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H10!lI$7f1(VUO
COUNTY
Cumberland
1. NAME
(First)
Herman
3. RESIDENCE Stroot or RD
1108 Brandt Avenue,
5. NUMBER
OF THIS
MARRIAGE 1
B. MAIDEN NAME
Earnes t
10, RESIDENCE
3 Dubs
12, NUMBER
OF THIS
MARRIAGE
Circle
15. PU.CE OF (County)
THIS
MARRIAGE
NUMBER OF
CHILDREN THIS
MARRIAGE
17A.
Perry
17B.
o
DIVORCE
00
Ciry. 80ro. or Twp
New Cumberland
6. RACE
WHITE BLACK
(Fltsl/
Roxane
S'r061 or RD.
1
6. RACE
WHITE
00
NUMBER OF DEPENDENT
CHILDREN UNDER 18
o
IRJ
o
Ciry. Bora. or Twp.
Mechanicsburg
BLACK
o
COMMONWE,t.UH or PElmSYlVAtUA
C1rrA/HMEm OF HEAHIl
VITAL RECORDS
RECORD OF
OR ANNULMENT
(eHEeK ONE) 0
STATE FilE NUMBER
STATE FilE DATE
HUSBAND
(~Mdle)
IL.1sr)
DATE (Man/h)
OF
.'RTH 08
J.
Daihl
(D,ty)
to
Cumberland
Slare PLACE (S/ilIO or ForOlgn Country)
OF
PA .'RTH Pennsylvania
1 USUAL OCCUPATION
Supervisor/Management - AMP
County
OTHER (Specl'y)
o
WIFE
IMiddlIJJ
{Las'l
9
DATE (Month)
OF
BIRTH 0 1
E.
Daihl
(Day)
17
Yenr
57
Yoar
66
Cumberland
Stals 11. PLACE (St.lle or Foreign Country)
OF
PA .'RTH Pennsylvania
14. USUAL OCCUPATION
Documentation Specialist
County
OTHER (Specify)
o
16,
DATE OF (Month)
THIS
MARRIAGE 05
DECREE GRANTED TO
HUSBAND WIFE
o ~
20, NUMBER OF HUSBAND WIFE SPLIT CUSTODY OTHER (Specdy)
CHILDREN TO 0 0 0 N/A
CUSTODY OF
22, DATE OF DECREE (Month) (Day) (Yoar)
24, SIGNATURE OF
TRANSCRIBING CLERK
(Sraloor Forolgn Country)
Pennsylvania
18. PLAINTIFF
HUSBAND WIFE
o 00
19,
21. lEGAL GROUNDS FOR
DIVORCE OR ANNULMENT
OTHER (Specify)
o
Section 3301(c)
(Day)
DATE REPORT SENT (Man/h)
10 VITAL RECORDS
(Dayl
27
PNC Bank
(year)
95
(Year)
I.
Thc partics intcnd to maintain scparatc and permancnt domieilcs and to livc apart from
each other. It is the intcnt and purposc of this Agrecmcnt to sct forth thc respective rights and
duties of the parties while thcy continuc to livc apart frOln caeh other.
2.
The parties have attcmpted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever detennine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing, Neither party shall
molest, harass, injure, threaten or interfere with the other party in any matter whatsoever. Each
party may carry on and engage in any employment, profession, business or other activity as he or
she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the
uses, ownership, enjoyment or disposition of any property now owned and not specified herein or
property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
Page 2
The adequacy of thc considcration for all agrcemcnts hcrcin containcd is stipulatcd, confcsscd,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or shc,
respectively:
(I) is represented by counsel of his or her own choosing (Daniel W. DeAnnent,
Esquire for WIFE) or has been advised of the right to legal counsel and has
chosen to proceed without such counsel (HUSBAND);
(2) is fully and completely infonned of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agreement; and
(6) fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution,
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualifY as marital property under the Pennsylvania Divorce Code, Title 23, Section 3301(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that confonns to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Page 3
Marital Property is not intended hy 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.
