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HomeMy WebLinkAbout87-0091VALERIE MURDOCK, Plaintiff Vs. CHARLES E. MURDOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ! CIVIL 1987 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Court House Carlisle, PA 17013 Telephone: (717) 249-1133 VALERIE MURDOCK, Plaintiff VS. CHARLES E. MURDOCK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. CIVIL 1987 : IN DIVORCE COMPLAINT 1. Plaintiff is Valerie Murdock, who currently resides at 17 North East Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Charles E. Murdock, who currently resides at 362nd Signal Company, Attn: SEL DCS, APO San Francisco 96301. The defendant is a member of the United States Army and is in active duty. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 14, 1979, in Augusta, Georgia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. Robert L. O'Brien, Esquire Attorney for Plaintiff 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. section 4904, relating to unsworn falsification to authorities. Date: Valerie Murdock IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~f CIVIL 1987 IN DIVORCE VALERIE MURDOCK, Vs. CHARLES E. MURDOCK, Plaintiff Defendant COMPLAINT IN DIVORCE LAW OFFICES FISHMAN, HESS & O'BRIEN 155 SOUTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 .......................... Oef.e._nda..n..t. ...... RCE AND NOW, ~ ..~,. , ]9 it is ordered and that ......... y.a! .e.r!e..M..u.r.d.o.c.k. ......................... plaintiff, and Charles E. Murdock ......................................................... , defendant, are divorced from the bonds of matrimony. !:il dec reed 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 Settlement Agreement of April 18, 1986 is incorporated as a final order and the court retains jurisdict '~ of other claims. IN TH URT OF COMMON PLEAS OF CUMBERLAND COUNTY ... ~a!_e..r_Le_.~u. rd...o.c_k.: ................................................ No ...... ~ ................ .c..!.y.!.~ .... 19 87 ........................................................... _P_!.a.!.n..t.!.r..r ........... VOLUNTARY SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~_~day of ~_~_, 1986, by and between CHARLES E. MURDerS, party of the first' ~ ' part, hereinafter called "Husband," and VALERIE MURDOCK, party of the second part, hereinafter called "Wife;" WITNESSETH: WHEREAS, the parties hereto were married on 14 April 1979, in a religious ceremony at ~usta, Georgia; have been and are Husband and Wife; and as a result of this union, one child was born, to wit: CHARLES C. MURDOCK, born ~5 ~ 1982, hereafter referred to as the "child;" and WHEREAS, irreconcilable differences have arisen between them, and the relations between the parties are and have been of such a character that the parties have voluntarily and mutually agreed to live separate and apart on account of which the parties have separated on 22 February 1985, and now have separated and live apart and intend to live separate and apart from each other for the rest of their natural lives; and Page I of 14 Pages WHEREAS, it is the desire of both parties finally for all time to settle, adjust, compromise and determine their property rights; all rights of support and maintenance by either party against the other by reason of their marriage, all dower, curtsey, alimony, and homestead rights, and any and all other rights existing between the parties growing out of the marriage relation; NOW THEREFORE, in consideration of the promises and the mutual covenants of each of the parties, they do hereby covenant and agree with each other for their respective heirs, personal representatives and assigns as follows: 1. TERMS OF SEPARATION: (a) The parties mutually and voluntarily agree to continue to live separate and apart in separate places of abode, without any cohabitation, as they have since 22 February 1985. (b) Each party shall be free from interference, direct or indirect, by the other as fully as though unmarried. The parties shall not molest, harass, nor malign each other, nor shall either attempt to compel the other to cohabit or dwell with him or her by any means whatsoever. Each party may, for his or her separate benefit, engage in any employment, business or profession he or she may choose and may choose and may reside in such place as he or she may choose. Page 2 of 14 Pages (c) It is their intention that a reconciliation, either tem- porary or permanent, shall in no way affect the provisions ~f this agreement having to do with the settlement and disposition of their property rights in their respective realty, if any, or per- sonalty, unless a new agreement is entered into in writing mutually revoking and rescinding this agreement and creating into a new one. 2. CHILD CUSTODY AND SUPPORT: The Husband hereby agrees that the Wife shall have the care, custody and control of the minor child with the right reserved to the Husband of reasonable visitation, provided, however, that exercise of the visitation privileges by said parent shall not conflict interfere with school schedules with bona fide plans previously made for activities; and all such visitation shall be exercised with due regard for the health and general welfare of said child. The Husband further agrees to all transportation costs both ways for