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HomeMy WebLinkAbout99-05895 } FT qtr l?I^% . i` I A lA ;fh wl ' p SC t?. 'rP' `? t rt r1 1 1? F Y ?l r yy f i ?'1 ?l:fl R I. . 1:;:11 V V A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. r *x? a Cathi Jo Green Plaintiff N O. 5895 - 99 Ciydl Terns VERSUS Richard. F. Green DECREE IN DIVORCE AND NOW, J2El U? 1 [' O) IT IS ORDERED AND ? DECREED THAT Cathi Je Green PLAINTIFF, AND Richard F. Green , 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. BY THE COU T: ATTE J. P OTHONOTARY .... . ... ....... .. .. .. .. ,;, ,. Ap , !J/ yio7?ix "w, G T CATHI JO GREEN, Plaintiff vs. RICHARD F. GREEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 5895 - 99 Civil Term ACTION IN DIVORCE MARRIAGE SET?LT;LEMENTAGREEI?'F?T THIS AGREEMENT, made thi:S' ' day of N , 2000, by and between, CATHI JO GREEN, of Silver Spring Township, Cumberland ounty ennsylva6ia, hereinafter referred to as "WIFE", and RICHARD F. GREEN, of Silver Spring Township, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND". WHEREAS, Husband and Wife were lawfully married on December 30, 1972, in Bucks County, Pennsylvania, and; WHEREAS, there were two children bom of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, WHEREAS, HUSBAND is PRO SE and has personally chosen to NOT retain an attorney. The Wife has employed and had the benefit or counsel of Jane Adams, Esquire, as her attorney. Each party has carefully and completely read this agreement in its entirety. Each party, after reading this agreement, understands the agreement and its legal effect. Each party is entering into this agreement freely and voluntarily after reading it, and the execution of this agreement is not the result of duress or undue influence. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. Each party hereto still desires to execute this Agreement, acknowledge that the terms and conditions set forth herein are equitable to each of the parties and waives his or her respective right to have the Court of Commons Pleas of Cumberland County or any other Court of competent jurisdiction make any determination or Order affecting the respective party's right to a divorce, alimony, alimony pendants lite, equitable distribution of all martial property, counsel fees, and costs of litigation. NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was filed, both parties will agree and sign the paperwork to complete a No-Fault Divorce after the applicable ninety (90) day time period has run. It is the intention of the parties that the division of property in this agreement shall be final and forever determine the parties 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. 2. INTERFERENCE. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner 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 or property hereafter acquired by the other. 3. SUBSEQUENT DIVORCE. The parties hereby acknowledge that WIFE has filed a Complaint in Cumberland County, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. WIFE hereby waives all rights to request Court Ordered counseling under the Divorce Code. 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 of 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 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 to be forever binding and conclusive upon the parties. 4. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 6. 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 this Agreement unless otherwise specified herein. 6. WIFE'S DEBTS. Wife represents and warrants to Husband that since the 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 Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the 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 Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. S. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. All loans and/or debts with Belco Community Credit Union, account 8635740. As well as all loans or debts under the Texaco Credit Card. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. All loans and/or debts under the Sunoco Card and Home Depot Account. HUSBAND and WIFE agree that they will close out all joint credit card accounts and reapply for new accounts in their own name. 9. MUTUAL RELEASE. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties sever had or now has against the other, except any or all cause or causes of action for divorce and except any or all causes of action of breach of any of the provisions of this Agreement. 10. DIVISION OF PERSONAL PROPERTY. Husband and Wife acknowledge that they have divided their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties shall exchange the following personal property pursuant to this agreement: HUSBAND may obtain personal items such as clothing, tools, a various personal effects from the marital residence at 1 Mountain View Drive, Mechanicsburg, Pa. 17055. 11. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions, retirement plans, Incentive Savings Plans, and Tax Sheltered Annuities, except as relates to Higher Education for the couple's children. (See below). The parties agree never to assume any claim to such benefits of the other at any time in the future. 12. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The TROOPER and PLYMOUTH shall be and remain the sole and exclusive property of Wife. (b) The JEEP CHEROKEE shall be and remain the sole and exclusive property of Husband. 