HomeMy WebLinkAbout01-04541IN THE COURT OF COMMON PLEAS
PLAINTIFF
VERSUS
JEFFREY M. ARCHER __
IV O. n1=~5A1 GTyTT.
DECREE IN
DIVORCE ~ (~~ t~
.•
AND NOW, ~ ,~ ~ IT IS ORDERED AND ~
DECREED THAT SUZANNE K. ARCHER ,PLAINTIFF,
AND JEFFREY M. ARCHER ,DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF 7HE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; NONE
THE SEPARATION AND PROPERTY SETTLEMENT AGREEMENT DATED
OCTOBER 11, 2001 IS INCORPORATED BY REFERENCE.
IN THE COURT OF COMMON PLEAS
Q\a.~~.~ CUMBERLAND COUNTY, PENNSYLVANIA
VS.
Je.F~c-e~ ~ ~r,~f CIVIL DIVISION
Cle~r.~.oc.~. NO. O\-yS~\ CIVIL TERM
PRAECIPETOTRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
Ground for divorce:
Irretrievable breakdown under§3301 (c)
3301(d)(1) of the Divorce Code.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: Us.,~ S~~s C`~w\ ~ Cefac.~:e~ ~`\a,.\-
~buc-cam ~?..~~~sLr~c~c~ ~e~...wc+a 2oc~.c~2 ~:re .. ~.
3.
Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code:
by plaintiff N~~~NJd,r ~ race ~ by defendant 4.lo~ca.~oe~ ~g boo ~
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4.
5.
Related claims pending:
Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which is attached:
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: tQov¢~~e~ ~\, 2-oa\
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: iyo~-~tr~ a~~ ai~o~
lu..c ~~
Attorney f r Plaintiff Defendant
T ~
SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
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THIS AGREEMENT, made this ~ day of October 2001, by and
between Suzanne K. Archer of Carlisle, Cumberland County,
Pennsylvania, a party of the first part, hereinafter referred to
as "Wife" and Jeffrey M. Archer of Carlisle, Cumberland County,
Pennsylvania, party of the second part, hereinafter referred to
as "Husband"
WITNESSETH:
WHEREAS, husband and wife were married on July 16, 1999 in
Carlisle, Cumberland County, Pennsylvania; and
WHEREAS, husband and wife have been living separate and
apart from each other since July 3, 2001;
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
continuing to 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;
~ i
WHEREAS, it is the intention and purpose of this 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 their mutual differences, after both have had full
and ample 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 of the
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 cohabitate or dwell
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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
DIVORCE
2.1
This Agreement is not predicated on divorce. It is
specifically understood and agreed by and between the parties
hereto and to each of the said parties does hereby warrant and
represent to the other 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
nonprosecution or non-defense of any action for divorce;
provided, however, that nothing contained in this Agreement shall
prevent or preclude either of the 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
actin 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
,:~
l 1
hereby waive any and all possible claims of 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 or 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 of this Agreement relating to the equitable
distribution of property of the parties are accepted by each
party as a final settlement of 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 any way by and such separation or
divorce; and that nothing in any such decree, judgment, order or
further modification or revision thereof shall alter, amend or
vary any term of this 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.
i ~
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 of the 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 4541 Civil 2001. 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 III
EQUITABLE 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 of the Pennsylvania Domestic Relations Code, and taking into
account the following considerations: the length of the
marriage, the prior marriages of the 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 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.
a. The parties hereby agree that any transfers of property
pursuant to the terms of this Agreement shall be within the scope
of the Deficit Reduction Act of 1984, or other similar tax acts
(hereinafter "Act"). The parties agree to sign and cause to be
filed any elections or other documents required by the Internal
Revenue Service to render the Act applicable to the transfers set
forth in this Agreement, without recognition of gain on such
transfers and subject to the carry-over basis provisions of said
Act.
3.3
The parties shall retain sole and exclusive right, title and
possession of all personal property currently in their possession
and/or personal property that was obtained by way of gift from
each party's family (i.e. wife has sole and exclusive right,
title and possessions of all personal property obtained from
wife's family, including but not limited to parents and
grandparents; husband has sole and exclusive right, title and
possessigns of all personal property obtained from husband's
family including but not limited to parents and grandparents).
Except as provided for herein, Husband shall make no claim
whatsoever for any personal property in wife's possession and/or
personal property that was obtained by way of gift or inheritance
from her family. Additionally, except as provided for herein,
Wife shall make no claim whatsoever for any personal property in
Husband's possession and/or personal property that was obtained
by way of gift or inheritance from his family. 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.
