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Home My WebLink About94-01538 \I ~ l. tf ~ j Dc \7i ............ ~. , ~ . ~~~~~-~~--~~~~~~~~~~~~~~~--~~~ ~ - JJ! ,. ~ ~ IN THE COURT OF COMMON PLEAS ~ ~ . ~ I ~ ~ ~ ~ . . ~ ~ ~ ;,; 8 t :-': $. 8 ~ . . t t (, "}V~,~. J: ~ ~:~ rv~/:&~~", I: ~ Prothonotary " 7. !~ ~ I'" ?; ~_.-.~........-'I' -----~--___~______________._.____~______..._.,_ ,~ ~~*~..~~~~**~-~~~~~-~~~*-~~~-~~-~. ~ OF CUMBERLAND COUNTY STATE OF '*' PENNA. $ ~ ~ ~ . 8 ~ . ;,; , .,':I:':E.~~1( ..P,...,f.);:.~~E:F,:.,. ........... ............ ........ ....... .... II ........ ...,.......,....... ...... .1'1,~~t:I t:~JL. .... .....,.... ......,... a !I N 0, .J.E~........... C;:!Y.H~..... 1994 VCI'SlIS " II . .....,................., II .,!?II}\~9~..R...J1..E:~R:E.E:/. '.~ ~ D",.f.endant 8 ... ~ ~ ~ ~ ~ ~ , ~ ~ 8 . ~ DECREE IN-A D I V 0 R C E<( ~ (0: 7(" .4- AND NOW. .. ~. .. .~." .. .. ". 19 cr .... ;, I. ocde'ed ond decreed that ..., 'P~,I; ,y, ~'" f!!.~I;~lj!. . , .. , .. .. .. , .. .. .. .. .. .. .., plaintiff, and.., ,~!1p,I;9J;1, '~" . f!!,~J;'~lj!.. .. , ... .. . ... .. ...... .. . ..,.., .." defendant, are divorced from the bonds of matrimony, And that the attached Postnuptial Agreement shall be incorporated, but not merged with this Dscree. ," d" f h f II 'I h h h 'Ine court retains IUrlS Ictlon 0 t e 0 oWing c aims W ic ave been raised of record in this action for which a final order has not yet been entered; ~'.. ~ <=.: ~ None .... .....0.0...0. "0 ..0....0......., .....0.....0.... ......................, $ $ ~ ~ fo# ............. . ;,.-:-." ~ -.'" .O' ", II!. /" J "" ww- . ..-:0... : "/ ':-. . - - - - . . . . - : - ; ............... .... ...... ... ........... ........ ......... ~ ~ .' - """ .... ~ .' .'.. , .: 8 '" ~ ~ ~ ~ ;,; ~ ,'~ ~ ," ~ i '.' ,', ~ ,', ~ ~ ',' ~ ,', ~ - , , ",~'''.':'~-=~~''~''-'~: ~~ ~!,..--!.' .. ~ ~ , ... ~ ?11~D.~ Q/;,7/iflf , ~ , . " 4 POSTNUPTIAL AGRBBMBNT THIS AGREEMENT, made and concluded this G~ day of .J"'.fl-.-d''''',:a<c.~ 1994, by and between TBRRY D. I'BRRBB, (hereinafter referred to as "HUSBAND") -AND- SHARON D. I'BRRBB, (hereinafter referred to as "WIFE"). WITNESSETH: WHEREAS, the parties are HUSBAND and WIFE; and WHEREAS, unfortunate and irreconcilable differences have arisen between the parties by reasons of which continued cohabitation as husband and wife has been rendered impossible; and WHEREAS, the parties have made full disclosure to each other of their assets and liabilities, and have agreed on a settlement of all property rights and differences existing between them; and WHEREAS, it is the desire of the parties, after long and careful consideration, to amicably adjust, compromise and settle all property rights and all rights in, to or against each other's property or estate, including property heretofore or subsequently acquired by either party, and to settle all disputes existing between them, including any and all claims for WIFE'S and/or HUSBAND'S maintenance and/or for spouse support, alimony pendente 1 .. I r r . .' . lite, alimony, counsel fees and expenses, custody and equitable distribution~ WHEREAS, TERRY D. FBRRBB is represented by Joanne H. Clough, Esquire and SHARON D. FERRBB is represented by Andrea C. Jacobsen, Esquire, and each par+-y has had the opportunity to review this Agreement in its entirety with their respective counsel~ and WHEREAS, the parties intend this Agreement to be a full and complete postnuptial Agreement, providing for the absolute and final settlement of all their respective marital and property rights and all claims for spouse support, alimony pendente lite, alimony, counsel fees and expenses, and equitable distribution of marital property. NOW, THEREFORE, for and in consideration of the mutual benefits to be derived by the parties and intending to be legally bound hereby, the parties hereby covenant and agree as follows: 1. PERSONAL PROPERTY: HUSBAND warrants and represents to WIFE, and WIFE warrants and represents to HUSBAND, that they have effected a fair and equitable division of all marital property of the parties, and that any and all marital property, except as expressly provided herein, presently in possession of WIFE shall be the property of WIFE, and that any and all marital property, except 2 i. r~: " r ,. , as expressly provided herein, presently in possession of HUSBAND shall be the property solely of HUSBAND. 