Loading...
HomeMy WebLinkAbout94-01954 ,.. '~-~'~~'~'~~'~~'~-~--~-~---')"~~~~:~'~;~-:~~~ M ~ ~7 , ~ 8 : IN THE COURT OF COMMON PLEAS : ,;,; ~ OF CUMBERLAND COUNTY l'f' STATE OF . PENNA. i ',' w ", ~ ~.' 8 ~ .' LISA HIPPENSTEEL OOUGHTER, ') n.................. 'I :1 N (I. ......,~.?~,~,......., ....~~,':':~~.. 1994 ~ '.' ~ '.' Plaintiff ~ '" Vel'SlIS ~ MI<:HAEL,P'd~HTER, * Defendal1t , " ." ~ " ~ '.' w '.' DECREE IN DIVORCE ~ ',' ~l ',' ~ t. ~ '.' AND NOW, ......... ,t2r-n'C.., n:...., 19, rx-:,. it is ordered and decreed that." .. ,"" ,,!-,.i,s~, !l.i~,n!3,t~,l. !3?,U.Cl~.~.r.,."..."". plaintiff, and. .............. .... .. .f:1i:<7~~U): ,~':1C]~~,,:r;.... ........, , ... defendant, are divorced from the bonds of matrimony. ~ ~ ~ ( ~ 8 8 ~ ,,' i ... 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; None ~ ~ ~ .:; ~ .. ........... ........ ............. ...... .............. ...... .............., " l:; ny T e Courl: / ~ $ --t fA..' /-1 ' , ".., ~ AIlCS.I: ~, ,~e tf'. t<1~~ /-'U'~, ';;:>/'!Y J, ',' ? r~ 4- ~1!/nl.e.J1k c;]d ,,' 'l~~ ~ 1'1 ~ '7Af;.olhonolnry ',' ~ ~ ~ . ~..::-.;;-::.:.- ::.:: -:;~ ,~:,":l .:+;. - .:.:: ~:.:. ':~:: -::~.- .:.:.~ ::.~~ ",:+;: '".:.:.' .:+:. .:.::::.:. .:+:.-'.:.:.~".:.:. '.:.:.' {o:.---,:.:: ::.:. .:.:~ .:.:. - .:+:. .:~~ t ~.' ~ -- ~.~ ~ ~ ~ ~ 8 ~ ~ ~ ~ ~ ;,; ~ 8 r- ~ 8 ~ ~ $ ~ ~ ;;; ~ ~ " i ',' ~ ~.' .', ~ .', ~ ." ~ ~ ',' ~ ~ ... lI,d(J,9,r M ~ '?iJl/ a LJ~ .y. 17, 'lj 7f~ JZC~ ~ 'fit! . DW ~-:;,~ , . .,! - '.;'; .... ". ...':'1: ... .'.,. ~ ~.-: . "-' , .' - . '.' - , . ..... ......., ,..... ..: ., .2: .' " ,- lJ"L a:'>> ,- - = N "" ., - C"'"') = "- -'" ,- . , ..'" --_. . , . . . , THIS AGREEMENT Is made and entered Into between LISA HIPPENSTEEL BOUGHTER and MICHAEL p, BOUGHTER, hereInafter referred to as Husbend end WIfe, The pertles were marrIed on August 2B, 1993. As a consequence of dIsputes and unhappy dIfferences, the partIes have separated, The partl es desIre to contlrm theIr seperatlon find make arrangements In connectIon therewIth, IncludIng the settlement of theIr property rIghts, and all other rights and obllgatlons arisIng out of the marriage relationshIp, It Is therefore agreed: 1. CONSIDERATION The consIderatIon for thIs Agreement Is the mutual promIses and agreements hereIn contaIned, 2. SEPARATION ANQ tiONINTERFER~~GE A. It wl11 be lawful for each party at all tImes hereafter to llve seperate and llpert from the other perty llt such pIece or pIeces es he or she may from tIme to tIme choose or deem fIt. B. Eech perty Shllll be free from Interference, euthOrlty end control, dIrect or IndIrect, by the other, es fully llS If he or she were sIngle and unmerr1ed. Ne1ther shell bother the other or compel or endeevor to compel the other to coheb1t or dwell wIth hIm or her. - 3. MUTUAL RELEASE Subject to the provIsions of thIs Agreement, eech party hes releesed end dlscherged, end by this Agreement does for himself or herself, end hIs or her heIrs, legel representatives, executors, admlnlstretors, end esslgns, release end dlscherge the other of and from all causes of ectlon, clelms, rights, or demands whetsoever, In law or equity, which either of the pertles ever hed or now has llgelnst the other, except eny or llll Clluse or Clluses of ectlon for divorce. 4. FULL DISCLOSURE The provisions of thIs Agreement llnd their legel effect ere fully understood by eech party to thIs Agreement, end eech party ecknowledges thllt the Agreement Is faIr end equlteble, thet It Is being entered Into volunter11y, end thllt It Is not the result of llny duress or undue Influence. Husbend end Wife eech represent llnd wllrrant to the other that he or she hes mede II full and complete disclosure to the other of llll assets of any nllture whetsoever In whIch such party has an Interest, of the sources end emount of the Income of such perty of every type whatsoever, and of ell other fects relating to the subject metter of thIs Agreement. WIfe represents thet she was represented by Dllrrell C. Dethlefs, Esquire, In reechlng thIs Agreement, and Husband represents that he wes represented by Robert C. Seldls, Esquire, In reachIng thIs Agreement. Both pertles represent thet the terms of thIs Agreement heve been fully explelned to them by theIr respective counsel. " .,....