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HomeMy WebLinkAbout99-05343 J a t r . a• > , IN THE COURT OF COMMON PLEAS OFCUME3ERLAND COUNTY STATE OF - PENNA. WILLIAM AUGUSTUS STTJM Plaintiff N O. 1999-05343 Civil VERSUS KATHRYN P.LIZARP.TH STUM, Defendant DECREE IN DIVORCE If 3: q pm AND NOW, JULY ` 2000 , IT IS ORDERED AND DECREED THAT WILLIAM AUMSTUS STUM , PLAINTIFF, AND KATHRYN ELIZARRTH STUM ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; w a a z ' 0 ti 41 N 44 > . V CO C ru ?- ; W z 5 E U W •ti F v ., b E ? 3 O D r+f W W W ?• E, Z y p 2 E U < m ,' N a 5 W 4 w z xa N C 2 0 a N C K 0w Ua> T Q W E• C7 '3 ¢ zw a z as o? w i rn x W r H a F C7 z a 2 a: uz a w 0 H a < WILLIAM AUGUSTUS STUM, Plaintiff Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-05343 Civil KATHRYN ELIZABETH STUM, DIVORCE Defendant AND NOW, this Day of 2000, it is hereby Ordered that the Property Settlement Agreement dated July 5, 2000 attached hereto is incorporated herein and made apart of this Order of Court. BY THE COURT: J. C lzc,?F? ZXIA - I' •i L'. ? .. THIS AGREEMEN'T', is made this Y? day of 2000, by and between: KATHRYN ELIZABETH STUM, hereinafter referred to as Wife; -AND- WILLIAM AUGUSTUS STUM, hereinafter referred to as Husband; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on August 2, 1986, in Enola, Pennsylvania; and WHEREAS, there is one child born of the marriage. r...: M1 J G f ; WHEREAS, diverse unhappy marital difficulties have arisen between the parties causing them to believe that their marriage is irretrievably broken, as a result of which they have separated and now live separate and apart from one another, the parties being estranged due to such marital difficulties with no reasonable expectation of reconciliation; and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property; and the settling of all matters relating to the custody and support of their minor children, and in general, the settling of any and all claims and possible claims by one against the other or against their respective estate, particularly those responsibilities and rights growing out of the marriage relationship. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of the parties hereto, husband and wife, each intending to be legally bound, hereby covenant and agree as follows: -2- r ? 1. SEPARATION. It shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to cant' out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. Should a Decree, Judgment, or Order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such Decree, Judgment, Order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto, that this Agreement shall survive and shall not be merged into any Decree, Judgment, or Order -3- r of divorce or separation. It is specifically agreed however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any Order of divorce, Judgment, or Decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any Judgment and be forever binding and conclusive upon the parties. 2. EFFECTIVE DATE The effective date of this Agreement shall be the "date of execution" or "execution date", 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. 3. MUT AL. RELEASES, Husband and wife do hereby mutually remise, release, quit-claim or forever discharge the other and 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 -4- 1 against the estate of such other, or whatever nature and wherever 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 curtesy, of claims in the nature of dower or curtesy, 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 or a surviving spouse to participate in a deceased spouse's estate, whether arising under the United States, or any other country; or any rights which either party may now have or at any time hereafter have for the past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, 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 -5- f ; 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. 4. DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of the Divorce Decree, unless otherwise specified herein. 5. MUTUAL CONS NT/ADVI OF COUNSEL, Husband and wife acknowledge and understand the terms and conditions of this Agreement, and wife is unrepresented, and Husband is represented by Diane M. Rupich, Esquire. Husband and wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that -6- it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. Wife fiuther acknowledges that she has had an opportunity to seek independent legal advice prior to the execution of this Agreement. 6. FINANCIAL. DI O R The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no formal discovery conducted in their pending divorce action and that neither party has filed an inventory and Appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owed by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. In the event that either party, at any time hereafter, discovers such an undisclosed asset, the parties shall have the right to petition the Court of Common Pleas of Dauphin County to make equitable distribution of said asset. -7- l , The non-disclosing party shall be responsible for payment of counsel fees, costs, or expenses incurred by the other party in seeking equitable distribution of said asset. 