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MARITAL SETTLEMENT AGREEMENT
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THIS AGREEMENT is made this ();/t day of ( I(/t(f){ t
, 1998, by
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and between VINCENT W. PUGLIESE ("HUSBAND") and DIANE L. PUGLIESE
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("WIFE");
WHEREAS, the parties hereto were married on June 17, 1977, in Carlisle,
Cumberland County. Pennsylvania; and
WHEREAS, no children were born of this marriage; and
WHEREAS, differences, disputes and difficulties have arisen between the
parties and it is therefore their intention to live separate and apart for the rest of their
lives and to settle fully and finally their financial and property rights and obligations
between each other.
NOW, THEREFORE, the parties hereto, intending to be legally bound hereby,
agree as follows:
1. LEGAL ADVICE AND VOLUNTARY EXECUTION OF AGREEMENT:
HUSBAND and WIFE each acknowledge that he and she have obtained, or have
had the opportunity to obtain, independent legal advice from counsel of his or her
selection, and that each have determined to complete this Agreement. The parties
acknowledge that Wife has been represented by Andrea C. Jacobsen, Esq.,
JACOBSEN & MILKES, with regard to this Agreement, and that Husband has elected
t.o proceed without legal representation.
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Each party acknowledges and accepts that this Agreement is in the
circumstances, fair and equitable, and that it is being entered into freely and
voluntarily. Each party hereby confirms that he or she fully understands the terms,
conditions and provisions hereof and believes same to be fair, just, adequate and
reasonable under the existing facts and circumstances. The parties further declare
that each is executing the Agreement freely and voluntarily, without duress, undue
influence or coercion, having eit.her obtained sufficient knowledge and disclosure of the
wealth, property, estate and income of the other, and their respective legal rights and
obligations; if counsel has not been consulted, the right to do so is expressly waived.
2. SEPARATION AND NONINTERFERENCE
It will be lawful for each party at all times hereafter to live separate and apart
from the other at such place or places as he or she may from time to time choose or
deem fit. Each party shall be free from interference, authority and control, direct or
indirect, by the other, as fully as ifhe or she were single and unmarried. Neither shall
bother the other or compel the other to cohabit or dwell with him or her.
3. SUBSEQUENT DIVORCE
The parties acknowledge that no divorce action seeking the dissolution of their
marriage is currently pending in any court. The parties hereby agree that, should
either party seek and obtain a divorce, the terms of this Agreement shall be
incorporated into the final divorce decree entered by the Court and shall constitute a
settlement of all claims related to the divorce action.
4. EFFECTIVE DATE
This Agreement shall be effective on the date above first written.
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5. MARITAL DEBTS AND OBLIGATIONS
a. WIFE hereby agrees to assume full responsibility for, and to hold
HUSBAND harmless with regard to the following items of outstanding joint marital
debt:
i. First Mortgage loan from GMAC Bank with approximate
current balance of $63,000.
ii. Home Equity loan from PNC with approximate current
balance of $19,000.
iii. All credit card obligations in WIFE'S name.
b. HUSBAND hereby agrees to assume full responsibility for, and to hold
WIFE harmless with regard to the following items of outstanding joint marital debt:
i. Revolving Credit Line loan from PSECU, with approximate
current balance of $9,000.
ii. Lease for 1998 Toyota Camry.
iii. All credit card obligations in HUSBAND'S name.
c. Each of the parties covenants and a.grees that to his or her
knowledge, except as otherwise provided for herein, all other joint debts and
obligations have been satisfied and they have no joint debts or obligations. Each party
further agrees that neither he nor she will any time in the future incur or contract any
debt, charge or liability for which the other party, or her or his property or estate,
might be responsible and each of them further covenants at all times hereafter to keep
the other free, harmless and indemnified of and from all debts, charges and liabilities
hereafter or heretofore contracted by them except as herein provided.
