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IN
THE COURT OF COMMON
PLEAS
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CUMBERLAND
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PENNA,
STATE OF
ROBERT C. BALES. JR,.
PlaIntiff
,"' 98-6755 CIVIL TERM II)
"II,
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CIVIL ACTION - LAW
JODI L. BAt,ES.
IN DIVORCE
Defendant
DECREE IN
DIVORCE
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it is ordered and
AND NOW,
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decreed thot
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, ,ROBERT G., ,BALES., JR.,
JODI L: ,BALES, , , , , ' ,
'" ", " , ' , " plaintiff,
" """, " defendont,
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~ are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been roised of record in this oct ion for which a finol order has not yet
been entered;
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", ~~~, ~~::ia~~ Settl?~ent A~reement, dated, Octob~.r, 28",1999, !"nd ,s,igned by"
, the ,I'~~~~~~, i~ ,l:'~r~by, in~orpora~~d, herein an?, m~?e, a, p~,r,t, ,of. ,t,h,i,s, ,D,i,v,o,r,c,e,
Decree.
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MANN/AGE SETnEMENT A (iNEEMENT
TillS A(;REE:\IE"'T mad.: this .J..L.!...'.:..,_ day of.w..U.. ,.,.', . 1999. by and
bet\\'.:.:n ROIlERT C. IlALES. .JR. (h.:r<:inalkr rdcrr.:d to as "IWSIlANJ)") and ,/01>1 L.
BALES (hereinaller rdcrmllo as "W'I'E"),
WITNESSETlI:
WHEREAS. HUSBAND and WIFE \\w.: lawfully marri.:d on May 25. 1991. and
separated on July 25. 1993: and
WHEREAS. divers.:. unhappy diflcr.:n.:.:s. disput.:s and diftieulties have arisen between
the parties and it is the imention of HUSBAND and WIFE to IiI'(' separate and apart for the rest
of their natural lives. and the parties hereto are desirous of sellling fully and finally their
respective tinaneial and property rights and obligations as between eaeh other. including. without
limitation by specification: Ih.: sellling of all malleI'S belween them rclating to the ownership and
equitable distribution of real and personal property; the sellling of all claims and possible claims
by one against the other or against their respective estates and equitable distribution of property
and alimony for each party,
The pm1ies hereto agree and covenant as follows:
I.
I'hl' p,lItil's illll'lllllll Illallllaill Sl'p;lI'illl' alld pl'l'Il1allelll dlllllleik's alld III live apart Irlllll
l'aeh other. II is till' illll'lII alld pllrpllSl' lIflhis t\grl'l'llll'lIl tll set Il,rth Ihc rcspcetive righrs and
dutics oflhc parrics while they elllllilluC lolivc al'arlli'ollll'aeh orher.
,
Thc parrics havc allclllplcd III dividc thcir malrill10llial propcrty 111 a manner which
con limns 10 a just and righl slandan!, wilh due rl'g:lrd /0 1/": righls of each party, II is the intenl
oflhe partics Ihal such division shall hc linal and shall Il.rever detenninc Iheir respcetive rights,
The division of existing marilal propcrly is nol imcmled hy IIIl' pat1ics 10 constitute in any way a
sale or exchange of assets.
3,
Further, the parties agree to eominuc living separately and apart Irom rhe other at any
place or places that he or she may sciect as they have heretofllre heen doing, Neither party shall
molest, harass. anlloy, injure, threaten or interfere with the other party in any malleI' whatsoever.
Each party may carryon and engage in any employment. profession, business or other activity as
he or she may deem advisable for his or her sole use and benelit. Neithcr party shall interfere
with the uses, ownership. enjoymcnt or disposition of any property now owned and not specified
herein or property herealier acquired hy the other.
