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HomeMy WebLinkAbout99-03411IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. TERRI L. SHEPARD Plaintiff VERSUS GREGORY W. SHEPARD No. 99-3911 DECREE IN DIVORCE AND NOW, 2-q ?IT IS ORDERED AND DECREED THAT TERRI L. S PARD PLAINTIFF, AND GREGORY W. SHEPARD ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; HONOTARY Ax5 PROPERTY AND MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, MADE THIS THE 14 DAY OF f)2Cem bP_r , 2000, BY AND BETWEEN: Terri L. Shepard, of Williamsport, Lycoming County, Pennsylvania, hereinafter called the "WIFE", AND Gregory W. Shepard, of Williamsport, Lycoming County, Pennsylvania, hereinafter called the "HUSBAND" WHEREAS, HUSBAND and WIFE, were lawfully married on the 10th day of August 1995, in Frederick, Maryland; and WHEREAS, HUSBAND and WIFE, have one minor child, Tessa K. Shepard (DOB: March 21, 1995); and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between HUSBAND and WIFE in consequence in which they are living separate and apart from each other; and the parties hereto are desirous of settling fully and finally the respective financial and property rights and obligations as between each other; including, without limitation all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to the past, present and future support, alimony a maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and all claims and possible claims by one against the other or against their respective estates. WHEREAS, HUSBAND and WIFE have made full disclosure of their assets to each other; and NOW, THEREFORE, inconsideration of the promises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuabie consideration, or receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby covenant and agree as follows: FIRST - SEPARATION HUSBAND AND WIFE shall at all times hereafter have the right to live separate and apart from the other party at such place or places as he or she may from time-to- time choose or deem fit, free from control, restraint or interference whatsoever by the other party. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions 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. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single or unmarried, except as to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabitate with the other or in any way interfere with peaceful existence, separate and apart from the other. THIRD - WIFE'S DEBTS Wife represents and warrants to HUSBAND that since the separation she and not, and in the future she will not, contract or incur any debt or liability for which HUSBAND OR HIS ESTATE MIGHT BE RESPONSIBLE. WIFE AGREES TO INDEMNIFY AND HOLD HARMLESS HUSBAND from any and all claims or demands made against him by reason of debts and obligations incurred by the WIFE, from and after the date of the execution of this Agreement, shall be the WIFE's individual responsibility. FOURTH - 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. HUSBAND AGREES TO INDEMNIFY AND HOLD HARMLESS WIFE from any and all claims or demands made against her by reason of debts and obligations incurred by the HUSBAND prior ro the date of the delivery of this Agreement. All further debts incurred by the HUSBAND from and after the date of the execution of this Agreement, shall be the HUSBAND's individual responsibility. The parties hereby acknowledge that the WIFE has filed a Complaint in Divorce in Cumberland County (Docket #99-3411) claiming that the marriage is irretrievably broken under the No-Fault Mutual Consent Provision of 3301(c) of the Pennsylvania Divorce Code of 1980 and subsequent changes. Both parties agree that the marriage is irretrievably broken and express their 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 the court to order counseling under the Divorce Code. It is further and specifically understood and agreed by the parties that the provisions of this Agreement as 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. SIXTH - DIVISION OF PERSONAL PROPERTY The parties hereto agree that they have divided between them, to their mutual satisfaction, the personal effects and household furniture and furnishings, and all other articles of personal property, which have heretofore been used by them in common. Neither party shall make any claim to any such items which are now in the possession of the other except: HUSBAND agrees to sign over his interest in the 1995 Hyundai Elantra automobile jointly owned and jointly financed by the parties within fifteen (15) days following the satisfaction of the lien. In the interim, WIFE agrees to be personally responsible for the loan at York Bank ($267.00/month) A. HUSBAND shall pay WIFE child support in the amount of sixty-five ($65.00) dollars per week for the support of the parties minor child Tessa. B. WIFE shall have primary physical custody of Tessa K. Shepard and both parties have joint legal custody, which means that the WIFE must consult with the HUSBAND regarding any decisions that need to be made regarding religious, educational and medical issues. C. HUSBAND shall be entitled to have visitation and temporary partial physical of Tessa and his step-daughter Ashtynne Harden according to the following schedule: 1. Alternating weekends from Friday until Sunday at times as agreed upon by the parties. 2. Tuesday and Thursday evenings at times as agreed upon by the parties. 