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HomeMy WebLinkAbout00-06045 , - ., , ~ r " . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . PENNA. . . STATE OF ~ TIMOTHY S. WOLF, Plaintiff No. 00-60Lf5 . VERSUS . . . . JANE G. WOLF, . Defendant . . . . DECREE IN DIVORCE ~~ t..s . . . "72"'P' , IT IS ORDERED AND AND NOW, . . TIMOTHY S. WOLF PLAINTIFF, DECREED THAT . . . JANE G. WOLF , DEFENDANT, AND . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECaRf~~ ~HIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; VV\J\I\..t . . . The Marital Settlement Agreement of June 12, 2001, is hereby incorporated. . . . . . . . . ..~ J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . .,-. "" ;, - ',~' -- , ',' ;.....' ~"o__ "H_' _ '.,~ ,. ",,,.:.,. ,,-.' - :'-<..~,~ ' ,--',".,'--'> -";;.C,,!,, , r , ... TIMOTHY S. WOLF, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERlAND COUNTY, PENNSYLVANIA v. : NO. 00-6045 CIVIL TERM JANE C. WOLF, : IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for the divorce is irretrievable breakdown under Section of 3301(c) of the Divorce Code. 2. The Complaint was placed in the U.S. Mail, certified, restricted delivery, on September 1, 2000, and service was accepted on September 5, 2000, 3. Plaintiff's Affidavit of Consent required by Section 3301(c) of the Divorce Code is dated June 12, 2001, and the Defendant's Affidavit of Consent required by Section 3301(c) of the Divorce Code is dated June 11, 2001. 4. There are no related claims pending. An Agreement of the parties dated June 12, 2001, is to be incorporated into the Decree in Divorce. 6>/131 oJ Respectfully submitted, s~ JACOBSEN & MILKES 52 E. High Street Carlisle, P A 17013 (717) 249-6427 Attorney for Plaintiff " c< '''>"," - ~' " '_"",,_C"_>,-," > ",,_ :y;),,~ _I ... . , '-;},^ , '- 0 0 C) c: ~'d 'I s: c= -00:-,' -c -r; rr1rri --~ jt=- "'-"- Z::J) ,.:-~h~ 7C;:: .1::- W~:;-:;. --<(<-- .-'''..... r::C,1 ;::i'l i-~ ''1"1 j; -.~,} :0 zO -"- ::::s;.(J -0 0:> esrn >c:: s;! ~ :D '0 --<( " .'fl'-'" " < - -~-- ,-.-,.- ,.,'''-. ',-- -': '_::--, ,--'~ ,>,0', ,'~-,>C-->,":/,;.', _ __ ..- -,- .,,- ,",,' '.'C,. c_ -:. . - ,,__ ""_,,, __', . -'"--,,,-'~' TIMOTHY S. WOLF, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV ANlA v. : NO. 00-6045 CMLTERM JANE C. WOLF, : IN DIVORCE Defendant MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this \ d~ day of June 2001, by and between TIMOTHY S. WOLF ("Husband") and JANE C. WOLF, ("Wife"). WHEREAS, the parties were married on March 18, 1989, and have remained married since that time; and WHEREAS, certain differences have arisen between the parties and, as a consequence, they are living separate and apart from each other; and WHEREAS the parties wish to set forth certain covenants and understandings regarding their separation and their respective property rights; NOW THEREFORE, in consideration of the mutual promIses and undertakings contained herein, the parties hereto, intending to be legally bound, covenant and agree as follows: 1. VOLUNTARY AGREEMENT: It is acknowledged by the parties that this Agreement is entered into voluntarily and after due deliberation by each of them. Husband is represented by Samuel W. Milkes, Esq., Jacobsen & Milkes and Wife is not represented. 2. SEPARATION AND NON-INTERFERENCE: It shall be lawful for Wife and Husband at all times hereafter to live separate and apart from each other -'.," ,,',.,'" '. --.-' ~-- -.,-:,;,;--~,~" --:-'-'_:""',;"",-".",",;;,,",::~,^";',::.;.--,:",,-:;6;,},;'~'--, "<"',,,,,~,-<-.~,,-; __, _,,:,<~ and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint, harassment or interference, indirect or direct, frOnI each other. The foregoing provisions shall not be taken to be an admission on the part of either party of the lawfulness or unlawfulness of the causes leading them to live apart. 