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HomeMy WebLinkAbout99-02910 +Yka: i?>JF5 t C 5-i 1 S ~vM r ?.d y t R +ti 3} 1 r IIZJ O v, O 1 Mr. . W. cr,..M • .•a.,. ,?,, t? • :oJ' :?: s :?...:e.. •:o: •:? • :?• :P, for :V? -.4> •0 o- co : s • :d --- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . „ PENNA. .r, Tq O 0 0 0 i e i e i 0 R _ A rJ"i N o- .99-; 92 09....9IVIL .................. DECREE IN I V .g C E 'Ot..tp AND NOW ............... . 19.9?.... it is ordered and decreed that ..... Darla. Markley. Innerst ....................... . plaintiff, and ....... James M. Innerst ........................................... . 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; 'Also, it is ordered and decreed that the Matrimonial Settlement Agreement ...................................................................... of ,the,psrties•¢ated,September•16,•1999,is.hereby. incorporated, by, reference and merged into this Decree. Q y o ttest - Prothonotary f i e i .? /o•7•y'9 lev7? C?? ??? jc ??'may ,???,•_ SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: 0 9-16 `, 7 DOCKETNUMBER: -J ?- aj /Q d/6,'14- PLAINTIFF/PETITIONER SS# /7e/,- (o - a ?? 9 NAME: a. f2 cA 6i A ek a J N IU k St DEFENDANT/RESPONDENT SS # '6 /0 NAME: _ 24 lt4 E5 /W • IAUN 6 F ST MATRIMONIAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this 161A day of6 '1999, by and between Darla Markley Innerst, of 1520 Thompson Lane, echanicsburg, Cumberland County, Pennsylvania 17055 ("Wife") and James M. Innerst, of 2590 Woodmont Drive, York, York County, Pennsylvania 17404 ("Husband"). RECITALS A. The parties hereto, being Husband and Wife, were lawfully married on December 12, 1992, in Cumberland County, Pennsylvania. B. Differences have arisen between Husband and Wife in consequence of which they have begun to live separate and apart from each other. C. Husband and Wife acknowledge that they both have consulted their attorneys and have been advised by their attorneys of all of their rights and duties or have had the opportunity to consult independent legal counsel and have wilfully, knowingly and voluntarily waived the right to consult an independent attorney. WITNESSETH NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings herein contained, the parties, each INTENDING TO BE LEGALLY BOUND, agree as follows: 1. Recitals. The Recitals set forth above are incorporated herein by reference. 2. Divorce. It is specifically understood and agreed by and between the parties, and each party does hereby warrant and represent to the other that, as defined in the Pennsylvania Divorce Code, their marriage is irretrievably broken. Wife filed an action in the Court of Common Pleas, Cumberland County, Pennsylvania, to No. 99-2190 CIVIL on May 13, 1999. The parties agree to take all legal steps (including the timely and prompt submission of all documents and the taking of all actions) necessary to assure that a divorce pursuant to 23 Pa. C.S.A. § 3301(c) of the Divorce Code is entered as soon as possible. This Agreement and any ancillary or supplemental agreements shall be incorporated by reference and merged into the proposed Divorce Decree presented to the Court. Husband and Wife shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint or interference whatsoever by the other. Neither party shall molest the other in any way whatsoever nor endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. 2. Marital Property. (a) Personal Property Division. Husband and Wife acknowledge that they have divided all personal property acquired during the marriage to their mutual satisfaction. Husband and Wife also agree that the furniture currently in the marital residence will remain with the marital residence. Husband hereby relinquishes all right, title and interest in Wife's personal property currently in her possession, and Wife hereby relinquishes all right, title and interest in Husband's personal property currently in his possession, except as provided herein to the contrary. (b) Real Property Division. Husband and Wife are presently the owners of the real property located at 1520 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055 (the "Residence"). The parties have agreed that Husband shall execute, upon signing this Agreement, a Special Warranty Deed to Wife conveying Husband's interest in and to the Residence. In consideration of said conveyance, Wife shall pay to Husband the sum of $5,000.00 due and payable at the time of execution of said Deed. Wife shall be responsible for all costs, fees, and legal fees associated with this transfer. Such Deed may be recorded by Wife promptly after execution hereof. Wife shall remain solely responsible for the existing encumbrances on and obligations concerning the Residence thereafter. Pursuant to Section 3 (B) below, Wife shall indemnify, defend and hold Husband harmless from and against the mortgage on said property and future expenses of the Residence, including but not limited to real estate taxes. (c) Retirement. Pension. 