the Child if the situs of the visit exceeds fifty (50) miles from the Child's residence. The Husband will give the Wife at least fourteen (14) days written advance notice of his intention to exercise his temporary custody rights under this Agreement. Page 3 of 14 Pages 3. ALLOWANCES TO WIFE AND CHILDREN: (a) The Husband agrees to pay to the Wife or other persons having the care of the Child in the Wife's custody, the sum of ninety percent (90%) of the Basic Allowance for Quarters (BAQ) authorized, at the time the payment is due, for the Husband's rank and grade per month'for the maintenance and support of the Child during the period when the child is in the Wife's custody. The remaining ten percent (10%) of the BAQ authorized for the Husband's grade and rank at the time the payment is due will be deposited monthly in a mutually agreed upon savings institution in a Trust account to accumulate and be paid to the Child on his twenty-first (21st) birthday. If the Husband leaves the Armed Forces for any reason, payments to the Wife and the Trust account shall continue at the same rate as they did before his separation. For each twenty-four (24) hour period the Child spends with the Husband after the seventh (7th) consecutive day, a sum equal to one-half the daily amount of support shall be deductible by the Husband from his monthly payment for that period as a food allowance by reason of the Child's absence from his mother. Support for the Child shall terminate upon the occurrence of any emancipation event as provided in Paragraph 3(c), upon the death of the Husband, or upon the child's adoption by another party, whichever shall first occur. (b) The Husband hereby agrees that the Wife and the a fore- said Child shall continue to be entitled to use and enjoy all medical and dental services, commissary and post exchange privile- ges, and other services allowed to them as a result of Husband's Page 4 of 14 Pages employment as a member of the United States Armed Services. During the time that the Husband and Wife are married, although living separate and apart, the Wife shall continue to enjoy these benefits, but upon divorce of the parties, these benefits shall terminate as to the Wife, but remain for the use and benefit of said Child, provided he qualifies for these benefits as determined by applicable United States Armed Forces entitlement regulations. In addition, should the Husband terminate his service with the United States Armed Forces, these services will be reevaluated by the parties hereto to ascertain the needs of the said Child and the respective responsibilities of the parties hereto to provide these needs until such time as said Child is emancipated. The Husband shall pay one half (1/2) of all of the reasonable and necessary dental, medical, psychological and hospital bills of the Child not otherwise covered by CHAMPUS or other government or pri- vate medical or dental insurance programs until the occurrence of an emancipation event as provided in Paragraph 3(c). The Wife agrees to ensure that, whenever practicable, the Child uses wha- tever medical, hospital, and dental services that are available to them through Armed Forces facilities. (c) With respect to the Child, an emancipation event shall occur or be deemed to occur upon the earliest happening of any of the following: (1) Reaching age eighteen (18); except and provided that an emancipation event shall be deferred beyond the eighteenth birthday of the Child if and so long as the Child pursues full Page 5 of 14 Pages time college education with reasonable diligence and on a normally continuous basis, and during such time the Child lacks suff'icient resources to be self-sustaining and is dependent upon his parents for support; but, in this respect, in no event shall emancipation be deferred beyond the Child's twenty-second birthday; (2) Marriage by the Child; (3) Death of the Child; (4) In the event that the Child, upon reaching the age of eighteen, is unmarried and is handicapped to such an extent that he is physically or mentally incapable, as opposed to unwilling, to support himself or to be engaged in full-time employment, then emancipation shall be deferred, and the Husband's obligation for Child support as set forth in Paragraph 3(a) and (b) shall continue in full effect until the Child's handicap or disability is removed or the Child marries or dies. 4. DIVISION OF PERSONAL PROPERTY (a) The parties have heretofore divided their personal pro- perty to their mutual satisfaction. Henceforth, each of the par- ties shall own, have and enjoy, independently of any claim of right of the other party, all items of personal property of every kind, nature and description and wheresoever situated, which are now owned or held by or which may hereafter belong to the Husband or Wife respectively, with full power to the Husband or the Wife to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. Page 6 of 14 Pages (b) DEBTS. The Wife shall be responsible for all existing joint debts and liabilities incurred by the parties prior to their separation except for the car loan on the 1977 Camaro with the Minnesota Mutual Life Insurance Company, Saint Paul, Minnesota, loan number 33398 which shall be solely the responsibility of the Husband. The Husband shall also be responsible for