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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
RAY '1', HUN'l'ER. JR..
Plaintiff
No. 2001-3818 Civil'l'erm
.
VERSUS
JULIA A. HUN'l'ER,
Defendant
DECREE IN
DIVORCE
AND NOW,
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'I- ~IT IS ORDERED AND
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DECREED THAT
RAY T. HUN'l'ER, JR.
, PLAINTIFF,
AND
JULIA A. HUN'l'ER
~ 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;
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The Seoaration and Prooertv Settl~t Agreement dated July 25. 2001
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ATIEST'~~
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PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2001-3818 CIVIL TERM
JULIA A. HUNTER,
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 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: By personal service on June 28, 2001 -
Acceptance of Service filed June 28, 2001.
3. Date of execution of the Plaintiff s affidavit of consent required by Section 3301 (c)
ofthe Divorce Code; June 14,2002; by the Defendant; June 14, 2002.
4. Related claims pending: None.
5. Date Plaintiffs Waiver of Notice III S3301(c) Divorce was filed with the
Prothonotary: June 14,2002.
Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the
Prothonotary: June 14,2002.
HANFT & KNIGHT, P.C.
By
Michael J. Hanft, squire
Attorney I.D. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Date: June 14, 2002
Attorneys for Plaintiff
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NUUUUAGESETTLEMENTAGREEMENT
THIS AGREEMENT, made this2.S'TIf day ofJuly, 2001, by and between RAY T. HUNTER,
JR. of Cumberland County, Pennsylvania, party of the first part, hereinafter referred to as "Husband"
and JULIA A. HUNTER of Cumberland County, Pennsylvania, party of the second part, hereafter
referred to as "Wife."
WITNESSETH:
WHEREAS, Husband and Wife were married on July 19, 1976, in Mt. Holly Springs,
Cumberland County, Pennsylvania; and
WHEREAS, Husband and Wife have been living separate and apart from each other since
June 21,2001; and
WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and
have been so for at least the past six (6) months; and
WHEREAS, certain diverse, unhappy differences have arisen between the parties hereto
which have made them desirous of living separate and apart from one another; and
WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights
and obligations, and make an equitable distribution of their marital property; and
WHEREAS, it is the intention and purpose ofthis Agreement to set forth the respective rights
and duties of the parties while they continue to live apart from each other and to settle all financial
and property rights between them; and
WHEREAS, the parties hereto have mutually entered into agreement for the division of their
jointly owned assets, the provisions for the liabilities they owe, and provisions for the resolution of
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their mutual differences, after both have had full and amble opportunity to consult with their
respective attorneys, and the parties now wish to have that agreement reduced to writing.
NOW, THEREFORE, the parties hereto in consideration ofthe mutually made and to be kept
promises set forth herein and for other good and valuable consideration, intending to be legally
bound and to legally bind heirs, successors, assigns, and personal representatives, do hereby
covenant, promise and agree as follows:
ARTICLE I
SEPARATION
1.1
It shall be lawful for 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 shall deem fit free from any
control, restrain, or interference, direct or indirect, by each other. Neither party shall molest the other
or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other
proceedings. The foregoing provision shall not be taken to be an admission on the part of either
Husband or Wife of the lawfulness of the causes leading to them living separate and apart.
ARTICLE II
DNORCE
2.1
This Agreement is not predicated on divorce. It is specifically understood and agreed by and
between the parties hereto and each of the said parties does hereby warrant and represent to the other
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that the execution and delivery of this Agreement is not predicated upon nor made subject to any
agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any
action for divorce; provided, however, that nothing contained in this Agreement shall prevent or
preclude either ofthe parties hereto from commencing, instituting or prosecuting any action or action
for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either
party from defending any such action which has been, may, or shall be instituted by the other party,
or for making any just or proper defense thereto. It is warranted, covenanted, and represented by
Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this
warranty, covenant, and representation is made for the specific purpose of inducing Husband and
Wife to execute this Agreement. Husband and Wife each knowingly and understandingly hereby
waive any and all possible claims if this Agreement is, for any reason, illegal, or for any reason
whatsoever of public policy, unenforceable in whole or in part. Husband and Wife do each hereby
warrant, covenant and agree that, in any possible event he and she are and ever shall be estopped
from asserting any illegality or unenforceability as to all or any part of this Agreement.
