HomeMy WebLinkAbout99-04231
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
.....DANIEL RICHARDSON,
Plaintiff Nc?.. 9.9-..9.2.3.].
Versus
..... WENDI...E.._.RI CHARDSON,
....... Defendant
DECREE IN
DIVORCE
1999
AND NOW, .... -D4 a.4 • . •'Zr (S ...... 19.901., it is ordered and
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decreed that ......... Denis,> • Richexdsgn • • • , • • • , • • • • • • , , , , , , plaintiff,
and .......... wendi..$r. MghPX09n ......................... 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; none.
?.T. JP. FuR?}tEg,QRD,?gRA.,..AP0.00;P..ANP..AEGREED,.t,hat;..tbe..terms.,..,
provisions and conditions of a certain Marital Settlement Aggree-
ment. between .the .panties. dated.,. and. •attached..hereto,. ar.e.ineor-
porated in this Decree in Divorce by reference"as fully as if the
same were set forth herein at length Sa dAd greement shall not
merge. tji but shall survivg t Ehape .a Divorce.
? v o r
Attest: J.
Prothonotary
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DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4231 Civil Term
CIVIL ACTION - LAW
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:
I. Ground for Divorce: Irretrievable breakdown under §3301(c) of the Divorce Code.
2. Date and Manner of service of the Complaint: Service by certified mail no. Z 104 208 580
on July 21, 1999. See attached Affidavit of Service.
3. Date of executiolr the Affidavit of Consent quired by §3301(c) of the Divorce Code:
by the Plaintiff: by the Defendant: 1-1/4
4
4. Related claims pending: None.
5. Date Plaintiffs Waiver of Notice in §3301(c) divorce was filed with the prothonotary:
filed simultaneously with this Praecipe to Transmit Record.
Date Defendant's Waiver of Notice in §3301(c) divorce was filed with the prothonotary:
filed simultaneously with this Praecipe to Transmit Record.
Respectfully Submitted:
ml?
Jeann' . Costopoulos, Esquire
Atto ey for Plaintiff
1400 N. Second Street
Harrisburg, PA 17102
Phone: (717) 221-0900
PA S.Ct. ID No. 68735
Dated: Z/l / yl
DANIEL RICHARDSON, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-4231 Civil Term
WEND[ E. RICHARDSON, CIVIL ACTION -LAW
Defendant DIVORCE ? o
W Y
DEFENDANT'S AFFIDAVIT OF CONSENT mac; ;
UNDER SECTION 3301(c) OF THE DIVORCE CODIF, ;Q
AND WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was fil4 on .fuly l t rn
?a
1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of the 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 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 rela •ng to
unworn falsification to authorities.
yf
Date. Signature: 0J
Wendi E. Richardson
Sworn to and subscribed to
Before me this day of
0geen; beA '1999.
Notarial Seal
Martha L. Noel, Notary Public
Carlisle Soro, Cumberland CarIH
My Camdeslan Expires Sept. ta, 2003
Member, Pennsylvania ASSOCIallon 01 Notenas
N tary Public
DANIEL RICHARDSON, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-4231 Civil Term
WENDI E. RICHARDSON, CIVIL ACTION -LAW
Defendant DIVORCE
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE r ;D a
1 I consent to the entry of a final decree of divorce without notice.
.
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I understand that I may lose rights concerning alimony, division of property, lacer's fqqs,
.
or expenses if I do not claim them before a divorce is granted.
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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.
4. 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.
Dated: I'' " R Signature: -
Wendi E. Richardson
Swom to and subscribed to
Before me this POr- day of
J e-C e.7r1.b `tx , 1999.
l Sasl
, Notary public
mberland Ca+nY
ires Sept. 18, 2803
gssoclatlon of Ndarles
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NdLayy Public y
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9g - -4a31
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this _/e day of 1999, by and
between WENDI E. RICHARDSON, (hereinafter referred to as "WIFE") and DANIEL J.
