HomeMy WebLinkAbout01-04987r r
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
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VIRGINIA LEE CONNER II
N O. 4987 2001
VERSUS
JOHN WILBUR CONNER
DECREE IN
DIVORCE
AND NOW, ~~~~A.Y/~"G/` ~, 2001 IT IS ORDERED AND
DECREED THAT Virginia Lee Conner , PLAINTIFF,
AND
John Wilbur Conner, III
DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None. All other claims have been resolved pursuant to a Matrimonial
Settlement Agreement dated August 31, 2001.
BY Tt*E COU
ATTEST: ~~ ,J,
PROTHONOTARX
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4987 Civil Term
Civil Action - 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 §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint:
Personal service on August 31, 2001. Acceptance of Service filed
September 7, 2001.
3. Date of execution of the affidavit of consent required by § 3301 (c) of the
Divorce Code: by Plaintiff August 31, 2001; the Defendant
December 2, 2001. Both filed herewith.
4. Related claims pending:
None. All related claims resolved pursuant to Matrimonial
Settlement Agreement, dated August 31, 2001, attached hereto.
5. Date of Plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with
Prothonotary: Filed herewith.
Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: Filed herewith.
Ma < V . mery
Supreme Court I.D. #72787
5115 East 7rindle Road
Mechanicsburg, PA 17050
(717}691-5400
Attorney for Plaintiff
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MATRIMONIAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made thisay of 'GGa-~, , 2001, by and between
Virginia Lee Conner of 916 Bonny Lafie, Mechanicssburg, Cumberland County,
Pennsylvania ("Wife"), and John Wilbur Conner of One South Baltimore Street,
Franklintown, Pennsylvania ("Husband")
Recitals:
A. The parties hereto, being Husband and Wife, were lawfully married
on November 21, 1998.
B. Differences have arisen between Husband and Wife in consequence
of which they have begun to live separate and apart from each other.
C. Husband and Wife acknowledge that they both have consulted their
attorneys and have been advised by their attorneys of all of their rights and duties or have
had the opportunity to consult independent legal counsel and have willfully, knowingly
and voluntarily waived the right to consult an attorney.
NOW, THEREFORE, in consideration of the mutual promises, covenants
and undertaking herein contained, the parties, each INTENDING TO BE LEGALLY
BOUND, agree as follows:
1. Recitals. The Recitals set forth above are incorporated herein by
reference.
2. Divorce. It is specifically understood and agreed by and between the
parties, and each party does hereby warrant and represent to the other that, as defined in
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the Divorce Code, their marriage is irretrievably broken. Wife has filed an action in the
Court of Common Pleas, Cumberland County, Pennsylvania at Docket No. 01-4987. The
parties agree to take all legal steps (including the timely and prompt submission of all
documents and the taking of all actions) necessary to assure that a divorce pursuant to
23 Pa. C.S.A. § 3301 of the Divorce Code is entered as soon as possible. This
Agreement and any ancillary or supplemental agreements shall be incorporated by
reference but not merged into the proposed Divorce Decree presented to the Court.
Husband and Wife shall at all times hereafter have the right to live separate
and apart from each other and to reside from time to time at such place or places as they
shall respectively deem fit, free from any control, restraint or interference whatsoever by
each other. Neither party shall molest the other in any way whatsoever nor 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 or unlawfulness of the causes leading to their living
apart.
3. Marital Property
(a) Personal Property. Husband and Wife acknowledge that they
currently have in their possession all of their separate and
distinct personal property. All other property, marital or non-
marital, currently existing in the residence located at 916
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Bonny Lane, Mechanicsburg, Cumberland County,
Pennsylvania, shall be provided to Wife. Husband hereby
relinquishes all right, title and interest in all other marital and
non-marital personal property located at the marital residence.
(b) Retirement, Pension, 401-K Plan. Husband and Wife hereby
relinquish all right, title and interest in the other's retirement
funds, pension benefits, deferred compensation, or any other
employee benefit.
