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HomeMy WebLinkAbout01-05381IN THE COURT OF COMMON PLEAS ROBERT VERSUS THERESA A. CHRISTOPHER N O. 01-5381 DECREE IN DIVORCE ////^~~~~ 'M~ c~'a~ 3ot ~? AND NOW, /~ , ~, IT IS ORDERED AND DECREED THAT ROBERT PLAINTIFF, AND THERESA A. CHRISTOPHER DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDfCTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The Marital Settlement Agreement between the parties dated December 19, 2001 is incorporated but not. merged he BY TH ATTEST: J. PROTHONOTARY (~ &w MA~tITAG S~TTL~MENT AGI~~~i~tEN"I' THIS AGREEMENT, made this ~j" day of t'ryrCr,~fx.1 , 2001, by and between Robert A. Doren (hereinafter "Husband") of Hampden Township, Cumberland County, Pennsylvania, and Theresa A. Christopher(hereinafter "Wife") of Lewisberry, York County, Pennsylvania. WITNESSETH: WHEREAS, the parties aze Husband and Wife, married on October 12, 1996, in Dauphin, Dauphin County, Pennsylvania; and WHEREAS, no children were born of the marriage; and WHEREAS, unhappy differences and difficulties have arisen between the parties, in consequence of which the parties intend to live separate and apart For the rest of their natural lives; and WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including but not limited to the ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance; and any and all claims which either party has, or may have, against the other or the other's estate; NOW, TFIEREFORE, in considerationofthe mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as follows: Documen[i120~958 Each party shall have the right to live separate and apart from the other party, free from the other party's interference, authority and control. Neither party shall interfere with the other or attempt to interfere with the other, nor compel the parties' cohabitation. 2. HUSI3AND'SANDWIFE'SDEBTS Except as otherwise set forth in this Agreement, the parties represent and warrant to each other that they have not incurred and will not contract or incur any debt or liability for which the other or the other's estate might be responsible. Each party shall indemnify and save harmless the other party from any and all claims or demands made against the other by reason of debts or obligations incurred by that party. 3. WAIVER OF RIGHTS AND MUTUAL RELEASES Except as provided in this Agreement, both parties absolutely and unconditionally release and forever discharge each other and their heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship, whether such claims exist now or arise in the future. This release shall be effective regardless of whether such claims arise out of former or future acts, contracts, engagements or liabilities of the parties or by way of dower, curtesy, widow'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 Pennsylvania, any state, commonwealth or territory of the United States, or other country. -~- Documen[ #205918 Except for any cause of action for divorce which either party may have ar claim to have, and except for the obligations of the parties contained in this Agreement, each party gives to the other an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other, including but not limited to alimony, alimony pendente life, spousal support, equitable distribution of marital property, counsel fees or expenses. 4. REAL ESTATE The parties own as teriants by the entireties the improved real property situate at 4833 Charles Road, Mechanicsburg, Pennsylvania, 17050. Said property was purchased and owned by both Husband and Wife prior to the marriage of the parties. Li consideration of the mutual promises of the parties, it is agreed as follows: (a) Contemporaneouswith the signing of this Marital Settlement Agreement, Wife shall execute a deed conveying to Husband all of her right, title, and interest, if any, in the mazital residence, free and clear of all encumbrances. (b) Husband shall pay for preparing and recording the new deed. Husband is the sole owner of real property located at Mountain Road, Middle Paxton Township, bauphin County, Pennsylvania. Contemporaneous with the signing of this Agreement, Wife shall execute a deed conveying to Husband all of her right, title, and interest in said property, if auy, free and clear of all encumbrances. Husband shall pay for preparing and recording the new deed. Wife is the sole owner of a property located at 906 Schoo}house Lane, Lewisberry, York County, Pennsylvania, which Wife purchased during the marriage. Contemporaneous with the -3- Document N20~9i8 signing of this Marital Settlement Agreement, Husband shall execute a deed conveying to Wife all of his right, title, and interest in said property, if any, free and clear of all encumbrances. I-Iusband will pay for preparing and recording the new deed. Furthermore, Wife agrees to assume sole responsibility for the payment of the mortgage on said property and Wife agrees to indemnify Husband for her failure to carry out said obligation. 