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HomeMy WebLinkAbout05-5514 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. OS' -~[;'I'I C;u~L~St2....vYl LISA M. WOODFORD, Plaintiff DANIEL WOODFORD Defendant : CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims setforth 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. Ajudgment 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 groundfor divorce is indignities or irretrievable breakdown of the marriage. you may request marriage counseling. A list of marriage counselors is available at: Cumberland County Courthouse One Courthouse Square Carlisle, PA 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO, 05- SSN Ct-uLL ~0V-"-t : CIVIL ACTION - IN DIVORCE LISA M. WOODFORD, Plaintiff DANIEL WOODFORD Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(C) AND 3301 (0) OF THE DOMESTIC RELATIONS CODE I. Plaintiff is Lisa Woodford (SS# 174-66-1278), a citizen of Pennsylvania whose primary residence is located at 3512 Countryside Lane, Camp Hill, Pennsylvania, 17011. 2. Defendant is Daniel Woodford (SS#198-52-2234), a citizen of Pennsylvania whose primary residence is 3512 Countryside Lane, Camp Hill, Pennsylvania, 17011. 3. Plaintiff and Defendant are sui iuris. Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on July 15,2000 in Carlisle, Pennsylvania. 5. The marriage is irretrievably broken. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8, There was one child born of this marriage. COUNT I. Request for No-Fault Divorce Under 3301(c) and Cd) of the Divorce Code 9. Paragraphs one through eight are incorporated as if fully set forth herein. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. 13. Defendant is not now and has never been a member of the armed forces of the United States. WHEREFORE, if both parties file affidavits to a divorce after ninety days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. In the alternative, should the parties continue living apart for a period oftime greater than two years, Plaintiffrespectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. Respectfully submitted, DATE: \ 0' 1-1 c"c:; l ~C'~)'- Lawrence J. Rosen, Esquire Attorney for Plaintiff 1101 North Front Street Harrisburg, Pa 17102 ID # 10625 (717) 234-4583 LISA M, WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. DANIEL WOODFORD Defendant : CIVIL ACTION - IN DIVORCE VERIFICATION I, LISA M. WOODFORD, hereby verify that the information contained in the foregoing Complaint is true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATE: to/I? letS" . ~oo (Yi Ir}~~fL L SA M. WOODFORD . LISA M. WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, C6. :5~-1 'I DANIEL WOODFORD Defendant : CIVIL ACTION - IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this -Ii day of G( .mbc.v ,2005, I, Aimee L. Paukovits, for the Lawfirm of Krevsky & Rosen, P.C., on behalf of Plaintiff, LISA M. WOODFORD, hereby certify that I have this day served a copy of the Complaint in the above-captioned matter, via Hand - Delivery U.S. Mail, on the following: DANIEL WOODFORD 3512 COUNTRYSIDE LANE CAMP HILL, P A 17011 ~ l \JJi\J1} \ '7 (J.B 'tCl) \~ Aimee L. Paukovlts 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 () -<<+ ~ -p r-\\ - ..0 ~, ~ \) I) "., ,'-'. -n ..... U\ ,-.? - ::0 \> ~ ,. - ,'.; IJ ~ ~ ~ ~ II ~ .' '; ~ .. J -- \..s':. - ---- LISA M, WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v. : NO, 05-5514 DANIEL WOODFORD, Defendant : CIVIL ACTION - IN DIVORCE ACCEPTANCE OF SERVICE . I, DANIEL WOODFORD, accept service of the COMPLAINT IN DIVORCE, which was filed with the Court on October 24, 2005, relative to the above-reference matter. Date: (JtI-;'fi-()j '-4~- ANIEL WOO ORD I~_' ,.' c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY LISA M. WOODFORD V. DANIEL WOODFORD DOCKET NO. 05-5514 CIVlL TERM MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT made this a:t:'day ofy'~ N~r.l.Da between LISA M. WOODFORD, hereinafter called "WIFE", , 2006, by and AND DANIEL WOODFORD, hereinafter called "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were married on JULY 15, 2000 IN Carlisle, Pennsylvania. and WHEREAS, There was one child born of the marriage. WHEREAS, certain differences have arisen between the parties as a result of which they separated in May of 2005 and are desirous, therefore, of entering into an Agreement which will distribute their marital property in a manner which is considered to be an equitable division of all joint property, and will provide for the mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, there has been a complete disclosure of the earnings and property of each party, and each understands hislher rights under the Divorce Code of the Commonwealth of Pennsylvania; and WHEREAS, the parties hereto, Wife and Husband having been properly advised by their attorney, Lawrence 1. Rosen, Esquire have come to this Agreement. The parties heretofore, intending to be legally bound, covenant, promise and agree as follows: 1. CONSIDERATION. The consideration for this Agreement is the mutual promise, covenants and agreements herein contained. 