2.2
It is further specifically understood and agreed that the provision ofthis Agreement relating
to the equitable distribution of property ofthe parties are accepted by each party as a final settlement
for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of
separation or divorce in any other state, county, or jurisdiction, each of the parties to this Agreement
hereby consents and agrees that this Agreement and all its covenants shall not be effected in anyway
by any such separation or divorce; and that nothing in any such decree, judgment, order or further
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modification or revision thereof shall alter, amend or vary any term ofthis Agreement, whether or
not either or both of the parties should remarry, it being understood by and between the parties that
this Agreement shall survive and shall not be merged into any decree, judgment or order of divorce
or separation.
2.3
It is specifically agreed that a copy of this Agreement may be incorporated by reference into
any divorce judgment or decree if or whenever sought by any ofthe parties hereto. It is understood
by the parties that a Divorce Complaint has been filed in the Court of Common Pleas of Cumberland
County at Docket Number 2001-3818. Such incorporation, however, shall not be regarded a merger,
it being the intent of the parties to permit Agreement to survive any such agreements.
ARTICLE ill
EOUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property in a manner which conforms to
the criteria set forth in Section 3502 ofthe Peunsylvania Domestic Relations Code, and taking into
account the following considerations: the length of the marriage; the prior marriages ofthe parties;
the age, health, station, amount and sources of income, vocational skills, employability, estate,
liabilities, and need for each of the parties; the contribution of one party to the education, training
or increased earning power of the other party; the opportunity of each party for future acquisition of
capital assets and income; the sources of income of both parties, including, but not limited to
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medical, retirement, insurance or other benefits; the contribution of dissipation of each party in the
acquisition, preservation, depreciation, or appreciation of marital property, including the contribution
of a party as a homemaker; the value of the property set apart to each party; the standard of living
of the parties established during their marriage.
3.2
The division of existing marital property is not intended by the parties to constitute in any
way a sale or exchange of assets and the division is being effected without the introduction of outside
funds or other property not constituting marital property, The division of property under this
Agreement shall be in full satisfaction of all rights of equitable distribution of the parties.
3.3
The parties shall retain sole and exclusive right, title and possession of all personal property
currently in their possession. Except as provided for herein, Husband shall make no claim
whatsoever for any personal property in Wife's possession. Additionally, except as provided for
herein, Wife shall make no claim whatsoever for any personal property in Husband's possession.
Should it be necessary for either party to execute any documents to convey title to any such personal
property in the other party's possession, they shall do so within thirty (30) days of the execution of
this Agreement or within thirty (30) days of the request from the opposing party.
a. Husband's severance check from TYCO with a gross amount of$16,915.00
and a net amount of $10,242.04 shall become the sole property of Wife.
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b. Husband's severance check from TYCO with a gross amount of
$5,120.70 and a net amount of$4,679.6l shall become the sole property of Wife.
c. The M&T Bank Savings Account Number 15004198311125 with an
approximate balance of$16,079.4l shall become the sole property of Wife.
d. The M&T Bank Checking Account Number 00008-28033 with an
approximate balance of$1,829.64 shall become the sole property of Wife.
e. Merril Lynch Account Number 202-46-6277 shall become the sole
property of Husband.
f. TYCO Retirement Savings and Investment Plan, Account Number
202466277 shall become the sole property of Husband.
3.4
Except as provided herein, Wife waives any right or interest she may have in Husband's
employment benefits, including any pension benefits, retirement plan, stock option purchase plan,
profit sharing plan or related matters. Except as provided herein, Husband waives any right or
interest he may have in Wife's employment benefits, including any pension benefits, retirement plan,
stock option purchase plan, profit sharing plan or related matters.
3.5
Except as provided herein, Husband and Wife agree to waive and relinquish any and all right
that he or she may now have or hereafter acquire in any real or tangible personal property
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subsequently acquired by the other party. Husband and Wife specifically agree to waive and
relinquish any right in such property that may arise as a result of the marriage relationship.