2
4,
Th~ ~onsid~ration fill'this contrm:1 and aW~<'Il1~nt is th~ ll1ulual h~ncfilto h~ ohtain~d hy
horh of th~ parti~s h~r~lo .lIId th~ co\'~nants and a):r~~Il1~nts of ~adl of th~ parti~s (0 Ih~ oth~r,
Th~ ad~'1ua~y of rh~ ~onsid~ration li.r all a):r~~Il1~nls h~r~in conwin<'d is slipulat~d. ~onl<:ss~d.
and admill~d hy th~ paJ1i~s, and th~ parlics inl~nd 10 h~ I~):ally hound h~r~hy,
Ea~h parly 10 Ih~ Agr~~m~nt ackno\\'l~dg~s and d~darcs Ihat h~ or sh~.
r~sp~ctivdy:
(I) is r~pr~s~nl~d by couns~l. (Ir\\'in. McKnight & IluglK's fi.r HUSBAND) of his
or h~r o\\'n choosing; or if not r~pr~s~nl~d hy counsd. und~rslands that h~ or sh~
has Ih~ right 10 counsd; WI FE choos~s not to h~ r~pr~s~nt~d hy counsel. and by
initialing this pag~ acknll\\'l~dg~s h~r right to ht.: rt.:pr~st.:ntt.:d hy eounsd;
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(2) is fully and t.:omplt.:tely inlilrmt.:d of th~ lilets rdating ro tht.: subj~t.:t malleI' of
this Agrt.:ement and ofth~ rights and liahiliti~s oflhe parties;
(3) enters into this Agre~mt.:nt voluntarily alkr rect.:iving Iht.: advice of t.:ounsel;
(4) has given eardit! and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agr~t.:ment; and
(6) fully and completely understands each provision of this Agre(~ment, both as to
the subjeel matler and legal en<:c\.
This Agreement shall become elrective immediately as of tht.: dale of execution,
3
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II is the purpose alld illl~llt or this I\gll'elllelltlo sellk' li'le\er alld eOlllllldely the illtcr~sl
and ohligations orlhe parties in all prop"rty thalth,'y own separalely. and all prop~rty that would
quali Iy as mariwl prop~11y und~r th~ P,'nnsyllania Divorce ('ode. Tilk 2.1. Section J,1() I (c), and
Ihnl is rererred to ill this ^greel11ellt as ":-'larital Property", as hetwe,'n th~msclves, their heirs and
assigns, The parties ha\'C a"elllpted to divide their Maritall'roperty in a manner that con limns 10
a just and litir Slandard. with due regard to the rights or each Party, The division of existing
Marital Property is not inlended hy Ihe parties to constitute in any way a sale or exchange of
assets, and the division is heing e1keted without the introduelion of outside funds or other
property not constituting a part or the marital estate,
II is the lilrther purpose of this ^greenwntto senle ",rever and completcly any obligation
under the Pennsylvania Divorce Code rclaling to spousal support or alimony,
fl.
Each party represents and warrallls that he or she has Illade a lilll and lilir disclosure to the
other or all or his or her property interests of any nature, including any mortgage, pledge. lien,
charge. security interest, eneumhranee. or restriction to which any property is subject. Each patty
tilrther represents that he or she has made a lilll and lilir disclosure of all dehts and obligations of
any nature tell' which he or she is currently liahle or l11ay heeome liahle, Each tilrther represents
and warrants that he or she has not made any gilis or trans reI's IiII' inadequate consideration of
MaritalPropel1y without thc prior consent or the other.
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II,
Al1TOI\IOBJI.ES: WIFE hcrchy waivcs all righr. rille and intcr,'st in any vchiclc Ihat
HUSBAND currcnrly owns or may own in Ihc fiuurc, HUSBAND shall hold WIFE hannlcss l\lr
any and allliahility associatcd wilh thc usc and purchasc of any vchiclc hc may own. and shall he
solcly rcsponsihle l\,r all insurancc and orhcr linancialrcsponsihility associaled with said vchiclc.
