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IN THE COURT OF COMMON PLEAS 9
41
OF CUMBERLAND COUNTY I$
STATE OF PENNA.
Tracy L. Bogden °
_ ............ ..._.._. - __..__........ ._....... _......... r:
Not. 99T 9
3.6.68 ................. I r,
Vcrsns .. ,I ••
William L. Bogden ................_..
DECREE IN
DI VORCE
at 3: 3 cP. N'?
AND NOW, ........ ... 3 ..... , 19 ! ... , it is ordered and
decreed that ..........Tracy L. Bogden• • . , • , , , , , , , , , , , , , ,,, , plaintiff,
s
William, L,,Bogdgn,,,,,,,,,,,,,,,,,, defendant,
and . . . . . . . . . . . . . . . . . . . . .
are divorced from the bonds of matrimony. y
v The court retains jurisdiction of the following claims which have
s
been raised of record in this action for which a final order has not yet
been entered;
.........................................................................
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By The
Attest: /? - (-' _.. J. / ems,
is
Prothonotary (°
/C./q, y? ? ?1 JJ1 4
y9131,6E
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this , 7'1 day of ? /?
v , 1999, by
and between TRACY L. BOGDEN, of 213 W. Marble Street, Mechanicsburg, Cumberland
County, Pennsylvania (hereinafter, the "Wife") and WILLIAM L. BOGDEN, of 58 Red
Barberry Drive, Etters, York County, Pennsylvania (hereinafter, the "Husband").
WITNESSETH:
WHEREAS, Husband and Wife entered into a marriage on or about July 12, 1997, in
Enola, Cumberland County, Pennsylvania;
WHEREAS, the Husband and Wife have two children together who were born out of
wedlock, namely: Ryan M. Bogden, born July 30, 1992, and Rylee W. Bogden, born
October 9, 1996 (collectively, the "minor children")
WHEREAS, differences have arisen between Husband and Wife in consequence of
which they desire to live separate and apart from each other;
WHEREAS, Wife filed a Complaint for Divorce pursuant to Section 3301(c) of the
Divorce Code on June 16, 1999; and
WHEREAS, Husband and Wife desire to settle and determine all of their rights and
obligations under the Divorce Code of 1980, as amended, and memorialize a child custody
arrangement for the aforementioned minor children.
NOW THEREFORE, in consideration of the promises and covenants contained herein,
and intending to be legally bound, it is agreed by and between the parties hereto that:
Page 1 of 10
1. Separation. It shall be lawful for each party at all times hereafter to live
separate and apart from each other at such place as he or she from time to time shall choose or
deem fit. They shall be free from any interference, direct or indirect, by the other in all
respects as fully as if they were unmarried. They shall not harass, disturb or malign each other
or the respective families of each other. The foregoing provision 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.
2. Entry as Part of Decree. An action seeking the dissolution of the marriage is
pending in a court of competent jurisdiction. The parties hereby agree to execute the Affida-
vits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce
Decree at the earliest possible date. The parties acknowledge the availability of counseling and
both parties have waived their right to counseling. It is the intention of the parties that this
Agreement shall survive any action for divorce which may be instituted or prosecuted by either
party and no order, judgment or decree or divorce, temporary, final or permanent, shall affect
or modify the financial terms of this Agreement. This Agreement shall be incorporated, but
not merged, in any final Decree in Divorce.
3. Mutual Release. Except, and only except, for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for
the breach of any part of this Agreement, Husband and Wife each do hereby mutually remise,
release, quitclaim, and forever discharge the other and the estate of the other, for all time to
come, and for all purposes whatsoever, of and from any and all rights, title and interest, or
Page 2 of 10
claim in or against the property of the other or against the estate of the other, of whatever
nature and wheresoever situate, which he or she now has or at any time hereafter may have
against the other, the estate of the other or any party thereof. Except, and only except, for all
rights, agreements and obligations of whatsoever nature arising under or which may arise
under this Agreement or for the breach of any part of this Agreement, 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, whether real,
personal or mixed, which the other now owns or may hereafter acquire.
