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HomeMy WebLinkAbout99-02264 ~r: ~[~~:") , ,/, '~~:: --,;1' tt~~.;, li\:, ;,~k:;-,-. ?~ 4S7l- '~~ 1~ ,!t); ..~t.' ,,-1{';:; O.r'.... ?(.. 5;:,.~ ~~~,-- ff'" ;il 11 ~\~;' r',., ~J' ... ". '- '+"'--,. ,: ~~': '/f.A,;.~, ~ 'y1};:','::':::' .,. f."',' \ ':f.;&; l~~i:' ,.".:,- ,.,..,.,'.... €~,':':/ ;'~"J' i ~,,\ '. :.-:."...,.,.. I~l:~;('. ~i~,~:: , 40;."...'.",..... lr~?'::;:?':' ':~'!F" . Co',:.!' _:L"":: llF':;~~. !,~ :,,", ~"":" ~~ ~,;,. i" ;",;:, "';:)-' .'," (;;. "'- ;1.:", :L.. !'~-"" ';' :". ,.;;, c. " >~:" : ,co"~ ~. ,\: ' , . t iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF NANCY WILKINSON, PLAINTIFF VERSUS JAMES C. WILKINSON, DEFENDANT ~ PENNA. ~ ~;, , " No. #99-2264 CIVIL TERM :~ DECREE IN DIVORCE . . ~ (. ''ISt'"'' . ,;)oO~, IT IS ORDERED AND AND NOW, fit. ....J... I 1 DECREED THAT AND . . . NANCY WILKINSON . . . PLAINTIFF, . . JAMES C. WILKINSON , DEFENDANT, . . . . ARE DIVDRCED 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; A PROPERTY SETTLEMENT AGREEMENT IS ATTACHED AND MADE A PART HEREOF FOR PURPOSES OF ENFORCEMENT. . . . . . Bm~ . . . . . . . . . ATOe", ~ (I~ ' . PROTHONOTARY J. . . . . . . '+ '+ '+ '+ +' '+ '+ '+ +' Of '+ -+... .. -+ '+' '+ . + '+ . + '+ '+ .. '+ + '+ '+ '+ -+ -+ + -+ + + + -+ + + + '+ ... '+ '+ '+ '+ + '+ + ,.,.:..' I . t. , 3,x).OI M, ~P' '1U~4/ lb 4 ~ 3';,;C).t'1 'J1~ I~ zf d/" \ ~ AGRBIMRNT NOT A BAR TO DIVORCB PROCBBDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 330l(c) of the Divorce Code of 1990 as amended by Act No. 1990, 206 effective 3-19-91. ~ BFFBCT OF DECREE. NO MERGER It is specifically agreed, however, that a copy of this Agreement may be incorporated, by reference, into a divorce judgment or decree, This incorporation, however, shall not be regarded as a merger, it being the intent of the parties to permit this Agreement to survive any such judgment, unless otherwise specifically provided herein, and for this Agreement to continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any divorce decree which may be entered with respect to them for purposes of enforcement only of any provisions therein, but shall survive such decree. That is, this agreement and all warranties and representations contained herein shall survive the Divorce Decree and shall continue to be enforceable in accordance with its terms. Except with regard to child support and child custody, no court may change the terms of this agreement, and it shall be binding and conclusive upon the parties. In the event of a reconciliation, attempted reconciliation, or other cohabitation of the parties hereto after the date of this agreement, this agreement shall remain in full force and effect in the absence of a written agreement signed by both parties expressly stating that this agreement has been revoked or modified, lL DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall take place simultaneously with the execution of this Agreement. !l!l ADVICE OP COUNSEL Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of her and his selection; that Wife has been independently represented by counsel and that husband, cognizant of his right to legal representation, declares that it is his express, voluntary and knowing intention not to avail himself of his right to counsel and chooses instead to represent himself with respect to the preparation and execution of this Agreement. ilel ADVICE OP COUNSEL This Agreement has been prepared by Ruby D, Weeks, Esquire, the attorney for Wife. Said attorney at the commencement of, and at all stages during the negotiation of this Agreement, informed Wife that she has acted solely as counsel for Wife and has not advised or