It is the further purpose of this Agreement to settle forever and completely any ohligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Patty acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
mamage.
7.
REAL ESTATE: WIFE hereby agrees to transfer to HUSBAND all right, title and
interest by virtue of a quit claim deed in the real property which comprises the marital residence
located at 1108 Brandt Avenue, New Cumberland, Cumberland County, Pennsylvania.
HUSBAND agrees to indemnify and hold harmless WIFE from any and all liability which may
arise, subsequent to WIFE vacating the premises, out of or occuning in relation to the subject
property.
Page 4
8.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay support to the WIFE. WIFE will not provide any financial support to the HUSBAND. The
parties also waive any right they have to receive alimony or alimony pendente lite payments
from the other following the entry of the Divorce Decree in this matter.
9.
PERSONAL PROPERTY: The parties hereby agree that all personal property acquired
during the marriage has been equitably divided between the parties to their mutual satisfaction
and agreement.
The WIFE hereby waives all right and title and interest which she may have in any
personal property designated as HUSBAND'S by virtue of the parties' prior physical division of
the marital property. HUSBAND likewise waives any right, title and interest which he has in the
personal property designated as WIFE'S by virtue of the parties' prior physical division of the
marital property, Henceforth, each of the parties shall own, have and enjoy independently of any
claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE, respectively, with fuJl power to the HUSBAND or the WIFE
to dispose of same as fully and effectually, in all respects and for all purposes as ifhe or she were
unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
Further, WIFE does hereby release, waive and forever discharge HUSBAND from any
and aJl claims she has now, ever may have or ean at any time have against HUSBAND or his
Page 5
estute or uny part thereot~ whether arising out of formal contructs, engagements or liabilities of
HUSBAND, arising by way of widower's right or under the intestate Law arising by any right to
take against the HUSBAND'S will.
HUSBAND does hereby release, waive and forever discharge WIFE from any and all
claims he has now, ever may have or can at any time have against the WIFE or her estate or any
part thereof, whether arising out of fonnal contracts, engagements or liabilities of WIFE, arising
by way of widower's right or under the intestate Law arising by any right to take against the
WIFE'S will.
10.
ASSET ACCOUNTS: The parties hereby acknowledge that they hold joint title to One
Hundred (100) shares in a PNC Bank, N .A. Brokerage Account, bearing account # 57768732,
which shares were purchased by the parties during their marriage. Further, the parties agree that
said shares shall be divided equally between the parties, with HUSBAND retaining Fifty (50)
shares and WIFE retaining Fifty (50) shares of said brokerage account, respectively. The parties
agree to take all necessary steps to effectuate the transfer of said shares into their respective
individual names within thirty (30) days ofthe date of this Agreement, and to cooperate with one
another in accomplishing said division of shares of the PNC Bank, N .A. Brokerage Account.
II.
AUTOMOBILES: The parties hereby agree that WIFE shall retain the 1994 Volvo
sedan which is currently in her possession, and the HUSBAND shall retain the 1994 Saturn, the
1984 GMC pickup truck, the 1971 Corvette, the 1957 Bel Air Sedan and the 1983 Harley
Davidson motorcycle which are currently in his possession, It is expressly acknowledged and
Page 6
aflinned that all vehicles retained by IIUSBAND were purchased prior to the marriage between
the parties.
HUSBAND hereby waives all right, title and interest in the 1994 Volvo sedan currently
in possession of WIFE. WIFE shall hold HUSBAND harmless for any and all liability
associated with the purchase, use and ownership of the 1994 Volvo sedan and any vehicle she
may now or in the future own, and shall be solcly responsible for all insurance and other
financial obligations associated with said vehicle.
WIFE hereby waives all right, title and interest in the 1994 Saturn, the 1984 GMC pickup
truck, the 1971 Corvette, the 1957 Bcl Air Sedan and the 1983 Harley Davidson motorcycle
which arc currently in his possession. HUSBAND shall hold WIFE hannless for any and all
liability associated with the use and purchase of the 1994 Saturn, the 1984 GMC pickup truck,
the 1971 Corvette, the 1957 Bel Air Sedan and the 1983 Harley Davidson motorcycle and any
vehicle he may now or in the future own, and shall be solely responsible for all insurance and
other financial obligations associated with said vehicle(s).