3. DIVORCE ACTION: The parties acknowledge that an action for divorce between them has been filed by Husband in the Court of Common Pleas of CUlllberland County, Pennsylvania, at the above referenced caption. The parties hereby acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle, amicably and fully hereby, all claims which might be raised by either party in the divorce action. The parties acknowledge that they will execute the necessary Affidavits of Consent for the entry of a final divorce decree in the pending action as soon as the law allows them to do so. 4. KNOWLEDGE OF MARITAL ESTATE: Each party agrees that she or he each fully understands the facts surrounding this divorce, and each has had the opportunity to be fully informed as to her or his legal rights and obligations. 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 Wife's opportunity to consult with an attorney of her choosing and Husband's consultation with his attorney. The execution of the Agreement is not the result of any duress or undue influence, and it is not the result of any collusion or improper illegal agreement or agreements. The parties acknowledge that each has been fully informed of, or is familiar with, the wealth, property, state, and income of the other, and each party is hereby satisfied that such information is true and correct. During the course of the marriage, it is generally Wife who has handled the finances and she is very much familiar with the economic status of both parties. " -~ "~-, ~ -- -~, -- - " '.J - -- ,'.'<-.' V""",:. ':~';'_''';''.'.. ',- c;,':';",,> "'-"'-"~4""'--' '_,,' ~:,,-,,-- ,', '-','" , Both parties are specifically aware of the respective income and assets of their marriage, including any income tax returns which have been filed, any bank accounts which have been held in either or both names, and any retirements funds, including the Oppenheimer Funds held as an IRA by Wife, and the PSERS retirement benefits held by Husband. Statements of accounts of both of these investments have been exchanged recently by the parties. 5. PERSONAL PROPERTY: The parties agree that they have generally divided all personal property, in a manner satisfactory to each of them. Each shall retain and be the full owner of any and all personal property now in his or her possession. In addition, there are certain items of personal property which are to be considered Wife's property, but which remain in the possession of Husband, due to Wife's inability at present to retrieve that property. So long as it is retrieved within one year of the date of this Agreement, Wife shall be entitled to full ownership of the following personal property, which is now in Husband's possession: 1. Pine hutch. 2. Mission furniture including a coffee table and chair. 3. Sofa. 4. Stuffed chair in small room. 5. Instruments including a Selmer tenor Saxophone, a Buffet clarinet, a King clarinet and a Cleveland flute. 6. House plants. If Wife fails to retrieve the property within one year, it shall be considered the sole property of Husband. 6. PRE-MARITAL PROPERTY: The parties agree that any property which might be considered premarital is in the possession of, or is titled in that parties' name and each is full owner of any such property in his or her possession. 7. MARITAL HOME: The parties are currently owners of a home and real estate located at 11 Waterloo Road, Carlisle, Pennsylvania, which is secured by a .-" < < -.--'.',. 0"'_0 , _, -,- ~-;'h..__'_ ;;, "~__ V';:"'~-""_ ;-~-;";-,' - .. .;", ";-~__-,;:,-,,,;,_-< ,- -,,,~..