HomeMy WebLinkAbout99-03628®`16
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF PENNA.
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Beth A. Walter,
Plaintiff,
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Carson L. Walter, Sr.
'99 - 3628
.................
Defendant.
DECREE IN
DI VORCE
AND NOW,... ?(...??.... 9.99.... it is ordered and
decreed that ...... 8?Ch.A..Walter....................... plaintiff,
and ......... Carson. L., Walter,,. sr.• .. , .... , .. • ........... defendant,
are divorced from the bonds of matrimony.
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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;kbllllQ
n .., The attached.mgrttgJ.agreement .between .the.parties .dated.July.6,.1999,, '
shall be incorporated into this Decree in Divorce pursuan to said Marital
Agreement :.... ....................... J .. .............
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p Ry The Cour
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Attest: J.
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Prothonotary
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MARITAL AGREEMENT
THIS AGREEMENT, made this
t4 day of 1999, by
and between Beth A. Walter, hereinafter-referred-to as Wife, ' f 347 Warmspring Road,
Chambersburg, Hamilton Township, Franklin County, Pennsylvania 17201, and Carson
L. Walter, Sr., hereinafter-referred-to as Husband, of 37 Sand Bank Road, Shippensburg,
Southampton Township, Cumberland County, Pennsylvania 17257.
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married on
June 28, 1986, in Chambersburg, Franklin County, Pennsylvania; and
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,
and the parties hereto are desirous of settling some of their respective financial and
property rights and obligations as between each other including, without limitation by
specification: the equitable division of marital property and 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.
NOW, THEREFORE, in consideration of the premises and of the mutual
promises, covenants and under takings hereinafter set forth which are hereby
acknowledged by each of the parties hereto, Wife and Husband, each intending to be
legally bound hereby, covenant and agree as follows:
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, if such grounds 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, 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 prior to or which may occur
subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault
divorce pursuant to the terms of Section 3301(c) of the Pennsylvania Divorce Code of
1980, as amended.
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.
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENS511RG, PA 112511391
AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties agree that the terms of this Agreement may be incorporated into any
divorce decree, which may be entered with respect to them.
DATE OF EXECUTION
The "date of execution" or "execution date" of the Agreement shall be defined as
the date upon which it is executed by the parties if they have each executed the
Agreement on the same date. Otherwise, the "date of execution" or "execution date" of
this Agreement shall be defined as the date of execution by the party last executing this
Agreement.
ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained
to Wife, by Jerry A. Weigle, Esquire, who is attorney for Wife and who prepared this
marital agreement. Husband acknowledges that he has been advised of his right to seek
independent legal counsel and he has decided not to do so. Both parties acknowledge
that they fully understand the facts and have been fully informed as to their legal rights
and obligations and understand the same. The parties hereto further 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 improper or illegal agreement or
agreements.
PERSONAL RIGHTS
Wife and Husband 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 as they may select. Each may, for his or her separate use or benefit, conduct, cant'
on and engage in any business, occupation, profession or employment, which to him or
her may seem advisable. Wife and Husband 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.
SEPARATION DATE
II The parties do hereby acknowledge that they separated on Monday, May 17,
1999. It is hereby agreed that May 17, 1999, shall be the separation date for purposes of
equitable distribution under the Pennsylvania Divorce Code unless altered by subsequent
agreement of the parties in writing and signed by each of the parties. No attempt at
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257.1397
reconciliation shall be considered to alter the separation date unless evidenced by written
agreement.
MOTOR VEHICLES
A. The parties agree that Wife shall become the sole and exclusive owner of
the parties' 1993 red Toyota Tercel motor vehicle. Wife shall be solely responsible for
all payments on the automobile loan for the 1993 Toyota Tercel. Husband agrees to sign
any documents in order to grant vehicle over into Wife as her sole possession, Wife will
bear any and all costs involved in said transaction.
B. The parties agree that Husband shall become the sole and exclusive owner
of the parties' 1984 brown Toyota Corolla motor vehicle. Husband shall be solely
responsible for all payments of the automobile loan for the 1984 ToyotaCorolla. Wife
agrees to sign any documents in order to grant vehicle over to Husband as his sole
possession, Husband will bear any and all costs involved in said transaction.
