HomeMy WebLinkAbout04-6479
o.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
DEBRA A. SCOTT,
vs.
: No. 0 it - (, <.j 7 r
Civil Term
GEORGE N. SCOTT,
Defendant
: ACTION 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.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
DEBRA A. SCOTT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 0 <j - ~ If I q
Civil Term
GEORGE N. SCOTT,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Debra A. Scott, a competent adult individual, who has resided at 26
Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since 1984.
2. Defendant is George N. Scott, a competent adult individual, who has resided at 26
Edgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since 1984.
3. PlaintitIand Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on August 26, 1978 in Columbia
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintitImay have the
right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have two children together; however, both are adults.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces ofthe United States
of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
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DEBRA A. SCOTT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
'IS.
: No. 04 - 6479 Civil Term
GEORGE N. SCOTT,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE;
AND NOW, this January 11,2005, I, Jane Adams, Esquire, hereby certifY that
on December 31, 2004, a certified true copy of the Notice to Ddend and Divorce Complaint was
served, via certified mail, return receipt requested, addressed to:
George N. Scott
26 Edgewood Drive
Mechanicsburg, Pa. 17055
DEFENDANT
. Complete Items 1. 2. and 3. A180 COl11pIete
Mern 4 H ResIrfcted DelIvery Is desInlcI. "
. PrInt your neme and addrelIa on the I8Y8I11l1
80 that we can I8lUm the card to you.
. Attach this card to the back of the rnaDpI,oce,
or on the front H epees permits.
1. Artlcle Add_ to:
(Oeo~e. N ~ Scott
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2. ArtIcle Number
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PS Form 3811, February 2lIlM
7003 3110 0004 5775 4269
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DEBRA A. SCOTT,
vs.
No. 04 - 6479 Civil Term
GEORGE N. SCOTT, .
Defendant
ACTION IN DIVORCE
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this /8 day of fI pI!., L , 2005, by and
between, DEBRA A. SCOTT, of Mechanicsburg, Cumberland County, Pennsylvania,
hereinafter referred to as "WIFE", and GEORGE N. SCOTT, of Mechanicsburg, Cumberland
County, Pennsylvania, hereinafter referred to as "HUSBAND".
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on August 26, 1978, in Columbia
County, Pennsylvania, and;
WHEREAS, there was one child born of this marriage;
WHEREAS, differences, disputes, and difficulties have arisen between the parties and it
is the intention of Husband and Wife to live separate and apart for the rest of their natural lives,
and the parties desire to settle their respective financial property rights and obligations as
between each other, including the settling of all matters between them relating to 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 Husband or
Wife; and in general, the settling of any and all possible claims by one against the other or
against their respective estates;
NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby
covenant and agree as follows:
1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a
full and fair disclosure of income, assets, and their valuation prior to the execution of this
Agreement as well as any other fact relating in any way to the subject matter of this agreement.
These disclosures are part of the consideration made by each party for entering into this
agreement.
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2. ADVICE OF COUNSEL. The Husband is PRO SE. The Wife has employed and
had the benefit or counsel of Jane Adams, Esquire, as her attorney. Each party has carefully and
completely read this agreement and has been advised and is completely aware not only of its
contents but of its legal effect. Husband has been advised of his right to counsel, volwltarily
elected to forego representation, and understands that Jane Adams, Esquire is only representing
Wife.
3. SEPARATION. The parties intend to maintain separate and permanent domiciles
and to live apart from each other. It is the intention and purpose of this agreement to set forth
their respective rights and duties while they continue to live apart from each other. Neither party
shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment,
or disposition of any property now owned and not specified herein or property hereafler acquired
by the other.
4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Wife has filed a
Complaint in Divorce in Cumberland County, Pennsylvania, claiming that the marriage is
irretrievably broken under the no-fault mutual consent provision of Section 330 I ( c) of the
Pennsylvania Divorce Code. Husband hereby expresses his agreement that the marriage is
irretrievably broken and expresses his intent to execute any and all affidavits or other documents
necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce
Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce
Code. The provisions of this Agreement relating to equitable distribution of property of the
parties are accepted by each party as a final settlement for all purposes whatsoever, as
contemplated by the Pennsylvania Divorce Code.
