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HomeMy WebLinkAbout99-05661 J i#. r.: t l? t,- ti A `l n1?. S v? +4'-i4 <7{?E•:':y?':?...a4rV-29;1 .:M. ":y M' ACV -V: W. :4••'?•.-W,:1.1i •4:• :?•"}';:AC ?}C?:16"•iW:r7q: {K•' 116".111C(iMK: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TODD E. BLACK, Plaintiff ............ ........... ....... . Versus ........._._........ LISA M. BLACK,. _ Defendant No. 99-5661 19 DECREE IN D/I VORCE AND NOW, ..../.!"`. ??? .... , 19 .901! , it is ordered and decreed that ........Todd.E.•,Black plaintiff, defendant, and .......... Lisa, n: , aiepx .................... 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; "K'(- The parties' Separation np,l, Property. Sull lulnun}, Agreement,,, .September.9pj.}999,.?5.)pppFPOrnied.bere.ln,,but,no.t.m ................. nr 'rho, ce rw. W ...Prothonotary i w •. 10 THIS AGREEMENT, made this day of , 1999, by and between TODD E. BLACK, of 102 South Fayette Street, Shippensburg, Cumberland County, Pennsylvania, party of the first part, hereinafter referred to as "Husband", AND LISA M. BLACK, of 44 Thompson Creek Road, Shippensburg, Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, Husband and Wife were married on February 20, 1988, in Junction City, Kansas; and, WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six months; and, WHEREAS, certain differences have arisen between the parties hereto which have made them desirous of living separate and apart from one another; and, WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property, determine their rights to alimony and support and any other matters which may be considered under the Domestic Relations Code; and, WHEREAS, it is the intention 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 and to settle all financial and property rights between them; and, WHEREAS, the parties hereto have mutually entered into an agreement for the i. division of their jointly owned assets, the provisions for the liabilities they owe, and provisions for the resolution of their mutual differences, after both have had full and ample opportunity to consult with attorneys of their respective choice, the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth hereinafter and for other good and valuable consideration, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint, or interference, direct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The forgoing provisions shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II DIVORCE 21 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the parties hereto that each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non- prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; not to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant, and agree that in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceablility as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, Should either of the parties obtain a decree, judgment or order of separation of divorce in any other state, country, orjurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be affected in any way by any such separation and divorce. Z3 This Agreement shall survive any decree in divorce and shall be forever binding and conclusive on the parties. It is understood by and between the parties that this Agreement shall be incorporated into any decree, divorce or separation, but it shall not be deemed merged in to such decree. ARTI III EOUITABI R D/ TRIB TIOAr OF MARITA PROP RTY 3.1 The parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in the Pennsylvania Divorce Code, and taking into account the following considerations; length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability; estate, liabilities, and needs for each of the parties; the contribution of one party to the education, training or increased earning power to the other party; the opportunity of each party for future acquisition of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during their marriage; the economic circumstances of each party, including federal, state and local tax ramifications at the time the division of the property is to become effective; and whether the parties will be serving as the custodian of any dependent minor children. 3.2 Personal Pronerrv. The parties acknowledge that they have divided their personal property, tangible and intangible, to their mutual satisfaction. The parties further acknowledge that they have the cash, accounts, or other tangible and intangible property in their possession that they wish to have and neither will make any claim whatsoever against the other party for any other items of personal property or assets that are in the other party's possession. 