(c) Real Property. Husband and Wife are joint owners of certain
real property, consisting of 1) the property and
improvements situated thereon, located at 916 Bonny Lane,
Mechanicsburg, Cumberland County, Pennsylvania, and 2)
a time share interest in a condominium unit at Westwood at
Split Rock. Husband hereby relinquishes all right, title and
interest in these properties. Husband agrees to execute all
documents necessary to convey, transfer or encumber the
real property as is reasonably required by Wife including, but
not limited to, deeds, mortgages or agreements of sale.
Wife agrees that she will take all reasonable and necessary
actions to remove Husband from the deed as well as any
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mortgage and/or mortgage note encumbering the real
property. Wife agrees that she is solely responsible for all
mortgage payments, as well as all utilities or other costs or
assessments which arise after the date of this Agreement.
Wife hereby expressly agrees to indemnify, defend and hold
harmless Husband from any and all liability, direct or indirect,
including attorney's fees and costs, which may arise in
connection with their obligation, joint or otherwise, for which
she has agreed hereunder to bear sole responsibility.
4. Debts and Obligations.
(a) Individual debts/obligations. Each party hereby agrees to pay
and hereby agrees to hold the other harmless from any and
all personal debts and obligations incurred by him or her on or
after the date of this Agreement. If any claim, action or
proceeding is hereafter brought seeking to hold the other
party liable on account of any such debts and obligations,
such party will at his or her sole expense defend the other
party against any such claim, action or proceeding, whether or
not well-founded, and indemnify the other patty against any
loss resulting therefrom.
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(b) Joint debts/obligations. Husband and Wife represent that
there are certain debts or other debts incurred by either of
them currently outstanding. The parties agree to allocate and
be responsible for such debts as set forth in Exhibit A
attached and incorporated fully herein.
Each party otherwise hereby expressly agrees to indemnify, defend and
hold harmless the other from any and all liability, direct or indirect, including attorneys'
fees and costs, which may arise in connection with an obligation, joint or otherwise, for
which the party has agreed hereunder to bear sole or partial responsibility, or which the
party has failed to disclose and provide for herein.
5. Legal Fees. Each party agrees that they shall be responsible for
their own legal and other fees incurred by them in connection with this domestic relations
matter unless otherwise specified herein or otherwise agreed to by them.
6. Automobiles. Upon execution hereof, the parties agree that the
Mazda 626 shall become the sole free and clear property of Wife, and that Wife shall
insure and assume all liability therefor except as otherwise set forth herein. Husband
waives any right, title or interest he may have in and to said automobile and shall
promptly execute any title or transfer documents necessary to fulfill this provision, either
herewith or when presented to him.
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Wife agrees to waive any right, title or interest she may have in and to any
automobiles which Husband may own. individually or jointly with Wife, if any, and Wife
shall promptly execute any title or transfer documents if necessary to fulfill this provision.
Each party shall, after execution hereof, maintain their own automobile insurance in their
separate names.
7. Additional Payments. Wife shall pay to Husband the sum of Seven
Hundred and No/100 ($700.00) Dollars as moving expenses. Wife shall make such
payment within 30 days of the date of this Agreement. Wife shall make an additional
payment of Four Thousand and No/100 ($4,000.00) Dollars to Husband as consideration
for the terms and conditions herein. Such payment shall be made at the rate of Fifty and
No/100 ($50.00) Dollars per month, commencing on the first day of the month succeeding
the execution of this Agreement, and continuing on the first day of each successive
month until paid in full. No interest will accrue on the outstanding balance of these
payments.
8. Other Writings. Each of the parties hereto agrees to promptly
execute any and all documents, deeds, waivers, bills of sale, tax returns or other writings
reasonably necessary to carry out the intent of this Agreement.
9. Further Debt.
(a) Wife shall not contract or incur any debt or liability for which
Husband or his property or estate might be responsible and
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shall indemnify and save harmless Husband from any and all
claims or demands, including attorneys' fees and costs, made
against him by reason of debts or obligations incurred by her.
(b) Husband shall not contract or incur any debt or liability for
which Wife or her property or estate might be responsible and
shall indemnify and save harmless Wife from any and all
claims or demands, including attorneys' fees and costs, made
against herby reason of debts or obligations incurred by him.