Should a decree, judgment, or order of separation or divorce be obtained by either ofthe
parties in this or any other state, country or jurisdiction, each of the parties hereby consents and
agrees that this Agreement and all of its covenants shall not be affected in any way by any such
separation or divorce; and that nothing in any such decree, judgment, order, or further
modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether
or not either or both of the parties shall remarry. It is specifically agreed that a copy of this
Agreement or the substance of the provisions thereof, may be incorporated by reference into any
divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the
specific intent of the parties to permit this Agreement to survive any judgment and to be forever
binding and conclusive upon the parties.
5. DATE OF EXECUTION. The "date of execution" or "execution date" of this
agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date. Otherwise, the "date of execution" or "execution
. .
date" of this Agreement shall be defined as the date of execution by the party last executing this
Agreement. All provisions of this agreement shall be effectuated by the parties within thirty
(30) days of the execution date of this agreement unless otherwise specified within this
agreement.
6. MUTUAL RELEASE OF ALL CLAIMS. Other than as provided in this
agreement, Husband and Wife each do hereby mutually remise; release, quit-claim and forever
discharge the other and the estate of the other, of and from any and all rights; titles, 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 such other, or whatever nature and wheresoever situate, which
she or he now has or at any time hereafter may have against such other, the estate of such other or
any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of
such other or by way of dower or curtesy, or claims in the nature of dower or curtesy of 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 by the other as
testamentary, or all other rights of a surviving spouse to participate in the decease spouse's estate,
whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the
United States, or any other country, however, the parties do not waive claims or any rights which
Wife may have or at any time hereafter have against the other for past, present or future support
or maintenance, alimony, alimony pendente lite, counsel fees, costs, expenses.
7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants
that they have not contracted any debt or liability for the other or which the estate of the other
party may be responsible or liable, and except only for the rights arising out of this agreement,
neither party will hereafter incur any liability whatsoever for which the other party or the estate
of the other party, will be liable. Each party agrees to indemnifY or hold harmless from the other
and against all future obligations of every kind incurred by them, including those for necessities.
8. OUTSTANDING JOINT DEBTS.
(a) Wife agrees that the following debts are her own personal responsibility and therefore
agrees to completely and finally pay on the following debts and obligations.
(b) Husband agrees that the following debts are his own personal responsibility and
therefore agrees to completely and finally pay on the following debts and obligations.
9. EQUITABLE DIVISION OF MARIT AL PROPERTY. The parties have
attempted to distribute their marital property in a manner which conforms to the criteria set forth
in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of
the marriage, the age, health, station, amount, and sources of income, vocational skills,
employability, estate, liabilities, and needs of each of the parties, the contribution of each party to
the education, training, or increased earning power of the other party; the opportunity for each
party for future acquisitions of capital assets and income; the sources of income of both parties,
including but not limited to medical, retirement, insurance or other benefits; the contribution or
dissipation of each party in the acquisition, preservation, depreciation, or appreciation of the
marital property, including the contribution of each spouse as a homemaker; the value of the
property set apart to each party; the standard ofliving the parties established during the marriage;
and the economic circumstances of each party at the time the division of property is to become
effective.
The division of existing marital property is not intended by the parties to constitute in any
way a sale or exchange of assets, and the division is being effected without the introduction of
outside funds or other property not constituting marital property. The division of property under
this Agreement shall be in full satisfaction of all the marital rights ofthe parties.
As such, the parties acknowledge that Husband or Wife's obligation to make the
payments defined in this agreement shall not be subject to termination, discharge, or
discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should
Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his
obligation to pay any debts for which he has asswned sole obligation as set forth herein, he or she
shall immediately be obligated to pay alimony to the other party in an amount equal to the
monthly obligation on such debts that he or she otherwise had assumed and for which he had
taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration
of the tax consequences associated with receipt of alimony. At the time of the implementation of
this alimony award, which may be made through the appropriate Domestic Relations of support
office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may
select, such party shall then be responsible for any such debts extinguished through the other
party's bankruptcy as described herein.
10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge
that they have previously divided all their tangible personal property. Except as may otherwise
be provided in this Agreement, Wife agrees that all of the property of Husband or in his
possession shall be the sole and separate property of Husband; and Husband agrees that all of the
property of Wife or in her possession shall be the sole and separate property of Wife. The parties
do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he
or she may have with respect to the above items which shall become the sole and separate
property of the other.
11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both
of the parties, they agree as follows:
(a) The 2003 Honda CRV shall be and remain the sole and exclusive property of Wife.
(b) The 2002 Jaguar shall be and remain the sole and exclusive property of Husband.
