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Home My WebLink About00-07359 , , , , , , , , , , , , , , , , , , , . . , , , , , , , , , , , , , , , , , , . , , . . , , , , , . , , , , . . , . ..0 J, ~ , "'1 ! f ~ ~~~~ ~~ ~~ ~ , , . . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PAUL E. WEIBLEY Plaintiff VERSUS BARBARA J. WEIBLEY Defendant ANDNOW'~ _ DECREED THAT ~. PENNA. No. 2000-7359 Civil Term IN DIVORCE DECREE IN DIVORCE L ,k3~O)P~, 21)01- , IT IS ORDERED AND WEIBLEY , PLAINTIFF, AND BARBARA J. WEIBLEY , DEFENDANT, ARE DIVORCED PROM THE BONDS OF MATRIMONY. 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; NONE. The terms of the Marital Settlement Agreement dated December 1, 2000 are incorporated but not merged into this Decree in Divorce. , , , . J. , '" ,''''':F. '" Of. , , , . . \- ,',,- '" . , , , , , , , , , . , , , , , , . , . , . , , , , , , , , , , , , , , , , , , , , , , , , , , , , , . . , , , , , , , , , , , , , , . . , , , . , , , , "~ -'''~,,"-~,-" ,.;- ('~'""' ',--, ,-'",,". '" '"-'-<,;...-~ '.n-"~ .'~ .,-~," ,. J, f' ,-, ~~..:.;':"~ IiJ -~ ~""'"' , .~% ~ ~I<( ~Y$ ~~~v,;pp .~ -' " . --<, ., ","" ", '" ,,,, ,. .--~ '-' ^" ~"",,,' " ,U~ ~~ --~ ", -~. ,,~ , , '~. .- /r7. E. r ~ Ie?' E"/ . L ~ ''-' , , " ~. .." "I SAIDIS 1R.J!'f:.~~ &J..Il'l~ ~I"._,..-...AW 26W.BIgh_ . ,<:'adIsI., PA '-1li!II<-:;:~I'_C- , PAUL E. WEIBLEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA CIVIL ACTION. LAW NO. 2000. 7359 CIVIL TERM Plaintiff vs. BARBARA J. WEIBLEY, Defendant IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS Agreement made this IS-'c: day of ~ ~efY\b4 2000, by and between BARBARA J. WEIBLEY, of 1552 Holly Pike, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as WIFE, and PAUL E. WEIBLEY, of 1552 Holly Pike, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as HUSBAND, WITNESSETH: WHEREAS, the parties hereto are HUSBAND and WIFE, having been joined in marriage on September 20, 1980, in Carlisle, Pennsylvania; and WHEREAS, a Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 2000-7359 Civil Term on October 19,2000; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony ~ ..,. ~ .. ~l' SAIDIS HUf!"t~ &.J..ll'IuSAY "lJOIINIMIoU\lAW 26W.BIgltStreet '6rlIde, PA . "......""......-. ~M~~t1^Wf~~~J.'''''''']' weibley' msa ljb November 21. 2000 , " pendente lite, counsel fees and costs, and in general, the settling of any and all claims and possible claims against the other or against their respective estates. NOW, THEREFORE, in consideration of these considerations, and the mutual promises and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. Advice of Counsel: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. HUSBAND is represented by Carol J. Lindsay, Esquire, and WIFE has been advised that she may be represented by counsel of her choice. Each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge as each has sought from counsel, and that execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. 2. Divorce: The parties agree to the entry of a Decree in Divorce. Ninety (90) days after the date of service of the Complaint, the parties will sign Affidavits of Consent and Waivers of Notice under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce. 2 ~ ...... .,. .< SAIDIS S~~ .o'IUllNlMWMAW 26 w.BlgJaStroet , ~ 0uif0I0, PA IlIl ~ ~' '''~'~ ~".""' ~",~~~.'C weibley ijb November 21. 2000 msa 3, Personal Property: A. Vehicles: HUSBAND will retain the 1995 Dodge Truck and WIFE will retain the 1994 Ford Explorer. Both of these vehicles are jointly titled and lien free. Within ten (10) days of the date of this Agreement, the parties will appear at a mutually agreed upon date and time at Sollenberger's Messenger Service and they will transfer the titles to the named vehicles to the party who is retaining the vehicles. The parties waive any claim they may have in the vehicle retained by other and will pay all of the costs associated with the vehicle he or she retains. HUSBAND will retain as his own separate non-marital property the four-wheeler and the tractors given to him by his mother p~ior to her death, and WIFE waives any right, title and interest she might assert in those vehicles. B. Household Goods and Business Inventory: WIFE is the owner of an antique sales business. The inventory for her business is stored in three show places which she maintains, one of which is in a bam on the marital premises. Further, the parties have household goods and furnishings, and certain antiques acquired during the marriage. WIFE will retain all of her business inventory, her business itself including fictitious names, business telephone numbers and business equipment. Further, WIFE may retain any personalty in the marital home, with the exception of HUSBANO's personal items, his guns, a mOwer, tools and any of the contents of the children's bedrooms. HUSBAND waives any right, title and interest he may have to the 3 ". :=-- .), :z6"IV-lIJgb_ .c,~PA ,~a ' __:r-"~'~ ~i:lJ'-'l!