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HomeMy WebLinkAbout94-02191 ~I o 3 J i I JI .......... 0'- '- (Q $ w. ~.' ~ ~# S 8 $ ~ ~ ~ ~ ~ ~ ;<l ~ ---- :~:..>>:o . .:~. .:c.- .:+:. .:c. .:c. .:c. .:c- iJIt.' * ~ ... .:+:. .:+:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:<<0,:--4.:.:.:,.:<<.::-:.>:":.:'_ .:.,.. .:.:. <Co ...:.<Co':~~ ~ . - - ~ ~ " ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '*' PENNA. ~ ',' ~ s ~ ',' ~ ',' ~ ~ -:> LISA G. WOLFE ~ ,,. N ll. .",nn"""" ",,<7.~,~,~,~ 1994 ;i ',' ., ,', ~ V(,I'~lI~ ~ ,,. EDWARD E. WOLFE ~ ',' ~ " W ',' ~ ~ '.' DECREE IN DIVORCE ~~ ~ ,; W. ... AND NOW".". ';!\A.he- 12...".".,." 19.1'", it is ordered and decreed that",,,,,,, ,~;t::;A ,G" ,WOLf E.",."...""...,.,."" plaintiff. and,.."""",.". ,~!'~~~J? ".'. .~9.L.F:E..".."..,...""".., defendant, are divorced from the bonds of matrimony. $ ~ .,' ,;, <:' 8 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; ~~~. ~,,!~I;~. ,~~",P. .~~~~.~~. ~,O.f)~ ~!l.u,~~9. j,lp;~!3,d.~c;:t.i.~~, !>)I,E\~, tr,E\ ,P!'lF,t).~S ,~~~, ,t.~~. :;.u.~~~~.t ,~~~.t.~~. I?f. . ~~~. .~~~~.t,~~, :>,e,~~~~.ll!~~~, ,~!1I;~~,ll!~I)~.,. , , , dated May 24. 1996. for the purpose of enforcement of any of the ny The W~ I( O/? ! Attest:fl ~,,~,~ ['O:~(fl~;~ 4?/~ ,t-"..J::j;{.. ,)..,~ .1 . ~,lprolhonolnry - ,.- ~ **~..~.**~*.~.~~.~~.****~*** 8 ~ 8 ~ '" 8 8 8 ~ ~. ~ ~ ." ~ ~ ~ 8 ~ ~~ ,;, <:' ~ .. ~ 3 .:. ~ ~ ~.~ .', ~ ." ~ w ,,. ~ $ ~ I~ ~ ':' I !I. ,.. ~ ,'. i~ !~ .. ~ 1"- J~ ,.. ~ '~ ~ ( I,', ;~ ~~ .- "'13~~ ~'0/7,,!,:JV.p.aj /~ 61.Jft; /.?~ /~a~ zj, ~ ~J~ .' . r ~ I MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this J. 'IE day of /YI'() (hereinafter called "Wife") , 1996, by and between LISA G. WOLFE, and EDWARD E. WOLFE, (hereinafter called "Husband"). WIT N E SSE T H: WHEREAS, the parties hereto are Husband and Wife, having been married on April 26, 1986 at New Cumberland, Cumberland county, Pennsylvania, and are the parents of one children, namely HARRISON DYLAN WOLFE, born June 14, 1988; and WHEREAS, difficulties have arisen between the parties as a result of which they now desire to live separate and apart and by this Agreement to settle all financial and property rights between them; and WHEREAS, in preparing this Agreement and negotiations contemporaneously therewith, Wife was represented by Debra K. Wallet, Esquire, and Husband was represented by R. Mark Thomas, Esquire, each of whom are satisfied with the terms of this Agreement, a full explanation of the same having been made to their respective clients; and WHEREAS, Husband and Wife respectfully acknowledge that before signing this Agreement they have been fully advised by their respective counsel of their rights and obligations, have read carefully and understand the terms of this Agreement, and have " '. . freely consented to this Agreement, believing it to be fair, just and equitable; and WHEREAS, Husband and Wife are satisfied that they understand the value and extent of all property which would be considered "marital property" under the Pennsylvania Divorce Reform Act, whether titled or owned separately or jointly as well as the value and extent of nonmarital property held or expected to be held by each other; and NOW, THEREFORE, in consideration of the mutual promises and undertakings set forth herein and intending to be legally bound hereby, the parties hereto do agree as follows: 1. MUTUAL SEPARATION - Husband and Wife shall be free from constraint or control by the other as fully as if he or she were unmarried. Neither shall disturb, trouble and interfere in any way with the other or with any person for associating with the other. 2. MUTUAL RELEASE Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does remise, release, quit claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, admitted or suffered to 2 .. :. '. , , . be done by said other party prior to and including the date hereof; further, the parties acknowledge that all rights under the Pennsylvania Divorce Code that are not specifically incorporated herein are hereby expressly waived. 