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HomeMy WebLinkAbout98-00863 \J ~ C1- ~ V) $ ~ ~ 4 f.. \i) \ \ I I ! I J / /' -C'.;' . ~... ;'-J" <'H'~i' ,',\';1 "./~~}J i. ';~, "J.' ~ .. ~ Ii - . - ~ . '- <::J *~~**~*~***~*ro*~****)~'~~*****~~-'. ;', ---........__._- ~--- ---...-.........----- ------.~~.--_.~-~.~ - -- . -~~.......~.........--~--_...------------........-....---.._..~---- --- .'~ ~ ~ ,.,..,....,.,...........,.....,.r. ....".<.................. ,/ ) D y '\~'~J{~j ~ ~~/ ~ AtlC, ~l: ?1" ".., '{ / , J. l~ I. (.... ~ ( . ~,: ~ Prothonolary ~ * ~____~ - ______v'__,,,__,,."_ ,-----.--.........--.--."..-,'~ ~~~~*~~~**~~**~*****~.~~,~~**~~~. ~ " .', ~ ~ ~.' ~ ~.' ,.; ~ ~.~ ~ ~ ~.' .', ~ ~ " ,', ~ ~ '.' .', ~ ,., ~ .. ~ '.' ..; ~ ." ~ ~.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF l':'t' "~~ / t~k~}?~~ ~ '-~~~"r PENNA. ",.:rOHN..R."STEFFEE I' I N (). 9,8:-:11,6,}""" Cj,,v.,U,,,,'rerm Plaintiff ' Vl"':H1S PEBORl\i'I ANN ,STEFFEE , Defendant ,', ~ ~ '.' DECREE IN J DIVORCE AND NOW, '\'01/~" ,~'1.,., 19 .if,. it is ordered and decreed that....,. ~.Ql'!~. ,R,., .$:r.E;F:I;'~j;;"."......"".........., plaintiff, and. .' ,. ,P.E;~9~N~ ,I;\~!'l. ,~1'?!",F:E;~" ,. .., , ,. " , , , . , ' , , , , , ,. , ", defendant, are divorced from the bonds of matrimony. ~i ri ~< ,', ~ ~.' ,.; ~ " ~ :'~ ,', ~ ~ ',' 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; ~ ~.~ ,', ~ .. ~ !:. ~ .. None . ......... ........,. ........ ..... ... ,..... ,...... ,.....,.... ...., .......,.. ~ '.~ ~ :< ,., ~ ~ ; :i: f-~ ~ '.~ ~ '.' ~ * * ~ ~ ~.~ ~ ',' ,., ~ .', ~ ~ ~ ... ~ ',' ~ ~ ~:. ,', ~ ~ '.' ~ ',' ~ I.. ~ ~ *- ~.: ~ '.~ ~ ~ ~ ~ ',' ~ ~ * ~ * ~ '. . , " " . ~ WHEREAS, diverse unhappy marital difficulties have arisen between the parties, causing them to believe that their marriage is irretrievably broken, as a result of which they have separated and now live separate and apart from one another, the parties being estranged due to such marital difficulties with no reasonable expectation of reconciliation; 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 of real and personal property; the settling of all matters between them relating to the past, present, or future support and/or maintenance of Wife by Husband or of Husband by Wife; and in t , general, the settling of any and all claims and possible claims by one against the other or against their respective estate, particularly those responsibilities and rights growing out of the marriage relationship; and WHEREAS, both Husband and Wife have been fully, separately and independently advised of their legal rights and obligations, and each covenants that he and she has each made a full and 2 , , I~ ,.' . (' , " .' complete disclosure to the other of his or her respective property, holdings and income; and The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The HUSBAND has employed and had the benefit of counsel of CONSTANCE P. BRUNT, ESQUIRE, as his attorney. The WIFE has employed and had the benefit of counsel of CHARLES J. AX, JR., ESQUIRE, as her attorney. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection and that each fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the Court has the right and duty to determine all 3 " . ,r " I i ~ i\ ." marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital " ~ ! property owned or possessed jointly or individually by the other party, counsel fees and costs of litigation, and, fully knowing the same and being fully advised of his or her rights thereunder, I , I , I each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are , fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleas of Dauphin County or any other court of competent jurisdiction make any determination or order affecting the respective parties' rights to a divorce, alimony, alimony pendente lite, equitable , I , I distribution of all marital property, counsel fees and costs of , , , litigation. NOW, THEREFORE, in consideration of the premises and of the promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt of ~ , i 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: 4 \ h I , . , '. , . claiming that the marriage is irretrievably broken under the no- fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. The parties hereby express their agreement that the marriage is irretrievably broken and express their intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code as soon as possible. The parties hereby waive all rights to request Court-Ordered counseling under the Divorce Code. Neither party to such action shall ask alimony or support contrary to the provisions of this Agreement. It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. 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 6 , ' " further modification or revision thereof shall 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, judgment, or order of divorce or separation. Notwithstanding the provisions of the Pennsylvania Divorce Code or of any law to the contrary, none of the terms and provisions of this Agreement shall be subject to modification by the Court or in any fashion other than as set forth hereinafter. It is specifically agreed, however, that this Agreement shall be subject to enforcement under the provisions of the Pennsylvania Divorce Code or, at the option at the aggrieved party, by a suit against the alleged breaching party either in law or in equity. 