7. DEBTS AND OBLIGATION Husband represents and warrants to wife that since June of 1999, 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 such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. Wife represents and warrants to husband that since June of 1999, 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 such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 8. REAL ESTATE. Husband and wife hereby acknowledge that they are the joint owners of the real estate located at 607 State Street, Enola, Cumberland County, Pennsylvania. Husband and Wife hereby agree that Husband shall remain in the real estate, and shall be responsible for the mortgage, utilities, taxes, upkeep and maintenance on said real estate, and hereby indemnifies and holds wife harmless from any and all obligation for the payment of said debts. Wife hereby agrees to execute a deed relinquishing all of her right, title and interest in said real estate upon payment of Five Thousand ($5,000.00) Dollars. Husband and Wife hereby agree that Husband shall pay to Wife the sum of $5,000.00 within two years from the date of the issuance of the Decree in Divorce. In the event, Husband should die within said two year period, the parties hereto agree that Wife shall become the owner of the real estate. 9. PERSONAL PROPERTY, Except as set forth hereto, husband and wife have agreed that their personal property has been divided to the parties' mutual satisfaction and neither party will make any claims to the property possessed by the other, except as set forth hereto: NONE. -9- 10. PENSION AND RETIREM .NT. Husband and wife hereby agree that they waive all of their right, title, and interest, which they may or may not have to the other's pension, profit-sharing, retirement plans, both individually or which they may have through their employers. The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act of 1980, No. 1980-26, as amended February 12, 1998, particularly the provisions for alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. 12. MUTUAL RELEASE OF CLAIMS, Except as otherwise stated in this Agreement, husband and wife each do hereby mutually remise, release, quitclaim and forever discharge the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and -10- . interests, or claims in or against the property (including income and gain from the property hereafter accruing) of the other or against the estate of each other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have; specifically including any rights which either party may have or at any time hereafter have for past, present, or future spousal support, or maintenance, alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, costs or expenses, whether arising as a result of the marital relation or otherwise. It is the intention of the 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. 13. WAIVER OR MODIFICATION TO BE IN WRITING, A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties, and executed with the same formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 14. 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 that purpose of giving full force and effect to the provisions of the Agreement. 15. AGREEMENT BINDING ON HEIRS, This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors, and assigns in the interest of the parties. 16. BREACH, If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorneys fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 17. LAW OF PF.NNSY VANIA ApptjCAgj,F This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 18. HEADIN NOT PART OF A R EMENT Any headings preceding the text of the several paragraphs/provisions 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. 19. DIVORCE, The parties hereto acknowledge that their marriage is irretrievably broken. The parties further agree to execute the necessary Affidavits of Consent and Waiver of Counseling, and Waiver of Notice of intent to Request Entry of Divorce Decree upon request so that the divorce may become finalized. The parties further agree and acknowledge that this Property Settlement Agreement shall be incorporated into said Decree in Divorce; however, shall not merge therewith. -13- IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. =AU Witness Kathryn Elizabeth Stum Witness William Augustus Stum l?? ?meboro Twp?, CN'?y? ? -14- COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the S day of J y// , 2000, before me, a Notary Public, the undersigned officer, personally appeared KATHRYN ELIZABETH STUIv1, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. My Commission Expires: 1 Z Z G l COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN E WI ftR ! a? On this, the S day of J M/? ,2000, before me, a Notary Public, the undersigned officer, personally appeared WILLIAM AUGUSTUS STUM, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. My commission expires: Notary Public No ARIAL SEAL WILLUIM H. aROWNSTEIN, Notary aft fy Ti tmsboro TWA., Cumberl?g Ca My L1omiNbak n Er?4pi ?erCp rl go I 1 WILLIAM AUGUSTUS STUM, Plaintiff Vs. KATHRYN ELIZABETH STUM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999--5343 IN DIVORCE PRAF..IP TO TRANSMIT R ORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievably broken under Section (XX) 3301 (c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: Certified Mail on September 4, 1999. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, July 5, 2000; by Defendant, July 5, 2000. (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A date of service of Plaintiffs affidavit upon Defendant: N/A. 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: N/A. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff: simultaneously herewith; by Defendant: simultaneously herewith. 5. Related Claims Pending: None BY: Diane M. upich, squire (717) 232-9724 Attorney for (xx ) Plaintiff ( ) Defendant l / ?. ?., r. .:: !:` `> _. ?_, r' ;,?? "?:w, ?; 4 IM1?. yr ????? ?. 1'[?n S1?'??? !?' 