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HomeMy WebLinkAbout02-0761TERRENCE L. WATTS, Plaintiff VS. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- ?&/ : CIVIL ACTION - LAW : 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 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. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE, Carlisle, Pennsylvania 17013 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 TWR OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, THIRD FLOOR Cumberland County Courthouse Carlisle, PA 17013 Telephone: (717) 249-1133 TERRENCE L. WATTS, Plaintiff VS. ARLENE C. WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT SECTION 3301 (C) ; 3301 (D) DIVORCE 1. Plaintiff is TERRENCE L. WATTS, an adult individual currently residing at 505 Huntingdon Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is ARLENE C. WATTS, an adult individual currently residing at 2 Roosevelt Street, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff has been a bona fide resident in 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 November 2, 1985, in Enola, Cumberland County, Pennsylvania. 5. Plaintiff avers that there has been no prior action for divorce or annulment of marriage by the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties are living separate and apart, and Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years. 9. Plaintiff avers that there are children of the parties under the age of 18, namely: NICOLE MARIE LOUISE WATTS 8/9/1990 10. Plaintiff avers that the Defendant is not in the Military or Naval Service of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. W-~EREFORE, Plaintiff requests the Court to enter a Decree of Divorce. DATED: Respectfully submitted, ~~ ~n ~g~/~squi re //i~2~9/~qarket/S~reet Attorney for Plaintiff VERIFICATION I verify that the averments in this Complaint for Divorce 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. Terrence L. W f TERRENCE L. WATTS, : Plaintiff : VS. : ARLENE C. WATTS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-761 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICW. COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF DAUPHIN : Jeffrey B. Engle, Attorney for Terrence L. Watts, Plaintiff in the above-captioned action, being duly sworn, according to law, deposes and says that he served a certified copy of the Complaint in Divorce in said action on Arlene C. Watts, Defendant, by posting same on February 19, 2002, in the U.S. Mail, Certified, Return Receipt Requested. See Return Receipt Card, signed by Arlene C. Watts, attached hereto, marked Exhibit "A", and made a part hereof. SWORN TO AND SUBSCRIBED BEFORE ME THIS ~ DAY OF ~-.~33~ / ,~ 2002. SCHEDULE "A" · Complete items 1, 2, and 3. Also complete item 4 if Restricted 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 mailpiecs, or on the front If space permits. P lene 2. Article Number (Copy from service label) aaal oqq t ~ PS Form 3811, July 1999 ~lellve~j addres~ differertt from item 1 ? nYse [ If YES, enter de~iveP/address ~eiow: [] No Sen/ice Type [] Express Mail [] Registered [] Return Receipt for Merchandise [] ~r~r~ M., [] C.O.D. ~12t~ ,4. Restricted Delivery? (Extra Fee) /~Yee Domestic Return Receipt 102595-00-M-0952 ~5~R~N~E L. WATTS, ~" Plaintiff VS. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE DATE: AFFIDAVIT OF CONSENT ~ WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on February 12, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I have been advised of the ave, ilability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. Arlene C. Watts, Defendant T-~E L. WATTS, ~ Plaintiff vs. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UI~DER ~3301(c) OF T}{E 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 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: A~lene C. Watts, Defendant T~ L. WATTS, ~'~ Plaintiff VS. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on February 12, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. 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. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. Terrence L-. Watts, Plaintiff ss# ¥ - T~E L. WATTS, ~-- Plaintiff vs. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODF. 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 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. Terrence L. Watts, Plaintiff TERENCE L. WATTS, Plaintiff VS. ARLENE C. WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-761 CIVIL ACTION LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: 3301 (c) section) 2. Transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground divorce: irretrievable breakdown under Section ( X / ( ) 3301(d) (1) of the Divorce Code. (Check applicable Date and manner of service of the complaint: February 19, 2002, by U.S. Mail, Certified, Return Receipt Requested (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 11/18/02 ; by Defendant 11/18/02 (b) (1) Date of execution of the Plaintiff,s Affidavit required by Section 3301(d) of the Divorce Code; ; (2) date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: Marital Settlement Aqreement dated November 18, 2002 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: Waiver of Notice was filed with the (b) Date plaintiff's prothonotary: 12/9/02 (c) Date defendant's prothonotary: 12/9/02 Waiver of No t i c ~f i_/i/i/~~~ the ~tt~n~ for ( ~/l Plaintiff MARITAL SETTLEMENT AGREEMENT AGREEMENT, made thisl~ day ofh~l/, 2002, between Arlene C. Watts, of Enola, Cumberland County, Pennsylvania, ("Wife"), AND ce L Watts, of £nola, Cumberland County, Pennsylvania. ("Husband"); WITNESSETH: WHEREAS, the parties are husband and wife; AND WHEREAS, unfortunate and irreconcilable differences have arisen between the parties by reason of which continued cohabitation as husband and wife has been rendered impossible; AND WHEREAS, the Parties were married on November 2, 1985; AND WttEREAS, the parties are the parents of