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HomeMy WebLinkAbout99-02058 "'t) ~ 2 3 .. - , ! .~ ~ i'1 '0 00 l() o '(1S , g: . o Z ~ y. ~ ~ ~ ~ .'~ i ,,~ v !i ~.~ ~ ~ ,', ~ ~~ ~ 8 ~' ~ ~', ~ ~ f.'~ ~ ~ .. ~ >.l ~ >.l liJ , ~,,:-;,->>:O'''<tt:. DECREE IN DIVORCE AND NOW, ......AI-!S':'.~i.~P....... 19(1~.., it is ordered and decreed that. . ... ... ~?~!l.~:. ~???~~;?. .. ..... . . .... ...... ...., plaintiff, and. ... . .. ... . . . .. . ... .~~ll! .'i...lj~~<!,,!,!x:<!.. .. .. .. . ... . ... .... '" 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; The terms of the Separation and Property Settlement Agreement between the p~~~~~~'~~~~~'~~~'ii:'i999' i~'h~~~b~'i~~~~~~~~~~d' ~~. if'~~~'f~~~h'~~'l~~g~h' b~~' ~h~ii' ~~~. ~~~g~ i~' ~h~' fi~~i' Di;'~~~~' D~~~~~' j,;;t~~~;'" 'th~' pa~:t'ie'":''''''' ........ J. ~ $ ~ ., ~ .~ ~ ;;; ~~ ~ ~~ $ ,:, ~ ~ '.' i ~.~ ~ '.~ .'~ * $ ~ *. '.' $ ~ '.' ~ ........-..-. _...._~-----._~--._~-~~.-------_.-.---.~~-_----.-----------~.) ~ .~_~,_~~____~______e*~__' ~ '.' Saparatlon and PropertY Settlemant Agreamant Pago 2 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 that he or she may [rom time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apalt. 2. Interference. Each party shall be free from interference. authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other. nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. Wife's Debts, Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Pus band or his estate might be responsible and shall indemnify and save Husband hannless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 4. Husband's Debts. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife hannless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. Outstanding Joint Debts. The parties acknowledge and agree that they have no outstanding debts and obligations incurred prior to the signing of this Agreement, except as follows: (A) PHH.US - first mortgage, approximate balance $127.000.00 (B) PSECU - auto loan. approximate amount $4.021.00 (C) PSECU - personal service loan. approximate amount $2,900.00 (D) PSECU - Visa credit card. approximate amount $6,300.00 (E) Student Loan Wife shall assume full responsibility for payment and ultimate satisfaction of the debts listed A. Band E above. and Husband shall assume full responsibility for payment and S.paratlon and ProP.rty Sa'Uamane AII....m.n' ultimate satisfaction of the debts listed as C and D above. Each pany shall indemnify, defend and hold the other pany harmless from any clilim or demand made against the other pany by reason of the dofault in the payment of debt assigned to him or her. In tho evont that either party contracted 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. and such party shall Indemnify. defend and hold the other party harmless from any claim or demand made against that pany by reason of such debt. 6. Equitable Distribution of Marital Property. The panies have attempted tD distribute their marital propelty in a manner which conforms to the criteria set fonh in !i3501 et. seq. of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that it is the second marriage for Husband and first marriage for Wife; the age. health. station. amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the panies; the contribution Df each party to the education, training or increased earning power of the other party; the opponunity of each party for future acquisitions 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 or dissipation of each party in the acquisition, preservation. depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of/iving of the parties established during the marriage; and the economic circwnstances of each party at the time the division of property is to become effective. 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 of being effected without the introduction of outside funds or other property not constituting marital property. The division of propeny under this Agreement shall be in fuil satisfaction of all marital rights of the parties. A. Distribution of Personal Property. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings. appliances, and other household personal property between them. and they mutually agree that each party shall from and after the date hereof Palla 3 S.p&I'Iltlon and Prop.rty S.ttl.m.nt A"....m.nt Paga4 be the sole and separate owner of all such tangible personal property presently in his or her possession, and this Agreement shall have the effect of an assignment or bill of sale from each party to the other for such prDperty as may be in the individual possessiDn of each of the parties hereto. The parties hereto have divided between themselves. to their mutual satisfactior" all items of tangible and intangible marital pToperty. Neither party shall make any claim to any such items of marital property. or of the separate personal property of either party, which are now in the possession and/or tmder the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give et:ect to this paragraph. Property shall be deemed to be in the possession or tmder the control of either party if. in the case of tangible personal property, the item is physically in the possession or control ofthe party at the time of the signing ofthis Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership. such as passbook. checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement. and neither will make any claim against the other for any interest in such benefits. except as stated hare in. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to their separate property and any property which is in their possession or control, pursuant to this Agreement, and may mortgage, sell, grant, convey. or otherwise encwnberor dispose of such property. whetherreal or personal, whether such property was acquired before, during or after marriage. and neither Husband nor Wife need join in. consent to, or acknowledge any deed. mortgage, or other instrument of the other pertaining to such disposition of property. B. Distribution of Real Estate, Husband shall transfer to Wife concurrent with the entry of a final Decree in Divorce, all of his interest in and title to their jointly owned real estate located at 390 Petersburg Road, Carlisle. Pennsylvania 17013 in exchange for which Wife agrees to be solely responsible for S.p....don and Prop.rty Salllamanl Ag..amanl Page 5 "! the mortgage obligation to PHH US Mortgage as well as for the payment of all current and future taxes, insurance and utility bills relative to said real estate. Wife covenants and agrees to pay and discharge said obligations Dn said premises. and agrees to indemnify Husband from any lDSS by reason of her default in the payment thereof, and agrees to save Husband hannless from any future liability with regard theretD. including the cost of defense and actual Coul'lsel fees Incurred to defend against an action brought against him by virtue of her default. Notwithstanding the above transfer. for a period of seven (7) years from final Decree, during the growing season, Husband shall be responsible to pnme front hedge by road and bushes within ten (10) feet of house and to mow the lawn a minimum of once per month, and twice per month during peak season, at no cost to Wife. 7. Vehicles. Notwithstanding Paragraph 6 of this Agreement, Wife shall retain possession and ownership of the 1993 Pontiac Bonneville presently in her possession. Husband hereby transfers all of his right, title and Interest in said vehicle to Wife. In consideration thereof, Wife shall asstune full responsibility for payment and eventual satisfaction of any and all liens presently encumbering the vehicle, and to indemnify, defend and hold Husband hannless for the same. Husband hereby agrees to sign any title or other doctunents necessary to transfer ownership of said vehicle at any time, upon demand, and further shall indemnify Wife for any costs. including actual counsel fees, incurred by Wife to enforce this provision. 