3. HUSBAND shall be entitled to custody every year on his birthday (June 22) and Father's Day from 9:00 a.m. to 9:00 p.m. WIFE shall have custody on her birthday (July 14) every year and Mother's Day from 9:00 a.m. to 9:00 p.m. This schedule shall supersede the normal weekend schedule. 4. Minor holidays shall be alternated such that in even numbered years HUSBAND shall have New Year's Day and Memorial Day, and WIFE shall have Fourth of July and Labor Day. This schedule shall be reversed in odd numbered years. The time for these holidays shall be as agreed upon by the parties. 5. For Easter, Thanksgiving, and Christmas, the parties shall share custody of the minor children at times as agreed upon by the parties. 6. At all other times, as agreed upon by the parties. The parties hereto agree that any monies held by either of them in an account in that party's name alone shall remain the sole and exclusive property of that party. The parties further agree that any monies previously held in joint savings accounts have heretofore been divided to their mutual satisfaction. HUSBAND agrees that any monies which WIFE has acquired through her own interests in either pensions, annuities, and/or retirement benefits, including but not limited to, IRA's, 401(K)'s and mutual funds, through her present or past employers shall remain her sole and exclusive property. HUSBAND further agrees to waive any interests he may have in such property and further agrees to waive any such claim in the future. WIFE agrees that any monies which HUSBAND has acquired through his own interests in either pensions, annuities, and/or retirement benefits including but not limited to, IRA's 401(K)'s and mutual funds, through his present or past employers shall remain his sole and exclusive property. WIFE agrees to waive any interests she may have in such property and further agrees that she will not assert any such claim in the future. TENTH - MEDICAL INSURANCE/COVERAGE Each party shall be responsible for his/her own health insurance protection and both parties agree to list Tessa on their respective policies as a dependant and cooperate in coordinating benefits as between insurance companies. It is further agreed, covenanted and stipulated that this Agreement shall be incorporated in any decree hereinafter entered by any court of contempt jurisdiction in any divorce proceedings that have been or may be instituted by the parties for the purpose of enforcing the contractual obligations of the parties. This Agreement shall not be merged in any such decree but shall in all respects survive the same and be forever binding and enforceable upon the parties. Both parties accept the provisions of the Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now or hereafter have against the other, if any, for alimony pendente lite, counsel fees, or expenses, or for spousal support before, during and after the commencement of any proceedings for the divorce between the parties. HUSBAND OR WIFE each do hereby mutually release, quit-claim and forever discharge the other and the estate of the 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. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees, and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. EOURT NTH BRFACH If either party breaches any provision of this Agreement, the other party shall have the right at his or her election, to sue for damages, or seek such other remedies or relief as may be available to him or her. The party breaching this contract shall be responsible for payment of legal fees and costs, including attorney's fees, incurred by the other in enforcing his/her rights under this Agreement. The provisions of this Agreement and its legal effect has been fully explained to the WIFE by her attorney, Julie M. Pentico, Esquire, and to HUSBAND, who has chosen not to be represented by his own counsel. HUSBAND and WIFE acknowledge that this Agreement is not the result of any duress or undue influence and that it is not the result of and collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have made a full accounting of their respective assets, estate, liabilities and sources of income and that they waive any specific enumeration thereof for the purpose of this Agreement. Each party hereto agrees that he or she will not at any time raise as a defense or otherwise the lack of disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraudulently withheld. The parties hereto confirm that they have relied on the completeness and substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no formal discovery conducted in their pending divorce action and that neither party has filed an inventory and appraisement. 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 and hold the other party harmless for and against any and all such debts, liabilities, or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. HUSBAND and WIFE covenant, warrant, represent and agree that with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other party may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be other wise specifically provided for by the terns of this Agreement. The modification and waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as the Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties hereto. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. It is the intention of the parties hereto that the within Agreement shall survive the action for divorce, and that no order, judgment or decree, temporary, interlocutory, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be made part of any such judgment or decree of final divorce, but shall not be merged therein. TJOIENTY-FOURTH - VOLUNTARY EXECUTION The parties hereby acknowledge that both have carefully read the terms of this Agreement, and both acknowledge that they fully understand the terms and agree to be bound by all of its provisions. FURTHERMORE, Both parties hereto declare that they do understand the full legal effect of this Agreement, especially with regard to the fairness and equitable nature of the distribution of marital property between them; and the waivers, especially those benefits enumerated in Paragraphs SIXTH through TENTH. Both parties acknowledge that their execution of this Agreement has been done voluntarily and knowingly and their execution is not the result of any duress or undue influence. This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980 and any amendments thereto. This Agreement contains the entire understanding of the parties hereto, and there is no other representations, warranties, covenants or undertakings other than those expressly set forth herein. TWENTY--SF-VENTH - AGREEMENT BINDING AMONG HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors and administrators. Each of the parties shall from time-to-time, at the request of the other, execute, acknowledge and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. IN WITNESS WHEREOF, and intending to be legally bound hereby, the parties have hereunto set their hands and seals the day, month and year first above written, to this Marriage Settlement Agreement, consisting of this and seven (7) other typewritten pages. i ess =?-W "?M? ? LL/4,4 ? TERRI L. SHEPAPJD Witness G G R. SHEPARD ? ?- ; ??. ': f _ ?? . ,..: ',..?.:,'r ,.- ? .:? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff NO,: 99-3411 VS. GREGORY W. SHEPARD CIVIL ACTION - LAW Defendant DIVORCE PRAECIPE TO TRANSMIT RECORDS 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: U.S. Certified Mail, return receipt requested, and U.S. First Class Mail, postage prepaid on June 12, 1999. See acceptance of service attached hereto as Exhibit A. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: By Plaintiff: December 13, 2000 By Defendant: December 13, 2000 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs affidavit upon the Respondent: 4. Related claims pending: None 6. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record: (b) Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: December 18, 2000 (c) Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: December 18, 2000 DATE: SCHEMERY ZICOLELLO By. v ti CC' Julie M. Pentico I.D. #69330 Attorney for Plaintiff 330 Pine Street Williamsport, PA 17701 (570) 321-7554 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff NO.: 99-3411 I I VS. GREGORY W. SHEPARD CIVIL ACTION - LAW DIVORCE Defendant ACCEETANCE OF SERVICE I, Gregory W. Shepard, being an adult individual, hereby swear and affirm that I accepted service of the Complaint in Divorce by certified mail, return receipt requested, on the 12" day of June, 1999 as per the attached receipts. Date: _y °` of Gre9dry W. Shepard I 514 687 '71'15 Recel t for Certified Mnil SENtiER: I Also YAelt to recelve III kill" j lip neevlees (lot an Awl 1") No Inmmnen Cnverepn nrovVterl t CMn1uI. AenO I e , A 1n1 • WIN,al IIM,al D nM time lot Intomslbnnl MAY lSen Monet Canton noon r, en, IM 41 - - - A . \m,•rmn noneeM•?Aee.. nn . wcen m\1n1 1144 IN I""" nnNS I.Mw 0101 1 ? 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III II III III IIII1., 1 II I II' >;_..';' en1r0A1A a Ono ?? tnteASs19B ezms DemeeHc RAW- Recel{ri °5 Form 9811, Oecernbar 1994 a. i f? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff VS. GREGORY W.SHEPARD Defendant NO.: 99-3411 CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE Julie M. Pentico hereby certifies that a copy of the Praecipe to Transmit Record and Divorce Decree was served upon Gregory Shepard, RR #2 Box 78, Williamsport, PA 17701 by placing the same in U.S. Certified Mail, return receipt requested and by U.S. First Class Mail, postage prepaid, the 8th day of January, 2001. SCHEMERY ZICOLELLO By: `JU l? e? ?e CO Julie M. Pentico I.D. #69330 Attorney for Plaintiff 330 Pine Street Executive Plaza Williamsport, PA 17701 (570) 321-7554 TERRI L. SHEPARD PLAINTIFF VS. GREGORY W. SHEPARD DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3411 CIVIL TERM 1999 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 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 grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is avail- able in the office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE. Carlisle. Pennsylvania 17013 IF YOU DO NOT FILE A CLAIfN FOR ALIMONY. DIVISION OF PERSONAL 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. Court Administrator, Third Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone: 1-249-1133 IN THE COURT OF COMMON PLEAS TERRI L. SHEPARD, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. ?4 iYf/ CIVIL TERM 1999 VS. : CIVIL ACTION - LAW GREGORY W. SHEPARD, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 fc) of the DIVORCE CODE 1. The plaintiff,Terri L. Shepard, is an adult individual residing at 487 State Street, in th a West Fairview section of East Pennsboro Township, Cumberland County, Pennsylvania 17025, since August, 1997. 