2. MARITAL RESIDENCE: HUSBAND and WIFE agree to sell the marital residence located at 8 Cedar Street, Newville, PA 17241. The marital residence is currently listed for sale at $76,900.00. 3. PROCEEDS OF MARITAL RESIDENCE: HUSBAND and WIFE agree that the proceeds from the marital residence will be used to pay off the $10,000.00 loan from WIFE'S mother. Any balance left after WIFE'S mother is paid off, will be split 50/50 between HUSBAND and WIFE. 4. DEBTS AND INDEMNIFICATION: HUSBAND and WIFE represent and warrant to each other that except as provided herein, neither one has contracted or will in the future contract any debts, charges, or liabilities whatsoever for which the other party or their property to their estates shall or may be or become liable or responsible, will at all times keep each other free, harmless and indemnified against and from any and all debts and liabilities heretofore or hereafter contracted or incurred by the other, except as expressly provided in this Agreement. 5. ATTORNEYS FEES: HUSBAND and WIFE agree that HUSBAND shall pay for his own counsel fees. HUSBAND and WIFE agree that 3 ( r . HUSBAND shall pay up to $400.00 in counsel fees for WIFE. Any counsel fees over $400.00 shall be paid by WIFE to her counsel. 6. PENSIONS: HUSBAND and WIFE agree that WIFE waives any and all right, title and interest she may have whatsoever in any pensions, retirement or profit sharing, IRA, or similar plan of HUSBAND in consideration of HUSBAND's agreement to waive any right, title and interest he may have whatsoever in any pension, retirement or profit sharing, IRA or similar plan of WIFE. 7. MUTUAL RELEASE: Subject to the provisions of this Agreement, each party has released, discharged and, by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all cause of actions, claims, rights or demands whatsoever, in law or equity, which either of the parties ever had, now have, or can have at any time against the other, specifically including rights or claims to spouse support, alimony, alimony pendente lite, counsel fees and expenses, and equitable distribution of marital property, except for any cause of action for divorce from the bonds of matrimony and any cause of action for breach of any provisions of this Agreement. The parties hereto expressly relinquish and waive any and all rights that they may have now or in the future to claim and/or obtain spouse support, alimony pendente lite, alimony, counsel fees and expenses or equitable distribution of property. , , ,. I I 4 I , ~ i - f. I ( r , 8. ESTATE RELEASE: 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 now 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, courtesy, statutory allowance, widow's I , , f allowance, right to take property under equitable distribution, 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 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 interest, rights and claims. 9. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or determine fit, 10. NO INTERFERENCE: Each party shall be free from interference, authority and control, direct and indirect, by the other as fully as if he or she were single and unmarried. Neither shall molest the other, compel or endeavor to compel, the other to cohabit or dwell with him or her, or to interfere with friendships, 5 , r . ( society or acquaintances which either of the parties hereto may choose or have from this day forward. 