RICHARDSON, JR. (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on April 15, 1980, in Camp
Hill, Pennsylvania, and were separated on June 20, 1999. HUSBAND has filed a Divorce Action
in Cumberland County docketed at 99-4231 Civil Term. The parties hereto agree and covenant
as follows:
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither parry shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
(1) is represented by counsel of his or her own choosing;
(2) is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agreement; and
(6) fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party, The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns tiled by or on behalf of either or both Parties during
marriage.
3
7.
REAL ESTATE: HUSBAND agrees to sign a deed in Lieu of Foreclosure for the real
estate situate at 7960 Bull Road, Lewisberry, Pennsylvania, which is currently in foreclosure.
8.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay support to the WIFE. WIFE will not provide any financial support to the HUSBAND. The
parties also waive any right they have to receive alimony payments from the other following the
entry of the Divorce Decree in this matter. WIFE will terminate the support action she has filed
in York County at 1747 SA 1999, PACSES Case Number 062101255 and waives any arrearages
upon the HUSBAND signing all documents necessary to finalize the Divorce and WIFE
receiving a Final Divorce Decree.
9.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. His bank accounts;
C. Any Life Insurance Policy; and
d. Any retirement account.
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
C. Any Life Insurance Policies; and
4
d. Any retirement or employee benefits with her employer, DDC.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE 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.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
AUTOMOBILES:
10.
a. WIFE agrees to waive any and all interest which she may have in HUSBAND'S
motor vehicles.
b. HUSBAND agrees to waive any and all interest which he may have in WIFE'S
motor vehicles. They each waive any claim which they have in any automobile
owned by the other party.
5
MARITAL DEBTS & BANKRUPTCY: Each party will be responsible for their own
debt incurred after the date of separation. HUSBAND will be solely responsible for his
outstanding debts and agrees to hold WIFE harmless and indemnifies her for any debt incurred
after the date of separation. It is hereby understood and agreed by and between the parties that
their obligations pursuant to this agreement shall not be affected by any bankruptcy proceeding
and shall not be deemed to constitute or be a dischargeable debt of a bankruptcy. Both parties
warrant that he/she has not heretofore instituted any proceeding pursuant to the bankruptcy laws
nor are there any such proceedings pending with respect to him/her which have been initiated by
others.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
WIFE waives all right, title and claim to HUSBAND's retirement account, and HUSBAND
waives all right, title and claim to any of WIFE's employee benefits.
13
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
t)
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HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions 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 should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
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 reasonably required to give full force and effect to the provisions of this
Agreement.
17.
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
7
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is
not the result of any duress or undue influence. The provisions of this Agreement are fully
understood by both parties 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.
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.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: 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.
21.
PAYMENT OF COSTS: The parties agree to pay for their own costs required to obtain
and complete the divorce.
8
22.
WAIVER 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, 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.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
...n //?,
W=-,,, Q DANI , .
RI HARDSON.
9
COMMONWEALTH OF PENNSYLVANIA
. SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this :ice 4 day of 1 . e2!31-Ln- ,
1999, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, WENDI E. RICHARDSON, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
N -sod
Cal* OM ?°
COMMONWEALTH OF PENNSYLVANIA mernber.
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this IV- day of1Q)a&r6tA
1999, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, DANIEL J. RICHARDSON, JR., known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, 1 have hereunto set my hand and official seal.
Notarial Seal
Diane M. Smith, Notary Public
F hanicsburg Soro. Cumberland Coum; i
Commission Expires June 22.204,'
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DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. Cllr - '??31 C w?9 Te ?c?
CIVIL ACTION - AT LAW
DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to 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 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 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.
COURT ADMINISTRATOR
4" FLOOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013-3387
TELEPHONE: (717) 240-6200
DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 9 9 - `1..731 6ij Tr--
CIVIL ACTION - AT LAW
DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE
The Plaintiff, Daniel Richardson, by and through his attorney, Jeanne B. Wigbels, Esquire,
avers the following:
1. The Plaintiff, Daniel Richardson, is an adult individual who currently resides at 7960
Bull Road, P.O. Box 390, New Cumberland, Cumberland County, Pennsylvania, 17070.