3. DIVORCE - Wife filed a Complaint in Divorce on April 26, 1994, in the Cumberland County Court of Common Pleas, which is indexed at No. 94-2191 civil Term. Husband and Wife agree that contemporaneously with the execution of this Agreement, they will each execute an Affidavit of Consent to the entry of a final divorce decree in this case. 4. EFFECT OF DIVORCE DECREE - This Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 5. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE - The terms of this Agreement shall be incorporated into any divorce decree which may be entered with respect to the parties. The Court of Common Pleas, which may enter such divorce decree, shall retain continuing jurisdiction over the parties and the subject matter of the Agreement for the purpose of enforcement of any of the provisions thereof. 6. DATE OF EXECUTION - The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution 3 ..... .'. . date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7. PERSONAL PROPERTY - The parties have physically divided and distributed their household goods and other tangible personal property. They mutually agree that each shall hereafter be the sole and separate owner of all such personalty now in their respective possessions free and clear of all rights, claims and interests of the other party. This agreement shall constitute a bill of sale by and from each party to the other to document the individual full ownerships by each party of the personalty now in their respective possessions. 8. MARITAL RESIDENCE - Husband and Wife are not the owners of any real property and, therefore, there is no marital property in the form of real property to be divided between the parties. 9. DEBTS - During the course of the marriage, and following the date of separation of the parties, Husband and Wife have incurred certain bills and obligations and have amassed a variety of debts. It is hereby agreed, without the necessity of ascertaining for what purpose and to whose use each of the bills was incurred, that each party hereto shall be solely responsible for all bills, obligations and debts that they have acquired in their own name since the date of separation on June 23, 1993. Each party agrees to hold the other free and harmless from any and all liability which may arise as a result of debts incurred since the date of separation, and agrees to indemnify and defend the other 4 -""'--""'-+' ), '. . from any claim regarding such debts. Both parties agree that, in the future, neither shall cause or permit to be charged to or against the other any purchase or purchases which either may hereafter make and shall not hereafter create any engagements, debts or obligations in the name of or against each other. with regard to debts incurred by either or both of the parties prior to the date of separation, it is hereby agreed that those debts will be paid as follows: a. Wife will assume the CoreStates loan currently in her name alone with an estimated payoff of $3,600.00. b. Husband will assume responsibility to pay the Discover and Sears cards currently in his name alone, with an estimated liability of $600.00 on each card. c. within sixty (60) days of the signing of this Agreement, Husband agrees to refinance the Security Pacific loan currently in joint names and be fully responsible for the refinanced loan which has an approximate balance of $2,000.00. If either party fails to pay in the entirety, the loans as agreed to herein, each party hereby promises to indemnify the other party for any payments which the other party may be required to make on loans assumed by the other. 10. ALIMONY - This Agreement does not provide for the payment of alimony to either party. Each party hereby acknowledges that he/she will not receive any alimony pursuant to this Agreement and hereby agrees not to seek any alimony or additional spousal support 5 ~ " ). ., . . in any form whatsoever from the other as of the date of the execution of this Agreement. 