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IN THE COURT OF COMMON FLEAS
OF CUMBERLAND COUNTY
STATE OF ?A. ~ PENNA.
WENDY LOUISE RIGGS, I?
.................
Plaintiff
....................
i
Versus
RICHARD DALE RIGGS,
........................... .
........................
Defendant
No-g469 ............ ................. 1999
0
DECREE IN
I VORCQQE
AND NOW, l ?j. 19.11 . , it is ordered and
decreed that ....... WENDY• LOUISE ,RjGG,$ . • • • , • • • . , . • . • , , plaintiff,
and ......RICHARD. AALF. RIGGS ............................... defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
The parties' Marriage Settlement..Agre.ement..dated.Octaber..9,••1999 ?••
sh " all"b"e"incorporated herein and the court has
Ctip.n.over no other claims.
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E WENDY W. RIGGS,
Plaintiff
VS.
RICHARD DALE RIGGS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 3469 CIVIL TERM
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please incorporate the attached Marriage Settlement Agreement, dated October 9, 1998, to the
above-captioned divorce action.
Respectfully submitted,
Dated: October 8, 1999
4 East Liberty Avenue
Carlisle, PA 17013
SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT Made this 9 day of 0c(v it IL _, 1998, by and between
WENDY W. RIGGS (hereinafter referred to as WIFE) and RICHARD DALE. RIGGS (hereinafter
referred to as HUSBAND);
WITNESSETH:
WHEREAS, the parties hereto were married on June 16, 1973, in Fayetteville, North Carolina;
have been and are HUSBAND and WIFE.
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of WIFE and HUSBAND to live separate and apart for the rest of their
natural lives, and the parties hereto are desirous of settling fully and finally their respective financial
and property rights and obligations as between each other, including, without limitation by specification;
the settling of 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
and/or maintenance of the WIFE, the settling of any and all claims and possible claims by one against
the other or against their respective estate.
NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants
and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which
is hereby acknowledged by each of the parties hereto, WIFE and HUSBAND, each intending to be
legally bound, hereby covenant and agree as follows:
1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: 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 as 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
I
on the part of either party hereto of any act or acts on the part of the other party which have occurred
prior to the date hereof. The parties intend to secure a mutual consent divorce.
2. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically
provided herein, this Agreement shall continue in full force and effect after such time as a final decree
in divorce may be entered with respect to the parties.
3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The parties agree that
the terms of this Agreement shall be incorporated into any divorce decree which may be entered with
respect to them.
4. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and
apart from the other party as such place as he or she may from time to time choose or deem fit. The
foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or
unlawfulness of the causes leading to their living apart.
5. INTERFERENCE: Each party shall be free from interference, authority, and contact by the
other, as fully as if he or she were single and unmarried except as may be necessary to carry out the
provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the
other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in
any way interfere with the peaceful existence, separate and apart from the other.
6. WIFE'S DEBTS: WIFE represents and warrants to HUSBAND that commencing September
1, 1998 and continuing into 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 reasons of debts or obligations incurred by her.
7. HUSBAND'S DEBT: HUSBAND represents and warrants to WIFE that commencing
September 1, 1998 and continuing into 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 reasons of debts or obligations incurred by him.
8. 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
ever 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 from breach of any provisions of this Agreement.
9. REAL PROPERTY: The marital home at 29 Eastwood Drive, Carlisle, Pennsylvania shall
be sold and the net proceeds derived from that sale shall be split equally between the parties.
10. DIVISION OF PERSONAL PROPERTY:
(a) The parties have heretofore divided their personal property to their mutual satisfaction.
Henceforth, each of the parties shall own, have and enjoy, independently of any claim of right of the
other party, all items of personal property of every kind, nature and description and wheresoever
situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE
respectfully, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually,
in all respects and for all purposes as if he or she were unmarried. All items of personal property shall
be divided between the parties as provided herein:
(b) Personal Effects: All items of personal effects such as, but not limited to: jewelry,
luggage, sports equipment, hobby collections and books, but not including furniture or any property,
personal or otherwise specifically disposed of pursuant to this agreement, shall become the absolute and
sole property of that party who has had the principal use thereof or to whom the property was given
or for whom it was purchased, and each party hereby surrenders any interest lie or she may have in any
such tangible personal property of the other.
