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HomeMy WebLinkAbout00-07201 ." . . , . . , , . . . . . . . . . . . . . . . . . . . . . . :f.ili"'i1i:ti "'''' , ""HInt; "':Ii'" '" ;t; ,'J -_'2, , '" "':f. ;t;;t;;t; OF CUMBERLAND COUNTY PENNA. 00 7~Ol ~( , , . . . IN THE COURT OF COMMON PLEAS . . . . . . . . . . . "'''';I; "'Of. '" :f. "':Ii'" ;F.:fi '" STATE OF DEBORAH TY~~ TnCIO No. P1Pl;nr;ff VERSUS .JOHN Lnr.T() Defendant . DECREE IN DIVORCE AND NOW'.~ ( (ll DECREED THAT DEBORAH LYNN Tnr.TO . . . , AND JOHN UJCIO ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . j tI~/fofA IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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; ~g. ..- PROTHONOTARY . . (fML . . . . J. '" ;t; :F. ,'''Ii . . . "i...6":' ' . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ".'~7"" 'C, ,~".,."'" C'. ~-- ~- .. L/ . Po ( t/t2.~ ( ,-, <w ""~ ",', ~ ..~ ,~~-" -'~, ~,= ,~>~~ -" "~-, 'Jim ..- lJ!lii~. ," ~. ,,. ~ aiJr ~ ~ ~- 4' tJte ~ ~~ ~ Pf- "",..,_,.,_,_~,'I..,.._,,*, J'I!lf.,~"~,~~'~-'!<~-_~,: ," __WiIi!I'l11'lftj~~ """,," '. ~_i _. ~O",' DEBORAH LYNN LUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO, 00-7201 : IN DIVORCE CIVIL TERM 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: irretrievably broken under Section 3301(c)ofthe Divorce Code. 2 Date and manner of service of the complaint: Served upon the Defendant, John Lucio, on October 20,2000, at the Law Offices of Paul Bradford Orr, 50 East High Street, Carlisle, Pennsylvania 17013, by Christina M. Holter. 3. (a) Date of execution of the affidavit of consent required by Section 330 I( c) of the Divorce Code: by the Plaintiff March 15,2001; by Defendant March 15,2001. 4. Related claims pending: None. 5. (b) Date Plaintiffs Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: March 22, 2001. Date Defendant's Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: March 22, 2001. THE LAW OFFICES OF PAUL BRADFORD ORR Date: 3/J..-3, 2001 Grego tIer, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court 10# 73471 By: .1i'~~~Dmi'M~jj(~I&~d~lIl~'~-'-~''"' . jj~~ ,~,.U..~.~,",~~II.! , . [~+~.,.= ." .~>'<~".<""~. .'"~"__'>'R,~'''''<'~ r",,"_ ;h_,;r~,Y~c~:!-",'-",'''''''F,,~''_'''<_. , _ " .", ~~ -~;~-..lli~""L ,~ ,. o ~ vc'f rnn-; z::c ~31~: ~c" d;: C") "=0 J>c: :z: -'j -- '_'"~'"'" _q. ~,~~ "~~r~' _~__~ .-. '> o :l': "",:-,::0 ;;" N -> o "'1"1 .-\ .~---;\;~ i:\~~, ._;.,..-r-\ '~~h~ o -'-{ 55 -< -c ....;;:.. ~ .~ "^", I_l_~ ~-I .... ~~_:., DEBORAH LYNN LUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO. 00- 7201 : IN DIVORCE CIVIL TERM PROPERTY SETTLEMENT AGREEMENT TillS AGREEMENT, as follows, made this 27 TH day of March, 2001, by and between Deborah Lynn Lucio, hereinafter referred to as "WIFE," and John Lucio, hereinafter referred to as "HUSBAND." Respectfully Submitted: THE LAW OFFICES OF PAUL BRADFORD ORR 1l~~j;;JL- 50 East High Street Carlisle, P A 17013 (717) 258-8558 Supreme Court ID No. 73471 0 0 ~-~) C i"I :;;: _-'C.... -J cn ~?--: 111fTl 0 ;-~ ~)J ......J . , Z r~ N , ;-,-: (J) c!:: -' .. , I', -< ~L i~~ ~C~I :2 d:::;C) ~ - () ~o Pc -- c- ~-1 .. -, z """ ~--::: ---J r" :0 -< -< '10 . . ; ,;;i~~";, , ,~ PROPERTY SETTLEMENT AGREEMENT THISAGREEMENT,madethis 3tJi:N day of ~ , 2000, by and between Deborah Lynn Lucio, residing at 432 Arch Street, Carlisle, Pennsylvania 17013, hereinafter referred to as "WIFE," and John Lucio, residing at 558 South Hanover Street, 2nd Floor, Carlisle, Pennsylvania 17013, hereinafter referred to as "HUSBAND." WITNESSETH: WHEREAS, the parties were lawfully married on July 5, 1990; and WHEREAS, in consequence of disputes and unhappy difficulties, the parties have agreed to live separate and apart during their natural lives; and WHEREAS, the parties are desirous of settling their existing property rights including an amicable equitable distribution, assignment and division of their property, which property is considered to be "marital property" as defined in the Divorce Code known as Act 26 of 1980, and amendments thereto enacted into law on February 12, 1988; and WHEREAS, the parties are desirous of settling the issues of spousal support, alimony, alimony pendente lite; and NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained and for other good and valuable consideration, the parties, intending to be legally bound, agree as follows: , . ~-". .