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Home My WebLink About99-06033"i. C o? r O S 0. 0` G i i 6 'I of i e• :?? :?• <e• ;e:• <e: te: u• te..?e;?:r•.?::r,• te:• te:Te:• :ewe: •:e> te:• :• te:! ?:e1 ?• ;e•. t?• t?• ;?• •:e:: •:w., i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF r PENNA. Lewis A. Napoli N c t .. 6033 ...... _ . ..... ........... 1999 ?'r r:ns Bonnita K. Napoli DE CREE IN AND NOW,..../,L.JW'?.....2-7 DI VORCE 1g .2400. , it is ordered and decreed that .. ... Lewis A. Napoli ..., plaintiff, and ............ ... Bonita K. Napo .li. . . . . . . . . . . . . . ....... . . . . . . . , , ... , defendant, are divorced from the bonds of matrimony. r r i s r r I ? r. r i i i b 1 ti 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; The marital settlement Agreement, dated August 5, 2000 and attached ........................................................................... here+ p, ,fig, 1pCPlporated,. but. not. merged,. into the De?ee ,ir?.Divorce..... . f A ? By ThCo?u Attest: / J. { (tp t •r Prothonotary 1 •?• •:e:• ce• {?? :?i {w• :?::?:• :?. •:r <?> :?: ;?> :e? L?J •:e? ce> •s:• <e:• :?:• :?: •:?:• !ei •.4 • W. Jd: .wcc 907l?t> ?O ua?c / ze- 14 t Soc. Sec. No. Lewis A. Napoli 179-44-8801 Soc. Sec. No. Bonnita K. Napoli 263-96-2242 4 i MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, is made this ? day of s 2000, between BONNITA K. NAPOLI, hereinafter referred to as "Wife" and LEWIS A. NAPOLI, hereinafter referred to as "Husband." WITNESSETH: The parties hereto, being Husband and Wife, were lawfully married on August 17, 1991 in York County, Pennsylvania and separated on or about April 3, 1999; There were no children born of the parties; Wife is represented by Mindy S. Goodman, Attorney at Law and Husband is represented by James W. Abraham, Attorney at Law; and Diverse and unhappy differences have arisen between the parties, and it is the intention of Husband and Wife to separate at this time, 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 and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of each other; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estate; The parties agree that this Agreement shall continue in full force and effect, from this date forward, whether or not the parties reconcile or ultimately divorce, whichever the case may be. In the event the parties would reconcile, this Agreement does not apply to marital assets acquired after the parties reconciliation, and serves only as a means of dividing the marital property that exists as of the date of execution of this Agreement. NOW THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, 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: 1. INCORPORATION OF PREAMBLE The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof. 3. EFFECT OF DIVORCE DECREE The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as the parties reconcile, or a final Decree in Divorce may be entered with respect to the parties. 4. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree that may be entered with respect to them. 5. NON-MERGER It is the parties' intent that thi:, Agreement does not merge with the Divorce Decree, but rather shall continue to have independent contractual significance. Each party maintains his or her contractual remedies as well as court ordered remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. Those remedies shall include, but not be limited to, damages resulting from breach of this Agreement, specific enforcement of this Agreement, and remedies pertaining to failure to comply with an order of court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in effect and as amended or hereafter enacted. 6. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties sign the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. 7. DISTRIBUTION DATE The transfer of property, funds and/or documents provided herein shall only take place on the "distribution date" which shall be defined as the execution date of this Agreement unless otherwise specified herein. 8. FINANCIAL DISCLOSURE 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. 9. SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from the other party, at such place or places as he or she from time to time may choose or deem fit. 10. NONINTERFERENCE Each party shall be free from interference, authority and control, direct or indirect, by the other in all respects as fully as if he or she were single and unmarried. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Neither party shall molest, harass, disturb or malign the other nor the family of said other, nor compel or attempt to compel the other to cohabit or dwell with him or her. 11. MUTUAL RELEASES Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does remise, release, quitclaim, and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of and from any and all claims in the nature of dower and 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 as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of the Commonwealth of Pennsylvania or any other state or any country, as well as any and all other claims, demands, damages, actions, causes of actions, or suits at law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to be done by said party prior to and including the date hereof; except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement, and shall in no way affect any cause of action in absolute divorce which either party may have against the other party. Notwithstanding the foregoing, should either Husband or Wife have a valid will in existence at the time of his or her death, and should said will designate the other as a beneficiary of his or her estate, said will shall be given full force and effect regardless of the terms contained in this Separation Agreement. Should either of the party's wills be revoked or be invalid for any reason, the terms of this Separation Agreement shall be binding upon the parties. 