6. REAL PROPERTY
WIFE and HUSBAND hereby acknowledge that they have jointly owned a
condominium unit located at 640 Allen View Drive, Mechanicsburg, Pennsylvania,
17055. Wife agrees to refinance the marital home within ninety (90) days of the
execution of this Agreement in order to remove HUSBAND's name from all obligations
associated with the home including the first mortgage with approximate balance of
$63,000 and the home equity loan with approximate balance of $19,000. Until such
time as the refinance of the unit, WIFE shall assume exclusive possession of the
premises and shall be responsible for all obligations for the property, including but not
limited to, any and all mortgage obligations, taxes, insurance, utilities, maintenance
and upkeep. WIFE hereby specifically agrees to indemnify and hold HUSBAND
harmless with respect to any of these related obligations pertaining to the subject
property. HUSBAND hereby waives any interest in the property and agrees to execute
a deed in order to transfer his interest in the property to WIFE upon notice of a
settlement date for refinance of the mortgage obligations against the present title to
the unit.
The deed shall be delivered to WIFE's attorney upon the agreement that it shall
not be recorded until WIFE's attorney can certify that all steps have been taken to
satisfy the existing mortgage or to remove HUSBAND's name from the obligation.
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7. PERSONAL PROPERTY
Except as provided for within this agreement, the parties acknowledge that
there has been distribution between them of their items of personal, tangible and
intangible property, including various bank accounts, credit union accounts,
furnishings, vehicles, etc., and they agree that the division thereof is to their mutual
satisfaction. Each of the parties shall hereafter own and enjoy, independently of any
claim or right of the other party, all items of personal, tangible and int.angible property
now or hereafter owned or held by her or him with full power to dispose of the same
effectively and for all purposes as if she or he were unmarried.
The parties acknowledge that HUSBAND shall release all interest, title or claim
to the 1992 Sat.urn GL vehicle owned by the parties, which shall hereafter be the sole
and separate property of WIFE.
The parties acknowledge that WIFE shall release all interest, title or claim to
the Camry vehicle leased by the parties, the leased interest in which shall hereafter be
the sole and separate property of HUSBAND.
8. PENSION, RETffiEMENT AND OTHER EMPLOYEE BENEFITS
HUSBAND and WIFE acknowledge that the marital property includes all or a
portion of WIFE's 401K plan through ASHCOMBE VEGETABLE FARM SAVINGS
PLAN, with approximate value of $14,700, and IRA with VAN KAMPEN AMERICAN
CAPITAL FUNDS and a share of HUSBAND's interest under the State Employees
RetireD1ent System. HUSBAND hereby forever waives and relinquishes any right,
interest or claim that he might have otherwise in WIFE's 401K plan, her IRA and any
other pension, retirement, deferred income or employee benefits plan to which WIFE
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may be or may become entitled. WIFE hereby forever waives and relinquishes any
right, interest or claim that she might have otherwise in HUSBAND's benefits under
the State Employees Retirement System, or any other pension, retirement, deferred
income or employee benefits plan to which HUSBAND may be or may become entitled.
9. INSURA.N'CE POLICY
The parties acknowledge that there exists a certain life insurance policy on the
life of HUSBAND with benefits of approximately $122,000 payable on death of
HUSBAND which has been paid on through the course of the marriage of the parties.
HUSBAND hereby agrees to maintain such insurance coverage from the date of this
Agreement. In the event of HUSBAND'S death or other liquidation for cash value of
the benefits of the insurance policy, HUSBAND agrees to pay WIFE the sum of
$10,000. This obligation shall be binding on HUSBAND'S estate. Excepting the
payment d'le her under this paragraph, WIFE releases all other interest or claim to
the proceeds or eash value of sueh insurance policy.
10. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, ALIMO:NY
WIFE and HUSBAND do hereby waive, release, discharge and give up any
rights which either may have against the other to receive spousal support, alimony
pendente lite, alimony or other post divorce maintenance or support. From the
execution date of this Agreement, it shall be the sole responsibility of each party to
sustain himself or herself without seeking any support from the other.
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n. A'ITORNEY FEES, COURT cos'rs
Each party hereby agrees to be solely responsible for his or her own counsel
fees, eosts and expenses. Neither shall be seeking any contribution t.hereto from the
other party except as otherwise expressly provided herein.
