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HomeMy WebLinkAbout98-03285 \- a .~ --i ~ 's. ,i ~ o ~ .... ....Q ~ t".. ... ~ ......; . - ..:l ... ,J "" Coo, C) I'f)i , ~ ()... ~ ".:+:. ,>>:.- .:.:. .:c. .:.:. <.;. .:.:. ':.;. ':.:. .:.;. .:+:. .~+:. .~.:. .:+:' .~.;. <.:' .:.;. -:.:. .~.:. .:.;, :. {.;..~.:,..:.;. .:+:. <.~. ':~:. ':~:'_, ':~:,~:*--~ . ~~"~__~''''..v... ..~.' '...." ....". ", " .. i ~. M ~ " 8 IN THE COURT OF COMMON PLEAS ~ ~ ~ " c:> OF CUMBERLAND COUNTY STATE OF ~, PENNA, " " " " " " 8 ~ " " ~ ~ John W. Robinson, Jr., Plaintiff t\! n, 9.87)2~?"H'HH" Il) V('l'."Hl~; ;0, ~ Janine L. Robinson, Defendant " " ~ " ~ " ., DECREE IN D I V 0 R C E ot 5: S')~,k1 , ANDNOW,~,~.,.., 19~., it Is ordered and dec:reed thot ....... . .John. .w... .Robl.n.s,o.n... .Jr.., . .. . . . . , . ., . . . " plaintiff, and . , . , . . , , . . . . . . . . J~nin" L~ . R,?bil~~,?~ , . . , , . , . . . . . . . . . . . . . . . " defendant, ore divorc:l'ld from the bonds of matrimony, " c:> ~ ... . it ~ $ .:i ~ " ~ ,;; " 8 ~ ... The C:OlJrt retoins iurisdiction of the following claims whic:h hove been raised of rec:ord in this action for which a final order has not yet been p.ntered; None. ~ r.' " " IT IS FURTHER ORDERED that the terms, conditions and covenants set forth in the wtitt~d'M'tit'l'S'ttl'.'dt'A.tii.idt'.~ai'~~a'i~titia'l~tb'h~'thi'~~ttii~'~h J,!l)~ )fi. . \ 9.9.~. ,1I,a . il)GQtpotllted. il)tQ, tois. Decree. by. refeJ;JWce. thereto,. but. are merged into this Decree. ~ ~ 8 ,-; ~ ... ~ " ~ , ~ ~:..-::~:,~,~:, , ~'~ P. ~I'OI"Onnl~l'.Y .:+:. .:+:. ':+:. .:+~. .:+;. .:+;, -:+:' <.:. -:+:. -:+;. (~ : ' i .~ I'" !.', !~ , ,~ <.:- .:.> 0:+> <.;. .:+:' .:+;. .~.;. <.~, ':+:. <+:.' " " " " " " M ,.,~ ~ 8 ~ " ~ " " s .', * ~ (. ~ ~ ~ ~ ~ Ii ,'~ ~ ,,~ ~ 8 ~ <:> "I ~ ~ ',' I~ ~ ... ~ W not -.' ~ ',' .1. )~ I,:, I~ , '-.', I:" , ' , llrnft # I June II. 1998 MARITAL SETTlEMENT AGREEMENT 1\\ \. THIS AGREEMENT, made this ~~_ day of~~J\ (' ,1998, by lInd between John W, Robinson, Jr" hereinafter referred to as "Husband", and Janlne L. Robinson, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, Husband and Wife were lawfully married on February 17, 1990;1nd WHEREAS, certain differences arose between the parties as a result of which they separated on April 1, 1998, and now live separate and apart from one another, and are desirous of settling fully and finally thoir 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 past, present and future support 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 otheT or against their respective estates for equitable distribution of all marital property; and a resolution of all mutual Tesponsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband, by his attorney, Barbara J, Patton, Esquire, and Wife, unrepresented, have come to the following agreement, NOW THEREFORE, .in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: ~(lnitiaIS) JL-I',(ti.bl , Draft III June II, 1998 1. SEPARA TION: It shall be lawful for each party at all times hereAfter to live separate and apart from the other as such place or places as he or she may from time to time choose or deem fit, 2. INTERFERENCE: Each party shall be fTee from InteTference, 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 AgTeement. Neither party shall harass the other nOT endeavor to molest the other, nor compel the other to cohabit with the other nor in any way malign the other, nor in any way Interfere with the peaceful existence, separate and apart fTom the other In all respects as if he or she were single and unmarried, 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since April', 1998, she has not, and in the future, she will not, contract or Incur any debt or liability for which Husband or his ostate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations Incurred by her, 4. HUSBAND'S DEBTS: Husband Tepresents and warrants to Wife that since April' , 1998, he has not, and in the future he will not, contract or Incur any debt or liability for which Wife or her estate might be responsible and shall Indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTSTANDING MARITAL DEBTS: Husband and Wife agree that Wife shall be solely responsible for all marital debt in her name alone and that Husband shall be solely responsible for all marital Jebt in his name alone. .7"- ~-<InitiaIS) 2 /'--<1,'....) Drllf\ 