3.6
Contemporaneously with the execution of this Agreement, Husband shall transfer to Wife
any and all of Husband' s right, title and interest in and to that parcel of real estate located at 93 Coon
Road, Gardners, Cumberland and Adams County, Pennsylvania and a lot adjoining 93 Coon Road,
Gardners, Cumberland and Adams County, Pennsylvania, heretofore owned by the parties as tenants
by the entireties. Said transfer is subject to those liens and judgments of record as of the date of
conveyance, all of which shall thereafter become the sole and exclusive obligation of Wife, except
that the current Orrstown Home Equity Loan on the property shall become the sole and exclusive
obligation of Husband, and he shall be entitled to claim any mortgage interest deduction for said
payments.
ARTICLE N
RELEASE OF SUPPORT FOR HUSBAND AND WIFE
4.1
The parties herein acknowledge that by this Agreement they have respectively secured and
maintained a substantial and adequate fund with which to provide themselves sufficient resources
to provide for their comfort, maintenance, and support in the station of life in which they are
accustomed. Except as provided herein, Husband and Wife do hereby waive, release and give up
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any rights they may respectively have against the other for alimony pendente lite, spousal support,
or maintenance.
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4.2
Husband and Wife specifically waive, release and give up any rights for alimony that they
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may be entitled to pursuant to Chapter 37 ofthe Pennsylvania Domestic Relations Code.
ARTICLE V
DEBTS OF THE PARTlliS
5.1
Each party represents to the other that except as otherwise specifically set forth herein, there
are no major outstanding obligations of the parties, that since the separation neither party has
contracted for any debts for which the other will be responsible and each party indemnifies and holds
harmless the other for all obligations separately incurred or assumed under this Agreement.
In the event either party contracted for or incurred any debts since the date of separation, the
party who incurred said debt shall be responsible for the payment thereof regardless of the name in
which the account may have been charged. Husband and Wife acknowledge and agree that they have
no outstanding debts or obligations of the Husband and Wife incurred prior to the signing of this
Agreement.
a. Husband shall be solely responsible for the Lowe's credit card in his
name only with an approximate balance of $3,500.00.
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Husband shall be solely responsible for the Home Depot credit card
in his name only with an approximate balance of $360.00.
c. Husband shall be solely responsible for the VISA credit card in his
name only with an approximate balance of $2,800.00.
d. Wife shall be solely responsible for the Bon- Ton credit card in her
name only, which credit card does not have an outstanding balance.
5.2
Each party relinquishes any right, title and interest he or she may have to any and all motor
vehicles currently in the possession of the other party. Within thirty (30) days of the date of
execution of this document, each party shall execute the necessary documents to have said vehicles
property registered in the other party's name with the Pennsylvania Department of Transportation.
a. It is the intention of the parties thatthe 1999 Ford F-350 pickup truck
shall be transferred solely to Husband.
b. It is the intention of the parties that the 1990 Jeep Wrangler shall be
transferred solely to Husband.
c. It is the intention of the parties that the 2001 Dodge Ram pickup truck
shall be transferred solely to Wife. Wife shall assume full responsibility for the loan
on the 2001 Dodge Ram pickup truck and shall indemnify and hold Husband
hannless for any obligations regarding said loan and said vehicle.
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ARTICLE VI
MISCELLANEOUS PROVISIONS
6.1
The provisions of this Agreement and their legal effect have been fully explained to the
parties by their respective counselor the parties have waived their right to have legal advice
regarding the meaning and implication of this Agreement. Husband is represented by Michael J.
Hanft, Esquire, and Wife is proceeding pro se and acknowledges that she has been advised that she
should seek independent counsel and that Michael J. Hanft, Esquire represents Husband in this
divorce and has not provided any legal advice to Wife. The parties acknowledge and accept that this
Agreement is, in the circumstances, fair and equitable, that it is being entered into freely and
voluntarily, after having received such advice and with such knowledge that execution of this 911
Agreement is not the result of any duress or undue influence and that it is not the result of any
collusion or improper or illegal agreement or agreements.
