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HomeMy WebLinkAbout94-01664 So. <:\.l ~ ~ "i-J .- l... ~ t! ~i , I ..........J .~ " ~ , . . . - . ':CO" .' ._. . .:c. .' ',z. ... '10 . '':co .:co .:co . 'It:' ':C-' . .:c- '_-)(:'~>~_>:4Il().OllllC.::<IIK:<IIK~ ~ I_ ~ ~ : IN THE COURT OF COMMON PLEAS ~ , ~ ~ ~ ;" .. . . ~ ~ ~ ~ ~ ~ 8 ~ 8 ~ ~ ., ~ !i '" v S ~ ~ ~ ~ ~~ .', ~ i ~f i !.~ $ OF CUMBERLAND COUNTY ~ e * STATE OF PENNA. ~ 8 8 S ~ Versus ................. I II :1 N (). ..~.~.~.~.~.~.~... :~.~.~.~...:i9m " ~ DEBORA MAE BRITCHER, ~ '.' ~'. ~ I>E.NNI.~. L., BR~TCHER, $ ;;; ... W >:" DECREE IN DIVORCE ANDNOW,....~..~._.. 19~':1., It is ordered and i '.' ,., ~ ~ 'f ~ decreed that.... ~~.~~~~. .~~~. !3.~~~~~.~~...............,....... plaintiff, and... .. . P.~l'!~~!l..~:. ~.r::~t.:!=.h.E!~... .. ... ... .... . . . .. . .. ... .... defendant, are divorced from the bonds of matrimony. ~ ,,; ~ ~ ~.~ i ~ The court retains jurisdiction of the following claims which have been raised of ry~d in this action for which a final order has not yet been entered; t.JJ~ w '.' ~ !="' i ~.' The attached Separation and Property S lement .... ... ..,......, ..... ........ ..... ....,.. .... ..... ...... incorporated herein. ,... .,. ....'...... ....,..........0'.... ~ ~.' ~P;~~.Il!~I)!=. AI! " ... ~ ..' ~ f.' Dy 0" .._ ,. ." ... _...,. ... .... Atle.I:~,.LI/~ ~I,. ~.d?J, ~,' ~ ~'"prolh~~olar)''' ....... - . - .. ~.. .......-...-...-..............-.-," - -'_.",."'-,-' --~. .. .....'..______________....~_._._"'....___ .........-..........0 I~ **~-~~~*--~_~_~~__e__~. .~ ~ I" ~ ~ '.' ,', * .'. ~ w '.' .', ~ ~ '.' .'. ~ ~. . . . . >f~ /H~,~ ~ ~ A:J.~>:7'9 IJ:.eI4,.. ~ SEPARATION AND PROPERTY SETTLEMENT AGREEMENT ~ 0!~ of 1!Jf\(J..G L THIS AGREEMENT, made this 1994, by and between DEBORA BRITCHER, (hereinafter referred to as "Wife"), and DENNIS BRITCHER, (hereinafter referred to as "Husband"). WITNESSETH: WHEREAS, the parties hereto are Husband and Wife having been married on June 18, 1986. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as botween each other, including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of their personal property; the settling of all matter between them relating to the past, present, and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. - 1 - , . NOW, THEREFORE, in consideration of the premises and of mutual promises, covenants and undertakings hereinafter set forth, Husband and Wife each intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: 1. SEPARATION: Husband and Wife shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint or interference whatsoever by the other, subject to the further provisions of this Agreement. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by a legal or other proceeding. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living separate and apart. 2. HUSBAND'S DEBTS: Husband shall hereinafter be responsible for any and all debts which he has incurred in his name, and promises to indemnify Wife for any liability she may have therein. Husband represents and warrants to Wife that since the date of their separation on or about December l2, 1992, he has not, and in the - 2 - . . 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. 