12. MARITAL PROPERTY The parties hereto acknowledge and agree that they have acquired various assets during their marriage, whether the same were held jointly or individually by the parties hereto, including but not limited to: (a) Household goods, contents, furniture and furnishings; (b) Life Insurance Policies; (c) Various bank accounts; (d) Various motor vehicles; (e) Husband's Thrift Savings Plan valued at approximately $47,072.11 as of the date of separation; (f) Husband's Annuity with American Life, valued at approximately $2,921.00 as of the date of separation; (g) Wife's Thrift Saving Plan valued at approximately $24,800.00 as of the date of separation (h) Tools with an estimated value of $10,000.00; (i) Two pre-paid cemetery plots located in a Catholic cemetery. 13. DISTRIBUTION OF MARITAL PROPERTY The parties hereto covenant and agree that the assets described in Paragraph 13, above, together with any other property that the parties acquired individually or jointly prior to the marriage, have been or are hereby being divided and distributed between them as follows: 7 (a) Household goods, contents, furniture and furnishings - The parties hereto have previously divided the household goods, contents, furniture and furnishings among and between themselves. Those household items that are presently in the possession of Husband shall become the sole and separate property of Husband; those household items that are presently in the possession of Wife shall become the sole and separate property of Wife. (b) Life Insurance Policies -The parties shall retain ownership of their individual life insurance policies and each shall take whatever steps are necessary to sign off on the policy of the other. (c) The parties hereto acknowledge that the bank accounts have heretofore been equitably divided by Husband and Wife. (d) Motor Vehicles - (i) Wife shall retain sole and exclusive possession of the 1993 Chevrolet Lumina, which is presently unencumbered. Husband shall take whatever steps are necessary to transfer title of the vehicle to Wife. (ii) Husband shall retain sole and exclusive possession of the 1987 Buick Station Wagon, which is presently unencumbered. In addition, Husband shall retain sole and exclusive ownership of any other vehicle that he purchased after the parties' separation. Husband shall be solely and exclusively responsible for any and all encumbrance on said vehicle and shall defend and hold Wife harmless from same. 8 (e) Husband's Thrift Savings Plan - Husband shall retain sole and exclusive possession of his Thrift Savings Plan valued at approximately $47,072.11 as of the date of separation, and Wife shall relinquish any and all right, title and interest she may have in same; (f) Husband's Annuity with American Life - Husband shall retain sole and exclusive possession of his Annuity with American Life valued at approximately $2,921.00 as of the date of separation, and Wife shall relinquish any and all right, title and interest she may have in same; (g) Wife's Thrift Saving Plan - Wife shall retain sole and exclusive possession of her Thrift Saving Plan valued at approximately $24,800.00 as of the date of separation, and Husband shall relinquish any and all right, title and interest he may have in same. (h) Tools - Husband shall retain sole and exclusive possession of his tools, which have an estimated value of $15,000.00 as of the date of separation; (i) Two pre-paid cemetery plots located in a Catholic cemetery (there are actually three, only two of which are marital property) - Husband shall retain sole and exclusive possession of both pre-paid cemetery plots and shall reimburse Wife for the current fair market value of one of these plots. Husband shall contact the cemetery, obtain written verification of the price of a new cemetery plot in that particular cemetery, and shall reimburse Wife the full amount within sixty (60) days of the date of execution of this Agreement. 14. LUMP SUM CASH PAYMENT TO WIFE Husband shall pay to Wife the sum of TEN THOUSAND DOLLARS ($10,000.00). This sum shall be paid within six (6) to eight (8) weeks of the date of execution of this Agreement. Said lump sum cash payment represents Wife's share of the marital property presently in the possession of Husband and does not constitute alimony or support. Until such time as Husband is able to make the lump sum cash payment to Wife, Husband shall pay to Wife the sum of $270.00 per month, said payments to be made payable directly to Wife. At such time as the lump sum cash payment is made, Husband's obligation to pay $270.00 per month will terminate and Wife will immediately execute an Affidavit of Consent under 23 Pa.C.S.A. § 3301(c) of the Divorce Code. 15. MARITAL DEBT The parties hereto acknowledge and agree that in addition to vehicle loans and/or other loans that are addressed elsewhere in this Agreement, they have accumulated the following marital debt during their marriage: (a) A personal loan from Husband's parents in the amount of $5,700.00; (b) A loan against Husband's Thrift Savings Plan in the amount of $14,000.00; (c) A Personal Signature Loan with Members 191 Federal Credit Union in the amount of $5,000.00. 10 Husband shall assume sole and exclusive responsibility for the foregoing marital debt. Husband covenants and agrees to indemnify, defend and save Wife harmless from all liability or claim on account of said debts and obligations for which he has assumed responsibility from and after the date hereof. 