all existing debts and liabilities incurred in his own name prior to the separation. The parties further agree that neither will incur any future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will hold the other harmless from any and all liability thereon. (c) INSURANCE POLICIES: The Husband agrees to pay the pre- miums and to maintain in full force and effect Serviceman's Group Life Insurance (SGLI) on his life payable at his death to CHARLES C. MURDOCK. Should the Husband remarry, he may add as additional beneficiaries his new spouse and children, provided that CHARLES C. MURDOCK's share shall not decrease below fifty percent (50%) of the proceeds of said policy. Should the Husband leave the Armed Forces and no longer be entitled to SGLI before the occurrence of an emancipation event as set forth in paragraph 3(c), then the Husband agrees to purchase private insurance on his life, in an amount equal to CHARLES C. MURDOCK's share of SGLI coverage at the time of his loss of that coverage, naming CHARLES C. MURDOCK as primary beneficiary, and agrees to maintain in full force and effect such life insurance until the occurrence of an emancipation event. 5. WAIVER OF ALIMONY: In consideration of the mutual agreement of the parties voluntarily to live separate and apart and the provisions con- tained herein for the respective benefit of the parties and other good and valuable consideration, each party releases and waives unto the other any claim of right to temporary or permanent ali- mony, support or maintenance, whether past, present or future. The Wife agrees to waive any interest she may have or acquire in her Husband's retirement income. 6. TAX MATTERS: The parties agree to execute and file joint Federal and State income tax returns for the year 1985 and for any subsequent year during which they shall be Husband and Wife and entitled under the applicable laws and regulations to file joint returns, provided that such filing results in a lesser combined tax then would result from separate filing. Each party shall pay that pro- portionate share of the tax due as shall be attributable to his or her respective earnings or income and each shall indemnify and hold harmless the other against any liability for his or her own Page 7 of 14 Pages proportionate share of said tax. A tax refund, if any, shall be divided equally between the parties. After final divorce o¥ the parties, the parties agree that the Wife shall be entitled to claim the Child as dependent and to take any dependency exemption for the Child for federal and state income tax purposes. 7. COUNSEL FEES AND COURT COST The Husband agrees to pay all reasonable fees and costs up to one-half of the legal fees and court costs of the Wife which are actually incurred in matters relating to an ultimate dissolution of the marriage. Otherwise, each party will be responsible and liable for their respective counsel fees and court costs for the prosecution or defense of an action between the parties for a final decree of divorce. 8. ACCEPTANCE AND MUTUAL RELEASE: (a) Each of the parties receives the property set apart to them and the undertaking hereof in full and complete settlement and release of all claims and demands of every kind, name or nature against the other party hereto, including all liability now or at any time hereafter existing or occurring on account of sup- port, maintenance, alimony (temporary or permanent), dower, curt- sey, or other allowances, either statutory or arising at common law. After this settlement the Husband and Wife shall require nothing whatever of the other, except as herein provided, as though the marriage relation between them had never existed. Page 8 of 14 Pages (b) Waiver of Claims against Estate: The Wife agrees the estate of the Husband shall belong to the person or persons' who would have become entitled thereto if the Wife had died during the lifetime of the Husband; and the Wife further agrees that she will not contest in any manner any Will of the Husband to be probated and will allow Administration upon his personal estate to be taken out by the person or persons who would have been entitled to do so had the Wife died during the lifetime of the Husband. The Husband agrees that the estate of the Wife shall belong to the persons who would have become entitled thereto if the Husband had died during the lifetime of the Wife; and the Husband further agrees that he will not contest in any manner the Will of the Wife to be probated and will allow Administration upon her personal estate to be taken out by the person or persons who would have been entitled to do so had the Husband died during the lifetime of the Wife. Each party releases to the other and to the heirs, executors, administrators and assigns thereof all claims or rights of dower, curtsey, or inheritance, descent, distribution, election, or alimony in and to all property, real or personal, of the other, whether now owned or hereafter acquired. 