~,"ot~F); 6, SUBSEQUENT DIVORCE A. AGREEMENT NOT PREDICATED ON DIVORCE - It Is spec1flcelly understood and egreed by and between the pertles hereto end eech of the saId perU es does hereby warrant llnd represent to the other thet the executIon end delIvery of thIs Agreement Is not predlceted upon nor mede SUbJect to llny agreement for Institution, prosecution, defense, or for the non-prosecution or non-defense of llny actIon for dIvorce; provIded, however, that nothing contaIned In thIs Agreement shell prevent or preclude either of the parties hereto from commencIng, Instituting or prosecuting any action or ectlons for divorce, upon Just, legel end proper grounds; nor to prevent either perty from defendIng llny such action which hes been, mayor shall be InstItuted by the other pllrty, or from making any Just or proper defense thereto. It Is warranted, covenanted end represented by Husband and Wife, each to the other, that thIs Agreement Is lewful 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 end understandIngly hereby welves any and all possIble clelms thet this Agreement Is, for eny 5. EOUITABLE DIVISION By this Agreement, the pertles heve Intended to effect en equlteble dIvIsIon of theIr merltel property. ThIs dIvIsion Is not Intended by the partIes to constitute In eny wey e sale or exchenge of essets. reeson, 111egel of for eny reeson whetsoever, unenforceeble In whole or In part. Husbend end WIfe eech do hereby werrent, covenent end egree thet, In eny possible event, he end she ere end shell forever be estopped from essertlng eny 111ege1lty or unenforceebl1lty es to ell or eny pert of this Agreement. 6. ENTRV AS PART OF DECREE - It Is the Intention of the pertles thet the Agreement shell survive eny ectlon for dIvorce whIch mey be InstItuted or prosecuted by either perty end no order, Judgment or decree of dIvorce, temporary, flnel or permanent, shall affect or modify the fInancial terms of thIs Agreement. ThIs Agreement shall be lncorporeted In but shell not merge Into eny such Judgment or decree of flnel dIvorce, but shall be Incorporated for the purpose of enforcement only. C. MUTUAL CONSENT DIVORCE - The pertles egree end ecknowledge thet theIr marnage Is Irretnevebly broken, thet they do not desIre mantel counsellng, and that they both consent to the entry of a decree In divorce pursuent to 23 Pe.C.S.A. Section 330 1(c). Accordingly, both parties egree to forthwith execute such consents, effldevlts, or other documents end to dIrect theIr respective ettorneys to forthwIth me such consents, affidavits, or other documents es mey be necessary to promptly proceed to obtaIn a dIvorce pursuent to seld 23 Pe.c.S.A. Section 3301(c). Upon request, to the extent permItted by law end the eppllcable RUles of CivIl Procedure, the nemed defendant In such dIvorce ectlon shell execute eny waivers of notice or other wlllvers necessary to expedite such dIvorce. 7. DIVISION OF I:'ERSO~AL PROPERTY Wife egrees that all of the property In the possession of Husband es of August I, 1994, shall be the sole end separate property of Husbend; end Husbend egrees thet ell of the property In the possession of Wife es of August I, 1994, shell be the sole and seperete property of Wife. The parties do hereby specifIcally waive, releese, renounce end forever ebandon whetever claims, If any, he or she mey heve with respect to the ebove Items whIch shell become the sol e and seperate property of the other. B. DIVISION OF MOTOR VEHICLES With respect to the motor vehIcles owned by one or both of the pertles, they egree es follows: Both pertles shell reteln the motor vehIcle presently In theIr possessIon. The titles to the seld motor vehIcles shall be executed by the parties, 1f epproprlate, for effectuatIng transfer as hereIn provIded, on the date of execution of thIs Agreement or at eny tIme thereefter et the request of either party. 