6.2
Husband and Wife do hereby mutually remise, release, quitclaim, and forever discharge the
other and the estate of the other, for all times to come and for all purposes whatsoever, of and from
any and all legal right, title and interest, or claims in or against the property of the other or against
the estate ofthe other, of whatever nature and wheresoever situate, which he or she 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 as byway of dower
or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family
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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 (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, source 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 thereof. It is the intention of Husband and Wife to give to each other by
execution of this Agreement a full, complete, and general release with respect to any and all property
of any kind or nature, real or personal, not 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 thereof.
6.3
Each party represents that they have 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 and hold the other party
hannless from and against any and all such debts, liabilities or obligations of each of them, including
those for necessities, except for the obligations arising out of this Agreement. Husband and Wife
each warrant, covenant, represent and agree that each will, now and at all times hereafter, save
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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 is otherwise specifically provided herein.
6.4
No waiver or modification of any of the terms of this Agreement 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.
6.5
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania which are in effect as of the date of this Agreement.
6.6
This Agreement shall be binding and shall inure to the benefit ofthe parties hereto and their
respective heirs, executors, administrators, successors and assigns.
6.7
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.
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6.8
If any term, condition, clause, section, or provision of this Agreement shall be determined
or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or
provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be
valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his
or her obligation under anyone or more of the articles and sections herein shall in no way void or
alter the remaining obligations of the parties.
6.9
It is specifically understood and agreed that this Agreement constitutes an equitable
distribution of property, both real and personal, which was legally and beneficially acquired by
Husband and Wife, or either of them, during the marriage as contemplated by the Domestic
Relations Code of the Commonwealth of Pennsylvania.
6.10
The parties warrant and represent that they have made full disclosure of all assets prior to the
execution of this Agreement. Each party represents and warrants that he or she has made a full and
fair disclosure to the other of all of his or her personal property interests of any nature, including any
mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property
is subject. Each party furtherrepresents that he or she has made a full and fair disclosure of all debts
and obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
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consideration of Marital Property without the prior consent of the other. Each further warrants,
represents, and declares that each is and has been fully and completely informed of and is familiar
with and is cognizant of the wealth, real and/or personal property, estate and assets, earnings and
income of the other and that each has made a full and complete disclosure tot he other of his and her
entire assets and liabilities and any further enumeration or statement thereof in this Agreement is
specifically waived.
Each party acknowledges that, to the extent desired, he or she has had access to alljoint and
separate State and Federal Tax Returns (including supporting documentation) filed by or on behalf
of either or both Parties during marriage.
6.11
In the event either party to this Agreement shall breach any term, covenant or other obligation
herein, the non-breaching party shall be entitled, in addition to all other remedies available at law
or in equity, to recover from the breaching party all costs which the non-breaching party may incur,
including but not limited to filing fees and attorney's fees, in ant action or proceeding to enforce the
terms of this Agreement.
6.12
This Agreement shall survive any action for divorce and decree of divorce and shall forever
be binding and conclusive on the parties; and any independent action may be brought, either at law
or in equity, to enforce the terms of this Agreement by either Husband or Wife until it shall have
been fully satisfied and performed. The consideration for this Agreement is the mutual benefits to
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be obtained by both of the parties hereto and the covenants and agreements of each of the parties to
the other. The adequacy of the consideration for all agreements herein contained is stipulated,
confessed, and admitted by the parties, and the parties intend to be legally bound hereby.
IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first
above written.
WITNESSED BY:
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RA T. HUNTER, JR.
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JUL A. HUNTER
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F:\User FolderWinn Docs\GendoCl;2001 \2273-1divorce.complaint.wpd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW. c....
NO. 2001- 3;>'; Ctvi( l~
JULIA A. HUNTER,
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 the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from the 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 (20) days of
the date on which you receive this notice. Failure to do so will constitute a waiver of your right to
request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2001-
JULIA A. HUNTER,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this 'Lon/- dayofJune,2001, comesPlaintiff,RAYT. HUNTER, JR., by and
through his attorneys, the Law Office of Michael J. Hanft, and files the following Complaint in
Divorce, and in support thereof avers as follows:
1. The Plaintiff is Ray T. Hunter, Jr., who currently resides at 93 Coon Road, Gardners,
Cumberland County, Pennsylvania 17324.
