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Home My WebLink About94-01929 c ~ ..:J. cJ . ... '- w c ~ ~ -' "(... UJ ., " . . . . .:+:.' ':Co' .:c- .:c-- ':Co',:.:.'.>>:-"<c,---:c-' .:<<. .:c..:.:. .:+:. .:.:. .:+:. .:+:. .:+:. .:+:. .:+:. .:.:.':-:'.:+:.::.:.:<~.:c-:-.:.:-:~.:.>~ .:+;,'.:c-- ,':c.~.:<c'c~ ~ - ~ ~ ~ i .! ,.; * ,', ~ ~ ..' ~ ~ $ ~ .' W f.' ~ DECREE IN ~ D I V 0 R C E ot- 3 ~ S".L e<< : . .. .. .. .. . JS, .. " 19~4...., it is ordered and .".,. ., ~ v ~.' IN THE COURT OF COMMON PLEAS v '.' i <! .', ~ ~ ,~ s s ~ '.' ~ ,0' $ ,.; * ,', ~ ~~ ,;., ., i ~.' ~ ~7 .~ ~ ~ ~.' i ... w ... w. '.' ,', ~ ~ '.' ~~ ~ ~ I~ I.., ~.:: I """ t..'$.e E:. . ~k...r.. $'CJ\"Dno\or'l J. ;* I '~ ~ bt)' ~H..,- D '\l\<:,<U('(\.0C'I'" I r'cl:,t.{ : ~ ~ . Pro hOllolnry I'.' ~ i* ~ - -. _...-._..... _._ 1.\ .. --... ...... .,-.-..- ....--..........--.-....-.-._--.~.- " .-- -, -....... .--"...-.. ...,. ~ , -~. '--" ~'~" . - . ' . .... . .~:. .:.:- .:.:. .:.;. .:.:. .:.:. .:.:. .:+:. .:+:. .:.:. .:+:- .:.:. .:.:. .:+;. .:.:. .:.:. .:+:. .:+:. .:+:. .:+:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:.' ~ " ~ '.' ~ '.' OF CUMBERLAND COUNTY STATE OF * PENNA. " ., w r,. a ~7 ~ '.' $ ,', * w ~.' JOY.<:I> .J~I>NE...E.RICKSON. Plaintiff . . . . . - . . . . . !I ........... :1 N (). ..~~::-J?,2.~.~.IVI~..!E.~ 19 CIVIL ACTION - LAW w r,. Verslls ~ '.' ..JAMlls...W:r~F.~F:(J.ER:r~I<SON, JR~!. :! IN DIVORCE w ',' Defendant ,: " rt! '.' .' ~ '.' ,', ~ .', ~ ~l .. ~ /'; ~ '.~ ~ decreed that.., . . .., ..Jl?Y<':Ji:. ~~Ji:~Ji:. Ji:~~<':1.<~l?~. . ..... ... .... ....,., plaintiff. and. .. ., .. ..... . .. ." .J,A,M.E.S. .I{I,L.F.~&~ .E.~I.C.~S.ql-!,. .J.R,.. . .. .... . .... defendant, are divorced from the bonds of matrimony. .', ~ ,~ ~ Q ... ~ 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; . .:r~q~~p'~~~~~ .~~~.~~~~~~g~ .~~~~~~~~~~,~g~~~~~~~.~~~~~~~~.~~y'.!~!.!~~~:..." "...... .........i.'.....~..~...".. ..~l'~. .....t ~ ~ ~ .;~.:i..~.i.:'... "';". ~'. ..:. '. ":, ",'1 r~\, ..- "',~."" ';......... 7;"" .. ./..~ .;,.. ~~ ".. !f,.~..:.~ .--..;... "0'_" . ..: ~ :'r__' "'."; 1 1 :' ,:..... ~ ....................'.0...... ,.. ... .... ........... ...... ~ .. ,t. " AlO+1'(.<. Ma..~d IO-;}LJ-9'f ... " , ~ . " MARRIAGE SE7TLEMPNT dGREEMENT THIS AGREEMENT made thisRday of May, 1994, by and between JOYCE 1. ERICKSON, (hereinafter referred to as "WIFE") and JAMES WILFRED ERICKSON, Jr., (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on September 24, 1982; and 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 propeny rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal propeny; the settling of all claims and possible claims by one against the other or against their respective estates and equitable distribution of propeny and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, WIFE and HUSBAND. each intending to be legally bound, hereby covenant and sgree as follows: 1. The parties intend to maintain separate and pennanent domiciles and to live apart from each other. It is the intention and purpose ofthis sgreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner that confonns to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever detennine their respective rights. The division of existing maritsl propeny is not intended by the parties to constitute in any way a sale or exchange of assets. J . 1 ., 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass. annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may can)' on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. Additionally, WIFE agrees to settle and discontinue all legal proceedings under the Protection from Abuse Act presently pending against HUSBAND under docket number 94-1793 Civil Tenn in the Court of Common Pleas of Cumberland County. PeMsylvanis. The proceedings shall be discontinued within twenty-four (24) hours of HUSBAND vacating the marital residence, as outlined in Paragraph Six (6) (A). 