3. WIFE'S DEBTS: Wife shall hereinafter be responsible for any and all debts which she has incurred in her name, and promises to indemnify Husband for any liability he may have therein, Wife represents and warrants to Husband that since the date of their separation on or about December l2, 1992, 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 against him by reason of debts or obligations incurred by her. 4. DIVISION OF PERSONAL PROPERTY: Husband and Wife acknowledge that they have acquired and accumulated various assets which would be defined as either separate or marital property under the Divorce code of 1980. The parties further agree that they have effected a satisfactory division of all of their personal property. More specifically, Wife shall, from and after the date hereof, be the sole and separate owner of all of the personal property presently in her possession or under her control. Husband, from and after the day - 3 - " hereof, shall be the sole and separate owner of all the personal property presently in his possession or in his control. From and after the date of execution of this Agreement, each of the parties shall own and enjoy, independently of any claim or right of the other all items of property, be 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. Husband Bnd wife hereby relinquish to the other all of his or her respective right, title and interest, if any either has, in and to any retirement or pension plans of the other whether through employment or otherwise, if any such plans are in existence. 5. MOTOR VEHICLES: Husband and Wife agree that they shall each become the sole and exclusive owners of any vehicles they currently own or possess, and in furtherance thereto they shall each take whatever steps are necessary to validate said ownership possession. 6. REAL PROPERTY: During the marriage, Husband and Wife resided at RD '1, Box 270, Landisburg, Perry County, Pennsylvania. Husband and Wife agree that Husband will take full possession of the property in exchange for Fifteen Thousand ($15,000.00) Dollars to be made - 4 - payable to Wife. Wife will relinquish all rights of ownership in the said property after said proceeds are received. 7. ALLOCATION OF PRESENT DEBTS: Husband and Wife each assert that there no outstanding bills in their joint names. 8. ALIMONY: Each of the parties hereby waive any right, claim or title which they may have to alimony payments from the other. 9. SUBSEOUENT DIVORCE: Husband and Wife hereby acknowledge that Wife instituted an action in divorce against Husband, which action is docketed to No. ~lf'" "&4 Cr, in the Court of CODllllon Pleas, Cumberland County, Pennsylvania. Husband and Wife each hereby agree to sign the appropriate affidavit of consent, in order to terminate said marriage, in consideration for all the other promises and covenants contained herein. At such time as the divorce action is concluded, the parties shall remain bound by all terms of this Agreement. Further, this Agreement shall be incorporated into the final decree in divorce, however, it shall not merge with said decree. - 5 - 10. LEGAL FEES: Wife waives all claims against Husband for payment of her legal fees. Husband waives all claims against Wife for payment of his legal fees. Each party agrees to be responsible for his or hew own legal fees and related expenses. 11. EOUITABLE DISTRIBUTION OF MARITAL PROPERTY. ALIMONY AND ALIMONY PENDENTE LITE: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the division of their marital property are fair and adequate and satisfactory to them and that this Agreement has been arrived at in a manner which conforms to the criteria set forth in the Pennsylvania Divorce Code taking into account all relevant considerations, including those set forth in Section 3502 of the Pennsylvania Divorce code. Husband and Wife further agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for equitable distribution of marital property, alimony, and alimony pendente lite. Each party shall indemnify, defend and hold the other harmless against any future action for equitable distribution of