8. Alimony. Husband shall pay to Wife, as alimony for her reasonable support and maintenance, the sum of $1,400.00 per month, for a period of 84 months, commencing in the 81f1:h month in which a final Decree in Divorce Is entered, and ending on the 36!l' month thereafter. Husband may make such payments in one monthly ltunp sum amount, or may divide the monthly payment into two semi.monthly payments of $700.00 a piece. at his discretion. The parties understand that such alimony shall be deductible by Husband and shall be deemed Income to Wife under the U. S. Internal Revenue Code. Husband's obligation to pay alimony hereunder shall tenninate upon the death of Wife. The period for payment of alimony hereunder shall not be extended beyond such 84 month period. and the amount of alimony due hereunder shall not be changed or modified in any way by either of the parties hereto, or by any subsequent change in circumstances. 3'w ~ s.P....tlon and Propeny S.ttlamlnt Allre.m.nt In addition to the alimony payments set (orth in the procoding par'lgraph. Husband shall continue to provide to Wife the medical and hospital insuranco now in eHect and insuring her at least through the date of the entry o( a (inal Dacreo in Divorco. T/lIJreafter, under appropriate law, Husband may continue to provide medical insurance to Wife through his employer, however, should such medical insurance result In Increased premiums for such Insurance, Wife shall be responsible to reimburse Husband for one. half of such increase In premium. 9. Alimony Pendente Lite, Counsel Fees and Expenses, Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties is fair, adequate and satisfactory to them. Both parties shall accept the Provisions set forth in this Agreement in lieu of and In full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses, or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. Each party shall be responsible for his or her own counsel fees, and each agrees to indemnify. defend and save the other hannless from any action commenced against the other for alimony pendente lite, counsel fees and/or expenses. 10. Divorce. A Complaint in Divorce has been filed to No. 2058 C 1999 in the Court of Common Pleas of Cumberland County, Pennsylvania, and either party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an Affidavit evidencing their consent to the divorce, pursuant to !l3301(c) of the Divorce Code. In the event. for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other hannless from any and all additional expenses, inClUding actual counsel fees resulting from any action brought to compel the refUSing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a Consent fonn and that. absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. Paga 6 Saparatlon and Proparty Settlement A{lntamont Page 7 11. Time of Distribution. The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective panies immediately upon the execution of this Agreement. The panies shall cooperate by executing whatever documents are necessary to effectuate a divorce under ~3301(c) or ~3301(d) of the Pennsylvania Divorce Code, and this Agreement to cooperate shall be enforceable by an assumpsit action for specific perionnance. However, upon refusal to consent, all distributed propeny shall be retumed to the pany originally in possession. until the time of final Decree. 12. Release. Subject to the provisions of this Agreement. each pany has released and discharged, and by this Agreement does for himself or herself, and his or her heirs,legal representatives, executors, administrators and assigns, release, indemnify (inClUding actual legalfees) and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, including equitable distribution. spousal suppon, alimony, counselfees, alimony pendente lite. and expenses which either of the panies against the Dther ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended. or under any other statutory or corrunon law, except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling. pursuant to ~3302 of the Divorce Code. 13. Waivers of Claims Against Estates. Except as herein otherwise provided, each party may dispose of his or her propeny in any way, and each pany hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction, to share in