--~ mortgage and also has recorded against it a home equity loan. The mortgage currently has a balance of approximately $75,000.00 and the home equity loan currently has a balance of approximately $15,000.00. The mortgage is in joint names and the home equity loan is in Husband's name only. The parties agree that within two years of the date ofthis agreement, Husband shall secure refinancing of the mortgage, so as to reflect this debt in his name only, and not in joint names. Wife shall cooperate in any manner necessary to assist in this. Commensurate with this refinancing, Wife agrees to deed to Husband, in his name only, the jointly owned property. In the event that Husband is unable to secure refinancing within the two-year time frame, the house shall then be placed for sale at market price in order to satisfy outstanding marital debts. Any proceeds beyond the payoff of the joint debt shall be payable to Husband. In the event that the real estate is to be sold, either because Husband is unable to refinance and is required to do so under the terms of this Agreement or for any other reason, Wife shall have a first option to purchase the real estate at an appraised market value, through an appraiser agreed upon by the parties or an appraiser appointed by the Court if the parties are unable to agree. If Wife should at any time in the future purchase this property and if either or both of the dogs are still living, that would have an impact upon the section in this Agreement having to do with the dogs. If for any reason Husband fails to fulfill his obligation to pay on the marital debt secured against this home, until such time as the home has been sold or refinanced in his name, and if this obligation remains unpaid for a period of sixty days or more, Wife may, at her option, move into the home and Husband shall vacate the home. In this event, Wife shall assume full and sole responsibility for any debts secured against the home and she shall forthwith secure refinancing for any such ^',",~ -" / '-' '"-0,';- -'- -,'--.' "'c-...';;- ;...;,-."" e_~.,Co_'" _'-'-_'''" ,."..~.,_;, _,">'" "'-;i";Y..;,,,> _, _ ".:,'__';;" _"""': debts in her name only. If Wife opts not to take possession of the home, or if she takes possession but fails to secure financing within ninety days of her taking possession, the home shall immediately be sold, under the terms set forth above. 8. ACCESS TO HOME AND STATUS OF DOGS: The parties are the owners of two Labrador dogs, one named Coz and the other named Amy. Both Husband and Wife are close to these dogs and wish to make arrangements for the best treatment of the dogs themselves and arrangements for both parties to be able to continue to have contact with the dogs. Effective the date of this Agreement, the dogs shall be considered Husband's, with the following conditions. Wife shall have reasonable and regular opportunity to visit with the dogs at Husband's residence. If at some point in time this becomes infeasible, due to strain in the relationship or a remarriage of either of the parties, or other circUlllstances which might not be envisioned at the present time, Wife shall continue to be allowed regular access to the dogs but arrangements would then have to be made for this to occur at some other location. In any event, Wife may spend time with the dogs, as of the date of this agreement, either at the residence or at other locations of her choosing, for reasonable periods of time. If Husband were to move to a different address, while either or both of the dogs are still living, and if that address still has reasonable accommodations for these dogs, the terms of this agreement will remain in effect. If Husband moves to a location not suitable for these dogs, the terms of this section would then be renegotiated in order to assure that the best interests of the dogs themselves is being provided for. If the parties are unable to reach an agreement, either may petition the court for a decision as to how to deal with the changed circumstances. Before bringing any court action, however, the parties would first be required to make all efforts to avoid this, including consulting with the Humane Society or other appropriate animal interest organizations. If at some point, under the terms of this Agreement, Wife purchases the .. ~_.