PERSONAL PROPERTY
A. Wife will remove the following items from the marital residence at a
mutually convenient time for both parties no later than July 1, 1999. Wife will have
exclusive ownership of the following items:
Green loveseat recliner;
Cherry kitchen hutch with all contents;
Sharp surround sound stereo system;
9-drawer brown dresser located in Jennifer's room;
Drawer bed located in Jennifer's room;
White Maytag washing machine;
Gas powered push mower; and
Weed wacker.
B. Husband and Wife do hereby acknowledge that with the exception of the
items specified in Paragraph A they have previously divided their tangible personal
property, including but not limited to jewelry, clothes, furniture, furnishings, rugs,
carpets, household equipment and appliances, vehicles, pictures, books, works of art and
other personal property and hereafter Wife agrees that all of the property in the
possession of Husband shall be the so1,2 and separate property of Husband and Husband
agrees that all of the property in the possession of Wife shall be the sole and separate
property of Wife. The parties do hereby specifically waive, release, renounce and forever
abandon whatever claims, if any, he or she may have with respect to the above items,
which shall become the sole and separate property of the other.
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EA51' KING STREET - SHIPPENSBURG. PA 17251.1397
AFTER-ACQUIRED PERSONAL PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim 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 respects and for all purposes, as though he or she were not married.
REAL ESTATE
The parties hereto acknowledge and agree that they are owners of land with
improvements situated at 37 Sand Bank Road, Shippensburg, Southampton Township.
Cumberland County, Pennsylvania, and more specifically described in Cumberland
County Deed Book B33 , at Page 64. For and in consideration of the mutual covenants
and agreements herein contained in the body of this instrument, Husband and Wife
further stipulate and agree that said real estate shall be retained by Husband. Husband
shall cause the parties' mortgage at York Federal Savings and Loan Association to be
refinanced so as to remove Wife's name from any liability therefor. In the event that
Husband is unable to refinance the above-referenced mortgage obligation solely in his
own name as contemplated above, Husband agrees to assume sole responsibility, as
between Husband and Wife, for any and all mortgage payments due thereon and to
indemnify and hold Wife harmless from any liability whatsoever on said mortgage
obligation.
WAIVER OF SPECIFIED CLAIMS BY HUSBAND
Husband hereby waives any and all right to claim any interest or share in Wife's
Federal Employee Retirement and Thrift Savings Plan valued at approximately Ten
Thousand Dollars ($10,000.00) when totaled together.
WARRANTY AS TO EXISTING OBLIGATIONS
Each party represents that he or she has 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 from 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.
WARRANTY AS TO FUTURE OBLIGATIONS
Wife and Husband each covenant, warrant, represent and agree that each will now
and at all times hereafter save harmless and keep the other indemnified from all debts,
charges and liabilities incurred by the other after the execution date of this Agreement,
except as may be otherwise specifically provided for by the terms of this Agreement and
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
that neither of them shall hereafter incur a liability whatsoever for which the estate of the
other may be liable.
LEGAL FEES
Wife shall pay the cost of legal fees incurred in preparation of this marital
agreement and all legal fees and court costs in connection with obtaining a 3301(c) No-
Fault Divorce. Husband agrees to cooperate by executing the necessary consents and
other documents required to effectuate said divorce, as requested by Wife's attorney.
INCOME TAX RETURNS
The parties agree to file separate federal and state income tax returns.
DEPENDENCX EXEMPTIONS FOR INCOME TAX
For purposes of federal and state income taxes, Wife shall claim herself and both
minor children. The parties agree to file separate tax returns.
MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim and forever
discharge the other and the estate of each 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, of whatsoever nature and wheresoever 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, 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 a surviving
spouse to participate in a deceased spouse's estate, whether arising under the laws of (a)
Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any
other country, 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 to each other by
the 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 provision thereof.
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSGURG. PA 17257.1397
WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in
writing and signed by both parties and no waiver of any breach hereof or default
hereunder shall be deemed a waiver of any subsequent default of the same or similar
nature.