401-K Plan. Husband hereby relinquishes all right, title and interest in Wife's retirement, pension and/or 401-K Plan and Wife hereby relinquishes all right, title and interest in Husband's retirement, pension and/or 401-K plan. 3. Debts and Obligations. (a) Individual debts/obligations. Each of the parties shall assume all debts and obligations presently in their individual names and shall indemnify, defend and hold the other harmless from said debts and obligations, whether incurred prior to, during, or subsequent to the marriage. This shall include all personal, individual credit cards and personal individual loans by either party. Each party hereby agrees to pay and hereby agrees to hold the other harmless from any and all personal debts and obligations incurred by him or her on or after the date of this Agreement. If any claim, action or proceeding is hereafter brought seeking to hold the other party liable on account of any such debts and obligations, such party will at his or her sole expense defend the other party 2 r against any such claim, action or proceeding, whether or not well-founded, and indemnify the other party against any loss resulting therefrom. (b) Joint debt s/obli ations. Wife shall indemnify, defend, and hold harmless Husband from and against any future payment of the first mortgage on the Residence, currently held by Fleet National Bank, and will also indemnify, defend and hold Husband harmless from and against any future payment of the second mortgage held by Commerce Bank/Harrisburg, National Association. Husband and Wife represent that there are no additional joint debts or other debts incurred by either of them currently outstanding with respect to which the other party may incur any liability now or in the future. Each party hereby expressly agrees to indemnify, defend and hold harmless the other from any and all liability, direct or indirect, including attorneys' fees and costs, which may arise in connection with an obligation, joint or otherwise, for which the party has agreed hereunder to bear sole or partial responsibility, or which the party has failed to disclose and provide for herein. 4. Legal Fees. Each party agrees that they shall be responsible for their own legal and other fees incurred by them in connection with this domestic relations matter unless otherwise specified herein or otherwise agreed to by them. 5. Automobiles. Upon execution hereof, the parties agree that the 1996 Saturn SC 1 titled to Wife and currently in Wife's possession with an outstanding lien to Members First, shall become the sole free and clear property of Wife. Wife shall assume liability for payment of such lien and shall indemnify, defend and hold Husband harmless from and against any payment related thereto and shall maintain insurance in her name. Husband waives any right, title or interest he may have in and to said automobile and shall promptly, at any time necessary, execute any title or transfer documents necessary to fulfill this provision. Upon execution hereof, the parties agree that the 1997 Chevy Cavalier jointly titled to Husband and Wife and currently in Husband's possession with an outstanding lien to GMAC in both names shall become the sole free and clear property of Husband. Husband shall assume liability for payment of such lien and shall indemnify, defend and hold Wife harmless from and against any payment related thereto and shall maintain insurance in his name. Wife waives any right, title or interest she may have in and to said automobile and shall promptly, at any time necessary, execute any title or transfer documents necessary to fulfill this provision. 6. Other Writings. Each of the parties hereto agrees to promptly execute any and all documents, consents, waivers, bills of sale, tax returns or other writings reasonably necessary to carry l out the intent of this Agreement. 