3.3 jj& In uranc . Each party agrees that the other party shall have and retain sole ownership and possession of any life insurance policy owned by that party. Each party shall have the right to borrow against, cash in policies, change beneficiaries, and exercise any other incidents of ownership of the respective policies free of any right or claim by the other party. Each party agrees to sign any documents necessary to waive, relinquish or transfer any rights in such policies to the party who owns such policy. 3.4 . ubs puen* Acquired ftpfM. Husband and Wife hereby waive and relinquish any and all rights that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other party. Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. 3.5 Real Estate. The parties are joint owners of certain real estate located at 102 South Fayette Street, Shippensburg, Cumberland County, Pennsylvania. Husband has and shall retain sole and exclusive possession of the real estate. Husband shall retain sole and exclusive responsibility for the repayment of any loan amounts due and owing on the real estate, including the first mortgage to Norwest Mortgage and the home equity loan to First Plus Financial. The parties acknowledge that the Deed to the real estate as well as the mortgage and home equity loan will remain in joint names until Husband has refinanced the debt associated with the real estate. Contemporaneously with Husband's refinancing of the debt into his sole name, Wife will execute a Deed transferring all of her rights and interests in the real estate to Husband, Wife shall make no claim whatsoever for use, ownership, am1kc financial interests relative to the aforesaid real estate. Husband shall hold harmless Wife and save her from and against any and all collection activity on account of any such encumbrance to the above real estate. 3.6 Pension. Retirement Profj( ari Neither party shall make any claim of any nature whatsoever concerning any insurance benefits, retirement benefits, profit-sharing accounts or other similar accounts or benefits available to or accruing to either party. 3.7 VtiLttS(s?. The parties acknowledge that Husband has and shall retain sole and exclusive possession of the parties' 1993 Ford truck. Husband shall retain sole and exclusive responsibility for the repayment of any loan amounts due and owing on that vehicle. Wife shall make no claim whatsoever relative to access for use of the aforesaid vehicle and shall make no ownership claim of any nature in the aforesaid vehicle. Furthermore, Husband shall hold harmless Wife and save her from and against any and all collection activity on account of any such encumbrance to the above vehicle. The parties shall transfer the title as necessary to reflect the above ownership, The parties acknowledge that Wife has and shall retain sole and exclusive possession of the parties' 1998 Ford Escort. Wife shall retain sole and exclusive responsibility for the .' repayment of any loan amounts due and owing on that vehicle. Husband shall make no claim I whatsoever relative to access for use of the aforesaid vehicle and shall make no ownership claim of any nature in the aforesaid vehicle. Furthermore, Wife shall hold harmless Husband and save him from and against any and all collection activity on account of any such encumbrance to the above vehicle. The parties shall transfer title as necessary to reflect the above ownership. The parties acknowledge that Husband has and shall retain sole and exclusive possession of the parties' 1980 750 Honda motorcycle. Husband shall retain sole and exclusive responsibility for the repayment of any loan amounts due and owing on that vehicle. Wife shall make no claim whatsoever relative to access for use of the aforesaid vehicle and shall make no ownership claim of any nature in the aforesaid vehicle. Furthermore, Husband shall hold harmless Wife and save her from and against any and all collection activity on account of any such encumbrance to the above vehicle. The parties shall transfer title as necessary to reflect the above ownership. The parties will, within thirty (30) days of the signing of this Agreement, refinance or pay in full the debt associated with all aforementioned vehicles so as to alleviate any responsibility or obligation of the non-possessing spouse with regard to any encumbrance on such vehicles. 3.8 Intanale Personal E=erty. The parties acknowledge that they have transferred or waived rights and interest in their intangible personal property, including their various bank accounts, credit union accounts, stocks and the like. Neither party will make any claim of any nature whatsoever against the other relative to financial accounts or other investments of intangible personal property that have already been retained by the other party. S DEBTS OF THE PARTIES 4.1 Outstanding .Ioint Debts Husband and Wife agree that there are no outstanding joint debts other than those dealt with in other provisions of this Agreement. 