9. DISPOSITION OF PROP~RTV From and after the dete of the sIgning of thIs Agreement, both parties shell have complete freedom of disposition as to hIs/her seperate property end eny property which Is In theIr possessIon or control pursuent to thIs Agreement end may mortgage, sell, grant, conveyor otherwise encumber or dispose of such property, whether reel or personel, whether such property was ecqulred before, during or efter merrlege, and neither Husbend nor Wife need Join In, consent to, or ecknowledge any deed, mortgege, or other Instrument of the other pertaInIng to such dIsposItIon of property. 10. PAVMENT OF SPECIFIED OBLIGATIONs The parties agree that the following constitute joint marital obllgatlons which shell be peld by the following person: A. WIFE - 1. All debts Incurred by Wife since the parties separetlon. 2. All debt associated with the motor vehIcle In Wife's possession at the time of the signIng of the Agreement. B. HUSBAND - 1. All debts Incurred by HUSband sInce the partIes seperatlon. All debt associated with the motor vehicle In Husband's possession at the time of the sIgning of the Agreement. 2. II. LEGAl, FEES Upon execution of this Agreement, Husband shall pay to Wife the sum of $255.25 which represents reimbursement of one-half (1/2) of WIfe's costs and legel fee In connection with thIs matter. ., i I j L :t ,l' ,-.h } ~. f' ,., 12. ALlMON~ Both parties acknowledge end cgree thet the provIsIons of thIs Agreement provIding for equlteble dIstribution of merltel property ere felr, adequate and satisfactory to them end are eccepted by them In lieu of end In full end flnel settlement end setlsfectlon of eny claims or demends thct either mey now or hereefter heve egelnst the other for support, melntencnce, allmony pendente lite or ellmony. Husband llnd Wife further, voluntarily and Intelligently, waIve and rellnqulsh any right to seek from the other any payment for support, maintenance, llllmony pendente lite or allmony. 13. EENSION PROGRAI1 Each party hereto shall maintain sole ownership over his or her IndivIdual pension plan, profit sharing or sImIlar retirement plan acquired IndivIdually or as the result of contributions by his or her employer. Wife hereby releases any Interest thllt she has In the retirement benefits of Husband accumulated as the result of hIs employment by Cllffery Auto SUPply. Husband hereby releases llny Interest thllt he hes In the retirement benefits of Wife accumulated as the result of her employment by United Telephone llnd eny other additional benefits she may have accrued. This waiver ls a full and complete discharge of each partIes' marital claim. 14. MISC~LLANEOUS All assets IncludIng, but not lImited to, savings accounts, checking eccounts, certlflcetes of deposit end life Insurence policIes shall be the sole end separate property of the title holder of saId asset. The pertles believe and agree, and heve been so advIsed by their respective attorneys, that the division of property heretofore mede by this Agreement Is a non-taxable divisIon of property between co-owners rather than a texable sale or exchange of such property. Each perty promIses not to take eny position with respect to the adJusted basis of the property assigned to him or her or with respect to any other Issue which Is Inconsistent with the position set forth In the preceding sentence on his or her federal or state Income tax returns. 