16. INDEMNIFICATION FOR PAST DEBTS Other than as stated elsewhere in this Agreement, each of the parties hereto covenants and agrees to assume full responsibility for and to pay all debts and obligations of whatsoever kind or nature incurred individually by that party either before or after the date of separation, October of 1999, and each of the parties hereto hereby covenants and agrees to indemnify and defend the other party and save him or her harmless from all liability or claim on account of said debts and obligations from and after the date hereof. 17. FUTURE OWNERSHIP OF PROPERTY Each of the parties hereto may hereafter own and enjoy, independently of any claims or rights of the other, all items of personal and real property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively in all respects and for all purposes as though he or she were unmarried. 18. MUTUAL RELEASES The parties hereto acknowledge that under prevailing Pennsylvania law they each have certain possible fiscal rights, including but not limited to the following; spousal support, alimony pendente lite in the event of a divorce, permanent alimony subsequent to a divorce, recovery of counsel fees, costs and expenses in the event of a divorce, and the equitable distribution of marital property, as well as the right to seek discovery of assets through interrogatories and/or depositions. It is the intention of the parties hereto that except as otherwise provided herein, all of the foregoing rights and remedies are hereby waived and forever released and that this Agreement shall have the effect of a final Order of Court relieving each party of the obligation to the other for any and all of the foregoing possible rights and remedies, except as otherwise provided herein. Specifically, both parties covenant and agree that: both waive, release and forever relinquish their respective possible rights of spousal support of, from and against the other party; neither party will at any time seek alimony pendente lite from the other party; neither party will seek discovery of assets; and the parties have effected an equitable distribution of their marital property and neither will seek further distribution by any action at law or in equity. 19. PENSIONS & RETIREMENT BENEFITS Each party hereby waives any and all claims that he or she may have against the other to any pension, employee saving or other stock benefit program 12 of the other, if applicable. Each party shall execute the paperwork necessary to relinquish his or her interest in any pension, employee saving or other stock benefit program of the other. 20. OTHER WRITINGS Each of the parties hereto agree to execute any and all documents, deeds, bills of sale or other writings necessary to carry out the intent of this Agreement. 21. ENTIRE AGREEMENT This Agreement constitutes the entire understanding between the parties, and there are no covenants, conditions, representations or agreements, oral or written, of any nature whatsoever, other than those herein contained. 22. LEGALLY BINDING It is the intent of the parties hereto to be legally bound hereby and this Agreement shall bind the parties hereto and his or her respective heirs, executors, administrators and assigns. 23. COSTS TO ENFORCE In the event that either party defaults in the performance of any duties or obligations required by the terms of this Agreement, and both extra-judicial and 13 judicial proceedings are commences to enforce such duty or obligations, the party found to be in default shall be liable for all expenses, including reasonable attorneys' fees, incurred as a result of such proceeding. 24. AGREEMENT VOLUNTARILY AND CLEARLY UNDERSTOOD Each party to this Agreement acknowledges and declares that he or she respectively: a. Is fully and completely informed as to the facts relating to the subject matter and their Agreement as the rights and liabilities of both parties; b. Husband enters into this Agreement voluntarily after receiving the advice of the James W. Abraham, Attorney at Law, and Wife enters into this Agreement voluntarily after receiving the advice of the Mindy S. Goodman, Attorney at Law; C. Has given careful and mature thought to the making of this Agreement; d. Has carefully read each provision of this Agreement; e. Fully and completely understands each provision of this Agreement, both as to the subject matter and legal affect. 25. AMENDMENT OR MODIFICATION This Agreement may be amended or modified only by a written instrument signed by both parties. 14 26. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in taw or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 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. 27. LAW APPLICABLE This Agreement shall be governed, construed and enforced under the statute and case law of the Commonwealth of Pennsylvania. 28. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the paragraphs and subparagraphs herein, 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. 15 BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first written above. Mindy S. Goodman, Attorney at Law Attorney for Wife James W. Abraham, Attorney at Law ?B1t t In }?Q"LL . Bonnita K. Napoli, Wif )?AAJ(- Lewis A. Husband 16 ,:, ?- ?;. - ; - ,, ` .