Loading...
HomeMy WebLinkAbout06-0706 TANNER LAW OFFICES, LLC J 300 Market Street, Suite J 0 Lemoyne, PA 17043 Phone (717) 73 J -8114/ Fax (7 J 7) 73 J -8115 Attorney for Plaintiff ANTOINETTE DONLEY Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. a - 'lOb Ct'u;L'!&.~ KEITH DONLEY, Defendant CIVIL ACTION - 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 will proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or reliefrequested 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 One Courthouse Square, Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RlGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 T ANNER LAW OFFICES, LLC ] 300 Market Street, Suite 10 Lemoyne, P A 17043 Phone (717) 731-8] 14/ Fax (717) 731-8115 Attorney for Plaintiff ANTOINETTE DONLEY Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. KEITH DONLEY, Defendant CIVIL ACTION - DIVORCE A VISa USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quesjas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se la avisa que si no defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulmiento puede ser emitido en su contra por la Corte. Una decision puede tam bien ser emitida en su contra por cualquier otra queja 0 compensacion rec1amados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantas para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, listed puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL. HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEV AR ESTE P APEL A UN ABOGADO DE INMEDIA TO. SI NO TIENE OR NO PUEDE P AGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff ANTOINETTE DONLEY Plaintiff v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. of.- - '700 C;L>~CT~ CIVIL ACTION - DIVORCE KEITH DONLEY, Defendant COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Antoinette Donley, by and through her attorney, Tanner Law Offices, LLC, and represents as follows: I. Plaintiff is Antoinette Donley who currently resides at 208 II th Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Keith Donley who currently resides at 3514 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 15,2001 in Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since February 1,2004 and continue to live separate and apart as of the date of filing this Complaint. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing ofthis Complaint, consent to this divorce. 7. Defendant is not a member of the Armed Forces ofthe United States of America or any of its Allies. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. WHEREFORE, Plaintiff requests the court to enter a decree of divorce, Respectfully submitted, -Ioid~ A. ~ Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 2.2..- 0 G, Antoinette Donley 0 .i4. - <-> 0 ~ P r:. ...0 C) C? ,.-- ,,? -01 .;;,-~ ~ \\. C> <. ~ -' :r:-n Fl rl1r- lit ' . c::> -'-:;\~J ~ I 0-' , - ~ -.~ ~'-? -::t -" _~~::-o) \JJ If=- ....... '. ~.r'1 ..c r:-? ~~ ~ D .r - ~ J:: ... T ANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ~ ~ ~ ~ ~ ~ ~ NO. O~ - '7 ()~ Cu.>cl '--r ~ ANTOINETTE DONLEY Plaintiff KEITH DONLEY, Defendant CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a copy of the Divorce Complaint filed in the above-captioned matter upon Thomas Bakie, by regular, first-class U.S. mail and certified U.S. mail, restricted delivery, return receipt requested, addressed as follows: Mr. Keith Donley 3514 Chestnut Street Camp Hill, PA 17011 and did thereafter receive same as evidenced by the attached Post Office receipt card dated February 10,2006. Respectfully submitted, -;loJefk 4. ~ Tabetha A. Tanner, Esquire Supreme Court J.D. No.: 91979 . < . . " :3' r'l <0 Lf1 'U.S. ostal Service,,, , "- CERTIFIED MAILM RECEIPT' (Domestic Mail Onfy; No Insurance Coverage Proyjded) cAi;iHi~:t i/"i" 1 ioliG I1J r'l a- m r'l o o o Certified Fee , /:~:- /~ 1-'." >; ; "~'~'-. ! ~ '1 . ~ "lli1(l '. 20 i." "V~:" 'ti~.~' , . l Postage $ $0.63 Return Receipt Fee (Endorsement Required) o IT' Restricted Delivery Fee '1:0 (Endorsement Required) I1J $3.70 '0' Total Postage & f:'ees $ $8.58 ',' '; , rztW20o. ~ . .l .. :3' o o r- " SENDEr~ COfl11 ~t.