represented Husband in any manner whatsoever. Husband, at the commencement of, and all stages during the negotiation of this Agreement, has been informed by Ruby D. Weeks, Esquire, that he has a right to be represented by his own counsel and has encouraged him to seek the advice of counsel. Husband has read this Agreement carefully and thoroughly, fully understanding each of its provisions, and therefore signs it freely and voluntarily. ~ FINANCIAL DISCLOSURB The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement, and that they do not wish to exercise their right to have appraisals by experts as to the value of the various interests of the other party. They understands that such appraisals would be necessary to fix the fair market value of these interests for purposes of equitable distribution. ~ WARRANTY OF DISCLOSURE The parties warrant and represent that they have made a full disclosure of all assets and their valuation prior to the execution of this Agreement. This disclosure was in the form of an information exchange of information by the parties' attorneys and this Agreement between the parties is based upon this disclosure. ~ OBTAINING INFORMATION ON FINANCES Each party acknowledges that they have been informed they may have the right, as provided by statute and Pennsylvania Rules of Civil Procedure, to obtain information regarding the parties' finances. such information would include, without limitation, their present and past income; and the identity and value of assets both presently owned and transferred previously. Such information may be obtained by one or more of several methods including depositions upon oral examination, written interrogatories, production of documents or entry upon property for inspection. The parties agree to waive any further discovery. ~ PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. ~ NO MOLBSTATION Husband and Wife shall not molest or interfere with each other, nor shall either of them attempt to compel the other to cohabit or dwell with her or him, by any means whatsoever. Neither party shall harass or be verbally or physically abusive to the other. 10. MUTUAL RBLIlASBS Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widowerls rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, " . , t except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 11. BOUITABLB DISTRIBUTION OP PROPBRTY It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either of them during the marriage, as contemplated by The Act of April 2, 1980 (P.L. 63, No. 26) known as "The Divorce Code," 23 P.S. 3101 et. seg. of the Commonwealth of Pennsylvania. And further, that the parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in 3502 of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage, the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of one party to the education, training, or increased earning power of the other party; the opportunity of each party for future acquisition of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. la. Real PrODertv The parties own no real property, ~ Oi.tribution ot per.onal PrODertvl Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property, and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. This Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possessions of each of the parties hereto. 