3.4
Except as provided herein, Husband waives any right or
interest he may have in the marital residence located at 556 West
Penn Street, Carlisle, Cumberland County, Pennsylvania. Due to
the short period of time in which the residence was the marital
residence; November 21, 2000 through July 3, 2001, there is no
marital equity in the residence. Both parties agree that the
appraised value of the property, as appraised for the purchase on
November 21, 2000, is $94,600, that Wife received $20,000 as a
gift from her parents upon the purchase of the property from
Wife's parents, thereby leaving a value of $74,600 as marital
property and an accompanying mortgage of approximately $76,000.
Husband agrees to execute a deed within 60 days of the date of
this agreement, deeding the house to Wife solely.
3.5
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 or the request of the other
party, each party shall execute the necessary documents to have
said vehicles properly registered in the other party's name with
the Pennsylvania Department of Transportation or the proper
authority within the state in which the party resides. It is the
intention of the parties that the 1996 Jeep Cherokee Country,
with a blue book value of approximately $12,365, shall be
transferred solely to Husband. It is the intention of the
parties that the 1997 Mazda 626 remain solely in Wife's name on
the basis this vehicle was not marital property as it was
obtained free and clear of all debts before the marriage. Except
as provided herein, Wife waives any right or interest she may
have in the 1996 Jeep Cherokee. Both Husband and Wife agree that
there are no existing debts on the 1996 Jeep Cherokee.
Furthermore, it is agreed by both Parties that Husband
waives any right or interest he may have in the household pets.
Wife agrees to waive her rights and interest in the home theater
system, the DVD player, the personal laptop computer, and the
:#.
livingroom loveseat, chair and end tables (originally a gift to
Wife from her parents). All property listed above, with the
exception of the living room couch and chair, was property
obtained during the marriage.' Additionally, both parties agree
that the balance of the savings account was $8,000, from which
Wife has paid $2,500 to Husband and Husband waives any right or
interest he may have in the remaining balance of $5,500.
3.6
Husband and Wife agree to waive and relinquish any right
that he or she may now have or hereafter acquire in any deferred
compensation, pension, profit-sharing, individual retirement plan
(IRA) or other retirement plan of the other party.
3.7
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 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.
ARTICLE IV
RELEASE OF SUPPORT FOR HUSBAND AND WIFE
4.1
The parties herein acknowledge that by this Agreement they
have respectively secured and maintained an 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. Husband and Wife do hereby waive,
release and give up any rights they may respectively have against
the other for alimony, support, or maintenance.
4.2
Husband and Wife specifically waive, release and give up any
rights for alimony that they may be entitled to pursuant to
Chapter 37 of the Pennsylvania Domestic Relations Code.
ARTICLE V
DEBTS OF THE PARTIES
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 except for the following:
A. There exists a first mortgage on the marital residence,
which obligation is to be that solely of Wifes. During the next
twelve months, Wife is to make all reasonable efforts to obtain
refinancing; thereby removing Husband's name from such
obligations.
B. There exists various credit cards, which may or may not
have outstanding obligations. These cards are either solely in
the name of the Wife or Husband. There are no cards existing
that are jointly owned by Wife and Husband. Each Party will
retain the credit card(s) in each of their names and make any
monthly payments as they become due.
Husband and Wife acknowledge that all other joint
miscellaneous utility bills associated with the marital
residence, except those itemized above, if any, are the sole
responsibility of Wife and Wife agrees to make all reasonable
efforts to remove Husband's name from all such bills.
ARTICLE VI
MISCELLANEOUS PROVISIONS
6.1
The parties hereto have retained independent legal counsel.
The provisions of this Agreement and their legal effect have been
fully explained to the parties by their respective counsel or the
parties have waived their right to have legal advice regarding
the meaning and implication of this Agreement. 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 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 of
the 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 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 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 since separation, 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 harmless 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
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 execution of this Agreement.
6.6
This Agreement shall be binding and shall inure to the
benefit of the 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.
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 any one 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.
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 entitles, 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
any 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, wither 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 be obtained by both of the parties hereto and
the covenants and agreements of each of the parties to the other.
IN WITNESS WHEREOF, the said parties of this Agreement have
hereunto set their hands and seals, intending to be bound legally
hereby, the day and year first above written.
Signed, sealed and delivered
in the presence of:
WITNESS:
WITNESS:
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~7~ E K. C ER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUZANNE K. ARCHER,
Plaintiff
vs.