4. Waiver of Claims under the Divorce Code of 1980, as amended, IncludinE
but not limited to, Claims for Spousal Support Alimony, A.P L. Attorney's Fees etc..
Each party absolutely and unconditionally releases the other and the estate of the other from
any and all rights and obligations which either may have for past, present, and/or future
obligations arising under the Divorce Code of 1980, as amended, including, but not limited to
claims for support for himself or herself, spousal support, alimony pendente lite, temporary
and/or permanent alimony, counsel fees or expenses from the other party.
5. Warranty of Disclosure. Husband and Wife each represent and warrant to the
other that he or she has made a full and complete disclosure to the other of all assets of any
nature whatsoever in which such party of every type whatsoever and all other facts relating to
the subject matter of this Agreement. The parties waive their respective rights under the
Divorce Code of 1980, as amended, to obtain formal valuations and appraisals and to engage
in formal discovery to identify and value all property owned individually or jointly by a party.
Page 3 of 10
Each party has had ample opportunity to review the financial condition of the other and each
party agrees not to challenge the instant Agreement based on an allegation of lack of sufficient
disclosure of assets, debts or income.
6. Duty of Cooperation. The parties shall mutually cooperate with each other in
order to carry through the terms of this Agreement. Within ten (10) days after demand
therefore, the a party shall execute and deliver to the other any deeds, bills of sale, assignment,
consents to change of beneficiary on insurance policies, tax returns and other documents and
do or caused to be done in any other act or thing that may be necessary or desirable to the
provisions and purposes of this Agreement.
7. Breach of Agreement. In the event that either party breaches any provision of
this Agreement, the non-breaching party may seek to enforce this Agreement in a court of law
or equity, and, if a breach of the Agreement is established in a court of law or equity, the
beaching party shall pay the non-breaching party damages for said breach, if any, and all
reasonable attorney's fees, court costs and expenses which are incurred by the non-breaching
party in enforcing the Agreement.
8. Personal Property. Husband and Wife have previously agreed to the distribu-
tion of all items of personal property, including, but not limited to, motor vehicles, accounts,
and household goods. Except as provided herein, Husband agrees that all such property in the
possession of Wife shall be the sole and separate property of Wife. Except as provided herein,
Wife agrees that all such property in the possession of Husband shall be the sole and separate
property of Husband. Each of the parties does hereby specifically waive, release and renounce
Page 4 of 10
any further claims with respect to said items.
9. Waiver of Right to Share in Retirement Benefits. The parties hereby waive,
relinquish and release any and all claims and rights either may have or ever had, presently has,
or may in the future acquire, in and to any and all retirement benefits titled in either parties'
individual name, whenever acquired, including, without limitation, any and all pension and
profit sharing plans, Keoughs, 401(K)'s, I.R.A.s and any and all other assets of like kind and
character, and any appreciation in the value thereof, whether due to market conditions or the
direct or indirect contributions or efforts of either party.
10. Marital Debts. Except as otherwise provided herein, each party agrees to
assume full responsibility for any and all debts in their individual name, regardless of whether
the debt(s) is/are marital or non-marital. Each party agrees to indemnify and hold the other
party harmless from any liability, cost or expense, including attorneys' fees, which are
incurred in connection with such debt(s).
11. Other Debts. Wife represents and warrants to Husband that since the parties'
separation she has not and in 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 Husband
harmless from any and all claims or demands made against him by reason of debts or obliga-
tions incurred by her. Husband represents and warrants to Wife that since the parties'
separation he has not and in the future he will not contract or incur any debt or liability for
which Wife or her estate might be responsible and shall indemnify and save Wife harmless
from any and all claims or demands made against her by reason of debts or obligations
Page 5 of 10
incurred by him.
12. Medical Insurance. Each party will be responsible for his/her medical
insurance.
13. Waivers of Claims Against Estates. 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 may 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, curtesy, 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, to 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.