14. Generals (1) Husband hereby waives all interest in Wife's property including but not limited to all accounts, certificates of deposit and securities. (2) Wife hereby waives all interest in Husband's property including but not limited to all accounts, certificates of deposit, and securities. ~ Motor Vehicles, Each party shall retain title, as their separate property, to any vehicle now in that party's possession, ~ PILING INVENTORIES AND APPRAISEMENT The parties further acknowledge their understanding that they each have the right to file Inventories and Appraisement with the Court and to require the other party to do so. Such Inventories and Appraisement require a party to indicate, under oath, information regarding all marital property in which either party has an interest as of the date the action was commenced. Fully knowing the same, each party nonetheless waives their respective rights to request additional discovery be conducted, to file Inventories and Appraisement with the Court, or to require the other party to do so. 17. APTER-ACOUIRED PERSONAL PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible and intangible, subsequently acquired by the other party. 18. SUBSEOUBNT PERSONAL DEBTS, Husband and Wife agree from time of the signing of this Agreement that each party shall be responsible for their own debts and hold each other harmless from same. 19. FUTURE DEBTS: Husband and Wife hereby mutually agree that subsequent to the execution of this Agreement neither party shall incur any debts which will obligate the other to make payment for same. Husband and Wife hereby acknowledge that there are no outstanding bills or other indebtedness which have been incurred by either for the liability of the other, and both parties hereby covenant and agree that neither shall have any financial obligation to pay any financial obligations which are solely the financial obligation of the other and which have been contracted by either party solely for their own benefit and without the knowledge or consent of the other party. Husband and Wife further agree that they will indemnify the other from any and all claims or demands made against the other by reason of any debts or obligations contracted in violation of this Agreement. 20. WARRANTY AS TO BXISTING OBLIGATIONS. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those lor necessities, except for the obligations arising out of this Agreement. ~ WARRANTY AS TO FUTURE OBLIGATIONS. Wife and Husband each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. 22. WAIVER OF SPOUSAL SUPPORT. ALIMONY PENDENTE LITE. AND ALIMONY The parties herein acknowledge that by this Agreement they have each respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient financial resources to provide for their comfort, maintenance and support, in the station of life in which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, alimony pendente lite, support or maintenance. It shall be from the date of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. ll.... RETIRIlMllNT PONDS A. The Husband, who has been employed by All American, Carlisle, Pennsylvania. It is agreed by the parties that the Wife shall waive any interest she may have in any of the benefits, including retirement, which the Husband may have as a result of his employment. B. The Wife, who is employed at All American, Carlisle, Pennsylvania. It is agreed by the parties that the Husband shall waive any interest he may have in any of the benefits, including retirement, which the Wife may have as a result of her employment. 24. DIVORCE Husband and Wife agree that Wife shall file a Complaint in divorce seeking a divorce on the basis of mutual consent. Husband and Wife both agree that ninety (90) days following the filing of a Divorce Complaint by Wife that both parties will execute the required Affidavits of Consent to be filed with the Court to allow the Court to grant a divorce on the basis of mutual consent. Wife agrees to pay all counsel fees, costs, and expenses incident to obtaining the aforesaid divorce. AND the parties hereto state and agree that this Agreement shall not in any way be construed as a collusive agreement. 