marital property, alimony, or alimony pendente lite by or on behalf of the other such indemnity to include the actual counsel fees of the successful party in any such future action. - 6 - 12. RELEASE: Subject to the provisions of this Agreement, each party does hereby remise, release, quitclaim and forever discharge the other and the estate of the other from any and every claim that each other may now have or hereafter have or can have at anytime, against the other, or in and to or against the other's estate,or any part thereof, whether arising out of former contracts, engagements, or liabilities of the other or by way of dower or claim in the nature of dower, widow's rights or under the intestate laws, or the right to take against each other's will or for support of maintenance or of any other nature whatsoever except any rights accruing under this Agreement. 13. BREACH: In the event 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 to seek such other remedies or relief as may be available to him or her. The party breaching this Agreement shall be responsible for payment of all legal fees and costs incurred by the other in enforcing his or her rights under this Agreement or in seeking such other remedies or relief as may be available to him or to her. - 7 - """'7""'~"'" ""'~t,:>:'_ 14. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 15. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 16. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or 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. l7. WAIVER: The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. - 8 - ~.~ 18. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 19. REPRESENTATION OF PARTIES: The parties have mutually worked out the terms of this Property Settlement Agreement. Wife has been represented by Bernard L. Coates, Jr., Esquire. Husband has been represented by Williams R. Bunt, Esquire. 20. FULL AND FINAL RELEASE: Husband and Wife hereby enter into this Agreement as a full and final aettlement of any and all outstanding claims which they have against the other. 21. EXECUTION OF OTHER DOCUMENTS: Each party shall on demand execute any other documents that may be necessary or advisable to carry out the provisions of this Agreement. 22. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. - 9 - ,-... "~ .- IN WITNESS WHEREOF, the parties hereto having fully read this Separation and Property Settlement Agreement and fully understanding the terms and ramifications herein, hereby set their hands and seals the day and year first above written. WITNESS I (3~. ........,J '(? Co-lS> IJ~$' 1-\2\~~ -t3~.:t;: lL. DEBORA BRITCHER ~ 89-". .:., ~:J"~ ~ DENNIS BRITCHER - lO - . ,',; AFFIDAVIT I i r COMMONWEALTH OF PENNSYLVANIA COUNTY OF j) (WI' )v--\- ) I SSI On this, the '( y h day of jJ~ , ! I, ! , i \ 'I 1994, before me, a Notary Public, the undersigned officer, personally appeared DEBORA BRITCHER, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. " ,} ,.) /"' r\ n~ // d h L1 fz:; tVc.. , Notary Public NOTARIAL SEAL CONNIE l, FANIIESTOCK. Notary Public Harrbburo. D.uphin Counly. Pa. _M-".Co!,,~~!'!.n Explr.s M4y 22, 1995 ~ --AA:'+A' lv- DEBORA BRITCHER IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. - 11 - f"\*, .,~~'-, ':",:''''' ,.... , . AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF (J(RR Y ) I SSI On this, the ~qt~ day of 1Jr1~ , 1994, before me, a Notary Public, the undersigned officer, personally appeared DENNIS BRITCHER, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. ~~~- Notary Publ c CAROl. A. SWNISOII. NOTARY ,tUaIC u-. - u -~I'A . ....... . ...... . . 1- M eo.