HUSBAND hcrchy w:livcs all righl. lirle and intercSl in any vchicle that WIFE currelllly owns or
may own in Ihc fiuurc, WIFE shall hold HUSBAND hannlcss lilr any and allliahility associated
with thc use and purchasc of any vehiclc shc may own, and shall hc solcly responsihle till' all
insur:mce and othcr financialrcsponsihility associated with said vchiclc,
10,
MARITAL DEBTS: It is mutually agrccd hy and herween the partics that WIFE shall
assumc allliahility till' and pay and indemnify thc HUSBAND against all debts incurrcd by WIFE
aileI' the date of separation, WIFE rcprcsents and warrants to HUSBAND that since the parties'
marital separation shc has not contractcd or incurred any debt or liability till' which HUSBAND
or his estate might be responsible and WIFE tilrthcr represents and warrants ro HUSBAND that
she will not contract 01' incur any debt or liability atier the execution of this Ah'l'eement. for
which HUSBAND or his estate might be responsible, WIFE shall indemnify and save
HUSBAND hannless trom any and all claims or demands made against him by reason of debts
or obligations incurred hy her,
HUSBAND shall assume all liability till' and pay and indemnify the WIFE against all
debts incun'ed by HUSBAND aner Ihe date of separation, HUSBAND represents and warrants
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
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liability till' whil:h \VIFE or her estate might he responsible' and HllSBAND thrlhl'r rl'prl'sell"
and warrants 10 WIFE (Iwl he will not contractor inenr any debt or liability alier the e\Celllion or
this Agreement. for wbieh WIFE or her estate mighl he responsihle, IllJSllAND shall illllemnily
and s<lve WIFE Imnnless Irom <lny <lnd <III c1<1ims or dem<lnds m<lde <lg<linst her hy reason or debts
or obligations incurred by him.
II.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree thai any Iile insllnln,'"
policies on the life of HUSBAND or WIFE or <lny other employee benclils. including hilt 1I0t
limited to rerirement. protit sharing or medie<ll henetils of either parly, sh<llll,,' Iheir o\\'n, WII'I,
w<lives <III right, litle <111(1 c1<1im to HUSBAND's employee benefits, <lnd III ISBAND waives <III
right. title, <lnd claim to <lny of \VI FE's employee benefits.
12,
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INVESTMENTS AND BANK ACCOUNTS: WIFE agrees to w<live all righi, litle and
interest wbieh she may b<lve in <lny <111(1 <III investments <lnd finanei<ll accounts of the IllJSBAND.
<lnd HUSBAND <lgrees to w<live all right, title and interesl which he h<ls in any and all
investments and financial <lccounts of the WIFE,
13,
DIVORCE: The pmties both agree to cooperate with e<lch other in ohtaining a tinal
divorce of the marriage, It is <lgreed that the parties will executc and lilc Ihe eonscnts nceessnry
to obtain the divorce. Any party who fails to coopcnlte with ohl<lining the Divorce shall pay all
tbe costs and legal fees of the party who is seeking the divorce.
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IIREACII: If cilhcr party bre;lclll's any provisions of this Agrccmcnr, Ihe othcr party
shall have Ihe righl. at his or hcr clection, 10 sue li'r damages f(,r such brcach or scck such othcr
remcdies or relief as may be available to him or hcr, and thc party breaching this contract should
be rcsponsible lilr paymcnt of Icgal fces and l'osls incun'ed by the other in enlilrcing Iheir righls
undcr this Agrel'mcnl.
/5,
AnnlTlONAL INSTRUMENTS: Each of rhe partics shall from timc to time. at the
requcst or thc other. exccutc. acknowlcdge amI deliver to the orher party any and all filrther
instrumcnts that may he reasonably rcquircd to givc filII force and effect to the provisions or this
Agrecmcnl.
16,
VOLUNTARY EXECUTION: The provisions of this Agrcement and their legal effect
have eirhcr been fully explained to the parties by their rcspective eounsel, or have been fully
reviewed and understood if not rcpresented 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 durcss or undue influcncc, The parties agree that unless otherwise specifically
provided herein, this Agreement shall continue in filII force and effect aller such timc as a final
Dccree in Divorce may be entered with respect to the parties, The partics further a/,'l'cc that the
tcrms of this Agrecment shall be incorporated into any Divorce Decree which may be entered
with respect to them, It is tbe parties' intent that tbis Agreement does not merge with the Divoree
Deeree, but rathcr shall continue to have independent contractual significance. Each party
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21.