12. MUTUAL RELEASE
HUSBAND and WIFE do hereby release each ot.her from any other claims with
respect to the marital and non-marital assets of the parties, except as provided under
this Agreement. Additionally, eaeh party hereby releases any interest that he or she
may have in the estate of the other. Except as provided for in this Agreement, the
parties hereby remise, release, quit-claim and forever discharge each other and the
estate of each other, for all time to come, and for all purposes whatsoever, from any
and every claim, including alimony, alimony pendente lite, equitable distribution of
marital property, counsel fees or costs under the Divorce Reform Act or spousal
support, or otherwise, that they make or hereafter make in and to or against each
other's estates or any parts thereof, whether by way or dower or curtesy, or under the
intestate laws, or the right to take or elect against the other's will, except only such
rights as accrue pursuant to this Agreement.
13. MUTUAL COOPERATION
HUSBAND and WIFE shall mutually cooperate with each other in order to
carry through the terms of this Agreement, including but not limited to, the signing
of documents.
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14. AGREEMENT BINDING ON lII~ms
This Agreement constituteH the finlllul~reellwnt. of' the Plll"ties und is binding
upon their heirs, assigns and SUCClJ8S0l'S in int.ereHt..
15. APPLICABLE LAW
This Agreement shall be eOllstrued under t.he luws of' t11lJ Commonwealth of
Pennsylvunia.
16. ENTIRE AGREEMEN1'
This Ab'l'lJemlJnt contains the ontire IInderHtllndinl-( of' the pllrtilJs, and there are
no representations, wurrantien, COVlJnunt.H 01' ulldertnldlll-(H other thun those expressly
set forth herlJin,
17. BREACH OF AGHEEMENT
In the event that either purly hreudwH uny provision of this Agreement or fails
to timely perform his or her ohlil-(utioll under t.hiH Agreemellt, she or he shall be
responsible for uny und ull eost.H incuned t.o en(i)rce t.he Agreement, including, but not
limited to, court eOllt.H und munHel fees of the ot.her purty. In the event of breach, the
other party shull huve the right., ut. her or his election, to sue for damages for such
breueh or to Hellk such ot.her unll udditional remcdicH us may be available to her or
him,
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IN WITNESS WHEREOF, The parties hereto have set their hands and seals
of the day first above written. HUSBAND and WIFE acknowledge that multiple copies
of this Agreement. have been executed and each party has received a duly executed
copy hereof.
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Witness v
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CENT W. PUGL SE
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Witness
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF CUMl~E~/.AND. :
On this, tho. '/fduy of lJtLC.t"(/~__, I\.D, 1998, before roe appeared DIANE
L. PUGLIESE, known to JIll!, (01' HlltiHl'actorily proven) to be the person whose name
is subscribed to the wit.hin inHtruJllent, and aeknowledged that she executed the same
for the pUI'JlOtjl)8 tlwl'I!in contllined.
IN WI'I'NgSS WllElUmF, I hereunto set my hand and official seal.
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_~~::?; ';;"':~'1" y , ....-' I~OTARIAL SEAL
.-: ' __,,-_'~,!...,~_L I MICHAEL R CARmCI Notary Public
NOTAHY PUBLIC ~ Camp Hili llOro. CUmberland Counly
1 My Commission &plros June 15, 2002
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY Ol~ CUMBERLAND
,
On thill, thlo, 'r)"~y of dr'/{'iJ,>:.I..' ,A.D. 1998, before me appeared VlNCENT
W. PUGLIESE, known to me, (or satisfactorily proven) to be the person whose name
ill subacrilwcl t.o tho within instrument. and acknowledged that he executed the same
for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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NOTARY PUBLIC
I NOTAAIAL SEAL
MICHAEL R. CARANCI, IloIary Public
I Ca:np H!II BolO. Cumberland County
: My Commlsslon &plros JU1lIl15, 2002
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ADDENDUM TO MARITAL SETTLEMENT AGREEMENT
01<' VINCENT W. PUGLIESE AND DIANE L. PUGLIESE
this
THIS ADDENDUM TO MARITAL SETTLEMENT AGREEMENT is made
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, 1999, by and between VINCENT W.
day of /f}d.h
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PUGLIESE ("HUSBAND") and DIANE L. PUGLIESE ("WIFE"),
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In consideration of the mutual covenants herein, the parties' modify ,their ,
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Marital Settlement Agreement of October 20, 1998, as follows:
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1.
