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HomeMy WebLinkAbout99-03605'` r:' t ;?,? 1 •? ,' '5 ".y 1? O ?''i ':? • 7 \ nk, ;?. M v ? '',, f's rExpAr f. A ?i? ',i;jG , ' i ?? a. ?,n± `? te• •:e;' •R• {?• •:K• •:?• {f: {?. 'N'•ti :may tiP• :e• •:E• ,g. 'C' CO:• te:• {?• t?•'.::eC:;ex??K::Q•: yep ?+ •:N" ea MJ -- i+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY h> STATE OF PENNA. vw? :. ERICK J. HALE ti Plaintiff N h. 3605 1999 Versus SHERRY A. PANZA i '. _.. __ Defendant i DECREE IN ot C o t AND NOW, ..-`!!.!'W, , . •s!?/ g .. , . • it is ordered and decreed that ... Erick. J.. Hale, • ...... , plaintiff, and .............SherrX. A.. Fame............................. , defendant, are divorced from the bonds of matrimon e i ii y f • 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; g ............................. ................................. is ............................... .............. /Attes p Prothonotary , G( _ ?'• .?: :,?: .5;. {A. rw. :t• •'r:• tit;. :a?. •:e:• G c?} •95 •:N •A:• •:?: {?> cE. .:r• •:c• :ei Jr. •:W: +d: •:e:... :e:• •:?: •i i:X'. ,nr.. ? l 'l?'1?;3, ,.F.y , ? s ?,,, ,. 2 ;;:?;,? THIS AGREEMENT, MADE THIS 13th day of October , 1999, by and between ERICK J. HALE Plaintiff (HUSBAND) And SHERRY A. PANZA, (Defendant (WIFE) WITNESSETH: WHEREAS, HUSBAND and WIFE were legally married on February 19, 1998 in Cumberland County, Pennsylvania. WHEREAS, No children were born out of this marriage; WHEREAS, differences have arisen between HUSBAND and WIFE in consequence of which they desire 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 arising between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony and\or maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. Now THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for 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. INCORPORATION OF PREAMBLE. The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of this Agreement. 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS, This Agreement shall not be considered to affect or bar the rights of HUSBAND and WIFE to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no-fault divorce pursuant to the terns of Section 33010 of the Divorce Code in HUSBAND's Dauphin County Divorce Action docketed to number 3605 S 1999. Upon the signing of this Agreement, the parties shall execute and file all documents and papers, including affidavits of consent, necessary to finalize said divorce. 3. 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. q, AGREE D NT 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. 5. NON-MERGER. It is the parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall continue to have independent contractual significance. Each party maintains his or her contractual remedies as well as court ordered remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. Those remedies shall include, but not be limited to, damages resulting from breach of this Agreement, specific enforcement of this Agreement and remedies pertaining to failure to comply with an order of court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in effect and as amended or hereafter enacted. 6. DATE OF EXECUTI/Z 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. 7. DISTRIBUTION DATE. The transfer of property, funds and/or documents provided 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. S. ADVICIR OF COUNSEL The provisions of this agreement and their legal effect have been fully explained to the Husband by his respective counsel, Bryan S. Walk, Esquire, for HUSBAND. The wife acknowledges she has the absolute right to consult with an attorney of her choice in regard to this agreement, but specifically has decided not to seek legal representation in regard to the pending Divorce matter. The parties acknowledge that they fully understand the facts and have been fully informed as to their obligations and they acknowledge and accept that this Agreement is, in 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 illegal agreement or agreements. 9. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS, Each party understands that he or she has the right to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have the right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties understand that a court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and is in his or her best interests, and that the Agreement is not the result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either party. Both parties hereby waive the following procedural rights: a. The right to obtain an inventory and appraisement of all marital and non-marital property as defined by the Pennsylvania Divorce Code. b. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code. C. The right to have property identified and appraised. d. The right to discovery as provided by the Pennsylvania Rules of Civil Procedure. e. The right to have the court determine which property is marital and which is non- marital, and equitably distribute between the parties that property which the court determines to be marital, and to set aside to a party that property which the court determines to be that parties' non-marital property. f. The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement and/or arising out of the marital relationship, including but not limited to possible claims for divorce, spousal support, alimony, Pendente Lite (temporary alimony), equitable distribution, visitation, and counsel fees, costs and expenses. 