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HomeMy WebLinkAbout01-109 FX :f. ;I; 'fi'ldli'f. '+' >f' ,- .. ~'f.++T.+' 'f.'f.'fi+''fi'f.T.+~++++'+' +++.'f.;f.+'I'~;+: 'f. + . . . ++++ +.+. ;I;;I;'l'+++.++.+'I; . . . IN THE COURT OF COMMON PL~~S OF CUMBERLAND COUNTY r~ . . . STATE OF . . . . . .lANE T.. BENFF.R . . . . . . VERSUS . RICHARD J. BENFER . . . . . . + + . . (. . . . . . . . . AND NOW, vVl2 "'I + + . PENNA. '" if No. 2001 109 CIVIL DECREE IN DIVORCE (,6 200( IT IS ORDERED AND DECREED THAT JANE L. BENFER , PLAINTIFF, . . . . . AND RTrWll.RT1 ,T "RRl\ili'R'R . . , 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; . . . . . . . . None. The parties hereby incorporate the attached . . Settlement Agreement, resolving all issues. . . . . . . . . . . . . + . . . . ++'t';t'...... +++++++'l' ;\' :'r. ... t . ~ ~ .. . + + + . . . . . ->. . . . " . . . . . " . . . . . . . .. . . . . + . . . . . . . . . . . . . . . . . + . . + . . . <! . . + + . . " " . + . . . . * + J. . . . + . . . .' ~ ." ": ~ ..\,-.-.\> '.;'''~ '. ".4~ ',~ 5"/8'01 M C~ pt~ .:d ,p4~ $'/8'tfJl '71~ ~ ;$ ~- $; , KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - 109 CIVIL RICHARD J. BENFER, Defendant IN DIVORCE SETTLEMENT AGREEMENT THIS AGREEMENT, is made this 20th day of IY/(ifJ by and between JANE L. BENFER ("Wife") and RICHARD J. ("Husband") . , 2001, BENFER WIT N E SSE T H: WHEREAS, the parties, currently Husband and Wife, will be obtaining a decree in divorce; and WHEREAS, by this Agreement, the parties have intended to effectuate and equitably divide their marital property and marital debts; and WHEREAS, diverse unhappy difIerences, disputes and difficulties have arisen between the parties and it is their intention to live separate and apart for the rest of their lives and to settle any and all claims by one against the other or against their respective estates. NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed as an essential part hereof and in consideration of the premises and of the mutual promises set forth herein and for other good and valuable consideration, receipt of which is hereby acknowledged, the parties, each intending to be legally bound hereby, covenant and agree as follows: 1. EFFECT OF DIVORCE DECREE. The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect-to the parties. This Agreement shall be incorporated, but not merged into the final decree in divorce. 2. FINANCIAL DISCLOSURE. The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. No representations have been made by either party to the other, or by anyone else, as to the financial status of the other except as expressly set forth in this Agreement. 3 . ADVICE OF COUNSEL. wife has retained Kenneth F. Lewis, Esquire. Husband has been advised that it is in his interest to retain counsel. The parties have been advised regarding this agreement by counselor have chosen not to seek such advise. Both parties acknowledge this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received independent legal advice, or foregone the opportunity to do so. The parties acknowledge this Agreement is not the result of any duress or undue influence and is not the result of any collusion or improper or illegal agreement or agreements. 4. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. The parties understand that each has the right to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or otherwise. Both parties understand they have the right to have a Court hold hearings and make decisions on the matters covered by this Agreement. Both parties understand that a Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Both parties waive the following procedural rights: 2 a. The Appraisement-of all marital Pennsylvania Divorce Code. right to obtain an Inventory and and separate property as defined by the b. The right to obtain an Income' and Expense statement of the other party as provided by the Pennsylvania Divorce Code. c. The right to have the Court determine which property is marital and which is non-marital and equitably distribute between the parties that property which the Court determines to be marital. d. The right to have the Court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including but not limited to possible claims for divorce, spousal support, alimony, alimony pendente lite, counsel fees, costs and expenses. 5. PERSONAL RIGHTS. Husband and Wife, may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 6. MUTUAL RELEASES. Husband and Wife each do hereby mutually release and forever discharge the other and the estate of the other of and from any and all rights or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of the other, which he or she now has or at any time hereafter may have against such other, the estate of such other or any party thereof, whether arising out of any former acts, or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or 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 3 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 (a) pennsylvania, (b) any state, Commonwealth or Territory of-the united states, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, 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 provision 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 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 provisiohthereof. 