5. DIVISIONOF PERSONAL PROPERTX The parties have divided all items of personal property, except as otherwise specified herein, to their mutual satisfaction. All personal property currently in Husband's possession shall be the sole and separate property of Husband. All personal property currently in Wife's possession shall be the sole and separate property of Wife. 6. MOTOR VEHICLES I-Iusband shall retain sole and exclusive ownership of the Chrysler Jeep and Ford Escort automobile in his possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. Wife shall retain sole and exclusive ownership of the Ford van and Saturn automobile in her possession and agrees to assume sole responsibility for all outstanding encumbrances, if any, including the loan from Fulton Bank. Both parties agree to execute, within thirty (30) days of the date this Agreement is signed by both parties, any and all forms, titles and documents necessary to transfer the aforesaid vehicles from joint ownership to individual ownership, as specified herein. -4- Document #20i9i8 7, :19iNT I~EI~T Except as otherwise stated in this Agreement, the parties acknowledge that they have no debts which were jointly incurred during their marriage. Any debts or obligations incurred by either party in his/her individual name, ocher than those specified herein, whether incurred before or after separation, are the sole responsibility of the party in whose name the debt or obligation was incurred. 8. RETIREMENTBENEFITS Husband owns or is a participant in the following pension/retirementJprofitsharingpians: Commonwealth of Pennsylvania State Employees' Retirement System Employee #: 047711 Commonwealthof Pennsylvania Account #: 01111142 (deferred compensation program) Wife owns or is a participant in the following pension/ retirement/profitsharing plans: Commonwealth of Pennsylvania Employee #: 104607 State Employees' Retirement System Commonwealthof Pennsylvania Account #: 011 11142 (deferred compensationprogram) Each of the parties does speciftcally waive, release, renounce and forever abandon all of their right, tiCle, interest or claim, whatever it may be, in any pension/retirement/profitsharing plan of the other party, whether acquired through said other party's employment or otherwise, and hereafter the pensionlretirement!profil sharing plan identified above as being either husband's or wife's shall become the sole and separate property. of the party in whose name or whose employment said plan is carried. -5- Document H?05958 9. DIVISION OF BANK ACCOUNTS Husband and Wife acknowledge that all joint bank accounts have been closed or divided to their mutual satisfactionprior to the execution of this Agreement. 10. INVESTMENTS Husband shall retain sole and exclusive ownership of the following investment accounts: Name PSECU Ameritrade Scudder Aggressive Growth Fund Scudder Blue Chip Fund Account No. 179567194 178-316873 73-133325094-0 31-1333325094-0 Wife shall retain sole and exclusive ownership of the following investment accounts: Name Account No. PSECU 206509668 Each party hereby agrees to completely relinquish and waive any and all interest they may have in the investment accounts of the other. Bath parties agree to execute, within thirty (30) days of the date this Agreement is signed by both parties, any and all forms, titles and documents necessary to transfer the aforesaid property from joint ownership to individual ownership, as specified herein. 11. PAYMENT TO WIFE In consideration for the promises and undertakings set forth herein, Husband has paid to Wife the sum of $55,000.00, the receipt of which swn is acknowledged by Wife. -6- Document x205958 1"?