10. Mutual Release. Except as otherwise provided herein and so long
as this Agreement is not canceled by subsequent agreement, the parties hereby release
and discharge, absolutely and forever, each other from any and all rights, claims and
demands, past, present and future, specifically from the following: alimony pendente liter
alimony; spousal support; division of property; claims or rights of dower and right to live in
the House; right to act as executor or administrator in the other's estate; rights as devisee
or legatee in the Last Will and Testament of the other; any claim or right as beneficiary in
any life insurance policy of the other unless specifically named otherwise or as required
herein; and any claim or right in the distributive share or intestate share of the other
party's estate, all unless specified to the contrary herein or in a subsequent writing signed
by the parties hereto.
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11. Tax Return. Each party shall be solely liable for any tax liability from
2001 forward and each shall indemnify, defend and hold the other harmless from and
against any such liability for tax years commencing in 2001 and thereafter. As to all tax
years prior to 2001, each party represents and warrants to the other that each has
provided true and accurate information concerning all income from all sources, all
deductions and legitimate business expenses and that, to the best of the knowledge of
each, all such tax returns have been true, correct and accurate. In the event the Internal
Revenue Service or any other taxing agency shall examine or audit such returns and
shall determine there was or has been a failure to state income or a disallowance of
claimed deductions, the person who failed to disclose such income or who inaccurately or
incorrectly claimed such deductions shall bear sole responsibility for the payment of any
such additional tax liabilities, penalties, interest or the like which may be thereafter
assessed and shall indemnify and save the other party harmless of and from any and all
claims, demands, suits, actions or causes of action, costs and expenses, {including
reasonable attorney's fees), to which such person or party may become exposed or liable
by reason of such additional taxes, penalties, interest or the like.
12. Medical/Health Insurance. Upon execution hereof, each party shall
be responsible for their own medical/health insurance and the maintenance thereof, if
any.
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13. Entire Aareement. This Agreement constitutes the entire
understanding between the parties, and there are no covenants, conditions,
representations or agreements, oral or written, of any nature whatsoever, other than
those herein contained.
14. Leoallv Bindino. It is the intent of the parties hereto to be legally
bound hereby, and this Agreement shall bind the parties hereto and their respective heirs,
executors, administrators and assigns.
15. Full Disclosure. Each party asserts that she or he has fully and
completely disclosed all the real and personal property of whatsoever nature and
wheresoever located belonging in any way to each of them; of all debts and
encumbrances incurred in any manner whatsoever by each of them; of all sources and
amounts of income received or receivable by each party; and of every other fact relating
in any way to the subject matter of this Agreement. These disclosures are part of the
consideration made by each party for entering into this Agreement. Each party further
represents and warrants that there are no undisclosed debts or obligations for which the
other party may be liable, and each party shall indemnify and hold harmless the other
party from any such liabilities, including attorneys' fees and costs.
16. Costs to Enforce. In the event that either party defaults in the
performance of any duties or obligations required by the terms of this Agreement, and
legal proceedings are commenced to enforce such duty or obligations, the party found to
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be in default shall be liable for all expenses, including reasonable attorneys' fees, incurred
as a result of such proceedings.
17. Aareement Voluntary and Clearly Understood.
Each party to this Agreement acknowledges and declares that he or she respectively:
(a) Is fully and completely informed as to the facts relating to the
subject matter of this Agreement and as to the rights and
liabilities of both parties;
(b) Enters into this Agreement voluntarily after receiving the
advice of independent counsel or, having been advised to
consult independent counsel, has knowingly and voluntarily
chosen to forego such consultation;
(c) Has given careful and mature thought to the making of this
Agreement;
(d) Has carefully read each provision of this Agreement; and
(e) Fully and completely understands each provision of this
Agreement, both as to the subject matter and legal affect.
18. Amendment or Modification. This Agreement may be amended or
modified only by a written instrument signed by both parties.
19. Applicable Law. This Agreement shall be governed, construed and
enforced under the statute and case law of the Commonwealth of Pennsylvania.
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20. Counterparts. This Agreement may be executed in separate
counterparts, each counterpart deemed an original and when combined represents the
legal binding intent of the parties hereto.