3. EFFECTIVE DATE. The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7 '. ' . , " 4. DEBTS AND OBLIGATIONS. The parties hereby acknowledge that there is an outstanding credit card debt due to VISA as of the date of execution of this Agreement. Upon the sale of the marital residence, as set forth hereinafter, the balance due on such account as of the date of execution of this Agreement or the entire balance then due, whichevp.r is less, shall be paid in full from the proceeds of the sale. Neither party shall incur any further charges following the date of execution of this Agreement on the said VISA account or on any accounts in the joint names of the parties or on which the other party can in any way be held responsible by the creditor, Any such accounts shall be immediately closed. Any such charges as may be incurred subsequent to the date of execution of this Agreement contrary to the foregoing shall be paid upon the sale of the marital residence by the party incurring the same. Each party shall also be responsible for any charges incurred subsequent to the date of execution of this Agreement on any accounts in his or her respective individual name, and shall retain said individual accounts for his or her own personal use. Pending the sale of the marital residence and payment of the 8 , . ,,' .~ balance on the said VISA account as set forth above, Wife shall pay the required monthly payments to keep the account current. From the date of execution of this Agreement, each party represents and warrants to the other that he or she will not contract or incur any debt or liability for which the other party or his or her estate might be responsible, and each party shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of such debts or obligations incurred following the date of execution of this Agreement, except as otherwise set forth herein. 5. MUTUAL RELEASES. Husband and Wife do hereby mutually remise, release, quit-claim or forever discharge the other and the estate of such other, for all time to come, and for 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 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 or 9 , ' ., - ' hereof. 6. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Except as otherwise set forth hereinafter, neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Anything to the contrary contained herein notwithstanding, Husband and Wife shall be deemed to be in the possession and control of any 11 . ' '. ' / ' pension or other employee benefit plans or other employee benefits of any nature to which either party may have a vested or contingent right or interest, apart from the provisions of the Divorce Code, at the time of the signing of this Agreement. 7. SUPPORT OF SPOUSE. ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES, COSTS AND EXPENSES. The parties each acknowledge that he or she has sufficient income, earning capacity and assets to support himself or herself and to meet his or her reasonable needs. Each party therefore waives and relinquishes any claim against the other party for spousal support or maintenance of any nature, alimony, alimony pendente lite, counsel fees or costs and expenses of litigation, regardless of any subsequent change in the circumstances of either party. 8. REAL ESTATE. The parties acknowledge that they are the owners of a marital residence situate at 3 Ashley Court, Boiling Springs, Cumberland County, Pennsylvania. The parties agree that the said residence shall be listed for sale on or before April 1, 1998/ with a reputable broker licensed to do business in the Commonwealth of Pennsylvania at a reasonable 12 , . ' -' ,00 I " 1\ price and upon reasonable conditions. The parties shall I I cooperate in all reasonable respects to sell the said property as soon as practicable thereafter. Upon settlement, the existing . i ~ . balance of the outstanding mortgage and all other liens existing as of the date of execution of this Agreement and reasonable expenses of sale shall be paid. Further, the balance due as of suffer or cause any further lien or encumbrance to be placed the date of execution of this Agreement on the VISA credit card account or the entire balance then due on the said account, whichever is less, as set forth hereinabove in Paragraph 4, shall be paid from the proceeds. Pending the sale, neither party shall against the premises. In the event of the breach of this provision, the party suffering or causing same shall be solely responsible for its satisfaction at settlement. The remaining { , balance of the settlement proceeds shall be divided equally between the parties, and each party shall retain his or her respective share as his or her sole and