~ AFTER~ACOI.IIRERPRQPERTY Each of the parties shall own and enjoy, independently of any claims or rights of the.other, all real property and all items of personal property, tangible or intangible, hereafter acquired, with fiill power to dispose of the 'same as fully and effectively as though he or she were unmarried. Any property so acquired shall be owned solely by that party and the other party shat l have no claim to that property. 13. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony oendente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this Agreement shall not constitute alimony but is made as part of the parties' equitable distribution settlement. 14. TAX MATTERS The parties have negotiated this Agreement with the understanding and intention to divide their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of section 1041 of the Internal Revenue Code, and as such will hot result in the recognition of any gain or loss upon the transfer by the transferor. 15. COUNSEL FEES AND EXPENSES Except as otherwise specified herein, each party shall be responsible for payment of his/her own counsel fees and expenses. -7- Ducumenc g20i9i8 1 b. A1~VICE (?F COIINSEL The parties acknowledge that each has received or has had the opportunity to receive independent legal advice from counsel of their selection and that they have been informed fitlly as to their legal rights and obligations, including al4 rights available to them under the PennsylvaniaDivorceCode of 1980 as amended, and other applicable laws. Each party confirms that he/she understands fully the terms, conditions, and provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the existing circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement. 17. AFFIDAVITS OF CONSENT Each party agrees to execute an Affidavit of Consent for the obtaining a no-fault divorce under the provisions of the Divorce Code of 1980, as amended. 18. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in section 3105(a) of the Divorce Code, as amended. As provided in section 3105(c), provisions of this Agreement regarding, equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modificationby the courC. 19. DATE OF EXECUTION The "date of execution", "date of this agreement" or "execution date" of this Agreement is the date upon which it is signed by the parties if they sign the Agreement on the same date. -8- Documcnl p265958 R11~~Iwi~~, It~~ "€1~I~ of ~xeetGli~n" , "~1Ie sf Ilti~ ~~r®em~nl" ~r "~~~eulitm tlut~" Tall ~a~ tkta~ ~1ttt~ ~n which the last party signed this Agreement. 20. HEADINGS NOT PART OF AGREEMENT The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction or effect of this Agreement. 21. SEVERABILITYANDINDEPENDENTANDSEPARATECOVENANTS Each separate obligation shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause 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. 22. AGREEMENT BINDING ON HEIRS This Agreement shall be binding on and shall enure to the benefit of the parties and their respective heirs, executors, administrators, successors, and assigns. 23. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations, warranties, covenants or promises other than those expressly set forth in this Agreement. 24. MODIFTCATIONOR WAIVER TO BE IN WRITING No modification or waiver of any term of this Agreement shall be valid unless in writing and signed by bath parties. -9- Document #20598 26. NO WAIVER OF DEFAULT The failure of either party to insist upon strict performance of any term of this Agreement shall in no way affect the right of such party hereafter to enforce the term. 26. VOLUNTARY EXECUTION The parties acknowledge that this Agreement is fair and equitable, and that they have reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or improper or illegal agreements. 27. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980, as amended. 28. ATTORNEYS' FEES FOR ENFORCEMENT If either party breaches ariy provision of this Agreement, the breaching party shall pay all reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the enforcing party is successfid in establishing that a breach has occurred. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year ftrst written above. WITNESS: ~~~' ~ ~~ Robert A. Doregn Theresa A. Christopher -10- Document #20>9~8 ..w""` "_~""~'~ivtMnNW['ALTH~F~PENNSYL ~.~. VANiA: ! ss COUNTY OF r_ ~,i.n.;t~:;,'~>~;;:~ , On this the ~ day of 1~ ~?