11. ENFORCEMENT - If either party defaults in the due performance of any of the terms, conditions and covenants of this Agreement on his or her part to be performed, the non-defaulting party shall have the right to sue for specific performance or damages for the breach of this Agreement, and the defaulting party shall pay the reasonable legal fees for any services rendered by the non-defaulting party's attorney in any action or proceeding to compel the defaulting party's due performance hereunder as well as costs for bringing the action or proceeding. 12. EXECUTION OF DOCUMENTS - The parties agree to execute all documents, including but not limited to, deeds of title that are reasonably necessary to effectuate the purpose of this Agreement. In the event that either party shall refuse or fail to execute and/or acknowledge any such document, then the other party shall have, and is hereby granted, the right and power to appoint one or more times any person or persons of his or her choosing as attorney-in-fact for the other party to so execute and acknowledge such documents. 13. CONTRACT INTERPRETATION For purposes of contract interpretation and for the purpose of resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly by their respective attorneys. 6 ;. " . 14. AFTER-ACOUIRED PROPERTY - Each of the parties shall hereafter 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 acquired by him or her after execution of this Agreement, 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. 15. CUSTODY AND SUPPORT - Husband and Wife will have joint legal custody of the child, Harrison Dylan, who has a date of birth of June 14, 1988. Wife shall have primary physical custody, and the parties agree that the Husband will be granted liberal periods of partial custody. It is further agreed that, at a minimum, the Husband will pick up the child at the baby sitter's location and keep the child for two to three nights per week. On those occasions when Husband has the child during the week, he is responsible for getting the child to the school bus the next morning. Husband shall have the child for a minimum of one week during the summer months. All holidays will be split evenly between Husband and Wife and each holiday will be shared unless otherwise agreed. Mother's Day and Father's Day will be spent with the parent whose day is being celebrated. Husband shall pay the sum of $80.00 per week in child support or such other amount as shall be determined by the Court based upon changed circumstances. Husband will provide health care coverage 7 , ,.: . for the child. The parties will share equally all uncovered medical expenses. It is hereby expressly agreed that Wife, who has primary physical custody of the child, will be entitled to the tax exemption for the child each taxable year. Both parties agree to provide college educational expenses for the child to the extent that they are financially able to do so. 16. INSURANCE - Each party will keep in place all current life insurance for the benefit of the minor child until Harrison Dylan is no longer in need of support or college educational expenses. Wife will maintain the life insurance obtained through her employment, namely one policy in the amount of two times her annual salary and a second policy in the amount of $50,000. As of the execution of this Agreement, she has no other life insurance. Husband will maintain the current Group Life insurance which is in the amount of $65,000.00. He has no other life insurance. 17. LEGAL FEES - Each party will pay his or her own legal fees for the obtaining of this divorce and Property Settlement Agreement. 18. WAIVER - Any claims not specifically referred to in this Agreement are hereby waived. 8 ...-x :-. . .: . 