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HomeMy WebLinkAbout00-06902 . . . .. ... . "'''' ;Ii,IH';;" . . ,J':" " ,~ "'''' "'''' ;Ii'" "''''''' "'''';Ii''''''",,,,,,,,,,,,, "'''''''''' "''''''' .. ... . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY AND NOW'~( Marcella :8. MeLaughliD. . . . . STATE OF . . . . . . . Marcella 8. MeLaughl1l1., Plailltift . . . VERSUS . . Richard D. McLaul!:hlin. . . . nereRdaRt . . . . . . . . . . . . . . . DECREED THAT . AND . . . . . PENNA. No. 6902 Ci'til Term 2000 DECREE IN DIVORCE co ~<(~'~~A,~ ~,-, IT IS ORDERED AND ~ . , PLAINTIFF, Richard D. McLaughlin , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. Ilene . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "''''''' :Ii:f."';+; :f.;f.:f.;f. . 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; . . . . . . . . . . . . . J. . f~ PROTHONOTAR' :f. ;f. :f. Of :F. :F. :f. :F. :f. :f.:f.:F.:f. :f.:F. :F. .. ".d..J. ~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I " ",,_e,' \ f '"'' '., l f! IcJ.tJl M- ~ ~ z: 4 ~ 4'/;l.O/ ~ ~ Jt'1f! ,- 1- ~ '-, ~-~ ._". 'i ,,-,,~'-___""~__i-~_~'_ fl,""",,.'~ _ _~,~"!"l! _ __ ~ '-c'_" _--J-- . 1- , .J!J OCt M~ - . - .'~ II$L 1;t -4 . J MARCELLA B. McLAUGHLIN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 6902 Civil Term 2000 RICHARD D. McLAUGHLIN, Defendant ACTION IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, madethis~_7~ day of ~ ,2001, by and between, MARCELLA B. McLAUGHLIN, of Mount Holly SpringS, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE", and RICHARD D. McLAUGHLIN, of Mount Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND". WITNESSETH: and; WHEREAS, Husband and Wife were lawfully married on March 9, 1986, in Palm Beach, Florida, WHEREAS, there were three children born of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband is PRO SE. The Wife has employed and had the benefit or counsel of JANE ADAMS, ESQUIRE, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. 3. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run. .-. H ~_ ~, J., "'" ;~ ,-"" ~~, . . The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It 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. 4. FREEDOM FROM INTERFERENCE. Further, the parties agree to continue living separately and apart from each other at any place or places that 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. 5. 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 that 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. 6. 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. 7. 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. 8. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, or whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or " . ..~ - ole." "iC ,', :' . all other rights of a surviving spouse to participate in the decease spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of any marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof. 9. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants represents that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. 10. 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. Chrysler Accoun\#11420957541435. (b) Husband and Wife will equally split payments and responsibility for the following obligations: Beneficial Accoun\#711715-00-506-177-8 11. DIVISION OF PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art, and other 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 wavier, release, renounce, and forever 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. 12. OTHER PERSONAL PROPERTY. The parties agree that the WIFE shall retain all furniture and personal property which is currently in her possession. 13. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The 1998 Plymouth Breeze shall be and remain the sole and exclusive property of Wife. (b) The Mitsubishi Truck 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, within thirty (30) on the date of execution of this Agreement, and said executed titles shall be delivered to the proper parties. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. The title to the 1998 Plymouth Breeze will be transfered to wife's name alone within thirty (30) days after the loan on said vehicle is paid off and returned by the bank to the parties. - M " ,. 0 ".i"..h ,~ Urm:: 14. 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. 15. ALIMONY, ALIMONY PENDENTE LtTE 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. 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. 16. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for calendar years 1986 through 2000 have been filed and that no notices have been received from the Internal Revenue Service which remain unresolved. Each party further represents to the other that to the best of his or her knowledge, the information set forth in the joint tax return for these calendar years was and remains accurate as relates to his or her sole income and acknowledges that the other party relied on such representations in signing those returns. Therefore, if any deficiency in federal, state, or local income taxes is proposed, or any assessment of any such tax is made against the other party by reason of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax, interest, and penalties or expenses shall be paid solely and entirely by the responsible party as determined to be attributable to that party on account of misrepresentation or failure to disclose relevant information of income on the aforesaid joint returns. It is further agreed that: WIFE shall claim the couple's three children as deductions on her income tax return. 17. LEGAL AND PHYSICAL CUSTODY OF CHILDREN. The parties agree that WIFE will have primary physical custody of the couple's three children, namely: Krystle McLaughlin, dab 3-23-87, Sarah McLaughlin, dab 11-6-90, and Tammi McLaughlin, dab 4,27-93. The parties shall have shared legal custody of the children and shall make decisions regarding medical care jointly. HUSBAND shall have liberal temporary physical custody according to a schedule to be agreed upon by the parties which shall be consistent with the best interest and welfare of the said children. As a minimum, shall have physical custody according to the schedule set forth below: HUSBAND shall have visitation with the children every other weekend, on alternating holidays, and at other times as the couple may mutally agree. In addition, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent that one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. , ~ , --"."".': .- 'i18'IklH1iJ,j:;j , 18. CHILD SUPPORT. Husband agrees to pay Wife Child Support as Ordered through the Cumberland County Domestic Relations Section. The obligation of support may be modified on the basis of material change in the circumstances of the parties or the children, and shall not contractually obligate the Husband to pay Wife a monthly sum without regard to the circumstances of the parties or the children. WIFE shall provide Primesource medical insurance, or its equivalent and dental coverage or its equivalent for the benefit of the children as provided by Court Order through Cumberland County Domestic Relations. The parties shall divide the cost of any unreimbursed medical expenses which are not covered by the medical coverage programs referred to above as directed by the Domestic Relations Order. 19. 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 default hereunder shall be deemed a waiver of any subsequent default of the same or similar nlilture. 20. 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. 21. 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. 22. 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 wlilrranties other than those expressly set forth herein. 23. 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. 24. 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 default 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. 25. SEVERABILITY. