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Home My WebLink About01-04677< . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Robert W. Sipe, '~~~ .- Plaintiff VERSUS Karen L. Sipe, Defendant N O. 2001-4677 DECREE IN DIVORCE AND NOW, 1~e 101' U ?, ti ~. '! , Z60 IT IS ORDERED AND DECREED THAT Robert W. Sipe PLAINTIFF, AND Karen L. Sipe ,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 SEEN ENTERED; The Property Settlement Agreement between the parties is hereby incorporated, but not merged. BY THE COU PROTHONOTARY o ~o• /~~ ~n ` n ~ ,< PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this>/`~ day of A~~-2001 between Robert W. Sipe of Cumberland County, Pennsylvania, hereinafter referred to as Husband, A N D Karen L. Sipe of Cumberland County, Pennsylvania, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on September 23, 1971 in Harrisburg, Pennsylvania :and R.2: A Complaint for Divorce has been filled in the Court of Common Pleas of Cumberland Gounty, Commonwealth of Pennsylvania;-and R.3: The parties' hereto desire to settle fully and finally their respective financial SAIDIS SIIUF$ FLOWER & LINDSAY ATTORP-.M1'S•AT•LAW ze w. xlgn saeee Grlisle. PA and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente life, NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above- captioned divorce action, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and the moving party shall move for the entry of the divorce decree at that time. If either party fails or refuses to execute and file the foregoing documents or if Husband fails to finalize the divorce within twenty (20) days after the date he makes the monetary payment to Wife aforesaid, said failure or refusal shall be considered a material breach of this Agreement ,and shall entitle the other party at his or her option to terminate this Agreement. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and ,known and numbered as 116 North 27th Street, Camp Hill, Cumberland County, Pennsylvania. Wife agrees within thirty (30) days of the date of shall convey the real estate SAIDIS SHCJF$ FLOWER & LINDSAY Armtu~xs•nr~uw 26 W. High Street Carlisle, PA with improvements thereon erected at 116 North 27th Street, Camp Hill, Pennsylvania to Husband by special warranty deed. Husband shall pay for all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection z with said property. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify Wife from any loss thereon. Husband agrees to take out a home equity loan against the property and to pay the Wife the sum of $40,000.00 cash within ninety (90) days of signing this Agreement. (4) DEBT: A. MARTIAL DEBT; Husband and Wife acknowledge and agree that there are no outstanding debts and obligations which are martial or for which the other might be liable incurred prior to the signing of this Agreement. B: Post Separation Debt: fn the event that either party contracted or incurred any debt since the date of separation on November, 1993, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he SAIDIS SIi[TFF, FLOWER & LINDSAY ATrOR[~Ya•AT•IAW 26 W. High Streel Carlisle, PA or she may have to any and all motor vehicles currently in possession of the other party. Within thirty (30) days of the date of this agreement each party shad execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and 3 shall hold harmless and indemnify the other party from any loss thereon. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like. Wife specifically agrees to waive any and all interest she may have by reason of her marriage to Husband in Robert Sipe Electric. (8) ALIMONY: WAIVER OF ALIMONY: The parties acknowledge that each has income SAIDIS SfiIIFF, FLOWER & LINDSAY nrroic~vs•n~uw 26 W. High Stree[ Carlisle, PA and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. a (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel, Husband is represented by Johnna J. Kopecky, Esquire and, Wife has been advised that she may be represented by counsel of choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after havang received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) BANKRUPTGY: The parties hereby agree that the provisions of this SAIDIS SHIIF$ FLOWER & LINDSAY 26 W. High SVee[ GrHsle, PA P.greement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party tiles such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void acid to terminate this Agreement in which event the division of the parties' martial assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as it this Agreement had never been entered into. s s i (12) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further envmeratior. or statement thereof in this Agreement is specifically waived. (13) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (1A) FULL SETTLEMENT: Except as herein otherwise provided, each party SAIDIS SNUFF, FLOWER & LINDSAY ATIORI~YS•AT•fAW 26 W. High Street Grlisle, PA hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente life, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (15) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and 6 quftclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. F,li rights of curtesy and dower and a!, claims or rights in the nature of curtesy and dower; D. All widow or widowers rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; SAIDIS SIit)F$ FLOWER & LINDSAY ATTORD-!YS•AT~41W 26 W. High Street Carlisle, PA G. A11 rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; ~~ H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (16) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, al! other provisions shall continue in full force and effect. (17) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (18) BREACH: In the event that either party breaches any provision of this SAIDIS SIIUFF, FLOWER & LINDSAY Arroiii~rs.Aruw z6 w. sign so-eet Carlisle, PA Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (19) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, a ,. representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (20) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. • ~..