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HomeMy WebLinkAbout98-05866 .... III j \l ~ "1- "" j \1 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA 17011 17171737-0100 I N TilE COUln' OF COMMON PLEAS OF CUMBEI,LANlJ COUNTY, I'ENNSYLVAN IA WENDY SUE FOUST PI ,1111 t j f [ v. NO. 98-5866 BRIAN KEITH FOUST Defendant CIVIL ACTION - LAW DIVORCE MARRIAGE__S~T.TLEMEN'LAGREEMENT i'l THIS AGREEMENT made this li day of '~''''v or..: 111 'J"~t. , , 191e, BY AND BETWEEN WENDYS. FOUST ("WIFE") of 4010 Mountain View Road, Mechanicsburg, PA 17055 AND BRIAN K. FOUST ("HUSBAND") of 21 Highland Drive Camp Hill, PA 17011. WIT N ESE T H : '.' WHEREAS, the parties hereto are HUSBAND and WIFE, having been married on May 6, 1995 in Mechanicsburg, Pennsylvania and separated on October 2, 1998. WHEREAS, WHEREAS. There were no children born of this marriage:. di verse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of Page 1 of 23 nettling fully and 1 inally tltc,ir re"I)('Ctlve financial and property ri<Jlttn ilnd obI i9ilt ionn an betw("'1I /.,,,,It other including, without limitation by specHlcatioll: L111- ,jdtl1ng of all matters bpt;.ween them relating to the ownership alld equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, illimony and/or maintenance of WIFE by HUSBAND or of HUSBAND by ~IIFE; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates, NOW, THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, WIFE and HUSBAND, each intending to be legally bound hereby, covenant and agree as follows: 1. INCORPORATION OF PREAMBLE: The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 2. ~GREEMENT NOT A BAR TO DIVORCE PROCEEDING~ This Agreement shall not be considered to affect or bar the right of HUSBAND and WIFE to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party, Agreement is not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any DIANE G. RADCLIFF 3448 TAINDLE ROAD CAMP HILL. PA 17011 (7171737-0100 Page 2 of 23 This act or <lcts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof. 3. PIYDRCE_DECREEL The parties acknowledge that their marriage irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above captioned divorce action. As soon as possible under the terms of said Divorce Code, the parties shall execute and file all documents and papers, including affidavits of consent, necessary to finalize said divorce. If either party fails or refuses to finalize said divorce or execute and file the documents necessary to finalize the divorce, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. 4. EFFECT OF DIVORCE DECREE: 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. 5. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. DIANE G. RADCLIFF 3448 TRINDLE AOAD CAMP HILL, PA 17011 1717) 737.0100 Page 3 of 23 is need!! and in in Ill!! eJ[' 11..1' bent lntcl'..nt!!, and that the AgreClIlf"nt 1[1 not till' l'f"!lU 1 t 01 any f )'aud, dureus, or undue influence exercifled by either party upon the other or by any other person or persons upon either party. Given said understanding and acknowledgment, both parties hereby waive the following procedural rights: a. The right to obtain an inventory and appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code. b. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code, except in instances where said income and expense statement is hereafter required to be filed in any child support action or in any other proceedings pursuant to an order of court. c. The right to have any discovery as may be permitted by the Rules of Civil Procedure, except discovery arising out of a breach of this Agreement, out of any child support action, or out of any other proceedings in which discovery is specifically ordered by the court. d. The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines to be marital. e. The right to have the court decide any other rights, remedies, privileges, or obligations covered by this DIANE G. AADClIff 3448 TRINDlE ROAD CAMP Hill, PA 17011 (7171737-0100 Page 6 of 23 DIANE G, RADCLIfF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737.0100 ^'lreement, includlng, but not limiV,d to, possible cluims [or divon:e, npolHhll HUppOl."t, alimony, alimony pendente lite (temporary alimony), and coun~Jel fees, costn .:lnd expenses. 