~ftJsalon EJ DIll 1 ' "'" - t. DENNIS BRITCHER ~~ ~ IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. - 12 - , '~ . >oF'" :-...."... '..\i. , ~ DEBORA MAE BRITCHER, Plaintiff . . IN THE COURT OP' COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA NO,94-l664 CIVIL TERM VB. CIVIL ACTION - LAW ACTION IN DIVORCE DENNIS L. BRITCHER Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 330l(c) Section <lllilclEl) l. Ground for divorce: irretrievable breakdown under (UU4)o(tn of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: April 5, 1994, Certified Mail, Return Receipt requested . 3. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by Section 20l(c) of the Divorce Code: by the plaintiff October l2, 1994 by defendant September 23', 1994 (b) (1) Date of execution of the plaintiff's affidavit required by Section 20l(d) of the Divorce Code: (2) date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: Nnnp Bernard L. Coates, J<~~~ ~, ....a....~ ~ . .,t 1. j r I " I j:< ~ h' -:z' en ::c 0- = :r (""") >-... .r,_ -:.,.. I- ~ ..., ~~;-:.:~. ," ~, ..~ ~ ~.., . en ':"~J 0- <-> c::> r'~ _, '~.,.:' '" DENNIS L. BRITCHER, Defendant I I I CUMBERLAND COUNTY, PENNSYLVANIA NO. Q4-I(djrcIVIL ~ I e/f'WI CIVIL ACTION - LAW ACTION IN DIVORCE vs. . . . . NOTICE TO DEFEND AND CLAIM RIGHTS .i 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, Cumberland Connty Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. , , i , , COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 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. NOTICE OF AVAILABILITY OF COUNSELING DEBORA MAE BRITCHER, : IN THE COURT OF COMMON PLEAS plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. CIVIL 1994 . . . DENNIS L. BRITCHER, . CIVIL ACTION - LAW . Defendant . ACTION IN DIVORCE . TO THE WITHIN NAMED DEFENDANT: YOU HAVE BEEN NAMED AS DEFENDANT in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, pennsylvania. This Notice is to advise you that, in accordance with Section 202 of the Divorce Code, you may request that the Court require you and your spouse to obtain marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 170l3. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PROTHONOTARY . ., . . DBBORA MAE BRITCHER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA I I I I I I I vs. NO. CIVIL 1994 CIVIL ACTION - LAW ACTION IN DIVORCE DBNNIS L. BRITCHER, Defendant COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Debora Mae Britcher, by her attorney, Bernard L. Coates, and seeks to obtain a Decree in Divorce from the bonds of matrimony with the above-named Defendant, and avers the following: l. Plaintiff Debora Mae Britcher is an adult individual residing at 2237 Aspen Court, Mechanicsburg, Cumberland County, Pennsylvania l7055. 2. Defendant Dennis L. Britcher is an adult individual residing at RD #1, Box 270, Landisburg, Perry County, Pennsylvania 17040. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 18, 1986. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Defendant is not a member of the Armed Services of the United States or any of its Allies. . , . B. Plaintiff has been advised of the availability of counseling, and understands that she has the right to request the Court to require the parties to participate in counseling. 9. The parties to this action separated December 12, 1992 and have continued to live separate and apart. WHBREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce. COUNT II. REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SBCTION 3502(a) OF THE DIVORCE CODE 10. The prior paragraphs of this Complaint are incorporated herein by reference thereto. l1. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHBREFORE, Plaintiff respectfully requests the Court to enter an order of equitable distribution oi marital property pursuant to section 3S02(a) of the Divorce Code. DATBD: 3/l0/94 ~~Af::, ~*~ ATTORNEY FOR PLAINTIFF 3207 North Front Street Harrisburg, PA 17110 (717) 232-7706 rT'"""'~'j;~r"*i!/:':,";'." ~..,;~J.- "'1, , I rJ n. , "'..,",,^,~ . . VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. DATED: '30 C]. '14 . ~~~~ DEBORA MAE BRITCHER ~.11 ~, r..... ~. ~ ~ ~ . ' "7' en >-... - :ft..: ::c UI:-; ~J:.! a.... O;,e.....J n L;:C)U"l rf 1."J:;:;i'. l"'1~~ " - ,'-)...t' "." ..~ . ' , ! ".~ J ',j ':1,_ n:: .... """ ,;i:':., '=> ~;t..' ~ 'l') j<;) \ In \Q \.r) <:) '::::J ~ ~ -..:::r- --.. "'" ~ ""'-.. -...... {~~',~ ..;: ro;;;; , ..... \\-<. ~ ~ ~ ...; '- ~-- .'..... ....~~.. , .,~....... ,- 13- UO ..... 'l \S'- \.l. I' - r0 ~Uo l'\) 'il ... ~~~ v ,J"Io .... - ,. . . DEBORA MAE BRITCHER, I IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. I NO. 94-1664 CIVIL TERM I DENNIS L. BRITCHER, I CIVIL ACTION - LAW Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE Bernard L. Coates deposes and says: l. That he is an adult individual residing in Dauphin County, Pennsylvania. 2. That on April 5, 1994, he sent by Certified Mail, Return Receipt Requested from Harrisburg, Pennsylvania P832-880-375 the Complaint in Divorce in the above-captioned case tOI William R. Bunt, Esq. Attorney for Dennis L. Britcher PO Box 336 l09 S. Carlisle Street New Bloomfield, PA 17068 3. That C. Swanson signed the receipt No. P832-880-375 which is attached to this Affidavit. DATED I lO/l8/94 (3~ .~e~ BERNARD L. COATES, JR., ESQUtRE ATTORNEY FOR PLAINTIFF 3207 North Front Street Harrisburg, PA l7ll0 (717) 232-7706 BY: Sworn to and subsc;ibed before me tl}is JiY 11 day of eJl' tMt!~ , 1994. (\ t'Jh~u 70r ).1.L~) ~r'-f: Notary Public tIOTM!M SEAL COUNIE l. r"":~r~'; :".K tl~;"rv Public IlJrrLbulg, O':l.;J_;:1 CCllnly. Pd. ':y Comn:Is:;o" h,~,:.I.':Y :~:!99S l. ',~_ .. ... . , , 'JI~~~-:-L:::;..:21:r;;~_t.. ~ "",you. '_ .,~... ",': ,. ':. ,->)v~~-~.. ,'. ,,~."~'" ,t't-;~fdT'?tt~"i!-if~; tC :A.....'fo!'l'lO'!"-l!ItIlo......"OI"'!,'!"~"~\:' :l;:I\J.Add~~~~~~' -~: ,1:1!9.t=" _;_..;,u..........._~O;-~'ii,O'R..tJCt~'O~~-""~i'P4I'% .._10_...._.._........- '~" . "",","' ~:~'o~ l! ~''I'- .,. .,!!""':-';". 1':' - Con.utt utIf tor tHo """,.-fi.ilt' l' '~\},j " MIld to:, ~pl~;eO~375\,j(.~i;;,~~,~{1~;~I~ 't !!iiU~m 'R.Bunt, B8q~ ,..~;:~i~ "',,.,'.,:;':,:;;'!;~;~:j ;1 ~, "~~"'O, Box 336 . ,";'.,D ~11tI1Id" [Jln.ulld '\':;" ;.~'o:";i\".'! ~i:99, S. Carl'isl.e ,"street"" Ja"'C.!!.l~" '.", i:J COP" ::w :~~l*~~fti I'F"~ ;!f~'" Blo~mfield, PA 17068 Cl~,' "'111" ,C),RItum, , ,ft, ~ j'}~i!,;f~' ~" ;. t'" " >, '7. D.I. 01 D,U\/IIl ,. ':.. 'i"';""~:'.'f,~.' ~'" ' '... ' ,.t' :. "'"PR'O:8~199t~~i~t.?J , ."t~,.,~d~~-!'J 8..,==~~~.UI~!Y.!!,,~~;~m }11~i ....~f\j.:" . '-\',:":' ."., , f": ..'.):\~::.-,t'!: It.,::,--,,.:-:~.(T<~/::.f~~f1~~; h '~i,):.~;ltHiI. ; ilL: !11.,h:.t.IJjltJJlfj1.<;~i~}ii':: ....'..~...r..,.-. >."'....,..c'~_-q...:....'-l.L~,"',U""'.j;. ~, ,. ,';l)~r ',"~'~. ..u.a._I__71.DO"'E8I1~,~!~~~SJ~ '_)";'-.1 P 832 11110 375 ........ RecelP~or A":,' Certlfle Mall N No Insuran Coverage Provided 1!:IIf'.r...:u Do nol use lor IntemaUana/ Mail (500 Rovolllo) ~W\lliam R. Bunt, Esq. StftetlndNo. ox 109 S. Carlisle P.o_. SWtn ZlP Code - Stre t l70 8 t $ ,5;).., c..-. r.. I, <..' ,j SpecNI 0tIwty Fee Ren1cted Ddwty f.. lll--- : ..............- /,6 0 w An.tn ReceIpC lO.l'hom.," ~ DeIt. and Mrhuft'. ... ""1 TOTAl. Poiuge 0"- $',5'.;1., i PoItmark Of O&te M ~ 4/5/94 Ie bl:~;.;11'r'" . .............. ~.- . -:r ~ - - .~ .' :c: ~ el- '.., , .' 'j r. ~ '- CJ .. ., :or " " . M ,,.', ,i ..