<;;;'"NiP' weibley' msa ljb November 21. 2000 personalty which WIFE is retaining. WIFE is free to keep or dispose of any of the personalty set out in this paragraph free of any claim by HUSBAND. B. Intangible Personal Property: WIFE has an individual retirement account at Legg Mason in the approximate value of $20,000.00 which shall be her own separate property. The Legg Mason account titled to HUSBAND and the parties' son, Austin P. Weibley, shall be and remain Austin's own personal property. In order to effect equitable distribution, it is the parties' intention that HUSBAND will pay WIFE $150,000.00. This payment will be made as follows: 1. Transfer to WIFE of all HUSBAND's right, title and interest in Legg Mason Preferred Account No. 334-0593 in the approximate amount of $90,000.00, which account contains a portion of HUSBAND's inheritance. 2. Transfer to WIFE of all HUSBAND's right, title and interest in Legg Mason Account No. in the approximate amount of $30,000.00, which account contains monies obtained through HUSBAND's inheritance. 3. Transfer to WIFE of the Van Camp Mutual Fund in the approximate amount of $17,000.00, which account was funded by HUSBAND's inheritance. 4. To the extent that the transfers set out in Sub-paragraphs 1-3 above provide WIFE with less than $150,000.00, HUSBAND 4 1- ~> y SAJDIS SIi.\Jffi.~ &..LJl~1JSAY ~I'''''''''.-'''- 26W. BIgb Street >~PA weibley' msa ljb November 21, 2000 will pay to WIFE the difference beween the balances transferred and $150,000.00. The transfers contemplated in Paragraphs 1-4 above shall occur within ten days of the date of this Agreement, provided, however, that by the date of the first transfer, WIFE shall have provided to HUSBAND a special warranty deed transferring to him all her right, title and interest in the marital home as more specifically set out below. Further, the transfers of the Legg Mason and Van Camp accounts shall be accomplished without tax consequence to HUSBAND and, to the extent possible, to WIFE. It is anticipated that there may be capital gains on the Legg Mason or Van Camp accounts in the event that WIFE liquidates those accounts. The capital gains shall be the obligation of WIFE to report on her income tax return in the appropriate year. C. Pension and Retirement Plans: HUSBAND will retain his PPG Pension Plan and PPG Retirement Savings Plan. HUSBAND will retain the EE Savings Bonds and a life insurance policy with Metropolitan Life. The parties will each retain his or her own checking or savings account and will close their joint accounts as soon as any checks outstanding thereon have cleared. 4. Real Property: The parties are owners of a home at 1552 Holly Pike, Carlisle, Cumberland County, Pennsylvania. The property consists of the marital home and wo outbuildings, one of which is used by WIFE to maintain her antique business and one of which is leased to a tenant. Within ten (10) days of the date of this Agreement, WIFE will transfer to HUSBAND all her right, title and interest in the marital 5 Ii Ii --_..,_.'~'......,:.'.",.- ' ". , '~" SAIDIS SHUFl\ FlOWER &.iliiDSAY MIUIINJmioM"oIAW UW~BIiIh_ CariIsle, PA . ~ - ~h~_ ,='" "b;,.