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HomeMy WebLinkAbout04-0594 Andrew C. Sheely, Esquire 127 S. Market Street p.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) LAURA J. KROUT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW RICKY A. KROUT, Defendant 04 - ..59'/ CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 against you and a decree in 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 with your children. When the grounds 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 1-800-990-9108 BY rrdrew C. Sheely, Esquire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew c. Sheely, Esquire ~27 $. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA IV NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA J. KROUT, : vs. CIVIL ACTION - LAW RICKY A. KROUT, Defendant 04 - 59'1 CIVIL TERM IN DIVORCE COMPLAINT 1. Plaintiff is LAURA J. KROUT, an adult individual who currently resides at 30 Sunset Drive, Mechanicsburg, Cumberland County, pennsylvania. 2. Defendant is RICKY A. KROUT, an adult individual who currently resides at 30 Sunset Drive, Mechanicsburg, Cumberland county, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. plaintiff and Defendant were married on September 12, 1998, in Mechanicsburg, pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. ~ 8. The marriage between the parties is irretrievably broken. 9. This action is not collusive. 10. The parties separated on or about February 7, 2004. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: February 1/ , 2004 /t;;ju(t Andrew C. Sheely, Esqu Attorney for plaintif PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 2 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: February ~ , 2004 (,/7 ~~ ~tl0l4 L - ~? / L/ LAURA J t)oUT' . - Andrew C. Sheely, Esquire 127 S. Market street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA J. KROUT, vs. CIVIL ACTION - LAW RICKY A. KROUT, Defendant 04 - /;7Y CIVIL TERM IN DIVORCE AFFIDAVIT Laura J. Krout, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. 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 a"thO"tia~ ~"~ ~. '", ~ ~ 0 "-' "- c.~') C -.- C::J ~ ~ ~ ~- -fl .,.. -., =.--;:! , (" pOl ~ .,. ~ , c:v ,;1 ~ ~ IA! "- ~ ~ .~, \ \ ., \ :r) '-.J 'IS \. , \ -" -t: ~ \ -...,. f~:;' ~ :..l ~ d ~ -.J Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA 10 NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LAURA J. KROUT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW RICKY A. KROUT, Defendant 04 - 594 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon RICKY A. KROUT, by Certified Mail, Return Receipt Requested, as indicated by the .tt,ched ,eceipt c"d', on Fob,u.ry ~04~ SWORN to and subscribed before me thisl~ay of February, 2004. ~;< ~ / 11, f; Jl.h>;Y Notary Public My Commission Expires: ~ N,01~"J.1l,'t S-,t'~}~l.. ~m;;,.L'y, ~!ot'""f Prtlt1c floro, Clll1llxilliinli Q) My ~.lIwlcl;l &pba Now. 18, ~ ,t .., ..D U1 m lr ru c:J m Certified Fee CJ Return Receipt Fee CJ (Endorsement Required) CJ Restricted Delivery Fee CJ (Endorsement Required) lOtal Po.tege & F... "'." ""d'" o e.~press e\pt 10f Mercn o 1I00U'0 lIac o 1I.Il'I\~red 0 C.O.O. Jl\ '1es o \l'\5\Jred 1'.'\6\\ "I (Extra Fee) dPe\\\Ief'1 - 'Restricts ....,., ~ &. , \l\l\l\l 3\l?'o, , ?S1\l /-- ~\l \l ~ ...=---=::: lIace'P' . p.eturn Wl\C\8l'lUt1\'o8f lee Isbill . oomestlC 2. 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PA 1705<; 1 Mechanicsburg Main Post Office MECHANICSBURG, Pennsylvania 170553459 4134870055-0096 02/11/2004 (800)275-8777 05:16:56 PM - Sales Receipt Sale Unit Qty Pri ce Product Description Final Price $0.60 $1.75 $2.30 70012510000030293568 MECHANICSBURG PA 17055 First-Class Return Receipt Certified Label Serial #: -------- -------- Issue PVI, $4.65 MECHANICSBURG PA 17055 $0.60 First-Class Restricted Delivery $3.50 Return Receipt $1.75 Certified $2.30 Label Serial #: -15G12.,0000030293568 Customer Postage -$4.65 Subtotal: $3.50 -------- ------... Issue PVI: $3.50 23c Stamp 1 $0.23 $0.23 Total: $8.38 Paid by: Personal Check $8.38 Order stamps at USPS.com/shop or call 1-800-Stamp24. Go to USPS.com/clicknship to print Shipping labels with postage. For other informetion call 1-800-ASK-USPS. BI1I#: 1000400476437 Clerk: 18 -- All sales final on stamps and postage. Refunds for guaranteed services only. Thank you for your business. Customer Copy UNITE;D STATE;S POSTAl. SE;R~ ...... f , ~ <-J;I ~~ (") ?~~ l:' ~ ....~ cc> C:;;:;) .<-- -rJ rl CO ~) o -n ~-.. 1111=: :'::~~1 ~~~~ ~) :.- 1'.) .. W o c.,:.-] .-~ ~ :-< . MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~<-,( day of March, 2006, by and between LAURA J. KROUT, (hereinafter "WIFE") and RICKY A. KROUT, (hereinafter "HUSBAND"); WIT N E SSE T H: WHEREAS, the parties hereto were married on September 12, 1998 , in Mechanicsburg, Pennsylvania; and separated on February 7, 2004; and WHEREAS, the parties have one child of this marriage; Tommy E. Krout, born on March 28, 1999: WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling completely the economic and other rights and obligations between each other, including, but not limited to: the equitable distribution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counseL WIFE was previously represented by Andrew Sheely, Esquire , and is now representing herself. HUSBAND is represented by Joanne Harrison Clough, Esquire. The parties further declare that each is executing the Agreement freely and voluntarily having either obtained sufficient knowledge and disclosure of their respective legal rights and obligations, or if counsel has not been consulted, expressly waiving the right to obtain such knowledge. The parties each 1 '. acknowledge that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. DIVORCE ACTION. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no fault divorce pursuant to S 3301( ) of the Divorce Code. A divorce action was filed by wife with the Court of Common Pleas of Cumberland County, Pennsylvania at Civil Action No. 04 -594 on February 11, 2004. The parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement or upon expiration of ninety (90) days after the service of said complaint on Husband. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Agreement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" and "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. 4. MUTUAL RELEASES. Each party absolutely and unconditionally release the other and the estate of the other from any and all rights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Each party absolutely and unconditionally releases the other and his or her heirs, executors, and estate from any claims arising by virtue of the marital 2 relationship of the parties. The above release shall be effective whether such claims arise by way of widow's or widower's rights, family exemption, 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 Pennsylvania, any state, Commonwealth, or territory of the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this Agreement an absolute and unconditional release from all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The parties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Each party understands that he/she had the right to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair and equitable, and that the terms adequately provide for his or her interests, and that this Agreement is not a result of fraud, duress or undue influence exercised by either party upon the other or by any person or persons upon either party. 6. SEP ARA TIONjNON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were 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. WIFE and HUSBAND shall not harass, disturb, or malign each other or the respective families of each other. 3 7. REAL PROPERTY. The parties are the joint owners of real property located at 30 Sunset Drive, Mechanicsburg, PA 17050. The parties sold this property and equitably divided the proceeds. 8. DEBTS. If a party has acquired debt, the parties agree that each shall assume full and complete responsibility for his or her own debts. HUSBAND represents and warrants to WIPE that since the separation he has not, and in the future he will not, contract or incur any debt or liability for which WIPE or her estate might be responsible, and he shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. WIFE represents and warrants to HUSBAND that since 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 he shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 9. HUSBAND hereby waives his right, title and interest to any of WIPE's pension and! or retirement and any and all other retirement benefits, otherwise disclosed. WIFE hereby waives his right, title and interest to any of HUSBAND's pension and! or retirement and any and all other retirement benefits, otherwise disclosed. The parties specifically waive any and all other retirement benefits obtained by the parties pre-marriage, during marriage, and post-separation. The individual who holds said benefits shall own the property solely and individually. Each party waives their right to title and interest to the other party's benefit. 4 10. BANK ACCOUNTS. The parties acknowledge that they have divided the marital bank accounts to their satisfaction. The bank accounts held solely in individual names shall become the sole and separate property of the party in whose name it is registered. Each party does hereby specifically waive and release his/her right, title and interest in the other party's respective accounts. 11. PERSONAL PROPERTY. Except as set forth here below, the parties hereto mutually agree that they have divided all furniture, household furnishings and personal property between them in a manner agreeable to both parties. The parties mutually agree that each party shall from and after the date of this Agreement be the sole and separate owner of all tangible personal property in his or her possession. 12. VEHICLES. The parties own an older model Chevrolet Lumina Mini Van. HUSBAND and Wife agree HUSBAND shall transfer his interest in said vehicle to WIFE and will sign any documents necessary to effect said transfer contemporaneously with the execution of this Agreement. 14. BANKRUPTCY OR REORGANIZATION PROCEEDINGS. Both Parties acknowledge each party filed Chapter 7 Bankruptcies after February 11, 2004 and received discharges. 15. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE. The parties hereby expressly waive, release, discharge and give up any and all rights or claims which either may now or hereafter have for spousal support, alimony pendente lite, alimony, or maintenance. The parties further release any rights that they may have to seek modification of the terms of this Agreement in a court of law or equity, with the understanding that this Agreement constitutes a final determination for all time of either party's obligations to contribute to the support or maintenance of the other. 16. ATTORNEY FEES, COURT COSTS. 5 Each party hereby agrees to be solely responsible for his or her own counsel fees, costs and expenses. Neither shall seek any contribution thereto from the other except as otherwise expressly provided herein. 17. ATIORNEYS' FEES FOR ENFORCEMENT. In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecting and enforcing his or her rights under this Agreement. 18. WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a.) The right to obtain an inventory and the appraisement of all marital and non-marital property; (b.) The right to obtain an income and expense statement of either party; (c.) The right to have all property identified and appraised; (d.) The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; and (e.) The right to have the court make all determinations regarding marital and non-marital property, equitable distribution, spousal support, alimony pendente lite, alimony, counsel fees and costs and expenses. 19. MUTUAL COOPERATION. WIFE and HUSBAND shall mutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of documents. 20. VOID CLAUSES. 6 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 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. 21. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 22. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 23. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. ~4(~ Ricky A. Krout ~~a()-~ LauraJ.Krou ' 7 COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF c..umJ5E~L.4N D On the :.:>i .\~ day of mO;y \,.." ;)\:::D{., . 2t#l5, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared Laura J. Krout, known to me (or satisfactory proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Loper, Notary Public Camp Hin Boro, Cumberiand County My Commission Expires 0cl27, 2007 Member, Pennsylvania ASsOciation Of Notaries -YYKY/)~ -m :t?rpDA Notary Pub c My Commission Expires: OcJ:d:n,-) 1, d cD' COMMONWEALTH OF PENNSYLVANIA :55. COUNTY OF CKmBEk'l..ANU On the ?:, \~ \- day of YYVxT.h, d..DY." . 2005, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared Ricky A Krout, known to me (or satisfactory proven) to be on of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. COMMONWEALIH OF PENNSYLVANIA Notarial Seal Mary M. Loper, Notary Public Camp Hill Boro, Cumbertand County My Commission Expires Oct. 27, Z007 Member. Pem'l-;;v\\J:;I'\?' A.~,~oc\atlf)n Of Notanes ~-m Notary Pu ic My Commission Expires: OeJo\:J.lf- ;;2" (;t~ 0 /\ ;;;l,()D 8 ....-:.>: -- -~ \"-;, '< LAURA J. KROUT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04-594 Civil Term RICKY A. KROUT, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD UNDER ~ 3301 (c) OF THE DIVORCE CODE 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 ~ 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: (a) Date of service: First Class Mail on February 13,2004. (b) Manner of service: United States Mail. Affidavit of Service filed: February 24, 2004. 3. Date of execution of the Affidavit of Consent required by ~ 3301 (c) of the Divorce Code: (a) By the Plaintiff: March 31, 2006 (b) By the Defendant: March 31, 2006 4. Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (a) By the Plaintiff: By the Plaintiff: March 31, 2006 (b) By the Defendant: March 31, 2006 , ... . 5. Related claims pending: NONE DATED: ( I '1...--1, ..-O~ Joanne 0 ugh, Attorney ID No. 36461 24 N, 32,d Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff LAURA J. KROUT, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 04-594 civil term RICKY A. KROUT, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on February 11, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing and service ofthe 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 or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Section 4904 relating to unsworn falsification to authorities. Date: 3-3/,Ofr; I~9~ i~,) <...;., :::::i f' (, LAURA J. KROUT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-594 civil term RICKY A. KROUT, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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 in do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. DATE: 1:7/ J\ - 0 \? ~.57 ~ i I I I ~ 0/' LAURA J. KROUT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RICKY A. KROUT, Defendant CIVIL ACTION - LAW IN DIVORCE v. NO. 04-594 civil term AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 11,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry ofthe decree or upon filing of my Waiver ofthe Notice ofIntention to Request Entry of the Decree. 4, I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Section 4904 relating to unsworn falsification to authorities, Date: J-JI-(l6 ~ 4,~/ Ricky A. Krout /". ,"',,) -" LAURA 1. KROUT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-594 civil term RICKY A. KROUT, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry ofa 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 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: J ~ 3/-t?h ~Cl~ Ricky A. rout ':") :.,^" t-..,:' "f:+;:f.:ti . . . . . . . . . . . . . . . :f.:f.:f. "f :f. :f. :f.:f.:f.:f. :f.:f.:f.:f. :+; "f :f. :f.:f."f :f.:f.:f.:f.:f.:f.:f.:f."f"f:f.:f."f:f.:f. :f.:f.:f.:f."f:f.:f.~ . IN THE COURT OF COMMON PLEAS : . OFCUMBERLANDCOUNTY : STATE OF PENNA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;t'''f:f.;t';t' Laura J. Krout. No. 04-594 PLAN'I'TF'F VERSUS Ricky A. Krout DECREE IN DIVORCE 116.LGI. )1 "9;' \ 1.0 AND NOW, , 2006 , IT IS ORDERED AND DECREED THAT Laura J. Krout , PLAINTIFF, Rickv A. Krout AND , 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; The terms of the atached Marital Settlement Agreement executed by the parties on March 31. 2006. are incorporated by reference, with this Decree. By THE COURT: AnOOT ~\\ -l \ \.~\\ " ~~~';P"OTHO"OTA"' :f.:f.:f. :+; "f "f:f.:f.;+:;+::f.:f.:f.:f.:f.:f.:f.:f.:f.:f."f:f.:f.:f."f:f.:f.:f.:f.:f.~ .. . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~? fftp '" ,A',T- ?"J"'" ?J'X^ f-;'F fir l' rr;,.v 4W -;-"? '1" 5C ~ . '