10. PERSONAL PROPERTY The parties acknowledge that they have previously agreed to a division of all their tangible personal property including, but not limited to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other tangible personal property. With respect to said division the parties agree that HUSBAND shall receive as his sole and separate property all items currently in his possession and WIFE shall receive as her sole and separate property all items of tangible personal property in her possession. Each of the parties hereto does waive, release, and forever abandon any right and all title, interest and claim, in and to the tangible personal property to become the property of the other party pursuant to the terms of this paragraph. 11. AFTER ACQUIRED PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, with or without non-marital assets, after the date of this Agreement, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried and each party hereby waives, releases, renounces and forever abandons any right, title, interest and claim in and to said after acquired property of the other party pursuant to the terms of this paragraph. 12. DIVISION OF VEHICLES. With respect to the vehicles owned by one or both of the parties, they have already been divided. 13. EACH PARTY RETAINS OWN PENSION PLANS. Each of the parties does specifically waive, release, renounce and forever abandon all of his or her right, title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan, Profit Sharing Plan, 401-K Plan, Keough Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee benefit plan of the other party, whether acquired through said party's employment or otherwise, and hereafter said Pension Plan, Retirement Plan, Profit Sharing Plan, 401-K Plan, Keough Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee benefit plan shall become the sole and separate property of the party in whose name or through whose employment said plan is carried. 14. DIVISION OF BANK A O NT / TO /I IF IN 1RANCE The parties acknowledge and agree that they have previously divided to their mutual satisfaction all of their bank accounts, certificates of deposit, IRA accounts, bonds, shares of stock, investment plans and life insurance cash value and hereafter WIFE agrees that all said bank accounts certificates of deposit,. IRA accounts, bonds, shares of stock, investment plans and life insurance cash value in the possession of the HUSBAND shall become the sole and separate property of HUSBAND and HUSBAND agrees that all said bank accounts, certificates of deposit, IRA accounts, bonds, shares of stock, investment plans and life insurance cash value in the possession of the WIFE shall become the sole and separate property of WIFE. Each of the parties does specifically waive, release, renounce and forever abandon whatever right, title, interest or claim, he or she may have in any that all said bank accounts, certificates of deposit, IRA accounts, bonds, shares of stock, investment plans and life insurance cash value that is to become sole property of the other pursuant to the terms hereof. 15. MARITAL DEBTS The parties acknowledge that they have previously divided the obligations and payments required thereof of any debts and obligations arising during the marriage and in accordance therewith any obligation being paid by a party will continue to be so paid and said party shall indemnify and protect the other party harmless therefrom. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and each agrees to pay it as the same shall become due. Each party agrees to indemnify and hold the other party and his or her property harmless from any and all such debts, obligations and liabilities assumed by a party pursuant to this Paragraph. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which the party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. 16. WAIVER OF INHERITANCE, Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, interest or claim, if any, either party may have in and to any inheritance of any kind or nature whatsoever previously or in the future received by the other party. 17. -WIFE'S DEBTS, WIFE represents and warrants to HUSBAND that since the parties' separation she has not and in the future will not contract or incur any debt or liability for which HUSBAND or his estate might be responsible and shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 18. HUSBAND'S DEBTS HUSBAND presents and warrants to WIFE that since the parties' separation he has not and in the future will not contract or incur any debt or liability for which WIFE or her estate might be responsible and shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 19. BANKRUPTCY. The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to terminate this Agreement in which event the division of the parties's marital assets and all other rights detennined by this Agreement shall be subjected to court determination the same as if this Agreement had never been entered into. 20. FINAL. EOUITABL DI TRIB tTION OF PROPERTY. It is the intent, understanding and agreement of the Parties that this Agreement is a full, complete and equitable property division. 