Loading...
HomeMy WebLinkAbout99-02826J C4 ri Ufa i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF? ' "y PENNA. Michael Brown, Plaintiff No. _99-2826 Civil Term VERSUS Claudia Brown, DECREE IN DIVORCE AND NOW, -9M" 11 ZUW IT IS ORDERED AND DECREED THAT Michael Brown PLAINTIFF, AND Claudia Brown_ 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; Maw Q/ate'/t?v a4ul .tx?irc .no?'Lc?(?G 14iy 0,aJcj,rjk MICHAEL BROWN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99 - 2826 Civil Term CLAUDIA BROWN, ACTION IN DIVORCE Defendant MARRIAGE SETTLEMENI AGREEME rT THIS AGREEMENT, made this 1(nl(4 day of ? f US'? '" - , 2000, by and between, MICHAEL A. BROWN, of Mechanicsburg, Pennsylvania, a eina er referred to as HUSBAND", and CLAUDIA G. BROWN, of Fairfield, Pennsylvania, hereinafter referred to as "WIFE". WHEREAS, Husband and Wife were lawfully married on August 20, 1966, in Ohio, and; WHEREAS, differences, disputes, and difficulties have arisen between the parties and It is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, WHEREAS, the provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Husband has employed and had the benefit or counsel of Jane Adams, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Barbara Entwistle, Esquire, as her attorney. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection and that each fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any collusion or improper illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the Court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pondente life, equitable distribution of all martial property owned or possessed individually by the other, counsel fees, and costs of litigation, each party hereto still desires to execute this Agre ement, acknowledge that the terms and conditions set forth herein are fair, just, and equitable to each C u a parties and waives his or her respective right to have the Court of Commons Pleas of Cumberland County or any other Court of competent jurisdiction make any determination or Order affecting the respective party s right to a divorce, JIlmony, alimony pendente lite, equitable distribution of all martial property, counsel fees, and costs of litigation. NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run. 6 The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It Is the Intention of the parties that such division shall be final and forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 2. INTERFERENCE. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 3. SUBSEQUENT DIVORCE. The parties hereby acknowledge that HUSBAND has filed a Complaint in Cumberland County, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301© of the Pennsylvania Divorce Code. WIFE hereby expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301 C of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry (it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of separation.) It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. DISTRIBUTION DATE. The transfer of property, funds, and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. 6. WIFE'S DEBTS. Wife represents and warrants to Husband that since the separation on June 30, 1998, she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the separation on June 30, 1998, 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 harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. l'U / 8. OUTSTANDING JOINT DEBTS. (a) Wife hereby agrees that the following debts and only the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. Wife warrants that these debts fully disclose her credit card liability; and she shall be responsible for any other accounts in her name alone or which she may have opened in joint names which have not been previously disclosed under this agreement. 1) The First USA Credit Card, #5417112666654560, Balance as of March 2000, $2088.00 2) The Sears Credit Card, #558972438797, Balance as of April 2000, $3976.00 3) The MBNA Credit Card, #549099019604, Balance as of March 2000, $0.00 4) The Lowe's Credit Card, #20390884672 or C8222039-088, Balance as of April 2000, $518.00 (b) Husband hereby agrees that the following debts and only the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. Husband warrants that these debts fully disclose his credit card liability; and he shall be responsible for any other accounts in his name alone or which he may have opened in joint names which have not been previously disclosed under this agreement. 1) $15,000 Business Loan, taken out for development of popcom machine. FCNB Bank, #7343187270, Balance as of March 2000, was $13500.00 2) Will assume second mortgage and payoff of business loan taken out against house of which the principal amount is between $60,000 and $65,000 with appropriate accured interest. 3) The Discovery credit card, #6011002313528820, Balance as of March 2000 was $3834.00 4) The First City Bank credit card, #4128003184575150, Balance as of January 2000 was $2360.00 9. MUTUAL RELEASE. Subject to the provisions of this Agreement, each party 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 and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties sever had or now has against the other, except any or all cause or causes of action for divorce and except any or all causes of action of breach of any of the provisions of this Agreement. 10. DIVISION OF PERSONAL PROPERTY. 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. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole end separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separato property of Wife. The parties do hereby specifically wavier, release, renounce, and forever abandon whatever claim, if any, tie or she may have with respect to the above items which shall become the sole and separate property of the other. 11. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all tights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 0 12. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The following vehicles shall be and remain the sole and exclusive property of Wife. The 1994 Chrysler New Yorker; the 1992 Chrysler mini-van. (b) The following vehicles shall be and remain the sole and exclusive property of Husband. The 1993 Plymouth Duster; the 1980 Honda cbx; the 1979 Honda cbx; the 1989 Yamaha rzr 1000; the 1975 Honda Goldwing; a 1972 Chevrolet Blazer; the 1978 Yamaha sr500; a second 1978 Yamaha sr600; a 1961 BMW 650 Is. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on or before July 31, 2000. The parties shall meet at PennDot or before some other appropriate notary service on or before this date and said executed titles shall be delivered to the proper parties before the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 13. MARITAL HOME. HUSBAND and WIFE hold title as Tenants by the Entireties to the premises identified as 1975 E. Mount Hope Road, Fairfield, Pa. Hamiltonban Township, Adams County, 17320. The parties agree as follows with respect to the marital residence: (a) On or with thirty (30) days of this agreement, HUSBAND shall deliver a warranty deed, conveying to WIFE all of his right, title and interest in and to the marital residence. Thereafter, WIFE shall be the sole owner of the marital residence and shall be.permitted to record the deed and take any other action with respect thereto that she deems appropriate. (b) As of the date of separation, and without regard to when bills for such items are incurred, received or due, WIFE shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and WIFE shall keep HUSBAND and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense. (c) There is presently an outstanding mortgage against the martial residence in favor of ALLFIRST BANK. There is also a business loan with CENLAR MORTGAGE, loan no. 002182610188259012 which is a secondary lien. Commencing on the date of this agreement, WIFE shall be solely responsible for timely payments of all past, present, and future principal, interest and other fees under the first mortgage with ALLFIRST BANK. HUSBAND will be responsible for the principal and all payments under the second mortgage with CENLAR MORTGAGE, loan no. 002182610186259012 (d) HUSBAND and WIFE agree to take all steps necessary to have the mortgages transferred to the proper respective parties; provided however, the two Mortgagees agree to such a change. The parties shall divide the cost of such a remortgage equally; however, it is not anticipated that such change will require substantial costs. (e) WIFE shall indemnify and hold HUSBAND harmless from any liability, cost or expense, in connection with any expense required to be made by WIFE including but not necessarily limited to, the first mortgage, property taxes, and insurance with respect to aforesaid premises. HUSBAND shall indemnify and hold WIFE harmless from any liability, cost, or expense in l/` connection with any expense required to be made by HUSBAND including but not necessarily limited to, the second lien on the aforesaid premises. 14. OTHER PERSONAL PROPERTY. The parties agree that the: WIFE shall retain possession of. her Macintosh computer, the Lionel model trains, and household furniture and fixtures. HUSBAND shall retain possession of. his Macintosh computers, his Winchester.22 target rifle, his F. W.B, model air rifle, his Savage .308 target rifle, his BSA.22 target rifle, and his Enfield replica. 15. ALIMONY, LEGAL FEES and INCOME. The parties agree that: (a) HUSBAND shall pay WIFE $650 per month for the next seventy two months beginning on May 10, 1999. HUSBAND will pay taxes on all alimony paid; HUSBAND will also pay WIFE $750 to assist her with her legal expenses. (b) WIFE agrees that she shall not be entitled to any future Income which may be received by Husband as profit from his invention of his Popcom Machine. (c) HUSBAND agrees that he shall not be entitled to make claim on any proceeds paid to WIFE as part of her Worker's Compensation Claim. 16. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for calendar years 1966 through 2000 have been filed and that no notices have been received from the Internal Revenue Service which remain unresolved. Each party further represents to the other that to the best of his or her knowledge, the information set forth in the joint tax return for these calendar years was and remains accurate as relates to his or her sole income and acknowledges that the other party relied on such representations in signing those returns. Therefore, if any deficiency in federal, state, or local income taxes is proposed, or any assessment of any such tax is made against the other party by reason of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax, interest, and penalties or expenses shall be paid solely and entirely by the responsible party as determined to be attributable to that party on account of misrepresentation or failure to disclose relevant information of income on the aforesaid joint returns. 17. LIFE INSURANCE. It is further understood and agreed by and between the parties as follows: (a) HUSBAND shall maintain and keep in full force and effect life insurance policies upon his life in the amount of $100,000, naming WIFE beneficiary for a minimum of ten years or until HUSBAND is medically uninsurable. (b) The parties may request the insuring companies to send duplicate notices of premiums due to Wife, and in the event of any default in payment of any premium or premiums by Husband on the said insurance, Wife shall have the right to pay the premium in order to prevent the lapse or cancellation of any policy, and she shall be immediately entitled to repayment from Husband for any amount of any payment. 18. WAIVER OR MODIFICATION TO BE 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 cD nature. 19. MUTUAL COOPERATION, Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 20. APPLICABLE LAW. The 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. 21. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party 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 property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge, 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. This agreement shall be binding and shall insure the benefit to the parties hereto and their respective heirs, executors, administrators, successors, and assigns. 