one (1) minor child, namely, Nicole Marie Louise Watts, age 12, (DOB 8/9/90); WHEREAS, the parties intend this Agreement to be a full and complete Marital Settlement Agreement, providing for the absolute and final settlement of their respective marital property rights and all claims for support and alimony; AND WHEREAS, the parties have made full disclosure to each other of their assets and have agreed on a settlement of all property rights and differences exis~ting between them. NOW, THEREFORE, for and in consideration of the mutual benefits to be derived by the parties, they agree as follows: 1. DIVORCE The parties agree that their marriage is irretrievably broken and that they mutually consent to a divorce and agree and have executed all necessary Affidavits of Consent and Waivers of Notice forms required by the court for the entry of a mutual consent divorce. Both Husband and Wife have directed their respective counsel to immediately file with the Court said Affidavits and Waivers and file the appropriate documents to request a Decree in Divorce fi:om the bonds of matrimony under Section 3301 (c) of the Divorce Code. 2. REAL ESTATE Wife hereby relinquishes any interest in the marital residence located at 505 Huntingdon Avenue, Enola, Cumberland County, Pennsylvania. In consideration for such release, Husband shall convey to Wife $31,600.00. Wife shall thereafter execute a fee simple deed conveying the property into the name of the Husband alone. Husband shall indemnify and hold Wife harmless for any past, present or future encumbrances or liens on said property. 3. PERSONAL PROPERTY a. Household Furnishing~q The parties agree that the household furnishings have been divided to the complete satisfaction of both parties. Either party hereby relinquishes any interest he or she may have in the possession of the furnishings currently in the possession of the other party. b. Vehicles The parties own their respective vehicles and release any interest they may have in and to the vehicle(s) owned by the other party. Husband shall retain the 1997 Dodge Pickup 4x4. Husband shall assume all responsibility for said vehicle and hold Wife harmless and :indemnify her against any and all past, present and future liability. c. Pension Wife releases and relinquishes any claim she may have in and to any pension which has or may accrue to Husband at his place of employment. Husband releases and relinquishes any claim he may have in and to any pension which has or may accrue to Wife at her place of employment. d. Loans/Obligations Each of the parties shall be responsible for his or her own debts~.~ t,~ ~ e. Bank Savings/Checking Accounts/Christmas Club, etc. All bank accounts have been divided among the parties to their mutual satisfaction. 4. CUSTODY AND VISITATION Husband and Wife shall share legal custody of the subject minor child. Wife shall maintain primary physical custody and Husband shall receive partial physical custody according to the following schedule: a. Alternating weekends from Friday to Sunday, tim es to be designated by parties; b. One weekly visit to be agreed upon by the parties; c. Alternating major holidays, times to be designated by the parties; AND d. All other times as the parties may agree. 5. WAIVER OF ALIMONY Husband and Wife 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 date of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 7. ATTORNEY'S FEES Each Party shall pay their respective Attorney's fees, for the divorce and the preparation of this Agreement and such other fees as are applicable hereto. 8. RELEASE Subject to the provisions of this Agreement, each party has released, discharged and, by this Agreement, does for himself or herself, and his or her legal representatives, executors, administrators or assigns, release and discharge the other of and from all cause of actions, claims rights or demands whatsoever, in law or equity, which either of the parties ever had, now have or can have at any time against the other, specifically including any rights or claims to dower rights, curtesy rights, support, alimony, alimony pendente lite, counsel fees and equitable distribution of marital property. 9. ESTATE RELEASE Husband and Wife hereby release any rights that he or she might hereafter acquire to share in any capacity in the estate of the other, or to act as administrator or executor of the estate of the other, or to participate in any manner in the administration of the estate of the other, and hereby waive any rights of election to take against the will of the other, or to claim the family exemption. 10. 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 may from time to time choose or determine fit. 11. NO INTERFERENCE Each party shall be free from interference, authority and control, direct and indirect, by the other as fully as if he or she were single and unmarried. Neither shall molest the other, compel, or endeavor or compel, the other to cohabit or dwell with him or her, or to interfere with friendships, society or acquaintances which either of the parties hereto may choose or have from this day forward. 12. NO DEBTS Neither party will or shall be entitled to contract any debts nor incur any charges or obligations in the name of the other party nor in any way use or attempt to use the credit of the other party. 13. DOCUMENTS Each party shall, at the request of the other, execute, acknowledge and deliver any documents which may be.reasonably necessary to give full effect to this Agreement. Further, each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignment, consents to change beneficiary on insurance policies, tax returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 14. NO BAR TO DIVORCE Nothing herein contained shall be construed to prevent either of the parties from instituting an action for absolute divorce against the other in any jurisdictic.n based upon any past or present conduct of the other, nor to bar the other from defending any suclh suit. 15. ABSOLUTE AND FINAL SETTLEMENT The provisions of this Agreement are intended to consider, determine and distribute all of the assets of the parties hereto as part of the terms of this Postnuptial Agreement. This Agreement is intended by the parties hereto to be a valid Postnuptial Agreement, providing for the absolute and final settlement of their respective property rights and all obligations of support. This Agreement is not intended to be a mere Separation Agreement. 