(c) Military Pension: The HUSBAND recognizes that his military pension is a property
asset divisible as part of this property settlement agreement. Since the parties have been married and
lived as HUSBAND and WIFE for a significant period of the HUSBAND's military service prior to this
agreement, the HUSBAND agrees that thirty-five percent (35 %) of his disposable military pension shall
be the sole and exclusive property of the WIFE. The HUSBAND further agrees that he has obtained
and shall maintain in full effect and force, irrevocably, the Survivor's Benefit Program at a rate of 10%
for the benefit of the WIFE. All amounts hereunder are to be paid by allotment from HUSBAND's
Military Retirement Pay. HUSBAND is currently receiving a portion of his pension as disability pay.
The parties recognize that the WIFE has no right or claim against the disability portion of the
HUSBAND's military pension. The calculation of each parties' respective shares shall only consider
that portion of the pension which is not allocated toward disability pay. The parties understand and
anticipate that at an undetermined time in the future, HUSBAND's disability may increase proportionate
to his regular military retirement.
(d) WIFE's Pension: The parties agree that the retirement and pension that the WIFE
has earned through the Pennsylvania State Employee's Retirement Service shall be her sole and
exclusive property. The HUSBAND agrees to waive any and all rights or claims he has to any portion
of this pension and shall execute any documents necessary to confirm this waiver.
(e) The parties jointly held mutual fund administered by Edward Jones shall be the sole
and exclusive property of the HUSBAND.
(f) The tax shelter annuity acquired through Shippensburg Area School District shall be
the sole and exclusive property of the WIFE.
(g) Bank Accounts: The parties shall equally share the business account established with
Financial Trust. The WIFE shall receive the first $1,000.00 that is held in the parties' joint savings
account. The remainder shall then be split evenly between the parties.
(h) Motor Vehicles: The parties own a number of motor vehicles that they wish to divide
between themselves. The 1997 Chevrolet Blazer shall be the sole and exclusive property of the WIFE,
together with any lien thereon. The 1996 Suzuki Sidekick and 1984 Chevrolet Blazer will be the
property of the HUSBAND, together with any liens encumbering those vehicles. The 1977 pickup truck
that is jointly owned by the parties shall be sold and the proceeds raised from that sale shall be split
evenly between the parties. The parties agree to execute any and all documents necessary to effect
transfer of title on these vehicles in accordance with the provisions stated above. Each party shall
independently refinance the obligation owing upon their respective vehicle, and shall be solely
responsible to make payments on any vehicle in his or her respective possession. Each party shall also
be responsible to insure the vehicles in their respective possession.
(i) Term Life Insurance: The parties agree to maintain all term life insurance policies
currently in existence as of the date of execution of this document. Neither party shall change the
beneficiary of such policies without the prior written consent of the other party.
0) Home Business: The parties agree that the business known as Wood Artistry by
Wendy Riggs that has been conducted out of their home jointly by the parties shall become the sole
property of the WIFE. The HUSBAND waives any and all rights or claims that he has to any income
derived from the business, any assets that are associated with the business, and any inventory associated
with the business. As of the date of execution of this document, the WIFE shall hold the HUSBAND
harmless and indemnify him from any and all liability arising from the conduct of the business. The
WIFE shall also be solely responsible for any debts that arise from the conduct of the business.
(k) WIFE's Inheritance: The parties agree that any property or funds that the WIFE has
received as a result of the inheritance from her mother shall remain her property solely. The
HUSBAND waives any claim or interest that he may have regarding such property or funds.
(1) Debts: The parties agree that they shall split the existing debt equally between them.