21. Severability. If any part of this Agreement is determined to be invalid
by a court of competent jurisdiction, such determination shall not invalidate the entire
document but shall apply only to that phrase, sentence, paragraph or section. The
remainder of the sentence, paragraph, section and Agreement shall continue in full force
and effect.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement
the day and year first above written:
WITNESS: WIFE:
Virgins Lee Conner
WITNESS: HU (', I I;~/(~`~ ~„ /~ I
Joh ilbur Conner
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COMMONWEALTH OF PENNSYLVANIA
SS.:
COUNTY OF CUMBERLAND
On this, the "31'~ day of 2001, a Notary Public, the
undersigned officer, personally appeared Virginia Lee Conner, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument
and acknowledged that she executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Nota Public
My Commission Expires:
(SEAL)
PIOTAAIAI SEAL
ROBY11 A. CFiCNIN, Notary Public
1leahenicsWrp Born, Crimberland County
Come~asan Expires Ser` >3, 2002
COMMONWEALTH OF PENNSYLVANIA
SS.:
COUNTY OF CUMBERLAND
On this, the '~ ~ day of 2001, a Notary Public, the
undersigned officer, personally appeared Joh Wilbur Conner, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument
and acknowledged that he executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~- Nota Public
My Commission Expires:
(SEAL)
fiOT SEAL,,,
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EXHIBIT "A"
Credit Card Obligation
Husband
Wife
Visa 4610-0015-2054-6963 (Approx. balance $4,248.49) MasterCards
MasterCard 5314-2032-2001-2397 (Approx. balance $861.85) Visa
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 6i+~+1-~er+~~ of - k9P7 ~ic~~~,~F/L!~
Civil Action - 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 claim of 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 grounds for the divorce is indignities or irretrievable breakdown of
the marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary at Cumberland County Bar Association, 2
Liberty Avenue, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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
VIRGINIA LEE CONNER, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. ~+:Crm-r2Ril°"°~ l ®I ' '~9fJ l `l (~ ll.~~'R'A'"1
JOHN WILBUR CONNER,111,
Defendant :Civil Action - In Divorce
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN NAMED DEFENDANT:
You have been named as the Defendant in a divorce proceeding filed in the
Court of Common Pleas of Cumberland Coun~+, Pennsylvania. This notice is to advise
you that in accordance with Section 3302(d) of the Divorce Code, as amended, you may
request that the Court require you and your spouse to attend marriage counseling prior to
a Divorce Decree being handed down by the Court. A list of professional marriage
counselors is available at the Office of the Prothonotary, Cumberland County Courthouse,
Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from the list. All necessary arrangements and
the cost of counseling services are to be borne by you and your spouse.
If you desire to pursue wunseling, 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.
VIRGINIA LEE CONNER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. fivit~~rm of -'Sr9P7 ~iu~~ lFitr~
JOHN WILBUR CONNER, III,
Defendant :Civil Action - In Divorce
COMPLAINT
COUNT I -Divorce 23 Pa. C.S.A. §3301(c)
1. Plaintiff Virginia Lee Conner, is an adult individual residing at 916 Bonny
Lane, Mechanicsburg, Pennsylvania 17055.
2. Defendant John Wilbur Conner, III, 916 Bonny Lane, Mechanicsburg,
Pennsylvania 17055.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6)
months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on November 21, 1998 in Pulaski
County, Arkansas.
5. Plaintiff avers that the ground upon which this action is based is that the
marriage is irretrievably broken.
6. There have been no prior actions of divorce between the parties in this
or any otherjurisdiction.
7. The Defendant is not a member of the Armed Services of the United
States of America.
8. The marriage is irretrievably broken.
9. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the court require the parties to participate in
counseling.
10. Plaintiff avers that there are no children born of this marriage.
WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree
of Divorce.
Respectfully submitted,
FENSTERMACHER AND ASSOCIATES, P.C.
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Mark K. mery
Supreme Court I.D. #72787
5115 East Trindle Road
Mechanicsburg, PA 17050
(717)691-5400
Attorney for Plaintiff
DATED: August 23, 2001
2
VERIFICATION
I, Virginia Lee Conner, have read the foregoing Complaint and hereby
certify that the facts set forth are true and correct to the best of my knowledge,
information and belief. This statement is made subject to the penalties of 18 Pa. Const.
