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HomeMy WebLinkAbout00-08503 . . . . . . ,., ,., Of. "'ff. . :f. :f. ~"'''':f.:f.'''''' '" '" '" "''''''' '" :f. . . . IN THE COURT OF COMMON PLEAS . . . OF CUMBERLAND COUNTY . . . . STATE OF George C. Rhoades . . . . . Plaintiff . . . VERSUS Patricia A. Rhoades . . . . . . Defendant . . . . . . . . . AND NOW, . . . DECREED THAT AND . PENNA. No, 2000-8503 DECREE IN DIVORCE f~ 2.'f , UD/ ,IT IS ORDERED AND ~pnrgp r Rhn~~pc , PLAINTIFF, Patricia A. Rhoades , DEFENDANT, ARE DIVORCED FROM 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; . . . . . . Tpp P~rT;PC' M~rjtal Prgpgrt7 ana gettlamcnt Azr~pmant d~t~g luag 12, 01 is inQorporated herein and the Court has jurisdiction over no other claims. . . . . . . . . . .. BYTHE co.u;;J PROTHONOTARY . . '" :F.iF.ff.:f.ff. ff. .. . . .. J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . , , . . . , , , . , , . . , . . . . . . . . , . . . . , , , . . . . . . . , , . . , . ~ i~ " "'"'"" ,,,,,,, "-. N~ . , o~ -, .w """,,",,'~N','" ,o"W,,,' " "'R4"~' """'j Jiiiilillrn mruUlr " , nl'Y'f"",l'! , ... . '. 7'.:;2S-6( M. ~ ~~ti1~? 7'~5-01 ~ ~ '?J; , '~'? p Wl!l~ ~, I1U.~~I"~~~.g"!~1!!'lffI?!:~~~~~"!",,,~U='r' .,=~_ J: __..",.,,,.,,,,,,,,r _o,~J1 . _, "H~ ,~ ~ ~..~ . ,- "~ ~.._- -........ GEORGE C. RHOADES, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA vs. CIVIL ACTION - LAW PATRICIAA. RHOADES, Defendant NO. 2000-8503 : IN DIVORCE CIVIL TERM MARITAL PROPERTY AND SETTLEMENT AGREEMENT This Agreement, made and entered into this ~ day of ~_, 2001, between Patricia A. Rhoades, 156 Pleasant Grove Road, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife", and George C. Rhoades, Perry County, Pennsylvania, hereinafter referred to as "Husband." WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on April 16, 1986 and are the parents of two minor children: George Anthony Rhoades, born July 23, 1986 and Jessica Nicole Rhoades, born November 10, 1984; and, WHEREAS, certain differences have arisen by and between the parties as a result of which they have now separated and the parties hereto are desirous of settling fully and fmally their respective financial and property rights and obligation as between each other including, without limitation by specification: the settling of all matters between them relating to the 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 Wife by Husband or of Husband of Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates; and, . WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the ,~L<" Ju ~"_J , _-",,;c, execution hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; and, WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of her right of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to counsel fees, or expenses and other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtesy, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future; NOW, THEREFORE, the parties hereto intending to be legally bound hereby do hereby mutually agree as follows: 1. Advice of Counsel. Husband and Wife acknowledge that they have been given the opportunity to obtain the advice of counsel regarding the provisions of this Agreement and their legal effect in advance of the date set forth above to permit such independent review. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel of his or her selection, and that each fully understands the facts and has been fully informed as to his or her legal rights and obligation, and each party acknowledges and accepts that this Agreement is, and under the circumstances, fair and equitable, after having the opportunity to 2 ~ ,"' ~~~. '!W/ receive such advice and with such knowledge, and that execution of this Agreement is not the result of any improper or illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has had the opportunity to be fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs oflitigation and, fi.llly knowing the same and having the opportunity to be fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to have the Court of Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order effecting the respective parties' rights to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs oflitigation. 2. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 3. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 4. Mutual Property and Estate Waiver. Except as otherwise expressly set forth 3 .''-' ...~ .-~-~" ~ ~" .. ...................= ~,- 1 "~,." herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of dower or curtesy, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties furthllr agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an 4 ~". yo""",,,", ""- - ~. ~ \~ -, . ~ ~..." equitable distribution of married property ordered by the Court pursuant to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenances, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 5, Division of Personal Property. The parties agree that they have divided their personal property including all household items, to their mutual satisfaction, except that Wife agrees to transfer to Husband the Steven King collection, match box car collection and Husband's leather coat and Husband agrees to transfer to Wife the muzzle loader gun. AUTOMOBILES: Further, the parties have agreed to retain the vehicles that they presently drive and that each will assume the respective payments for their vehicles if any. In this regard, Husband shall retain the 2000 Toyota Truck; Wife shall retain the 1997 Ford Explorer. The parties agree to execute any and all documents necessary to effectuate the change of title on said vehicles, if necessary, BANK ACCOUNTS: The parties hereby agree that the Certificate of Deposit at PNC Bank: shall be divided equally by the parties. From and after the date of the signing of this Agreement both parties shall have complete freedom of disposition as to their separate property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, conveyor otherwise encumber or dispose of such 5 . '~. "eo' ,= ~-" - : In -......"- property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. 6. Debts. The parties agree to assume their respective credit card debt and car loans if applicable. Each will indemnify and hold hannless the other as to these respective debts. The parties agree to be responsible for any other individual debts which are presently in their individual names and to indemnify and hold harmless the other for the aforementioned debts.. 7. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will indemnify and hold the other harmless from any and all liability thereof. 8. Real Property, It is hereby acknowledged by both parties that they are the co- owners of real property located at 156 Pleasant Grove Road, Mechanicsburg, Cumberland County, Pennsylvania, which has a home equity loan thereon in both parties' names in the approximate amount as of the date of separation of $35,000.00. Husband agrees to transfer his interest in the real property in the event that Wife refinances the mortgage on the marital residence. Husband shall execute a deed of conveyance which will be held in escrow with the Husband's attorney pending settlement on said ref mance, with the deed of conveyance to be released to Wife's attorney at settlement. Wife shall make application as soon as practicable to proceed with the refinance which shall be accomplished within ninety (90) days of the date of this Agreement. Upon settlement on the refinance, Wife shall pay to Husband the sum of $35,000.00. Husband agrees to cooperate and to sign any and all documents necessary to 6 .10.'--, ""'_,,_c - ~~ ~ 0" ~-, '~ . >>. . -~:iIH>i"~'_ accomplish the transfer and refinance, as aforesaid. Pending the refinance of the premises, as provided for herein, Wife agrees to pay any and all expenses in connection with the marital residence, including but not limited to home equity loan payment, taxes, utilities, and assessments. Wife shall further indemnify Husband and hold him harmless from the aforesaid obligations. 9. Support, Alimony and Alimony Pendente Lite. Child support, spousal support, alimony pendente lite and alimony is determined by Order of Court docketed at No. 01030 S. 2000. Once the Divorce Decree is entered, spousal support/alimony pendente lite shall cease. Both parties waive any future claim for alimony. 10. Custody. The parties agree to share legal custody of their children, Jessica and Anthony. Wife shall have primary physical cl,lstody of the children with Father having periods of partial physical custody as the parties agree. 