Loading...
HomeMy WebLinkAbout98-06853 , I , I , : i .... ~ ... ~ ~ '" ~ ~. ~ - ~ ~ t .... ~ - - , ..::) , - I~' ~ 0.: ~! e.::,i ~\ ~\ \ ':.:' ':+:. .:.;. -;.; .:+> ,;.;.:.;.;.; :+: ~, ~. . :. . ._ . t',.:'.- ;.: ;.: ..: :.;, ;.; ;.: :.:.;,: ;+:' .;.:. ~I '.' IN THE COURT OF COMMON PLEAS ~I . . ~, , ~~ , .',1 "i " ~, ','I ~; . i ~I ~I ~! ~ ",; S OF CUMBERLAND COUNTY t:1' STATE OF ;~~~ PENNA, SUSAN ANN sew. lOT 6853 S II) 98 :\ ll. \',r',d KARK ROllER! sew. rOT ~ s . , ~l ;1 . , ., ~I ':'/ ~) ,:.:- .:t:.-.;e ,8 !~ , j~ i .;- ).', ," i : ;~ ) . i~ I.:. * ~ s ~ ~ '.' i" ~ ,', ~ I~ .. ,', ~ ~ (. DECREE IN AND NOW, .~. D~ 0 R T ~~.. it i, o,d.,.d o"d ~~~On Scl1nidt decreed thot ",'.'"", , , , , , , , . . ' , " , , . , , , . ' , '. plaintiff, and, ' . .' .', , , , , , , K,a~k ,Robert ,Scl1nidt " ' , , , , . . , . , ' , ,. , . defendant, I'" ~ 3: 3lfP~, 1~ 1:: (~ ( ~.: ~ ~ .. $ ~ ~ ~ ~.' are divorced from the bonds of matrimony. s s 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; .",.....". '. .~~~""',...,"',..,"",.,.,.... $ ~ ~" $ ~ $ ~ ,.., ~ fo" (). *- '.' ~ ~.. $ )-. ~ <: ~ 9...~~;;.--::+:. .:+;. ':+;. -:+:- -:.;. ~:.:.~::";-~:.~:~~:+::~':~;}' .:+:. -:+:- .:.;. -:+;, .:.;. -:+:- Prothonotary ~ ~~ ~ S I ~ i" ~ I ~ , I i ~ , 1., (~ ~~ i'" !~ !,., J. ~ i,'. (~ $ * .., , ,~ -:+:- -:.:- ':~;. <l!):- -:.;. .:.;. ':~;, -:t-:- .:+;. .:+:- SUSAN ANN SCHMIDT. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW vs No 98-6853 Civil Term MARK ROBERT SCHMIDT, Defendant , ACTION IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT .I) -- THIS AGREEMENT. made thi~;!~ day of \J We.. .1999, by and between, SUSAN SCHMIDT, of Camp Hill, CumtlerJand County, Pennsylvania. hereinafter referred to as 'WIFE", and MARK SCHMIDT, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS. Husband and Wife were lawfully married on August 26. 1989. in Mechanicsburg, Pennsylvania, and; WHEREAS, diverse 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 natu~al lives, and the parties hereto are desirous of settling fully and finally their respective financial property rights and obligations as between each other, including, without limitation or specification, the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, settling of all matters relating to the past, present, and future support. alimony, and/or maintenance of Wife by Husband or Husband by Wife; settling of all matters between them relating to the past, present, and future support and/or maintenance of the child(ren); the implementation of custody and visitation arrangements for the minor children of the parties; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. WHEREAS, the provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Husband has employed and had the benefit or counsel of Cindy S. Conley, Esquire as his attorney, The Wife has employed and had the benefit or counsel of Jane Adams, Esquire, as her attorney. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection and that each fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any collusion or improper illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the Court has the right and duty to determine all marital rights of the parties including divorce. alimony. alimony pendente lite, equitable distribution of all martial property owned or possessed individually by the other, counsel fees, and costs of litigation. each party hereto still desires to execute this Agreement, acknowledge that the terms and conditions set forth herein are fair, just, and equitable to each of the parties and waives his or her respective right to have the Court of Commons Pleas of Cumberland County or any other Court of competent jurisdiction make any determination or Order affecting the respective party's right to a divorce, alimony, alimony pendente lite, equitable distribution of all martial property, counsel fees, and costs of litigation. . . NOW THEREFORE, In conSlderatoon of the premises and of the mutual promises, covenants, and undertakings hereinafter sel forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of Ihe parties hereto, Wife and Husband, each In lending to be legally bound. hereby covenant and agree as follows 1, SEPARATION, That the parties IIltend to malllt3ln separate and permanent domiciles and to live apart from each other, Il is the intenlilln and purpose of Ihls agreemenllo set forth their respectove rights and duties while they conllnue to live apart from each other, Whereas a Complaint in Divorce was filed. bolh parties will agree to a No.Fault Divorce after Ihe applicable ninety (90) day time period has run. The parties have attempted 10 divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the fights of each party, tt is the intention of the parties that such division shall be final and forever determine 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, 2. INTERFERENCE. Further, the parties agree to conlinue living separately and apart from each other at any place or places Ihat he or she may select. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner 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, 3. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Wife has filed a Complaint in Cumberland County, claiming that the marriage is irretrievably broken under the no.fault mutual consent provision of Section 3301 (c) of the Pennsylvania Divorce Code, Husband hereby expresses his agreement Ihat the marriage is irretrievably broken and expresses his intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301 (c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code, It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment. or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction. each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry (it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of separation,) It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof. may be incorporated by reference into any divorce, judgment, or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4, DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. DISTRIBUTION DATE. The transfer of property. funds. and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein, 6. WIFE'S DEBTS, Wife represents and warrants to Husband thai Since the separallon she has not and in the future she Will not contract or Incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligallons Incurred by her. 7, HUSBAND'S DEBTS, Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debl or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligallons incurred by him, 8. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations, Any and all debts in her name alone regardless of when incurred, (bJ Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. Any and all debts in his name alone regardless of when incurred, 9. MUTUAL RELEASE. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators. and assigns, release and discharge the other of and from all causes of action. claims, rights, or demands whatsoever. in law or equity, which either of the parties sever had or now has against the other. except any or all cause or causes of action for divorce and except any or all causes of action of breach of any of the provisions of this Agreement. 10. MUTUAL WAIVER OF EMPLOYMENT BENEFITS, The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 11. OTHER ASSETS/FINANCIAL ACCOUNTS. The parties acknowledge that unless specified otherwise herein. all other assetslfinancial accounts shall be and remain the sole and exclusive property of the party to whom said asseUaccounts are titled or if untilled, to the party in possession. 12. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties. they agree as follows: (a) Registration and Title of the 1992 Toyota Camry will be transferred from Husband's name to Wife's name. (b) The Nissan Maxima shall be and remain the sole and exclusive property of Husband, The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided. on or before the date of execution of this Agreement, and said executed titles shall be delivered to the proper parties by the distribution date, Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles, , , " 13. PERSONAL PROPERTY. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waiver, release, renounce, and forever .1: t abandon whatever claim, if any, he or she may have with respect to the above Items which shall become the sole and separate property of the other Notwithstanding the above. the personal property described on Exhibit "A" shall be divided between the parties as provided for In Exhibit -A" The following Items (formerly owned by Wife) Will be lelt for Ashley's use in her bedroom, playroom, green room and basement. and shall hereafter constitute Ashley's separate property, Dresser Desk and chair Bed frame and head board Wall shelves (x2) Girl/Boy print Round end table Table cloth Loveseat Hassock Chest Bookshelf Chair Linen drawers Sofa in basement Prints in basement Toy box White bar stool Table Stereo and speakers Any other accessories 14. LUMP SUM PAYMENT, Husband shall. within thirty (30) days of the date of execution of this agreement, pay to Wife. the sum of Fifty Thousand Dollars ($50,000,00) as and for equitable distribution. 15. MARITAL RESIDENCE. The parties acknowledge that they own, as tenants by the entireties, real property known as 316 West Meadow Drive, Mechanicsburg, Cumberland County. Pennsylvania 17055 (hereinafter referred to as the marital residence), Wife shall, upon receipt of the above-referenced lump sum payment. transfer to husband. all of her right, title, and interest in the marital residence, subject to any outstanding debt associated with the marital residence which shall be husband's sole and exclusive responsibility. Thereafter, husband shall be the sole and exclusive owner of the marital residence free and clear of any right, title and interest of wife's, Husband shall be solely responsible for all payments of taxes, utility charges, mortgage payments, assessments, and maintenance costs of the marital residence and shall indemnify wife and hold her harmless from any responsibility thereof, 16. ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to alimony pendente lite. and each party agrees to be responsible for his or her own legal fees and expenses, 17. WAIVER OF ALIMONY. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release. and give up any rights they may respectively have against the other for alimony, support, or maintenance. It shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. In furtherance of Ih.s paragraph, Wtle agrees 10 withdraw any ond 011 clarms that she has Mrelolorc filed lor alimony wllh Ihe Coull of Common Pleas 01 Cumberland or any other Courts 18, LEGAL AND PHYSICAL CUSTODY OF CHILDREN. The part.es agree that both parties Will have shared legal and phYSical cuslody of Ihe child. Ashley Schmidl Schedule 0' care Will be delermined by both parenls The parties acknowledge that a change of custody may occur any limo dUring tho course 01 Ashley's Iile based upon her needs and maturity pursuant 10 further agreement of the partIes or If the parties are unable to agree by court order, 19. CHILD SUPPORT, A, Untit further agreement of the parties or order 0' court, Husband's obligations shall be: 1 ,During the school year: Pay 60% of after school care' (unlilthe age of 12 or maturity level), 2,During the summer months: Pay 60% for all day care' (until the age of 12 or maturity level), 3.Pay for 60% of Ashley's activities throughout the year. e,g" dance, soccer, elc,. and associated clothing, 4,Pay for any appointments, lunches. snacks. field trips, etc, thaI may be scheduled during the days of Husband's care, 5.Provide health and medical insurance available through his place of employment at reasonable cost for Ashley for so long as he is able or until she reaches the age of 22, whichever first occurs. 6.Pay 60% of Ashley's unreimbursed medical expenses, Note: While Ashley is jointly cared for, Husband may claim her as a dependent on his income tax, B. Until further agreement of the parties or order of court. Wife's obligations shall be: l.During the school year: Pay 40% of after school care (until the age of 12 or maturity level). i, 2.During the summer months: Pay 40 % for all day care (until the age of 12 or maturity level). 3,Pay for 40% of Ashley's activities throughout the year, e,g" dance. soccer. etc.. and associated clothing, 4.Pay for any appointments, lunches, snacks, field trips, etc. that may be scheduled during the days of Wife's care, t. 5,Pay 40% of Ashley's unreimbursed medical expenses. ,', ';i. The obligation of support may be modified at any time on the basis of material change in circumstances of lhe parties or the child either upon the agreement of the parties or order of court, ,OJ, r~ f' ~i ~: C, Husband may have Ihe benefll of uSing his employer's Medical Expense Reimbursement Plan and Dependent Care Assistant Plan through the 1999 lax year Beginning January 1, 2000, Wofe shall use the Medical Expense Reimbursement Plan and Dependent Care Assistant Plan provided through her employer and Husband shall dlsconllnue use of these plans 20, HEALTH INSURANCE. Husband shall provide heallh and medical insurance through his employment for Wife unlll the final Divorce Decree is obtained 21, TAXES. Husband and Wife shall file a joint Federal, State and local Income Tax return for the 1998 tax year. Wife shall keep $600 of the refund for the 1998 tax year, All future lax returns shall be filed separately, with the returns to be retained by Ihe respective parties While Child is joinlly cared for, Husband may claim her as a dependent on his income tax, 22, WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or defaull hereunder shall be deemed a waiver of any subsequent default of the same or similar nature, 23. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement 24. APPLICABLE LAW, The Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 25, WAIVER OF CLAIMS AGAINST THE ESTATES: 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 of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take 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, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. This agreement shall be binding and shall insure the benefit to the parties hereto and their respective heirs, executors, administrators. successors, and assigns, 26. METHOD OF PAYMENT. All payments for child's after school and summer care along with settlement contributions shall be sent to wife. unless otherwise specified at: 252 East Crestwood Drive, Apartment C-8, Camp Hill, Pa" 17011 or at her current address if she moves. 27. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein, 28, OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments. assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 29. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same. nor shall the waiver of any defauit or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. ~ Casserole dIsheS (d,strobuted). Pots' and pans' (dlstrobuted). DIsh towels (dlstrobuted). Blacker and Decker chopper Longebergor basket (napkins)' Ivy pot above cabInets' Oriental rug' Sola' Lazyboy' Calfee table" End table' Brass lamp' Brass fireplace tools' Brallforeplace door/screen' Green cushions (3)' Home entertainment center (armoire)' Large brall candia slicks Small brass candle stIcks' Crystal candle sticks. Green lamp'. Print - cottage scene' Pront - peollles and iroses'# Prints - herbs x4' Print. JlmThorpe's home Wreaths. fall' spring' indoor (lemon lea!)'# Indoor (floral)'. Mltzsubishi TV (gift)' Yamaha stereo-receiver. tape deck, turntable and two speakers (gift).. Floral arrangement on book shelves' Camcorder (gift)" Eucalyptus wreath in powder room' Tissue holder' Crystal bowl with potpourri' Wastepaper can and soap dispenser' Doorknob tassels' Brass wastepaper can' Waterford lamp. Oriental pot' Mirror' # Floral swag'# Botanical prints x3' Bolvia clock Bolvla clock (black background) # Brass bowl Filing cabinet' Palm tree in oriental pot' Fig tree In oriental pot' Christmas cacti in floral pots' Throw rug in foyer' Dining room table and chairs China closet Center piece - everyday' Christmas' Green Ice bucket IN TIlE COlJRT OF COMMON PLEAS, ('lJMIlEIU.i\ND ('tH IN I Y.I'I:NNSYI.V ANIA SlJSAN ANN SCHMIDT, l'laintill' : CIVil, A('IION - LA W vs. No. 98.6853 Civil Term MARK ROBERT SCIIMIDT, Defendant ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECOR!) TO THE PROTHONOTARY: Transmit the record. together with the following inlllfll1ation to the Court for entry of a divorce deerec: I, Ground for divorce: irretrievable breakdown undcr &1301 (c) ofthc Divorce Code. 2. Datc and manner of the service of the Complaint: Dclivcrcd bv certified mail. restricted dclivery. return reccipt requestcd. delivered on: Deccmber 14. 1998. 3. Date ofcxeeution of the affidavit ofconscnt required by 3301(c) of the Divorcc Code: By Plaintiff: Junc 16. 1999. By Defendant: June 15. 1999. 4. Related claims pending: Nonc. 5. Date Defcndant's Waiver of Notice in S3301(c) Divorce was filcd with the Prothonotary: June 21,1999. Respectfully Submitted: \ , Date: G 'd, I. 01 9 ~ I . No. 79465 117 South Hanover SI. Carlislc, Pa. 17013 (717) 245-8508 Attorncy for Plaintiff ~ IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUSAN ANN SCHMIDT, Plaintiff : CIVIL ACTION - LAW vs, N n--- I "nt-''') : 0,. 'I I'h.ii ?)~ J _ ') : ACTION IN DIVORCE MARK ROBERT SCHMIDT, Defendant NOTICE TO DEFEND AND CLAIM 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Liberty Avenue Carlisle, Pa, 17013 (717) 249-3166 ~: ;\. I 5. I ol'<l wish '" r_ III following ..NIce. (Iolon .ml..): JtD '....... Ade"'" ~ R..lrIcIed Delivery j I lmllalor Iol I.., ! 4e. . Number C I . Llc;',;?- L/. CI 4b. S.NIce Type j o RogIllorlld ....ISl Cor1lftod a: .. o Exp.... Mall 0 lnourlld ~ o RounRocollllIotMon:hardso 0 COD ::0 7. Doto of Delivery ! il .. J i .~_,"""'''''''''''''''', 'I .Cclfrlr,IMII......J............ I .".,. ycu......"..... an'" "'*" ".. bM 10"" we C;M ret"",... -...... -AhctI M form to......." tit........ . on.. Ndl.1IPICe doM noli .w~'!-__.... ..........__.............. , .'fhI ReI"" .......theM to...... "'...... ~ Ind IhI dIIIt 8 -, 13. 0 Mdto. 10: . { ~ _1 \ ~J fP 102595-",B~I79 Domestic Return Receipt i , ~ : t . 1-.. I t I'., . , d.;" l!~, 11'" ~ ,:~y" h~.* :) I!" 'I. 'i' h fl,L ( ;-.: ; ,y'-, SUSAN ANN SCHMIDT. Plainllff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW vs, No, 98,6853 CIvil Term MARK ROBERT SCHMIDT. Defendant : ACTION IN DIVORCE AFFIDAVIT OF CONSENT /)_ 1, A coml1laint in divorce under section 3301(c) of the Divorce Code was filed on UC /../rh) Iqq(( , 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce, 4, I understand that I may lose my rights concerning alimony. division of property. lawyer's fees, or expenses, if I do not claim them before a divorce is granted, I understand that the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa,C,S, 4904, relating to unsworn falsification to authorities, Date: 1"2- . i G ' q c, ,C>4u1fP.-.a-c"dJ-"" ('A/ Susan A'nn Schmidt. Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301tcl OF THE DIVORCE CODE 1. I consent to entry of a final decree of 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. 94904 relating to unsworn falsification to authorities, Date: 12.. ' {&" q ~ 0vM~/M Qf.(hd/ Susan Ann Schmidt, Plallltiff IN THE COURT OF COMMON PLEAS OF CUMAERI.AND COUNTY, PENNSYLVANIA SUSAN ANN SCHMIDT, ) ) ) ) ) ) ) CIVIL ACTION. LA W IN DIVORCE Plaintiff v. NO. 98 - 6853 Civil Tcrm MARK ROBERT SCHMIDT, Defcndanl WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 11330I(c) OF THE DIVORCE CODE I. I consent to the entry of a final decrce of divorcc withoul noticc. 2. I understand that I may losc rights conccming alimony, division of property, lawyer's fces or expenses if I do not claim thcm before a divorce is granted. 3. I understand that I will not be divorced until a divorce decrec 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 lhatthe statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of I g Pa.C.S. 94904 relating to unsworn falsification to authorities. rr Date: ~""-<.15 tqq I 11M UJ .JLit Mark Robert Schmidt, Defendant ~