12.
MARITAL DEBTS: The parties hereby agree that the HUSBAND shall assume all
liability for any and all debt which may now or in the future exist relating to the any credit card
accounts which are titled in HUSBAND's name alone. WIFE shall assume all liability for any
and all debt which may now or in the future exist relating to the any credit card accounts which
are titled in WIFE's name alone. The parties hereby acknowledge and affinn that, as ofthe date
of this Agreement, there are no open or active joint credit accounts of any type, and further that
all credit cards, lines of credit, private credit accounts or any such other extensions of credit are
Page 7
in the individual name of the party who negotiated said credit. In addition, the parties
acknowledge and aflinn that there has been a filII and filiI' disclosure to the other party of all
debts and obligations, including but not limited to any outstanding or open credit accounts.
It is mutually agreed by and betwcen the parties that WIFE shall assume all liability for
and pay and indemnify the HUSBAND against all debts incurrcd by WIFE after the date of
separation. WIFE represents and warrants to HUSBAND that since the parties' marital
separation she has not contracted or incurred any debt or liability for which HUSBAND or his
estate might be responsible and WIFE further represents and warrants to HUSBAND that she
will not contract or incur any debt or liability after the execution of this Agreement, for which
HUSBAND or his estate might be responsible. WIFE 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.
HUSBAND shall assume all liability for and pay and indemnity the WIFE against all
debts incurred by HUSBAND after the date of separation, HUSBAND represents and warrants
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and warrants to WIFE that he will not contract or incur any debt or liability after the execution of
this Agreement, for which WIFE or her estate might be responsible. HUSBAND 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.
13.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
Page 8
but not limited to rctircment, profit sharing, 40 I K or mcdical benefits of cither party, shall be
thcir own. WirE waivcs all right, titlc and claim to HUSBAND's cmployce, pcnsion and
rctircmcnt benefits, and HUSBAND waives all right, titlc, and claim to any of WIFE'S
employee, pension and rctiremcnt bcncfits.
HUSBAND agrees to take any and all action necessary and to cooperate, within thirty
(30) days from the datc of'this Agrcement, in thc removal of his name as a beneficiary or owner
from any and all pension, profit sharing or other retirement accounts which WIFE may currently
possess. Similarly, WIFE agrecs to take any and all action necessary and to cooperate, within
thirty (30) days from the date of this Agreement, in the removal of her name as a beneficiary or
owner from any and all pension, profit sharing or other retirement accounts which HUSBAND
may currently possess.
14.
BENEFITS AND BANK ACCOUNTS; WIFE agrees to waive all right, title and
interest which she may have in the following joint savings or checking or any other bank
accounts which arc primarily in the use and control of HUSBAND:
a) PNC Bank, N.A. Checking Account - Account No. 5140014431;
b) PNC Bank, N.A. Savings Account - Account No. 5130042746;
c) PNC Bank, N.A. Certificate of Deposit - Account No. 2001011475.
HUSBAND agrees to waIve all right, title and interest which he may have in the
following joint savings or checking or any other bank accounts which are primarily in the use
and control of WIFE:
a) PNC Bank, N.A. Checking Account - Account No. 5080244584;
b) PNC Bank, N.A. Savings Account - Account No. 5130314596.
Page 9
HUSBAND agrees to cooperate in closing or removing WIFE'S name from any and all
joint accounts which arc designated ahove as being in the primary control of the HUSBAND
within fifteen (15) days of the execution of this Agreement. Similarly, WIFE agrees to cooperate
in closing or removing HUSBAND'S name from any and all joint accounts which arc designated
above as being in the primary control of the within fifteen (15) days of the execution of this
Agreement. Prior to the removal of each party's name from the respective accounts, each party
hereby agrees not to deplete the assets of those bank accounts which are in the primary use and
control of the other party, as referenced and enumerated above in this paragraph 14.
15.