15. GENERAL PROVISIONS A. WARRANTV AS TO EXISTING OBLIGATIONS - Each party represents that they have not heretofore Incurred or contracted for any debt or llebl1lty or obllgatlon for which the estate of the other party mey be responsible or llable except as may be provided for In this Agreement.. Each perty agrees to Indemnify or hold the other party hermless from end agelnst any end all such debts, llabllltles, or obllgatlons of every kInd which may heve heretofore been Incurred by them, Including those for necessities, except for the obllgatlons arising out of this Agreement. B. WARRANTV AS TO FUTURE OBLIGATIONS - WIfe and Husband each covenent, werrant, represent, and agree thet each w111 now and et ell times hereefter seve harmless and keep the other IndemnifIed from ell debts, cherges, end llebl1lt1es Incurred by the other efter the execution date of this Agreement, except llS may be otherwise speclflcelly provided for by the terms of this Agreement and thllt neither of them shall hereefter Incur llny llablllty whatsoever for which the estete of the other mey be lleble. C. SEVERABILITY - If eny term, conditIon, cleuse, or provisIon of this Agreement shall be determIned or declared to be voId or lnvelld In law or otherwise, then only that term, condition, clause, or provIsIon shell be stricken from this Agreement and In all other respects this Agreement shall be valid and continue In full force, effect , end operation. Likewise, the failure of eny party to meet hIs or her obligatIons under anyone or more of the paragraphs hereIn, with the exception of the setisfllctlon of the conditions precedent, shall In no way voId or alter the remaining obligatIons of the partIes. D. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they wl11 forthwith execute any and ell written Instruments, esslgnments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desIrable for the proper effectuation of this Agreement, and as theIr respective counsel shell mutuelly llgree should be so executed In order to carry out fully and effectively the terms of this Agreement. E. ENTIRE AGREEMENT - This Agreement contelns the entire understendlng of the pertles, and there are no representetlons, warranties, covenents, or underteklngs other then those expressly set forth herein. F. WAIVER OR MODIFICATION TO BE IN WRITING - No modIfication or waIver of any of the terms hereof shall be valId unless In wrl tlng and sIgned by both pertles llnd no waiver of eny breech hereof or defeult hereunder shell be deemed e waiver of eny subsequent defeult of the seme or slmller nllture. G. MUTUAL COOPERATION - EllCh pllrty shall, et any time and from time to tIme hereafter, take eny end ell steps end execute, ecknowledge, and dellver to the other perty eny and all further Instruments end/or documents thet the other party may reasonebly requIre for the purpose of givIng full force and effect to the provisions of thIs Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed In eccordance with the lews of the Commonwealth of Pennsylvanle. I. BINDING EFFECT - Except as otherwise stilted herein." this Agreement shell be binding and shell Inure to the benefit of the parties hereto end theIr respective heirs, executors, adminIstrators, successors, and assigns. J. NO WAIVER OF DEFAULT - This Agreement shall remain In full force end effect unless end until termInated under and pursuent to the terms of thIs Agreement. The failure of either perty to Insist upon strict performence of eny of the provisions of this Agreement shall In no wey effect the right of such perty hereafter to enforce the same, nor shall the welver of eny breach of any provIsion hereof be construed es a welver of any subsequent defllult of the seme or slmller nature, nor shell It be construed as a welver of strict performllnce of