2. The defendant, is an adult individual residing at R.R. # 2, Box # 78, Williamsport, Lycoming County, Pennsylvania, 17701, since November of 1998. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for more than six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff an Defendant were married on 10th day of August 1995 in Frederick, Maryland. 5. There have been no prior actions of divorce or annulment in this or any other jurisdiction between the parties. 6. The Plaintiff and Defendant are not in the Military or Naval Service. 7. The marriage is irretrievably broken. 8. The Plaintiff respectfully requests the Court to enter a decree in divorce. 1 verify that the statements made In this Complaint are true and correct. I understand that false. statements herein are subject to the penalties of 18 Pa., C.S.. s4904, relating to unsworn falsification to authorities. DATE: (Ttit) ZZ L.SHEF? aintift D B. OWEN, Esquire Attorney for the Plaintiff Supreme Court I. D. # 15508 708 A N. Front Street Wormleysburg, PA 17043 TERRI L. SHEPARD, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS : NO. % 9. 39/1 CIVIL TERM 1999 GREGORY W. SHEPARD, : CIVIL ACTION- LAW DEFENDANT : IN DIVORCE AFFIDAVIT 1, TERRI L. SHEPARD, being duly sworn according to law, depose and say: 1. 1 have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. 2. 1 understand that the Court maintains a list of marriage counselors, which list is available to me upon request. 3. Being so advised, I do no request that the Court require that my spouse and I participate in the counseling prior to a divorce decree being handed down by the Court. the penalties ofdle Pa.,dG.S. that a false 4904,1 relating sto herein are made subject to to authorities. CIATE- TERRI L. SHEPARD, Plaintiff TERRI L. SHEPARD : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 91-NII CIVIL TERM 1999 vs GREGORY W. SHEPARD, CIVIL ACTION - LAW IN DIVORCE Defendant l PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(c) OF THE DIVORCE CODE If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty (20) days after this affidavit has been served on you or the allegations will be admitted. 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on the day of '1999. 2. The parties have lived separately and apart since November, 1998. i 3. 1 understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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 FA., C.S., s4904, RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:" 2 1191 TERRI L. SHEPAR , Plaintiff a. N ° ? cis=; _ =?•'? D 1 ? co w ?-- _ - L r.F U oqi CU 00 41 ii . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff VS. GREGORY W. SHEPARD CIVIL ACTION - LAW DIVORCE Defendant ACCEPTANCE OF SERVICE t, Gregory W. Shepard, being an adult individual, hereby swear and affirm that I accepted service of the Complaint in Divorce by certified mail, return receipt requested, on the 12"' day of June, 1999 as per the attached receipts. Date: U I A U I Greg ry . Shepard ~ I elso welt to receive the follow- SENDER: u>n eervtcea (lor an 011M 1") 11 ewrye+l• Rem 1 Iv+ Z W , tm•l fo VV '. 1Ne to" ee Mel •e een nlem 1111 LanHl. a•,m s, ee, tlt•1 aF. 'e Address M F"" You, ""'t 11r+1 ; 4N .° nn IM twom n1 1 U Addruaee uta b rou• ?e. 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FI N 2 514 687 7,18 Us Poster Service Receipt for Certifled Mall No Insurance Covereon RreWlrl Do nol use lot Imelllellonnl Mau ( ee mteme, to S (.11LC W ")%NA I.Irt,4 errs (V 91 ale, IPCM. -' '--- _1..:1111Awsip?n>l.•(Ira Ibslape GerrMnd Fee /+ 4? *c(al Delivery Fee Rrstrklnd Delvery Fee neaen nlCNRl Sarw*Ipb yamM a Dale Delvered trenn ite:I to mem One.+wawea4/daeu YOSaL Peadge a Frail ?I i / e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff NO.: 99-3411 VS. GREGORY W. SHEPARD CIVIL ACTION - LAW DIVORCE Defendant 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 4, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the 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 f 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: 0 - 13- DU Terri L. Shepard ?:? ? _ is •° 'VJ .. _;. i i+JW C;J C' 1 o U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff NO.: 99-3411 VS. GREGORY W. SHEPARD CIVIL ACTION - LAW DIVORCE Defendant 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. 1 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. 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: / 2- d - n6- ,'P' Terri L. Shepard ' c? Lll2 -` rzl? U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff VS. NO.: 99-3411 GREGORY W. SHEPARD CIVIL ACTION - LAW DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 4, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the 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. Q DATE: 12 - ! 06) i`h Gregory . Shepard [r o> cv c:? ; rn Li :3(1- G ' O ' J _, c? J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA TERRI L. SHEPARD Plaintiff NO.: 99-3411 VS. GREGORY W. SHEPARD CIVIL ACTION - LAW DIVORCE Defendant 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. 1 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. 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: IA' - 13 co f4`?t:ft Greg W. Shepard l\ ? 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