~ 'HI ltl. v ON . Complete items 1, 2, and 3. Also complete ttem 4 If Restrtcted Delivery Is desired. . prtnt your name andaddlllSS On the rev$lS9 so that we can rewl11 the card to you. . Attach this card to the back of the mallplec$. or on the front n space pennlts. ~icl.!'dd"'sed to: ~ M~. KeiM. boob ::i 3s/1 Ch~~nuJ- ~. Lu Co.mp J..I;/J, fJlJ /7011 Q. o Agent o Addressee Cf9ate of Dellv,ry ..t-j Q - \>l.;l D,lsdelivery__ 1tem1? OVes ff VES, enterdollvery address below: 0 No 3. SeMce 1jIpe ~ CeItIlIed Mall 0 ExpIeSO Mall o Registered 0 Return Receipt loi" Merchandise o Insured MallO C.O.D. 4. _lodlloilwo)"1jEmFIIeJ ~ , ~. Article Nutnbet rrramferfiom --C 'S Fonn 3811. February 2004 7004 2890 0001 3912 5814 Domeetic Returil ReceIpt 102595-02-M.1540 i .. ~\J -c -;:7 ::3 "" (") I',) -l"! "... . , v. ~ ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANTOINETTE DONLEY Plaintiff NO. 06-706 CV KEITH DONLEY, Defendant CIVIL ACTION - DIVORCE MARITAL SETTLEMENT AGREEMENT This Agreement, made and entered into this J(j ty. day of '3" vl\-e. ,2006, between Antoinette Donley, residing at 208 11th Street, New Cumberland, Cumberland County, Pennsylvania 17070, (hereinafter referred to as "Wife", and collectively with "Husband" as "the parties") and Keith Donley, residing at 3514 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011, (hereinafter referred to as "Husband", and collectively with "Wife" as "the parties"). WHEREAS, the parties hereto are now Husband and Wife, having been lawfully married to each other since September 15,2001 in Maryland; WHEREAS, the parties hereto are now living separate and apart and desire to enter into an Agreement respecting their property rights; WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will Page 1 of 10 ensue from the execution hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; WHEREAS, each party warrants, as part of the consideration ofthis Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of her rights to be supported by the Husband and all of her rights of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to alimony, counsel fees, or other expenses, except as set forth herein; and Husband likewise wishes to relinquish all his rights of curtsey, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future, except as set forth herein; NOW THEREFORE, the parties hereto intending to be legally bound hereby do mutually agree as follows: 1. Separation. Husband and Wife do hereby acknowledge that they have lived separate and apart since February I, 2004, and continue to live separate and apart as of the date Page 2 of 10 of this Agreement, and further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 2. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3. Mutual Property and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of dower or curtsey, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Page 3 of 10 Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise ofthis power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 ofthe Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution of married property ordered by the Court subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that, except as provided herein, neither shall hereafter be under any legal obligations to support the other, pay any expenses Page 4 of 10 . , for maintenance, funeral, burial, or otherwise for the other; to that end, each of the parties hereto does hereby waive any right to receive support, alimony, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 4. Spousal Support/Alimony. In consideration of the mutual agreement ofthe parties, and their decision to voluntarily live separate and apart and the provisions contained herein for the respective benefit of the parties and other good and valuable consideration, the parties agree that each shall forever waive his or her right to be supported by the other party by way of spousal support and/or alimony. 5. Health Insurance: Husband agrees to continue to pay for Wife's health insurance until the Divorce is finalized. 