7. PERSONAL PROPERTY. The parties make the following disposition and settlement with respect to their personal property. a) Husband and Wife agree they have equitably divided all their personal property to each party's satisfaction. b) Vehicles. Wife shall become sole owner of the 1998 Mazda currently titled in both names. Husband shall sign the title and any other documents necessary to effect this transfer. Wife shall indemnify and hold Husband harmless from any debt arising from the ownership and/or use of these vehicles. c) Retirement Accounts. Husband and Wife shall each maintain and be the sole owner of his/her retirement accounts (Wife's with an approximate value of $11,830.71 and Husband's with an approximate value of $628.62. Each party waives any and all interests he/she may have in the other party's retirement accounts as listed above. d) Wife shall maintain and be the sole owner of her bank accounts at Pa. state Employees Credit union (minimal value) and the account with her daughter at Waypoint Bank (minimal value) . Husband shall maintain and be the sole owner of his bank account at Pa. state Employees Credit union (appx. marital value $1,000- $2,000). 4 e) The marital portion of any other financial instruments and/or financial accounts shall be divided equally between the parties. f) Husband shall pay to Wife the sum of $500.00 per month in lieu of child support. The parties acknowledge that this provision does not prevent Wife from filing for such support, but that if she does so, Husband is no longer liable to continue making the $500.00 monthly payments. 8. AFTER-ACOUIRED PERSONAL PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were not married. 9. REAL ESTATE. a) Wife shall retain and be the sole owner of the marital home located at 37 Scarsdale Drive, Camp Hill,cumberland County, PA 17011. Upon presentation, Husband shall execute any and all documents needed to effect the transfer of the home to Wife's sole ownership. b) Wife shall take all reasonable and necessary steps to promptly refinance the property. c) Wife shall be responsible for all costs associated with the marital home, including the mortgage and PNC home equity loan, and shall indemnify and defend Husband against all debts and/or monetary obligations of whatever kind regarding the property. 10. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. and/or claims pendente lite The parties hereby waive and surrender any rights they may have to interim or final alimony, alimony and spousal support. 11. ATTORNEY'S FEES AND COSTS. The parties waive and surrender any rights and/or claims they may have to interim or final counsel fees and/or costs. 5 12. DEBTS. a) Husband shall be solely responsible for the VISA currently in wife's name at PSECU (account #195-56-1657), with an approximate debt due of $8,800.00. b) Wife shall be solely responsible for the Kohl's charge in the approximate amount of $1,150.00. c) Each party shall indemnify and hold the other harmless against all actions or collections of whatever kind arising out of the above debts. 13. WARRANTIES TO EXISTING OBLIGATIONS. Each party represents that he/she has not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred, including those for necessities, except for the obligations arising out of this Agreement. 14. WARRANTIES TO FUTURE OBLIGATIONS. Husband and Wife each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. 15. 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 nature. 6 16. BREACH. It is expressly stipulated that if either party fails in the due performance of any of his or her obligations under this Agreement, the other party shall have the right at his or her election to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal remedies as may be available and said other party shall have the right to recover his or her reasonable legal fees and costs for any services rendered by his or her attorney. 17 . 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. 18. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 19. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 20. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior Agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 21. 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 7 , 1/:;':, 1',<\;,.. ". '1:.. way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance or any other obligations herein. 22. SEVERABILITY. If any term or provision of this Agreement shall be determined to be invalid, then only that term or provision shall be stricken 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 her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining ob~igations of the parties. 23. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. ~ ~. t . . ./?tdlU"'. -\.. ~ ~itness __/ G ~'/JC~ w~ ness JANEq4~~~ RICH?: ~1EN1R :1/--/ 8 ~ ,.... >- \- <: ~ ""- F; ~ :;:J.e( !J_t ~...,.-; :::=: 0:;;;: f:~~~ ,,,..:.1: ~~ ,. o.~~ :3;-(0 1 ',_' CO) ,.-:-,:.: )"? ~~)- .-- .'- ~~c:Z ",-..-! \0'-': " . .U~..U W- "-.-', ::LJD- .--- ~~ ;;,: .- t_~_ => r" 0 (.) -' $' KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff .~.. , i _. ~( JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - 109 CIVIL RICHARD J. BENFER, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for . divorce: irretrievable breakdown under section (X) 3301 (c) () 3301(d) of the Divorce Code. 2. Date and manner of service of" the Complaint: Acceptance of Service dated 1/11/01 and filed 1/23/01. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on May 1, 2001; by the Defendant on May 1, 2001. 