the propeny or the estate of the other as a result of the marital relationship. including without limitation, dower. cunesy, statutory allowance, widow's allowance, right to take in intestacy. right to take against the Will of the other. and right to act as administrator or executor of the other's estate. and any right existing now or in the future under the Permsylvania Divorce Code, as amended from time to time. and each will, at the request of the other, execute. aclmowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. s.P....Uon and Prop.rty S.ttllm.nt Al1rnmlnt 14. Rights on Execution. Immediately Upon the execution of this Agreement, the rights of each pany against the other, despite their continuing marital status, shall temtinate and be as if they were never married. 15. BrGllch. In the event of breach of any of the terms of this Agreement, the nOnbreaching pany shall be paid, as pan of any award or Judgment against the breaChing pany, all costs. including actual counsel fees paid to his or her attorney. 16. Incorporation in Final Divorce. The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the panies. This Agreement shall smvive in its entirety resolving the spousal suppon, alimony. propeny and other interests and rights of the panies under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania. This Agreement may be enforced independently of any suppon order. divorce decree or Judgment and its terms shall take precedence over same, remaining the primary obligation of each pany. This Agreement shall remain in full force and effect regardless of any change in the marital status of the panies. 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 the panies to execute the Agreement. 17. Additional Instruments. Each of the panies shall from time to time, at the request of the other. execute. aclmowledge 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. 18. Separability. In case any provision of this Agreement should be held to be contrary to, or invalid under. the law of any country, state or other jurisdiction. such illegality and invalidity shall not in any way aifect the other provisions hereof. all of which shall continue. nevenheless. in full force and effect. and each paragraph herein shall be deemed to be a separate and undisputed covenant and agreement. 19. Entire Agreement. This Agreement contains the entire understanding ofthe panies and there are no representations, warranties, covenants and undertakings other than those expressly set forth herein. Husband and Wife aclmowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and PaaaS s. &radon an" Pro. SetU.m.nt A ....m.hI separate propeny are fair. equitable and satisfacto'Y to them. based on the length of their maniage and other relevant factors which have been taken into consideration by the panies. Both panies hereby accopt the provisions of this Agreement With respect to the division of propeny in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distributiDn of their propeny by any Coun of competent juriSdiction pursuant to Section 3502 of the Divorce code or any other laws. Husband and Wife each VOIWltarily and intelligently waive and relinquish any right to seek a Coun ordered detennination and distribution of marital propeny, but nothing herein Contained shall constitute a waiver by either pany of any rights to seek the relief of any coun for the PlUllose of enforcing the provisions of this Agreement. 20. Modification and Waiver. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed With the same formality as this Agreement. The failure of either pany to insist Upon strict performance of the provisions of this Agreement shaH not be construed as a waiver of any subsequent default of the same or similar nature. 