=- ,"-" "C'O , . .;0'"' _~_Y';- '":~._, " '0' ,'. ., J:__ - ;,b';~'\"-i > "'., '-> ,;,",":; :,.:':.,;. ,,\: :-;;'~J.:;~~' .~';. - ,,0, ;. ;-'~"~k residence owned by Husband and either or both of the dogs are still living, the dogs would remain at the residence and would become the property of Wife, if she elects this, effective the date of her taking ownership of the residence. Husband would have the same rights and opportunity to spend time with the dogs as has been provided for Wife under the terms of this Agreement. Further, in the event Wife is able to secure a residence which is adequate for and allows the dogs to be with her, Wife will have reasonable and regular opportunity to have possession, or custody of the two dogs, at times agree upon by the parties. If the dog, Coz, should die first, the dog, Amy shall be considered Wife's dog, with Husband having the same rights to have custody of this dog as Wife had with the dogs under the terms of this Agreement. 9. RETIREMENT/SAVINGS: The parties acknowledge that certain retirements benefits may be payable to each of them. Specifically, in connection with Husband's employment with the Carlisle Area School District, he has accrued retirement benefits which will be payable to him in the future and which were accrued during the marriage. These may include both retirement itself and some investments funded during the marriage. Wife may also have accrued retirement benefits from past employment and she has an IRA. The parties specifically agree not to raise any claim towards any such retirement, pension, IRA, 401(k) or similar investments now in the name of the other party or accrued by the other party. In the event that any further documents need to be signed, or in the event that a court order needs to be entered reflecting this agreement, the parties agree to cooperate in any manner necessary to accomplish that end. The only savings of any significance is approximately $400.00 in a credit union fund and this is to be considered fully property of Wife. 10. MEDICAL INSURANCE: Wife is currently covered under Husband's "'ju.__.. _",<,-,--~ ~"f->'="-",,'~';",,:,,; - .~;,,,:, medical insurance in connection with his employment with the Carlisle Area School District. Husband agrees to cooperate in any manner necessary to assist Wife in being able to carry that insurance on, even after divorce, through COBRA benefits. This shall be fully at Wife's expense, however. 11. LIFE INSURANCE: Husband agrees to maintain a life insurance policy on his own life, naming Wife as beneficiary, in an amount of at least $150,000.00 so long as either or both of the dogs is still living at Husband's home. Any disability policies currently held or which might be held in the future by Husband, and any other life insurance policies shall be and remain his sole property with his discretion as to who to name as beneficiary. 12. DEBTS: Each party shall be responsible for his or her premarital debt incurred by him or her and any other debt in his or her own name, unless otherwise addressed in this Agreement. 13. AUTOMOBILES: Wife shall retain full ownership of the 1994 Mazda pick-up truck which is fully paid for and which is titled in her name. Husband shall retain full ownership of the 2000 Honda Civic, which is financed in his name only and is titled in his name. 14. BANKRUPTCY: Each party agrees that in the event he or she should file for bankruptcy, he or she shall indemnify and hold the other harmless for any indebtedness or liability this causes the other person and that such obligation shall not be dischargeable in bankruptcy, or shall be reaffirmed if it is discharged. 