16. ENFORCEMENT The parties hereto agree that the provisions of this Agreement may be entered and enforced by an appropriate court order at the action of the entitled party and against the obligated party, as the case may be. Provided further, all costs of such litigation, including reasonable Attorney's fees, shall be paid by the party refusing to carry out their commitments under this Agreement. 17. VOLUNTARY EXECUTION AND FAIRNESS OF AGREEMENT Each party acknowledges that this Agreement has been entered into of his or her own volition, with full knowledge of' the facts and full information as to the legal rights and liabilities of each and the assets of the other, and that each believes the Agreement to be reasonable under the circumstances. 18. MODIFICATION AND WAIVER A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provision,,; of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 19. SITUS This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 20. PARTIAL INVALIDITY If any provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 21. BINDING EFFECT Each of the parties hereto intends to be legally bound hereby, and this Agreement shall be binding upon their heirs, personal representatives and assigns of the respective parties hereto. 22. DIVISION OF PROPERTY The Parties acknowledge that they have, among themselves; agreed upon the division of the assets referred to herein. They further acknowledge that they have reviewed all the terms of this Agreement and that they had the opportunity to discuss, and have explained to them, any provisions that they did not fully understand. IN WITNESS WHEREOF, the parties hereunto set their hands and seals, the day and year first above written, each adopting the seal following his or her signature, as his or her own. WITNESSES: COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND · On this the [~' day of J/~O/,~., 2002, before me, a Notary Public, the undersigned officer, personally appeared Te~,~nce L. Watts, known to me (or satisfactoril rov .... w . ,r. '. . . : . y p en) to be the person t~hose name ~.s, ~.scri ,'~t. ~e w~thin ~nstmment and acknowledges that she executed the same for ne purposes mere~n contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. (SEAL) COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND · Notary Public t Notarial Seal J . Ca..therine M. Blair, Notary Public I. ~uumb. ed.and _Boro, Cum .bedand County [My u0mnuss~on ~-.xpires June 16, 2005 ~ ~, ~f~jhtanA Association of NO~ri~ On this the ~' day of J/~'c/7~,2002, before me, a Notary Public, the undersigned officer, personally appeared Arlene C. Watts, known to me (or satisfactofilyproven) to be the person whose name is subscribed to the within instrument and acknowledges that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal· Notary Pubhc New ' ry u~ic CumberfandBon3 ~Pkes dune 1 IN PLEAS THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PENNA. TERENCE L. WATTS VERSUS ARi.KNE C. WATFS NO. 02-761 DECREE IN DIVORCE DECREED THAT TERENCE L. WATTS AND ARi,~NE C. WATTS ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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 a Postnuptial Agreement ~etween the parties, dated November 18, 2002, are hereby incorporated but not merged into and made part of this Decree. BY THE COURT: / AT~: OTHONOTAR~ Terence L. WaRs, Plaintiff V. Arlene C. Watts, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-761 Civil,Action - Law In Divorce NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 7th day of January, 2003, hereby elects to retake and hereafter use her previous name of Arlene C. S/l~tt. ~..nature - married name) (Signature - to be known as) COMMONWEALTH OF PENNSYLVANIA : : SS.: COt NTVOF : Onthis, the /5/k dayof q'~'""~o~ ~ q~ ,200__~ beforeme, aNotaryPublic, the undersigned officer, personally appeared Arlene C. Watts, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. --'------=~-ARIAL S.E.A.L ~ublic JOHN R. BEINHAUR_, Not.a.ry ~ Lo r Paxton Twp., Dauphin ~,oumy ~,,I~, ~-w,~%miss on Expires March 13, 2003~ My Commission Expires: (SEAL) T~KhR~Nt~E L. WATTS, Plaintiff VS. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV~/qIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AN~ WAIVER OF COUNSELINC. 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on February 12~, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. 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. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. DATE: Terrence L~. Watts, Plaintiff ss# V - --~~ TEKKENCE L. WATTS, ~-- Plaintiff VS. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCF. CODF, 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 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. Terrence L. Watts, Plaintiff ~E L. WATTS, ~ Plaintiff vs. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-761 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELINC, 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on February 12~, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. 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. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. DATE: Arlene C. Watts, Defendant T-~{%R~E L. WATTS, Plaintiff VS. ARLENE C. WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-7611 : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF, 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 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: Arlene C. Watts, Defendant