12. PERSONAL_PROPERTY, HUSB^ND and WIFE do hel"eby ackno.....ledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, carpets, household equipment and rugs, appliances, tools, pictures, books, works of art and other personal property and hereafter WIFE agrees that all of the property in the possession of HUSBAND shall be the sole and separate property of HUSBAND; and HUSBAND agrees that all of the property in the possession of WIFE shall be the sole and separate property of WIFE. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. 13. AFTER-ACQUIRED PROPERTY: Each of the parties shall hereafter own and enj oy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, since October 2, 1998, the date of the parties' marital separation, with full power in him or her to dispose of the same as fully and effectively, in all respects Page 7 of 23 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA 17011 (7171737.0100 waive, releiH1e, renounce and forever abandon whatever right, title and intet-cst thcy may havc in the vehicles that shall become the sole and SCp'HdLe property of the otner pursuant to the terms of this Paragraph. 15. IllY.ISI.ON_OF_REALj;STATK:. The parties are the joint owners of a certain tract of real estate known and numbered as 27 Highland Drive, Camp Hill, Pennsylvania having a value of $102,000.00 and subject to a mortgage owed to Pa. Housing Finance having an approximate balance of $84,565.00 and a Member's 1" home equi ty loan having an approximate balance of $8,401.00 the real estate is currently under contract for sale with a tentative settlement date of November 30, 1998. With respect to the real estate the parties agree that there shall take all steps necessary to complete the sale of the real estate. At settlement, the proceeds, after payment of all normal and reasonable settlement costs and payment of the mortgage and home equity loan shall be equally divided between the parties. The parties further agree that each party shall be responsible for the reporting of 50% of any gains resulting from said sale on his or her applicable income tax returns and shall pay any and all taxes arising out of said reporting. Each party shall indemnify, protect and save the other party harmless therefrom from any such taxes which that party is responsible to pay as the result of the foregoing. Page 9 of 23 ::\; r L I~ If! 19. WIF~S_DEBTS~:. 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 ~IIFE 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. 20. HUSBAND'S DEBTS: 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. 21. MARITAL DEBT: During the course of the marriage, HUSBAND and WIFE have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without DIANE G. RADCLIFF 3448 TRINDlE ROAD CAMP Hill. PA 17011 (7171737.0100 Page 12 of 23 ~ ~ DIANE G. RADCLIFF 3448 TAINDLE ROAD CAMP HILL. PA 17011 1717) 737.0100 ascertaining for what purpose and to whose use each of the bills were incurred, the parties agree as follows: a. ~IIFE shall be solely responsible for 1:11" follo~ling bills and debts: 1. Any credit card accounts, loans, debts or other liabilitieo in her sole name. b. HUSBAND shall be solely responsible for the following bills and debts: 1. VisA The joint -S('6.~o:. charge having account an approximate balance at separation of $300.00. 2. Any credit card accounts, loans, debts or other liabilities in his sole name. Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills which pursuant to the terms herein are not the responsibility of the other party. Any joint debt shall be canceled so that neither party can make any further charges thereunder and if said charges are made in violation of this Agreement than the party incurring said charge shall immediately repay the same. Any liability not disclosed in this agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. From the date of this Agreement. each party shall only use those credit card accounts or incur such further obligations for which that party is individually and solely liable and the Page 13 of 23 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA 17011 17171737.0100 parties shall cooperate in closing any l'emaining accounts which provide for joint liability. 22. BANKRUl'-'l'CY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party f Bes such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 23. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint federal and state returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. Page 14 of 23 replacement tll"z<l.