2. The Defendant is Julia A. Hunter, who currently resides at 93 Coon Road, Gardners,
Cumberland County, Pennsylvania 17324.
3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of
the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding
the filing ofthis Complaint in Divorce.
4. The parties were married on July 19,1976 inMt. Holly Springs, Cumberland County,
Pennsylvania.
5. The marriage is irretrievably broken. The foregoing facts are averred and brought
under Sections 3301(c) of the Divorce Code ofl980, as amended.
6. The Plaintiffhas been advised of the availability of counseling, and that the Plaintiff
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may have the right to request that the Court require the Parties to participate in counseling.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintiff from the Defendant.
Respectfully submitted,
LAW OFFICE OF MICHAEL J. HANFT
Mi~2W
Attorney ill No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, P A 17013-9142
(717) 249-5373
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered by
my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint in Divorce and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
~ .7 $~7
R T. Hunter'
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
CIVIL ACTION - LAW
v.
NO. 2001- 3818 CIVIL TERM
JULIA A. HUNTER,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, JULIA A. HUNTER, the Defendant in the above captioned matter hereby accept service
of the Complaint in Divorce filed in the above captioned matter.
(It/~ O. 1~/?1~~
Juvh A. Hunter I
Dated: 711d & ~ !JOu /
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
NO. 2001-3818 Civil Term
v.
JULIA A. HUNTER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
1.
21,2001.
A Complaint in divorce under Section 330l( c) of the Divorce Code was filed on June
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 of divorce after service of notice of intention
to request entry ofthe 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 of18 Pa. C. S., Section 4904 relating to unsworn
falsification to authorities.
Date:L_ /~ ~V
I' / ,
Sworn to and subscribed before me this
Ny~ day of;::Un'C. ,2002.
N~ 01.~
Notarial Seal
De~ise L. Nye, Notary Public
South Mld~c~n 1\vp.. .Cumberland County
My Commission Expires Feb. 26, 2005
Member. l'&nnsyIvanlaAssocfationofNotaries
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
v.
JULIA A. HUNTER,
Defendant
CIVIL ACTION - LAW
NO. 2001-3818 Civil Term
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER &330HC) 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 ifI 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 rnade in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn
falsification to authorities.
Date: r /(; 2.PQ'l,.-
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
NO. 2001-3818 Civil Term
v.
JULIA A. HUNTER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
1.
21,2001.
A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June
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 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.
Q~ a.tI-~
Julia . Hunter, Defend t
Date: 9u.u J If, 9-DOa.
Sworn to and subscribed before me this
JLf?h day of ;j U ne.... , 2002.
lfMuNJ bf ~
Notary Public
Notarial Seal
Denise L. Ny.. Notary Public
South Middleton Twp.. Cumberland Counly
My Commission Expires Feb. 26. 2005
Member, PennsytvaniaAssoolatiOnolNolaries
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2001-3818 Civil Term
JULIA A. HUNTER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER &330HC) 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. S4904 relating to unsworn
falsification to authorities.
Date: 9Vo.t\( II{ f ;).002...
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I./n,," a. -
Julia . Hunter, Defen ant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
NO. 2001-3818 Civil Term
v.
JULIA A. HUNTER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
1.
21,2001.
A Complaint in divorce under Section 330l( c) ofthe Divorce Code was filed on June
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 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: o-J ?G'
/
/00/
Sworn to and subscribed before me this
aft /Iv day of t!J <>1-0 be r , 2001.
~dtO~
Not ubhc
F:\User Folder\Finn Docs\Gendocs2001 \2273~ I affidavit,consent.wpd
Notarial Seal .
Mary M. Price, Notary Pubhc
Carlisle Bero. Cumberland ~~U~~03
My Commission Expires Aug. .
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RAY T. HUNTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2001-3818 Civil Term
JULIA A. HUNTER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER &330HC) 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. 94904 relating to unsworn
falsification to authoritie$.
Date: OJ 7.6; Z ClO/
7~~
T. Hunter, Plaintiff
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