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Home My WebLink About98-04504 i , i \ , , \ I I j ~\ 0: , "I' , ~! ct' ~\ , , I I , ~! 1 , ~l 01 ..,1 ~1 'it' ~ , ! / f ",,~. " ! /-;.\/ I' L ~I I I -::-i :) ~ - i ~i i j ::r-' 0' ""I ::t-1 I ~j ~' .1 ~j \ _ ,_' 'T ,~:.'., t,~"l "'n.' ~.: .( a".:;,""'..' {.l_~>:", '~^".' ',',,':,,' ~ ~J., ~..':.^>,' .'~:'.. ,.'\:.. ",',', , ~ /",;'~' '-.,,'\' ",' ':~, , .' .:.;. .:.:. .:.:. .:.:. .:.:' .:.:. .:.:. ':.:. .:0:. .:.:. ':.:. -:.:. .:.:. .:.: ';':' .:.: .:.:. .:.;. ':.:. .:.:. :- .:.:- .:.:. .:.:. .:.:. .:.:' -:.:. .:.:. .:.:. ,:0:-',;4 ~\' -.---.--.. ..- --.' ~~-'.- --~- ,...-. , , . , , . , , . .,.. ". .._. ----_._~- ~ .. ;1 ~\ ~\ ~I ~\ ',' ~ ~ '.' ~ $ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~t €fv.~h" ;,~;\,tl'rk~ t /~~ J:..:.l~(',..! \, ..,,~:,,:-/,~."r PENNA, JAMES B.PEARSON, Plaintiff l\ I). 98-:-4504 CIVIL IlJ ~ \'1'1'.';IIS ~ DENA A. PEARSON, s ~ '.' Defendant .' ~ y ~ :!! ~ DECREE IN D I V 0 R C Eit ~; ~ ~A .. ..LCo ..... i 9 99..,. it is ordered and ~ ... ~ '.' ~ .~ '.' ~ ~ ~ ~ $ $ $ ,', i!- ~ ~ ~ !~, S ,'. ~ ~ . '.' ,', i!- ~ " ~ ~ .. ~ $ ~ ~ .' ~ ~ ~ ~ ~ ~ $ * ~.;. p ~ ~~;., ."J. y ~ ~ ~.: . ,'~,.' ~ ~ . ~ ~ ~ .. _~_ _.____....__.. ..,..v.. .. .. . _ ._~. v. v'_" v' .v'" ..-- . . .... .. : ~ ....:...~:...:.:. ':0:' .:.:. .:.:. ...:. '. " -:.:. .:.:.'.:.:. .:.;. .:.:. .:.;. .:.:. -:.;. .:.;. .:.:. .:.:- .:.:..:.:-.:.:. ,':.:' -:.:..:>;..:.:- -:<:. .:.;. .:.;..:.;.. ~ y AND NOW, . ... ~ decreed that..... E.~ .~....~~~W~o~.............,.............., plaintiff, and.. ,I?E~!\. .~:. ~.r:~~~P.~.......,.... ... ", ., .... .."...,..... defendant, are divorced from the bonds of matrimony. ~ ~ ~ ~ ~.~ ~ ~ ~" 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; ~ y .~t:~. !'I.~r:J;' ~~.Q€!. ?,e.t: H!""IT!€!I.lj;. .!\gr!".>~n)~t1:t. ,<J" t.e.<1 . f,,)J.r.l,1ax.y. .12." .199.9. . . . . , ,i.~ .?~.r.e:?~, .i,r;~?r}:(~7~,~e:~. ~.~~<?, .t.~~~. p'~C;-;.~.~ .~:l. .1?+y~,~c;~:....,.,..,.., ~ ~,~ $ ,', ~ ~ / [ly ~ '#'" ) 1"1 fN) /:.( ':,. ';;":' . / ',-b ."J'.,,/.';~ .~. (( 'f. (~ (j~',,:/ 1';'/' ,',..t.., .:,.<. .....:.I'j ~~ If' ? 1"/ c/' L7' / r // , " ,'/ //..'1(;.,.(' IJO/,-f''''i:/ ,6/"-: /.' , . :" . ,'_ I "_, . ".1. ". , ,,' " {.-, .'.' '." ".<,' ,.' I>. ,,' I., . '. ,~ .. ' .' , O' ~ .. ~ .....,'.- , ....-,~-r:,-~~":"_~.".~ J . l/.w O.FfICE OF THOMAS D. GOULD ATtORNEYS Al lAW 2 EASI MAIN STREET' SH1REMANSTOWN. PA \7011 717.731.1~61 .......-.------ _.., ..: tN: .",.,;::->;,::~~~'i;...':,l;'::",,"''''''''''''''.''''''''"''--"'~''''''-~~...- MARRIAGE SETTLEMENT AGREEMENT (~-t1. THIS AGREEMENT made this and between James B. Pearson, "Husband,") and Dena Ann Pearson, "Wife") . day of rt~'~R'Y , 199?, (hereinafter referred to (hereinafter referred to by as as WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on January 2, 1992; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, there was one (1) child born of this marriage, James Brandon Pearson/ Jr., born 12/1/94; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; 1 . SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE Each party shall be free from interference, authority, and contact by the other as fully as if he or she were single and unmarried except as maybe necessary to carry out the provisions of the agreement, Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence/ separate and apart from the other, and each of the parties hereto completely understand and agree that neither shall do or say anything to the child of the parties at any time which might in any way influence the child adversely against the other party. 1 3. DIVISION OF PERSONAL PROPERTY The parties have agreed to divide and have already divided between them to their mutual satisfilction the personal affects, household furniture and furnishings and all other articles of personal property which heretofore have been used by them in common, Neither party will make any claim to any such items which are now in the possession or under the control of the other. 