()f tJY dllY other nimilar laws, which remedic" uh,:lll 1 1)('] lid", hill. not lImited La: 1. the entry o[ jud:Jlllt!nL; 2. the authorization of the taking and seizure of goods and chattels and collection of rents and profits of real and personal and tangible and intangible property; 3. the award of interest on any unpaid installment; 4. the transfer and sale of any property required to obtain compliance with the obligations undertaken by this Agreement; 5. the posting of security to insure future payments to assure compliance with the obligations undertaken by this Agreement; 6. the issuance of attachment proceedings and the holding of the breaching party to be in contempt and the making of appropriate order therefor including, but not limited to, commitment of the breaching party to county jail for a period not to exceed six (6) months. 7. the award of counsel fees and costs. 8. the attachment of the breaching party's wages. d. Any other remedies provided for in law or in equity. 35. LAW OF PENNSYLVANIA APPLICAl3.LE..:.. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737.0100 Page 20 of 23 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA 17011 (717)737-0100 36. SEVERABILITY: II .IllY tello, ('llIHilllIJIl, CldlllH' cJt- proviniun of thiu Aqreel1ll'llt nhal1 1)(' ch'lf.'1'1lI1I1(.d or declaTed tel be vuiJ or invillid ill JilW 01' otherwiHt', then only thi1t term, condition cliluse 01' provision shilll be stricken fr'om this Agreement and in 0111 other respects this Agreement shall remi1in valid and continue in full force, effect and operation. Likewise, the failure of either party to meet his or her obligations under this Agreement under anyone or more of the paragraphs hereunder, with the exception of the satisfaction of a condition precedent, shall in no way avoid or alter the remaining obligations of the parties. 37 . HEA1llHG~Ll'ART OF AGREEMEN'l'...:. Any headings preceding the text of the several paragraphs and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. Page 21 of 23 COMMONWE^LTlI OF PENNSYI.\'^Nr^ l'l' d.). COUNTY OF CUMBERLMm On thin thp L~dilY ol ~~!"~- l:J~, be[ol'e me the undersigned o[[lcer, pcrEJonally appeal'cd, WENDY S. FOUST, knOlm to me (or satisfactorily proven) to be the person whose name is subscribed to the within ^greement, and acknowledged that WENDY S. FOUST executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal. ~,~I)L~ My Commission Expires: COMMONWEALTH OF PENNSYLVANIA NOlanal Seal Catherine E. Alvarez. Notary Public Hdrrlsburg. DauphIn County My CornrnlSSI':1n Expires July 2. 2001 ~lern/)f!r PennS'Ilvo1ll1a As~oC!ahon of iJolarles SS. COUNTY OF CUMBERLAND On this the ~day of ;U~, 19 Cfy--, before me the undersigned officer, personally appeared, BRIAN K. FOUST, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that BRIAN K. FOUST executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~rYI,~ NOTARY PUBLIC My Commission Expires: DIANE G. RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 (717) 737.0100 Page 23 of 23 NOlanal Seel CllrlSllne M White Notary Public MocnanlCSburg Bora. Cumberland Countv My Commrsslon Expires SePt. 17 2001 .mOOI, Pennsylvan~ AsSOC~tion 0 NO ~! \: / ' t 1; /. It! \'11-:111>'" ::ill'; J." 'II::;' I': II Ill' I:: 'j'J IF (',' I:;i'j' -1: (', j~'::';'j:: I'!.J.:,\.': "J'- ('l~:-:I',VI"'r.tdn! '~::;,n'. i'J':U~;.';'n,'/,\n:,\ " , , , " 'Ii! r,Hl.I, BRIM! KEITII J"I)II::T J)(" t ','Zlti,IIlt (':V11, t\C'.i'I~)U I.A','; I) r VOI.:('E PIIAI-:l.'I PI; UF TJ.:MISNIT III;COIW To the Prothonot,:u:y: Transmit the record, to\jet.ht_"l' y./ith the fOllo...'illt] Illtormatiol1, to the CQUl"t for elll1'Y of a divOl:Cl: decl"L'e: 1. Ground for divorce: Irretrievable breakdo"1J1 under Section 3301 (c) of the Divorce Code. 2. Date a. b. and manner of service of the complaint: Date: October 10, 1998 Manner: Certified Mail, Restricted Delivery 3. Date 3301 a. b. of execution of the affidavit Ic) of the Divorce Code: Plaintiff: 1/15/99 Defendant: 1/22/99 of consent required by Section OR Date of execution of the Plaintiff's affidavit required by Section 33011d) of the Divorce Code and date of serVIce of the PlaIntiff's 3301 (d) affidavit upon the Defendant: a. Date of execution: n/a b. Date of filing: n/a c. Date of service: n/a 4. Related claims pending: No issues are pending. All issues have been resolved pursuant to the Marriage Settlement Agreement between the I?arties dated November 18, 1998 which Agreement is to be incorporated Into but not merged with the Divorce Decree. S. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 33011d) II) (i) of the Divorce Code: a. Date of Service: n/a b. Manner of Service: n/a OR Date Waiver of Notice in Section 33011c) Divorce was filed with the Prothonotary: a. Plaintiff's Waiver: 1/19/99 b. Defendant's Waiver: 2/1/99 , ESQUIRE Road ( - - -~ >"'_."...''':4~ I N TilE couwr OF r:Or~N()N l'I.E^t; <J!' CUr~n1:I!I.^NI) COUNTY, I'ENN~;YI.VM, I ^ WENDY SUE FOUST I'l,dnt i t I v. NO. '/ J. ~. j (, (, e:.;~(-r,:.- BRIl\N KEITH FOUST Defendant CIVI L ^CTION DIVORCE L^\'I NOTICE 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 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 the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. DIANE G, RADCLIFF 3448 TRINDLE ImAD CAMP 1111.1.,1'/\ 170] I (717) 737-0100 .. [ G. Plaintiff h"s IJ,"'n ..<1'/1:1,.<1 01 II". ..v.., J.,tJllllY of counseling and the' l'1qht tu 1"'1"":;1 1 h,ll 1.11" CUUlt I ,.qui te the parties to participate in cOll"'J,-'llllg. 7. The Defendant is not a m(.mbet. of the Armed Services of the United States or any of its Allies. 8. The Plaintiff aver" that the g,'ollnds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. Or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EOUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from May 6, 1995 DIANE G. RADCLIFF 3448 TRINDI.E ROAD CAMP IIILL,I'A 17011 (717)737-0100 - 3- VERIFICATION \-JENllY ,; FOU:;T V"I']! if'~; lholt tile- ntaLernentB rndde U1 this Comp 1 il i tlt dr.,' true dnd '2urrccL. t-:ENIJY S. FOUST understands that false statements herein are n~de subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authoritles. / "I ! (~t I (;,; ) J _ ): ?;~~ ~ S,; FOUST (~ DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HII.L, PA 1701] (717) 737-0100 ,5, DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP ifILL, "A ] 70 II (717)737-0100 ..... '".~ LAW OFFICES SNELBAKER. BRENNEMAN & SPARE .:"::':";~ I: I' II I: I , I WENDY SUE FOUST, Plaintiff I Ii v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 90-5866 CIVIL TERM BRIAN KEITH FOUST, Defendant. CIVIL ACTION - LAW DIVORCE PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Keith O. Brenneman, Esquire and Snelbaker, Brenneman & Spare, P. C. as attorneys for Defendant Brian K. Foust in the above-captioned matter. SNELBAKER, BRENNEMAN & SPARE, P. C. By: ~~ Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendant Brian K. Foust Date: October 26, 1998 1 ."".,",~......,.,. CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing praecipe to be served upon the person and in the manner ! indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Diane G. Radcliff, Esquire 3448 Trindle Road camp Hill, PA 17011 K~~ Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendant Brian K. Foust I : Date: October 26, 1998 , , (', Of.) c: i;~.1 ') I IF, .:::, , '-"'I i~. r 1 .~ ---< , i; .. "" ,~. J. ,~ -- C;n '.. r--~ ! , ~~ " ""-, Cj E ' "', ~..: j;:) ..- ~t; ~'? ~ ~ (~..i ',) ~- - , " -< '7'1 :..i.1 , Dated: ,-WE IN TilE CQUia OF COMr~QN PLEN; OF CU~lHi';!!LMm COUNTY, PENNSYLVAN I A ~iENrw ~;UE FOUST 1'1" illLl t I v. NO. 9~.. 5~GG BRI!\N KEITH FOUST Defendant CIVIL ACTION .. L^~I DIVORCE AFFIDAVIT ...OF_CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 10, 1998. 2. The marriage of Plaintif f and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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. Section 4904 relating to unsworn falsification to authorities. DIANE G. RADCLIFF 344M TRINDI.E ROAll CAMP 1I[1.I..I'A 17011 (717) 737-0100 :;'10, j';'\ ,::j ;-) ,ld , -~ ! -, " '..J , , : "> ~ ' ) I I ~' . , DIANE G. RADCLIFF 344M TRINOLE ROAD CAMP 1111.1., I'A 170] 1 (717)737-0100 IN THE couln OF COMMON PLEAS OF CUMBERLAND COUNTY, I'ENNSYLVNHA \'If.:NDY SUE FOUST pJ"inLifj, v. NO. 9B..SBGG BRIAN KEITH FOUST Defendant CI V 1 L ACTION - LA"I DIVORCE I'lADLER_ill'___Nill'lCE-OL.lNIEN.'UON_TILREQUES.T ENIRY.....0L1LDlV..oRCILD,ECREE.....UNDER SECTlON,l301 (cl DLTHE_DIVORCE ,.CODE 1. 1 consent co the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made 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 Dated: 11 Ie; J CJg /' I unsworn falsification to authorities. ,) -jl :'1 '.:J .. ') ,'ri i~ i ,,' 1;'\ " ..! "'" ,', : '~