14. Custody of Minor Children. The parties agree to the following with respect to
the aforesaid minor children:
A. Husband and Wife shall have joint legal custody of the minor children.
Except in the case of an emergency, all major decisions affecting the
minor children' growth and development, including medical treatment,
education, and religion, shall be made jointly by the parties. Neither
party shall, while in the presence of the minor children, make (or allow
to be made) any disparaging or derogatory remarks about the other
Page 6 of 10
parent. It shall be the express duty of each parent to uphold the other
parent as one whom the minor children should respect and love. Each
parent shall be entitled to receive information concerning the minor
children, including medical records, educational records and religious
records. Each parent may attend medical appointments or scholastic
conferences and activities.
B. Wife shall have primary physical custody of the minor children.
C. Husband shall have periods of partial custody of the minor children
every other weekend from Friday evening at 7:00 p.m. to Sunday
evening at 6:00 p.m., and at such other times as the parties mutually
agree. However, Husband agrees that during these periods of partial
custody, he will not allow the minor children to be in the presence of
Lynn Russell and/or Vicki Russell, except' he first obtains Wife's con-
sent.
D. Father shall be responsible for all transportation necessary to effectuate
this Agreement.
E. The parties shall have reasonable telephone contact with the minor
children at all times.
F. Neither party shall move to a residence greater than 40 miles from the
Cumberland County Courthouse unless he or she first provides a written
notice to that effect to the other party at least sixty (60) days prior to any
Page 7 of 10
such move.
Notwithstanding the above, the parties understand and agree that the custody provisions
contained in this Agreement are subject to modification at any time by a court of competent
jurisdiction.
15. Representation. It is recognized by the parties hereto that Wife is represented
by Michael A. Koranda, Esquire. It is recognized by the parties hereto that Husband is not
represented by legal counsel, although he understands that he has the right to be represented by
legal counsel. By the signing of this Agreement, the parties recognize that he/she fully
understands the legal impact of this Agreement.
16. Effective Agreement. This Agreement shall bind the parties, their heirs,
executors, administrators and assigns.
17. Voluntary Execution. The provisions of this Agreement are fully understood
by both parties and each party acknowledges that this 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.
18. 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.
19. Prior Agreement. It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
20. Modification and Waiver. Any modification or waiver of any provision of this
Page 8 of 10
Agreement shall be effective only if made in writing 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.
21. Governing Law. This Agreement shall be governed by and shall be construed
in accordance with the laws of the Commonwealth of Pennsylvania.
22. 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.
23. 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.
24. Contract Interpretation. For purposes of interpretation and for the purpose of
resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared
jointly by the parties.
Page 9 of 10
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.
WITNESS:
WILLIAM L. BOGDEN
ACY L. QC} DEN
Page 10 of 10
COMMONWEALTH OF PENNSYLVANIA )
ss:
COUNTY OF DAUPHIN )
On this, the day of 1999,
before me, a Notary Public, personally appeared WILLIAM L. BOGDEN, known to me to be
the person whose name is subscribed to the within Marital Settlement Agreement and acknowl.
edged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Ae'?
Notary Publ c
NOWN &W
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Harrisburg Dnou lp Kiln Cod*
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COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF DAUPHIN ) ss:
On this, the 71a? day of )4
1999,
before me, a Notary Public, personally appeared TRACY L. BOGDEN, known to me to be the
person whose name is subscribed to the within Marital Settlement Agreement and acknowl-
edged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
FCr ,E/\1
Notary
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[ON PLEAS
TRACY L. BOGDEN,
IN THE COURT OF C0 PENNSYLVANIA
CUMBERLAND COUN
Plaintiff,
VS.
WILLIAM L. BOGDEN,
No. 99-3668
Defendant. CIVIL ACTION - DIVORCE
PRAE IPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: June 16, 1999, by first class mail and
certified mail/restricted delivery (a= Affidavit of Service).
3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code:
by Plaintiff September 27, 1999; by Defendant September 27, 1999.
4. Related claims pending: None.
d' the prothonotary:
5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed wi
September 28, 1999.
,th the prothonotary:
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed µ
September 28, 1999.
Respectfidly submitted,
TOMASKO & KORANDA, P.C.
219 State Street
Harrisburg, Pennsylvania 17101
Telephone No.: 717-pg-110 , /
By: -!42 _/Lle
MICHAEL A.