separate property. Notwithstanding the foregoing, in the event that either party has failed to make payment of any charges on credit card accounts for which he or she is responsible pursuant to the provisions of Paragraph 4 hereinabove or has failed to make any required 13 - ' '. . . payment for household expenses as set forth herein prior to settlement, payment for such charges or expenses shall be made or the other party shall be reimbursed for one-half of any such payments made by that party on behalf of the non-paying party from the non-paying party's share, prior to distribution of the proceeds as set forth herein. wife shall continue to reside in the marital residence until settlement. Through July, 1998, Husband shall be responsible for payment of the mortgage payment. From August, 1998, through the date of final settlement, the parties shall jointly be responsible for the monthly mortgage payment. Commencing in August, 1998, the parties shall pay each monthly mortgage payment, with Wife delivering her $390.00 to Husband on or before the first day of each month. Husband shall then forward the entire payment to the mortgage company. All household expenses, including, without limitation, any and all utilities, sewer, water, refuse collection, assessments, proper maintenance, repairs and improvements, shall be paid by Wife. Any real estate taxes assessed against the said 14 , . , . " property shall be paid from the escrow account referred to in Paragraph 9 hereafter. 9, VEHICLES. The parties acknowledge that they are the joint owners of a 1989 Plymouth Voyager, which vehicle is in Wife's possession. The parties agree that the said vehicle shall be sold as soon as practicable after June 25, 1998, and they shall cooperate in all necessary respects to do so upon reasonable terms and conditions. The proceeds of the sale of said vehicle shall be deposited into a joint account with a mutually-acceptable financial institution, such account requiring the signatures of both parties for any withdrawals to be made. The funds deposited in the said account shall be used for payment of any property taxes assessed against the marital residence until such time as the residence is sold. Upon the sale of the residence, any remaining balance in the said escrow account shall be divided equally between the parties, and each shall retain his or her share of the said funds as their sole and separate property. Wife hereby covenants and agrees to transfer to Husband all of her right, title and interest in and to the 1984 Toyota 15 . . " Corolla, which vehicle shall become the sole and exclusive property of Husband. Wife hereby acknowledges that she has no further claim, right, title or interest whatsoever in said vehicle in the future. Further, Husband agrees to assume the full responsibility for any costs, fees, or expenses incident to the transfer of the aforesaid vehicle from Wife to Husband, The parties acknowledge that Wife also owns a 1992 Saturn, on which there is an outstanding encumbrance with the Pennsylvania State Employees Credit Union ("PSECU") in the joint names of the parties. Wife shall retain the said vehicle as her sole and separate property. Wife shall be solely responsible for the payment of the said PSECU encumbrance, and she shall indemnify and save Husband harmless from any liability thereon. Wife will refinance the said loan on or before the settlement of the sale of the marital residence, so as to obtain Husband's release. Commencing with the date of the entry of a final Decree in Divorce or the policy renewal date, whichever first occurs, each party shall be solely responsible for insuring his or her respective vehicle. 16 . . I .' '. 10, DISTRIBUTION OF CASH ASSETS, STOCKS AND BONDS. 'rhe parties acknowledge and agree that they have previously divided their marital bank accounts equally and that each shall retain the one-half distributed to him or her as his or her sole and separate property, free of any claim by the other party. Each party will also retain as his or her separate property any bank, credit union, brokerage or other depository accounts of any nature in his or her respective individual name, 11, PENSION. PROFIT-SHARING. RETIREMENT. CREDIT UNION OR OTHER EMPLOYMENT-RELATED PLANS, The parties hereto expressly waive and relinquish any right, claim, title or interest in any pension, profit-sharing, retirement, credit union or other employment-related plans in which the other has any interest by virtue of his or her past or present employment, whether vested or unvested, matured or unmatured. 