19. MISCELLANEOUS A. This Agreement constitutes the entire agreement between the parties, being the final and complete settlement of all matters between them and supersedes any prior written or oral agreements between them respecting the within subject matter. There are no representations, agreements, arrangements or understandings, oral or written, between and among the parties hereto relating to the subject matter of this Agreement which are not fully expressed herein. B. This Agreement may not be amended, modified, altered or revoked except in writing executed by both the parties hereto. C. This Agreement may not be assigned by either party without the prior written consent of the other party. D. This Agreement may be executed in multiple counterparts, each of which shall be deemed an original for all purposes, and all of which together shall constitute one and the same instrument. E. This Agreement shall be binding upon the parties hereto, their heirs, executors, administrators and assigns. F. This Agreement shall be interpreted under the laws of the Commonwealth of Pennsylvania. G. The failure to strictly enforce any part of this Agreement shall not be deemed a waiver of any other part of this Agreement. 9 ~~_~ ~- r " .\ H. Titles are for convenience and ease of reference only and are not to be considered part of the Agreement for purposes of interpretation. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. ...rllkta. JL.. w....r WITNESS ~.~. LISA G. WOLF ~~~~ tdu'wtf I' 1..1- EDWARD E. WOLFE ;;1 WITNESS 10 ~ .3' ~ .. ~; .::1 13~ ..,.. '-)~ a:: ,1~ r- ".~ w..... I :"12: --'u - 'Z CC,. =: 'l,Q f-~ : '.,Cl.. U. \.0 :'5 (,1 a. U I . IN TIlE COC'RT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2191 CIVIL 19 94 LISA G. WOLFE, Plaintiff vs. EDWARD E. WOLFE, 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: .3JO/ irretrievable breakdown under Section (~(c)) 1. Ground for divorce: ~ ~~ (1) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: Aori 1 30 1994 via Certified/Restricted Delivery J. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by Section .33,,/ -r&l-(c) of the Divorce Code: by the plaintiff May 15. 1996 . . by defendant May 24, 1996 (b) (1) Date of execution of the plaintiff's affidavit required by .330/ Section Z81(J) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None. Marital Settlement Aqreement dated May 24, 1996. (Attached) 5. Indicate date and manner of service of the notice of intention to file ..3..3D1 of said notice under section~ praecipe to transmit record, and attach a copy (d)(l)(i) of the Divorce Code. Plaintiff's Waiver signed May 15, 1996 - ------. and Defendant's Waiver signed May 24, 1996. (),(\,.l ~,.~ Debra K. Wallet Attorney for (Plaintiff) ~llR9oof~ ~ ~ r I~ .. ~1i ..:z J.. :c 0 r- 0- ~~ C. r- " a: '., u. I ..~ UJ ~ ;::1 FE :':3 ...., ll. lD ::; 0 C'" U . ~ ~ ;:- !~ .. ~~i ..::r ~) ~. :c 'J 0 fE 0- )~ C. r- '~1li 0: 'z c.. I "1:5 o::UJ -~ "~ :5 fE ...., ~'.; a.. ~ u:;) ::; c"' u . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA G. WOLFE, Plaintiff 04-- dll'Jl No. -- 7 ~ v. EDWARD E. WOLFE, Defendant IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 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. Court Administrator Cumberland County Courthouse 4th Floor 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717)240-6200 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LISA G. WOLFE, . . Plaintiff . Ciu..:J I.Lt._ . q".)/'ll . No. . v. . . . IN DIVORCE . BOWARD E. WOLFE, . . Defendant . . DIVORCE COMPLAINT 1. The Plaintiff is LISA G. WOLFE, who currently resides in Cumberland County, with an address of 220 N. Second Street, Wormleysburg, Pennsylvania. 2. The Defendant is EDWARD E. WOLFE, who currently resides in Cumberland County, with an address of l316A Mallard Drive, Camp Hill, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 26, 1986 in New Cumberland, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provision of the Divorce Code, Section 3301(c), in that the marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counselling and of the Plaintiff's right to request that the . Court require the parties to participate in counselling and does not request same. 8. Defendant is not a member of the armed services. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. Respectfully submitted, \.-O.c1J\ A.. -It. w tU.W- Debra K. Wallet, Esq. 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-1300 I.D. 1123989 Attorney for Plaintiff Date: .., "If 19., ,.'nIt&l,?,~......., . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LISA G. WOLFE, Plaintiff v. No. EDWARD E. WOLFE, Defendant IN DIVORCE VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. c.