JEFFREY M. ARCHER,
Defendant
CIVIL ACTION--LAW
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 in the
Office of the Prothonotary, Cumberland County Courthouse,
Carlisle, Pennsylvania.
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.
Court Administrator
Cumberland County Courthouse
3 South Hanover St.
Carlisle, PA 17013
(717) 240-6200
t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUZANNE K. ARCHER, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
NO.
JEFFREY M. ARCHER,
Defendant
COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d)
OF THE DOMESTIC RELATIONS CODE
AND NOW, comes Plaintiff, SUZANNE K. ARCHER, and files the
following Complaint in Divorce, and in support thereof avers as
follows:
1. Plaintiff is Suzanne K. Archer, an adult individual, who
currently resides at 556 W. Penn Street, Carlisle, Cumberland
County, Pennsylvania 17013 since July 16, 1999.
2. Defendant is Jeffrey M. Archer, an adult individual, who
currently resides at 503 B Street, Carlisle, Cumberland County,
Pennsylvania, 17013 since July 7, 2001.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six (6) months
immediately preceding the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 16, 1999
in Carlisle, PA 17013.
~~,
~~
5. The Plaintiff and Defendant were separated on or about
July 7, 2001.
6. There have been no prior actions of divorce or for annulment
between the parties.
7. The Plaintiff and Defendant are not members of the armed
forces of the United States or any of its allies.
8. The Plaintiff avers that the marriage is irretrievably
broken.
9. Plaintiff has been advised of the availability of counseling
and that the Plaintiff may have the right to request that the
Court require the parties to participate in counseling. The
Plaintiff does not desire counseling.
10. Plaintiff requests the Court to enter a decree of divorce.
Dated: ~ (~~
L
~UZAINNE K, AHER
SS West Pen St.
arlisle, PA 17013
(717) 240-0587
Plaintiff
SUZANNE K. ARCHER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
JEFFREY M. ARCHER,
Defendant
CIVIL ACTION--LAW
IN DIVORCE
NO.
VERIFICATION
I verify that the statements made in the foregoing Complaint
in Divorce are true and correct to the best of my knowledge,
information and belief. This Verification is made only as to the
factual averments contained herein, and not to legal conclusions
and averments authorized by counsel in her capacity as attorney
for the party or parties hereto. 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.
l ~CG~
S Z E K . AR`~
_~.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SU~ANNE K. ARCHER, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
N0. 01-4541 Civil
JEFFREY M. ARCHER,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301 (c) of the
Divorce Code was filed on July 27, 2001.
2. The marriage of the Plaintiff and Defendant is
irretrievably broken and more than ninety (90) days have elapsed
from the date of filing the Complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
5. I understand that the costs of these proceedings will be
paid for by Plaintiff.
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 : (~~
S E K. CHER
~ 4 t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUZANNE K. ARCHER, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
NO. 01-4541 Civil
JEFFREY M. ARCHER,
Defendant
AFFIDAVIT OF CONSENT
1.. A Complaint in Divorce under section 3301 (c) of the
Divorce Code was filed on July 27, 2001.
2. The marriage of the Plaintiff and Defendant is
irretrievably broken and more than ninety (90) days have elapsed
from the date of filing the Complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
5. I understand that the costs of these proceedings will be
paid for by Plaintiff.
I verify that the statements made in this affidavit are true and
correct. T 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:
JEF R M. CHER
~~. ..
IN THE COURT OF COMMON. PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUZANNE K. ARCHER, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
NO. 01-4541 Civil
JEFFREY M. ARCHER,
Defendant
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 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. Sectin 4904 relating to
unsworn falsification to authorities.
Date: /~~I"Q~ i,L.!
NE K. A HER
i w 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUZANNE K. ARCHER, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
NO. 01-4541 Civil
JEFFREY M. ARCHER,
Defendant
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 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 relaying to
unsworn falsification to authorities.
Date: ~g ~~'~
ARCHER
.~
.,.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SUZANNE K. ARCHER, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
N0. 01-4541 Civil
JEFFREY M. ARCHER,
Defendant
CERTIFICATE OF SERVICE
AND NOW, this 28th day of July 2001, I, Suzanne K. Archer,
Plaintiff, hereby certify that I have this day served the
following person with a copy of the foregoing Complaint, by
depositing same in the United States Mail, Certified Mail--Return
Receipt Requested, Restricted Delivery, Postage Prepaid,
addressed as follows:
Jeffrey M. Archer
503 B Street
Carlisle, PA 17013
~~~
SYzz~hne K. A,~cher
556 West Penn St.
Carlisle, PA 17013
(717) 240-0587
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