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and sgreements of each of the parties to the other. The adequacy of the consideration for sll agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. s. DEBTS: It is further mutually sgreed by and between the parties that the debts be paid as ' follows: a. The HUSBAND shall assume sll Iiabilit). for and pay and indemnifY the WIFE against the following debts and outstanding accounts: Montgomery Wards, and Visa. b. The WIFE shall assume all liability for and pay and indemnity the HUSBAND against all liabilities for household utilities in which her name is listed as a debtor or is listed as a co-debtor. 2 I " 6. Except as herein provided, the parties agree to divide their personal property as follows: HUSBAND shall receive the following items: a. cordless phone b. upstairs push-button phone c. stereo d. Recliner chair in living room e. personal clothing and belongings f. all guns and hunting equipment g. archery equipment h. all tools, with the exception of those belonging to Mr. Baum (WIFE's father), specifically excluding the air compressor i. HUSBAND's family items from his parents j. the air conditioner which had been used in the first floor of the marital home WIFE sgrees to give to HUSBAND the television presently in the master bedroom ofthe marital home once the Montgomery Wards bill is paid in full. WIFE shall receive the remaining items of personalty in the maritsl home. No payment shall be made by either party to the other as a result of the division of property contained herein. The parties agree that this division is fair and equitable, and is voluntary and made without duress by or upon either party. The parties further agree that henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, sll items of personal property of every kind, nature and description and wherever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for sll purposes as if he or she were unmarried. The following division of specific items of personal and real property will be equitsbly distributed as follows: A. REAL ESTATE: HUSBAND agrees to and does hereby release to WIFE any and sll interest he may have in the maritsl residence at 271 Barnstable Road, Carlisle, Cumberland County, PeMsylvania 17013. HUSBAND shall execute an assignment of interest to WIFE for the property, said assignment to be recorded in the Recorder of Deeds Office of Cumberland County, PeMsylvania, along with the original Agreement of Sale executed for said property on January 1, 1988 between HUSBAND and WIFE, and Donald K. and June A. Baum. WIFE shall pay to HUSBAND the sum of Thirty Thousand and noll00 ($30,000.00) Dollars within sixty (30) days of the date of this agreement. HUSBAND agrees to vacate the marital property within forty-eight (48) hours of the execution of this agreement. All keys to said property shall be relinquished to 3 , . . WIFE by HUSBAND when HUSBAND vacates said property. HUSBAND agrees to give twenty-four (24) hour notice to WIFE before entering said property for the purpose of removing remaining personal property as outlined above. B. PERSONAL PROPERTY: The parties agree that they will mutuslly divide their personal effects and household property as noted above within thirty (30) days of this agreement. C. EMPLOYEE BENEFITS AND RETIREMENT PLAN: The parties agree to and do hereby release to each other any interest they may have in each other's employee benefit a!ld retirement plans and employee stock ownership plans. D. BANK ACCOUNTS: HUSBAND releases to WIFE the joint checking sccount at DAFCU. 7. VEmCLES: a. HUSBAND agrees to convey any and all interest which he may have in the 1987 Pontiac 6000 SE within thirty (30) days of the execution of this agreement. At the time of transfer of said interest, WIFE shall be responsible for any and all insurance on said vehicle. In furtherance of the above, WIFE agrees to remove HUSBAND's name from any financial obligation concerning said vehicle within thirty (30) days after the transfer of said vehicle. b. WIFE agrees to convey any and all interest which she may have in the Dodge Charger, the Volkswagen Kannagis. the 1987 Pontiac Trans Am, the Chevrolet Pickup Truck, and the Kawasaki 250 racing motorcycle within thirty (30) days of the execution of the agreement. At the time of transfer of said interests, HUSBAND shall be responsible for any and all insurance on said vehicles and motorcycle, and any and all payments connected with the purchase of said vehicles and motorcycle. In furtherance of the above, HUSBAND agrees to remove WIFE's name from any financial obligstion concerning said vehicles and motorcycle within thirty (30) days after the transfer of said vehicles and motorcycle. 