4. AUTOMOBILES Husband is the owner of a 1993 Dodge Stealth. Wife is the owner of a 1997 Chevrolet Cavalier. The parties agree to maintain their separately owned vehicles and shall be solely responsible for all payments, maintenance, insurance and other costs and fees related to their respective vehicles. Each party agrees to indemnify and hold the other harmless for any and all liability related to their respective vehicles, Wife acknowledges that her vehicle is encumbered by a loan with the Navy federal Credit Union that is in Husband's name. Husband agrees to continue to allow Wife's vehicle loan to be in his name provided Wife indemnifies Husband and assumes sole and complete responsibility for the payment of that loan. If Wife fails to make timely payment on Husband's loan, Husband may pay the amount due on the loan and deduct that amount from his past, present or future child support payment to Wife. Wife, at anytime, may refinance her vehicle and payoff Husband's loan. 5. MARITAL DEBTS There are no outstanding joint marital debts. Except for Wife's vehicle loan indicated above, Husband shall be responsible for all debts solely in his name and Wife shall be responsible for all debts solely in her name. Husband shall indemnify and hold Wife harmless for any debt in his name, including but not limited to his vehicle loan, Wife shall indemnify and hold Husband harmless for any debt in her name, including but not limited to her stuuent loans and Husband's loan on her vehicle as indicated in paragraph 4. 6. SUPPORT/ALIMONY/ALIMONY PENDENTE LITE The parties hereby waive, release, discharge and give up any rights either may have against the other to receive spousal support, alimony pendente lite or alimony. 2 .' '<t,,':' ,.' '.. "" :,', ,I .... :,,1'.' "J-,. , . T.. ,", ~'~" ",:. "I.," , . ::,:,':"'.'* ':~"j.' .':, l~ r 7, PENSION AND RETIREMENT ACCOUNTS Husband and Wifa shall maintain their separate pension and/or reti rement accounts, Husband re Unquishes any and all rights he may have in Wife's pension or retirement accounts and Wife relinquishes any and all rights she may have in Husband I s pension or retirement accounts. 8 . CUSTODY Wife shall have legal and physical custody of the child, Husband shall have visitation, to include the right to take possession of the child from Wife for periods of times as agreed to by the parties, The parties agree to use their best efforts to insure that their child has regular and meaningful contact with the other parent. The parties agree and understand that any custody schedule will need to be flexible to adjust to the various work and living arrangements of the parties. 9. CHILD SUPPORT Husband is to pay Wife $500.00 per month for the support of his child until January 2000 at which time the amount will decrease to $400.00. The $500.00 payment includes Husband's equitable share of the child care expenses. The parties agree that in the event of a material change in the cost of living or the financial circumstances of either party, or a change in the custody arrangements set forth herein, the amount of the support payments shall be subject to an appropriate adjustment by agreement or, if the parties are unable to agree, by the Domestic Relations Office or Court of competent jurisdiction. 10. MEDICAL/DENTAL INSURANCE AND EXPENSES Husband is providing medical/dental coverage for the child through his employer. Husband shall continue to provide the medical/dental coverage if such coverage is available at a reasonable cost as part of his employment benefits, whether or not such benefits are paid directly by the employer or by partial contribution by Husband. Wife and Husband agree to each pay one half of all unreimbursed and deductible medical & dental expenses related to their child. 3 r i 1'/ . WAIVER OF CLAIMS AGAINST ESTATES Except all herein oth(~rwille provided, each party may dispose of hill 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 acqui re und0r the present or future laws of any jurisdiction to share in tho property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widows allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate. 18. BINDING AFFECT This agreement shall be binding upon the parties' heirs, successors and assigns. 19. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and executed with the same formalities as this agreement, The failure of either party to insist upon 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. 20. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time of this agreement are null and void and of no affect upon entry of the Decree in Divorce. 21. 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. 22. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall not have any binding affect whatsoever in determining the rights or obligations of the parties. 5 -, , ' . . , I, " " . ,,' ,~ . " 1 " 0 ~ ' " ~ ' . .' .', " t ~ -" " '... -'. ?<, ~PPLICABLE LAW Thi,; .1<1H'dllt'lit :lh.IlI be con,;trued under the L,w,; of the COlTullon'N'~a1t.h of Penn:;ylvilnia, JlJ Wl'l'Nr:~;S \~IIEHE:OF', the parties set their I1<Jnds ilnd seals /')") //"") ( i (// /!.. .. .,/ )../ L, /7/-./. ,/) }"-;;; :, ..,-" Date ;/ James B. Pearson 2. \:<, -CR.- 1mo. ~Cl.,-Qa \\\f)b~ , Da te '-- Dena Ann Pea rson 1h . /L7 ,. ,)-1/4" j), ~.<H.Ld Witness Il:b !) - tcb 6 ;' ' ~ .' 'f' .' ..', ," , ,: ." ' .' , " ,\~ , " .,- ,-. ~. (ll ~~ u". t~ : \ i.r. ,"" ~~:~ ;.: r:~ I~~ . "' (l)~ (~, t I C,: ~\. I" i'" .' u., ':!' ,1 0 "", U . '. . ,:.: ."" ,i.,~") .,' ,"':~ :"; ~,' '! <,", ,":.', ,';", '':',,~ ,:,' ~,,' .' "'_' ".', "~ ... I"" ,....~ .".., '., , J1lMES B. PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98 - 4504 CIVIL TERM DENA A, PEARSON, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the 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: U.S, Mail, Certified, Restricted Delivery, August 17, 1998, 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By plaintiff, February 26, 1999; By Defendant, February 22, 1999. 4. Related claims pending: None 5, Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on March 1, 1999. Date Defendant's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on March 1, 1999. ~b.~ Thomas D. Gould, Esquire Attorney For plaintiff ".......~..I ".l,-~,j" l,':"_t. , ',"' \" "., .";.;'J:':'~:, :,"/.,'.;': ''';''. ,'" ' ,--r- >-- r-- "2-:: a; lJ'; '.l :5 1- c."'" UJ(: -' u. '~} ~'~ ~~~ ~.~: .~: , ~:'I 1 ( ~ 0' . I 1 U.IL; -' C:-.: . :',~~'J a: ~L~ c:,;; ,.',;::~ ,...- :L: ~<: !.l.. ," ':) 0 0' U ~,'" ~.. ' .' ", " _ . ~, >. ..' . :. '.' . c > '*..--._ ,. _ . _ : 1 _' , _ _, .' . '. ' .' JAMES B, PEARSON, PLA.INTIFF IN THE COURT OF COMMON PLEAS CUMBEIUJ\N1) COUNTY, PENNSYLVANIA v. NO. ge -l/ftJl/ CIVIL TERM IN DIVORCE DENA A. PEARSON, DEFENDANT NOTICE TO DEFEND AND CLA.IM 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ~~,,",..,..;.:..' ,.. " ' , .:~ ....~ '" '-', .:,' .:.,' ,',' ",' -, '..~, .' . , "/:' ',I'''' ',' .', .,,' JAMES B, PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERL1IND COUNTY, PENNSYLVANIA v. NO. 98 - '; ~""'f CIVIL TERM DENA A, PEARSON, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is James B. Pearson who resides at 48 W. Allen Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Dena A. Pearson who resides at 3140 Petre Road, Apartment 102, Chesapeake, Virginia 23325, 3. The Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 2, 1992 in Beaver County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. ;....,.. 1., , ' "I' " " ", ,'~ ',_ ' ,. :"., '. ~. , .". ~ 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9, Plaintiff requests the court to enter a decree of divorce. 71;;rI# 1> ~;!!:lfff,t/ Thomas D. Gould Attorney for Plaintiff 1. D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Fax 761-1974 I verify that the statements made in this Complaint 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: '-/ .:Ir'c., 02 OQ../ 1/-'<;. ' ~ :/'~'"'.>...-- tL:-.- '.. t.::..<......._-", James B, Pearson ..........,....,. - ....