This division will be in any manner that is mutually agreed upon between the parties. The parties
further agree that effective September 1, 1998, they will attempt to modify their personal finances in
such a way so as to confirm that all future debt incurred at that time shall be associated solely with the
party who incurred that debt. Each party agrees to waive any right to reimbursement for any such post-
separation debt incurred and satisfied. The parties may at their mutual agreement utilize the proceeds
from the sale of the marital home to satisfy any pre-existing joint debts. Such use of the proceeds of
the sale of the real estate must be based upon a mutual agreement of the parties to do so.
11. AFTER ACQUIRED PERSONAL PROPERTY: Each of the parties shall hereafter own and
enjoy, independently of any claims or right of the other, all items of personal property, tangible or
intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as
fully and effectively, in all respect and for all purposes, as though he or she were unmarried.
12. ALIMONY: Each party hereby waives any right or claim they may have to receive alimony,
spousal support, alimony pendent lite or other maintenance that they may have as a result of the
separation or divorce action.
13. COUNSEL FEES: The parties shall equally share in all counsel fees associated with the
preparation of this document and the pursuit of a divorce.
14. OPPORTUNITY TO REVIEW: Both parties have had ample opportunity to review this
agreement. By executing the document, they confirm that they understand the terms of the agreement
and find those terms to be acceptable to them. Each party has had the opportunity to review the
agreement with counsel of his or her choice. The WIFE has elected to be represented by James J.
Kayer, Esquire. The HUSBAND has elected to represent himself, after having been advised that he
has the right to obtain independent counsel of his own. Each party has fully disclosed their assets and
agree that no attempt at fraud or duress has been made in the execution of these documents.
15. DI_ VORCE: The parties hereto agree to enter into a mutual consent divorce. WIFE agrees
to pursue the divorce and to be the Plaintiff therein, HUSBAND agrees to sign the necessary
documents, including an Affidavit of Consent and further instruments that may be reasonably required
to give full force and effect to the provisions of this Agreement.
16. WAIVER OF CLAIMS: 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 shall 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, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to
take against the Will of the other, and right to act as administrator or executor of the other's estate, and
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.
17. BREACH: 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 for such breach or seek such other remedies
or relief as may be available to him or her, and the party breaching this contract shall be responsible
for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement.
18. VOID CLAUSES: 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.
19. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience
only. They shall have no effect whatsoever in determining the rights or obligations of the parties
20. INDEPENDENT SEPARATE COVENANTS: 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.
21. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request
of the other, execute, acknowledge and deliver to the other party any and all further instruments that
may be reasonable required to give full force and effect to the provisions of this Agreement.
22. APPLICABLE LAW: This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980.
23. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to
the benefit of the parties hereto and their respective heirs, executors, administrators, successors and
assigns.
24. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties
and there are no representations, warranties, covenants or undertakings other than those expressly set
forth herein.
25. TH DIFICATION AND WAIVER: A modification or waiver of any of the provisions of this
Agreement shall be effective only if made in writing and executed with the same formality as this
Agreement. The failure of either 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.
26. WAIVER OF RIGHTS: The parties hereto have been informed of their rights or have been
advised to seek counsel to inform them of their rights under and pursuant to the Divorce Code, Act of
April 2, 1980, Number 1980-26, particularly the provisions for alimony, alimony pendente lite,
equitable distribution of marital property, counsel fees or expenses. Both parties agree that this
Agreement shall conclusively provide for the distribution of property under the said law and hereby
waive, release and relinquish any further rights they may respectively have against the other for
alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses.
From the date hereof, each party may acquire either personal or real property in their own name. Any
property so acquired shall be owned solely by the individual and shall not be subject to any claim
whatsoever by the other party.
27. EXECUTION OF DOCUMENTS: Both parties hereby agree to execute any documents
required to implement this Agreement.
28. FINANCIAL DI CLOS RE: The parties confirm that they have relied on the substantial
accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year
first above written.