DIVORCE: The parties both al,7fee to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
16.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
Page 10
17.
ADDITIONAL INSTRUMI!;NTS: Each of the parties shalllrolll lime 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 provisions of this
Agreement.
18.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have either been fully explained to the parties by their respective counsel, or have been fully
reviewed and understood if not represented by counsel, and each party acknowledges that the
Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is not the
result of any duress or undue influence. The parties agree that unless otherwise specifically
provided herein, this Agreement shall continue in full force and effect after such time as a final
Decree in Divorce may be entered with respect to the parties. The parties further agree that the
terms of this Agreement shall be incorporated into any Divorce Decree which may be entered
with respect to them. It is the parties' intent that this Agreement does not merge with the Divorce
Decree, but rather shall continue to have independent contractual significance. Each party
maintains his or her contractual remedies as well as court ordered remedies as the result of the
aforesaid incorporation or as otherwise provided by law or statute. Those remedies shall include,
but not be limited to, damages resulting from breach of this Agreement, specific enforcement of
this Agreement and remedies pertaining to failure to comply with an order of court or agreement
pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set
forth in the Pennsylvania Divorce Code or other similar statutes now in effect and as amended or
hereafter enacted.
Page 11
19.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there arc no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
20.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
21.
PRIOR AGREEMENTS: 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 of no effect.
22.
PAYMENT OF COSTS: Each party shall be responsible for their own attorneys fees
incurred in the settlement ofthe divorce and economic issues surrounding this divorce.
23.
WAIVER OF CLAIMS AGAINST EST A TES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result ofthe
marital relationship, including without limitation, dower, cUltesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
Page 12
ROXANE E, DAIIIL,
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
98- 3<1c/1 CIVIL TERM
HERMAN J. DAIHL,
Defcndant
IN DIVORCE
NOTICE
You have been sued in court. I f you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are wanlcd that if you fail to do so, the case
may proceed without you and a decree in divorce or annulmcnt may bc entercd against you by
the court. A judgmcnt may also be cntcrcd against you tor any other claim or relief requcsted in
these papers by the plaintitI You may lose moncy or property or other rights important to you,
including custody or visitation of your childrcn.
When the ground tor divorcc is indignitics or irrctricvablc brcakdown of thc marriagc,
you may request marriagc counseling. A list of marriagc counselors is availablc in thc Office of
the Prothonotary, Cumberland County Courthouse, Carlislc, Pcnnsylvania 17013.
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 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liherty Avenue
Carlislc, Pcnnsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITI( DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is requircd by law to comply with
the Americans with Disabilities Act of 1990. For intonnation about acccssible lilcilitics and
reasonable accommodations availablc to disabled individuals having busincss before the court,
pleasc contact our office. A II arrangcments must bc madc at lcast 72 hours prior to any hcaring
or busincss bctorc thc court. You must attcnd the schcdulcd confcrcncc or hearing.
. ,: ;.:_;~:,'::;~t.-:'l.:;':::~~=
VERIFICATION
Thc lorcgoing Complaint in Divorcc is bascd upon inlormation which has been gathcrcd
by my counscl and mc in thc prcparation of this action. I havc rcad thc statcments madc in this
Complaint and thcy arc true and corrcct to thc bcst of my knowlcdgc, inlormation and bclicf. I
understand that falsc statcmcnts hcrcin lIladc arc subjcct to thc pcnaltics of 18 Pa.C.S.A. Scction
4904, rclating to unsworn lnlsification to authoritics.
~w, ~. ~.1b
ROXANE E. DAIHL
Date:
June 17
,1998
IWXANE E. I>AIIIL.
1}laintiIT
: IN TilE COURT OF COI\Ii\ION I'LEAS OF
: ClJI\IBEIU,ANI> COUNTY. PENNSYLVANIA
v.
CIVIl. ACTION - LAW
911- l'Ic'/CIVIL TERM
HERMAN .J. DAIHL,
Defendant
IN IHVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
Thc Plaintift~ bcing duly sworn according to law. deposcs and says:
I. I have bccn advised of thc availability of marriagc counscling and undcrstand that I
may requcst that thc court rcquirc that my spousc and I pal1icipatc in counscling.