4.2 The parties acknowledge that they each have their own credit card debt. The parties represent and warrant that they will indemnify and save harmless the other from any and all claims or demands made against them by reason of debts or obligations incurred from their own, individual credit card debt and will indemnify and save harmless the other from any and all claims or demands made against them by reason of those debts. ARL"F. V AS/MONY. AL-IMONYP .ND .NT . .IT PO / A C PPORT? CHILD SUPPORT AND b'A/NT NAN S.l The parties herein acknowledge that they have each secured and maintained a substantial and adequate fund with which to provide themselves sufficient resources to provide for their comfort, maintenance and support in the station of life in which they are accustomed. Husband and Wife do hereby waive, release, and give up any rights they may have respectfully against the other for alimony, support or maintenance except as provided in paragraph 5.2. 51 Wife shall pay Husband child support in the amount ONE HUNDRED FIFTY and 00/100 ($150.00) DOLLARS every two (2) weeks paid directly to Husband. If Wife fails to pay Husband the required amount in a timely fashion, Husband may file with Cumberland f • ' County Domestic Relations for an award of child support. In addition, Wife shall keep the parties' two (2) children on her health insurance and she will make all information regarding the children's health insurance available to Husband. ARTICLE VI MISCELLANEOUS PROVI ION 6.1 Advice gf o •n /. The parties acknowledge that they have had the opportunity to review the provisions of this Agreement and further have had the opportunity to secure legal counsel and advice relative to the legal effect of this Agreement. The parties acknowledge that they have either received independent legal advice from counsel of their own selection or that they have specifically chosen with full knowledge and on their own volition, to not seek legal advice relative to this Agreement. They further acknowledge that they fully understand the facts that are the basis of this Agreement. They acknowledge and accept that it is being entered into freely and voluntarily after having the opportunity to receive legal advice and with the knowledge that execution of this Agreement is not the result of any duress or undue influence, and further that it is not the result of any collusion or improper illegal agreement or agreements. 6.2 Counsel Fees. Each party agrees to be responsible for his or her own legal fees and expenses, and each party hereby agrees to waive any claim for alimony, alimony pendente lite, counsel fees, expenses or costs. 6.3 Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, of any party thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as by way of dower of curtesy, or 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 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, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendent lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, not 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 thereof. 6.4 No waiver or modification of any of the terms of this Agreement 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. 6.5 Husband and Wife covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper implementation of this Agreement. 6.6 This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 6.7 Disclosure. The parties each warrant and represent 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 has an interest, of the sources, and amount of the income of such party of every type whatsoever, and all other facts relating to the subject matter of this Agreement. 6.8 F,pforceabft and Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of the Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this contract and agreement is the mutual benefits 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. In the event either party breaches the aforesaid Agreement and it is determined through r appropriate legal action that the alleged party has so breached the Agreement, the breaching party shall be responsible for any and all attorney's fees as well as costs and expenses associated with litigation incurred by the non-breaching party to enforce this Agreement against the breaching party. In the event of breach, the non-breaching party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her including equitable enforcement of the Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESSED BY: COMMONWEALTH OF PENNSYLVANIA ) ) SS COUNTY OF CUMBERLAND ) On this the /? day of 1999 before me, the undersigned officer, personally appeared TODD E. BLACK, known to me (or satisfactorily proven) 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 hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA ) ) SS COUNTY OF CUMBERLAND ) On this the DO day of 52??