DIVORCE
The parties hereto agree to enter into a mutual consent divorce under Section
3301(c) of the Pennsylvania Divorce Code of 1980, as amended. Wife agrees to pursue
the present divorce action filed to No. 4q-46,,43 Civil, 1999 in the Court of
Common Pleas of Cumberland County, Pennsylvania, and to be the Plaintiff therein.
Husband agrees to sign the necessary documents, including the Affidavit of Consent, at
such time after the ninety (90) days of filing of the Complaint and further instruments
that may be reasonably required to give full force and effect to the provisions of this
Agreement.
MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and all
steps and execute, acknowledge and deliver to the other party any and all future
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.
LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania.
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.
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.
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSRURG, PA I72S7-1397
WAIVER OF ALIMONY AND OTHER 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, Action of
April 2, 1980, Number 1980-26, as amended, 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 except as specifically provided for in this
agreement, 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.
FINANCIAL DISCLOSURE
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.
ENTIRE AGREEMENT
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.
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 of such party hereafter to enforce the same, nor shall the waiver of any breach of
any provision hereof be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict performance of any other
obligations herein.
SEVERABILITY
If any term, condition, clause or provision of this Agreement shall be determined
or declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provisions shall be stricken from this Agreement and in all other respects this
Agreement shall be valid and continue in full force, effect and operation. Likewise, the
II failure of any party to meet her or his obligations under any one or more of the
paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall
in no way void or alter the remaining obligations of the parties.
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 12G EASI KING STREET - SNIPPF_NSBURG, PA t72S7.1397
HEADINGS NOT PART OF AGREEMENT
Any headings 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.
VOLUNTARY EXECUTION
The provisions of this Agreement and their legal effect have been fully explained
to the parties by their respective counsel, and each party acknowledges that the
Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not
the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the
day and year first above written.
WITNESS:
BETH A. WALTER
CARSON L. WALTER, SR.
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257.1397
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
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On this, the Z _ day of ( 1999, before me a
Notary Public, the undersigned officer, per (onally-appeared BETH A. WALTER, known
to me to be the person whose name is subscribed to the within Agreement and
acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
(SEAL)
COMMONWEALTH OFPENNSYLVANI ttiurly
9MfM!;.P: *q Pu*
COUNTY OF CUMBERLAND
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On this, the 0 ? day of? ---? 1999, before me a
Notary Public, the undersigned officer, personall ppeared CARSON L. WALTER, SR,
known to me to be the person whose name is subscribed to the within Agreement and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
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MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA I7257-1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER,
Plaintiff,
V.
CARSON L. WALTER, SR.,
Defendant.
CIVIL ACTION - DIVORCE
NO. 99 - 3628
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Civil Term
Transmit the record, together with the following information, to the court for
entry of a divorce decree:
Divorce 1 Code, Grounds for divorce: irretrievable breakdown under § 3301(c) of the
.
2. Date and manner of service of the complaint: June 17, 1999, by mailing
the same postage paid, certified mail, addressee only, and return receipt requested, at
Shippensburg,Pennsylvania.
3. Date of execution of the affidavit of consent required by § 3301(c) of the
Divorce Code: by Plaintiff October 22, 1999, by Defendant October 10, 1999.
4. Related claims pending: None
5. Date Plaintiff's Waiver in § 3301(c) Divorce was filed with the
prothonotary: October 26, 1999.
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with
the prothonotary: October 26, 1999.
MARK, WEIGLE AND
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A. eigle, Esquire
Attorney f r Plaintiff
126 East King Street
Shippensburg,PA 17257
717-532-7388
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBIIRG. PA 172S7.1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER,
Plaintiff,
V.
CARSON L. WALTER, SR.,
Defendant.
CIVIL ACTION - DIVORCE
NO. (j 9. 3G ;? F Civil Term
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 judgement 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 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 Cumberland County Courthouse, Carlisle,
PA 17013.