2, 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 deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart. The parties agree that their date of final separation was May of2005. 3, NO INTERFERENCE, Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. 4. COUNSEL FEES. A. The parties agree to share responsibility for legal fees. 5. SUPPORT. The parties agree to waive any rights to supporl which one may have for or against the other. 6. ALIMONY, CHILD SUPPORT AND OTHER FINANCIAL OBLIGA TIONS: The parties expressly waive any claim that one may have against the other for alimony. 7. PENSION BENEFITS. The parties hereby waive any claims which they may 2 have to any pension benefits owned by the other. 8. WIFE'S DEBTS. Wife represents and warrants to Husband that since the separation she has not and in the future will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnifY and save Husband harmless from any and all claims or demands made againsl him by reason of debts or obligations incurred by her. 9. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the separation he has not and in the future will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnifY and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 10. OUTSTANDING DEBTS. The parties affirm that there are existing marital debts. The parties intend that all existing marital debt shall be satisfied from the proceeds of the sale of the marital residence. These debts include but are not limited to Visa, Sears, Discover, Bonton and Hecht's. Pending the sale of the marital residence the parties will continue to make the necessary payments on aforesaid obligations from joint funds which they are depositing in their joint checking account. 11. REAL ESTATE The parties acknowledge that the marital residence located at 35]2 Countryside Lane, Camp Hill will be sold as soon as possible. The proceeds from the sale of the marital residence shall be divided equally between Husband and Wife. Wife and Husband acknowledge that Wife has used three thousand dollars ($3,000.00) of marilal 3 funds to obtain a new residence. The parties further agree that Wife will pay Husband one thousand five hundred dollars ($1,500.00) from her share of the proceeds of the sale of the marital residence to repay Husband for his share of aforesaid marital funds used by Wife to obtain her new residence. 12. DISTRIBUTION OF PERSONAL PROPERTY. A. Household Property. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties will agree to sign, upon request, any title or documents necessary to give effect to this paragraph. Property shall be deemed to being the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of the Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement bene tits of any nature to which wither party may have a vested or contingent right or interest at the 4 time of the signing ofthis Agreement, and neither will make any claim against the other for any interest in such benefits during the period of separation, except as stated herein or subsequently agreed upon in writing. Wife shall retain a Chevrolet Van currently in her possession and Husband shall retain 1994 Mitsubishi currently in his posslOssion. The parties agree to sign any documents necessary to establish the ownership of said vehicles. 13. AFTER ACQUIRED PROPERTY. Each of the parties shall hereafter own and enjoy independently of any claim or right of the other, all items of property, by they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were unmarried. 14, CUSTODY AND LIFE INSURANCE. Wife and Husband shall have shared legal custody oftheir minor child Avery Woodford (DOB 11/22/0 I). Wife shall have primary physical custody of Avery Woodford and Husband shall have periods of partial physical custody at such times and places and under such conditions as the parties may agree upon from time to time. The parties will share equally the costs of schooling for A very. The parties also agree that they will maintain life insurance policies in the amount oftwo hundred and fifty thousand dollars ($250,000.00) naming the other as beneficiary of said policies until Avery reaches the age of twenty one. 15 MEDICAL INSURANCE. Both parties agree to continue to assume responsibility for their own medical insurance. Medical/dental/vision costs above the coverage of insurance will be split equally between the parties. 16 TAX RETURNS. The parties shall continue to file their tax returns separately. 