The titles to the said motor vehicles shall be executed by the parties, if appropriate for
effecting transfer as herein provided, within thirty days ofthe execution date ofthis Agreement,
and said executed titles shall be delivered to the proper parties on the distribution date. Each
party agrees to be solely responsible for the amounts presently due and owing against his or her
respective automobiles.
12. MARITAL HOME. HUSBAND and WIFE hold title as Tenants by the Entireties
to the premises identified as 26 Edgewood Drive, Mechanicsburg, Pennsylvania, 17055. The
parties agree as follows with respect to the marital residence:
(a) Within thirty (30) days of this agreement, Husband shall apply for refinancing on the
marital home in his name alone. Immediately upon refinancing, Husband shall present
Wife with a check, which shall equal 50% of the difference between the appraised value
and the current loan's payoff amount. Upon refinance, Wife shall deliver a deed to
Husband, conveying to Husband all of her right, title and interest in the marital residence,
in exchange for the payment. Husband shall be responsible to pay for all costs, including
filing fees or any other costs, associated with the refinance. If Husband fails to refinance
within six (6) months, he shall still be responsible for providing Wife with a check which
shall equal 50% of the difference between the appraised value and the current loan's
payoff amount on the 180th day after this agreement.
(b) As of the date of separation or refinance, whichever comes first, and without regard to
when bills for such items are incurred, received or due, HUSBAND shall be solely
responsible for all past, present, and future costs or liabilities associated with or
attributable to maintaining the marital residence (except as provided herein), including
but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone
service, homeowner's insurance, and gardening expenses and repairs, and HUSBAND
shall keep WIFE and her successors, assigns, heirs, executors, and administrators
indemnified and held harmless from any liability, cost or expense, including attorney's
fees, which are incurred in connection with such maintenance, costs, and expense.
(c) HUSBAND shall indemnifY and hold WIFE harmless from any liability, cost or
expense, in connection with any expense required to be made by HUSBAND including
but not necessarily limited to, the first mortgage, property taxes, and insurance with
respect to aforesaid premises.
13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to
waive any and all rights they have in and to each other's employment benefits, including but not
limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties
agree never to assume any claim to such benefits of the other at any time in the future.
14. HEALTH INSURANCE. The parties agree as follows regarding Health Insurance:
George N. Scott currently has health insurance through his employment. George N. Scott will
continue to pay for coverage on the parties' daughter Stephanie L. Scott as long as she is an active
college student. In addition, George N. Scott will continue to pay for Health Insurance Coverage
on Debra A. Scott for a period of two (2) years from the date of the final Decree in Divorce.
15. COLLEGE COSTS. The parties agree as follows regarding their daughter
Stephanie L. Scott, who is currently attending college: George N. Scott will contribute to
Stephanie L. Scott's college tuition and books in the amount of $1 00.00 a month each and every
month of the year that she is actively enrolled in college and up to and until she graduates from
college.
16. INCOME TAX RETURNS. Husband and wife represent to each other that to the
best of their knowledge all federal, state, and local taxes required to paid with during the
marriage and during the periods covered by such tax returns have been paid. Husband and Wife
further represent that there are no tax deficiencies proposed or assessed against Husband and/or
Wife for such periods, and neither Husband nor Wife executed any waiver of the Statute of
limitations on the assessment or collection of any tax for such periods. If any deficiency in
federal, state, or local income taxes is proposed, or any assessment of any such tax is made
against the other party by reason of his or her having joined in the filing of joint federal, state or
local income tax returns, Husband and Wife shall indemnifY and hold harmless the other against
and from any and all tax, interest, penalty, or expense relating from any such tax deficiency,
including reasonable counsel and accounting fees, and such tax, interest, and penalties or
expenses shall be paid solely and entirely by the responsible party as determined to be
attributable to that party on account of misrepresentation or failure to disclose relevant
information of income on the aforesaid joint returns.
17. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or
waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and
no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent
default of the same or similar nature.
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 further instruments and/or documents that the other party may reasonably require for the
purpose of giving full force and effect to the provisions of this Agreement.
19. APPLICABLE LAW. The Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this
Agreement.
20. INTEGRATION. This Agreement constitutes the entire understanding of the
parties and supersedes any and all prior agreements or negotiations between them. There are no
representations or warranties other than those expressly set forth herein.
21. OTHER DOCUMENT A TION. Wife and Husband covenant and agree that they
will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds,
notes, or such other writings as may be necessary or desirable for the proper effectuation of this
Agreement.