6. Division oCPersonal Property. Henceforth, each ofthe parties 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 hereinafter belong to the Husband or Wife respectively, with full power to the Husband or Wife to dispose of the same as fully and effectually in all respects and for all purposes as ifhe or she were unmarried, with the exceptions as set forth below: Page 5 of 10 . . a. The parties acknowledge that the marital residence, located at 3514 Chestnut Street, Camp Hill, Cumberland County Pennsy.lvania 170 II was purchased by the parties on October 13, 2003. The parties acknowledge that the marital residence is currently in foreclosure due to Husband's failure to make timely payments toward the mortgage balance due. Husband and Wife agree that Wife shall purchase the property for the Reinstatement Figure provided by Phelan Hallinan & Schmieg, LLP, a firm with offices located in Philadelphia, Pennsylvania. The Reinstatement Figure as of June 15,2006 and valid through June 30, 2006 is Nine Thousand, Eight Hundred Five Dollars and Forty-Three Cents ($9,805.43). Wife shall make this payment and Husband shall sign and fully execute a Quit Claim Deed transferring all his right, title and interest in said property to Wife, on or before June 30, 2006 so as to prevent the house from being foreclosed upon. Wife shall then assume all responsibility for all future mortgage payments and shall indemnify and hold Husband harmless against any future liability resulting therefrom. Husband shall vacate the marital residence on or before July 8, 2006. Prior to his vacating the marital residence, he shall not damage Page 6 of 10 . , or destroy any property or portion of the marital residence. Husband shall assume any and all liability for any such damage or destruction and shall indemnifY and hold Wife harmless for same. Upon Husband's vacating the marital residence, Wife shall immediately contact all utility and other service companies and change all services to her name. Husband shall remain liable for all utility and service bills which remain outstanding and for which he was the only one to use the service, namely for all time prior to Wife occupying said property . 7. Future Debts. The parties further agree that neither will incur any further 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 thereof. 8. Divorce. The parties acknowledge that an action for divorce between them has been filed by Wife and is presently pending divorce between them in the Court of Common Pleas of Cumberland County, No. 06-706 CV. The parties acknowledge that it is their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and fully settle hereby all claims raised by either party in the divorce action. Page 7 of 10 " ", 9. Incorporation and Judgment for Divorce. This Agreement and all of its provisions shall be incorporated into the decree of divorce in the aforementioned divorce action, either directly or by reference. 10 Breach. In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 11. Enforcement. The parties agree that this Agreement or any part or parts hereof may be enforced in any court of competent jurisdiction. 12. Applicable Law and Execution. The parties hereto agree that this Agreement shall be construed under the laws ofthe Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. 13. The Entire Agreement. The parties acknowledge and agree that this Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. Page 8 of 10 14. Modification of this Agreement. The 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. 15. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate 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. 16. Voluntary Execution. Each of the parties has read and understands the above and is signing this Agreement as a free and voluntary act and having had the opportunity to obtain advice of separate legal counsel. Page 9 of 10 '.' . .. IN WITNESS WHEREOF, and intending to be legally bound, the parties have set their hands and seals the day and year first written above. -f~ A-f~ Signature of Witness 17m Jo.~ Printed Name of Witness -ro.'twIIta A. -r;,1If\.V Printed Name of Witness Page 10 of 10 (-:) ~" C'::.'.) 4::::) '-- 'C:-::l -(T~ TI ~.