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The parties amend paragraph 5. MARITAL DEBTS'? AND"
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OBLIGATIONS to read as follows:
a. WIFE hereby agrees to aBsume full responsibility for, and to hold
HUSBAND harmless with regard to the following items of outstanding joint
marital debt.:
1. First. Mort.gage loan from GMAC Bank wit.h approximate
current balance of $63,000.
n. Home Equity loan from PNC with approximate current
balance of $19,000.
III. All credit card obligations in WIFE'S name.
IV. $170 per month toward the LeaBe of the 1998 Toyota
Camry.
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b. HUSBAND hereby agrees to assume full responsibility for, and
to hold WIFE harmless with regard to the following items of outstanding joint.
marital debt:
i. Revolving Credit Line loan from PSECU, with
approximate current balance of $9,000.
11. The balance ofthe Lease for 1998 Toyota CanllY.
Ill. All credit card obligations in HUSBAND'S name.
c. Each of the parties covenants and agrees that to his or her
knowledge, except as otherwise provided for herein, all other joint debts and
obligations have been satisfied and they have no joint debts or obligations. Each
party further agrees that neither he nor she will any time in the future incur or
contraet any debt, charge or liability for whieh the other party, or her or his
property or estate, might be responsible and eaeh of them further covenants at all
times hereafter to keep the other free, harmless and indemnified of and from all
debts, charges and liabilities hereafter or heretofore contracted by them except as
herein provided.
2. The parties amend paragraph 7. PERSONAL PROPERTY to read
as follows:
Except as provided fOl' within this agreement, the parties acknowledge that
there has been distribution between them of their items of personal, t.anbrible and
intangible property, including various bank accounts, credit union accounts,
furnishings, vehicles, ete., and they agree that the division thereof is to their
mutual satisfaction. Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other party, all items of personal,
tangible and intangible property now or hereafter owned or held by her 01' him with
full power to dispose of the same effectively and for all purposes as if she or he
were unmarried.
The parties acknowledge that WIFE shall release all interest, title or claim
to the 1992 Saturn GL vehicle owned by the parties, which shall hereafter be the
sole and separate property of HUSBAND.
The parties acknowledge that HUSBAND shall release all interest, title or
claim to the 1998 Toyota Canuy vehicle leased by the parties, the leasehold interest
in which shall hereafter be the sole and separate property of WIFE.
Notwithstanding the foregoing, WIFE agrees to continue to pay and be
responsible to provide liability insuranee on the 1992 Saturn GL vehicle until the
end of the current term for the parties' leasehold interest in the 1998 Toyota
Camry vehicle, in or about September 2000.
Notwithstanding the foregoing, HUSBAND agrees to continue to pay and be
responsible to provide liability insurance on the 1998 Toyota Camry vehicle until
the end of the current term for the parties' leasehold interest in the 1998 Toyota
Canny vehicle, in or about September 2000.
3. The parties amend the said A!,'l'eement by the deletion of paragraph
9. INSURANCE POLlCY. Husband shall have no obligation to maintain any
insurance coverage on himself, or to bind his estate to any payment out of the
benefits of any policy.
4. Except as modified by this Addendum, the parties acknowledge and
reaffirm all provisions of their said Agreement dated October 20, 1998. That
Agreement, as modified by this Addendum, contains the entire understanding of the
parties and supersedes any other agreement between them. There are no other
representations, warranties, promises, covenants or understandings between the
parties other than those expressly set forth therein and in this Addendum.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals
as of the day and year first above written.
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DIANE W. PUGL1)jlSE
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DIANE L. PUGLmSE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUN'l'Y, PENNSYLVANIA
v.
: NO. 98-7292
CIVIL TERM
VINCENT W. PUGLIESE
Defendant
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to t.he Court
for entry of a divorce decree:
1. Grounds for the divorce is irretrievable breakdown under Section of
3301(c) of the Divorce Code.
2. The Complaint was served upon and accepted by the Defendant on
January 2, 1999.
3. Affidavits required by Seet.ion 330l(c) of t.he Divorce Code were executed
by the Plaintiff and by the Defendant.
4. There are no relat.ed claims pending.
5. The Notice of Intention to Request Entry of Divorce Decree was signed by
Plaintiff on May 24, 1999 and by Defendent on May 24, 1999.