21. Intent. It is the intent of the Parties by this Agreement to fully and finally foreclose any reson to the Couns for relief on the basis of any statute or Case law presently existing or which may exist at some time in the future Within the Commonwealth of Permsylvania. including but not limited to equitable distribution, alimony and other relief Wlder the PermsylvanJa Divorce Code, as amended. This Agreement has been drafted and accepted on the basis that such reson would constitute a breach Wlder this Agreement, entitling the nOnbreaching party to reimbursement for actual COWlsel fees. Other than as prOvided by the terms of this instrument, it is intended that the Coun shaH treat the panies as if they had never entered into a marital relationShip. This Agreement shaH be interpreted and governed by the laws of the Commonwealth of Permsylvania and. where such law is inconsistent. the terms of this instrument shall govern. 22. Voluntary Execution. The provisions of this Agreement and their legal effect have been fully explained to the panies by their respective COWlsel. and each party acknowledges that the Agreement is fair and equitable, that it is being entered into VOIWltarily, With full knowledge of the assets ofbothpanies, and that it is notthe result of any Pa ..9 ~ \D ~ lr. Q .. ~~ !~ u.' :c '" ... a.. 0""1 ""5- I'"> ,... ~~ ~ fC~ ~"J ..." I;.H if ;::l Q.l ex ~ u... '" B 0 '" '"'- JOHN B. WOODWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. KIM G. WOODWARD, Defendant : NO, 99-2058 CIVIL : CIVIL ACTlON.LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Coun for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section (X) 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: April 14, 1999 by Certified Mail 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: July IS, 1999 by Defendant: August 6, 1999 (b) (I) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pendiog: No economic claims have been raised. 5. (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 ofPlaintitrs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: July 26, 1999 Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: August 13, 1999 JO L, JR. ESQ. :>- \D ~ Fi In ~p " - => <: oS" H:!;? 5: CJ~ '-'-ro- gc:. Q- "~~ e:.' ..... :5 ~~; - g :;Cijj ~: '" """ OJa.; '-'- ~ 0;:> C1\ O"l " . ;. .,f "t - '- JOHN B. WOODWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 9'~ - .20S-P ~ : CIVIL ACTION-LAW' : IN DIVORCE vs, KIM G. WOODWARD, Defendant 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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 JOHN B. WOODWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. VS. KIM G. WOODWARD, Defendant CIVIL ACTION,LAW : IN DIVORCE COMPLAINT 1. The Plaintiff John B. Woodward is an adult individual whose residence is 390 Peter:o:burg Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant Kim G. Woodward is an adult individual whose current address is unknown at this time but whose last !mown residence was 390 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17055. 3. The Plaintiff has been a bonafide resident in the Commonwealth of Pennsylvania for at least six months inunediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 26, 1980, in Deland, Florida. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties under the age of 18. 7. The Plaintiff in this action is not a member of the Armed Forces. 8. The Plaintiff and the Defendant are both citizens of the United States. 9. The Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to a divorce decree being handed down by the court. 10. The Plaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, BY Jo W. Purcell, Jr., Esquire I. (, #29955 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 j' ,. (. ~f,: c:. ,.:. ('~ ,', l'-' . , ~ :: ..p. I ", ,-- I,~ ,I". , (.,' . :,..- r- 'e,) I '1 ~.~ U,ll. ,- Q~\ ' "': ,i:/ "\il (' C\- '_1\ . .. .... ~, U' (l"\ ::l 0 C1' () ',::::-- ) < .... ~~ o-l>l "'''' ziii ~~ o . u~ "'Z ~ 0::> ..l f-l8 I Ug~ ~"' :s tJu ~~ <~ ="' ..l:> E-q:Q H H I z S .:>'" HJSHZ ".... .... .... .... f~ :3' '" "'..... 0'" ~ '" Z S ..., rJ ':1 "" ,- . \() \n 'c-) rr-..J f'- 1- "-. :.:.:: p \:,...", f\"'\ I"- r\\ '" "" l'- ,,-.> '0 -;:.) '-..::. "'J ~ 1" """ ~ .-^=l r- "- ~\6) '"l.--' - ... c '" "C . C '" Qj ~~ ",'" o o :3' "' " '" ~ .... '" z .... H Z !;! o-l ~ o " ~ "' > '-' :.: !j , . .., ~ ::: Z _ . 0 ~~~ ~ ~ ~ ~ ;l'. ;i: . . ~ 5 : ~ ~ ~ - I 01'0 wIsh 10 rocolVO tho lollowlng SOrvlCOS (tor on ollmlool 1. 