25. ATTORNEY ~EES. COSTS & EXPENSES The parties agree to waive receipt of and to be responsible for their own attorney fees, costs and expenses in connection with the negotiation and preparation of this Agreement and the granting of a divorce decree. ~ BRBACH or AORBBMBNT If either party fails in the due performance of obligations under this Agreement at their election, the non-breaching party shall have the right to sue for damages for breach of this Agreement or to rescind same and seek such legal remedies as may be available to them. The breaching party will be responsible for actual legal fees and costs incurred by the non-breaching party necessary to the enforcement of this Agreement. ~ LAW or PBNNSYLVANIA APPLICABLB This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. ~ AORBBMENT BINDINO ON HIIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. ~ SBVBRABILITY 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. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 30. INTBORATION This Agreement constitutes the entire understanding of the parties and Bupersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. n.... NO WAIVIlR OP DIlPAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement, The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. ~ WAIVIlR OR MODIPICATION TO BIl IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 33. SUBSIlOUENT DIVORCIl It is contemplated that Wife will proceed with a Complaint in Divorce against Husband in the near future. Husband and Wife each agree to sign an Affidavit of Consent and an Affidavit waiving counseling to be filed in said divorce action, In the event such divorce action is concluded, Husband shall be entitled to receive a copy of the Decree in Divorce for the normal fee charged by the Prothonotary and shall not be assessed any costs of the proceeding, except as previously agreed to herein in Paragraph 25, In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agreement, which shall not be incorporated by reference into the Divorce Decree, and this Agreement shall not be merged in such Decree, but shall in all respects survive the same and be forever binding and conclusive upon the parties. . . 1L. HBADINGS NOT PART OP AGRBEMBNT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. ~ 11 l:uJ- Wi eBe a?;tl'{ i2~' (I iiLfjl,t-~iPr: ~James C. Wilkinson ./ Q(}tU-KlU~ w tness i:r. Lf) ~~ :a: M IS ,;.. ~-= :c: -c) ;:-. u..~' a.. r,:I~ ~t cD is c;.,: t.,Wt.. I ~~ Ii:..:: ~ ;..:: x; ... ts 0 ~ CClIlIlilIlInIl or ._ULVIUUA .. COUII'rY or CI......t.lUlD Tha abova nllllled, Nancy Wilkinaon, being duly aworn according to hw, dapoaaa and aaya that tha facta containad in tha foragoing Complaint ara trua and corract, and tha Complaint ia not mada out of lavity or by colluaion batwean har and tha aaid Dafandant for the mere purpo.. of being fr..d and a.paratad from aach othar, but that it b brought in aincadty and in truth for the caua. mentioned in the .aid Complaint. Sworn and .ub.crip,,~ to ~;fO~ .}hb ...1!L':d~~. Carol A ~Olarla' Seal MyC~~I~~i~~n~E3~~ge~~~~~~ xprres June 28 1 I.toriiliir.--.= ' .. -. ..,......Asocdiiiiii '" Noiiiiiii {1~ 1{~urlf)/Y7 IIII'll Notary Pu lie ">- tv~1.~,:,; ~ ' (::)1. . . li' 'n . 'i_< U~,l \ ::'11 C'- ~L r: ~~ :.; ...... l:. C'') ":) o <Tl ~_, \!) (~ _OJ .,., (j "-..J - )-.... ~ "--,... ?i: ~ ~ & '~ r( L/) <-1 ~ ~ ~ (::t:. \} ~ ~ \ (}. () f] V; C) 1:"- \) t6 \' '4 ~ () 0j0 jJ . ~~ (0- U;; tj r.i ~ (jr:( ....... ....... '&,... '~ ~~~ B ~ ~ . il; ""Eiltl .. tl ~I~ t;, ~ i Ii' n ~ ~ n ~~~ J S s a ! i. I g ~ t< bal, rt ~ I .. ~ il~ IDOCA" .. .t:gCQ ,Ii i~ ~>i~ '" >- C"J ~ ~ M .. 