11. DOCUMENTS: Each party shall, at the request of the other, execute, acknowledge and deliver to the other party any documents which may be reasonably necessary to give full force and effect to this Agreement. 12. AGREEMENT NOT PREDICATED ON DIVORCE: It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement or institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted and represented by HUSBAND and WIFE, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing HUSBAND and WIFE to execute the Agreement. HUSBAND and WIFE each knowingly and understandingly hereby waives any and all possible claims that this Agreement is, for any reason, 6 r ( illegal or for any reason whatsoever, unenforceable in whole or in part. HUSBAND and WIFE each do hereby warrant, covenant, and agree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 13. CONSENTS TO DIVORCE TO BE EXECUTED: HUSBAND and WIFE each agree to execute Affidavits of Consent to Divorce and Affidavits of Waiver of Counseling contemporaneously with the execution of this Agreement. It is the intention of both parties to promptly seek and obtain a Decree in Divorce after the execution of this Agreement. 14. ABSOLUTE AND FINAL SETTLEMENT: The provisions of this Agreement are intended to consider, determine and distribute all of the assets of the parties hereto as part of the terms of this Postnuptial Agreement. This Agreement is intended by the parties hereto to be a valid Postnuptial Agreement, providing for the absolute and final settlement of their respective property rights and all obligations of spouse support. This Agreement is not intended to be a mere separation agreement. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or promises other than those expressly set forth in this Agreement. 7 ,. , 15. VOLUNTARY EXECUTION AND FAIRNESS OF AGREEMENT: Each party acknowledges that this Agreement has been entered into of his or her own volition, with full knowledge of the facts and full information as to the legal rights, liabilities and the assets of the other, and that each believes this Agreement to be reasonable under the circumstances and not the result of any duress or undue influence. 16. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 17. SITUS: This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 18. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or 8 " I otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 19. ENTRY AS PART OF DECREE: It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce (temporary, interlocutory, final or permanent) shall affect or modify the financial terms of this Agreement. This Agreement shall be embodied in and made part of any such judgment or decree of final divorce. 20. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of all attorney's fees, legal costs and expenses incurred by the other in enforcing their rights under this Agreement. 21. BINDING EFFECT: Each of the parties hereto intends to be legally bound hereby, and this Agreement shall be binding upon his or her heirs, personal representatives and assigns of the respective parties hereto. 9 " . . IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written, each adopting the seal following his or her signature as his or her own. "X alL' c~ ~~~A~ .,J~~~o:;'nlU SHARON D. FERREE ~~~':>~EE .. ......... COMMONWEAL~.OF PENNSYLVANIA COUNTY OF c..:JJJJ8tlfLJ)AJ1) : : ss: : On this, the;J,;)Jff) day of IluGtisr 1994, before me the undersigned officer, personally appeared\-~I.7A'OAl:2), ~~lC known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that they executed the same for the purpose herein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. commission Expires NOTARIAL SEAL VIRGINIA M. MAS , CUIABallANO CO P" /IV COUUISSClN EXl'IRfS NOVEII881, I, 1..7 --- / 10 .. I I SSI I COIOlO.. COUJrrY OJ' On this, the L>~ day Of~~~/19~ befor~me........ the undersigned officer, personally appeared ~V)! ~c:rr-~ known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that they executed the same for the purpose herein contained. IN WITNESS WHEREOF, I have My commission Expires hereunto set my hand and seal. ilimV Cro(L NOTARIAL SEAL CARRIE E. COOK, Notary Public Harrisburg. Dauphin county My Commission Expires Aug 8.1998 'J .;...0 11 ~ - >- 1.1:- .1.