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HomeMy WebLinkAbout08-6254ABRAHAM LAW OFFICES 45 East Main Street. Hummelstown. PA 17036 (717) 566-9380 CAROL CHAMBERS MILLS Plaintiff V. HERBERT B. MILLS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. Of - bd6q &VI I -l (h, CIVIL ACTION - LAW : DIVORCE NOTICE 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 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 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 Court Administrator, 4`h Floor, 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: Court Administrator 4'h Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 CAROL CHAMBERS MILLS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 0 P • 6 2 5V L' ( 7'? HERBERT B. MILLS : CIVIL ACTION - LAW Defendant : DIVORCE COMPLAINT AND NOW, comes Plaintiff, Carol Chambers Mills, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Hummelstown, Pennsylvania and files the following: NO-FAULT DIVORCE (Pursuant to 23 Pa.C.S. Section 3301(c)) 1. Plaintiff, Carol Chambers Mills, is an adult individual whose address is 1226 Pin Oak Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Herbert B. Mills, is an adult individual whose address is 1226 Pin Oak Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident 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 January 14, 1984 in Strasburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. 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 bmitted: James W. Abraham, Esq. Awn Law Offices 45 East Main Street Hummelstown, PA 17036 (717) 566-9380 Attorney for F'b"K Carol Chambers Mills DATE: 1 OV21108 I, C,?40 L (f ff- AM46YES A us , the undersigned, hereby verify wW cozy that the foregoing document and the statements made therein are true and tort to the best of ;my Imowladge, information and belief. I further understand that any a A met* t le:hmin-are subject to the penalties of Title 18 Pa.C.S.A. Section 4904 r?atiag to-unsworn falsification to authorities. I DATE: I DO "?/0(5 CERTMCATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have sewed a true and correct copy of the foregoing document, by certified mail, upon the following person at the following address on the date stated herein: Herbert B. Mills 1226 Pin Oak Drive Mechanicsburg, PA 17055 DATE: 10/21/0& James W. Abraham, Esquire LAJ q a c n co CAROL CHAMBERS MILLS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 6254 CIVIL TERM HERBERT B. MILLS : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 21, 2008. 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 penal ' s of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. ? n A n A A n /? /7 / ." DATE: bl) _WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) 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. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A_ Section 4904, relating to the unworn falsification to authorities. DATE: V 4{ !If „1u 7Q49 31 25 ` " ` CAROL CHAMBERS MILLS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 6254 CIVIL TERM HERBERT B. MILLS : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 21, 2008. 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 the unworn falsification to authorities. 0 DATE: HERBERT B. MILLS, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) 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. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DATE: 0" dr., IF HERBERT B. MILLS, Defendant RL1;,l,r'- sn,'.t? . ?i i 1, Ii f. OF THE ?y 2609 iUti Z5 IF I' ' J CAROL CHAMBERS MILLS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 6254 CIVIL TERM HERBERT B. MILLS : CIVIL ACTION - LAW Defendant : DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of ?--- , 2009, by and between Carol Chambers Mills ("Wife"), of Mechanicsb , Pennsylvania, and Herbert B. Mills ("Husband"), of Mechanicsburg, Pennsylvania. WITNESSETH WHEREAS, the parties hereto are Husband and Wife, married on January 14, 1984 in Strasburg, Pennsylvania. WHEREAS, diverse, unhappy 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 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, and the settling of any and all claims and possible claims by one against the other or against their respective estates, as well as any other matters related hereto. NOW THEREFORE, in consideration of the 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. 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 a 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 may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code of 1980, as amended February 12,1988. 2. 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 a final decree in divorce may be entered with respect to the parties. The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement. 3. DATE OF EXECUTION: 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. 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. 5. CONSENT OF PARTIES/ADVICE OF COUNSEL: Husband and Wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and Wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. Husband and Wife acknowledge that they have each had the opportunity to have this Agreement reviewed by an attorney and/or have done so, prior to signing. 6. FINANCIAL DISCLOSURE: The parties acknowledge, confirm and verify that each has relied on the substantial accuracy of the financial disclosure of the other, except as set forth herein as an inducement to the execution of this Agreement. In the event Husband or Wife has failed to disclose any information regarding any marital asset and/or marital debt, the parties' reserve the right to equitable distribution of said marital asset(s) and/or debt(s), even after the entry of a decree in divorce; and further reserve any other rights which may arise from said non-disclosure, even after the entry of a decree in divorce. 7. PERSONAL PROPERTY: Husband and Wife agree that Husband shall have and keep as his sole and separate property, the 1996 Dodge Dakota truck and Wife shall transfer sole title to Husband. Wife shell have and keep as her sole and separate property the 2002 Saturn Vue car. Husband and Wife shall be solely responsible for any and all financial and legal obligations regarding their respective vehicles and shall indemnify and hold the other harmless as to any default of their financial or legal obligations. 