~ Hess Robert W. Sip i Hess K ren L. Sipe SAIDIS SHIIF$ FLOWER & LINDSAY ATipgtffiYSMTHAW 26 W, pigh Street Carlisle, PA I, .. .# .. .. _ _ ` ,. s o r.,},e4tec -~"~ - i 3;aT«3~3[ z l&'2~ .; tE Robert W. Sipe IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-4677 CIVIL TERM Karen L. Sipe CIVIL ACTION - LAW 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: Certified Mail, Restricted Delivery dated August 7, 2001, copy attached hereto as Exhibit "A". 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plantiff: December 18, 2001 By Defendant: February 20, 2002 4. Related claims pending: N o claims raised. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Stree[ Carlisle, PA 5. Date Plaintiff's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary: December 21, 2001. Date: Jo J.~Fopecky, sq. At orney for P aintiff f-. r-- - : ~' `` ` : _: ~- -~., -- il: l~- ~ ~'~ M1 ~ Postage `D Certt0etl Fae .7 fD ~ Retum Receipt Fee (Endorsement Required) p ReatriMetl Delivery Fee O (EndonemeM Raquhed) ~ Total Postage & Fees m ul Sent To r9 l ~ p p M1 atree Apt No.; o a..J'x'/ .C "i 1 city, stew: q ~' f Ctxnplete ifamS'1r 2,"gnEi 3. A16o complete item 4 if Restricted Delivery is desired: ^ Print your narp~jand;address on the reverse so that we cah'iEturn the card to you. ^ Attach this carol to the back of the mailpiece, or on the front ff space parmRS. 1.'Alrticle Addressed to: ~~ p ~17 W ~ t ~~~tl, ~~ ~-~o~~ V. _e IY ~.~ ~. A,-Received6y (Please Print /e J B~~qt-~f livery C. Sign fure - ; ` + /lye ^ a X ~3~~ A lessee D. Is d~e~v' y~ dre dH fin ' eTri'~f des i If X~S,prfter delive ddrass below ~ No 3. 5 fceType ~ertified Maif ,^.(Express Mail ^ Registered (J~Return Receipt for Merchandise ^ Insured Mail ^ G.O.D. py 4. Restricted Delivery? (Extra Fee) _ txQ Yes 2. PS Receipt 102595.00-M-0952 .~e ~ ~ {' _ ~ ~ - "l 11 .~_ ~~~ -_ Z".l '- ~. Lr ~ _b C ~',. c a~i~*m+etem}^,.a~ ~ a,~Fn r .u~osimc ra yarn ~.•x u~+.e _. M. :av,~ru~-s ~saa ~sM~~s~ e ROBERT W. SIPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO.U~'y~~CIVIL TERM KAREN L. SIPE, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE SAIDIS SHUF$ FLOWER & LINDSEY 26 W. High Street Carlisle, PA 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SAIDIS, S F, OWER & LINDSAY Date: man~i 1(0, lop ( By: Jo a J. opecky, Esquire Supreme urt ID # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ROBERT W. SIPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ' Ol-~ft~77 v. NO. CIVIL TERM KAREN L. SIPE, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Robert W. Sipe, who currently resides at 116 North 27th Street, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Karen L. Sipe, who currently resides at 308 Prowell Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 23, 1971 in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of SAIDIS SHLiFF, FLOWER & LINDSEY 2G W. High Street Carlisle, PA marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: j't~"~ By: Joh J. op ck Esquire Supreme C urt ID # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUF$ FLOWER 1 & LINDSEY 26 W. High Street Carlisle, PA 2 ,~ AFFIDAVIT I, Robert w. Sipe, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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: ~~~~ Zp0/ LI/ Robert w. ipe, Plaintiff SAIDIS SHUF$ FLOWER & LINDSEY 26 W. High Sireel Carlisle, PA ., VERIFICATION I verify that the statements made in this Complaint 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: ~~02~ ?,pp/ '^'. Robert W. ipe, Plaintiff SAIDIS sxu~, FI.owEx & LINDSEY 2G W. High Street Carlisle, PA ~~ c=- ,r . ~. ~~ ~ ~ ~ ~ ;- ~s ' ~ < < , ,°? r c~-; ~ ((~~ i ._ ~ ... ~ Yip ~+ ~ ~C. f4 _~,n _~ O \ M _-I a ..L7 4j 'G ~.,,,d _ Q ROBERT W. SIPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. N0. 01-4677 CIVIL TERM KAREN L. SIPE, CIVIL ACTION - LAW Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on . 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: f'°Z y d' ° ~ ,W ~ Robert W. Sipe; Plaintiff SAIDIS SIIUF$ FLOWER & LINDSAY ATI'ORNEYS•AT•LAW 26 W. High Street Carlisle, PA n ~ -- ~~~ ~ -'-„ ~~, n ,~_ ~~ ~ ~'~~ r c,~ -sz ~ -; . - ~~; ~, Q~ i ROBERT W. SIPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4677 CIVIL TERM KAREN L. SIPE, CIVIL ACTION - LAW Defendant IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c~ OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: /~ ~ d/ !~/ Robert W. Sipe, PI intiff SAIDIS SNUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA c> c ~ ._ <, ~~ m " ~ ~ _. „ ~..s i ~ _ I`r". ~Y CJ7 ~' ~ "~:J C? ~~ JZ~ ~~ ~ ~~ ~~ ~~ ~lif ~ . ~i~ ~~ ,.. _ _ .tlm'ryj -~'FLmtYM'T~hV'4prYk~`5~3aM~-'e~iM3F..ratrF`" ~ i ~~ ~V r ) w4Fd ROBERT W. SIPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4677 CIVIL TERM KAREN L. SIPE, CIVIL ACTION - LAW Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on . 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated ~ ~~ ~ ~- ~ ~ ~ ~ Ka en L. Sipe, Defendant SAIDIS SHUF$ FLOWER & LINDSAY 26 W. High Street Carlisle, PA x ..._.... ,__,., ~, .. .. ...,. _., ,_...._,~ ,... ,.- ,..,. ..... _. .,. .. Jai z s ~~02 ROBERT W. SIPE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-4677 CIVIL TERM KAREN L. SIPE, CIVIL ACTION - LAW Defendant IN DIVORCE 1. I consent to the entry of a final Decree of Divorce without notice. SAIDIS SH[JFF; FLOWER & LINDSAY 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. l verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated ~~ ~~ ~ 1 Karen L. Sipe, Defendant 2G W. High Street Carlisle, PA r. ~., v `. „' __ t.: ~ _ r~~~F ,, ~ ~~. ~ ,.. ,,,- ~..:..z