7. Further Debt. (a) Wife shall not contract or incur any debt or liability for which Husband or his property or estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands, including attorneys' fees and costs, made against him by reason of debts or obligations incurred by her. (b) Husband shall not contract or incur any debt or liability for which Wife or her property or estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands, including attorneys' fees and costs, made against her by reason of debts or obligations incurred by him. 8. Mutual Release. Except as otherwise provided herein and so long as this Agreement is not canceled by subsequent agreement, the parties hereby release and discharge, absolutely and forever, each other from any and all rights, claims and demands, past, present and future, resulting from the marriage relationship, specifically from the following: alimony pendente lite; alimony; spousal support; division of property; claims or rights of dower and right to live in the House; right to act as executor or administrator in the other's estate; rights as devisee or legatee in the Last Will and Testament of the other; any claim or right as beneficiary in any life insurance policy of the other unless specifically named otherwise or as required herein; and any claim or right in the distributive share or intestate share of the other party's estate, all unless specified to the contrary herein or in a subsequent writing signed by the parties hereto. 9. Tax Return. The parties have elected to continue to file separate individual income tax returns. Each party shall be solely liable for any and all of their own tax liability and shall indemnify, defend and hold the other harmless from and against any such liability. 10. Medical/Health Insurance, Husband shall maintain medical/health insurance for Wife through his employer for so long as Husband's employer shall permit. After such time, Wife shall be responsible for payment of her own medical/health insurance and the maintenance thereof, if any, whether through COBRA or another plan, as Wife shall decide. 11. Entire Agreement. This Agreement constitutes the entire understanding between the parties, and there are no covenants, conditions, representations or agreements, oral or written, of any nature whatsoever, other than those herein contained. 12. Legally Binding. It is the intent of the parties hereto to be legally bound hereby, and this Agreement shall bind the parties hereto and their respective heirs, executors, administrators and assigns. 13. Full Disclosure. Each party asserts that she or he has fully and completely disclosed all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them; of all debts and encumbrances incurred in any manner whatsoever by each of them; of all sources and amounts of income received or receivable by each party; and of every other fact relating in any way to the subject matter of this Agreement. These disclosures are part of the consideration made by each party for entering into this Agreement. 14. Costs to Enforce. In the event that either party defaults in the performance of any duties or obligations required by the terms of this Agreement, and legal proceedings are commenced to enforce such duty or obligations, the party found to be in default shall be liable for all expenses, including reasonable attorneys' fees, incurred as a result of such proceedings. 15. Agreement Voluntary and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: (a) Is fully and completely informed as to the facts relating to the subject matter of this Agreement and as to the rights and liabilities of both parties; and (b) Enters into this Agreement voluntarily after receiving the advice of independent counsel or, having been advised to consult independent counsel, has knowingly and voluntarily chosen to forego such consultation; and (c) Has given careful and mature thought to the making of this Agreement; and (d) Has carefully read each provision of this Agreement; and (e) Fully and completely understands each provision of this Agreement, both as to the subject matter and legal affect. The parties acknowledge that they haveboth utilized the services of the same attorney, John R. Beinhaur, Esquire. The parties acknowledge that they were made aware of their absolute right to obtain separate counsel and have voluntarily and knowingly waived such right and by signing this Agreement agree that the possibility of conflict of interest was disclosed to them each and have knowingly, voluntarily and willfully waived such potential conflict in utilizing the same attorney. 16. Amendment or Modification. This Agreement may be amended or modified only by a written instrument signed by both parties. 17 Anplic„_ able Law. This Agreement shall be governed, construed and enforced under the statute and case law of the Commonwealth of Pennsylvania. 5 18. Counterpart s. This Agreement may be executed in separate counterparts, each counterpart deemed an original and when combined represents the legal binding intent of the parties hereto. 