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TRACY L. BOGDEN,
Plaintiff,
vs.
WILLIAM L. BOGDEN,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q6/ - ,31, LP 01-C Jt LL
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree of divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for any other claim or
relief requested in these papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your children.
When the 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 the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania, 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.
Court Administrator
4th Floor, Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
TRACY L. BOGDEN,
Plaintiff,
VS.
WILLIAM L. BOGDEN,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 36 G8 0,-U.l Te«.
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
Plaintiff is Tracy L. Bogden, who currently resides at 213 W. Marble Street,
Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is William L. Bogden, who currently resides at 58 Red Barberry
Drive, Etters, York County, Pennsylvania, 17319.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on July 12, 1997, in Enola, Cumberland
County, Pennsylvania.
5. There have been no prior actions of divorce or annulment of marriage between
the parties.
6. Defendant is not a member of the Armed Services of the United States of
America or its Allies.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff prays that a Decree be entered divorcing the said Plaintiff and
Defendant from the bonds of matrimony heretofore contracted between them.
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 4904
relating to unsworn falsifications to authorities.
Date: 1
TR L. BOGD,7
Respectfully submitted,
TOMASKO & KORANDA, P.C.
219 State Street
Harrisburg, PA 17101
Telephone: 717-238-1100
By:
ICHAEL A. OR NDA
Pa. I.D. #58808
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TRACY L. BOGDEN,
vs.
Plaintiff,
WILLIAM L. BOGDEN,
Defendant.
AFFIDAVIT OF cFRVICE
COUNTY OF DAUPHIN
COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99.3668
CIVIL ACTION - DIVORCE
ss:
I, Michael A. Koranda, Esquire, being duly sworn according to law, hereby deposes and says the
following:
I . On June 21, 1999, 1 served the Complaint Under Section 3301(c) of the Divorce Code in
the above-captioned matter on the Defendant, William L. Bogden, by first class and certified/restricted
delivery at his address of 58 Red Barberry Drive, Etters, Pennsylvania 17319.
2. On June 23, 1999, the Defendant accepted delivery of the Complaint, as videnced by the
return receipt attached hereto as Exhibit "A" and incorporated he in.
46E L A 1 RANDA
SWORN JTO and subscribed before me
this of I99Q.
0.
NOTARY BLIC
Notarial Seal
vinniezella D. Datong, Notary Public
Harrisburg, Dauphin County
My Corrmission Expires Mar. 10, 2003
° SENDER: I also wish to receive the
• Complete items l and/or 2 for additional services.
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card to yau.
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TRACY L. BOGDEN, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 99-3668 (Civil)
WILLIAM L. BOGDEN, CIVIL ACTION - LAW
Defendant. IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June
16, 1999, and served upon Defendant on June 23, 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.
4. I have been advised of the availability of marriage counseling, and understand
that I may request that the Court require that my spouse and I participate in counseling. I
furthar understand that the Court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request. Being so advised, I do not request that the
Court require that my spouse and I participate in counseling prior to a divorce decree being
handed down by the Court.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date: 4/ 1 KACY L. BOGD %
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TRACY L. BOGDEN,
Plaintiff,
VS.
WILLIAM L. BOGDEN,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3668 (Civil)
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date: /S? t
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TRACY L. BOGDEN, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-3668 (Civil)
WILLIAM L. BOGDEN, ; CIVIL ACTION - LAW
Defendant. IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June
16, 1999, and served upon Defendant on June 23, 1999.
The marriage of plaintiff and defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I have been advised of the availability of marriage counseling, and understand
that I may request that the Court require that my spouse and I participate in counseling. I
further understand that the Court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request. Being so advised, I do not request that the
Court require that my spouse and I participate in counseling prior to a divorce decree being
handed down by the Court.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date: 7 > 7 - ?? 5 ?_rl
WILLIAM L. BOGDEN
R.
LL.
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TRACY L. BOGDEN,
Plaintiff,
VS.
WILLIAM L. BOGDEN,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3668 (Civil)
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date:
WILLIAM L. BOGDEN
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