4. Related claims pending: NONE. Propertv Settlement Aqreement incorporated into decree resolvinq all issues. DATED: 5/2/01 i~ KEN~ET? F. LEWIS, ESQ. ">- r- ;>- i:l: ~ <cO .-" -$;2 ~<( ~~ 0- ..,- U:; :2 -- ~)~ ,=,. ::j c::> :sti) ...L::': "::''J:;~ ;---, '- a.:z ~ -! .~ J.JLU -- <:.l::;: CD C- .'-'" :;C ::2 u.... :::> CI .~ U ~ ~. .. . KENNETHF. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001 - ioq CIVIL : RICHARD J. BENFER, Defendant : : IN DIVORCE 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. When the ground for 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 Courthouse, Hanover and High streets, carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF-PROPERTY, LAWYER r 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. CUM~E~~D COUNTY aAR AsSOCIATION , " 2 LIBERTY AVEJ:f!JE ' C~ISLE, PA 17013 (717)' 249-3166 1-800-990-9108 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - /09 CIVIL JANE L. BENFER, Plaintiff : RICHARD J. BENFER, Defendant : IN DIVORCE COMPLAINT IN DIVORCE COUNT I Request for a No-fault Divorce Under &3301(c) of the Domestic Relations Code 1. Plaintiff is Jane L. Benfer, who currently resides at 37 Scarsdale Drive, Camp Hill, Cumberland county, PA 17011. 2. Defendant is Richard J. Benfer, currently residing at 239 Main st., Apt. A, Shiremanstown, Cumberland County, PA 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 12, 1982 in Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce pursuant to 9 3301(C) of the Domestic Relations Code. COUNT II Request for Equitable Distribution of Marital Property Under &3502 of the Domestic Relations Code 8. Plaintiff hereby incorporates Paragraphs 1 through 7 of her Complaint as if fully set forth herein. 9. The parties are owners of marital property subject to equitable distribution. 10. Plaintiff believes she and defendant will be able to reach an agreement as to their property. If so ,Plaintiff requests the Court to make their agreement part of the decree in divorce. 11. Absent an agreement between the parties, Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties and the marital debts of the parties without regard to marital misconduct in such proportions as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests this Court to enter an Order of Equitable Distribution of marital property and marital debts pursuant to 93502 of the Domestic Relations Code. DATE: 1/8/2001 4gj KElf~ET F. LEWIS, ESQUIRE Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S. section 4904, relating to unsworn falsification to authorities. /, p oZ, /1 (,'i ~,-I' ,,1' -"I .tJ4~-- Dated: 1/'3/01 ( \_-f''''/ ,.;.l-1AL JANE BENFER , ~~ ,-- "" :::::~ ~, lL'>-~ .'_:J ,:':-' fj:~. c.... ft:~: " <:::t: o co u: co if' "] 51 :>-€ ~~ ~\JJ O-rf) ~- ~ 8~ 0 " ~ '~'"," 1.;\ (l l ' -"].""'<j . . ,;;;' l,{'!tl 0 j ,:2 I'- i>o ':cz ;,j,.1uS ~~O- ~,~ (;) co I ::::') CJ ,-Iv, 6. '" "':C c;:S ~ tlJ"'" -J: ~ o <l o '0 or ,~ ~ =i' <:!:: Ie ~ -' 0- C>- J6 e, .-- ~ ~ IS -=::. -- KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAi.D COm,TY, PENNSYLVANIA v. NO. 2001 - 109 CIVIL RICHARD J. BENFER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under section 3301 (c) of the Divorce Code on January 8, 2001. 2. The marriage of plaintiff' and'. Defendaht- is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. 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. Dated: 5 );!zoo/ Gt~ ;( JANE L.IBENFER ~L-- '" - ,... >- ~ ~ '-'" 5 5:0& tLl8 z Et~~ .- o~ ~~~ ;2 ,...,~. ~5== co -~("fJ ! :Jz kq';;..~ c:::z ;-;' ~i~: >- ~J.Jt.U "'" !:11e- -;::.--: ::.;:: -~ "- :::> Cl <=> D KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 109 CIVIL RICHARD J. BENFER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under section 3301 (c) of the Divorce Code on January 8, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. 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. Dated: 5!1/2cOI ;-" ~~./ ~~.I' RICHARD J. NFER >- ,.... >- ,.,.. ~ ~ 2: u.!!;;; .9 ::::5$; ~J?--~\ Oz -- oiC w... ~-' -- R~,"; <<:::.r o:::~ ~, ' '7>= .. -, ~.~2 CO '::?(/) 1 ~Z '-,....."""? - G:~::,' :>- tuCb ~ :;:;; COo.. .... "';: .' '::5 ,~ 0 <=> (,) ;',- ". .~_-_. <-0. KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - 109 CIVIL RICHARD J. BENFER, Defendant IN DIVORCE WAiVER OF NOTiCE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (e) OF THE DIVORCE CODE 1. I consent to entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Decree is entered by the Court ,and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated:SjJ /ZflO} f). -/~ LI'~ ^ JANEIL. BENFER :>- ,... i::: s; ..... s ~ 9 ~~ '::>$ ~ ~.2: _.~ :s:: of:::=' '3!2 @f:L:- co ~yq, J ~IZ >- !..::t:7 L;:.. :.L l.ll 1JJ ~~ ~o.: i-. ...;;;;., .2: L!... - -:.> :::) 0 0 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - 109 CIVIL : RICHARD J. BENFER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (0) 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: 5 If j2M I RI~~{' ~!~ 0>- f'- 0>- ct: I-. is 9 ;;;: U.!~;' 8!f fiG - (-):s:- '<- ......... "'" ,::).:::.; C':':';- E;'~:-~ c:;;, 2::';:.;.:: , SE9 ~"~ >- /:J::;z :"'1,;. ~'_-: '"'" ~-uw ~: .tJ.Jo..,: :rc ::::;;: L.:_ :::5 c". <:::> 0 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front stroset . " Harrisburg, PA 171p2 (717) 234-3136 Attorney for Plaintiff JANE L. BENFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - If)' CIVIL RICHARD J. BENFER, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. DATE: / //1 /t)/ .r . ~~$~~ RICHARD J. BENFER-