~~;'; weibley . ljb November 21, 2000 msa home. HUSBAND will be solely responsible for the payment of the debt thereon to Members 1st Federal Credit Union and shall indemnify and hold WIFE harmless on account of such debt. HUSBAND, upon transfer, will be solely and exclusively responsible for the payment of all charges on account of the house, including utilities and taxes. WIFE may remain a resident at the marital home for ninety (90) days from the date of the transfer at no cost to her. Further, at the same day as the date of the transfer of the deed to the marital home, HUSBAND will pay to WIFE those amounts set out in Paragraph 3 above, and WIFE will execute a Lease, according to the terms of i which she shall pay to HUSBAND $1,000.00 per month for a period of one year for the lease of the stone bam on the marital premises. Said Lease will have a term of one I i I I II .' II )1 I I year and may be renewed upon the Agreement of the parties. NOTWITHSTANDING the ability of the WIFE to remain resident in the marital home for ninety (90} days from the date of this Agreement and her Lease of the stone barn, HUSBAND shall have exclusive possession of the marital home, and, after the ninety (90) days aforesaid, WIFE will confine her presence at the marital property to the stone barn and the entrance and exit therefrom. WIFE specifically waives any interest she may have on any lease proceeds for the stone barn or the other rental building at the marital residence. HUSBAND inherited a farm with his brother. WIFE waives any and all interest she may have in the farm and will execute, upon the request of HUSBAND any documents required to document the waiver. II Ii 6 Ii -_..~-- ",. ~ .. ~, SAIDIS SH\Jffi.~WER &LIl"luSAY ............,_r....... U"W. BlghSCreet '~..PA ~ IiiIi: < ~ "~, " ",~I, ~ ~ ~~"I~,~l.itt--3!(,,.,..,h,' weibley ljb November 21, 2000 msa 5. Alimony: The parties waive any claim that they may have one against the other for alimony, alimony pendente lite or spousal support. The parties acknowledge that each has sufficient assets with which to maintain themselves after divorce. 6. Marital Debt: In the course of their marriage, certain credit card debt has been incurred by WIFE, including a Master Card obligation in the amount of approximately $7,500.00. With the exception of the first mortgage, the second mortgage and the line of credit, payable to Members 1st, which will be HUSBAND's individual obligation, WIFE will assume all debt as her exclusive obligation as of the date of this agreement. Each party will incur no debt for which the other may be liable, and will indemnify and hold the other harmless for any debt so incurred. 7. Custody: The parties are parents of two children: Justin Weibley, born December 23, 1996; and Austin P. Weibley, born August 28, 1986. The parties shall share legal and physical custody of said children. HUSBAND shall have physical custody of said children each week from Tuesday after school or at 4:00 p.m. until Saturday morning at 9:00. WIFE shall have physical custody of the children from Saturday mornings at 9:00 a.m. until Tuesday after school or at 4:00 p.m. The parties agree to a modification of this basic schedule for holidays, vacations and special occasions so long as the agreement is mutual. The parties will do nothing which injures the love and respect the children have for each of the parents. 7 Ii Ii ... .... SAIDIS SHUffi.fIPWER &'.I.J.L"luSAY !Uu............oou.w uw.BJghStreet ~.~PA "~M-'~:m<'i',;ji[,',:,} weibley tjb November 21 , 2000 msa Each parent will bear the costs of the children's expenses while the children are in their custody. Such expenses include food, housing and transportation. HUSBAND will pay 60% of Justin's pre-school at St. Patrick's, and WIFE will pay 40% of that cost. The parties will also split any daycare which is necessary for the employment of one or the other of them during that parent's custodial time with HUSBAND paying GO% of that cost and WIFE paying 40% of that cost. HUSBAND shall maintain health insurance for the children. The parties will share common expenses for the children such as clothing and activity fees and the like. 8. Exchange of Informati()n: The parties have requested from each other and received any information regarding their assets, liabilities, income and expenses which the party requires prior to entering into the terms of this Agreement. The parties aCknowledge that the terms of this Agreement are fair and equitable and constitute an II equitable distribution of marital property and debt, taking into account all of the relevant factors set out in Section 3502 of the Divorce Code, 23 Pa. C.S.93502 including the length of the marriage; any prior marriage of the parties; the age, health, station, amounts and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution by each party to the education, training or increased earning power of the other; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to, medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or 8 Ii Ii ., SAJDIS SI-llJffi.