8. INCOME TAX RETURNS: All future income tax returns will be filed separately and the parties will each retain any refund due to them. It is further agreed between the parties that each party will use one of the two children born to their marriage as a deduction on their income tax returns. 4 , . .. 9. SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and matcrial spoussl support from each other and agree not to request or seek to obtain alimony or spousal support bcforc or after any divorce which may be granted. 10. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that upon the expiration of the ninety (90) day waiting period since the filing of the divorce, or at final settlement, whichever occurs later, the parties will execute and file the consents necessary to obtain the divorce. 11. BREACH: If either party breaches any provisions 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 svailable to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 12. lillDITIONAL INSTRUMENTS: Each of the parties shall from time to time, st the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. 13. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect have been fully explained to the parties and its provisions are fully understood. Both parties agree that they are executing this agreement freely and voluntarily. s - f,' ;-- h,"" " 14. ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. Both parties agree that this agreement shall become an Order of Court with the Cumberland County Court of Common Pleas entering said Order and retaining jurisdiction should circumstances change and either party desire or require modification of said Order. IS, APPLICABLE LAW: This agreement shall be construed under the laws of the Commonwealth ofPeMsylvania, 16. PRIOR AGREEMENTS: It is understood and sgreed that any and all property settlement agreements which mayor have been executed or verbally discussed prior to the dste and time of this sgreement are null and void and of no effect. 17. WAIVER OF CLAIMS AGAINST nm ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may 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 limitstion, dower, curtesy, statutory sllowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 6 't:-~~- ...--- IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESSES: ~_ d' ~-,-L JrfY, 'E L ERICKSON ' (SEAL) (SEAL) 7 , " COMMONWEALTH OF PENNSYLVANIA: :5S: COUN1Y OF CUMBERLAND . . PERSONALLY APP~D BEFORE ME, a notlll)' public for Cumberland County, PeMsylvania, this~day of '1170 ';thc 1994, James Wilfred Erickson, Jr.. known to me (or satisfactorily proven) to be the person hose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~i~ hCd r. No III)' Public c: ~5t.( {.j COMMONWEALTH OF PENNSYLVANIA: NoIlIIiaISeaI Blrtln E. SlIel, Nalaty PI.t*: CartII8 Boro. Qrrtlefland ColrIV Myc..",.o.sIoo,Elipires.u.3.1996 :8S: COUN1Y OF CUMBERLAND . . PERSONAL~ APPEARED BEF RE ME, a notlll)' public for Cumberland County, PeMsylvania, this.H- day of 1994 Joyce Irene Erickson, known to me (or satisfactorily proven) to be the person ose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. tk>l";.lI Seal f3<0t:;,\ MOfTcon Nolatyf'\tJla C:tI-..io! &ro. cu,iberland CounIv My CO"'.'Tl:Js;", E,p<oo Doc. 15. 1996 MCiiiiii . 4_---= . . ............. Noraiiii 8 :' t ,~ t , ''. ," ^', . ~ ' -, " '. -, JOYCE IRENE ERICKSON, Plaintiff : IN mE COURT OF COMMON PLEAS OF v. . . : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACflON . LAW 94-1929 CIVIL TERM JAMES WILFRED ERICKSON, JR., Defendant 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about April 18, 1994, defendant's attorney, Ron Turo, Esquire, accepted service of the divorce complaint of behalf of his client, lames Wilfred Erickson, lr. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: September 30, 1994 By the defendant: September 29, 1994 4. Related claims pending: None October 12, 1994 ~\ '" Lr"> ~,... ,.z'- ;.c ."l-:!',.t _ ....