- ...,~::: ~,~c.::-" t..0'.(.,)~ '':;-''1:- :""t .~- -~.-~ -Co.. ," 'i~ ~" ~;~'l: .T, ~, to.. ~; ~c..'" ~ "" <:f> co' Q:), ..... ~' , ,-;~< : ,'a. "'.~ ~ ...... -' TIRRY D. J'IRRIIII, I IN THB COURT OJ' COMMON PLEAS plaintiff I CUMBBRLAND COUNTY, PBHlfSYLVJUfIA I v. I NO.9. - 1538 CIVIL I SHARON D. J'IRRIIII, I CIVIL ACTION - LAW Defendant I IN DIVORCB PRAECIPB 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 3301(c) or ~ of the divorce code. inapplicable section.) 2. Date and manner of service of the complaint: March 31. 1994. bv Affidavit of Acceptance of Service (strike . 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit Of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff 9-6-94 ; by the Defendant 8-22-94 . (b) (1) Date of execution of the Plaintiff's Affidavit required by section 3301(d) of the Divorce Code: . (2) Date of service of the Plaintiff's Affidavit upon the Defendant: . 4. Related claims pending: NONE . , ~ /5/ . .'1 /Attorney for Pla ntif Joanne H. Clough, Esquire - , "':7 en , - ::r.: .n% "" ..' :;t' co = n. u..o ......, :c Cl 2 5 .. ..;l tl ~ ~ uioh~ z oS Q~'" 0.. ze;;:: U) < Oz;:: :;;! ~ l:!z;;; i:a z 4n""z <~~:Sg :c ~ 0!!S~ 110I Zlll... Z ~lil" z ...~ < :z: o -. ; - f", ".' . \ . - , ,,' JOANNE HARRISON CLOUGH . Arlllls~.... AT 1,1\\\ ,. .!!III NOR,." .'U:O:'"..O S rRFfT ItANRISIU'R(j.I'INNS"l'I.\'ANIA I1lllJ '11'UI'IHI~'" "'PI ]\(I.'H"II , . " , TBRRY D. FBRRBB, I IN THB COURT OF COMMON PLEAS plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I NO. q(- /53g {! ":VI ( 7(>rm v. I I aBDON D. FERREB, I CIVIL ACTION - LAW Defendant I IN DXVORCB NOTICE TO DEFEND AND CLAIM ALL 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 within twenty (20) days. 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, Cumberland county Courthouse, One Courthouse square, Carlisle, pennsylvania. IF YOU DO NOT FILE A CLAI~ 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 Lawyer Referral Service Court Administrator One Courthouse square Carlisle, pennsylvania 17013 (717) 240-6200 , " TORY D. I'BRR8B, I IN THB COURT 01' COMMON PLEAS plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA I v. I NO. I SHARON D. I'ORBB, I CIVIL ACTION - LAW Defendant I IN DIVORCB COMPLAINT IN DIVORCB UNDER SBCTION 3301 (0) 01' THB DIVORCE COD~ 1. Plaintiff is Terry D. Ferree, an adult individual who currently. resides at 305 Oak Grove Road, Harrisburg, Dauphin County, Pennsylvania, 17112. 2. Defendant is Sharon D. Ferree, and adult individual who currently resides at 8 Cedar street, Newville, Cumberland County, Pennsylvania, 17241. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and Defendant were married on May 11, 1991, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. ;""j : l .... .;'1 , , . . __-"->-.'.A'.___'.... , , 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Neither the Plaintiff or Defendant is a member of the Armed Services of the United states or any of its Allies. 8. The plaintiff avers that the ground on which the action is based is that the marriage is irretriebably broken. WHEREFORE, Plaintiff requests the court to enter a Decree of Divorce dissolving the marriage between the parties. tfully submitte Clough, 204 State street Harrisburg, PA 17 Attorney 1.0. No. (717) 233-1000 Attorney for Plaintiff ;1' ,,' fi " .'1 \ . . . VERII'ICATION I, Terry D. Ferree, verify that the statements made in the attached Divorce Complaint are true and correct to the best of my knowledge, information and belief. 