-,...., r- " , " ,'_.', ,N . .'''' I .' .' J.l\MES B, PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS ctlMBERIJIND COUNTY, PENNSYLV1\NIA v. NO. 98 - 4504 CIVIL TERM DENA A. PEARSON, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on August 5, 1998 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on August 17, 1998. ~'o.~ Thomas D. Gould ID # 36508 Attorney At La,. 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 I ';; SENDER: f:5! . Complete items 1 and/or '2 lor ilddrllonat SfJrvIC05. 1fI . Complote Ilems 3. 4.1, and 4b I G:l . Print your name and m.1dro~s on tho rllvorsu althiS form so th,,! Wll can mlurn this ~ card to you. I ~ . Attach this form 10 rho Ilont 011110 m;J,lpioce. or on tho:} back it spdce (joes not ClJ palmi!. I... . Writo "Rorum Recoipt RQQuo.~tnd'l)n 1M nwilpiocll bolow tho arliclt.! Jlumouf. .! . Tho Roturn Receipt wil! show to wtKlm lIH:J lIrtlC'O WitS doti...orod anlJ rho dalo - delivered. t. S 3. Article Addressed to; I ~ Dell~ A. PeColI'Sf)'" ! t , ''/.0 P~t're. (LJ.. iU Apt IO~ ._ J cl.;, s c:..ftAJ:f, 1/ If .2 312 S" I I , ,~ 1-1 1 ~ PS Form 3811, December 1994 ~1SJfitiTED . ~ U 'E ..... a. '. U ~ ",I C ,21 " "' co ., 'iij I ~, 0; ;~ o J "', ~I J!!I ... ,;'~j; I ...~D'~~ ) '" 102595,98,8 ~"g"'fjlln\estlc Retur~ AeOlilpl', ".! 4a. Articlo Number Z. ~ 75" t;J'!;" <I () 7 Q. Certified o Insured 8. Addresseo's Address (Only if requested and fee is paid) .....,.,,~"'M...,.,. 0 'D r) C \j:J .,"j .-1.:..\ ,< 1 :J L' ! '- ) , , , l: I ,:,~) r. .~ ~~) .. L , ~~.: ,-.ii 1 ~ ,~') I.J') , " .n , :::,:, :'J :1l :"[j ,.,J -.:,; 'f' , ~~':. :.: '.' '" .., :. ,,~, ~. _',~\','_". ,j" ~' t,:(' ,':"." .'~ r"",: ":.'.: " .7' "._,~...,.L....,..'..~.'v..,,~;"';:;':;:;';;';: --", ,","~, i JAMES D. PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 98 - 4504 CIVIL TERM DENA A. PEARSON, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT ,: " Ii 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 5, 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 of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree, 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses, if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 990,;' d- 0- ~.~8P ~ames B. Pearson ~ ""'- ,-- IJJQ (. ....~' c~'. ('~:;: :~ T l. ~ C::rU' '-1.I.l. r~~ l:::~ \... -- . tr. c;.. ~~ :.~)~~ ~ ~~ ... ,~ . i ';';~: :'''/ .r~ 1 n~ ro-'; ... -~ .- ,. O. C" C'\ :::J o '--' ,.:,:.' " ,1,,:" ,;".:' ...."!..,.",-:.'.~.:'.'1"..,':~..':~::I-.I.:;,.. " ",~<'~":.,; .::' ...~:..)':' '.':_ "_:'~".:.~ '''~'';'''~''.~ . ',.,.,. ..:... " 'f~ i., ,~...... ,~,. "''''',.' "~"'" ('''_.'.., JAMES B. PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 98 - 4504 CIVIL TERM DENA A. PEARSON, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33011c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 9'::1 0 ..:J.. d-. (0 ~~, LJL >- r' (., cr" tr. r.:-: ., ~-:; (~ 0.... , \J~:. . si:s: - ...... " (~, ,-.- ,- '.- ;:1 C_'; I .\ 1.1,; .' U.: , fc I' I ," -.i .-::: .' (.1- e- tL ('.71 ::s U C' U '''<"",,,) l. ! ..';'./ ''-''-',''- .:::-::-..::- ',': ~;.":.', .",'.'. "f" ..:".,.,:~~~, '~",'~:",::", ""':':,~ "_,:" ,;,.,,;.-".:,.......;,~''''.1.... ';'1_"" .: "~,"Il JAMES B. PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 98 - 4504 CIVIL TERM DENA A, PEARSON, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 5, 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 of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses, if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, ~ . ffi, Q,~~I)M\'1) ena A. Pearson DATED: 2-22 -qq .,.. r-- (; tr: if. .J.. I- cr. "-J UJ~? 0" .. ~, ~- U.' .,'.- q.. ,:;~I C.);. cn c:,i, I '.1 Lij,L' , El,;:' rJ-:: it,:i,] ..:,( , e" ~ ::.) u, c' 0 0'" (.) '.'_' .... :; '~.~ ....:~..~:'~.:\?'..'_.,<.:. . '. .:.,:......'>'.,\:.'. :\" :~". '\'. <..;.,..;.~ '~_, "'..~,;.~'~ ):.;~~'-;.r;, " ',;., '. l~ ;';":':::;-,~7 -~ JAMES B. PEARSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98 - 4504 CIVIL TERM DENA A. PEARSON, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301/c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, DATED: 2-2~-qg 1m.a,~~ Dena A. Pearson