15. COUNSEL FEES: Each party shall be individually responsible for payment of his or her counsel fees incurred by him or her in connection with any matters having to do with this divorce. 16. NON-MERGER IN DIVORCE DECREE: The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement, and neither this Agreement, nor the terms -C','-'___._' hereof, shall be deemed to have been merged in any decree or judgment granted in the divorce action, but shall survive and be forever binding upon the parties. 17. EXECUTION OF DOCUMENTS: Each of the parties shall, from time to time at the request of each other, execute, acknowledge and deliver to the other party any and all further instruments that may reasonably be required in order to give full force and effect to the provisions of this Agreement. 18. MUTUAL RELEASE: 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, spousal support, equitable distribution of marital property, counsel fees or costs under the Divorce Reform Act, or otherwise, that they make or hereafter make in and to or against each other's estates or any parts thereof, whether by way of 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. 19. NON-WAIVER: The failure of either party to insist in anyone or more instances upon the strict performance of any of the terms hereof in this Agreement shall not be construed as a waiver or relinquishment of such term or terms in the future. 20. BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court costs and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her, including equitable enforcement of the Agreement. 21. ENFORCEMENT: The parties agree that this Agreement or any part ,'."" '~."_,~ '.-:'0,_,'.,=" """",, "',,.," ",',i... ""~, "" _,",","'"..'. ;",~:",--';;,,,' '. " "-.~ . . or parts hereof may be enforced in any court of competent jurisdiction. 22. APPLICABLE LAW AND EXECUTION: The parties hereto agree that this Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and shall bind the parties hereto, and their respective heirs, executors and assigns. This Agreement shall be executed as original in quadruplicate. 23. ENTIRE AGREEMENT: The parties acknowledge and agree that this Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 24. INCORPORATION IN JUDGMENT FOR DIVORCE: In the event that either Husband or Wife at any time hereafter obtain a divorce, this Agreement and all of its provisions shall be incorporated into any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce shall retain the right to enforce the provisions and the terms of the Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals as of the day and year first above written. ~ z.,~~/~-;? TIMOTHY S. WOLF ~, SAMUEL W. MILKES, ESQ. ATTORNEY FOR HUSBAND ~ c W#- C. WOLF .. .",'~v , lli'.tiiiiJIMif:";;"F" "iIii'~' -~~,-.- "M "~,, ti!VI!I"-: '~ c~tiIW ^ " '--1 ". .- -~ - ,,~,~ - " ~-"'- ~-" -- -" --. ~ ~ - ,0',,(;' ,,'- ~ "-~ . - , ~-- ",-"~,;",, "--'~"-",,^ . .. .~... ~-' -,~ ,,- . 0 (.:.:'.) () C. -'\'1 ;?" ?~~ ._J, C(\ h~ -' ---;, -, ~J:; 1:-;: ""- Z 1"" :~_J. d en -.-- -'< ;.:-::: ~~ ~~~ ~C) ~ ~PI ...;,;... ():D -y C) :PC: Cf? 0 rn ;?'. ~ ~ {x:> 0< , ~, ... , ~ " "~' -.-, "M"'="~_' -,_., '-._.~,,- .,..J.;,',__."""'.'<<,__,_,,, "..,'. >~"."".,"'''''_ A'~~-''''-' ---.---,;"..;.,,-,:'~:.,;-}.---,j.,'..'"_';.t~_, ""1 "'cJ TIMOTHY S. WOLF, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV ANlA ; NO. oo-fj)45" CML TERM JANE C. WOLF, : IN DIVORCE Defendant NOTH~R TO ORFRNn A NO (;T.A 1M R1C:-HT~ 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 the 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 - .m __~ _.-c-' P' ._ ,,_____ ';," .' ,,,,__, - / '" C. "_'_-';:__'._" ~;,' n_"". . . _,- _ ,,^ ,_~ :'.; ". 