~ nt~ ~ ; >~ , 2001, before me, the undersigned officer, personally appeared Robert A. Doren known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and o f ial seal. ~- -~ ~~ . COMMONWEALTH OF PENNSYLVANIA: l~~p~~is~~o~ Expires Iniul:~~l.II, ctillarlc!, Noi:;iy N,;a~!~; ; C;:mplliilBuio. Curntfadauu CGN~fy j h1/ Comm!sslon Expires .i~.eG~; t 5, !~u~ ~; ; + ss COUNTY OF (~~c nr.c3 t,~s.~v,7 .~` On this, the ~ day of i~li<>rr~~ , 2001, ,before me, the undersigned officer, personally appeared Theresa A. Christopher known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that she executed the same for the purposes therein contained. [N WITNESS WHEREOF, I hereunto set my hand and o ial seal. ~.~ - >~- ~, My CommissianExpir~~; 1`1111€ttll~ilut:;+i 3it;il:,i.1 i} t:€ia~1!Ci, iu~,;tyi'fiiFltc :r,~.thl!i~,s,~. %uss~Wit7i:n1 f'uuuly Donimen[g2059i8 _c_ ~ a .~ ~ r ~ cn r• , - -" -`~ w CC i «-; ~ t~(i ~~ «c~ ~~ . r. ~r:~ c ~ ~ yy L1 ~ , : S ~) % - C _ ~ , 7 J ~' ,_ ROBERT A DOREN, Plaintiff v. THERESA A. CHRISTOPHER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5381 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSNIIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: A Complaint in Divorce was filed on September 14, 2001, and served on Defendant on September 21, 2001 via certified mail, return receipt requested. Affidavit of Service has been filed. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: Plaintiff- Apri13, 2002 Defendant - Apri13, 2002 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: n/a (2) Date of service of the plaintiff s affidauit upon the defendant: n/a 4. Complete the appropriate paragraphs: Document #: 225272.1 ~ 3 (a) Related claims pending: none (b) Claims withdrawn: none (c) Claims settled by agreement of the parties: N/A (d) State whether any written agreement is to be incorporated into the Divorce Decree. Marital Settlement Agreement dated December 19, 2001. 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code: n/a (b) Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: Apri13, 2002 Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: April 3, 2002 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date arl R. Hildabrand, Esquire I.D. No. 30102 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 201020.7 .. ys ROBERT A DOREN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. O 1-5381 THERESA A. CHRISTOPHER, Defendant. CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this ~ day of April, 2002 I, Karl R. Hildebrand, Esquire, of Metzger, Wickersham, Knauss & Erb, attorneys for Plaintiff, Robert A. Doren, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Theresa A. Christopher 906 Schoolhouse Lane Lewisbeny, PA 17339 METZG WICI' RSHAM, KNAUSS & ERB, P.C. arl R. Hildabrand Document N: 225272.1 ~%5~5txu:fJ63s5'xi~"'~~-^~ Fr«raz:.c+~~se»aamm~s31~ ~ - - - ~ ~. 1 c7 C= ca E V ~- =~ c "(t l';° ~ y U3 ~: i ` : ~-a C" ~ r: ,c 5 . ~' C1 ~ , '~}~! ~ ~'~ ~ ~.v En .~ _ _ I r .~ ROBERT A. DOREN, v. Plaintiff THERESA A. CHRISTOPHER, Defendant TO: Theresa A. Christopher, Defendant 906 SchoolhouseLane Lewisberry,PA 17339 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. dl - SaF` CIVIL ACTION- LAW IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEE5 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 (800)990-9108 Document#205968 _, ... ROBERT A. DOREN, Plaintiff u. THERESA A. CHRISTOPHER, Defendant .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. pl -S`3~( L:lv~l. ` CIVIL ACTION- LAW IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Robert A. Doren, an adult individual currently residing at 4833 Charles Road, Mechanicsburg, Cumberland County, Pennsylvania, since 1994. 2. The Defendant is Theresa A. Christopher, an adult individual who currently resides at 906 Schoolhouse Lane, Lewisberry, York County, Pennsylvania,17339, since October of 2000. 3. The Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediatelyprior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 12, 1996, in Dauphin, Dauphin County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. No children were born of the marriage. 9. The marriage is uretrievablybroken. Document #205968 .. ~ 10. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render Plaintiff s condition intolerable and life burdensome. 11. During the marriage the parties acquired marital property and assets which Plaintiff requests the Court equitably distribute and assign. 12. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. WHEIlZEFORE, Plaintiff requests that this Court enter a Decree in Divorce, and enter an Order equitably distributing marital property, and enter such other orders as are appropriate. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: / "~3'd~ -3- Document #205968 ,. y VERIFICATION I, Robert A. Doren, hereby 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.A. §4904 relating to unsworn falsificationto authorities. ~~Cv ~~~, Robert A. Doren Date -Z~ Document #205968 e •- C ~~ 'Tj~< ~ ~t2- ~: u, ~, ~ ~ a ROBERT A. DOREN, Plaintiff v. THERESA A. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O~_ 5.38/ C,.-i~ CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Karl R Hildabrand, Esquire, counsel for Plaintiff, Robert A. Doren, hereby certify that a true and correct copy of the Complaint in Divorce was served by certified mail, return receipt requested, upon Defendant, Theresa A. Christopher, on September 21, 2001. Attached hereto, marked as Exhibit "A", and incorporated herein by reference is the signed return receipt card for said service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By ~~~~ Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiff Dated: 2 G o ~ Documen[ N: 2/7051.1 ^ Compf®teHems 7, 2, and 3. Also complete ~- r item 4 if ResLicted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the meilpiece, or on the front if space permits. 1. Article Addressed to: Theresa A. Christopher 906 Schoolhouse Lane Lewisberry, PA 17339 G. Sgnat re Ir v ^ Agent dressce D. s delivery dfe tam 1? ^ Yes It YES, delivery addles w: ^ No ~Z~x17! ~~ , - 3. Service Type/ C~Certified Mail ^ Express MaN ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ~ C.O.D. 4. Restrictetl Delivery? (EMra Fee) ^ Yes 2. Article Number (COPY from service iebeq 7000 ~~~p ®Pt~'>! 4~©7 99$l i ;, ;; „ , , ; P$ Form 3811, July 1999 Domestic Retum Receipt to2596-ss•tA-ossz _' ~" ' ~ ~ ~w~' ~ ~s I~IkBi v ,~ almWe3xaaxs ~ - r^. 9771_. t ° J <_'~_~ ~~ Ems. ~y ~~. t- t~ ~ _ .. ~ -.. fY t ~ ~ „r ROBERT A. DOREN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO.OI-5381 CIVIL TERM THERESA A. CHRISTOPHER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on September 14, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days has 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. . 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. 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. §4904 relating to unsworn falsification to authorities. Dated: I ~ J - ~ ~ Document #: 224]05./ s Robe A. Dore ~~: ~ Y s ~ ,~ =; c ~. ~ , ='~ ~ a _ , ~ -° -L; =~ c~ c ~• -~ ROBERT A. DOREN, Plaintiff v. THERESA A. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.Ol-5381 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(Cl OF THE DIVORCE CODE I consent to the entry of a fmal 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 divorce 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. §4904 relating to unsworn falsification to authorities. Dated: I ~ ~j "a Z ' U-~~/ _ Robert A. Doren Document #: 224106./ ~ `r, ~~~, ~ ;., ~~-_ _., ~-_ ~~ ~~ ~ ~ .~ ~ ,~ ROBERT A. DOREN, Plaintiff v. THERESA A. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OI-5381 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on September 14, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days has 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. 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. 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. §4904 relating to unsworn falsification to authorities. Dated: ~ 3 d ~" ' ~D ~. Theresa A. Christopher Document #: 224705.1 ca c e ~~ ~, ~,~_~ ~ ~` ~~ ~ -<._ ~=' -n ~c-~ _~ ~~ -~b z ,~ .c- r ~; -~ -: ~:~ ~Ta ~~ -~ ~ ~~ ,, ROBERT A. DOREN, v. Plaintiff THERESA A. CHRISTOPHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.Ol-5381 CIVIL TERM CIVIL ACTION -LAW 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. 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. I understand that I will not be divorce 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. §4904 relating to unsworn falsification to authorities. Dated: `-f~ ~ 3 ~~' ~~1/ZQ.~- ~ . Theresa A. Christopher Document N: 224706.! R r~. ~ 1 ~~~ ~ ~ _~ ~irr~ ~i ~ .-;-r; - ~~ m.. t ~D ~~ -<,~: <~' - cs 7_ ? C ' .. ~ b ~ y" C