8~ it1q M "("j ::c ,~ It..,(: "- ~~ !~~:; co S~ O~1: I UJL." ill~ Ef!~;.! 0:: oCt ,-. x: :::>.: U- ::::> 0 0 u -, ~ C'? ~ C'? "'" iJl 5~ tSQ ,..~ :c: o~ __CJ t+':L. 0.- o~ at) co ~l ce; wtL I ffi ~l,j c<:: u--'-" .,,, <00- 1:--: :lC ~ ..-'6 ::> 0 u >- (") ~ ~ M ~ M ::>~ wQ 8~ ~o ::<:: !i-:J.: "- o~ dt:~ co 3 I L/ C!~: I lli~ wt.:-. ~~" 1 "" I,./....::.j\. "" r=: :a:: ::;;: IJ.. ::> 0 (:) U " .' " -'~;: '. Ii ',1,; !' ,);, .1:\ i'~ Plaintiff IN THB COURT OF COMMON PLBAS OF CUMBERLAND COUNTY, PENNSYLVANIA '? ':1 NANCY WILKINSON, v. CIVIL ACTION - LAW IN DIVORCE JAMBS C. WILKINSON, Defendant #99-2264 CIVIL TERM ~". ,. {~ WAIVBR OF NOTICE OF INTBNTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER S 3301 tel OF THE DIVORCB CODE 1. I consent to the entry of a final decree of divorce without notice. 2, I understand that I may lose r.ights concerning alimony, division of property, lawyerls 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: 3/1! 0, . ., I /JJf/' ; C t..." ' &t:f"C'...:'7-- W~lkinson, Defendant >- M ~ ~ M M ~:!!: UJQ 8~ s..2f"5 :c p-~.r-- C- n:>; ~r;: 3~ li? co wo.. I lH~ ~_IL' <::: a:: of' "'" ~: x: -.,; u. S 0 0 u " :, '. , , ~' . ,I . . .1 " . Z DB 333 972 .... - - ------------- ",' U. S. POSTAL SERVICE UH C,iC:I.lSr.r f'A 17013 '::~/.:. 38.00 ,:.',11 II [13 ;i. I ' " ,)'-, 15::;2:44 .---- ---.-------- CUSTOMCf( r.CCCIf'r ....- .-------- Postage $ '3, - 0 I . t...rD : C':' PCST VAL It1f' ~d'~;; ?n::'TriGE STtlMPS ;jl).-; f'O~;Tplj[ STAt1F'B 6.95 1.65 -1.65 Certi6edFee Sj>edllOel""ryF.. ' rfjT,\L 6.95 6.95 cr;SH T \ if ':2.;) C~ :;,1;(;[ $ B'6oM, ----------- ICo. THN1K YOU .o::~ ...-...._._-~.. --'-.,..' ---------- 'I ... SENDER: I alao _10 ~ !he ' .~"""__2""__ -9..rvtcoa(foran . .~-.....""'... f I.=r::..."""''''''-. 011................_.."'"'......_... extra fee): "...'.. _,~ jl I . Aboh..formtolheftontd....nlIpIece.Ol"<<tlhebIldi.JPIiii'"doMnot ,"....-:11 I : .="'-~_onltlo__ltIo_" .. ",,-' : , .=.::rReorllptwllllhowkJwhom....arUCleWUdllvwldandlfMdlll:1;:". ',,, ~....",,~\I, . J & 3, ArtIcle AddrOll8dIo: 4a. "1 ;JArnesC. W:/Krnso/V 201. 91cf(. . · CJo All AmeriCAfJ-rrllvel IJlfl7/I.&rtd< ~'::o=::- lrCertJtled I! · IJ..OI HRrrlsbul3"H})e OExpreuMaJI OJnaured I ' Ca.ri;s/e} PII 170/3 ~O=f~forMetchardoo OCOD I ' .9( 5. Received By: (PrlntNams) 8. Addreaaee a Add.... (Only" UBStBd t' Illd IH Is paid) ~ 8, Slgnalura: (AcIdte88H or Agont) 1 X .. PS 111'''' ". D22lI Domestic Aetum Receipt .oa '. . t. , " ,II... 'if - ~ C"j ~Q c>; ~('i; ~ a;gs '~ ~~f Cl..: ') "" <::l ',>Sf " LiJ!l.~ .~;?p, r:.., ,.:):;> eft:.. 8: :1;:;;> i!.: "J (] ,'l.lh:. -~ ts '""' ~ " m ;::j (J . 0'" . , .It " NANCY WILKINSON, IN THE COURT Oil' COMIION PLEAS Oil' CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW IN DIVORCE JAMBS C. WILKINSON, Defendant *99-2264 CIVIL TERM PRAECIPE TO WITHDRAW COUNTS IN DIVORCE TO THE OppICE Oil' THE PROTHONOTARY, Please withdraw the previous requests for DIVISION OF PROPERTY, COUNSEL FEES, COSTS, EXPENSES, in the above captioned divorce action since these matters have been satisfactorily resolved between the parties through a Property Settlement Agreement entered into March 1, 2001. Dated: 3}t.p!CJ( Ruby D. Weeks, Esquire Attorney for P aintiff cc: Ruby D. Weeks, Esquire James C, Wilkinson, Pro Se ~ ~ ~ M M =>:'1: Q 8~ ~t; :c: If~ a.. a~ ',;(.2 <D 7i:J) w, I 3z ~L-_ "" ffiro E:~-;" d co a.. ,~ :c :i ..... '5 0 a . .. . . ..Q ~ ~ ~ -So - ~ ill ~ ~ .:1 r'l; r::!: en ::::> '- \'l- UJ ~:; o~ , ... (.)t:: '.J~ ~ ~ G:. I T- ei) ~ I,J__.,_ "'" o;::i ~ rl~;:'__ ::Ii: ,1,'-' c.., ~i.J5 ~ ::tt u.:1[: ::JZ -..c '-;:u ~ ~ 6:\- ~ ;n~ <:...) -'C1: ~ in. :::: u.. ::::> 0 0 U