11. Pension/401K/Retirement Benefits. Each party agrees to waive any right they may have in the others' pension or retirement plan or 40lK 12. Taxes. The parties agree that all 2000 income taxes shall be filed separately. 13. Counsel fees. Each party agrees that they shall pay their respective counsel fees. 14. Divorce. The parties acknowledge their intention and agreement to proceed in an action in divorce to obtain a fmal decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in any divorce action. The parties agree to execute any and all documents necessary for the entry of a final divorce decree. 15. Breach. In the event that either party breaches any provision of this Marital 7 ,,""~ ~ - 1 . ~ ,- .-;" Property and Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 16. Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any court of competent jurisdiction. 17. Applicable Law and Execution. The parties hereto agree that this marital settlement agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 18. The Entire Agreement. The parties acknowledge and agree that this marital settlement agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 19. Incorporation and Judgment for Divorce. In the event that either Husband or Wife at any time hereafter obtain a divorce in the action for divorce presently pending between them, or otherwise, this agreement and all of its provisions shall be incorporated into any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this marital settlement agreement. 20. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be 8 ",;'I!J""~" ~ _. , i~~.; 'il'J'llIioi$;;,' 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. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year fIrst written above. WITNESS: ,r! ~Av~ 9 ". - ~=.. ~~Mliri\jIl1!~!~liIi'h~~l1~~~AilJ~fi5ff~miliiil1l~- ,~ If.~' ~. .~ J .lIt,,,=, ""-~_=. ~;~ <e _. "' ","*" _"~ '" ~;:: o ~t~.; z((;: j;:' C :!j ("', c:: :? ,-',; T'-,) fYo _:J ~- -., ~') 9;? ~,~~ :;;; ~. -0 -< C:) \0 . ."'o_~..., "_~""'"~ .~~~ .. GEORGE C. RHOADES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA : CIVIL ACTION : NO. 2000-8503 V. PATRICIA A. RHOADES, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following inforrnation to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c),-99tlT (d}tl) of the Divorce Code. (Strike out inapplicable section). 2. Date and rnanner of service of the Complaint: Acceptance of Service, made on December 20, 2000. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by sec. 3301 (c) of the Divorce Code: by plaintiff Tune 12,2001; by defendant Tune 12, 2001. (b) (1) Date of execution of the affidavit required by sec. 3301 (d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff's affidavit upon the defendant 4. Related claims pending: None 5, Complete either (a) or (b). "". ~ ~ ~~, ~ ~ A<i<i!"u.-= ' d_ --, ~ > ."""-. ~ , (a) Date and manner of service of the Notice of Intention to file Praecipe to transmit record, a copy of which is attached (b) Date plaintiff's Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: Tune 26, 2001. Date defendant's Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: Tune 26, 2001. Date: &, -.) ~ -0 I ~jl1..~~ tto ey for Defendant Jacqueline M. Verney, Esquire Suprerne Ct. # 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 .~~ .," --- ... ~ ~ GEORGE C. RHOADES, Plaintiff vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.IJV-li'5W~ I~ PATRICIA A. RHOADES, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the c1airns set forth in the foregoing 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 in divorce or annulrnent 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: Office of the Prothonotary Curnberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 II 1____ -. .... GEORGE C. RHOADES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00- ~S03 ~ T /L.u-- PATRICIA A. RHOADES, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you rnay request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors ;s available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling, JL- " ~ GEORGE C. RHOADES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. O(J - 8503 ~ T........... PATRICIA A. RHOADES, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, GEORGE C, RHOADES, by his/her attorney, Samuel L. Andes, and makes the following Cornplaint in Divorce: 1, The Plaintiff is GEORGE C, RHOADES, an adult individual who currently resides at 156 Pleasant Grove Road in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is PATRICIA A, RHOADES, an adult individual who currently F resides at 156 Pleasant Grove Road in Mechanicsburg, Cumberland County, Pennsylvania. 