9. FURTHER ASSURANCES: The parties, for themselves and their respective heirs, per- sonal representatives and assigns, do mutually agree to join in and execute any instruments and to do any other act or thing that may be necessary or proper to carry into effect any part of this agreement, or to release any dower or other right in any property which either of said parties may now own or hereafter acquire, including the execution and delivery of such deeds and assurances as may be necessary to carry out the purposes of this agreement. Page 9 of 14 Pages 10. INCORPORATION: With the approval of any court of competent jurisdiction in which any divorce proceeding may now be pending or which may hereafter be instituted, this agreement shall be incorporated in any decree of absolute divorce which may be passed by said court. In the event the court shall fail or decline to incorporate this agreement or any provisions thereof in said decree, then and in that event the parties, for themselves and their respective heirs, personal representatives and assigns, agree that they will nevertheless abide by and carry out all of the provisions thereof. It is further agreed that regardless of whether said agreement or any part thereof is incorporated in any such decree, the same shall not be merged in said decree, but said agreement and all the terms thereof shall continue to be binding upon the parties and their respective heirs, personal representatives and assigns. 11. INTEGRATION: This agreement contains the entire understanding of the par- ties. There are no representations, warranties, promises, cove- nants or understandings other than those expressly set forth herein. Page 10 of 14 Pages 12. PRIOR AND SUBSEQUENT AGREEMENTS: The parties hereto hereby cancel, annul and invalidate any and all other prior property settlements by them at any time here- tofore made. Any subsequent modifications or additions to this agreement shall be effective only if in writing signed by both of the parties. 13. INDEPENDENT COUNSEL, PARTIES FULLY INFORMED: Each party has had independent advice by counsel of his or her own selection. Each party regards the terms of this agreement as fair and reasonable and each has signed it freely and volun- tarily without relying upon any representation other than those expressly set forth herein. 14. MODIFICATION AND WAIVER: (a) No modification or waiver by the parties of any of the terms of this agreement shall be valid unless in writing and exe- cuted with the same formality as this agreement. No waiver of any breach or default hereunder shall be deemed a waiver of any sub- sequent breach or default. (b) None of the provisions of this agreement shall be sub- ject to modification by any court. 15. ENFORCEMENT: The Wife agrees that she will not contact, either directly or indirectly, the Armed Forces or the commanding officer with respect to the enforcement of this agreement as long as he is in compliance with the provisions of this agreement. Page 11 of 14 Pages 16. SOLDIERS AND SAILORS CIVIL RELIEF ACT: The Husband hereby agrees to waive any and all rights he may have under the provisions of the Soldier and Sailor Civil Relief Act of 1940, as amended, in any subsequent action for divorce instituted by the Wife, provided that the terms of the divorce decree will not contradict or in any way change, add to or delete from any of the terms of this agreement. The Husband realizes that this waiver will allow default judgement of divorce to be entered against him in accordance with the terms of this agreement. 17. BINDING EFFECT: All covenants, promises, stipulations, agreements, and pro- visions contained herein shall apply to, bind and be obligatory upon the heirs, executors, administrators, personal represen- tatives and assigns of the parties hereto. 18. NOTICES: For the purposes of this agreement, all notices or other com- munications given or made hereunder shall, until written notice to the contrary, be given or mailed to the Wife at 17 N. East St. Carlisle, Pennsylvania 17013, and to the Husband at 362nd Signal Com~gny, ATTN: SEL DCS, APO San Francisco 96301. In the event that either Husband or Wife shall change his or her per- manent residence, he or she shall forward, by registered mail notice to the other of them within five (5) days after such change or any removal. Page 12 of 14 Pages 20. DATE OF AGREEMENT: The effective date of this agreement shall be the date of the Husband's signature. IN WITNESS WHEREOF, I have at Carlisle Barracks, Pennsylvania, this ~___ day of _~k~)~o,~. , 198~, set my hand and seal to this Agreement consisting of fourteen (14) pages, this included, the preceding pages hereof bearing my initials, and I do solemnly declare and affirm under the penalties of perjury that the con- tents of the foregoing document are true and correct. WITNESSES: .... VALERIE MURDOCK (SEAL) COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I HEREBY CERTIFY that on this /~day of _L~_,4~¢J~ , 1986, before me, the subscriber, a Notary Public of the State and County aforementioned, personally appeared VALERIE MURDOCK, and made oath in due form of law under the penalties of perjury that the matters and facts set forth in the foregoing Agreement are true and correct and that she acknowledged that the Agreement was her voluntary act and deed. WITNESS my hand and Notarial seal. (SEAL) Page 13 of 14 Pages GLORIA A. GABIVER, NOI'A~Y NORTH i~IODLZ'TON TWP., CUA~]~R~D MY CO~!