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise; the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 26. BREACH. If either party breaches any provisions of this agreement, the other party shall helVe the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 27. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges and declares that he or she is fully informed as to the facts relating to the subject matter of this ~'".' ,Ie - . ,- ...,.;'~ ~"uOil\\~l " agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: Date: ~d~' MARCELLA B. Mc HLlN COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the~day oVf)Ih~ / ,2001, before me, the undersigned officer, personally appeared /,J?:v-rp1ft.j3./JJoi""'rAj'JJknown to me, (or satisfactorily proven) to be the person whose name IS subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Date: Notary Public y cOT^,'ll~~*~PiJlltlo S' &C~}l3I;-ro, (~~jo.iit MY~ . t:v~f);J2~ RICHARD D. McLAUGHLIN COMMONWEALTH OF PENNSYLVANIA ) ):ss ) T.V' l... '~~i.ll<;t, ~ IN WITNESS WHEREOF, I hereunto set my hand and official seal. My commission expires: ,'-[=-"""" "I::AI rf"'".i",;\r.""I~ ~eAL ',: ,Jf'~N~ t::':'r:f~~:i~;~jf;}! r~i1Jtmy ?ubiic , ", - "- '" ~'" " ~- '. 'i CSr~1-i11;; ~.';:!^); ~,-; 'J;1';~~ft~nrl C1/t~' , .. C" ,.~ ;,...,,,," '~~:"'-""'- ~"",;f'h 12 ('fiY Omih~......i ~"F;"""'" ~~l. \'/, "~;'i:;,l i~- ~ ~~,.";j".'.' '"' _~o " '-'. ----'. - """'. ~"*= --""'.... .-~" .', I'; ,.' ~" o c: ~ -0-""1 ~~Ij ZL- UJ -~-^ -<:--=--- r:::: C_~' *C: .--~ <. ~ )>c:' 7' :::; -< lWf ,_ ~ c.;;c__ ~ iL ~ o o ---Q -... --r: ~", ~ ~. :-'~:<:lI ~:I :.:,.) co I, n~' ! '-j\:J I ~> ,-__, ,-- 't, ,- -,- (,":1-",-' '-,-0 ::',:,.;rn ~J ->~ c') :<: . 'IJD"ll:!1"; , . MARCELLA B. McLAUGHLIN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 6902 Civil Term 2000 RICHARD D. McLAUGHLIN, : ACTION 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 divorce: irretrievable breakdown under 93301 (c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receiot requested. delivered on: October 12. 2000. 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff: By Defendant: March 30, 2001 March 27, 2001 4. Related claims pending: None: no claims raised. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: March 28, 2001. Date Plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: March 30, 2001. Date: 4 ~~.. 0 \ Ja e Adams, Esquire I. . No. 79465 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff f"s:<.~,d" ,,,,~ ""'''i1t 'i" ~>tlOL~.\li~"~#.1~~~~\j;l<-""- .-:;...;-. " ," """'" - ~., ~-""~, J"l . C) ,::J U IE "'" I~; , rTj~~,~ -n Z~J; :;'::1 2C ; (n ...::' r,) -<:::.::.~ ~C-;- t:i j>r.. Z(j )>-c: G) '...",. :j;l .~ c:- ::;;! fv S:] -< . - -I ~''''''''='Il{(%:.' MARCELLA B. McLAUGHLIN, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ No. OO-b9c;~ G~.n'C 't-~ : ACTION IN DNORCE RICHARD D. McLAUGHLIN, 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, DNISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DNORCE 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 ~l -.io.. ,<, ,.~ti " ,. ,. ... , MARCELLA B. McLAUGHLIN, Plaintiff vs. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~ No. 1Jf?, (, '10.2- ~ "[W.- RICHARD D. McLAUGHLIN, Defendant : ACTION IN DNORCE COMPLAINT IN DIVORCE 1. Plaintiff is Marcella B. McLaugWin, an adult individual, who has resided at 308 Pine Road, Mount Holly Springs, Cumberland County, Pennsylvania, since 1997. 2. Defendant is Richard D. McLaugWin, an adult individual, who has resided at 228 N. Baltimore Ave., Apt 3, Mount Holly Springs, Cumberland County, Pennsylvania, since June 1, 2000. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months inunediately previous to the filing ofthis Complaint. 4. The Plaintiff and the Defendant were married on March 9, 1986 in Palm Beach, Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff 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. 7. Plaintiff and Defendant have three children together, namely Krysde McLaughlin, dob 3/23/87, Sarah McLaughlin, dob 11/6/90, and Tammi McLaughlin, dob 4/27/93. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. ,---~ ~ 1-...- .I I, , , ," [j~) ~ "'" " 1 O. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint 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. $~~ J) ~,,~~- Marcella B. McLaughlin, Pia' ff Respectfully submitted, Date: 10. C;. 00 {UawA- ane Adams, Esquire LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~N"i."",""".","",,,, '~''!!l.~IMi~-"j~~ ~~~.tjU~1iif.Jlill~~Il!!iiIMl!ir"--- .I'IW,lt .... ~'~~ _."".:...1 ""iJ ~ (I::.> 0 ~ ~ It. 't () '0 ~ ~~&&.~ ~ r I -o~ F--J.. t -( ~;.. ~ -c ~o ,." ;' ':1 1 fi II k ~-.... 0 ':+::'i "--' C C.:J .',1 .~. = -06" CJ mr~: -; \": Z:::' , (;) ~5~- , '.0 -,~'~{~} r' / -- _.'-..- 22 ~> ,.-- :2 ",,-. -,- ' -,"-', Co -- .~ .' )> C ~5,n L::::: ~"1 j;! 'j p.., ::0 - , -< " ~I~~ '- ~. .~ ~--. -O'\iU/.----~; MARCELLA B. McLAUGHLIN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 6902 Civil Term 2000 RICHARD D. McLAUGHLIN, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaintin divorce under section 3301 (c) of the Divorce Code was filed on October 9.2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 3~ 3:/- 6/ /JJ$r//g' ~ Marcella B. McLaug in, Pia' WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 633011cl 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' 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. ~904 relating to unsworn falsification to authorities. Date: 3---J7~ 0 I /?b1'///6",$;I~4 Marcella B. McLaughlin, PI . I i~;t;l!liIillJ.l:.l ~IIU?~ ~'-""~>'~rW-~~riailtk!~~iR~"" '~a' ,~ ,- -, A~ ~". _ 1.-,",,,< , ~ --~ l....;;.~.. ., .~ k-~ " o c "'0$ r11fT- Z::J:, Zr' en;):." -<2 r-::'-j ~"-". Pro 2',.; );-".0 '~~ :< .-" ",,'w'-J<-... -'Ill I. o o -n ::J!:: :po :;;0 "" o =;:1 fll 21 c- ;88 '-J 1- ...:-:c) -,--7-, CJf3 bill i-:! l7 -< '" ::1.;: (::> ~ - ~." ,I " ,; - "' . ---c - . ~ ""'-"'l:; MARCELLA B. McLAUGHLIN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 6902 Civil Term 2000 RICHARD D. McLAUGHLIN, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on October 9, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry 01' the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 3/27!Od1 i3~~b 1) h J6~ Richard D. McLaughlin, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER li33011cl 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. ~4904 relating to unsworn falsification to authorities. Date: 3/:P 7/07 - jlliV~"'~ w~__~iiili<.:.f<l . --JjlMf -~~T~-'~'~ ,;:,;.,,~ -,~~ _-.'1"..;....,.. ~~ ~ . ' L. "-- (") C () c: 't' ~~ :?;: vr6 ~~ rl1f'::'- ).:n" ~ ? ", ::'.tj ,~--- ~::J:.1 <c I'V :-1 :-i') (I)~.1:.:: CV '''-, ~",' ~~_s;; '--{ , C} C'-. C -0 -T, ~l) ~.;.- :~~) ~"; ~-C., C) 5>C! SJ (-~;. Tn 2: "_.' ,:.) -[;~ -j =0 "". (".,) -< r ~ -, 1 " '" . ='-, 1 r MID'. MARCELLA B. McLAUGHLIN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 6902 Civil Term 2000 RICHARD D. McLAUGHLIN, Defendant : ACTION IN DNORCE AFFIDAVIT OF SERVICE OF THE NOTICE TO DEFEND AND COMPLAINT AND NOW, this October 16,2000, I, Jane Adams, Esquire, hereby certify that on October 12,2000, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE were served, via certified mail, restricted delivery, return receipt requested, addressed to: Richard McLaughlin 228 N. Baltimore Ave. Mt. Holly Springs, Pa. 17065 Respectfully Submitted: ane Adams, Esquire I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FORPLAINTITF "'$i "~'~'"'~'~l;l!i!_~~S1~;.~~~'<'~~~1;ti~~i/l~~,""~It4liij!;ji~.;"li,,jllIM@'j~~~Jf""" ,~,,~ ., ~~", ~, ", ""~... " I ~ 0 C' ~i c: 0 "'- 0 -v~~J n rn!ll "-< Z..u zc- ~~: c:r-, ~ C -u --::]';/ )> (; .~! ;::'-5 z 0 rn )> C ~ -~ -! :z ~.) )::;V ::<! ::0 \,0 -:.: ~ "" ,I; I ~~~.~, .~ Compiet'e iteh1S~ 1, 2, and 3. Also complete ' item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed ,to: D. Is delivery address different from item 1? If YES, enter delivery address below: fb,ohd fh<:, LavsJ-,I~1') d.d.B /'J, g~~~ /VIf. Hdfo5"prinrp ht '/7c1as- 3:. Service Type ~ D-Express-Mail .I~ ,0 Ret~rn'Receipt for Merchandise o Insurec(Mait_ D-C.D.D>" 2. -Article Nl,lm~er (qqpy frp-,n ~ryi~e lab_~Q; PS,Form 3811 ,July 1999 ~t61:E,! .?'4V\g8~ Domestic' Retum Receipt 102595.00.M.0952