Stat. Ann. §4904 relating to unsworn falsification to authorities.
DATED: ~' ~ 3 "~ ~
By:
Vi inia Lee Conner
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4987 Civi{ Term
Civil Action - In Divorce
ACCEPTANCE OF SERVICE
I, John Wilbur Conner, III, Defendant in the above-captioned matter, hereby
accept service of the Complaint in Divorce in full satisfaction of the Pennsylvania Rules
of Civil Procedure.
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ohn Wilbur Conner, III
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4987 Civil Term
Civil Action - In Divorce
PLAINTIFFaS AFFI®AVIT OF CONSENT AN®
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code
was filed on August 24, 2001.
2. The marriage of the Plaintiff and Defendbnt is irretrievably broken,
and ninety (90) days have elapsed from the date of both the 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.
4. I have been advised of the availability of marriage counseling, and
understand that I may request that the Court require that my spouse and I participate in
counseling. I further understand that the Court maintains a list of marriage counselors
in the Prothonotary's Office, which list is available to me upon request. Being so
advised, I do not request that the Court require that my spouse and I participate in
counseling prior to a divorce decree being handed down by the Court.
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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.A. Section 4904, relating to unsworn falsification to authorities.
DATE: J ~'~2/ p 1,
rginia Lee Conner
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4987 Civil Term
Civil Action - In Divorce
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is
entered by the Court and that a copy of the Decree will be sent to me immediately after
it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S,A. Section 4904, relating to unsworn falsification to authorities.
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Virginia .Conner
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4987 Civil Term
Civil Action - In Divorce
DEFENDANT'S AFFIDAVIT OF CONSENT AND
V1i'AIVER OF COt~NSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code
was filed on August 24, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken,
and ninety (90) days have elapsed from the date of both the 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.
4. I have been advised of the availability of marriage counseling, and
understand that I may request that the Court require that my spouse and I participate in
counseling. I further understand that the Court maintains a list of marriage counselors
in the Prothonotary's Office, which list is available to me upon request. Being so
advised, I do not request that the Court require that my spouse and I participate in
counseling prior to a divorce decree being handed down by the Court.
_~ ~ '1 .~ • i ~.
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.A. Section 4904, relating to unsworn falsification to authoroties.
DATE: '~~~~~' ~ - U"~t~'
~ilbur Conner, III
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VIRGINIA LEE CONNER,
Plaintiff
v.
JOHN WILBUR CONNER, III,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4987 Civil Term
Civil Action - In Divorce
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is
entered by the Court and that a copy of the Decree will be sent to me immediately after
it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
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Joh Wilbur Conner. III
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CERTIFICATE OF SERVICE
AND NOW, on this 3rd day of December, 2001, I, Mark K. Emery, Esquire,
hereby certify that I have served the foregoing Praecipe to Transmit Record by mailing a
true and correct copy by United States first class mail, addressed as follows:
John Wilbur Conner, III
P.O. Box 78
Franklintown, PA 17323-0078
FENSTERMACHER AND ASSOCIATES, P.C.
By:
ar .Emery
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Virginia Lee Conner
Plaintiff
Vs
File No. 01-4987
IN DIVORCE
John Wilbur Conner III
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /defendant in the above matter,
[select one liy marking "x"]
prior to the entry of a Final Decree in Divorce,
or x after the entry of a Final Decree in Divorce dated December 11, 2001
hereby elects to resutne the prior surname of
and gives this
written notice avowing his /her intention pursu o the provisions~pf 54 P. .704.
Date: April, 28, 2004~.('~S"L~ (.~/~~
Signature
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Si tore of name being resumed
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland )
On the 28thiay of April , 200!+, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he /she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal. /M , ~~/
COMMONWEALTH OF PENNS VANIA Notary Public
Notarial Seat
Heidi M. Nelson. Notary Public
Medranicalwrg acrd, Cumbedand County
My Cammissipr Fires June 27, ZOW
n~rr~xr, aemreyweme A~aason or r
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