17 MUTUAL CONSENT DIVORCE. This Agreement shall operate as a full 5 and final Settlement Agreement concerning all marital rights of both parties in accordance with the terms herein. The Parties hereto agree that each shall contemporaneously herewith sign an Affidavit of Consent to a divorce pursuant to Section 3301 (c) of the Divorce Code. Counsel shall prepare and promptly file the parties' respective Affidavit's of Consent, a praecipe to transmit record, Waiver of Notice ofIntention to Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code and a vital statistics form, all for the purpose of obtaining an immediate Decree in Divorce. Counsel shall obtain and provide the parties copies of the original divorce decree and a copy of their Marital Settlement Agreement incorporated therein. 18. TIME OF DISTRIBUTION, The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective parties as soon as possible. The parties shall cooperate by executing whatever documents are necessary to effectuate a divorce under 330 I (c) or 330 ] (d) of the Pennsylvania Divorce Code, and this Agreement to cooperate shall be enforceable by an assumpsit action for specific performance. However, upon refusal to consent, all distributed property shall be returned to the party originally in possession, until the time of final decree. 19. RELEASE. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release, indemnify (including actual legal fees) and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, including equitable distribution, spousal 6 support, alimony, counsel fees, alimony pendente lite, and expenses which either of the parties against the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or under any other statutory or common law, except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling, pursuant to 3302 of the Divorce Code. 20. WAIVERS OF CLAIMS AGAINST ESTATES, Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and any right existing now or in the future under the Pennsylvania Divorce Code, as amended from time to time, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 21. RIGHTS ON EXECUTION. Immediately upon the execution of this Agreement, the rights of each party against the other, despite their continuing marital status, shall terminate and be as if they were never married. 22. BREACH, It is expressly stipulated that if either party fails in the due 7 perfonnance of any of his or her material obligations under this Agreement, the other party shalJ have the right, at his or her election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal remedies as may be available, and the defaulting party shalJ pay the reasonable legal fees for any services rendered by the non- defaulting party's attorney in any action or proceeding to compel performance hereunder. 23. INCORPORATION INTO FINAL DIVORCE DECREE, Thetennsofthis Agreement shalJ be incorporated but shalJ not merge into the final divorce decree between the parties. The parties intend that this Agreement shalJ be enforceable under the Divorce Code of 1980, as amended, and, in addition, shalJ retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. 24. ADDITIONAL INSTRUMENTS. Each of the parties shalJ from time to time, al the request of the other, execute, acknowledge and deliver to the other party, any and alJ further instruments that may be reasonably required to give fulJ force and effect to the provisions of this Agreement. 25. SEPARABILITY. In case any provision of this Agreement should be held to be contrary 10, or invalid under, the law of any country, state or other jurisdiction, such illegality and invalidity shalJ not in any way affect the other provisions hereof, alJ of which shalJ continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate and undisputed covenant and agreement. 26. ENTIRE AGREEMENT. This Agreement conlains the entire understanding 8 of the parties and there are no representations, warranties, covenants and undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them, based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to Section 3502 of the Divorce Code or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 27. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only ifmade in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of the provisions ofthis Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 28. INTENT. It is the intent of the parties by this Agreement to fully and finally foreclose any resort to the courts for relief on the basis of any statute or case law presently existing or which may exist at some time in the future within the Commonwealth of 9 Pennsylvania, including but not limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended. This Agreement has been drafted and accepted on the basis that such resort would constitute a breach under this Agreement, entitling the non-breaching party to reimbursement for actual counsel fees. Other than as provided by the terms of this instrument, it is intended that the court shall treat the parties as ifthey had never entered into a marital relationship. This Agreement shall be interpreted and governed by the laws of the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms ofthis instrument shall govern. 29. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal effect have been fully explained to Husband and Wife by their counsel, Lawrence 1. Rosen, Esquire. The parties agree that the instant Agreement is equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each ofthem and/or by their respective counsel. 30. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 31. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto, and their respective heirs, executors, 10 administrators, successors and assigns. 32. RECONCILIATION. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. IN WITNESS WHEREOF, The parties hereto have hereunto set their hands and seals the day and year first above written. WITNESS: "-' ")" ;;: , "':") /Ind CE J. ROSEN, ESQUIRE , /2 ,.",//,' ~~1 i/ ':1< ~ RENtE J. ROSEN, ESQUIRE .r ..~. - ii h ) /. J ~' ,"--:7Z\.'''~ V'-' tI'rJ-<:~a. [ ./ \,. DANIEL WOODFORD 11 (2 .... "'1 (J~ ,~ .~ 'n --< ')" h-Oj ~~J c;\ .',: LISA WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-5514 DANIEL WOODFORD, Defendant : CIVIL 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 Section (x)3301 (c) ()3301 (d)(l) of the Divorce Code. (Check applicable section.) 2. Date and manner of service ofthe Complaint & Amended Complaint: October 2S, 200S - Hand Delivered 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent & waiver of required by Section 3301 (c) of the Divorce Code: by the Plaintiff on January 2S, 2006; by the Defendant on January 2S, 2006. (b)(I) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: N/A. (2) date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: Request that terms of Settlement Agreement dated Januarv 2S, 200S and executed bv the parties be incorporated and not merged into the Divorce. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached. (Lb~ Lawrence J. Rosen, Esquire Attorney for Plaintiff 12 ;~..,') c-;:-_ .:_, () -n .-1 -J::.T: ~T:C:~- (~; L , ~;-'. ." ,.." tJ;.:., I 0; rv. LISA M. WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v. : NO. 05-5514 DANIEL WOODFORD, Defendant : CIVIL ACTION - IN DIVORCE AFFIDA VlT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 24, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken. Ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of final decree of divorce after service of notice of intention to request entry of decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if! do not claim them before a divorce is granted. 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: 1/(11 SIl>tN' / I \... ~d( "" ~:~ C) c,'''' -q .... :::J ~ ;::ij:~ C""'l Ci , ~'~"..) C) fp LISA M. WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. 05-5514 DANIEL WOODFORD, Defendant : CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if{ 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, <) / J,trt i.i I f ~ -It(rz; (( h'/ '" <:,"';,' 0 ~;~) 1:.:-' -on " -" :::l 0i OJ I C-, -. -,'- LISA M. WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA v. : NO. 05-5514 DANIEL WOODFORD, Defendant : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 24, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken. Ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of final decree of divorce after service of notice of intention to request entry of decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if! do not claim them before a divorce is granted. 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. 9 4904 relating to unsworn falsification to authorities. DATE: Jt~v' ;t~-o f.t ~ ~"1~4~~ DANIEL WOODFORD' c) c- o ~'i' I ...,., ,."' C:J :? ;~..~I~ I CP :0::0 :<. LISA M. WOODFORD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. 05-5514 DANIEL WOODFORD, Defendant : CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if! 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. DA TE:X",- .;:;')=-(/ " qla=i~r / .' . .' . (,.1../ j"',,-.:;/S?---d DANIEL OODFORDt -r: . n ',:~; ~g, ,~_:_~ (J"' G -n ..,. r''-'~ c:J I 0..... ::1 ;::j,:!l . r- '):::':') ;,) c._;: .,:-1,,:' l'n -:t c-" _(~ ::.D ..< 'f'f:+:+:+' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H . . . . :+'f ++;f,:+ . :+ :+:+:+:f. :f. :!i:+:+:f.:+:!i :!i:+0f,+ :f.+'l':f:+:+:+'+:+'l':f:+. :+':+''+'Of.:+' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. :Lisa Woodford No. 05-5514 VERSUS Daniel Woodford DECREE IN DIVORCE 'Fv~ (~ @.. <?"O~ A,1-1 , ~, IT IS ORDERED AND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f+'f:+':+' AND NOW, Lisa Woodford DECREED THAT , PLAINTIFF, Daniel Woodford 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; It is requested that the terms of the Settlement Agreement dated January 25, the Divorce. . . . 2006 be in"o:~_"~_) not B~~; merged into J. . . . PROTHONOTARY . . . . 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