- . I 1. Separation. The parties shall hereinafter live separate and apart. Each shall be free from interference, authority, and control, direct and indirect, by the other as ifhe or she were single and unmarried. 2. Control of Avreement. The provisions ofthis Property Settlement Agreement shall govern all past, present, and/or future claims for alimony, support, counsel fees and costs, alimony pendente lite, equitable distribution, or other property rights, and all other claims which the WIFE or HUSBAND has or might have against the other except as set forth hereinafter. 3. Divorce. A Complaint in Divorce was filed in Cmnberland County by Wife on or about October 18, 2000, which Complaint is docketed to No. 00-7201 Civil Term. Simultaneously with the execution of this Property Settlement Agreement, the parties agree to sign any and all docmnents necessary to obtain a Divorce Decree under Section 3301 (c) ofthe Divorce Code, including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of Notice ofIntent to Seek Divorce under Section 3301 (c) of the Divorce Code. The parties intend that this agreement shall be incorporated into any forthcoming Decree in Divorce. 4. Emvlovee. Pension and Retirement. Each party shall retain any individual retirement account, and/or retirement benefit plan (including but not limited to pension or profit sharing plans, deferred compensation plans, defined benefit plans, 401 (k) plans, severance packages, employee savings and thrift plans, IRA's, or other similar benefits), whether vested or non-vested. The above shall specifically include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. The parties represent that they are aware of the values in each others retirement accounts and/or specifically waive the right to ~ .:IIIi$~~".' f .. ,_ _ L -"~ ~_<:lti';, request any further documentation thereon. Furthermore, each party shall be and remain sole owner of any other asset in his or her control not specifically covered by other provisions ofthis Agreement. Should it become necessary, each party agrees to sign any other title or documents necessary to give effect to this section upon request of the other party. 5. Personal Prooertv. The following personal property acquired during the marriage will be the property of the Husband in accordance with the provisions provided herein: A. Hutch Wife will obtain possession until Husband provides thirty (30) days notice that he will pick up the property. In the alternative, Wife will provide thirty (30) days notice that the Husband must pick up the property; B. Pfaltzgraff dishes C. Flatware (stainless) D. European glassware E. Table with four chairs Wife will obtain possession until Husband provides thirty (30) days notice that he will pick up the property. In the alternative, Wife will provide thirty (30) days notice that the Husband must pick up the property; F. Bose radio; G. Lamp; H. Valet; I. Walnut Bookshelf; J. Patagonia pack; K. Day pack; L. Blue backpack; _I _ ~ i ~I 1 , ,~= , ~"";' M. Green pack; N. Ping Golf Clubs; O. Tennis equipment; P. Softball equipment; Q. Sony Color Television All other tangible personal property will be the property of the Wife. It is agreed that each party shall retain all items of tangible personal property currently in their possession as if it were their sole and separate property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party which are now in the possession or under control of the other. Furthermore, each party agrees to waive any right, title or interest they may have to the property in the possession of the other. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph. 6. Automobiles. There are no jointly titled automobiles in existence. The parties shall each retain their respective vehicles as their sole and separate property, subject to any liens and encumbrances on their respective vehicles. Each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and promptly sign any and all documents necessary to effectuate the above referenced transfer. 7. Bank Accounts. Any and all bank accounts in the parties' names which existed at separation have been previously divided to both parties' mutual satisfaction. Furthermore, each party agrees to waive any right, title or interest he or she may have in the bank account of the other. 