDENT SEPARATE COVENANTS: It Is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and Independent covenant and agreement. 18... VOID CLAUSES: If any 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 fuit force, effect and operation, 1i.. CONSENTS TO DIVORCE: The parties agree that they shall execute Affidavits of Consent and their Waivers of Notice which shall be flied with the court along with a Praecipe to Transmit the Record in order' that a Decree in Divorce Incorporating the herein agreement can be Issued In due course. &. DISTRIBUTION DATE: The parties hereto acknowledge and agree that for purposes of distribution of property as provided for in this agreement, the date of execution of this agreement shall be known as the Distribution Date. 2L DATE OF EXECUTION: The parties hereto acknowledge and agree that the date of execution referred to herein shall be known as the last date upon which either party executes this agreement loving Agloemonl.w~~ 10 .. " " , (. \, ""/ 'r , .' '" (') ,~ 0 c: _0 ')" , :.c." c..... .-1 "nr.-; .~..... T ,. rllf.... :.~ ;'1"ifll \, ;..~. ~--~ :/1." "" Tl~ l ".~ r-) ::1 r') " '~ILJ ~.~: (:: "U '::8 ~ '; C": .J.. (~~") ~:' : t J ~'.) -'-~ n .-" ~:..; ~ ,~ =2 "" ~ -< j ) ! \ \ n j. , ' ii Ii , " [: . .---., ~ ,. ~-r'."-' ".,..' i r, "'I'.,, "' I,,' . (,""'c l' >_, .,,'..... ' ".:i, LAw 0",.'01:. e,. .JAM 1:. A, MILLE" t".... ;'~~l;.J~<', ~IT ~!~.,au"'I_HMlU.1HlOt PIt "tal . f7." 1,u'.II. "~"""..:' , ..~.. '''<''''''':'' ..;.,H-"r," \........... 1':Y~il~i::i!(:,%. , ',,' ,:, V "..";"'tJ" ,p., , ': i:,,~,;l.\,l~~ "f"",\',..I. ~~ ,.... 1'7111 Ill"'.' O(l/FY~ ~-). . Dexter R. Loving Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-797 Deborah M. Loving Defendant CIVIL ACTION. LAW 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 service of the Complaint: a CERTIFIED COpy OF THE COMPLAINT IN DIVORCE was served upon Defendant by certified mai/ number P 016 244 803 on February 14, 1998, 3, Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: by Defendant: j , , December 24, 1998 December 24, 1998 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: December 24,1998 by Defendant: December 24, 1998 James A Mi/Jer, Esquire AttorJ)eyfor Plaintiff 122'locust Street ~Suite 100 Harrisburg, PA 17101 4. Related claims pending: There are no related claims pending, Respectfully S~~o/'r(~ By: i' !', ,\.....; (') \.0 0 G "" " ,: t._ -J -0 [11 ~ :1':!J 9.'!rl1 1i1,-_ -:-:1") ili5: N ""t? N --:, ~() ~O -n "T' :.- g~ ~~.:(:-, ::l~ .-,.0 ~ ,-rn ;"''''c: ~ ~ N ~ 0< :) \ ~~~ -, ~ ., ) ?--0 "'=>(\, e --" 9n ~ ro C,r ~ -n --j ----r ~ ,- ~. -0 OJ rn ff,:];! c';!q' oJ ~I ...._ _.1 .,.,h-1 IU zc I::> 66 ...., ~ ~~:~ ~ - f\ r;:.1..:) "'" ..~~ ~\ -........ ;;;C) :J; 0 c\, ~() N ~m ~ W '>S p~;.; .. :;;! ~':l :n !i:! ~I~ -.. -.I ~ c- \:' '~' ::.,..~~~~;..:-'::;t;;,:"_" , t\C'iLAW~D"~ICE. D.~ .JAMII:8 A. MII.I.E" Jlh, j..~.1'trl,~;L.I:Im:'et.~._IIUM.IDal H.......,...'..... I,IDI . "'" ""1'1' t~~)~(,'t~:,:~,,~~,'" , Dexter K, Loving Plaintiff . ,.. "'" ...'.,.., 6f'l~1~ , ,. -. .--..., v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 98.797 CIVIL ACTION. LAW IN DIVORCE Deborah M, Loving Defendant AF.F.IDAVILOF_C.ONSENI 1. A complaint In Divorce under Section 3301 (c) of the Divorce Code was filed on February 10, 199B, and service was obtained upon the defendant by certified mall number P 016 244 B03 on February 14, 199B. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree, 4. 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,A, Section 4904, relating to unsworn falsification to authorities. Datej d ,~ '-LS &- \t hUVL0, Vl Um VI- e, ") Deborah M. Loving U ".! ~f ),",-':.. ',':, " i . ' './LAW a....ICIE.,C,. "AMIE. A.. MILLIE" :.:\1111 Loou.. a'N<<T.1kHtt lao, H_UItttt M ,."at . I"" UI."II if~/l;'L.,' ,~ .,..:::'-.. , orc'9)It.:nL .--.., . .....1".,' III'."." Dexter R. Loving Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO,: 98-797 Deborah M. Loving Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSEtfi 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 10, 1998, and service was obtained upon the defendant by certified mail number P 016 244 803 on February 14,1998. 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same, 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4, 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,SA Section 4904, relating to unsworn falsification to authorities. Date: 17/7,// 7'i? ,~- , C'::f"" Dexter R. Loving G '...0 0 C..: "" -n .:+... ,- --I "'0'.: :::.: 'r~ -11 rTH "'1 " ''-1[11 .' '"? ;-~.) ; ID ' . .... ...:.:!C) ~::~. -rJ . ~-r. ',.." ". :~: t:-: -,' ( :~C:.) , r:".' :;.-rn '. ::::\ ':..; '- :'j - 5:1 -, -< '~ '~ .-.' .~::I '-"~,::~;~.\:}!,I'.:<"~};.'.'"",,', ',:. '. . ";,'L;AWi,C""'CEiI O,......ME. A. MILLE" ;_.:..:I....LalUIT Intl'ff-.,m: loa. H.....uu. M ,'''IDI f 1"'''1 aU.I'_' '~;~")" " .:\:'..<. ." ,.. ~: . fU '"'''' u...""" or ''B''coL l._~-'~'~"'i ~:.:;-~ Dexter R. Loving Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO,: 98-797 Deborah M. Loving Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A,DIVORCE DECREE UNDER SECTION 3301(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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities, Date: (~/2 'I! 99 /-~ --- ' Dexter R. Loving n t...:J <':> I, \.f;.J -q :-:.~ '- ~ '. ,-~ r;~ : :-,,~ " , -" r) j- , r- :"":,: ~'.m r, '-=' <0 "." I -~. ,.:l() '-'': " "'J ~} ." '. ~n . .} ~.. .,-,.C) .. ;..', ~ ~.., ) m , ,~ .~ ~~:! " :'J r:- :.0 -. -< ,I