2 Except as otherwise stated herein, Husband and Wife hereby acknowledge that they have equitably divided all household furnishings and/or items, as well as all other personal property, to their mutual satisfaction and neither party shall make a claim against the property as agreed upon and/or in the other's possession. 8. REAL PROPERTY: Husband and Wife hereby agree that the marital residence, located at 1226 Pin Oak Drive, Mechanicsburg, Pennsylvania (hereinafter "the Property") is marital property. Husband and Wife agree that the Property shall become the sole and separate property of Wife upon Wife's removal of Husband's name from the existing mortgage and payment to Husband in the amount of Forty Thousand ($40,000.00) Dollars, representing one-half of the equity in the Property, by refinancing of the Property. Said refinancing shall take place within six (6) months from the date of this Agreement. Husband shall execute a deed transferring the Property to Wife upon the sign migof this Agreement, which deed shall be held by Wife's attorney and shall not be recorded until said refinancing takes place, as well as the payment to Husband of the aforesaid amount from the refinancing. In the event Wife is unable to refinance the Property as stated in they preceding paragiraph, Wife agrees to immediately list the Property for sale with a realtor and the Property shall be sold at fair market value and the net sales proceeds shall be equally divided between Husband and Wife. Pending the refinancing or sale of the Property, Wife shall have exclusive possession of the Property and shall be fully and solely responsible for the payment of the mortgage, taxes and insurance on the Property as well as any other expenses related to the Property. Husband and Wife agree to fully cooperate and to sign any and all necessary documentation for purposes of the refinancing or sale of the Property. 9. PENSION AND RETIREMENT BENEFITS/FINANCIAL ACCOUNTS: Husband and Wife shall forever waive any and all past, present or future, legal or equitable interest in any pension and/or retirement benefits of the other, which either party may have now or in the future; and neither party shall make any claim against the other's pension or retirement benefits at any time 10. MARITAL DEBTS: Husband and Wife agree that the Bonton credit card debt and the VISA credit card debt are marital debts. Husband and Wife further agree that Wife shall be fully and solely responsible ;for payment of both the Bonton and VISA credit card debts and shall hold Husband harmless and indemnify Husband from any default as to payment of said debts. 3 11. AFTER ACQUIRED PROPERTY: Each of the parties shall own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, and/or real property, acquired by him or her, after the date of final separation, on or about July 1, 2008, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried. 12. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date of final separation, on or, about July 1, 2008, she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and save harmless Husband from any and all claims or demands made against Husband by reason of debts or obligations incurred by Wife. 13. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the date of final separation, on orabout July 1, 2008, he has not contracted or incurred any debt or liability for which Wife or her estate might be responsible and Husband further represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indemnify and save harmless Wife from any and all claims or demands against Wife by reason of debts or obligations incurred by Husband. 14. WAIVER OF RIGHTS: The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act of 1980, as Amended February 12,1988, particularly the provisions for alimony, alimony pen4ente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any fuuther rights they may respectively have against the other for equitable distribution of marital property, attorney fees and expenses. 15. PERSONAL RIGHTS: Husband and Wife may and shall, at all times hereafter, live separate and apart. They'shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not 4 molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabitate or dwell by any means or in any manner whatsoever with him or her. 16. MUTUAL RELEASE: Except as otherwise stated in this Agreement, Husband and Wife each hereby mutually remise, release, quitclaim and forever discharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of each other, of whatever nature and wheresoever situate, which he or she now has or may have at any time in the future. Except as otherwise stated in this Agreement, Husband and Wife each hereby further mutually remise, release, quitclaim, waive and forever discharge the other and the estate of each other, for all time to come and for all purposes whatsoever, of and from any and all rights which either party may have, or at any time hereafter have, for past, present or future equitable distribution of marital property, attorney 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 provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 17.WAIVER OR MODIFICATION TO BE IN WRITING: A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties and executed with the same formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 18. MUTUAL COOPERATION: Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all future instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions of this Agreement. 5 19. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors and assigns in the interest of the parties. 21. OTHER DOCUMENTATION: Wife and Husband covenant and agree that they will forthwith and within thirty (30) days after demand or due date, execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree, should be so executed in order to cagy out fully and effectively the terms of this Agreement. 22. NO WAIVER OF DEFAULT: This Agreement shall remain in full force and effect unless and until terminated undet 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 subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 23. BREACH: If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorney fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 24. SEVERABILITY: If any term, condition, clause or provisions 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 6 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 provisions herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 25. LAW OF PENNSYLVANIA APPLICABLE: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 26. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs/provisions and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this, Agreement nor shall they affect its meaning, construction or effect. 27. DIVORCE: The parties hereto agree that their marriage is irretrievably broken, and subsequent to the filing of a Complaint in Divorce, both parties agree to enter into a mutual consent divorce under Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended February 12,1988. The parties further agree to sign the necessary documents, including the Affidavit of Consent and Waiver, concurrently with the execution of this Agreement. This Agreement shall be incorporated, but shall not merge, into the final decree in divorce. WITNESS WHEREOF, the parties hereto, have set their hands and seals the day and year first above written. Witness: 7 HERBERT B. MILLS COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF tkj P# c w On this I gKday of C l (I.-C , 2009, before me, the subscriber, a Notary Public, in and for the said Commonwealth and County, came the above-named person, Carol Chambers Mills , satisfactorily proven to me to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes stated herein contained and that such mstnunent may be filed and/or recorded. WITNESS my han and Notarial seal. NOTARY PUBLIC MY COMMISSION EXPIRES: POWA_OI ASALTH OF PENNSYLVANIA NAIN aw MW W. AWW& NOWy Public INimmfiipaNn aoro? Dwp,k? camhr _ W CamMINI SNOW NW 20. M3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF q?? SS: On this l day of . 2009, before me, the subscriber, Notary Public, in and for a said Commonwealth and County, came the above-named person, Herbert B. Mills , satisfactorily proven to me to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purpose herein contained and that such instrument may be filed and/or recorded. my hand and Notarial Seal. MY PUBLIC EXPIRES: CAMMONWEALTH OF PENNSYLVANIA Nodal Seal Leslie K Neidig, Notary Public Warrington Twp., York County My Commission Expires Feb. 4, 2011 Member, Pennsylvania Association of Notaries OFF THE wy 2009 Se P 22 F111 2: 9 ABRAHAM LAW OFFICES 45 East Main Street, Hummelstown. PA 17036 (717) 566-9380 CAROL CHAMBERS MILLS Plaintiff V. HERBERT B. MILLS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 - 6254 CIVIL TERM CIVIL ACTION - LAW DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section x 3301(c) ( ) 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: October 25, 2008 by certified mailsee attached Affidavit of Service. 3. Complete either 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 6/19//09, filed 6/25/09; and by Defendant on 6/1/09, filed 6/25/09. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of plaintiffs affidavit upon the Defendant 4. Related claims pending: None pursuant to Marital Settlement Agreement. 5. Complete either paragraph (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 Plaintiff's Waiver of Notice was filed with the Prothonotary: 6/25L09. (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 6/25/09. Respectfully sub 'tted: DATE: 9/22/09 James W. Abraham, Esquire Abraham Law Offices 45 East Main Street Hummelstown, PA 17036 (717) 566-9380 Attorney for Plaintiff, Carol Chambers Mills I% it f C AR Y F 2003 SEA' 22 HI 2: 19 r" . o c ? CAROL CHAMBERS MILLS Plaintiff vi. HERBERT B. MILLS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 6254 CIVIL TERM : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, Carol Chambers Mills, in the above-captioned action, hereby affirm that the Complaint in Divorce filed herein, was served upon Defendant, Herbert B. Mills, by certified mail on October 25, 2008, as verified by the green return receipt card from the US Post Office, which is attached below: ¦ Complete kerns 1, 2, and 3. A190 complete Item 4 If Restrkted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space Permits. 1. Article Addressed to: j,,2.d2G P,u 0 ?4 K A K.t v? f/li(cC?rQU CGS QU R-G /? 1-7oSS" A. Sign re ? x N B. Received by (prfrrte5N?rre) , C• of 4 D. Is delivery address different from Item 1? © Yes If YES, enter delivery address below: §?No 3. type *: Mall O Express Mail Registered 0 Return Reoeipt for Momhandise 0 insured man D C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7006 2150 0000 7637 0114 PS Fort 3611, Farbnmwy MIN DarreeMc ReWM Receipt tares-M-lgoo DATE: 9/22/09 James W. Abraham, Esquire THE For1A?Y 2009 SEP 22 PH 19 Ou"m +` , CAROL CHAMBERS MILLS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 6254 CIVIL TERM HERBERT B. MILLS : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 21, 2008. 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 penal ' s of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. ^ 11 „ n . „ A n If / DATE: tl/ 9/02 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. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. M A „ _ _ n n Cl. - . DATE: CAROL CHAMBERS MILLS Plaintiff V. HERBERT B. MILLS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 - 6254 CIVIL TERM : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT„ .ice- f o - 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code wa"Ied oft October 21, 2008. _r_'. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety0) days -a 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 the unworn falsification to authorities. DA HERBERT B. MILLS, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) 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. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DATE: 'C // A-Z HERBERT B. MILLS, Defendant IN THE COURT OF COMMON PLEAS OF CAROL CHAMBERS MILLS CUMBERLAND COUNTY, PENNSYLVANIA V. HERBERT B. MILLS : NO 08 - 6254 DIVORCE DECREE AND NOW, _y 2-q zoo , it is ordered and decreed that CAROL CHAMBERS MILLS plaintiff, and HERBERT B. MILLS , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") The Marital Settlement Agreement dated June 1, 2009 and attached hereto shall be incorporated, but shall not merge, into the final Decree in Divorce. By the Court, Y ?'.ti . 'r jr i