Win ss ,--
WENDY . RIGGVU
Witness
RICHARD DALE RI
WENDY RIGGS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. ; CIVIL ACTION - LAW
RICHARD DALE RiGGS, : NO. 99 - 3469 CIVIL TERM
Defendant : IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please 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 the complaint: Acceptance of Service signed June 14, 1999
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 the Plaintiff 10/12/99; By the Defendant 10/14/99.
B. (1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the Divorce
Code: none
(2) Date of service of the Plaintiffs affidavit upon the Defendant: none
4. Related claims pending: The parties' Marriage Settlement Agreement dated October 9, 1999 is
incorporated herein and the court has jurisdiction over no other claims.
5. Complete either (a) or (b).
A. Date and manner of service of the notice of intention to file praecipe to transmit record,
a copy of which is attached: none
B. Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary:
10/26/99; Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary 10/26/99.
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Attorney for
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WENDY W. RIGGS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 - t CIVIL TERM
RICHARD DALE RIGGS, 3
69
Defendant : 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 maybe 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 divorce is indignities or irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland
County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES
OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT
TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland county is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
James J. Kayer, Esquire
Attorney for Plaintiff
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
_.
WENDY W. RIGGS,
Plaintiff
VS.
RICHARD DALE RIGGS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE
COMES NOW, Plaintiff WENDY W. RIGGS, through her attorney, James J. Kayer, Esquire and
avers as follows:
COUNT I - DIVORCE
1. Plaintiff is WENDY W. RIGGS, who resides at 127 Cumberland Avenue, Shippensburg,
Franklin County, Pennsylvania, 17257.
2. Defendant is RICHARD DALE RIGGS, who resides at Apartment 104, 5082 Lilac Lane,
Harrisburg, Dauphin County, Pennsylvania, 17111.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 16, 1973 in Fayetteville, North Carolina.
5. There have been no prior actions of divorce filed in this matter.
6. Defendant is a former member of the United States Armed Forces.
7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of
the Divorce Code.
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.
• 1
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
James J. Kayer, ts(
Liberty Loft
4 Libe y Aven e
Carlis , PA 17013
(717) 3-7922
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. The language of the document ntay, in part,
be the language of my counsel and not my own. 1 have read the statements made in this
document and to file extent that it is based upon information which I have given to my counsel,
it is true and correct to the best of my knowledge, information and belief. To the extent that the
contents of the statements are that of counsel, 1 have relied upon counsel in making this
Verification. 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 ( 1999
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WENDY W. RIGGS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 - CIVIL TERM
RICHARD DALE RIGGS, 34(ocl
Defendant : IN DIVORCE
ACCEPTANCE OF SERVICE
1, Richard Dale Riggs, hereby accept service this d, of June, 1999 of the Notice to Defend and
Complaint in Divorce tiled in the above captioned matter.
Richard Dale Riggs
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Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 3469 CIVIL TERM
RICHARD DALE RIGGS,
Defendant
: IN DIVORCE
UNDER & 3301(c) OF THE DI VORCER r yr
CODE
1 consent to the entry ofa 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. I understand that 1 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 8, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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.
4, 1 understand that f may lose rights concerning alimony, division of property, lawyer's fees or expenses
if 1 do not claim them before a divorce is granted.
1 verify that the statements made in this Waiver and Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to
authorities.
DATE: X02 ?/ 1999 /,)`?J
WENS W. RIGGSJ (/
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Kayer'and Brown r'
".A Professiorial corporation,
-' Liberty Loft '•,4 E. Liberty Avenue . •
! Carlisle, PA 17013
(717) 243-7922
WENDY W. RIGGS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
RICHARD DALE RIGGS,
Defendant
: CIVIL ACTION - LAW
:NO.99-3469 CIVILTERM
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER & 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of P, final decree of divorce without notice.
2. 1 understand char 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 1 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 8, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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.
4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses
if 1 do not claim them before a divorce is granted.
I verify that the statements made in this Waiver and Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unswom falsification to
authorities.
DATE: IyOC-T 1999 -'
RICHARD DALE RIGG