~WER &LIl'luSAY ............"'-'T.lAW 26W.BlgbSlreet " , tarIrs1.. PA 'l!!~ weibley' msa ljb November 21, 2000 '. appreciate of the marital property, including the contribution of a party as homemaker; the value of the property set apart to each party; the standard of living of the parties during the marriage; the economic circumstances of each party including federal, state and local tax ramifications at the time of the division of the property, and whether the party will be serving as custodian of any dependent minorchildren. 9. Modification: No modification, rescission, or amendment of. this agreement shall be effective unless in writing signed by each of the parties hereto. 10. Applicable Law: All acts contemplated by this agreement shall be construed and enforced under the laws of the Commonwealth of Pennsylvania. 11. Agreement Binding on Parties and Heirs: This agreement, except as otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs, executors, administrators, legal representatives, assigns and successors in any interest of the parties. 12. Agreement Not to be Merged: This agreement shall be incorporated into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. 13. Documents: The parties hereto agree that they will execute and deliver one to the other any documents necessary to give effect to the terms of this Agreement. 9 ~ " -:", ~I SAIDIS HlJffi.~ &LIJ."IuSAY ,,,"........,,.,(f.IAW uW.BIP_ : CirlJsIe, PA '~"illiI@lh7 ....-.-'- w~ibley' msa ljb November 21. 2000 14. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles, 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,. of 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, or widows' or widowers' 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 all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of I Pennsylvania, any other State, or any other Country, or any rights which either spouse 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 the 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 term thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal .10 II )1 ........".._."-"-, 'I '. SAlOIS SIIU!!!!D. WEB. &.I..ll'lllSAY .,.ulDUl.........AW 26W.BIgII_ ,cmIsIe. PA i.J~ ~ ", ',\!,~er" "!!!r;;~ - ,:' -"" lilIIlM""'~li"'''''~e;~ weibley . ljb November 21, 2000 msa or mixed, which the other now owns or may hereafter acquire, 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 term thereof. 15. 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 counselfees 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. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. Witness: (Seal) (L~ (Seal) 11 ~~~"'j!li..i~-";-':!I;'-'!i'~,{;"<L,)::'_"ili!"''Y';'~"'''''h"""t-l~,'';''ll,~_r""--'':;;''"'''':_'~~I!l>1'i''''!l#'''!i!J'1I/li.13lii111l~~'~~~1llri.R:~~~~riH -''I: g c- o "'.-1 s::: ':0- >>CO -0 :D 1l;Jf11 -:;:t::J ",,-:D ,- N -om ~~ -;"o,CJ ~_Z w ~~:? !~ -0 ~-H ::Jr. (') ~ .;.i,nm ~ Ul ~ C '~-"",kl...~,~_""~ _"U"..o~ - ~~ ............ . ~'~"""'ro'J""",_~--,,"' PAUL E. WEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - 7359 CIVIL TERM IN DIVORCE VS. BARBARA J. WEIBLEY, 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 Section 3301 (c) :3:391 (8)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant, Barbara J. Weibley, on November 2, 2000. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff February 13, 2001; by the Defendant February 23,2001. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the Plaintiff's affidavit upon the Defendant: _ 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: n/a (b) Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: 'ir (-';;'''' ':J,~ , ~-t':~Jl!l1 1lii&"ffi~.M~ .,_"!"_.",:,i_,,,,.';"O-:"~r.'""~-. '=-' 0" ..1 ',~'~""-a_. 1,L.>U-""4.~ 'O'~"_' [ .em" -"" ,it' ~ 0 0 -'n > :;;:1 1m ..., F;~'r: "'.~ :::0 N -.-m :39 w ( 6 ;;:::'0 -0 :;:i=+t ig ::0: Qt5 N oI"n ~ U1 ~ (:::> -< ,~ ~ " " SAlOIS SHlJ!'lif!PWER &W'llJSAY ATIDRNEYSo,(l".lAW 26 w.Wgh-.t Carlisle, PA PAUL E. WEIBLEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - ? 