WAIVER OF CL\Ii\IS AGAINST ESTATES: Ex~.:pt as h~r~in oth.:rwis.: provid.:d.
each party may dispose of his or her properly in ,my way. and .:a~h party herd,y waives and
relinquishes any and all righls he or she may no\\' havc or her.:atkr a~quire. under the pres.:nt or
future la\\'s of any jurisdklion. 10 share in lh~ prop~rty or th.: .:stal.: of th.: oth.:r as a r~sul1 of the
marital relationship. ineluding without limitation. dO\vcr. eurt.:sy. statutory allowan~.:. wido\\"s
,llIowanee. right to lUke in intestacy. right to tak~ against th.: \ViII of the other. and right to act as
administrator or exccutor of th~ othcr's estate. and ea~h will. at the r.:quest of the other. .:xecute.
acknowledge and deliver any and all instruments which may be necessary or advisable to .:arry
into effect this mutual waiver and relinquishment of all su~h interests. rights and claims,
IN WITNESS WHEREOF. the parlics hereunto have sctthcir hands and scals thc day
and ycar first abovc writtcn,
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ROBERT C. BALES, JR.
~ ~ (lo aftv
JODI L. BALES
(SEAL)
W;tl-'2' rJ( dW,' ,.i:.~u- J..#<...-
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(SEAL)
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('Oi\li\IONWEAI.TII OF I'I':NNS\'I.\'A;\;IA
ss:
COUNTY OF CUi\IIlEIU.Mm
I'ERSONAI.I.Y API'EAIU:n BEFORE ME. this J~' day of 'i'{ tn'-( Ii) /) .t.JL.
I <)lJlJ a Notary "uhlic. in and III I' thc ('ol1ll1lol1ll'calth of I'cnnsylvania. Counly of CUl1lhcrland.
,1001 L. BALES. knllwn tll mc (or satislilctorily provcn) to hc thc pcrson whosc name is
subseribcd to thc within Marriage Selllcl1lcnl Agrcemcnt. and :Icknowlcdges that she cxccuted
the same It)r thc purposes th,'rein containcd.
IN WITNESS WIIEREOF. I havc hcreuntll sct my hand and ofticial seal.
Notarial Seal
Martha L. Noal. Notary Publio
Carlisle Bora. Cumberland Coultv
My Convnlsslon Expire. Sept. 18, 2llo3
Member, PennsylVania AsSOCIatIon of Notanes
V!^{(~tJf (J;fYt~
COMMONWEALTII OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
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PERSONAL-I. Y APPEARED BEFORE ME, this J..L.. day of. \ r 0 VI ,,-,,\
I 99lJ, a Notary Public. in and for the Commonwealth of Pennsylvania and County of
Cumberland, ROBERT C. BALES, JR., known 10 mc (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Selllement Agreement. and
acknowledges thaI he executed the same lor the purposes therein contained,
IN WITNESS WIIEREOF. I have hereunto set my hand and oftieial seal.
Notarial Seal
Martha L. Noel, Notary Public
Carlisle Borc. Cumberland County
My Convnlsslon Expire. Sept, 18.2003
Member, PennsylVania Association ot Notaries
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,\1\IEIUc,\NS \\'1'1'11 /lIS,\llll,ITIES
'\~T OF 19911
The ('ourt or Common I'leOls or Cumherland Counly is required by law 10 comply with
Ihe Amcric:l/ls with DisOlhilitics Acl or 1990. For inlimnation about acccssible facilities and
reasonable accommodalions available to disabled individuals having husiness before the court,
pleasc colli act our office. All arrOlngemenls lIlust be made atleasl 72 hours prior to any hcaring
or business befllre lhe court, You musl allemllhc schcduled confercnce or hcaring,
ROHERT C. HALES, .JR.,
PlalnllFF
: J:'I' TilE COlIRT OF COMMON PLEAS OF
: CIIJ\IIlERI.ANJ) COUNTY, J'ENNSYLV ANIA
\'.