3, Both the Plaintiff and Defendant have been bona fide residence of the Commonwealth of Pennsylvania for at least six months imrnediately previous to the filing of j"' , [ f, this Complaint. 4. The Plaintiff and Defendant were married on 16 April 1986 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7, Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. II ,",:- -. . .0 - COUNT I IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce, WHEREFORE. Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. Date: I), ) I J ()O I ... ,YJ. - ~ GEOR~ RHOADES &Jtf2 (LQ., Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I I' II - GEORGE C. RHOADES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-8503 CIVIL TERM PATRICIA A. RHOADES, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE The undersigned, PATRICIA A. RHOADES, does hereby accept service of the Divorce Complaint filed against her in this matter and acknowledges receipt of a certified copy of that Complaint. Date: '.;?~O/O-OD Jbtv~ AC)wo.dAo PATRICIA A. RHOADES I j/I i!':'-~.;":tli'~ 0.'"<" ,,- -,;.,."k--'ai;r'il~-'- ,~ -~(r[~"'~~~-~~L \_,}:__;J~;h- ',. }S,:~~ _, ."y;~l:,! ,~J)!!'!_,,"_t-:!ID. "_~ _"" '_,_ ~,,'"- ., "'" -."-- --'-'-""-".'~ -;",' s. '-,;:.,i;;i~-- ," h ''''fe-'- .~ = .-- ~".- "'"~- - ,~- - .0' ' o c ""'=" -o~;~ ~1f.D 6f~:1 ~i.~~' ~~=) 5:;c:! 2:" --; -( ,:-;) U'/ . C,,", .",",,,; o o o :C''l , J ~1 :..~:J '" --, 'T'i,:-l:! :]fTf -'.-'-..-' '-', ! '--,':.:C) ~.~ .=f-, :--1__'] ~;';" ,~'-) ~r,", .:n --< ['" ("~ ~ ~-:l ~'-',. - .. ~ .-.."~'- ".~ ~ . "~ "f _..J ~-~~~"'. , GEORGE C. RHOADES, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA CIVIL ACTION - LAW PATRICIA A. RHOADES, Defendant : NO. 00-8503 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on December 7, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904, relating to unsworn falsification to authorities. Date: C;j~~7 ~~ ~ ~,- <" -~"-~' Uj ~.""""~:i~~t;Iik",\~I!\ill~,~'"i"",1 - " , ~- -~ -j'-""'-" ',' r ftdiillllllf""" ~~r.IB( 0 0 0 c: -,', s: ,,_.~ -Ow '.- Q)L~ -,""." ~<A ;'.....:7 Z~'_','_ O~, SQ':> ~C_- ,,<",",.-- :i> c' -'. bC) co )>c: :z: :::0 =< \..0 ! - .~ ". ",-~ -""".~"'~, GEORGE C. RHOADES, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA CIVIL ACTION - LAW : NO. 00-8503 CIVIL TERM PATRICIA A. RHOADES, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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! 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. section 4904 relating to unsworn falsification to authorities. Datet/p)61 ~ " "'L~""",,......;.,-c,;;~""~iI1M1~1~<lJi~_tti~-~""'';. LLJr n dd~ ~" ~. . <. Ii~' ~. "~'llIn""'" ,-. o [iji~t gs~: ~~~; " 20 "-0 .J>(_ !J " .. '- ""W c~ L ,-- ---.." ~ t..) en ~" ~ ~ a <0 11 ,~~J" _~~~, _..~ ~J . - " _~~ _,".L ~ "......... ^ iOlMlll!id',M;';,i' . GEORGE C. RHOADES, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v. CIVIL ACTION - LAW PATRICIA A. RHOADES, Defendant : NO. 00-8503 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on December 7, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904, relating to unsworn falsification to authorities. Date: ~/ \')'0\ ~~~~ALleD Patricia A. Rhoades, Defendant " ' ,'r,';';~'.~ ;;'.'..'.," 1lI'~-' tii.ir" <~ "-"""'-'~~a'!!~W';i~r'");-'~ll3m:,,)*"~,~t-(;~ill~~lI! a.:a:C:- - ,~ ,~. M_< ~_"_ .,~= .. ~- 1flll~-'" ~ .-. ~:r-'-"' o c: 5-.. -on' rl1r-;" -:?' " ~~. ~~~) ZJ'.~:.. S>~i ::;:j -<: c . _ <, "",,^".'h' '.' , 1"..,;) <y, "",." '--,' ~, ~..:;'1~; ~ :< ~ :::> ,0 III ~-'"""'~~.''''.'. "~ ~ > . , GEORGE C. RHOADES, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW : NO. 00-8503 CIVIL TERM PATRICIA A. RHOADES, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. section 4904 relating to unsworn falsification to authorities. Date: ~O- \d-D \ ~~htf~r1M Patricia A. Rhoades, Defendant .....- ~. ~, -';0"--" "-~,,,~'s:":" -.llillJ'rBj[1iIliliM;~~~1GWlii~1'!m~llM"~1I~J!l:ii""',.j';"':- . ~'"," -~ " '-..'II_iII.' . '~ ..'... () 0 c: Cj <'" , I i.)f-:::"-: ~ EPg:: c:: "'10-' 'oU 2r-'" N "~I"' en> r:5(S (,T; ~ .) :r.---"'"' r) d;C:: -,:,. ~,---." ""'C ,,") >C' 9? ~5t , , ~ D );:; (L) :::D -<