21. WAIVER OF ALIMONY ALIMONY P ND NT IT SPOUSAL, The parties hereto agree and do hereby waive any right and/or claim they may have, both now and in the future, against the other for alimony, alimony pendente lite, spousal support, maintenance, counsel fees and costs. The parties agree that husband will provide Medical and Dental insurance for Wife for a maximum period of 12 months. The agreement to provide Medical and Dental insurance is only binding upon the husband as long as he is employed by 22. PERSONAL RIGHTS. HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. HUSBAND and WIFE shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 9 23. MUTUAL RELPA c HUSBAND and WIFE each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and whatever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or courtesy, or claims in the nature of dower or courtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) the Commonwealth of Pennsylvania, (b) State, Commonwealth or Territory of The United States, or © any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses whether arising as a result of the marital relation or otherwise, except, and only except, all rights, and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of HUSBAND and WIFE to give each other by execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 10 24. MODIFICATION AND WAIVFR Any modification or waiver of any provision 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. 25. MUTUAL QpERATION. 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. 26. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 27. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 28. OTHER DOCUMENTATION. WIFE and HUSBAND covenant and agree that they will forthwith, execute any and all written instruments, assigns, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be executed in order to carry out fully and effectively the terms of this Agreement. 29. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right to such party hereafter to enforce the same, nor shall the waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any obligations herein. 30. 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. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 12 31. S . A I •ITY. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the condition precedent, shall in no way avoid or alter the remaining obligations of the parties. 32. GOVERNING LAW. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 33. HEADINGS NOT PART OF AGREEMENT. Any heading preceding the text of the several paragraphs and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 13 BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby have hereunto set their hands and seals the day and year first above written 7 WITNES Erick J. Hale WITNES .. `?a ?2ti Gl ? L Sherry A. anza 14 t f_ v C) S- C ?L- r- ?16 ci :16 U ? v ERICK J. HALE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. No. 1999 3 601-- lei ci -/ SHERRY A.PANZA Defendant CIVIL ACTION - 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 Section 3301 c or 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service by Defendant by Personal Delivery, on July 12,1999 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 Plaintiff on?ctober 13 ; and signed by Defendant on (b) (1) Date of execution of the PLAINTIFF'S Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the PLAINTIFF'S Affidavit upon the DEFENDANT: 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (check one) of the Divorce Code; the Divorce Code; (a) Decree to be entered under 3301(d) (I) (b) Decree to be entered under 3301 © of (C) Not Applicable. (See Waiver filed by Defendant on October 13-1999 and filed by Plaintiff on Date: BY: Br S. Walk A torney ID No. 63881 Counsel for Plaintiff tl: U'7 4?n 6+ ?z4 ? L: aY ? (7J U ? V ERICK J. HALE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. No. 1999 3l0?? SHERRY A. PANZA Defendant CIVIL ACTION - 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 I you, including custody or visitation of your children. \ When 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 in the Office Of Prothonotary Dauphin County Courthouse, Harrisburg, PA. 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 PA 17013 (717) 249 3166 or 1 800 990 9108 ERICK J. HALE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. SHERRY A. PANZA Defendant No. 1999 - 3G o S CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Erick J. Hale, by Bryan S. Walk Esq., and represents as follows: DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Erick J. Hale, who currently resides at 327 West Winding Hill Road, Mechanicsburg, Cumberland County, PA 17055 and has resided there since on or about one month.. 2. Defendant is Sherry A. Panza, who currently resides at 237 West Locust Street, Mechanicsburg, Cumberland County, PA 17112 and has resided there for one year. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint 4. The Plaintiff and Defendant were married on February 19, 1998, in Cumberland County, PA. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff avers that there are no children the age of 18. 