19. Severability. If any part of this Agreement is determined to be invalid by a court of competent jurisdiction, such determination shall not invalidate the entire document but shall apply only to that phrase, sentence, paragraph or section. The remainder of the sentence, paragraph, section and Agreement shall continue in full force and effect. IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first written above: WITNESS: WITNESS: WIFE: = Darla Markely Innerst HUSBAND: jj Ja s .Innerst 6 COMMONWEALTH OF PENNSYLVANIA SS.: COUNTY OF DAUPHIN On this, the 6 14--day of September, 1999, before me, a Notary Public, the undersigned officer, personally appeared Darla Markley Innerst, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notaryubli? c -? My Commission Expires: (SEAL) NOTARIAL SEAL JOHN R. BEINHAUR, Notary Public Lower Paxton Twp., Dauphin County M Commission Expires March 13, 2003 COMMONWEALTH OF PENNSYLVANIA : SS.: COUNTY OF DAUPHIN On this, the /o/'4 day of September, 1999, before me, a Notary Public, the undersigned officer, personally appeared James M. Innerst, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary I&blic My Commission Expires: (SEAL) NOTARIAL SEAL JOHN R. BEINHAUR, Notary Public Lower Paxton Twp, Dauphin County M missi n x a March 13 2003 DARLA MARKLEY INNERST, Plaintiff V. JAMES M. INNERST, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2910 CIVIL CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: May 24, 1999, by United States first class certified mail, return receipt requested. The original PS Form 3811 Domestic Return Receipt is attached hereto and marked as Exhibit "A." 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: by Plaintiff on September 16, 1999; by Defendant on September 16, 1999. 4. Related claims pending: Matrimonial Settlement Agreement executed by the parties and dated September 16, 1999, to be incorporated by reference and merged into the Divorce Decree. 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe to Transmit Record. 6. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe to Transmit Record. Date: of -/6 -Q? Respectfully submitted: BEINHAUR & CURCILLO By: John Beinhaur, Esquire Supreme Court I.D. No. 55631 4650 Fritchey Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff EXHIBIT "A" e. SENDER: M4 I also wish to recehro ft f :== t ardor 2 for addftloeW " 4 and4b a or an following sef*es ( ,W pr"ywt?r ro?rr eiq aCprsu on eia ra?wea of oiM ism fo VW w+ an rwim tlir Mp y/ ozVa tee): d ' 1 b you cud ft1h lNt 6, to IM eoM of Na mWpkm. or on the buk a apaoa dm iwl A ress s Ad t. ? Addmme o •wma 7W" RooW ReQUostacr n ft mandooa beww dw Wads mrrbw. ow arddai wu doNvered and sr date h h t 2.0 Rastrkted Dailvery r lee f t r ! i om m o w a The RM" RKW wa o do!+ emd. . o CortsuM postmas er 9. Attlda Addressed to: 4a. ATMs umber ?-o?rt-356-4 JArV+ES M lNVlefSt 4b. Nivice Type ; f 257ao tumr&oy)t (Driv ? Registered ce . , , PA t?vo? Agot-k ? Express LW ? Ineu ?f?n?dww' coo 'r ( Date of Debve y rp A we By: (PrksI Name) p 8. Addressee's teas ( H ed and Ian is ? .. cJ« . ca 1?9y gnature: ( or U GSp3 , X = P3 r Decernbsr 1964 +d Domestic RelUm Receipt M';. , > rr co n r' i l 1 it l u a cx- ? u3 a. G m Q I 4 Darla Markley Innerst Plaintiff, V. James M. Innerst Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA N0. 6'y- a9?c, , :CIVIL ACTION - LAW :IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any claim of relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by the parties. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthoiuse High and Hanover Streets Carlisle, PA 17013 (717) 697-0371 BEINHAUR & CURCILLO Jolfn R. -- DATED: S - f :? ' 17 Attorney for Plaintiff Darla Markley Innerst Plaintiff, V. James M. Innerst Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 I. ,? 410 &,?J 7-z..- :CIVIL ACTION - LAW :IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, Pennsylvania. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, as amended, you may request that the Court require you and your spouse to attend marriage counseling prior to a Divorce Decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling services are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this Notice. Failure to do so will constitute a waiver of your right to request counseling. Darla Markley Innerst :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. James M. Innerst Defendant, NO. 99. a 91o (?lf/u TtN•. :CIVIL ACTION - LAW :IN DIVORCE COMPLAINT DIVORCE UNDER SECTION 3301(c) OR 3301(dd) 1. Plaintiff Darla Markley Innerst, is an adult individual residing at 1520 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant James M. Innerst, is an adult individual residing at 2580 Woodmont Drive, York, York County, Pennsylvania, 17404. 