CIVIL ACTION -LAW
I1N_ CIVIL TERM
.1001 L. HALES,
DeFendanl IN I>IVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTION 3301(c) OF TilE DIVORCE CODE
NOW comcs the plaintiff: Robert (', Bales. Jr,. by his allorney. Rebecca R. Hughes.
Esquire. and tiles this complaint in divorce againslthe defendant. Jodi L. Bales. representing as
lollows;
I. The plaintilT is Robert C. Bales, Jr,. an adult individual residing at 65 West Big Spring
Avenue. Newville. Cumberland County. Pennsylvania 17241.
2, The defendant is Jodi L. Bales, an adult individual residing at 113 Chestnut Avenue
Mt. Holly Springs. Cumberland County. Pennsylvania 17065,
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the tiling of this action in divorce,
4, The plaintiff and the defendant were married on May 25, 1991 in New Kingstown,
Pennsyl vania.
5, There IVl're t\l'lI ehildrl'n horn ro this maniage. namely. /~nhen C. Bales, III. horn July
25, /99/. age 7 years. and Alicia /~, /lalcs. hom J,lI1uary 20. 1')<).1. ,Il!e 5 years,
6. Pursuanllo the Divorce Code. Section .1JOI(e). the plainlitTavcrs as rhe grounds upon
which rhis action is hased Ihatlhe marri;ll!e het\l'een the panics is irretrievably broken.
7. The plaintiff avers rhat he has heen advised of the availahilily of counseling and that
said pany has the right to request that the eoun require rhe panics to panieipate in counseling,
WHEREFORE, the plaintiff demands judgrnenl dissolving Ihe marriage between the
two parties,
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60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I.D. No. 67212
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Date:
)/-/9
,1998
VERIFICATION
The f(,regoing Complaint in Divorce is based upon inlimllalion which has bcen galhered
by my counsel and me in the preparalion of this aClion, I have read thc stalcmcnts madc in this
Complainr and they are true and corrcct 10 Ihe best of my knowledge. inlimnation and belief: I
understand Ihat lillse stalemcnls hcrcin made are subject to the penalties of IS Pa.C.S,A. Section
4904. relaling 10 unsworn lillsi tication ro aurhoritics,
~!l. BALES, .JR.
Date:
A / /'l~
tv.""
,1998
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ROB~:RT Co BALES. .JR..
l'lalnllrr
: I~ TilE COl:RT OF C():\IMON I'I.EAS OF
: ('I::\IIIEIU,A~J) ('O{JNT\'.I'ENNS\'LV ANIA
\'.
('IVIL ,\CJ'lON. L,\W
<IN- CIVIL TERM
JODI L. BALES.
Defendant IN J)IVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff: being duly swom according to law. deposes and says:
I. I have been advised of the availability of marriage counseling and understand that 1
may request that the court require that my spouse and I participate in counseling.
2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's
Office. which list is available to me upon request.
3, Being so ad\'ised. I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this aftidavit arc true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa, C,S. Section 4904 relating to
unswom falsification to authorities,
;v;~ I it.1
.199N
~((/
ROBERT . BALES, JR.
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,IOJ)l I., HALES.