(..t__ _, U-;.r.:4,;',"i-: ....., ~c~c.,..t ..... c. ~t: r)::'- I.... 1>-- X. _~l ':.: ,:~' l:~~~~ ;'J._1',,-;.r: - -: .~-,W t:,::;;,(ll.. ...=> or.> . c; ~ \...r; 1"J -=::) <) :i\ .-:::t- ........... " ""'" lr) ~ .......... t.:r- ~ '~ en - ..,.- - ~-';::>1~~ .. ,("\ l::J ~ ."""'f") ~~ ~ -,.,. ~ '>l. N' "'" C>:: ... '""" -- ~~ ~~ ~~ <::.,~ ~~ n - .... . .. :::l ~ 5 III I~~~. .. -1 l;l 0] ~ 1& l!l", , 1:1 I> ~~~~~ ~ a i!l I ~8 1:1 m I 8~~~i!l ~~ ~ ~ .., E-l I:tl o ::l ~ ~ ti ~ III ~ w ~ to) i a:: ~ .,):l~t;~ " 0'" z (OY cij : ~ ~ ~ .. ~ ~ "o...J blo ti J: ~ Foe lr. 0 1/1 ~ tt t ~ ~ ..:s ~ ; ~ .. I-l 2 ~ oJ' oJ Z 5 g ~ ~. 3 ~ I-l .' . . . . .. . . . . law ODic(!s . . . . '. '. . , . IR'YIN. IRWIN & }IcKNIOI:IT . . .0 fo JOY~E IRENE ERICKSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94- If) r CIVIL TERM IN DIVORCE JAMES WILFRED ERICKSON, Jr. Defendant NOTI~E 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 In divorce or annulment may be entered against you by the court. Ajudgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children, When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is availsble in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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. Court Administrator Cumberland County Courthouse Fourth Floor 1 Courthouse Square Carlisle. Pennsylvania 17013 ,"".....-,.~' " JOYCE IRENE ERICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACfION - LAW : . . 94- CIVIL TERM JAMES WILFRED ERICKSON, Jr. Defendant . . IN DIVORCE COMPLAINT IN DIVORCE PURSUANT IQ SECTION 3301 (c) and 3301(a)(6) OF THE DIVORCE CODE NOW, comes the plaintiff, Joyce I. Erickson, by her attorneys, Irwin, Irwin & McKnight, Esquires, and files this complaint in divorce sgainst the defendant, James W. Erickson, Jr., representing as follows: COUNT I 1. The plaintiff is Joyce I. Erickson, an adult individual residing at 271 Barnstable Road, Carlisle, Cumberland County, Pennsylvania 17013. ., 2, The defendant is James Wilfred Erickson, Jr., an adult individusl residing at 271 Barnstable Road, Carlisle, Cumberland County, Pennsylvania 17013. 3, The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on September 24, 1982 in Carlisle, Cumberland County, Pennsylvania. S. Two children were born of this marriage: Donna R. Erickson, born October I, 1986, and Daniel J. Erickson, born August II, 1988. 6. Pursuant to the Divorce Code, Section 3301(c), the plsintiffavers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. --,--- ,. WHEREFORE, the Plaintiff demands judgment: a. Dissolving the marriage between the two parties; b. Equitably distributing all property, both personal and real, owned by the parties; and c. for such further reliefas your Honorable Court may deem equitable and just. COUNT 11 9. Paragraphs One through Five are hereby incorporated by reference as though fully set forth below. 10. Pursuant to the Divorce Code, Section 3301 (a)(6), the Plaintiff avers as the grounds upon which this action is based that the Plaintiff is the injured spouse and that the Defendant has offered such indignities to her as to render her condition intolerable and life burdensome. 11. Paragraph Eight is hereby incorporated by reference as though fully set forth below. WHEREFORE, the Plaintiff demands judgment: a. Dissolving the marriage between the two psrties; ..7{.r~"'.~"f~~r~:::r::,,~,7i,~'rf:~:<:'"': . ... lZ'.="'.'" ~..' " b. Equitably distributing all property, both personal and real, owned by the parties; and c. for such further relief as your Honorable Court may deem equitable and just. Respectfully submitted, IRWIN, IRWIN & McKNIGHT By: Rebecca R. Hughes, squ e 60 West Pomftet Street Carlisle, PA 17013 (717) 249-23 S3 Attomey for Plaintiff Supreme Court 1.0. No. 67212 Date: April I S, 1994 . . .. VERlFI(:A TION The foregoing Complaint is based upon information which has been gathered by my counsel and myself in the preparation of this action. The langusge of the Complsint may in part be the language of my counsel and not my own. I have read the statements made in this Complaint and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this verification. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. ~. ",p.r:Au ~ fCE L ERICKSON . Date: ~ IS- ,1994 - "'..,"'....,,,."',,.. ~ .. ,..,...~-~""_~-:-...--~-..,~~,.,,..,..~.._~..'Z..__ ~7:'_',:,~.,O- JOYCE IRENE ERICKSON, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVll.. ACTION - LAW 94- 19 d.. q CIVIL TERM : JAMES WILFRED ERICKSON, Jr. Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, RON TURD, ESQUIRE, accept service of the Complaint in Divorce on behalf of my client, JAMES W. ERICKSON, and state that I have his authorization to do so. kt!!2 DATE: April 18, 1994 r:-~'...-'.":' ......... ......:._:;;;.;;..; ~ ~ U) :;, ~.. ..- Lu;:;'!; .t U.:z:L.';;'; ~o~..i '''- X'o ':-- ..'. ~:.:;.::! :V> . : ~~ ,t' :r. l.jljj~ - u.WJ ;:.2;(1,. ...::0 0'" - ~ Q: ... - " '~~ .;.,+~ .. ",-.,,,.,.......,.:,,..,.... ,C /~.':,';.,:'''_:''i..:.' '. ','.C' :-- . JOYCE IRENE ERICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. . . : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACl'ION - LAW 94-1929 CIVIL TERM JAMES WILFRED ERICKSON, JR., Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDA VIT The Plaintiff, 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 participste in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's 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. 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 Ps. C,S. Section 4904 relating to unsworn falsification to suthorities. September -ZJ....., 1994 -t:uJ> tv ~ J~ L JAMES WILFRED ERI9'80N, JR. ":2" en - ,..~ ..c;.- ....:.-: .....J~..., :: ~~;::~"rj :c: a..- N .., ~ ~:' . . ~... :-. " '" .. en C-...J "- .... V> ,'" '-, . "'r.=...~,,,.=- __.~ ~."''''''''' , JOYCE IRENE ERICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. . . : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AcrION - LAW . . : 94-1929 CIVIL TERM JAMES WILFRED ERICKSON, JR., Defendant . . . . IN DIVORCE DEFENDANT'S AFFIDAVITOF CONSENT 1. A complaint in divorce under Section 3301(a)(6) and 3301(c) ofthe Divorce Code was filed on April IS, 1994. 2. The marrisge of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a finsl decree in divorce. 4. I understand thst I may lose rights concerning slimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verifY thst the statements made in this affidavit are true and correct. I understand that fslse statements herein made are subject to the penslties of 18 Pa. C. S. Section 4904 relating to unsworn fslsification to authorities. September ))1 , 1994 -Jr^ lu g, .14- 1- AMES WILFRED ERICIESoN. JR. ':',,: a; ::r: o- N r<> '".. ..r.._ ~-" t.~ .l~. WCl. .' Us ;'.:, ~~~~~ . - en C'.l .... .... V"> ., ;.;(.,... .'.-J. -.'-"' .\,-- .. " . . . JOYCE IRENE ERICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . :CUMBERLANDCOUNTY,PENNSYLV~ . . v. . . CIVn.. ACfION - LAW . . : 94-1929 CIVn.. TERM JAMES Wn.FRED ERICKSON, JR., Defendant . . IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDA VIT The Plaintiff, 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 Prothonotary's 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. 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. September "?~" 1994 (") " r 0' \.r.... <';" l/c I ~-~ l" r .r ~ (' /L-~.1-) v 'JOYCE IRENE ERICKSON' " -;".~ ': -.." :' ~. ... '. ' ":~'. :,~;' ~" .. , ~ J; " ....., .'... \. ~ ;1' ',' .<...... ~>o..., ""0""'_ . . . JOYCE IRENE ERICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. . . : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-1929 CIVIL TERM JAMES WILFRED ERICKSON, JR., Defendant IN DIVORCE PLAINTIFF'S AFFIDA VIT OF CONSENT J. A complaint in divorce under Section 3301(a)(6) and 3301(c) of the Divorce Code was filed on April IS, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry ora final decree in divorce. 4. 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. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein msde are subject to the penalties of 18 Pa, C. S, Section 4904 relating to unsworn falsification to authorities. September. io ,1994 I .-e' ~ ., I J C: C. , ('~' :"' t C' , i: {/: ,. _. ,.....:.;...., . ., JOYCE IRENE ERICKSON