$SION EXPIRES FEB. 5, Member, Pennsylvania Association of Notaries IN ~TNESS WHEREOF, I have at _~I;111t~ , , this L~-~ day of ~ , 1986, set my hand and seal to this Agree~en~ consisting~of sixteen fourteen (14) pages, this included, the preceding pages hereof bearing my initials, and I do solemnly declare and affirm under the penalties of perjury that the contents of the foregoing document are true and correct. WITNESSES: _~.~-~ _~_~~-~ (SEAL) WITH THEU$ ARMED FORC~ ) AT SEOUL, KOREA ) SS: COUNTY OF ) I HEREBY CERTIFY that on this _l~-- day of _ __ ]i-$_'. 1986, before me, the subscriber, a Notary Public u, ~,,: ~ and r~v_...j,,, -.~.-......-.~^ncd, personally appeared CHARLES E. MURDOCK, and made oath in due form of law under the penalties of perjury that the matters and facts set forth in the foregoing Agreement are true and correct and that he acknowledged that the Agreement was his voluntary act and deed. WITNESS my hand and Notarial seal. (SEAL) NOTARY PUBLIC I/ BRIAN D. BARLEY Page 14 of 14 Pages CPT, IA, 507-76-1911 Legal Assistance Off]cot HQ, US Army Garrison, ATTN: EAGY-]A-LAO APO San Francisco 9§301-007§ (Jranted genera] powers of a notary public ~l~d US Consul by Title 10, USC~ ~ 9~ VALERIE MURDOCK, Plaintiff Vs. CHARLES E. MURDOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91 CIVIL 1987 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 201(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail on February 11, 1987. 3. Date of execution of the affidavit of consent required by Section 5/26/88 ; by Defendant 10/28/87 201(c) of the Divorce Code: by Plaintiff 4. Related claims pending: None Respectfully submitted, Robert L. O'Brien, Esquire H~ 31 VALERIE MURDOCK, Plaintiff vs. CHARLES E. MURDOCK, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NO. CIVIL : IN DIVORCE AFFIDAVIT VALERIE MURDOCK, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. Sworn to and subscribed before me thi~s/~/~bL~ay o~ ~/~-, 19~ Member, Pennsyl~,ania Association of Notaries April 16, 1987 Court Administrator Cumberland County Court House Carlisle, Rennsylvania l?O13 RE: Civil Action #91 In Divorce - Vaterie Murdock vs. Charles Murdock - Civil 1987 Dear Court Administrator: I am the Defendant in the above referenced action. On or about the 25th of February, I received a document titled "Notice to Defend and Claim Rights" from your court. My reason for the delay in replying to the notice is that I was unable to receive legal help until 23 March, when my military attorney returned from leave. I am in the U.S. Army and stationed in Korea. If the enclosed property settlement is incorporated into the petition for divorce, I will waive my rights under the Soldiers' and Sailors' Civil Relief Act. If it is not, or the plaintiff requests any relief that was not included or has not specifically been settled in the agreement, then I hereby invoke my rights under the Soldiers' and Sailors' Civil Relief Act, 50 USC App. Sec. 201, 1976, based on my present military duty in Seoul, Korea. Thank you for your kind cooperation in this matter. Sincerely yours, Charles Murdock Enclosure VALERIE MURDOCK, Plaintiff Vs. CHARLES E. MURDOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91 CIVIL 1987 IN DIVORCE CERTIFICATE OF SERVICE COMES NOW, Robert L. O'Brien, Esquire, and certifies that service of the Complaint in Divorce and Notice to Defend and Claim Rights in the above action were served upon Charles E. Murdock, Defendant, by mailing a certified copy thereof by certified mail, restricted delivery, return receipt requested. The said documents were delivered and received by Charles E. Murdock in accordance with a copy of the return receipt card, attached hereto. FISHMAN & O'BRIEN Robert L. O'Brien, Esquire VALERIE MURDOCK, Plaintiff Vs. CHARLES E. MURDOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91 CIVIL 1987 IN DIVORCE AFFIDAVIT says: CHARLES E. MURDOCK, being duly sworn according to law, deposes and 1. I have been advised of the availability of marriage counselling and,~3nderstand that I may request that the court require that my spouse and I ~ar~.cipate in counselling. '~'~ 2. I understand that the court maintains a list of marriage cou~elors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. CHARLES E. MURDOCK Sworn to and subscribed before me this 2$th day of ©ctober x'. Assi-~s~n~ Adjutant , 1987~ Pusan, Korea. VALERIE MURDOCK, Plaintiff Vs. CHARLES E. MURDOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91 CIVIL 1987 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 201(c) of the Divorce Code was '~iled on January 14, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and .~,n~nety days have elapsed from the date of filing the Complaint. ~: 3. I consent to the entry of a final decree of divorce. ~" 4. 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. CHARLES E. MURDOCK VALERIE MURDOCK, Plaintiff V$. CHARLES E. MURDOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91 CIVIL 1987 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 201(c) of the Divorce Code was filed on January 14, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. VALERIE MURDOCK VALERIE MURDOCK, : Plaintiff : : VS. : : CHARLES E. MURDOCK, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91 CIVIL 1987 IN DIVORCE AFFIDAVIT Valerie Murdock, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Valerie Murdock Sworn to and subscribed before me MY ~'OMMIS$10N EXPIRES OCT. 10, ~8 , (,,/ Member, pennsylvania Asseciatiofl o~ Notaries