'H'-~'_"_V;'-" ~- ". . - \0 ,- TIMOTHY S. WOLF, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . : NO. 00- 4,0 95"CML TERM JANE C. WOLF, : IN DIVORCE Defendant r.OMPT.ATN'T' TN OTVORr.R COUNT I - DIVORCE 1. Plaintiff is TIMOTHY S. WOLF, presently residing at nWaterloo Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is JANE C. WOLF, presently residing at 545 pi Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and Defendant were married March 18, 1989. 5. There have been no prior actions of divorce or for annulment between the parties in this or any othf)l' jurisdiction 6. Neither party to this action in divorce is currently a member of the Armed Forces of the United States of America. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage between the parties hereto is irretrievably broken. 2 ,...--,-'';''-- -,'-':"-"":,.' "C" c ~-'"' - ,-" -~i <' 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff requests this Court to: a. Enter a final Decree of Divorce divorcing the Plaintiff from the Defendant; and b. Grant such further relief as it shall deem proper and just. Respectfully submitted, *# BY: Samuel W. Milkes JACOBSEN & MILKES 52 E. High Street Carlisle, P A 17013 (717) 249-6427 (717) 249-8427 - Fax Attorney No. 30130 ~ ,"-',,-,,-^' . -~- , - .__",,,~_,_~_,,,,_,~_.n'<, '".,' _~ ,_ '" _ _'___~'~'_" -" ,::'e' --- .'" -,,', ~_ ,',-- _ c. 'c' ' -';_' -_0-0_'_' ,~ '''"--.'''JLi: VERIFICATION I hereby verify that the statements made in the foregoing 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. ~~~ TIMOTHY . OLF 1$'-/:>-_ 4 ,"c,-_ __ __, --, . .. ----> _N,,2(_"";;';'~~',_-f o~ " .,~-;,,-'-- ~;;., - "-, ~ ",,,_,"',' .,._,,;.,;:, - ~ ,,-,,-" - - - I-~--,,-- --,-,--, ~ - -~- ~ Q 'tl:::. -, ~ (:) --- D --- ~ V\ 0 ~ "\ ~ ~ _ -u," ~ __ r;l':- 'v, ~ ~y:; ~ :"'J -...; VI , <:l' 0'-' ~ r' III ,. Ul .-- ......) <) J~ ,-- ~ -" ~;,. ~ +-_ "" ):~c" "t- ---- .....<- fii' ~ ~ -J=:- ,,_,~o,,~ . .,.. -- ., ,., ,~ - -"_'-'"'_0'"'" .-, ;:=:;; ~~:~ ---oJ :;? c:- _J;:'" ,.~. - .. -- ~ @ r'l .--; , -~ ~-~ ~ J1 - ",.; ~~. _'n' ~'. '_, _ 0 - 0 " , ,_. ;~--,:l~ i"".:>;j:"',~.,, F :,,! , ~ TIMOTHY S. WOLF, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6045 CIVIL TERM JANE C. WOLF, : IN DIVORCE Defendant c;F.R'T'TFTc;A'T'F. OF ~F.RVTc;F. I, Shelley Eichelberger, hereby certifY that a true and correct copy of a Notice To Defend Rights and Claim Rights and a true and correct copy of a Complaint In Divorce Under Section 3301(c), was duly served for the Defendant, Jane C. Wolf, by a registered letter deposited in the U.S. Mail on September 1, 2000, addressed as follows: . Jane C. Wolf 545 First Street Carlisle, PA 17013 And further that this attached card demonstrates that on September 5, 2000, the Defendant was served. I hereby verify that the statements made in the foregoing 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. Date: q I ~ 100 0~ [L}L_9~ Shelley EI berger J ." , ~ ','" ~"- ' o>_,J, .., ce,,, ,",-"- - -~"'-", , ~,< ,~~ C3 E~~- :r~ (J)-<--= ~ ~> ~-"" 5~~ --< -~,- c c ''C, /~~...., ,,"-"-'. J~";' :...) ':::"i -',", :CJ --< -. ..-,'-"""!:'---.,,"',-.-' ... 'l', ., " '~ '"' .' .. I ~ ! ~ Ii I ... ~ ",.,j I al......sI1 to_ve Iha ~:"::l:. additional services. following services (for an -ill" name"ahd address on the reverse of this-form so that we can return this extra fee): card oyou. 81 . - this .... to the f10nt of the mailpIeca, or on the back K spaca <Ioea not 1. 0 Addressee'. Address I' ponnK. . Write "Retum Receipt Recluested" on the mallJ)lecebelowthjlartlole number. 2. III Restricted Delivery .1lle Return ReceIpt will show to whom the article was delivered and the date Co. ostm Ie to f ... delivered. nSUIL p as r rea. Q, 3. Article Addressed to: 48. A~e Number II . Jane Wolf Z 33L 878 285 ~ 545 First Street 4b. S.rvlce Typ. i Carlisle, PA 17013 CJ R.gl.t.red XlD Certnied a: CJ Express Mell CJ Insured g> fl CJ Return Receipt for Mercl1andlse 0 COD " 7. Dale of Dellv.