~ . en ':l'U \ , C_ - '" '"' l .... ~, = .;J . / ) ~ , \ . . .. II ..l......""'.........._ . .1"""\ r"'," -. DEBORA MAE BRITCHER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-l664 Civil Term CIVIL ACTION - LAW IN DIVORCE vs. DENNIS L. BRITCHER, Defendant AFFIDAVIT I, DEBORA MAE BRITCHER, 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 l8 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. Q~C\./7Lcv:.. ~ DEBORA MAE BRITCHER Sworn to and sU~~9;ibed before ~e this fYl'1I day of to t'R>6t!<-.. , 1994. _(~>~L ?f:dJ-J.,1?l't)~Jc otary PublJ.c C 0, NC7"~:l\t ~E"l C;'.WE l. f""" -, L" H.,;tj'-. .:" (, ~,., NOfJry PubUc ~ :.~:~:~~;;':.' -', 1 (:"~':liy p" ,-;I~;; l.'.')' :!i. 1??5 ..---- ':r' en - == c- ::r ;:r C""') ~)ooo ;-:~ l..I<'7-~.: ~-, {~ z:; :~ ,.':?, :":R"" ..' ~ 0- c..> c::J I ~~I .0{. .:.,.I'-t' " .. :;; ~'-' en , \ \, \ - '..-' '-" " (--*. "~"""'"--'.<.., ,~t:~,.,,: ,........, (", '. ... DEBORA MAE BRITCHER, I IN THE COURT OF COMMON PLEAS Plaintiff I DAUPHIN COUNTY, PENNSYLVANIA I vs. I NO. CIVIL 1994 I CIVIL ACTION - LAW DENNIS L. BRITCHER, I Defendant I IN DIVORCE AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Dennis L. Britcher, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. Defendant is not a member of the Armed Services or any of its Allies. 4. I consent to the entry of a final decree of divorce. , , 5. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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 l8 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~1hy I &~. DENNIS L. - '<JL~ BRITCHER Sworn to and subscribed befo e me this ol31!! day of , 1994. l:MCI. A. SWAHSOII. NOTARY PUBLIC .... 8Ioell.1leId. """ Co., PA CIl"'lIh I & Dee I 1995 r; c::> ~>- ..(t; - :":.t lJl,,< -:- U-;r.V:;.t' ::.. ~~~ ':. <: :... ... , " ~~. '.: .', ';' . ;::r 'r~:::: ~~ , .' '" '0<-' ,.--""" --'---1 f~,. C'-ttM\Jt:,.:., l ~,. '-'" lI',," H ~;j)'; l iI\" Ui".IL'$;q' 1.',,1 'l" "." i ~I~~~;;::,,:, ~ j -::r en - - 0:: : :r ("I") cn - .. J ,... .., '--'" .", .. (J".r.-'.....- > " ...... I"". ,--. DEBORA MAE BRITCHER, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS. I NO. CIVIL 1994 . CIVIL ACTION - LAW . DENNIS L. BRITCHER, I Defendant I IN DIVORCE AFFIDAVIT I, DENNIS L. BRITCHER, being duly sworn according to law, deposes and saysl 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 l8 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. Q~ kG,,'d. DENNIS L. BRITCHER Sworn to and subscribed before me this J3Al day ~~ Notary Publl.c = .... ..... <.:.> (,..; ",. -'.'1 :1-_ .... .'~' - t.O .z:;.. .:.... DEBORA' MAE BRITCHER, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 94-l664 Civil Term CIVIL ACTION - LAW vs. DENNIS L. BRITCHER Defendant IN DIVORCE AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, DEBORA MAE BRITCHER, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on 2. irretrievably of filing the The marriage of Plaintiff and Defendant is broken and ninety days have elapsed from the Complaint. date 3. Defendant is not a member of the Armed Services or any of its Allies. divorce. 4. I consent to the entry of a final decree of 5. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. I verify that the statements made in this Affidavit are true and correct. In understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn folsification to authorities. Date: loll ()- / q ,-I , , , . GO~J--tll.A lrvO".L- A~..i:-rA.Lt~ DEBORA MAE BRITCHER Sworn to and subsc~ibed befo9T ~ this /?fll day of 12cl-bc>tC, , 1994. (1 It (lhwl-LL <<:f),-.L?'Jt>t V Notary Pu ic = r> - ~ W r ~ NOTARiAl SEAL CONNIE L FAHNmcCK. NOI 10\0 =uru, O.uphi. Cou.~ :~,bll ---!,1~. _upi.... ~y!~ I' - '. - ...~ - CoD .r:-