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: J - 3-.1-' q "l -?i%. ,2 &". Ter D. Ferree d'; - :c <>- Ol) .-4 M co r-.I "" .. :II: \S >-~ ..:... ~;I; W("'~"?~ UZL.';.t. ':;:ciu~ ,... x 0;''' r-)~. "r.-' '~T~ .::.J u.. =:> ~(",." p, 01") \ . -0 I..'} \-0 ~\\) ':::J\<"') " ~, Q.. ~.::: ~~ ~ "'-' 0;;..) ~ P) (\-< ~ '. -cJ '~ ~ .' -'l ,... , "':' -J '-J '..... JOANNE HARRISON CLOUGH AlTORNrV AT LA'" / 204 STATE STRErr HARRISBVRG.I'El'il'iSn\'Al'iIA 1710 ' 17PI1H.1000 I -0 ':>\ - ~ -<:l ~ I'- r\\ ~ ':p ~ ~~'\\~ ~ ':_X,:(\ .... ~ \)0 '~~ :I: ~ ::J 2 S ~ u - ~ ~z ~ ~ ~~~ ~ ~ ~~~ < ~ ~~~ :I: ~%"'- < /lO::> ~ III Z !a Z ::l < ~ o -. . I i' o J; . ~. . '- .... TBRRY D. I'BRRBB, Plaintiff I IN THB COURT OF COMMON PLBAS I CUMBBRLAND COUNTY, PENNSYLVANIA I I No.'t~-IS3B I I CIVIL ACTION LAW I IN DIVORCE v. SHARON D. I'BRRBB, Defendant AFFIDAVIT OF ACCEPTANCE OF SERVICE I, ~\-,..~ ~-'L"'~ I hereby acknowledge that I have received a certified copy of the Divorce complaint on the ~ day of rY'I~". c...~ , 19~ 'f .~<::;b~~ Sharon D. Ferree . ~",--.,..-..~,.-. -:r- en - "';,.. -. ,~ ~ - :II:: Co- o N ," ;.;..; ,.- ~ ,---; .. ' !:::::! .' ".,--, ...., N "" a... -; '. ~ ~ ,-... ~. (*~ ::c ~ ;:J 2 o ~ ,.;.l ~ u" t::z ~~~~~ en < lij~";' ;:;a~~::: ~ ~ <~~ < 2 t;~~ ::C5i5~- loLl '" z lil z ~ < :z: o ..... .. .~. , . : " " JOANNE HARRISON CLOUGH ATTORNEY AT LAIl' 204 STA- STREET HARRISBURG, fl." NSYI.VANIA 17101 ,71)'2l\,IOOO ."'" " '...... '";4 ...., .. ~ , . TBRRY D. ~BRREB, Plaintiff I IN THB COURT O~ COMMON PLEAS I COHBERLAND COUNTY, PENNSYLVANIA I I NO. 94 - 1538 CIVIL I I CIVIL ACTION - LAW I IN DIVORCE v. SHARON D. ~BRRBB, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 28, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final Decree 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 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. 54904 relating to unsworn falsification to authorities. Dated: g \~2 \~~ .~~~~ Sharon D. Ferree ~ S" ~~ t: :r.:: ~ m ..:r ,,)' ~.) , ., r c:o ''':':' Q.. ... V> :: ~ 5! :J ,. S t:<~ u I.l.l-J!! Z Eo ~~~ ~ c~... 0.. z~;:: III < Oz;:: ~ ~ ~~~ <~i:":o :: j:: ":ill!: J.&l < ~i~ Z ~~.. Z ...~ < :c o -. ..... , '- . , . ~ t JOANNE HARRISON CLOUGH , . /...,..nRI'(~ AT tA',X' WII NURTII SECONll STRFfT IIARRISHURG. I'ENNSYLV ANI A 17110 TEI.EPIIONE 171711.16.7870 ...'. , .. .', .,.--.--- .. ... . . . . " . . 1 TIDUlY D. I'IDUlBB, I IN TBB COURT 01' COHMON PLBAB plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 94 - 1538 CIVIL I I I SHARON D. I'BaRBB, I CIVIL ACTION - LAW ! Defen12ant: I IN DIVORCB AFFIDAVIT OF CONSENT A Complaint in Divorce under Section I: 1. 3301 (c) of the ~ Divorce Code was filed on March 28, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree 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 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. S4904 relating to unsworn falsification to authorities. - ~,;:; (--::::, . Ter y D. Ferree ... "'-- Dated: S<,:#r<r/l'3~,7 6, f CC"<<t ":>" ?' ,. ~: :.~ :r.: -'1: en ::r 1".1 (-', .- ., '-', ' . ~ CO ~:C" c.. .... ..,., :J: ~ 5! :J ... S ti<~ V IJ ~~~ Z =i C~... 0,," z~;:: II) < OZ;: ~ ~ ~~~ < ~ i: ":0 :J:~~~~ !2: ~!ll~ z ...~ < :: o -. " ~ ., . . '. ."' p " . ,JOANNE HARRISON CLOYGH . An-OktoH:v AT I ~u.' 11UI NORTlt SfCONIl STRrfT IIARRIS8URG, PfNNSYI.\, ANIA 17110 lTI.fPIlONE 171?) 2\f,.7R1n TERRY D, FERREE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, , , : No, 94-1638 SHARON D, FERREE, Defendant , : CMLACTION. LAW : IN DIVORCE ENTRY OF APPEARANCE Please enter my appearance as counsel for Defendant, SHARON D, FERREE, in the above-captioned case, Dated, 1 J., (i't G~Q (~ ANDREA C, JA' OBSEN, ESQUIRE JACOBSEN & MILKES 62 East High Street Carlisle, PA 17013 Attorney No, 20962 '=' CD - - .,~ s::: ~ ," 'C. "-' '. :~ -' = -,