4;., :; ?:h?. 5 7 ? r 1-9 r w w a ; 4 + 'L H ,,, c - ro e z z O F w F ? y N v i U U E W C O L S S c z 4 C 5 rn a H V U E 0 ? 2 N CO co G M [ 4 i 4c W H'- p j > H H M H ?L' Z N ozQ .E ? ' o C u a >Cn v ra F H c-: z ti F m a U F z N a x co H V W C H a C g U a w' v 3 zz r J• m ai W LL ? xa z r ? op WILLIAM AUGUSTUS STUM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. s, 1999 ~ .3142 KATHRYN ELIZABETH STUM, CIVIL ACTION - LAW Defendant IN DIVORCE 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 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. 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 1-800-990-9108 WILLIAM AUGUSTUS STUM, Plaintiff vs. KATHRYN ELIZABETH STUM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1999 - 5 3'i 3 ?e ! 7.+,,.,- CIVIL ACTION - LAW IN DIVORCE 1. The Plaintiff is William Augustus Stum, an adult individual, who currently resides at 9 Salt Road, Enola, Cumberland County, Pennsylvania and whose social security number is 164-58-7922. 2. 3 The Defendant, Kathryn Elizabeth Stum, is an adult individual, who currently resides at 607 State Street, West Fairview, Cumberland County, Pennsylvania 17025, and whose social security number is 211-60-6256. Plaintiff and Defendant were married on August 2, 1986 in Enola, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff and Defendant are both citizens of the United State. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There is one child born of this marriage; namely: Raymond Augustus Stum, bom October 10, 1989. -2- 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, DILS & RUPICH BY: ` Diane M. Rupich, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 -3- I Verify that the Statements made in this COt+IPLAINT IN DIVORCE 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: AUGUST 23, 1999 WILLIAM AUGUSTUS STUM WILLIAM AUGUSTUS STUM, Plaintiff Vs. KATHRYN ELIZABETH STUM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-05343 Civil IN DIVORCE I, Diane M. Rupich, Esquire, hereby certify that a certified copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code has been served upon the Defendant, Kathryn Elizabeth Stum, at her mailing address of 607 State Street, West Fairview, Pennsylvania by depositing the same at the Post Office, at Harrisburg, Pennsylvania, Certified Mail No. Z 569 1 14 418. Attached hereto is the return receipt executed by Kathryn Elizabeth Stum evidencing receipt of the same dated 4, 1999. BY: Diane M. Rupi , Esquire 1017 N. Fro avStreet Harrisburg, Pa. 17102 (717) 232-9724 I.D. No. 71873 July 17, 2000 i h SENDER: aClMe henn 1 WWor 2 for addldarW "Noes. Complete hems 3, 4a, and 4b. "• I also wish to receive the follovdng services (for all : Pdrx youu runame, and eddr"s on the nvene of We form so sat we mn return this cud to extra fee): y Zion to the from of the mYlplsa, or m the MCI, If spas 6M not UA ti all 1. 13 Addressee's Address p r h aWdmis'RNUm Rectlpt Raqu"rM'pn the mellpiM below be am tle numMc 2.LZ StdCted Delivery The Raum Receipt will Mow to whom the adltle was delivered delivered and the date Consult postmaster for fee. 3. Article Addressed to 4a. Article Number Kaar,zyv GG cab. Sf -2 5-C .7 E 60 7 S-f1a+t S ee f 41). Service Type ? ? R i t d ?C l9 eg s ere p eR e5{' FAIRUICw ?c- t ?ExpresaMall ?Inaured a: f ? Retum Receipt for Menchandse ? COD ° . Ml 7. Date of Delivery G t 5. cgcelved By: (Print Namt C `R'??Q`?1J S ??.M S. Addressee's Address (Only/frequested and fee is paid) " 3 ns re ( ressee gent) 6.819 i X PS Form 3811, D ber 1994 Domestic Retum Receipt r• y C CJ -?-?' ?_> ? ..J ?? C7 _1 '? ?J ? !J • . 3 WILLIAM AUGUSTUS STUM, Plaintiff KATHRYN ELIZABETH STUM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1999-05343 DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 1, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of tiling and service of the complaint. 3. I consent to the entry of a final Decree in Divorce. 4. 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. 5. 1 have been advised of the availability of marriage counseling, and being so advised, I do not request that the Court require my spouse and myself to participate in marriage counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ?? oC) William Augustus Stum, Plaintiff WILLIAM AUGUSTUS STUM, Plaintiff Vs. KATHRYN ELIZABETH STUM, Defendant M THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-05343 CIVIL ACTION - LAW IN DIVORCE 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 in 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 Waiver 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: f o 0 --T William Augustus Stum, Plaintiff i:- •') I. J l l ' l J .?: f WILLIAM AUGUSTUS STUM, Plaintiff KATHRYN ELIZABETH STUM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1999-05343 DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 1, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final Decree in Divorce. 4. 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. 5. I have been advised of the availability of marriage counseling, and being so advised, I do not request that the Court require my spouse and myself to participate in marriage counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsificatio to authorities. Date: -C) 0 ?` 14:- Kathryn Elizabeth Stum, Defendant ::, _ _ `:; ?.:, - -L •.J .. J .y.'? WILLIAM AUGUSTUS STUM, Plaintiff Vs. KATHRYN ELIZABETH STUM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-05343 CIVIL ACTION - LAW IN DIVORCE I consent to the entry of a final Decree in 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: Kathryn Elizabeth Stum, efendant :-, ,. =? ? ??? J.. ?? ? .?