7. The Plaintiff is a citizen of the United States of America. 8. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 9. The marriage is irretrievably broken. 10. The 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. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and the Defendant. Bryan S. Walk I.D.# 63881 108 - 112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 ATTORNEY FOR PLAINTIFF ERICK J. HALE V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA SHERRY A. PANZA Defendant No. 1999 CIVIL ACTION - DIVORCE I hereby certify that on the 11 th Day of JANE , 1999, A copy of the Divorce Complaint was served by certified mail, return receipt requested, addressee copy of Plaintiffs Complaint In Divorce upon the person named below, in accordance with the applicable Rules of Procedure, addressed as follows: Sherry A. Panza 237 West Locust Street Mechanisburg, PA 17055 Bryan. Walk Attorney ID No. 63881 108-112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 Counsel for Plaintiff 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. Section 9909, relating to unsworn falsification to authorities. Date: ?^,//? yet C I /, l// Erick J. H e Z-1 t-i 2 C, ? Cj) N h M y ? 1io v° h ERICK J. HALE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. SHERRY A. PANZA Defendant No.300Y-1999 CIVIL ACTION - DIVORCE I Sherry Panza, hereby acknowledge that I was served a copy of the Divorce Complaint, in this matter on _'1999. Date 2 4 Date -'-1 I?21() 9 Date a? Sherry A. Pan / W' ess n ss Lr it w Q cn 4 F = !l : CO AFC ? a y 2 ? U ERICK J. HALE Plaintiff V. SHERRY A.PANZA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 36o- 1999 L CIVIL ACTION - DIVORCE PLAINTIFF' 3 AFFIDAVT OF Cnrrarram AND NAME OF CO nacFr run 1. A Complaint in Divorce under Section 3301(C)of the Divorce Code was filed on June 14,- 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. I 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. Section 4904 relating to unsworn falsification to authc (/?? j Date: } a% y WW O cn S Cc n. d o SO) .. w iiw Icl o cn ?T v ERICK J. HALE Plaintiff V. SHERRY A.PANZA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 1999 - 3 6 0 CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO R nrTF em r?rrnv na n DECREE UNDER SECTION 3301 (c)OF THE PIVORCE 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. Section 4904 relatinq..to unsworn falsification to authoriti Date:-. Hale Q U^ t „ UC 7C U;, co U3 ? uj ?L;I - ~ _) if 1 C ti ) O i U ERICK J. HALE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. No. 1999 - 3 6 O Y? SHERRY A. PANZA Defendant CIVIL ACTION - DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(C)of the Divorce Code was filed on June 14, 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. I 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. Section 4904 relating to unsworn falsification to authorities. Date: /%//3/!! S1?C G c -1Z-- ?herry A. Panza Qd o? u: n- j ??.. V 01 O+ 7 U ERICK J. HALE Plaintiff V. SHERRY A.PANZA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 1999 - 3605- CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DTVORC DECREE UNDER SECTION 3301 (c)OF TEE DIVORCE rnny 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. Section 4904 relating to unsworn falsification to authorities. Date: &Zl - 10-L? Q Sherry A. nza? tr u: r ?F 4 i nY wn. .JZ i f- O n cl_ v 0*1 U ERICK J. HALE V. Plaintiff SHERRY A. PANZA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 1999 - 36,03 CIVIL ACTION - DIVORCE ERICK J. HALE :200 54 3782 SHERRY A.PANZA :174 60 8602 ,7 4 ? J - co .?? Ci ??_ ~ c fLj o ??a o cr, COAILIO/Iwr, A L 1 N of rE 11NSYL VAMA II Ins 151 nrv.E no bFrnn fXIEN for n( ALT II VITAL neconos n ECOnD OF ;;;;;;? ------ DIVOnCE On ANNULMENT Cumberland x E (CHECK ONE) $IAIE IILF IIUMo Fn S IAT I rILE nn II HUSBAND 1. UAMF !liar/ feuuntrl Lnr i. OAI! nnrr M/ Erick . - Hale Or a nnl 7 26 75 ). nF, $IU EIICF . SIRrI Or q, D. .... _...fp n pr '?cs -[?jV/IIY _ - nrllr _ Cmecnhan?°cbur ) ?. rLnCf T, O/ pr.rrn y.[br 327 West Winding Hill Road g Cumberland PA O1 _ - MIN Pennsylvania n, Nyr,nlFn n ACE 3. usunl occurnrlorl Or nua Fl wIUIF 1 ? nI.ACK or NF n11..Jlyl AnnIAOE ? Laborer WIFE n. I.IAI(IEII NAME frpw L11iIINN EL.11/ 9, OAIF Ltgnln O.Y fear ----- ..Sherry T A. Panza OF o1nl)l 8 9 63 O. nF..$IDFPICE S"I"or!(.U. C., Y. np.a. pr l r. p. QI (cumbe$Yland) 11, FLACF IAnle p/ r."i$n Ww(r yl 4807 Delbrook Road Mechanicsbure PA Dr vo,f.,o.FI'1.-in q, rIUVOFn [1. IIe LF T•TGECUfn IDrv vnu l E nLAtr. OT 111 n l$n•aNrl AIA nn1AG 2 r ' lJ ? ? Is. rLACE OF ICO run Yl (S?ltoJOmfm CaynyY/ 10. DAIEUr (Abnml lOFYI 1'A7, Dn l l ul5 IA mnmmcE Ti Cumberland Pennsylvania 1Anmm?cE 2 19 98 n If UTAn En OF Cm L• III. NVhIni O oEFE fm Enl c f 177 IE. Tln nrnrF ?FFRE r 0 nF111111$ OnEN UNOEn 10 HU$nA11U WIFE OIIIEIIISf•[IIY I IIU$'J AN] YIIFE OlllEn l$p•[III I r.lnnnlncE D 0 I Q ED ? © ? ? - --- CIIILOnE11 TOM r[GV5[OOY a • Oi11En Is"I"I ]I. LE CAL OnOUIIDS rOn IIr DIVOnCE On AN"' IT CUSTOOYOF ? I i bl B k _ lI. DATE Or OECrIEE Ihlanflr/ 10"I ll'url rretr eva y ro en ]J. UAIE nEr'Ufll SEMI lM1lorrlhl TUry Yror IO VITAL IIECOIIOS 0.. $IOIIAIUnEOF lnAr I:CNEING CLEnY. v? gn u z i c, LL q ^' VJ ) v O MLL ??2 i U CYN U