12. TAXES. By this Agreement, the parties have intended to effectuate and by this Agreement have equally divided their marital property. The parties have determined that such division conforms to a right and just standard with regard to the 17 . , I - . ". rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. As a part of the equal division of the marital property and the marital settlement herein contained, the parties agree to save and hold each other harmless from all income taxes assessed against the other resulting from the division of the property as herein provided, The parties acknowledge that they have filed various joint income tax returns during the course of their marriage. In the event that any additional taxes, penalties or interest are assessed as a result of any such joint return, the party responsible for under-reporting income or claiming any improper deduction shall indemnify and save the other party harmless from such tax liability, penalties or interest. 13. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time to time at the request of the other, execute, 18 . "t, ~ I 't '. acknowledge and deliver to the other party any and all further instruments or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 14. MODIFICATION AND WAIVER. A modification 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 shall not be construed as a waiver of any subsequent default of the same or similar nature. 15. ENTIRE AGREEMENT, This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein, 16, DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 17 , INDEPENDENT SEPARATE COVENANTS, It is 19 '.', ..... . .. .- specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 18. 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 or to seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. 19. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, 20. 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 full force, effect and operation. 20 . ........... ..... ., ... COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF DAUPHIN On this '11/-- day of o te,d l,- , , 199B, before me, the undersigned officer, personally appeared DEBORAH ANN STEFFEE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the PUrp~s t~~ contained. k,,-Z,-<~/- Notary Public * * * * * * * * NOlarlal Seal Consfance P. Bruni. NOlaI'( Public Harrisburg, Dauphin Counly My Commission Expires Ocl, 20, 200 t COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF DAUPHIN On this'll /--day of (" . ~ I /) C"'t_ J ,-"--_ J , 199B, before me, the undersigned officer, personally appeared JOHN R, STEFFEE, known to me (or satiSfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. 1 U ;4~~~~ Notary Public 22 Notarial Soal Cons lance p, BrunI, NOlary Public Harn~b~tg. Dauphin Coul1ly My CommisSion Expires Ocl, 20, 2001 . \ ..~- - - .---.... . - --- - ,.. '" JOHN R. STEFFEE, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW I NO. q~_ ~(o3 DEBORAH ANN STEFFEE, Defendant 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 Prothonotary's Office, Cumberland County Courthouse, Carlisle, Pennsylvania, 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, Office of the Court Administrator Cumberland County Courthouse 4th Floor 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 ! j [ . ,.. .,~j ( " , 9. The Plaintiff avers that the grounds on which the I ir , ' I' , ' action is based are that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. Respectfully submitted, ,6~ CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 2941 North Front Street Harrisburg, PA 17110 (717) 232-7200 Attorney for Plaintiff .'- - ( . . P 139 731 702 US Poslnl SOIVlco Receipt fof (;eriffied Mall No Insuranco Covorago Provldod. On nol uso lor Intornallonol Moll 509 mvolSo Sonllo S.teffe.c__ S~.ot^~m~y Court Post Ollice, Slale, & ZIP Codo . . . 07 Postage $ .55 Certified Foe 1.35 Spedal OelivlJry Foe Aoslrictod Oolivory Fee 2.75 on 0> Retum Receipt Showklg 10 0> 1.10 - Whom & Oale Delivored '2 R""'Ro:~SIowr'ljO\\l>Jm. .:( Dalt,&Adlbssee's ess 0 $ 5.75 o TOTAL Postago & I os co M F'ostmarK or 011.10 E ,f February 13, 1998 l/l 11. .~ D: Ji! aCompfetlll.rTII1andlor 2 for additlonal HNleeI. .. aComplelllleml3, 48. and 4b. !" I -::: tv:;,~.am. and add,... on the revert. of thl, form 10 thai we can r8Cum IhI, . -Attach this tonn to the front of the mallplKe, or on the back It Ipace doe, not po""'. :. .Wrlt,.Retum RlCtJlpt RequeltlCr on the mallp1ece be"='=~~~ number. ,= -The Relum RlC8fpC wlQ Ihow to whom thlankla was delivered and the dalo ,e dellverect. '0 :1 3. ArtI~l. Addrassod 10: DEBORAH ANN STEFFEE 3 Ashley Court Boiling Springs, PA I also wish 10 rocolva the following SOMCOS (for an oxtra 100): j 1. 0 Addrassoo'o Addross 2. IlIll: Roslrlcted Dollvory Consull postmaslnr lor fno. 4a. Artlclo Numbnr P 139 731 702 17007 1;. 1 II: E 4b. SnMco Typo il o Rnglslerod Qg Cortlfiod II: co o Expross M~ p ..' , , 0 Insurod .Ii o Rotum~iPtttiri.lerchsl1.fso 0 COD !! .e 7. Dalal'~.on~~,,- "~ :s rn .\3, ~ B. Addrsss o'a Addre . 91 II roquosted ~'" andle.'li;pald) . .<.'< I .. _......~~,..~/ ". '. r)r J \... <2-/ :.!! Domestic Return Receipt '--' ~'~'''r t ..r'-'. - - - ~~ - , ,...___ ____1''''' ... - - JOHN R. STEFFEE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. NO. 98-863 Civil Ter.m DEBORAH ANN STEFFEE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 13, 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the 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: ~~w . ~_. ' _ -:.=::::"ft1V: -