-:. - ;, . --- ,, `:. ? ?, ?. LEWIS A. NAPOLI IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. V. NO. 99 6033 BONNITA K. NAPOLI CIVIL ACTION - LAW Defendant DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section !x) 33n1(c) ( ) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: on October 7, 1999; see attached Affidavit of service with green return receipt card. 3. Complete Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on 8/18/00 and by Defendant on 8/2/00 (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A 4. claims : See Agreement datede8/5/00 attachedptodthe Decree inrDivorceettlement 5. Date and manner of service of the Notice of Intention if theledecreePraeciipsetotobeTracord, enterednsmit asectionf3301cd ( attached Divorce Code: _N/A ( )(i ) of the 6. Date and manner of service of Notice of Intention to file Praecipe To Transmit. Record, a copy of which is attached, if the decree is to be entered under section 3301(c) of the Divorce Code Inten OR, date of execution of Waiver of Notice of tion 8/2/00; date of filing Waiver 8/ i/00. James W. Abraham, Esq. 513 North Second St. Harrisburg, PA 17101 DATE: 8/18/00 (717) 232-7825 Attorney for Plaintiff LEWIS A. NAPOLI : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. NO. 99 6033 BONNITA K. NAPOLI CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, and attorney for Plaintiff in the above-captioned divorce action, hereby certify and affirm that the Complaint in said action was served upon Defendant by certified mail on October 7, 1999, as stated on the green return card from the Post Office attached hereto: SENDER: I also wish to receive the . . CwnpWe some t and/w x for edatlontl seMua IOllowing eervlCea (for an • Complele WM 3.4e, and xb. • Print you runts end eddron Wee rowans of We form w Net ws Con rotum this extra lee): 8 s cam Aftsch t}1e6m W W. frmt d the mespaw. or on to tuck "apace does m 1. Addressee's Address ?? e yime 'Mtum Heoepr npueeteo'm the mo V. bek tlr erode numher. 2. ? Restricted Delivery • TM Rae neaelpt wia W W wMm we snide was del Wered and the de4 COnsub postmaster for fee. TL deWAcla rderee. 3. Addressed to: 4a. Article Number u oI / 083 5,Y9 djO ItYI (: f 4. /-1 0? i ) I i ':-- 4b. Sorvice Type E 4Awq- J""''` ? Registered "wined ( r /f n ? Express Mail El Insured / _g ? Retum Reteiptfor Merdwndise ? COD , 7. Date of Delivery 5. ReceNed By: (Print Name) B. Addressee's Address (Only it requested and tee Is paid) 6. Signal xl? .2 PS Fonn DATE: 8/18/00 Dacernber094 toMeo-esaovs James W. Abraham, Esq. o ?- cn c - ?¢ ?:. .-, _? u LEWIS A. NAPOLI Plaintiff V. BONNITA K. NAPOLI Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. ' /'n//J NO. q c, ( o33 eta `-"V : CIVIL ACTION - LAW : DIVORCE NOTICE YOU HAVE against the claims ; prompt action. You may proceed without entered against you against you for any by the Plaintiff. important to you, in BEEN SUED IN COURT. If you wish to defend et forth in the following pages, you must take are warned that if you fail to do so the case you and a decree in divorce or annulment may be by the Court. A judgment may also be entered )ther claim or relief requested in these papers ou may lose money or property or other rights .luding 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 Court Administrator, Cumberland County Courthouse, 1 Courthouse Square, 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 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 LEWIS A. NAPOLI : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. NO. 99- G U 33 &,?i 7-.m.-- BONNITA K. NAPOLI : CIVIL ACTION - LAW Defendant DIVORCE COMPLAINT AND NOW, comes Plaintiff, Lewis A. Napoli, by and through his attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: COUNT I DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff, Lewis A. Napoli, is an adult individual who currently resides at 1316 Well Drive, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant, Bonnita K. Napoli, is an adult individual who currently resides at 505 Chestnut Grove Road, Dillsburg, Pennsylvania, 17019. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 17, 1991 in Dillsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties which are active. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. S. Plaintiff and Defendant are not members of the Armed Forces of the United States. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff DATE: 10/1/99 1/ / VERIFICATION I, 'S. 7c S Y? i , the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my I knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities. DATE: / - z C/- C) / CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, on the date indicated below, to the following person(s): Bonnita K. Napoli 505 Chestnut Grove Road Dillsburg, PA 17019 DATE: 10/1/99 James W. Abraham, Esq. P a U Cn ?1 V v - LEWIS A. NAPOLI Plaintiff V. BONNITA K. NAPOLI Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. : NO. 99 6033 : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 1, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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 Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: >lat off' LEWIS AA P t C1 r CV C rl :.J o (J LEWIS A. NAPOLI Plaintiff V. BONNITA K. NAPOLI Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 99 6033 : CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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. 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.A SECTION 4904 RELATING TO UNSWORN FALSTFICATION TO AUTHORITIES. DATE: ?-4,-UJ ?iwa a Ylopr?' LEWIS A. NAPOLI ? - ? u: - '? _ , J ? ? ^ ( ,. N - ??' ' 1 -? i:_ ti ?.i, O :? - O C.J LEWIS A. NAPOLI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY, PENNSYLVANIA V. BONNITA K. NAPOLI, Defendant NO. 1999-6033 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33010) OF THE DIVORCE CODE A Complaint in divorce under § 3301 (c) of the Divorce Code was filed on June 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. 1 consent to the entry of a final decree of divorce without formal notice of the intention to request entry of a divorce decree. 4. 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. 5. 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. Cons. Stat. § 4904, relating to unsworn falsification to authorities. Date: ? Bonnita K. Napoli 6 u- r J._ c: ? ? U