eny other obllgetlons herein. K. HEADINGS NOT PART OF AGREEMENT - Any heading precedIng the text of the severlll paragraphs end subparegraphs hereof ere Inserted solely for convenience or reference end shall not constItute e part of this Agreement nor shall they effect Its meenlng, construction, or effect. L. ADDRESS OF PARTIES - Each perty shall at all times keep the other Informed of hIs or her place of resl dence, end shell promptly notify the other of any chenge, givIng the llddress of the new pIece of resIdence. M. WAIVER OF CLAIMS AGAINST ESTATES - Except as hereIn otherwise provided, each party may dIspose of his or her property In any wey, end eech party hereby waives and relInquishes any and ell rIghts he or she mey have or hereafter acquire, under the present or future lews of Pennsylvenle or another Jurisdiction, to share In the property or the estate of the other es a result of the merltel relationshIp, Including, without llmltatlon, dower, curtesy, their statutory equlvelents, widow's allowence, homestead rights, right to take In Intestecy, right to take egelnst the w111 of other, and right to act es admInistrator or executor of the other's estate, and each party wl11, et the request of the other, execute, ecknowledge, and dellver eny and ell Instruments which may be necessery or advlseble to cerry Into effect this mutual waIver end rellnqulshment of ell such Interests, rights end clelms. N. ATTORNEV'S FEES FOR ENFORCEMENT - In the event that either perty breaches any provision of this Agreement, and the other party retains counsel to esslst In enforcing the terms thereof, the partIes hereby agree thet the breechlng party w111 pay ell reasoneble ettorneys' fees, court costs, and expenses Incurred by the other party In enforcing the Agreement. IN WITNESS WHEREOF, and Intending to be bound hereby, the parties heve sIgned and seeled this Agreement on the J!.' dey of AI ~ , I 9~, at Hem sburg, pennsyl van I a. In the presence of: / '- "'-~/7 '- (SEAL) IN THE COORT OF CQofolOO PLEAS OF CUoIBERLAND CXXJNTl{, PENNSYLVANIA LISA HIPPENSTEEL BOUGHTER, Plaintiff NO. 1954 CIVIL 1994 vs. MICHAEL P. OOUGHTER, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infotTlllitioni to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdCMll under Section 3301 (c) 3301 (d)(l) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of s~ice of the canplaint: April 25, 1994 Certified Mail Return Receipt Requested 3. Canplete 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 March 17, 1995 by the defendant March 9, 1995 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) Date of service of the plaintiff's affidavit upon the defendant: N/A 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code March 24, 1995 by Mail on Defendant's Attorney ~ At orney for Plaintiff/~f~.R~ . . , . : ~ = e.- N 0::> -:r >-.. "">- ;.~~..,f t~~<;z: --, <:')(.' '. (....~.~.i' ," ,'-,......."..1 --...l-. .' r t,;,' - (T1 .......... ,"j'" ~~~.:~ ~. :=> 'Oc:,... <>= .... od: ~ i rn; ~ '\ ~ ~ ~~ ,/ ~ ~ t ~ r'"~.''' ~.....~ .'-,.....~~~; LISA HIPPBNSTBBL BOUGHTBR, PLAIRTIFf : IN THB COURT Of COMMON PLEAS : CUMBERLAHD COURTY, PBNRSYLVARIA VS. HICBABL P. BOUGBTBR, DBPBMDAHT . ~ RO.: 9//"'/?6o/"~~ . : CIVIL ACTION - LAW - : DIVORCB ACTION 1f0TICB You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice have been served, To defend against the aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the defendant, or by an attorney, You are warned that if you fail to take action against these claims, the court may proceed without you and a judgement for any money claimed in the complaint or for another claim required by the plaintiff may be entered against you by the court without further notice. You may lose money, property or other rights important to you, YOU SHOULD TAKB THIS PAPBR TO YOUR LAWYBR AT ONCB, IP YOU DO NOT HAVB A LAWYBR OR CANNOT APPORD ONB, GO TO OR TBLBPHONE THE OPFICE SBT PORTH BBLOW TO PIND OUT WHBRE YOU CAN GBT LEGAL HBLP. ~UMBBRLAND COUNT~ CUMBBRLAND COUNTY LAWYBR RBPBRRAL SERVICB, ONB COURTHOUSB SQUARB POURTH PLOOR CARLISLB, PA 17013 (717)697-0371 f'.,...''';--.;....,,,.,.,.,:-n!:tr.