2. The Defendant, Wendi Richardson, is an adult individual who currently resides at 528
Chestnut Grove Road, Dillsburg, York County, Pennsylvania, 17019.
3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on April 15, 1980 in Mechanicsburg,
Cumberland County, Pennsylvania.
COUNT 1- DIVORCE
5. Paragraphs one (1) through four (4) are incorporated herein by reference as if set forth
specifically below.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. This action is not collusive.
WHEREFORE, the Plaintiff respectfully requests this Honorable Court grant the Plaintiff
relief from the bonds of matrimony and order a Decree in Divorce.
Dated:
Jeany B. igbels, Esquire
WIGBELS & WELCH
1400 North Second Street
Harrisburg, Pennsylvania 17102
PA Supreme Court ID No. 68735
Telephone: (717) 221-0900
Fax: (717) 221-0904
DANIEL RICHARDSON, THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, pENNSyLVANIA
V. : No. 9q- 1403! L'o ierr,
WENDI E. RICHARDSON, CIVIL ACTION - AT LAW
Defendant DIVORCE
VERIFICATION
I, Daniel Richardson, hereby verify that the statements made in the foregoing Divorce
Complaint 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.
i
Date: Signature:
LLVCHARDSON
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DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4231 Civil Term
CIVIL ACTION - LAW
DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(c) OF THE DIVORCE CODE
AND WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 13,
1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of the 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. 1 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.
Date: Signature: XC z /Z;V?
Daniel ' ar s
Sworn to and subscribed to
Before me this day of
l .? n v '1999.
lle
Notary Public
Notarial Seal
Diane M. Smith, Notary Public m, ftnc .n
My Cor",ssiog Expives June 2X2000
DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4231 Civil Term
CIVIL ACTION - LAW
DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 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.
4. 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.
Dated: l/T'? Signature: al?
Dane ' hardson
Swom to and subscribed to
Before me this A X?- day of
kbUz irnltek 199`
Notary Public
i
Notarial Seal
Diane M. Smith, Notary Public
FM?ortimission anicsbur9 Boro, Cumberland County
CExpires June 22. 2006
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DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4231 Civil Term
CIVIL ACTION - LAW
DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(c) OF THE DIVORCE CODE
AND WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 13,
1999.
2. The manage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of the filing and service of 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. 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 rela'ng to
unworn falsification to authorities.
4!y f
Date. Signature. 1/v
Wendi E. Richardson
Sworn to and subscribed to
Before me this .r-."A day of
nacein b Ul , 1999.
N ry Public
Notarlel Seal
Martha L. Noel, Notary Publdc
Carlisle Boro, Cumberland Canty
My ComNselon Expires Sept.18, 2803
Member, PersByNanla Assn 0011 of Naiades
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DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4231 Civil Term
CIVIL ACTION - LAW
DIVORCE
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 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.
4. 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.
Dated: Signature:
Wendi E. Richardson
Sworn to and subscribed to
Before me this R r,'- day of
N eC2:7n.bgx , 1999.
N& W Public
Noteriel Seal
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DANIEL RICHARDSON,
Plaintiff
V.
WENDI E. RICHARDSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4231 Civil Term
CIVIL ACTION - LAW
DIVORCE
AFFIDAVIT OF SERVICE
TO THE PROTHONOTARY:
I, Jeann6 B. Costopoulos, Esquire, verify that the Complaint in Divorce was served upon the
Defendant indicated above on July 21, 1999, by first class, Certified Mail No. Z104 208 580, postage
prepaid, return receipt requested, restricted delivery, pursuant to the requirements of Pa.RC.P.
§1930.4.
By:
Jeanne . Costopoulos, Esquire
Attorney for Plaintiff
1400 N. Second Street
Harrisburg, PA 17102
Phone: (717) 221-0900
PA S.Ct. ID No. 68735
Dated: r
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PS Fo 3811, December 1994 Domestic Return Rec@lpt
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US Postal Serwce
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