8. Credit Card Debt. The parties acknowledge and represent that there is no joint ~~ ~ ~ ~;'-~.0.0~ credit card debt in existence. 9. Miscellaneous Debt. Any debt not specifically listed in this Agreement and/or incurred after the date of October 18, 2000 shall be the sole and separate responsibility ofthe party who incurred it. 10. Af!reement Executed Voluntarilv and Clearlv Understood. Each party to this Agreement acknowledges and declares that he or she respectively: A. Is fully and completely informed as to the facts relating to the subject matter of this Agreement, and as to the rights and liabilities of both parties; B. Enters into this Agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind; C. Has given careful and mature thoughts to the making of this Agreement; D. Has carefully read each provision of this Agreement; E. Acknowledges that there has been a full and fair financial disclosure by both parties, and fully and completely understands each provision of this Agreement. II. Release of all Claims. Each party releases the other from all claims, liabilities, debts, obligations, actions, and causes of action of every kind that have been incurred. Moreover, neither party is relieved or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. 12. Holdinf! Other Parro Free and Harmless. HUSBAND hereby warrants to WIFE that he has not incurred and he hereby agrees that he will not hereinafter incur any liability or obligation on which she is or may be liable. If any claim or action is brought attempting to hold WIFE liable for any such liability or obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or not founded, and he shall hold her free and >-~ '_ .l A ~~ l , """'"~_k"C, harmless therefrom. WIFE hereby warrants to HUSBAND that she has not incurred and she hereby agrees that she will not hereafter incur any liability or obligation on which he is or may be liable. If any claim or action is brought attempting to hold HUSBAND liable for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether or not founded, and she shall hold him free and harmless therefrom. 13. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any document, and do or cause to be done, any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 14. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each has been fully and completely informed of, and is familiar with and cognizant of the wealth, income, real and/or personal property, whether jointly or individually titled, estate and assets of the other, and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities, and any further enumeration or statement thereof in this Agreement is hereby specifically waived. The parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and agrees for himself or herself that his or her heirs, personal representatives or assigns, that he or she will never at any time hereafter sue the other or his or her heirs, personal representatives or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full and proper disclosure. Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto. 15. Waiver of Rights to Other Estate. Except as provided for herein, HUSBAND and ~ ~~ ~. - L, , " ',~: , WIFE each waive any and all right: A. To inherit any part of the estate of the other at his or her death, except as provided herein; B. To receive property from the estate of the other on intestacy unless nominated by another party legally entitled to so act; C. To act as personal representative 'of the estate of the other on intestacy unless nominated by another party legally entitled to so act; D. To act as the personal representative under the Will of the other unless so nominated by a Will or Codicil dated subsequently to the effective date of this Agreement; E. To claim a family allowance in the estate of the other. 16. Containment of Entire Al!reement Herein. This Agreement supercedes any and all other Agreements, either oral or in writing, between the parties relating to the rights and liabilities arising out of their marriage. This Agreement contains the entire agreement ofthe parties. 17. Partial Invaliditv. If any portion of this Agreement is held by a Court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue in full force and effect without being impaired or invalidated in any way. 18. Modification. This Agreement shall not be subject to modification except as in accordance with Pennsylvania law and with a writing between both parties evidencing their intent to modifY the Agreement. 