~ " 1f0TICIA Le han demandado a usted en 1a corte, Si usted quiere defenderse de estas damandas expuastas en las paginas siguientes, usted tiene viente (20) dias de p1azo a1 partir de la fecha de 1a demanda y 1a notificacion, Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en 1a corte en forma escrita sus defensas 0 sus objeciones alas demand as en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orde contra usted sin previo aviso 0 notificacion y por cua1quier queja 0 alivio que es pedido en 1a peticion de demanda. usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted, LLBVB BSTA DBHANDA A UN ABODAGO IHHBDIATAMBNTB, SI NO TIBNNB ABOGAD 0 SI NO TIBNB BL DINBRO SUFICIBNTB DB PAGAR TAL SBRVICIO, VAYA BN PBRSONA 0 LLAHB POR TBLBFONB A LA OFICINA CUYA DIRBCCION SB BNCUENTRA ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUBDB CONSBGUIR ASSISTENCIA LBGAL: CUlWBRLAND COUNTY CUMBBRLAND COUNTY LAWYBR RBFBRRAL SBRVICB, ONB COURTHOUSB FOURTH FLOOR CARLISLE, PA 17013 (717)697-0371 ~ Darrell C, Dethlefs, Esquire By: DCD:tw - , LISA HIPPENSTEEL BOUGHTER, PLAIH'l'IFF IN THB COURT OF COHHON PLEAS : CUMBBRLAND COUH'l'Y, PBHNSYLVAHIA . . : RO.: VS. . . HICHABL P. BOUGHTBR, DBFENDANT : CIVIL ACTION - LAW - DIVORCB ACTION COMPLAINT IN DIVORCB UNDBR SBCTIOR 3301(c) OR SBCTION 3301(d) OF THB DIVORCB CODB AND NOW comes the above Plaintiff, Lisa Hippensteel Boughter, by her attorney, Darrell C, Dethlefs, Esquire, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Lisa Hippensteel Boughter, is an adult individual who resides at 932 Forrest Court, Carlisle, Pennsylvania 17013, 2, The Defendant, Michael p, Boughter, is an adult individual who resides at 2906 Chesterbrook Court, Apt 603, Camp Hill, Pennsylvania 17011, 3, The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint, 4. The Plaintiff and Defendant were married on August 28, 1993. 5, The Plaintiff and Defendant are both citizens of the United States of America, 6, There have been no prior actions in divorce between the parties, 7. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies, 8, Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 9, The causes of action and sections of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken, After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce, Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d), The marriage of the parties is irretrievably broken, The Plaintiff and Defendant separated on or about February 22, 1994. WHBRBFORB, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony, Respect By: \ Darrell C, D Bsquire Attorney ID': 58805 Wagner Building, Suite 205 355 North 21st Street Camp Hill, PA 17011 "....,...., . 'lIUU;I_:[~.A'J'_tQ~ I hereby verify that the statements of fact made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements therin are subject to the criminal penalties contianed in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities, L~ ~".-'~/ g'-9/zf;Z .~~ Hipp tee1 Boughte~ Date: r):;If:/ L (je( I (, PI)'; 1'\ '5'(( d /vf (tiltH' { j f! dau UA (.. v 13J-.LU A Ie r q~- /CiS4- C~( ( CERTIFICATE OF SERVICE AND NDW, thlS...l1 dllY of April, 1994, I do hereby certify thllt II true llnd correct copy of the foregoing Compl11lnt hils been served upon the following person by depositing the slime In the United Stlltes MIll1, flrst-clllSS, postllge pre-Pllld llnd llddressed liS follows: Hlchllel P. Boughter 2905 Chesterbrook Court Apt. 503 Cllmp Hili, PA 17011 ,.,-" -..... ., ...:,'\ OF DARRELL C. DETHLEFS ~ Dllte: By' Dllrrel1 C. Dethlefs, Esquire Attorney 10" 5B605 WllgnerBul1dlng, Suite 205 355 North 21 st Street Cllmp H11I, PA 17011 (717) 975-9446 . '''':^;-,'-''- !R ~ N' 0::> ":T - .r'" ....,- t: ;;. :~~: -. _ -'0.