3. Plaintiffand Defendant have been bona fide residents of the Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 12, 1992, in Cumberland County, Pennsylvania. 5. Plaintiff avers that the ground upon which this action is based is that the marriage is irretrievably broken. 6. There has been no prior action of divorce between the parties in this or any otherjurisdiction. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. 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. 9. There are no children bom of this marriage. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, BEINHAUR & CURCILLO By: ohn R. Beinhaur Supreme Court I.D. #55631 4650 Fritchey Street Harrisburg, FA 17109 (717) 651-9100 Attorney for Plaintiff DATED: _ Ail 1999 2 CERTIFICATE OF SERVICE AND NOW, this j?L/-day of 1999, I, John R. Beinhaur, hereby - 419# certify that I have served the foregoing Complaint in Divorce by mailing a true and correct copy by United States first class mail, certified mail return receipt requested, postage prepaid, addressed as follows: James M. Innerst 2580 Woormont Drive York, PA 17404 Respectfully submitted, BEINHAUR do CURCILLO BY J hn R. Beinhaur Supreme Court I.D. #55631 4650 Fritchey Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff DATED: _?44 a4y 1999 3 VERIFICATION I, Darla Markley Innerst, have read the foregoing Document and hereby affirm and verify that it is true and correct to the best of my personal knowledge, information and belief. I verify that all of the statements made in the foregoing are true and correct and that false statements made therein may subject me to the penalties of 18 Fa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Ale,& Darla Markley Innerst DATE:, /9q9 l m SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: DOCKET NUMBER: PLAINTIFF/PETITIONER SS# 174-60-2999 NAME: Darla M rklalr TnTlerst DEFENDANT/RESPONDENT SS # 206-56-9610 NAME: James N. Innerst o, c r al J c? W DARLA MARKLEY INNERST Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-2910 CIVIL ACTION - LAW JAMES M. INNERST Defendant, : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) or-3M40) of the Divorce Code was filed on May 13, 1999. 2. The marriage of plaintiffand 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 decree. 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: 9 f/6 /4^7 Darla Markley Innerst Q c [_?ice, r C?Q U3 CL n? a O Oi U DARLA MARKELY INNERST, Plaintiff, V. JAMES M. INNERST Defendant, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2910 CIVIL CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 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: Darla Markley Innerst g r- C'i T_ CV u r L LLI ? 5 0?, v DARLA MARKLEY INNERST Plaintiff, V. JAMES M. INNERST Defendant, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2910 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT L A complaint in divorce under Section 3301(c) or-3391(dj of the Divorce Code was filed on May 27, 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 decree. 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: ` %G % Ja .Innerst lll? U •.- ? nQ 7 LL (d•' Ll.. 1.1J.? L?. ?? dl ON s7 v DARLA MARKELY INNERST, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-2910 CIVIL CIVIL ACTION - LAW JAMES M. INNERST Defendant, : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C. S. §4904 relating to unsworn falsification to authorities. Date: /G 9 L "t _ is .Innerst } ? M r r G cl C7 i s a '!' u u _ rn U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DARLA MARKLEY INNERST Plaintiff V. JAMES M. INNERST % Defendant NO. 99-2910 C I V r L 19 99 ACTION IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the f o4`1 day of Cc}o6p 12 __1 19 99 , hereby elects to retake and hereafter use her previous name of DARLA SUE MARKLEY (Signature - magi . ri;:it>e ._ It-Gd2,e? _ (Signat - to be krsrwn ' ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss• On the /4/4, day of T?zcvahb,0 19 119, before, a Notary Public, personally appeared Lhr(e aaLtf /neersk known to me to be the person whose name is subscribed to the within docu- ment, and acknowledged that she executed the foregoing for the pur- pose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. =axlon AL ?-? tary Public phin County aroh 13 2603 '- otary Public Ct; U?. ?.•_ ?? j: - ??llJ ??,r?, ?1 r i? - fU' ?: (1 C'6 ?, ? ? ?-. ? Qr Cv _?. L', ... ?.__ ? ? ?