~ S 7'- s-~o po- I 8. Addre....'. Address (Only if requested .. and fee is paid) ! , " 11 .1 1 fI FIeoIllip! ,---' C' - ~ - -ii__ I ,'-q '_-_;,",,0"_ "',,'--';'-.I;'__ '> ",_ ,~- >;'t~ . TIMOTHY S. WOLF, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERlAND COUNTY, PENNSYLVANIA v. : NO. 00-6045 CIVIL TERM JANE C. WOLF, : IN DIVORCE Defendant AFFIDA VlT OF CONSENT L A Complaint in Divorce under the Divorce code was filed May 30, 2000, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 94904 relating to unsworn falsification to authorities. Date: (p / / d ) 0 / ~-~/A! / Tinlothy S. oU :::; ',' ~' -" '. '-,,>, "",'-,",;';';:;..;;.',. ~~ .,. ~jjlilJ'~-' llIIIiiiiI' ,--"-- .,~"" '. "-,'.. ,- ,', 2 ,.;; fi?i;i:i ::.:?I""" :.$ :.:i ,- cl5~-: ~~~: :Ji;\...J fiB c:- >' ~ ., 'J C':} -. ,---.., ::-~ '1 s::::: .':-,:;:; ,,,,~ --- r"::"::- :'i2:;' .t:.~ ?- -:;: ,~,-: f-'- :~~:.Zf {,5r"i1 .::,,-1 -~ CD -<: Co " - " It -,',: , -~~----.'-- -'-".,',:.. -""'- ,- _ - ,- , _ c. ~ -,' _c- ......1-- - , ,,--,-, - # TIMOTHY S. WOLF, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6045 CIVIL TERM JANE C. WOLF, : IN DNORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DNORCE DECREE UNDER 3301(c) OF THE DNORCE 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. S4904 relating to unsworn falsification to authorities Date: (g / IJI 0 I -z::~/#~ Timothy S. olf ,.~,(" .];jLt,J Jli, ",;;, ;h~""""""'-- ">.,.,. .... . " ,,3_~,>"", _""'__~~,~., --e., """ ';" ~.\~,;.~"'- -".,- '-~, - -,<,'0''''- --:,,-.. "-:-;\'-\""", ,'-~-, ~-- --"-~~~-'- :"",__;___~ ',;,._n_ . . ,,,~''"',,., 'd., \ -~._," C'._ . .... " --~ - 0 0 ()- c: on '2" "- ..-- ,-- CJcu C , nln~ ;;:~ ~ Z'~ '"I' ZC~- -::i ~2 of~'- .:::::~t.~) ~Ci ;ro" T: ~'.H :i>:.---, -,;'~ ~:.2 0 ... 2\,.1 orn ;;;8 S' ~ g ...j --< ,~ -~, I ~- -'- '", ---c--" ,~"_. O~~ :-,-,' '--"-"" , " - - ,- '-.,- i;:", '" """,,,+.' ~ ~,_", '. _,"";_" -:~':::", " , , , TIMOTIIY S. WOLF, Plaintiff : IN TIIE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, ~SYLVANIA v. : NO. 00-6045 avn. TERM JANE C. WOLF, : IN DIVORCE Defendant AFFlDA VIT OF CONSENT 1. A Complaint in Divorce under the Divorce code was filed September 1, 2000, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 94904 relating to unsworn falsification to authorities. Date: C, -11- 0 ( ~ W:f #1 "':\i;~)i:::~~-;:'} ',"'>"'",7,>_ ...... "-';::':ill':> ... ~ --.^'" - .=,-, ,- -'~ ~'-, -. ,- ';...- -~ , "';;;;:-:~ .;~-,' \''';-" ~" - - > P,~ ;~--"i-- -. ~.--,'-~ \>:a>--\-,c-"H--:""", ._ "'b- ---~ () a ~ C >- _S'" -'>- ",,(n SPfJC ~ .~T :::Xi <e- lL;::' 0) x- -to ~} '~' ~(~ '-')r1., --1',--", "'" :"T:: ,:T! Pc -"" '-',,_!...,' :z: -' ~, ~-3;: C) $0 ~? Csrr; !;;; j;! ~ <r> ':J:J -:: ~ " - '.. "". -I :il ::_1 , :1 :1 -I 'il " , ,'", ". ,,-,'- -,."" ",.' ~. - - < " O' ~ - .. '. 1 '" . TIMOTIIY S. WOLF, Plaintiff : IN TIIE COURT OF COMMON PLEAS : CUMBERlAND COUNTY, PENNSYLVANIA v. : NO. 00-6045 CIVIL TERM JANE C. WOLF, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQlUEST ENfRY OF A DIVORCE DECREE UNDER 3301(c) OF TIIE 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. ~4904 relating to unsworn falsification to authorities Date: G _1/-01 ~c~ e C. Wolf ii;."" ,~ . ' ~. '," " ~ -.- .~ C,,'.,., . "'~ , -, '~',,>;'J..,. . "_":-',C'.,, ~, ';:';:';1/_"\':;"~'" . ... ,- ~'{':":U;~"': .x'" Ii Ii!Il " . __ o_~ ,_ ,_" . ,"',~ "'~" "''' ~,~- ". ;C' ,-,':-_,_~. , ._--.-, ." (",;",- - ~-' >>!,""'r:"">''"'.'" , ~ i~ II .. :.i !ii il: .. i 0 a ',,-,J >;;; " , '17 fL~ (- Qin; c: ." 2:.:)) :::~ ~ :Z:c ~I r g;;cc .c' '=-1 r-, K"-,: ;~ ~..J , I, ~.-, ',,0. 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