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22. NO WAIVER OF DEF AUL T. This Agreement shall remain in full force and effect
unless and until terminated under and pursuant to the terms of this Agreement. The failure of
either party to insist upon strict performance of any of the provisions of this Agreement shall in
no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any
default or breach of any provision hereof by construed as a waiver of any subsequent default or
breach of the same or similar nature, not shall it be construed as a waiver or strict perfOlmance of
any other obligations herein.
23. SEVERABILITY. If any term, condition, clause, or provision of this Agreement
shall be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause, or provisions shall be stricken from this Agreement; and in all other respects,
this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the
failure of any party to meet his or her obligations under anyone 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.
24. BREACH. If either party breaches any provisions of this agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach, or seek other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this agreement.
25. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement
acknowledges that he or she is fully informed as to the facts relating to the subject matter of this
agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion
or duress of any kind, has given careful thought to the making of this agreement, has carefully
read each provision ofthis agreement, and fully and completely understands each provision of
this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and
year first above written:
WITNESS:
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~RA A. SCOT , Wife
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COMMONWEALTH OF PENNSYLVANIA )
):ss
COUNTY OF CUMBERLAND )
On this, the Ii day of Hril; L ,2005, before me, the undersigned officer,
personally appeared DEBRA A. SCOTT known to me, (or satisfactorily proven) to be the person
whose name is subscribed to the within instrument, and acknowledged that he/she executed the
same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTAR!AL ilEAL
Win -'OT1<OWSKI, Notary Public
t H,;lnl~,':; fwp" ClJmberiand pounty
. . n Ires June 25, 2006
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My commission expires:
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COMMONWEALTH OF PENNSYLVANIA )
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On this, the / >1 day of It 1',21 L , 2005, before me, the undersigned officer,
personally appeared GEORGE N. SCOTT known to me, (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that he/she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
i"- - NOTARIAL SEAL
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DEBRA A. SCOTT,
VS.
No. 04 - 6479
Civil Term
GEORGE N. SCOTT,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was tiled on December 27, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the filing and service of the Complaint.
I consent to the entry of a final decree of divorce after service of notice of intention to request entry of
S/2 jO!J
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,/George N. Scott, Defendant
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WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER &3301(<) AND &3301(d) OF THE DIVORCE CODE
1. I consent to 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 divorc,d until a divorce decree is entered by the Court and that a copy of
~e 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 an ':0
~erein are made subject to the penalties of] 8 Pa.C.S. !l4904r .
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
DEBRA A. SCOTT,
vs.
No. 04 - 6479 Civil Term
GEORGE N. SCOTT,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on December 27,2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the filing and service of the Complaint.
3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of
the decree.
I verify that the statements made in this affidavit are trlle and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date: ;,. ~I. 0.;
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Debra A. Scott, PlaintIff
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER 11330)(0) AND 1I330)(d) OF THE DIVORCE CODE
1. 1 consent to 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 tn,Ie 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: /0/31/05'
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Debra A. Scott, Plaintiff
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DEBRA A. SCOTT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 04 - 6479 Civil Term
GEORGE N. SCOTT,
Defendant
: ACTION IN 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. Ground for divorce: irretrievable breakdown under &330!(c) of the Divorce Code.
2. Date and manner of the service of the Complaint: Via certified mail, restricted
delivery, return receipt requested, received on December 31, 2004.
3. Date of execution of the affidavit of consent required by 330l(c) of the Divorce Code:
By Plaintiff:
October 31, 2005.
By Defendant:
May 2, 2005.
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in S330l(c) Divorce was filed with the
Prothonotary: May 4, 2005.
Date Plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the
Prothonotary: November 2,2005.
Date:
11/~-iJ
e Adams, Esquire
. No. 79465
64 S. Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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IN THE COURT OF COMMON
PLEAS
OFCUMBERLANDCOUNTY
Debra A. Scott, Plaintiff
PENNA.
STATE OF
No.
No. 2004 - 6479 Civil Term
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VERSUS
George N. Scott, Defendant
DECREE IN
DIVORCE
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AND NOW,
IT IS ORDERED AND
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Debra A. Scott
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DECREED THAT
, PLAINTIFF,
George N. Scott
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF REC'i'f}D IN THIS ACTION FOR WHICH A FINAL ORDER
YET BEEN ENTERED: NO~
HAS NOT
The marriage settlement agreement which was executed April 18th 2005 and
filed April 22, 2005 shall be incorporated and not merged int this D
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By TH,:(o:;e wV>
ATTEST: ... ~ J.
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