2. I undcrstand that thc court maintains a list of marriagc counsclors in thc Prothonotary's
Officc, which list is available to mc upon requcst.
3. Being so advised, I do not rcquest that thc court rcquirc that my spousc and I
participatc in counseling prior to a divorcc dccrcc bcing handcd down.
I vcrify that thc statcmcnts madc in this affidavit arc truc and COITCCt. I understand that
false statements hercin made arc subjcct to thc pcnaltics of 18 Pa. C.S. Scction 4904 relating to
unswol11 falsi fication to authoritics.
I>ate:
June 17
,1998
~[~
ROXANE E. DAIHL
P 492 3Ll7 O'ii'
US Paslal ServIce
Receipt for Certified Mail
No Insuranco Covorago ;'lrovidcd.
Do not uso for Intornational Mail Soo (avof"SL'
y.nllo
HERMAN J DAIHL
Slmel & Number
1108 BRANDT AVE
Post Office, Slalo, & liP Code
NEW CUMBERLAND PA
Postage X S
17070
,n
Certified Fco X \ , '1 <:
oJ ".~'
Special Delivery Fee
cslricted Delivery Fee X II -, C
"' ('., I..,)
m AetumAecClp
m X \.\0
Whom &: Dale Delivered ~ Retum Al.'Ccipt Showing \0 Whom,
<: Date, & Addressee's Address
c:i S S, C] ~
o TOT At Postage & Fees
'"
'" PoslmarkorOalc
E DAN
0
u. 06-18-98
U)
<l. DAIHL DIVORCE COMPLAIIlT
':i SENDER:
!! -Complete Items 1 and'or 2 lor addillonalaervices.
'" -Complete IIams 3, 40, and 4b.
~ II Print your name and address on tho reverse of this form so that we can relum Ihls
Ii card to you.
> IIAUach this form 10 the Ironl of the mal1ploc8, or on the back II space does not
e permit.'-
G) -Write-Return Rocelpt Requested' on the rnallpiece below the ar1lcle numher.
5 -The Return Receipt will show to whom the arllcle was delivered and the date
c delivered.
o
~ 3. Article Addressed to:
"
'ii.
E
8
I elso wish to recelvo the
following services (for an
extra fee):
1.
e's Address 11
t:.
Restricted Delivery .:l
Consult postmaster or ea.
4a. Article Number
HERMAN J DAIHL
HOB BRANDT AVE
NEW CUMBERLAND PA 17070
P 492 347 092
4b. Service Type
o Registered
o Express Mall
o Return Recelpl for Merchandise
7. Date of Delivery
5. Received By: (Print Name)
IlD Certified
o Insured
o COD
8. Addressee's Address (Only if requested
and feals paid)
!; 6. Slg at re: (Addrassae or Agent)
~ X
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Domestic Return Receipt
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ROXANE E. DAIHL,
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
: ClJl\lBERLAND COlJNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
98-34119 CIVIL TERM
HERMAN J. DAIHL,
Dcfcndant
I!'; DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. A Complaint in Divorcc undcr Scction 3301(e) ofthc Divorcc Codc was filcd on June
18,1998.
2. Thc marriagc of Plaintiff and Dcfcndant is irretrievably brokcn and nincty days havc
elapsed from the datc of filing of the Complaint.
3. I consent to the entry ofa final Dccrcc of Divorce without noticc.
4. I understand that I may lose rights conceming alimony, division of propcrty, lawyer's
fees or expenses if I do not claim thcm bcfore a divorce is granted.
5. I understand that I will not be divorccd until a divorce dccrce is entered by thc Court
and that a copy of the decrec will be scnt to me immediately aftcr it is filcd with the
Prothonotary.
I verify that thc statcments made in this affidavit are truc and corrcct. I undcrstand that
false statements herein madc are subjeet to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authoritics.
Datc: November 13th .1998
~.o.~.~
ROXANE E. DAIHL
Plaintiff
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