/)l'fl'llIlunt
9H-l,755 CIVIL TER:\I
ROIIERT C. IIAI.ES. ./R..
l'lulnllrr
: 1:'01 TilE COllIn OF CO:\I:\IO:'ol PLEAS OF
: {'l1:\/IlERL,\:'oIJ> (,OIlNTY.I'EN:'oISYI.\'A:'IIIA
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CI\'II. ACTlO:'ol -I.AW
IN J>IVORCE
AFFII>A VIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P, RULE NO. 1920.4 (a)(I)(i)
: SS:
COMMONWEALT" 01' I'ENNS\'LVANIA
COUNTY OF CUMBERLAND
stale:
NOW. Mark D. Schwartz. Esquire. heing duly swom according In law. docs depose and
I. That he is a competent adult and attorney f()r the plaintiff in the captioned action in
divorce,
2, That a certified copy of the Complaint in Divorce was served upon the defendant on
December II. 1998. by certified. restricted delivery mail. addressed to her at 113 Chestnut
A venue. Mt. Holly Springs. Pennsylvania 17065. with Return Receipt Number Z 013 279064,
3, That the said receipt l(lr certified mail is signed and altaehed hereto and made a part
hereo t:
I verilY that the statements made in this aflidavit arc true and correct. I understand that
false statements herein made arc subject to the penalties of 8 Pa, C. S, Section 4904. relating to
unsworn talsilication to authorities
1\' RK D. SCHWARTZ. ESQUIRE
Attorney for Pluintiff
Date: October 28th
.1999
ROHERT C. HALES. ,In..
1'llIlnllff
: I:'; TilE ('onn OF ('0\'\'0:'; "LEAS OF
: ('!'\IIIEIU"\:';U (,Ol::';I'Y.I'E:';:';S\'L\'ANIA
\'.
CI\'IL ACTIO:'; . LA\\'
IIK-(,7~~ CI\'II. TER\I
JOJ)J I.. BALES.
Ucfcndllllt
I:'; UI\'ORCE
PLAINTIFF'S AFFIDA VIT OF CONSENT
I. ^ complaint in divorcc undcr Scction 3301(c) of the Divorce Code was liIed on
December I. 1995,
2, The marriage of plaintifT and dclcndmll is irretrievably hroken and ninety days have
elapsed Irom tbe date of the tiling of the complaint.
3, I consent to the entry of a linal decree in divorce,
4, I understand that I may lose rights concerning alimony. division of property. lawyer's
fces or expenses if I do not claim them bclllre a divorce is granted,
I verify that the statements made in this aftidavit arc true and correct. I understand that
false statements herein made arc subject to the penalties of IS Pa, C, g, Section 4904 relating to
unsworn falsification to authorities,
Date: October 28th . 1999
~iL BALES, JR.
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ROIIERT C. IIAtES, .JR..
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('1\'11. ACTION - J.A W
.101>1 I.. IIALES,
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911-(,755 CIVIL TEI{i\1
IN I>IVOIKE
I>EFENDANT'S MARRIAGE COUNSELING AFFII>A VIT
The defendant. being duly sworn according 10 law. deposes and says:
I. I have been advised of the availability of maJTiagc counseling and undcrstand that I
may request that the court rClJuire that my spousc and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Oftice. whieh list is available 10 me upon request.
3. Being so advised. I do not rcquest that the court require that my spouse and
participate in counseling prior to a divorce decree being handed down,
I verifY that the statements made in this a!1idavit are true and correct. I understand that
lalse statements herein made are subject to the penalties of 18 Pa, e.s. Section 4904 relating to
unsworn lalsilication to authorities,
Date:
N~v I~
,1999
~ ~. Poaho
JODI L. IIALES
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SOCIAL SECUI~ITY INFOJ~;\IATION SHEET
PURSUANT TO ~3 Pa,l',S,:\, SIT I it,:--; 4304,1 (a) (3) ALL DIVORCES ~1l;ST
INCLUDE TilE PARTIES SOCIAL SECURITY NIJ1\IIlER
PI. EASE FILL IN TilE ^PPROPRI:\TEI:-;FOR~IATIO:-; A:-.JD RETURN TO TIlE
PROTHONOTARY'S OFFICE
DATE:
November 17, 1999
DOCKET NUMBER: 9H-6755 Civil Term
PL^INTlFF~~{ SSiJ 592-60-0483
NAME:
Robert C. Bales, Jr.
DEFENDANT/N~X."ON~SS II 160-68-2219
NAME:
Jodi L. Bales