~ '-j :r f1i ,I1 " , ,', -I c-; -:J " C, '--.'-' f.../ ;.:.< . '- Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 (717) 731-8114 ttanner@tanner-Iaw.com v. ~ IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA ~ ~ NO. 06-706 CV ~ ~ CIVIL ACTION - DIVORCE ~ ~ ANTOINETTE DONLEY Plaintiff KEITH DONLEY, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Groundfor Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of Service of the Complaint: United States Postal Service, first class mail, postage prepaid, certified, restricted delivery. Return receipt dated February 10,2006. 3. Date of Execution of the Affidavit of Consent Required by Section 3301 (c) of the Divorce Code: by Plaintiff on June 26, 2006; by Defendant on June 26, 2006. 4. Related Claims Pending: no other marital claims pending. All marital claims were settled by the enclosed Marital Settlement Agreement dated June 26, 2006 to be incorporated into the Divorce Decree. , .\. 5. Date of Filing Waivers of Notice: Plaintiffs waiver is being filed with this Praecipe; Defendant's waiver is being filed with this Praecipe. -~ 11. "i/J1/Yl d~ Tabetha A. Tanner, Esquire Attorney for Plaintiff Supreme Court J.D. No. 91979 ~, ;:~ en '-- ,.- c) ;:;'~ ::;:l-n n...-., -~;\~ ,,) --J ~,~,~'~ ::::-\ . ,.~~ c:.,""J C"' ~ Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 (717) 731-8114 ttanner@tanner-Iaw.com ANTOINETTE DONLEY Plaintiff v. ~ IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA ~ ~ NO. 06-706 CV ~ ~ CIVIL ACTION - DIVORCE ~ ~ KEITH DONLEY, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on February 3, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of Divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: (; lLtOeo \~ tomette on ey, amtl r-' !~:~ c.... ,....... ~ --n -' CJ {.,/1 Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 (717) 731-8114 ttanner@tanner-Iaw.com ANTOINETTE DONLEY Plaintiff v. ~ IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA ~ ~ NO. 06-706 CV ~ ~ CIVIL ACTION - .DIVORCE ~ ~ KEITH DONLEY, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE J}ECREE UNDER ~3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: (0 r 2&,{) {o o " r-' c:? ,.-:-;:, \:.;;[.... ~ ~,.l :? ,- ,---- :1; t'-J -J o (.5', ---'-j ~ ,"" Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 (717) 731-8114 ttanner@tanner-Iaw.com ANTOINETTE DONLEY Plaintiff v. ~ IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA ~ ~ NO. 06-706 CV ~ ~ CIVIL ACTION - DIVORCE ~ ~ KEITH DONLEY, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9330 I (c) of the Divorce Code was filed on February 3, 2006. 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of Divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: 6 -~~ -tJ ~ ~~ 0--' (,.,,~ ~::-;: !'-) _! o u-: Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, P A 17043 (717) 731-8114 ttanner@tanner-Iaw.com v. ~ IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANIA fi ~ NO. 06-706 CV ~ ~ CIVIL ACTION. DIVORCE ~ ~ ANTOINETTE DONLEY Plaintiff KEITH DONLEY, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE PECREE UNDER ~3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ -c:?(, - tJ b <,,) '--, -r., -- o (.:', ;to ;to ;to ;to ;to ;to ;to '" Of. ;to Of. Of. Of. Of. Of. 0f.0f. Of.Of.;tO "'Of; Of. IN THE COURT OF COMMON PLEAS ;to Of. OFCUMBERLANDCOUNTY ;to PENNA. STATE OF ANTOINETTE DONLEY, Plaintiff No. 06-706 Civil Term VERSUS KEITH DONLEY, Defendant DECREE IN DIVORCE AND NOW, -:::r~ ~ c:t"' ~. 'tJc)p#/ · 2006 , IT IS ORDERED AND DECREED THAT Antoinette Donley , PLAI NTI FF, AND Keith Donley , 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; No issues remain outstanding, All issues have been resolved and settled by the parties' Marital Settlement Agreement dated June 26, 2006, filed of record an ncor rated into, but not merged * th this flecree. ~ ^ ~ ATTEST: /~/~' ..e..X~ ~ y..>Wn,~ . ROTHONOTARY '" Of. ;to!f. Of.;tO;tOOf.!f.Of.!f.;tOOf. ;to ;to Of. ;to !f. ;to '" Of. ;to !f. ;to ;to !f. !f. ;to ;to ;to !f. !f. !f. Of. Of. !f. ;to Of. Of. ;to ;to !f. !f. ;to ;to ;to '" J. !f. '" '" '" Of. !f. '" '" ",'fi '-W:2~~ ~.L.( ~b). ~.~~-~ ~Oc.'L.