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DIANE L. PUGLlJ<;SE
Plaintiff
: IN THE COURT OI? COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
CIVIL TERM
VINCENT W. Pl:GLIESE
Defendant
: IN DIVORCE
COMPLAIN'!' UNDER SECTION 3301 c) OR :3301 d
OF THE DIVORCE CODE
1. Plaintiff is Diane L. Pugliese, who resides at 640 AIlenview Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is Vincent W. Pugliese, who resides at 178 S. Wyoming
Street, Hazelton, Pennsylvania 18201.
3. Plaintiff has been a bona fide resident in the Commonwealth for at
least six months immediately previous to the filing of this Complaint,
4. The Plaintiff and Defendant were married on June 17, 1977, Carlisle,
Cumberland County, Pennsylvania.
5. ,!'here have been no prior actions of divol'ce or for annulment between
the parties.
6. The marriage is irretrievably broken.
7. P~aintiff has been advised that counseling is available and that
Plaintiff may have the right to request that the Court require the parties to
participate in counseling.
8.
~ejther Plaintiff or Dcfendant is a member of the Armed Forces of the
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I hereby verify thut the statements made in the foregoing ure 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.
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DIANE L. PUGLIES~-- /
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DIANE L. PUGLmSJ'~
plain tiff
: IN THE COURT OF COMMON PLEAS OF
: CUMl3l~RLAND COUNTY, PI~NNSYLVA:-JIA
: cr<. V 'I,)
: NO. CIVIL TERM
v.
VINCENT W. PUGLIESE
Defendant
: IN DIVORCE
CI~H.1'IFICATE OF SERVICE
I, Angela Garland, hereby certify that a true and correct copy of the
Complaint Under Section 3301(c) or 3301(d) of the Divorce Code in the above
captioned matter was duly served upon the Defendant, Vincent W. pugliese, by
depositing it in the U.S. Mail, certified, return receipt requested, on December 30,
1998, addressed as follows:
Vincent W, pugliese
178 S. wyoming Street
Hazelton, Pennsylvania 18201
The return reeeipt card was signed on January 2, 1999. The return receipt
card is attached as Exhibit "A."
I hereby verify that the statements made in 1,11<' foregoing are true and
correct. 1 understand that false statements herein are made subject to the penalties
of 18 Pa,C.S. Section 4904, relating to unsworn falsification to authorities.
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DIANE L. PUGLIESE
Plaintiff
: IN THE COUR'!' OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 98-7292
CIVIL TERM
VINCENT W. PUGLIESE
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUES'I'
ENTRY OF A DIVORCE DECREE
UNDER ~ 3301(c) OF THE DIVORCE CODE
1. I consent to the 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 ::,rranted.
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.
9 4904 relating to unsworn falsification to authorities.
Date: /'," :i/ fI
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DIANE L, PUGLlEf:lE
Plaintiff
: IN TilE COURT ()l<' COMMON PLEAS Ol~
: CUMBERLAND COUNTY, PI~NNSYLVANIA
v,
: NO. 98-7292
CIVIL TERM
VINCENT W. PUGLIESE
Defendant
: IN DIVORCI<;
AFFIDAVIT OF CONSENT
L A Complaint in Divorce under the Divorce code was filed on December 29,
1998, and served on January 2, 1999, on the grounds that the marriage of the
parties is irretrievably broken.
2. 'l'he marriage of Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of filing und service of the Complaint.
3, I consent to the entry of a final decree of divorce.
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 the Affidavit 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:
r/')L/ 1((0
d~~~tL_'T Ie). ;Q
VINCENT W. PUGLI E
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'JACOIISEN BiMILKES
,',' S2 aA.sT.Il~ ~TREET
CARLlSLE,PA 17013.3085
'(717)249,6427
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: IN nm COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 98.7292
CIVIL TERM
VINCENT W. PUGLIESE
Defendant
: IN DIVORCI~
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER Ii 3301(c) OF THE DIVORCE CODE
1. I consent to the 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.
!i ,1904 relating to unsworn falsification to authorities.
Date:
J- J- y:. ? 9'
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VINCENT W. PUGL
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