111 .June II, 1998 8. MUTUAL RELEASE: Except as provided In this Agreement, each party waives his or her right to alimony and any furtheT distribution of property because both agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980, Subject to the provisions of this agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs. legal repTesentatives, executoTs, administrators and assigns, release and discharge the otheT of and from all causes of action, claims, rights or demands whatsoever In law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except In any or all causes of action for breach of any provisions of this Agreement, Each party also waives his or her right to request marital counseling pursuant to 23 Pa,C.S.A. Section 3302. 7. EQUITABLE DISTRIBUTION: A, Real Estate. Wife agrees to transfer to Husband Immediately upon signing of this Agreement, all of her Interest in and title to their jolntly,owned real estate at 1441 Riegle Road, Harrisburg, Dauphin County, Pennsylvania, 17112 subject to the mortgage given to PHH Mortgage Services, in eXChange for which Hu~balld i , agrees to be solely responsible fOT the payment of all future mortgage payments, taxes, insurances and utility bills relativs to said real estate, Husband covenants and agrees to pay and discharge the existing mortgage obligations on said premises and agrees to Indemnify Wife from any loss by reason of any default in payment and agrees to save Wife harmless from any future liability with regard thereto. (1) Wife agrees that upon the exocution of the deed, Husband shall be come the sole owner of any and all homeowner's policies, title polioies and any other policy of insurance with respect to the real estate and shall be entitled to receive any payments now or hereafter due under such Insurance policies. ;J ~_(1nitiaIS) 3 d p--(lnltiaIS) {; . Draft #1 June II, 1998 (21 Husband shall promptly apply for refinancing to satisfy the existing mortgage on 1441 Riegle Road, Harrisburg, Dauphin County, Pennsylvania 17112. Pending settlement on his new finanolng, Husband shall continue to be solely responsible for the existing mortgages, Insurance, taxes and other charges associated with the property, B. Vehicles 1. The 1990 Ford Ranger and the 1973 FOTd Mustang currently titled to Husband shall be retained by Husband. Wife hereby waives any interest she may have In Husband's vehloles. 2. Tho 1993 Ford F150 ourrently titled to Wife shall be retained by Wife. Husband hereby waives any Interest he may have In Wife's vehicle. C. Indlvldusl Retirement Accounts, Pensions And Employment Benefits: Eaoh party shall retain sole ownership and control of his Iher IRA's, Pensions and other Employment benefits. D. Joint Bsnk snd Chsrge Accounts: All joint bank and charge accounts, credit card accounts and any other joint accounts shall be teTminated and each party shall take those steps necessary to have the other removed as a responsible party from any such aocount. E. Household Furnishings: Husband and Wife agree that all household furnishings have been divided between the parties to their mutual satisfaction, F. Property to Wife: The parties agree that Wife shall own, posses, and enjoy free from any claims of Husbend, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property together with any insurance policies covering that property, and any escrow accounts ? ~_(lnitiaIS) 4 ;/; )) ~(lnitia1S) ( Draft III June 11,1998 relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. G. Property to HusblJnd: The parties agree that Husband shall own, possess, and enjoy free from any claims of Wife, the Pf'OpeTty awarded to her by the terms of this Agreement. Wife hereby qultclelms, assigns and conveys to Husband all such property together with any insurance polloles covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sele to evidence tha transfer of anv and all rights in such property from Wife to Husband. H. Mlscellllneotls Property: All property not specifically addressed herein shall hereafter be owned by the party to whom the pToperty is titled, and if untitled, the party In possession. This Agreement shall constitute a sufficient bill of salo to evidence the transfer of any and all rights in such property from each to the other. I. rllx L1l1b/lity: The parties believe and agree that the division of property heretofore made by this Agreement is a non,taxable division of property between co- owners rather than l;l taxable sale or exchange of SlJch property. Each party promises i not to take any posl.ion with respect to the adjusted basis of the property assigned t him or her with resp~ct to any other issue which is Inconsistent with the position sot forth In the pTecedlng sentence on his or her Federal or State Income tax returns, 8. LIFE INSURANCE: Each part shall continue to own any life insurance policies currently in effect, without restriction as to the designation of beneficiaries. 