3S-1 CIVIL TERM IN DIVORCE Plaintiff V5. BARBARA J. WEIBLEY, Defendant 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. I When the ground for the divorce is indignities or irretrievable breakdown of the I 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, Carlisle, .1 :1 Pennsylvania, 17013. iI i i I I I I I , I I I i I i IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PENNSYLVANIA 17013 (717) 249-3166 Date: W J~ J.,.,m By: uire -; ~) file: tjb October 17, 2000 PAUL E. WEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - 735'1 CIVIL TERM IN DIVORCE vs. BARBARA J. WEIBLEY, Defendant COMPLAINT PAUL E. WEIBLEY, Plaintiff, by his attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is Paul E. Weibley, who currently resides at 1552 Holly Pike, Carlisle, Cumberland County, Pennsylvania, where he has resided since 1985. 2. The Defendant is Barbara J. Weibley, who currently resides at 1552 Holly Pike, Carlisle, Cumberland County, Pennsylvania, where she has resided since 1985. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 20, 1980, at Carlisle, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. SAIDIS SHUffi.!!OWER . &Lll'iuSAY 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the ATIOIINI!\'8o.(.lAW UW. mgh street CarlisIe, PA marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. II SAIDIS SHUffi.!!pWER . &LIl'luSAY AllOIlNI!YSoKf.IAW U W. mgh street Carlisle,PA file: ~b October 17, 2000 . 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: I Date: tf} 1f It{' 1 ptJPi) I II !) II Ii I I I I SAIDIS SlIIJffi. !!OWER . &~1JSAY ~.lAW UW.Blgh_t CarllsI.. PA - ,;, -~ ~ " _ J ~ iIiiI~~ ----,'", ',,' &-,:;,'-" ' file: Ijb October 17. 2000 VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. f2!~fL~ Date: al- I rt - ;1000 I ii J '" '." ,. " ,,,,,;,, "'''5 ,.",',," ,"'.". -' ";;,;"""';ii(r";';:'-'",,':',~,,, ;::!i.Jj;)'~'- II.. ,.,_ '" ,- c>;',~,i',,,,, ,~, :.-" - ~ - ... ie',','" ',,~'i,", '''," -'-'~ ., '-"'",' ,_ . 0 C), G (~: ~ ......... :::~- .:-) ~ -or:, i;") ~ '-.J fTir-,- -, ~ ~ :;~:J , ZC'- '_L~ ~ ~ U! ~, ~ ~ ~~ -n ~. ~ \ .<'"--'r-", , , >"S ~.' '- ~ \ ~ ::,:-~ ::::> ~,' (; ~ -< OJ \::1 . ~ ~~ . t ~ "~ -, - , ',,, '" '" "-,, , "')' --, ~:~,~ ~c I I I Ii II II 1\ I SAlOIS " SHUffi.!!DWER il . &UNVSAY Al"JORNFlSoIO'.1AW UW. Blghstre.t Car1isle, PA _,__"",- ~,,:>c,,"_ 0';-"',.,,>,-, file: ljb October 23, 2000 PAUL E. WEIBLEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 2000. 7359 CIVIL TERM Plaintiff V5. BARBARA J. WEIBLEY, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce in the above captioned matter. Date: j//d-Iod I / I I' 'A ,~- ..-,:, ,"',~t~:',OW>':';"~ -:;:; ':~. ~~ ."s.. ,-'.- ..,' ",',,'d,' ~ ' ~"~'~-"",< ,~~" o C-..: 2;><- Ig;{ ft s.::o f; <::. :;j I, " ,I I! ii Ii I a ~~~ -~ nil t..)j r.., C) -_-J .'cJ ~":"'" , ,'~', ::':~/ SY : -, ~JM ~ -<: - ~--' ~ ~ '0 ,.';".;Ib'" - - . " llli!1,~.;^, . , PAUL E. WEIBLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 2000. 7359 CIVIL TERM IN DIVORCE vs. BARBARA J. WEIBLEY, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !3l 3301 (c) of the Divorce Code was filed on October 1,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn fal,ifi03'o" to .,thmlti". \=JJ {. W~ Paul E. Weibley, Plainti Date: J- \"3 ~ 0 \ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UfIlDER s3301(c) OF THE DIVORCE CODE SAlOIS SHUFF, FLOWER & LINDSEY ATIORNEYS.AT.LAW 26 W. High Street Carlisle. PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn f"',"''''o" to aothoritie,. ? a-9.. 'S W~ Paul E. Weibley, PI . tiff Date: .:2 - l ~ -c> ( ,i":", ,,; "'~,_. ~o -~' "~~. ".,",~- ~. ,=, ~" , LiiiI~'~'j-:o'J~ ",," " ~, . ^ ".0""00 ,.'" ~--",-" C" ";" '.'"'-"''' 'ill h "( 00 0 o c ~~ ~~ --~ l , :::-"S .,-":~. --j -<.. .--- - lei],. ~ i I ~ ~ I i! a .." ~'1 ::..--:r N o o -r, ~ . (~ (.~, :::.t ;"'-:,:U ~'::;:(J ;:;':;;,rn ~ -< cO (..) . . SAlOIS SHUFF, FLOWER & LINDSEY ATIORNEYS'AT'LAW 26 w. High Street Carlisle, PA . -". ',' d__ = ".,~i rc -.' . . PAUL E. WEIBLEY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - 7359 CIVIL TERM IN DIVORCE Plaintiff vs. BARBARA J. WEIBLEY, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !l 3301 (c) of the Divorce Code was filed on October 1, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand tha false statements herein are made subject to the pen's 18 Pa. .S. 4 4 r . ating to unsworn falsification to authorities. Date: WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER s3301(c) OF THE DIVORCE CODE 1 . I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is I fiiedwith the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and be ief, understand t t fal statements herein are made subject to the penaltie of 18 a.C.S. 90 ti 9 to unsworn falsification to authorities. Date: II