/yI}?? Notarial Seel Robin J. Ooshom, Notary Public Carlisle aoro, CumbeHand M` y Commission Expires Apc 17, , 1999, before me, the undersigned officer, personally appeared LISA M. BLACK, known to me (or satisfactorily proven) 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 hereunto set my hand and official seal. NOTARIAL SEAL DEBORAH WARREN. Notary Public Shippensburg, Cumberland County My Commission Expires Nov. 8, 2001 ._ ?- -• ?- L ?_ L' ,r ? , !; ?-, ? :? i <.. .._ 1 (. IJ_ 1 TODD E. BLACK, Plaintiff VS. LISA M. BLACK, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.99-5661 CIVIL TERM IN DIVORCE Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) 2. Date and manner of service of the Complaint: By certified mail, restricted delivery, on September 20, 1999. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff. December 22, 1999 by defendant: December 22, 1999 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Signed: December 22, 1999 Filed: December 29, 1999 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Signed: December 22, 1999 Filed: December 29, 1999 Kristen Goddar onsen, Esquire Attomey for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 oN >- i PJ s LL.. :.f. TODD E. BLACK, Plaintiff VS. LISA M. BLACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.'99•-"661 CIVIL 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 TODD E. BLACK, Plaintiff 4S. LISA M. BLACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 49- ,f66 / CIVIL IN DIVORCE COMPLAINT IN DIVOR.CF 1. Plaintiff is Todd E. Black, an adult individual currently residing at 102 South Fayette Street, Shippensburg, Cumberland County, Pennsylvania. He has lived there six (6) years. 2. Defendant is Lisa M. Black, an adult individual currently residing at 44 Thompson Creek Road, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 20, 1988, in Junction City, Kansas. 5. There have been no prior actions for divorce or annulment between the parties. 6. Plaintiff is a member of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, G FFIE &. ASSOCIATES lCnsten Goddard nsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA.C.S. Section 4904 relating to unworn falsification to authorities. DATE: 9 - f - 9 9 \ ? Cbmw , ` 64 J2 TODD E. BLACK, Plaintiff . r^` ? i Ja ?? .. ii ? !•rn _ M 1 4 TODD E. BLACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW LISA M. BLACK, NO. 99-5661 CIVIL Defendant : IN DIVORCE AND NOW, this 91 J?r day of j?kr t , 1999, comes Kristen Goddard Donsen, Esquire, attorney for Plaintiff, Todd E. Black, and states that the Defendant, Lisa M. Black, was served with a true and attested copy of the Complaint in Divorce by certified mail, restricted delivery on September 20, 1999. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Godd? d onsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800) 347-5552 Sworn and subscribed to this a/k day of 1991. Notary P is Noterlal Seal Public Robin J. Gos CUmberlanryd County Carlisle Bolo, 603 My Commission Expires Apr. 17, 2 a SENDER: tsq f*We b n t MVW 2 for eddNnW wvkoL I also Wbh to fooolve ifte OWnPWe Itwe 3,4A. and 4E, fowmnp servkes (for an ON Vwrr nw wd address w atom of my fwm w eW" m nNm 9n • extra fee): uu yo.toes ea4 W Ile frWOM ? M 0 or m the ttwk s pace dm not r. , pN?1n p aWme•nw A P w tl 1.? Addresswe Address um wW A99 u w a mmOm bdw10 attlda r"*m.. •re ROM RwWR VA Oxm to whom fr&Ws w EmvaM end the ceps O & 2.ARWMctod Delivery CormA postrnseter for fee. P VOIS 3 Ardde Addressed to: 48. Ardde NW r -Lisa Mi. Block 94 ?mp?m GYe?k ?uc>a' ?'"PPeiSb`"r?, ? 1?Z5`? 6. Recei B?:7P/Inf me) O J 9 ,t e. t?klnssse 1? ) / Replstered GN ExprmMa4 ? Irtwt.:J RoomReowforMomhvdn ? ML Date of Delhrery Qy - v9 Addressee's Address(Odrareyuasted Ca. sad /ae tY paid) +F? 102595-97-MI79 cr r? ? f . ! T •' I J n :J C 0c ? 1 r i Ilk, TODD E. BLACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW LISA M. BLACK, NO. 99-5661 CIVIL TERM Defendant : IN DIVORCE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 15, 1999 and served on September 20, 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: LISA M. BLACK, Defendant >- C.? - C; L. C: -.? ..? C.. 1 i ?_ :) TODD E. BLACK, Plaintiff VS. LISA M. BLACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 99-5661 CIVIL TERM IN DIVORCE 1. 1 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: LI KK4. BLACK, Defendant ? T ? Ir; i` ?•? i? ? ?_ ,; i..'. (.. Q, ?4 Cpl _. (. ' .. 7 LI . 1 ., i. _) TODD E. BLACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW LISA M. BLACK, : NO. 99-5661 CIVIL TERM Defendant : IN DIVORCE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 15, 1999 and served on September 20, 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 62::n c /') 7 M TODD E. BLACK, Plaintiff TODD E. BLACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW LISA M. BLACK, NO. 99-5661 CIVIL TERM Defendant IN DIVORCE I. I consent to the entry of a f inal 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:/-;,' ?.? 9Y /"/,Jj? TODD E. BLACK, Plaintiff ?7 C 1 L? ` ?- i .. i. i ?' c. (.. ?.