9. ALIMONY: Both parties mutually waive all support, alimony and maintenance of any kind from the other party, ~<lnitialS) 5 p-<lnitiaIS) Draft III June II. 1998 Wife acknowledges and agrees that the provisions of this Ag lement providing for the waiver of alimony to her by her Husband are fair, adequate, and satisfactory to her and are based upon her actual need, her Husband's ability to pay, the duration of the parties' marriage end otheT relevant factors which have been takan Into consideration by the parties, Although the approval of this Agreement by a court of competent jurisdiction In connection with this action In divorce or annulment flied by Husband OT Wife shall be deemed an order of the court and may be enforced as provided in 12 Pa,C,S,A. Section 3701, as amended, this Agreement, insofar as It pertainG only to support for Wife and the payment of alimony fOllowing the entry of a final Decree In Divorce between the parties, may not be modified, suspended, terminated, or reinstated at the instance of request of the Wife or Husband, or subject to further order of any court upon changed circumstances of the Wife or Husband of a substantial or continuing nature, or for any reason claimed by Wife whatsoever, Upon that condition, Wile hereby accepts the provisions of this Agreement In lieu of and in full and final settlement and satisfaction of all claims and demands that she may now or hereafter have against Husband or her SUPPOTt and maintenance of herself and for alimony, and Husband and Wife further voluntarily and Intelligently waives and relinquishes any right to seek a modification, suspension, termination, relnstltutlon, or other court order with respect to the terms of this Agreement pertaining to the payment of support to Wife OT the payment of alimony by Husband. Husband acknowledges and agrees that the pToviGions of this Agreemant providing for equitable distribution of marital property are fair, adequate and satisfactory to him and are accepted by him In lieu of and in full and final settlement and satisfaction of any claims or demands that he may now have or hereafter have against the Wife for support, maintenance or alimony, Husband further voluntarily and intelligently waives and relinquishes any right to seek from the Wife any payment for support or alimony. ~(lnitiaIS) 6 fLy d-:(__(lnitiatS) , Draft III June 11,1998 10. ALIMONY PENDENTE LITE, COUNSEL FEES AN EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties lire fair, adequate and satisfactory to them, Both parties agree to accept the provisions set forth in this Agreement In Lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel faes or expenses or any other provision for their support and maintenance before, during and afteT the commencement of the proceedings for divorce or annulment between the parties, 11. INCOME TAX RETURNS: The parties have heretofore filed joint federal and state tax returns. Both par'tles agree that In the event any deficiency in federal, state or local income ta.x Is prapased, 131' any assessment af an such tax is made egalnst either af them, each will Indemnify and hald harmless the other from and against an lass or liability far any such tax deficiency ar assessment and any loss or liability far any such tax deficiency or assessment and any Interest, penalty and expense Incurred In cannectian therewith, Such tax, Interest, penalty or expense shall be paid salely and entirely by the individual wha is finally determined ta be responsible for the actions, misrepresentations or failures ta disclose sepaTate incame resulting in tax liability. The parties shall file separately in ._ and thereafter, 12. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise pravided each party may dispase af his 131' her praperty in any way, and each party hereby waives and relinquishes any and all rights he 131' she may naw have 131' hereafter acquire, under the present 131' future laws af any jurisdictian, ta share in the property 131' the estate of the atheT as a result af the maTital relatianship, Including wlthaut limitation, dawer, curtsey, statutary allawance, widow's allowance, right to take intestacy, right ta take against the will af the other, and right ta act as admlnistratar or executor af the ather's estate. Each will, at the 9k (Initials) , 7 ~(I"iti''') Draft NI June 11,1998 rflque$t of the other. execute, acknowledge and deliver any and all instruments which may be necossary or advisable to carry into effoct this mutual waiver and relinquishment (If all such interests, rights and claims end both parties will revoke prior wills or testamentary documents. 13. AGREEMENT NOT PREDICA TED ON DIVORCE: It Is specifically understood and agreed by and between the parties heTeto and each of the said paTties does hereby warrant and represent to the other. that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for Institution, prosecution, defense, or for the non- prosecution OT non,defense of any action for divorce; pTovlded. however. that nothing contained In this Agreement shall prevent or preclude eltheT of the parties hereto from commencing. instituting or prosecuting an action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has beon, mayor shall be instituted by the other party. or from making any just or proper defense thereto, It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to execute this, Agreement. Husband and Wife each knOWingly and understandingly hereby waivJs any and all possible , claims that this agreement is, for any reason illegal or for IIr1Y reason whatsoever. unenforceable in whole or In part, Husband and Wife each do hereby warrant. covenant and agree that, in any possible event. he and she are and shall forever be estopped from asserting any illegality or unenforceabllity as to all or any part of this Agreement. 14. SUBSE~UENT DIVORCE: Husband at his cost by his counsel has flied an action for divorce under 3301 (c) or (d) of the Divorce code. ~jlnlliaIS) 8 cP-(lniI18IS) Draft 111 June 1 1,1998 Both parties agTee to execute Affidavits 01' the Respondent will execute Consent or a Counter Affidevit to enable counsel for Husband to proceed with 8 no.fault divorce as soon as possible, providing Wife with a duplicate decree. The parties further agree that each of them shall be responsible for their own attorney's fees. The parties shall be bound by the terms of this agreement, which shall be Incorporated by reference into the Divorce Decree, shall not be merged in such Decree, but shall In all respects survive the same and be further binding as an enforceable contract, conclusive upon the parties. 16. BREACH AND ENFORCEMENT: If either party breaches any provision of this Agreement, the otheT party shall have the right at his or her election, to sue for damages for such breach, or seek such other remedios or relief as may be responsible for payment of logal feas and costs incurred by the other in e"forcing his or her rights under this Agreement, Reasonable inteTest shall be assessed from the date of breach. A. This Agreement mll'1' be specifically enforced by either Husband or Wife In Equity, and the paTties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law, The parties do not Intend or purport hereby to Improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and In recognition of the general jurisdiction of Courts In Equity oveT agreement such a8 this one, B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and In such event it is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this ~(lnitillIS) 9 JL.IJ.ill.J,) Draft #1 JUlie 11, 1998 Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid undue delay. C. Each party further hereby agrees to pay and to save and hold harmless the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable lor, in any way whatsoever, or shall pay upon, or in terms or provisions of this Agreement by reason of any of the terms or provisions 0'1 this Agreement by reason of which either party shall be obliged to retein or engage counsel to Initiate or maintain or defend proceedings against the other at law or equity or both in any way whatsoever, provided that the party who seeks