22. WARRANTY OF DISCLOSURE. The parties warrant and represent that they have made a full disclosure of all their assets and their valuation prior to the execution of this Agreement. This disclosure was in the form of an informal exchange or information by the parties' Attomeys and this Agreement between the parties is based upon this disclosure. 23. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 24. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of This Agreement. 25. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and unfit 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 default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 26. SEVERABILITY. 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 provisions 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 his or her obligations under any one 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. 27. BREACH. If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year 4 first above written: WITNESS: ?/ / Witness Date: fitness ? Date: f/'9000 ?MIC AEL A. BROWN, Plaintiff CLAUDIA G. BROWN, Defendant C ' C0 Ir n c v.t i C? u U MICHAEL BROWN, Plaintiff VS. CLAUDIA BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 2826 Civil Terns : ACTION IN DIVORCE PRAECIPF 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 0301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receinLmqugsted. deliv r d on• May 14 1999 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: September 13, 2000 By Defendant: September 1, 2000 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 13, 2000 Respectfully Submitted: Date: (q- 13 v/ ne Adams. Esquire I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff r r r- us , u?G N OF d ` W uJ to 41 g CU MICHAEL BROWN, Plaintiff VS. CLAUDIA BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. q4 - ??a10 L T{', 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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) 244-3166 MICHAEL BROWN, Plaintiff VS. CLAUDIA BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99- ?2 k6 eZ-L1 7-t?? ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Mike Brown, an adult individual, whose current address is 5020 Richard Lane, Mechanicsburg, Pa. 17055, 2. Defendant is Claudia Brown, an adult individual, who currently resides at 1975 E. Mount Hope Road, Fairfield, Pa. 17320. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 20, 1966 in Ohio. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together, both of which are over eighteen, namely, Aaron Brown and Amy Brown. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Anned Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Mike own, Pla ntiff Respectfully submitted, Date:.S (b / 9 I.Y. No. 79465 J,f 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?y? 4l C? ?n i '110 1 60 CJ ? o q 0 MICHAEL BROWN, Plaintiff VS. CLAUDIA BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 2826 Civil Terre ACTION IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AND NOW, this May 17, 1999, 1, Jane Adams, Esquire, hereby certify that on May 14, 1999, a true and correct copy of the Plaintiff's Notice to Defend and Complaint were served, via certified mail, return receipt requested, addressed to: Claudia Brown 1975 E Mount Hope Road Fairfield, Pa. 17320 Respectfully Submitted: UL Ja a Adams, Esquire No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 4 a SENDER: I 9 m • Complete Items 7 and/or 2 for additional sorvlces. • Complolo hams 3, 4a and 4b I also wish to receive the 1 , . wwa?rr //y?t,..??lp,isynas®,? //??? ?q • Pdnl your name and addross on the favar? following e,, services (for an pi,,..,a , card to y o u 6 i 1 y . i d, , f? Yl V'1 Vs extra fee): YY?6rs Attach th ls . form ro rho front of the mallpleca, or c s i W Portrait. i Apr 1. ? Addressee's Address W i ' ' ° i r t • r te v Return Rea9lW Requested•on the mail +ol?rl • The Return Rocoipt Will show to whom the anic a was tlelrvor deli tl ¦ ?y' itibc 2 Restricted Delivery a 0 and the data e vered. 3. Anicle Addressed lo: Consult postmaster for fee. N g ` 0. / 4a. Article Number `a+ . s n Q? r ?W h , US . u l !.? C UV 17AQ 4 . Service Type 13 Registered )@rcenifiecf m - ? Express Mail ? Insured ? Retum R ???0 P'/7 eceipt for Merchandise ? COD a 7. Date of Delivery 5. Received 0 Pnnt Nama) y' ( 8. Addressee's Address (Only it requested s 6. Sin Lire: (Addresse or Agent) and lee is paid) i tQ m Ps Form 3811, December i994 la2sss ss 1-0 DDRIBStiC Return Receipt i 1 j 1 1 i I 1. r 09 x? 0 MICHAEL BROWN, Plaintiff vs. CLAUDIA BROWN, Defendant IN THE COURT CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 2826 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 10, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 understand that I may lose my 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 the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ! - / • p o - r? laudia Brown, Defendant WAIVER OF NOT1 L" OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OFT E DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if do not claim them before a divorce is granted. 3. 1 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: ' l , J , Uv C , .cM laudia Brown, Deters ant w c ?, r5:3 ; w ? . MICHAEL BROWN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 99 - 2826 Civil Term CLAUDIA BROWN, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 10, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 understand that I may lose my 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 the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ri / 3 pv Michael Brown, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 433010 OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if do not claim them before a divorce is granted. 3. 1 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: CJ , 3 • V D &1-629 - Michael Brown, Plaintiff t ff??J =? C`J es 4 _ 2 ? F"• N cn O O