0 Addressee's Address 2.1iil Restncled Oelivery Consult poslrMsler for leD. 48. ArtKf'! Number -z... S:;,~ OO~ 41'\ \ 4b. Sorvice Type o Aeg;"'Rrorl o Express Mall o Return Rece~llor Morchandlse 7. Dale 01 Delivery J r tf-Iy.tf~- e. Addressee's Addross {Only jf requested nOO too is paid) .. SENDER: -8 .C"mpkll.. n"m't I fl/lll'f)l" If" A'~H,,~,..I Wl'Yl(nl .. .CI"lffiJJ401.llflfll'J3.4a .,lI.l41, i . Plml ~U~. ,,!t.,... .,".'..'.k.... ",. ".., 141...t1'..lJllt,,~ 10,"1 $0 IIl11l *\1 ca" ,.,,,1Il \hI' carGlOyw . Attach thI,latm 10 IhfJ Iron' ~ tI.. "....I'....U1. lJf ()Il ItltJ &IOl01 tl_IJlctt l)..... M . ~':' oR.rum Rero"" R6<.1tJftt'liU ooltltt ""'IJ~1tUt bokWIIlhe Md. nurrl* I . The Return RIIt"'~" Win m""" to wwhl:Jm the ."0(" w.. ck.I..."rlld and If'" dll18 ~ dolIve,ed g 3. Article Addrossed 10, Jl~tv-. c.,WOOOW"""'~ t ?I'~ Y~'t~V-;;~J\YC\ ~~ , ' c'c...y\.",\",, \11 'lO\S 5. Roceived By: (Priflt Namo) ~ ! g ,. .!! PS Form 3811, December 1994 Z 533 IJt.Co died o Ins red o COO lrrl~9'i.96-B.Q229 Domestic Return Receip,~ I oL 471 i. a 1 a: E ~ a: go 'ill ~ 2' ~ ~: ~~ ~. Postage Certified Fee Special Deli\'ery Fee Restricted De~very Fee '" m Retum Receipt Showing 10 ..... Whom & Dale Delivered l2 RetumR<<~ShowMgtoWhan. .:( Oate,&Ada"essee'sMfress o o TOTAL Postage & Fees $ CD ~ postmark or Dale ~ ~ L.-J -'!) ~ 1 C1 0. Exhibit "A" $ JOHN B. WOODWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99.205B CIVIL : CIVIL ACTION.LAW : IN DIVORCE vs. KIM G. WOODWARD, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on April 7, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~33C 1 (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. ~ 4904 relating to unsworn falsification to authorities. Date: 01/)'/ It;'", /97 CJ / I 4 4L- 8. ~~ /ohn B. Woodward h_ . . ''i. J{1f.!:~\~'fl.~'}\r;-!"~/~,,*i"';;~"'P~>/;';! q"; ""~~;~"';,'J,~l '\"'~ir' ~..,_:, fj~;'~;:-:::l~UJ ;;:{i,';';' "'~'a' nt ';;I ';'B~:..:a':~;~~~~~'{-it.:(,,;~~, ,t.;:,;' ;d.... ,;,.}t,.~,.,'" .~P;'. ...... "U" JVW""",",~l".r.-<,.-..d,","-!'.~ ""~'l::' . :"'\?'~':""p"" t' \~~~'C""" ....:..;.i.,<;.~~,.\,>/f~~,':'~li , ,,~':;.,i1.~,..l;,la~-,:';':;'.., t \",1'\ _,rOleaSK1f1Ol orpora~1 ;'" ',":" '.':,f,'oi,"" '-"1 -:t _~'?"';~i:',.", ~~, ~, ~"\~!.""";,zl' ~",..",.Vi,'f..\,~tri:'''~~~}l!\'''''-''<:i;I'-I'}''''''4''E- "'u' r.., ,', A' " "'C'''::I;'''''*P'~;A'''"~1''7-0'13'''~'-':'L'''::''~F'~i:;t _'-" ":~;~,~ "l-'lliP~'\"~t"f.r.;'.;ht,,\.,\~,,tf~~... ~y. 1..0." J-'-", '" berty yet)",~, IH~"; "'''.' J;'~"./;~'-.."'+'i:;,:I~'i-:I\:;~~.I;;/j/"*._';i: 't-l<~;;..;-~>ij::Jl,,>l':~"~'~"'r,,'3,1"~,;.:- -~~! ,",.'F, ,'<"< f"'(717) ~43 7922 . ," ". - .',' '.. ;'-. 'f~ ":".\. ;1.:'.....'" -". .,~',;,."':.f~l .H~\:L~~:~.i!,.~-::;;!: ~~~::!!.-,.:.: ,,:',e~~S' '~"""<'" '": ',:", ~' :. :".' '.,-:. ':, ~ " ' .~. ,~ ',f II" "" "',~~ ~~,:~:;:i'j;::~~_o1~~'-:' ~/\:;:'t(c;;j;.l"~,"_~ JOHN B. WOODWARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. KIM G. WOODWARD, Defendant : NO, 99.2058 CIVIL : CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on April 7. 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint, 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S, ~ 4904 relating to unsworn falsification to authorities. Date:&}'f,~It. /99f ~-J~ '-'Kim G. Woodward JOHN B, WOODWARD, Plaintiff \'5. : IN mE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA KIM G. WOODWARD, Dcfendant . NO. <)<),2058 CIVIl. . CIVIl. ACTION,LAW . IN DIVORCE PRAECIPE TO THE PROTHONOT AR Y: The Social Security Number of the Pluintiffis 266.94.9459, and the Social Security Number of the Defendant is 227-11-8108, Respectfully submitted, PURCELL, KRUG & HALLER BY 7- L, oh . Purcell, Jr. , 29955 1719 North Front Street Harrisburg, P A 17102 Attorney for the Plaintiff >- \0 ~ ~ In ~ .. ~~ - ~;') :c ~~ c.. Q~ [' r- 3~ ffL1.! C) if =:J 10- e>: ~ 0'\ G 0'\ >- lr) ~ "! .,. ~ -= ,.. '7 .... e,::.:; ::1< .9 (l) wR (".'J:-c,: 9 ~ ~ (J.:. :t: ~');i.: 0, ..'-( . u... a.. -'" (~F: :1;,.J c- eo ";:"i'i5 ~ ~ GL N '1;~ '9 c(. U.:l. '.Z G:' c. 'U[iJ ...., ",10- r:.. V> ~ L'. <n ::> 0 '" U