to recover such attorney's fees, and costs of litigation must first be successful In whole or in part, before there would be any liability for attorney's fees and costs of litigation. It is the specific agreement and intent or the parties that a breaching or wTongdolng party shall bear the burden and obligation of any and all costs and expenS3S and counsel fees incurred by himself or heroelf as well as the other party in endeavoring to protect and enforce his or her rights under this Agreement, 16. ADDITIONAL INSTRUMENT: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provil:lions of this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explelned to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 9~lnitinIS) 10 rF-<I.,tloI,) Draflllt June 11,1998 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertaklrtgs other than those expressly set forth herein, Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and divisions of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other Televant factors which have been taken into consideration by the parties, Both paTties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfection of all claims and demands that they may now have or heTeafter have against the other for equitable distribution of their property by and any court of competent jurisdiction pursuant to 23 Pa,C.S.A, Section 3501 m. ~ or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 19. DISCLOSURE: Husband and Wife represent and warrant to the other that he or she has made a full and complete disclosure to the otheT of all assets of any nature whatsoever In which eitheT party has an interest, the sources and amount of the Income of such party of every type whatsoever and of all other relevant and material facts relating to the subject matter of this Agreement. 20. MOD/FICA TlON AND WAIVER: A modification or waiver of any of the provisions of this AgTeement 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 strict peTformance on any of the provisions of this AgTeement shall not be construed as a waiver of any subsequent default of the SAme or similar nature, m ./ ~_(lnitiaIS) 11 cP-L(lnltiaIS) Draft III June II, 1998 21. PRIOR AGREEMENT: It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and have no effect. 22. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They have no effect whatsoever in determining the rights or obligations of the parties. 23. INDEPENDENT SEPARA TE COVENANTS: It is specifically undeTstood and llgTeed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and Independent covenant and agreemant, 24. APPLICABLE LA W: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 25. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be vcid 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 operetlon. 26. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. ~(lnltiaIS) 12 #L<'''''') (P I' . "." f;J ,::;; li . ." ! i t'L' ('I ( If G , I". (! I , (,'\i I I, ,. ~\ ':') t) 6\ (".) ,. JOHN W. ROBINSON. JR.. Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY.PENNSYLVANIA . , VI. · NO. 98-3286 . JANINE L. ROBINSON. Defandant · CIVIL ACTION - LAW · IN DIVORCE PRAECIPE TO TRANSMII...B.ECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1, Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2, Date and manner of service of the complaint: Sorved upon Defendant by United States Mall, certified, restricted delivery, return receipt requested on June 11, 1998. 3, Date of execution of the affidavit of consent required by Section 3301 leI of the Divorce Code: by plaintiff: September 17, 1998. by defendant: September 21,1998, 4. Date of execution of the Waiver of Notice In Section 3301 (c) Divorce: by plaintiff: September 1 7, 1998, by defendant: September 21, 1998, 5. Related claims pending: None, 6. Date and manner of service of the notice of Intention to file praecipe to, transmit record, a copy of which Is attached, If the dllcree is to be entered under Section 3301 (dH1 HI) of the Divorce Code. N/A 7. Plaintiff and Defendant have signed a Separation and Property Settlement Agreement dated June 16, 1998. WHEREFORE, the Court is requested to enter a Final Decree in Divorce In compliance with Section 3301 (c) of the Divorce Code and Pa, R.C,P, 1920.42(a)(1) and to incorporate the terms of the Separation and Property Settlement Agreement in accordance with Section 301 (a)(1) and (4) and 40Hbt)Of the Divorce Code, /"- ~ , ~ /4:A~) ,. ) Edward r Welntraub~e ~ Attorney for Plaintiff JOHN W. ROBINSON, JR., Pllllntlff VI. · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : NO. Y J. 3;,) &'.5" (I{ ~)-LZ-< · CIVIL ACT'ION . LAW · IN DIVORCE JANINE L. ROBINSON, Defendllnt NOTICE To DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the olaims set forth In tha following pages, you must take prompt action. You are warned that if YOIJ fail to do so, the case may proceed without you and II 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 aT relief requested in these papers by the Plaintiff, You may lose money OT propeTty 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 tho PTothonotaTY, Cumberland County Court House, 1 Court House Square, Carlisle, Pennsylvania, 17013,3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKIE 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. f:h.( A'Sso(~. CUMBERLAND COUNTY tAW-Yt'A FI~~EhI"lA\;;"-5!" v1GJ:., , GGl::lAT ABMlr41BTAATOfl ,~A./ bpf'( 'I CUrAerRt.,",1 1~COi.ll"LU GTJUH I AUMlN'::HAA'VA' CARLISLE, PA 17013 (717) 24a Bf!eQ ,.;; 4-1 ,j I ft.? ier-e.. / it (';1 \..... :[' (\") 1'., I~-~ .. ~]i IJ.i~"~-! - 'q I;: IIJt; "I'" -) .' ~'..( -f.: :i, ,'i:: ~:-: 1 (rib fi1" \.[) ~) flJ "{" .'J" ["(I" It "1.. n i'ij :t.:' I..,{ ::.1 ill '.I.. r ) ';ii l~ <:0 ~" 'r.J 0' 0 JOHN W. ROBINSON, JR., . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY,PENNSYLVANIA . VB. . NO. 98.3286 . JANINE L. ROBINSON. . CIVIL ACTION. LAW Defendllnt . IN DIVORCE AFFIDAVIT OF SERVICE' COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF ". 'Ih AND NOW, this J.2- day of June. 1998 peTsonally appeared before me, a Notary Public in And for the aforesaid Commonwealth And County, Emily A, Fritz, who being duly sworn according to law, deposes and says that on June 11, 1998. she mailed a certified copy of a Complaint in Divorce by certified mail, restTicted delivery, return receipt requested, to Janina L. Robinson at 228 North 25th Street, 2nd Floor. Camp Hill, Pennsylvania, 17011. and the same was received by her on June 18, 1998 as indicated by the return receipt card which is attached ~ereto, , / ( , .,~Lu"~ / J Emily A, Frit" ~~) . ,IV Sworn to and subscribed before me on this ~day of ~/tL, 1998, ~~{~ Notatlnl Saal Queantl,J, Strernrnol. Notary Public Ham'burg, Dnupl1ln Court My Commls,;loo Expires Oct, 2,Y2000 ,:, I ~ r'rj i__: ..:.. 'u./(':' //) :.:~ U ';.'~ . C.) l.l_ : . Li. (: C'J , ) , c._, I __:1..:., u {:C';c~ . 5 i i IU,J !Il (,L ,,) ~ , , , , t.) , (,) JOHN W, ROBINSON, JR., * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY,PENNSYLVANIA * VI. * NO. 98.3286 * JANINE L. ROBINSON, * CIVIL ACTION. LAW Defendant * IN DIVORCE AFf'IDAVIT OF CONSFJtl 1. A Complaint In Divorce under Section 3301 (c) of the Dlvoroe Code was flied on June 11, 1998, 2, The marriage of Plaintiff and Defendant Is irretrievably broken and ninety 190) days have elapsed from the date of the filing and service of the Complaint. , 3, I consent to the entry of a final decree in dlvoroe after service of notice of Intention to request entry of the decree, I verify that the statemflnts made in this affidavit aTe tTue and correct. I understand that false statements herain are mad a subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities, Date: 9- J7~7(r JOHN W. ROBINSON. JR.. . IN THE COURT OF COMMON PLEAS Plelntlff . CUMBERLAND COUNTY ,PENNSYLVANIA . VI. . NO, 98.3266 . JANINE L. ROBINSON. . CIVIL ACTION. LAW Defendent ,. IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 11. 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after servioe 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 mAnA subject to thEJ penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities, Date: 1, z/, 1P ~. ,,' rJne L. Robjns~n. D~fen JOHN W. ROBINSON, JR.. . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY ,PENNSYLVANIA . VI. . NO, 98-3286 . JANINE L. ROBINSON, . CIVIL ACTION - LAW Dafendant . IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(01 OF THE DIVORCE CODE 1 , I consent to the entry of a final decree of dlvoroe 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 enteTed 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, Section 4904 relating to unsworn falsification to authorities, Date: 1. Zf. c;t l1'A,'~f L .A~~~, ~Robinson, Defendant