13. MARITAL HOME. WIFE holds title to the premises identified as 1 Mountain View Drive, Mechanicsburg, Pa. 17055, Silver Spring Township, Cumberland County, 17055. The parties agree as follows with respect to the marital residence: (a) HUSBAND has delivered a warranty deed, conveying to WIFE all of his right, title and interest in and to the marital residence. Therefore, WIFE is the sole owner of the marital residence and has recorded the deed and may take any other action with respect thereto that she deems appropriate. (b) As of the date of delivery of the deed, and without regard to when bills for such items are' incurred, received or due, WIFE shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and WIFE shall keep HUSBAND and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense. (c) There is presently an outstanding mortgage against the martial residence in favor of National City Mortgage of Dayton, Ohio, in the amount of approximately $140,000.00 under account number 064743-2. Commencing on the date of this agreement, WIFE shall be solely responsible for timely payments of all past, present, and future principal, interest and other fees under the mortgage. (d) WIFE shall indemnify and hold HUSBAND harmless from any liability, cost or expense, in connection with any expense required to be made by WIFE including but not necessarily limited to, the first mortgage, property taxes, and insurance with respect to aforesaid premises. HUSBAND shall indemnify and hold WIFE harmless from any liability, cost, or expense in connection with any expense required to be made by HUSBAND including but not necessarily limited to, the second lien on the aforesaid premises. 14. ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. 15. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for calendar years 1972 through 2000 have been filed and that no notices have been received from the Internal Revenue Service which remain unresolved. Each party further represents to the other that to the best of his or her knowledge, the information set forth in the joint tax return for these calendar years was and remains accurate as relates to his or her sole income and acknowledges that the other party relied on such representations in signing those returns. 'rherefore, if any deficiency in federal, state, or local income taxes is proposed, or any assessment of any such tax is made against the other party by reason of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax, interest, and penalties or expenses shall be paid solely and entirely by the responsible party as determined to be attributable to that party on account of misrepresentation or failure to disclose relevant information of income on the aforesaid joint returns. For the year 2000, HUSBAND and WIFE plan on filing their taxes married joint. If any refund is due and owing, the refund will be split 50%/50% between the parties. For all subsequent years, each party will file separately, and retain their respective refund amounts. 16. WAIVER OF ALIMONY. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively have against the other for alimony, support, or maintenance. It shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. In furtherance of this paragraph, Wife agrees to withdraw any and all claims that she has heretofore filed for alimony with the Court of Common Pleas of Cumberland County or any other Courts. 17. LEGAL AND PHYSICAL CUSTODY OF CHILDREN. The parties agree that WIFE will have primary and legal physical custody of the children, Rebecca Green and Kati Green. However, HUSBAND shall have liberal temporary physical custody according to a schedule to be agreed upon by the parties which shall be consistent with the best interest and welfare of the said children. 18. HEALTH INSURANCE • CHILDREN. WIFE shall provide Blue Cross, Blue Shield, Major Medical, and dental coverage or its equivalent for the benefit of the children. As secondary insurance, WIFE shall also provide such coverage for the benefit of the children, for so long as it is available to her through her employment. In the event one party is unable to provide the aforesaid coverage, the other party shall obtain Blue Cross, Blue Shield, Major Medical, and dental coverage or its equivalent for the benefit of the children for so long as it is available through employment. If neither party is able to maintain said Insurance through their respective employment, then the cost of said coverage shall be divided equally by the parties. The parties agree that the twenty percent (20%) of the medical expenses which are not covered by the medical coverage programs referred to above shall be paid by WIFE. The parties further agree that any non-covered or extraordinary medical and/or dental expense, including orthodontia shall be paid by WIFE. This paragraph shall be made a part of any order of support referred to previously in this agreement. 19. HIGHER EDUCATION. The parties have a Mutual Fund valued at approximately $20,000 that is jointly titled and is to be used for education purposes. HUSBAND also has a retirement fund, valued at approximately $40,000. WIFE desires that her portion (50%) of this fund be used for education purposes. 20. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 22. MUTUAL COOPERATION. Each parry 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 further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 23. APPLICABLE LAW. The 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. 24. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each parry 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 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. This agreement shall be binding and shall insure the benefit to the parties hereto and their respective heirs, executors, administrators, successors, and assigns. 28. WARRANTY OF DISCLOSURE. The parties warrant and represent that they have made a full disclosure of all their assets and their valuation prior to the execution of this Agreement. This disclosure was in the form of an informal exchange or information by the parties' Attorneys and this Agreement between the parties is based upon this disclosure. 28. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other then those expressly set forth herein. 27. OTHER DOCUMENTATION. Wife and Husband agree that they will cooperate and execute any and all written Instruments, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 28. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to Insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 29. SEVERABILITY. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 30. 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 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. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: CATHI JO GRE7 ness Date: COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND 1 On this, thec jF day of kavee? , 2000, before me, the undersigned officer, personally appeared CATHI JO GREEN known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. otaryA, - - -+.. 1j,•, My co issidn expires. SEAL Fit u1 RICHARD F. GREEN Date: COMMONWEALTH OF PENNSYLVANIA *W' s COUNTY OF CUMBERLAND ):ss On this, thexi % day of ?)P&Z ..2000, before me, the undersigned officer, personally appeared RICHARD F. GREEN known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and proca ru i .,? ; ?e r.?.a: rr , S?C avly commission expi a -is F/ C) ?"J c ?. _ Ci SiL ? ? ) ?J .J l CATHI JO GREEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. qq - ")?95 C: &Tenrn RICHARD F. GREEN, ACTION IN DIVORCE Defendant 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 CATHI JO GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND cCXO?UNTY, PENNSYLVANIA VS. No. ?? '1`t??- 5095 RICHARD F. GREEN, : ACTION IN DIVORCE Defendant 1. Plaintiff is Cathi Jo Green, an adult individual, who has resided at 1 Mt. View Dr., Mechanicsburg, Pa., 17055 since 1987. 2. Defendant is Richard F. Green, an adult individual, who has resided at 1 Mt. View Dr., Mechanicsburg, Pa. 17055, since 1987. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 30, 1972 in Bucks County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together, namely, Rebecca Green, D.O.B 12-2-81, and Kati Green, D.O.B. 4-8-84. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. §4904 relating to unswom falsification to authorities. /1' - /?p /7 ?7 Cathi Jo Green, aip iff Respectfully submitted, Date: / Z3 (/1 t tr d ?7i1 ?_ Jane Adams, Esquire . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 15 UiL_ [V 7l Cc z r- cn O vN U N 0 00 CATHI JO GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 5895 - 99 Civil Term RICHARD F. GREEN, ACTION IN DIVORCE Defendant TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 33§ 01(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receipt r gq u. t d delivered on September 29 1999, 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: December 21, 2000. By Defendant: December 20, 2000. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 28, 2000. Date: L- 3 _ b I Respectfully Submitted: J ne Adams, squire I . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ;uf, q a ° w p 'o CATHI JO GREEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA. VS. No. 5895 - 99 Civil Term RICHARD F. GREEN, ACTION IN DIVORCE Defendant 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 24, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or expenses, if I do not claim them before a divorce is granted. I understand that the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: - a / - 0 U 4 Cathi Jo Green laj tiff 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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: oa -4 C l Cathi Jo Green, Plai of ?_ o? ,_ -: ? - ?-.- ??_; ., . ?? ?. O'J . r 7 iL:'' C• - 1:.1 ? IL:J ?Jn O ? i`_ _ ? O 7 V r CATHI JO GREEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 5895 - 99 Civil Term RICHARD F. GREEN, ACTION IN DIVORCE Defendant 1. A complaint in divorce under section 3301(c) of the Divorce Code was fled on September 24, 1999. 2. The marriage of Plaintlff and Defendant is irretrievably broken and ninety days have elapsed from the da of the filing of the Complaint. ?- ---- - 3 ant to the entry of a final decree of divorce. 4. 1 understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or expenses, if I do not claim them before a divorce is granted. -? I understand that the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. Date: /0C) /? f5 k- !!! Richard F. teen, Defendant 1. 1 consent to entry of a final decree of divot dhout-?- notice 2. 1 understand that I may lose rights concerning alimony, division of propert'Y?Nwyer's fees or expenses if I do not claim them before a divorce is granted. C.._-_:_. - 3. 1 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 verity 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: ? / la a /zo 'c'q rA - Richard F. Green, Defendant .Y C _ to l• ^?(L e i 'SENDER:-• also wish to receive the • Complete items 1 and/a, 2 for additional services. a s s Com({IaIifitems 3, 4a, and 4b. ..:; following services (for an 4 • Pdcardn?yt0 bur you. name and adds. on the reverse of Ihle form so Ihat wa can return this extra lee): C s Adach this farm to the from of the mallpiece, or on the back if space does not 1. ? Addressee's Address ppeermit. m • Wdte Wefbm Receipt Requesfad on the mailplece below the article number. 2 R9strlcted quelive is The Return Receipt will show to whom the article was delivered and the date C delivered. Cons e 4 1 o rticfe Addressed lo: 4a. Article Number ?? )?,?tan F Glee. , 33 D 6 C ; 1 E nn 4b. Service Type / y'(OUV1 Ytt<.a„ Uj Q,t,.r ? Registered 1u ' ? Express Mail B stiff 1 UgG 191.9 11 Return A COD r?5. Received By: (Print / 70 ( J .Date of D D U 2 -4 i. r me) S. Addresse dreM111Only uVtod •Y ' and lee is C 1l0Ott?? or a U$PS I '" PS Forth 3811, December 1994 i 102595 99.8 0229 I ' 1 ! 1 1 F l CATHI JO GREEN, Plaintiff VS. RICHARD F. GREEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 5895 - 99 Civil Term ACTION IN DIVORCE AND NOW, this October 1, 1999, I, Jane Adams, Esquire, hereby certify that on September 29, 1999, a true and correct copy of the Plaintiff's Notice to Defend and Complaint were served, via certified mail, return receipt requested, addressed to: Richard Green 1 Mountain View Drive Mechanicsburg, Pa. 17055 Respectfully Submwa)o'v?_ itted:J e Adams, Esquire . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF R a N W LU u_ O ? j