19. 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 -- - - ~" ~ _c either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 20. Attornev's Fees and Exoenses. Each party shall be responsible for their own attorney's fees and expenses, except as specifically provided herein. 21. Mutual Cooperation. Each of the parties shall, on demand, execute and deliver to the other any deeds, bills of sale, quit claims, assignments, consents, tax returns, and other documents, and do. or cause to be done any other acts or things as may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, cost, and other expenses reasonably incurred as a result of such failure. 22. Bankruotcv. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay under the provisions ofthis Agreement, each has the ability to fulfill his or her respective obligations from income or property not reasonably necessary to be expended for such party's maintenance and support or for the maintenance and support of such party's dependants. Should either party file a Petition under Title XI of the United States Code, or should a petition be filed against either involuntarily, each party acknowledges and agrees that the discharge ofthe debtor party's obligations under this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to the non-debtor party or the non-debtor party's child or children. 23. Law of Pennsvlvania Aoolicable. This Agreement shall be constructed in accordance with the laws of the Commonwealth of Pennsylvania. 24. Date of Aflreement. The effective date of this Agreement shall be the date on which the last party executes the Agreement if the parties do not execute the agreement on the .. '~"'\"I . I. ~ I" ~, """,,~i;k. same date. Otherwise, the effective date will be the date that both parties execute the Agreement. 25. Educational Expenses for Child. The actual educational expenses for their child, Whitley Lucio, will be shared equally. This provision will apply to any post-secondary school or training, and will be calculated by deducting any grants, scholarship, etc., from the total cost of the school or training. 26. Successors and AssifJns. This Agreement, except as otherwise expressly provided herein, shall be binding on and shall accrue to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors and interest of the parties. IN WITNESS WHEREOF, the parties hereby have hereunto set their hands and seals the date and year first above written. J:;r.d ~/d I.t ho{oo Date O~A~ J ~A'~ Deborah Lynn Lucio II /'10 j. 0 ~ Date John Lucio "~ "" ~.., = ~ ~ ~- , "~~ I o_~~~ .j '-, -..=0' '''_'~~'''_ COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the ~ fh.. day of '-n~ , 2000, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared Deborah Lynn Lucio and in due form of law acknowledged the above Agreement to be her act and deed and desired the same to be recorded as such. COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the ~f;I..., day of ~ Notarial Seal Heather L. Smith. Notary Public Carlisie Born, Cumbertand County My Commission Expires Apr. 7, 2003 Member, Pennsylvama ASSOCiation at Notaries ~~ , 2000, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared John Lucio and in due form oflaw acknowledged the above Agreement to be his act and deed and desired the same to be recorded as such. [--.-..... Notariai Seal Heather L. Smith, Notary Public Carlisle Born, Cumberland County My Commission Expires Apr. 7, 2003 Mem~ber, Pennsylvania A aci ion at Notaries ~ . ,""~...., .~ "'~ ~ .~ i-.l ,- (' liiti~)N!" , , . . . DEBORAH LYNN LUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO. 00- '7J-D/ CIVIL TERM : IN DIVORCE NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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, P A 17013 Phone: (717) 249-3166 ., __ , .1_ - ~"'.~ -~lm:iIilA' -" . DEBORAH LYNN LUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO. 00-7.;1.01 CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaintiff is Deborah Lynn Lucio, who currently resides at 432 Arch Street, Carlisle, Cumberland County, Pennsylvania.. 2. Defendant is John Lucio, who currently resides at 558 South Hanover Street, 2nd Floor Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 5, 1990, in Conway, Horry County, South Carolina. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. . . ~ " , , . 8. Plaintiff requests the Court to enter a Decree in Divorce. Date: /O/J<tJOl> By .~if!!:: Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 ID# 73471 "~;, . ,. "~"', 'L..>",lIiiiI~~"",,J;:_ . VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. DATE: /0)}8"/01:) ID~~ Deborah 1. Lucio, Plaintiff "-~H ".~ tii_=~-,,~... f~ , ,,'-> '" 00' "-'''G '" "- v\ ~- ~'"'"' ~ .w 1~ oil> ',- l~]lIim' ,_ _,~,"~.~"""" _ "r_.,.,.^"",_"~"_",~_,"",_,"___.. ,.._'."""""0 ''''''''__''",~'N ,-',."' ,-~ "-, , ., <. - ~ ~ j ... ~ ... "0 - c- .j V- Y\ ."\ G & (1 ~ r , " , L:'~ ,,' () cO:: ;-;7;;- f91 j,~~~~' ~E ~(; c Z --j -- -"""" ~"--"~"i . ~ ;""J :.-') -".; C::;, -u ~.t"' c; --':.,=-f-i ~ -,' ..- ~~rfr -,~ 5J -< lS:; c...) .t::- <","'~--~- ~ '" - ~~.~, ~ ~"--. '~l>:I!1l:.I',6, . DEBORAH LYNN LUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO. 00-7201 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this dO rJ. day of OJ~ , 2000, I Gregory L. Cutler, Esquire, attorney for Deborah Lynn Lucio, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint for Divorce and Order of Court, executed by the Plaintiff in the above- captioned matter, upon the Defendant, John Lucio, at my law office, by my Secretary, Christina M. Holter, at 50 East High Street, Carlisle, Pennsylvania by hand delivery on Wednesday, October 18, 2000. LAW OFFICES OF PAUL BRADFORD ORR ,ClL By: Greg ~ . Cutler, Esquire Attorney for Plaintiff Supreme Court ID# 73471 50 East High Street Carlisle, P A 17013 (717) 258-8558 ..~ ~ _, l - " '~~~- '<t~'l-:::i .. ", "'- DEBORAH LYNN LUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO. 00- 7201 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 20, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: ~/J)' lo( /~A J~ Deborah Lynn Lucio, Plaintiff 0 0 (') C -n ~:: ::r,: -01-'" :;;:._# 1'1 fTlf'll Z:JJ ;,;:.:; P zr".'" N ---,r----r: ~ '...: ,--'1 eny- --J - -~ --<2': ::@~~ Gel -0 5-~G ::;; ~~ 7 . ~o - >c .. -,".1 7"': ~ > :::! ~ :::0 --< - '.lflI!lIlIIiI J"~,;,, - ... - , , ... DEBORAH LYNN LUCIO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO Defendant : NO. 00-7201 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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 subjectto the penalties of18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: '711/\101 ()=~~,J<< () 0 (") C .TJ s: ::1!: -ow }::,"" ;:~: rnm ,'" z::r:.' N "T.lm :z:c _J : ~~J .....' ~z ~~;~ ~:? r:" r-' <'--' -0 -,-' " ~c :If; gs -",.0 - Pc .' -.--1 Z ,~ :<i ,;:- 53 Cl -< ~,.~'" --" . _......~"' L .. ~~-,-.L""1~"2'''_ . . .......... , . .~ - DEBORAH LYNN LUCIO, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW JOHN LUCIO, Defendant : NO. 00-7201 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301( c) of the Divorce Code was filed on October 20, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: MCt-R.c.h I ~ I 'J-oO I ~ "'_... . li~];!\illl\lli!i~J'i1k" " ... (" . . ... .'. ... DEBORAH LYNN LUCIO Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW JOHN LUCIO Defendant : NO. 00-7201 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ofthe 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 of18 Pa. C.S. S4904, relating to unsworn falsification to authorities. Date: 1'IIC\~e-h I ~ I '1-06 I 0 0 c. .j C ~Tl ~~ :~ .-' -oce ~':':,,"" " n1r-r. ~o ,-' Z::L 1''' -.-" ;-p ZC ~~~: -' l~ ~C~ .~ ;~:1 '-.' -..,-! P- C::' .- c,-! f~~ '7' - """0 - C~, >c .. sB z ~ :;:I <~ CJ -< ~ ~~ , ......, 'J"'--'~ "_~'~_"""" j '"~_''' " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW H 0-1' \{)e;+<~ L'Y Ir\ '^ (-ur "0 : , . Pl.aintiff : : : vs. : : l"o~\/\ 1_'vIcJO : : Defendant : File No. 00 ~ "I ~() \ ". IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter. having been granted a Final. Decree in Divorce on the I 0 day of t\pn'/,:]8::;J.CJof. hereby elects to resume the prior surname of \~U \ott , and gives \ this written notice pursuant to the provisions of 54 P.S. S 704. DATE: AuF I to I r2fXt:J / O~fJ~igi~ COMMONWEALTH OF PENNSYLVANIA: : 55. COUNTY OF CUMBERLAND On the 1t0 day of (}\?~l)f)-\- . ~ZDO\, before me, a Notary Publ.ic. personal.l.y appeared he above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal.. NOTARIAl SEAL EtlEIl L.ILE. NOTARY PUBLIC CARLISI! IlOROCUMBERLAND co. 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