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
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 1]25)-1397
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER, CIVIL ACTION - DIVORCE
Plaintiff,
V. NO.
99- 3 G a ? Civil Term
CARSON L. WALTER, SR.,
Defendant. IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I - IRRETRIEVABLE BREAKDOWN
AND NOW, comes the above named Plaintiff, Beth A. Walter, by and through
her attorneys, Mark, Weigle and Perkins, and Jerry A. Weigle, Esquire, and seeks to
obtain a Decree in Divorce from the above-named Defendant, upon the grounds
hereinafter more fully set forth:
1. Plaintiff , Beth A. Walter, is an adult individual presently residing at 3470
Warmspring Road, Chambersburg, Franklin County, Pennsylvania, since May 1999.
2. Defendant, Carson L. Walter, Sr., is an adult individual presently residing
at, 37 Sand Bank Road, Shippensburg, Cumberland County, Pennsylvania, since .1987.
3. The Plaintiff and Defendant are nationals and citizens of the United States
of America, and both have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of the
Complaint in Divorce.
4. The Plaintiff and Defendant were married on June 28, 1986, in
Chambersburg, Franklin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties or in any other jurisdiction.
6. Plaintiff has been advised that counseling is available and the Plaintiff
may have the right to request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
8. The parties have lived separate and apart since May 17, 1999.
9. The Plaintiff requests the court to enter a decree of divorce.
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SNIPPENSRURG. PA 17257-1397
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in
Divorce from the bonds of matrimony and for such other and further relief to which
Plaintiff shall be entitled.
MARK, WEIGLE AND PERKINS
r
Jerry Weigle, squire
Attorney for Plaintiff
126 East King Street
Shippensburg, PA 17257
717-532-7388
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSRURG. PA 172S7.1397
VERIFICATION
I verify that the statements made in the foregoing Complaint in Divorce are true
and correct. I understand that false statements herein are made subject to the penalties of
18 Pa C.S. § 4904, relating to unworn falsification to authorities.
Beth A. Walter, Plaintiff
Dated: G C
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 172574397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER, CIVIL ACTION - DIVORCE
Plaintiff,
V. NO. 99-3628 Civil Term
CARSON L. WALTER, SR.,
Defendant. IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on
June 15, 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 fmal 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 unswom falsification to authorities.
Beth A. Walter, Plaintiff
Dated: (00T (,x
MARK, WEIGLE AND PERKINS - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 172S7.1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER, CIVIL ACTION - DIVORCE
Plaintiff,
V. NO. 99-3628 Civil Term
CARSON L. WALTER, SR.,
Defendant. IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on
June 15, 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 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 unswom falsification to authorities.
Carson L. Walter, Sr., Defendant
Dated: /Q//9/9q
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 172S7.1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER, CIVIL ACTION - DIVORCE
Plaintiff,
V. NO. 99 -3628 Civil Term
CARSON L. WALTER, SR.,
Defendant. IN DIVORCE
1. I consent to the entry ofa 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 unworn falsification to authorities.
?- e f b 6 - 11)CJ o?
Beth A. Walter, Plaintiff
Dated:
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SNIPPENSOURG, PA 1]2S]-1399
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER,
Plaintiff,
V.
CARSON L. WALTER, SR.,
Defendant.
CIVIL ACTION - DIVORCE
NO. 99 - 3628 Civil Term
IN DIVORCE
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 unworn falsification to authorities.
Dated: 11411 942
Carson L. Walter, Sr., Defendant
MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SMIPPENSRURG. PA I72S7.1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER, CIVIL ACTION -DIVORCE
Plaintiff,
V. NO. 99 -3628 Civil Term
CARSON L. WALTER, SR.,
Defendant. IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Heather Carey, being duly sworn according to law, deposes and says that on June
17,1999 she served true and attested copies of Notice to Defend and Claim Rights and
Complaint in Divorce upon the Defendant, Carson L. Walter, Sr., by mailing the same
postage paid, certified mail, addressee only, and return receipt requested, at
Shippensburg, Pennsylvania, addressed as follows:
Carson L. Walter, Sr.
37 Sand Bank Road
Shippensburg, PA 17257
Heather Carey
Sworn to and subscribed before
me this 6 s day of July, 1999.
Notary Public
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MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SMIPPENSBURG. PA 17257-1397
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
BETH A. WALTER,
Plaintiff,
V.
CARSON L. WALTER, SR.,
Defendant.
CIVIL ACTION - DIVORCE
NO. Civil Term
IN DIVORCE
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