- .I '- <; '-',,..- ;~ ~': ,_..~ .~. <li1 ;..; . -. !~ <"') i:'~ ;~ ~:. g; """" ::;0 LISA HIPPENSTEEL DoUGHTER,: IN THE COURT OF Cot1t1oN PLEAS Plainttff CUt1DERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - LAW t1ICHAEL P. DoUGHTER, Defendant NO. 94-1954 ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Compllllnt In Dlverce ~derSectlon 330 Hc) of the Divorce Code WIlS filed on)~Prll 16, 1994. ;"/1 _ 2. The mllrrlllge of Pllllntlff and Defendlllt Is Irretrievllbly broken IInd ninety (90rdllys hllYS elllpsed from the dllte of fl11ng of the Compllllnl :. 3. I cmsent to the entry of II flnlll decree of divorce. ...u ,""" 4. I understand thllt If II cllllm for lI11mony, IIUmmy pendente lite, ITlIlrltal p~erty, counsel fees, or expenses hilS not been ftled With the Court befere the entry of II flnlll decree In dlverce, the right to cllllm IIny of them will be lost I verify thllt the stlltements mllde In this Affldllvlt lire true Ilnd correct. understand thllt flllse stlltements herein In ITlIlde subject to the penllltles of 16 PIl.C.5.A. Section 4904 rellltlng to unsworn flllslflclltlon to lIuthoritles. 3./7.176 Dllte' L By' L ~Iq oughter, Pllllnt ff ~ ... :i! !II ~ ....~ ~ t-;t:. ~t.,.~...t' -;c.... .,~- t\: o(j~ :.._ .t; (~~~::i .';'1 .'<~' 1"~ -JU') ._ ,- .r ..: \,o14J:"'~ u. ';r:~i~f_' ...Xu.. ..."" 0'-' ..... .... - - ,-- . .' <' ~;,; LISA HIPPENSTEEL BOUGHTER,: IN THE COURT OF COMMON PLEAS Platnt1ff CUMBERLAND COUNTY, PENNSYLVANIA Y. CIVIL ACTION - LAW NO. 94-1954 ACTION IN DIVORCE MICHAEL P. BOUGHTER, Defendant AFFIDAVIT OF CONSENT I. A Compllllnt In Divorce ~der Section 330 I (c) of the Divorce Code WIIS flied on-APril la, 1994. I " I 2. The marrIage of Plalntl ff and Defendllllt Is Irretrlevllbly broken IInd nInety (90) dlIys have elapsed from the date of ftllng of the Compllllnl _ , 3. I consent to the entry of a fl nal decree of dIvorce. ~ ~" 4.1 understllnd that If a claIm for alImony, alimony pendente lite, ITllIrltal property, counsel fees, or eHpenses hilS not been filed with the Court before the entry of a final decree In divorce, the right to claIm any of them w111 be lost I verify thllt the stlltements made In this Afftdavlt are true Ilnd correct. understllnd thllt false statements hereIn se rTllIde subject to the penaltIes of la PaC.5.A. Section 4904 relating to unsworn falsifIcation to authoritIes. Dllte' -'1m_cd ~ 119Y By ,. ~ - ;,.. "," ..[ J- &.Ii:- ,.r:.r ::>::): '.'- :....~t..;, :";.:-~:~ ." ...-.-, _.,1>. "' ,l.!l .:;:f;~ ;~i-':~ l4..;.,:) 0<'> =-:: --r " .... - - ~ a: ~ ,...,' .- )lJ ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . . / .CYJ . . /1rMsk(/ B()"9/'h~ P1ainti f . . . . I ?5Y c,'v.; I?fl/ . . File No. . . vs. . . IN DIVORCE : 7-1/-c-~d~ I ? 130<'''7;( Ie/C . Defendant . . . . . . NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the /3 day of '/. -/ ,19 f.5' , hereby elect to resume the prior surname <7 II,. t: S 1(" t' , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: y' . /1 r-~ [~..,~' ,'Y/ /~ L" / . ) ~,. ',-7 ,::::;> /-. /' '/)/"'(c.~ /I'( Signature / / i /t-.., .-'-:.t'.di/ g resumed ---.)./ / . ..-l"..'.~ // {Signature of name COMMONWEALTH OF PENNSYLVANIA: : S5. COUNTY OF CUMBERLAND : On the o/7~ day of !tic-I , 19 93:before me, a Notary Public, personally appe:r~(ttie above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. o set and official seal. NOlarlal 50al K8yo N. Fallor, Notary Public Dk:kInson Twp cumborland CounlY My comml.s1o';'ExplrosApriI23, 199B MentJe<. f'emSI'lv3r'.1 As:lOCialIOf1 ot NotaIlOS ~ IJ') 11. en ;... 0- - .r ... ::c ..~ ~ 2 ci , .' a.. 1.:1 ( N) (...:~ l(l ,., :::-j c::> ,... (b - '9J ':t. ::f.J - \I) ct - ~ - CJ ::i!