~. Section 4904, relating to unsworn falsification to ties. 1) Q /Lx.e..J2-.-S d',(;i ,{), LUxth LISA G. W FE Date: Joj J Ill, /qt/ ..".. en - ~ \ ' \.() R r'\) .............. 10 'ZJ ~ --- \<j r:J \ ...r; - ~"... _r.-. ;!C t-" _ l.i,..;...,'''f CD r.:: ..1:;-:.; ::I' 1......-,. .-.\ :~ ,:... '? ~. N \..~J d* ... ~ '1 ...,... ~ cl~} ~ "" <--J "" "- ~'" .." ~ -iit ~ ~ 4 - -- ('J'\ 1'\'") ~ . :::: .., .,.j J ~~~ .., ~ ~ "'" Iail = p,. 2l ..:l!;j'" "0'- ..:. UJ !:: in ] <A:< 8 ~"'ll.w::l . ii ~ .(I).Jz,.t > i :-:"Cl...lo'" fll' " :z:.... ~ ~<::;:=...;::- ~ ~=:i~ ~ ~[) . . II:! Iail~< CJ ! Q u Z H ~ H ~ . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LISA G. WOLFE, . . Plaintiff I . . v. . NO: 2191 CIVIL 1994 . . . EDWARD E. WOLFE, . IN DIVORCE . Defendant . . AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Debra K. Wallet, being duly sworn according to law, deposes and says that she is the attorney for Plaintiff, LISA G. WOLFE and that she did mail a true and correct copy of the Complaint in divorce in the above matter, by certified mail, return receipt requested, to the Defendant, Edward E. Wolfe on April 28, 1994, at his last known address: 1316A Mallard Drive, Camp Bill, PA 17011, which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403. The signed receipt acknowledging receipt on April 30, 1994 is attached hereto as Exhibit "A". \0.......... -it. ""~ Debra K. Wallet, Esquire Sworn to and subscribed before me this~ day of ?/ f::;; ._ , 1994 --;;:; /, ;J/:tI 4A r,L~.L/ / IIOU.,!: I "'.' ---'r K^TrW:^ K. ',':.\r; f~:','~Y r I Carli~lt' 0 Jr,:, c. T~:: r i . T' j (.' I: .~... ;'1 My Cornml~:'lcll Fxpir(o: :':t.'r:, l-i, 191/.1 , --.---. . ---I ,no > , ....,_:.. : "J".~_'ond/OIZf."ddl_-" I allo wllh '0 lOcal"" tha I' ",' 1;",~ _ 3, and h . b. :.:;..- lollowlll\l 10",lc," "Of on .xua .:".:::<'f.""" 'fOW nIlM...s",,1t on \hi ftVtf" ot tN. tom\ 110 that we ten ,..): ).' ~'lotIim ..... cord 10 you, rl~~.::.:'" 10'" _ .1 ... -, or on'" ....k 'I ..... 1. 0 AddlO._'. Add,... F" ~)y...._R"""_otIlI.. on 11>0 ","""",,,-.....-- 2. gg RoaU\Cle<l DlUv..., . io:.'I1!O_..-,.....poO'Moyou1l>O.,1I1I.tllf..'...- ..j . <, _.. _ .1 ' Conlult ItRllI'or lorl... ' '"., l:; 'i Ai\IdtI Addfouod to: "'a. Artlcla Number ., )' ;1\'5Mi-. Edward E. Wolfe P 327 944 548 .,;", . ,'" .1,*,':,1316A Mallard Drive <lb. S.",lc. Typa 0 'A'U-~ ,,>, '!ij ,t;::cainp Hill PA 17011 0 RogIalarad .- "'" :.:;~ ~:ti\~ ' " ~ Cortlflad 0 COD ,:;'j~. f;~it.: " 0 ExplOlI Mall 0 RttUm RacoIpt f",j.'i~'.. f ,.,. ".;~ (~;,-,. , . .UA.GPO:,IIf-ZlT- DOM!8TIC RETURN RI~\r~' .-' ... :.-~-..-~.-'::~;-::H-.'~X.;~,:.~. . __" .w_,_.....;..-~""....__.".-=.-,.-_.--'-r'..",-~._.~-""- P 327 ~44 548 .. . , RECEIPT FOR CERTIFIED MAIL . "'" hO I~SURANCl COvrRAGE PRO~ID!D ." NOT fOR lNTEIi"ATtONAl MAil I . ' ft (See !1fillerS6J :lI 1_ j ~ Senllo r. Edward E. Wolfe . .'i ! f'TLnN'Mallard 1'"-' '" .. Drive t, . 0 ',' ...; 0: Co. Slale d~ ZIP Code .. d , ,; am H~ll, PA 17011 '.. '" Pos1age S Ceftllted Fee .29 1.00 S~lal Delivery Fee ReSlrl(lcd Deliverv Fee 2.50 1.00 Relu'" ReceIpt shOWing '" 10 whQln and D.lte o..liv{'I{.>d = Return R(.>(e 1 _ Date and ,,~~ ShOw,ng 10 whom ! '(>$5 01 Oellvery .:j TOTAL PosI.lge and Fe".. I Puslmdrk. Of OJI~ l 4128/94 ~ s 4.79 ~ ~ ~ .. ;J~ ...:z I~ - ',J a: .~~ G r- >$ fIe: c.. I 'J~ ~_' 7- '~l ~ :"..l r= -~ ~'E ~ \0 ::J a, U ~- .. .- -- ,. - .tall" l?fi;'~.r e/ DEBRA K. WALLET , ," 24 N. 32nd Street Camp Hill, PA 11\111 Telephone (117) 7J7.IJOO CERTIFIED COPY ATTORNEY FOR I verify that the statements made in this Affidavit are true and correct. I understand diat false statements herein are made subject to the penaltip.s of 18 Pa. C. S. ~4904 relating to unsworn falsification to authorities, Date: ~-\'S -Cjlo ~.~ i /ftL USA WOLFE , ; .,' .., ,;l ,', J '(1' ,~ " . . .l C".' i :. ~ " l. t., " t" ('.l/ I'" . ." ,~ ',~ ." ..'; .~ II .~ ;- ~ 4' ~ - ,- If .. :i~ ..:r :t: c... > .)~ 0 ,..... .~~ fi I lU S i5 ,a -, .'" & U) ;J 0"1 -<<i(~ l?#<<.r fY DEBRA K. WALLET 24 N. 3lrxl Stm:1 Camp Hill. PA"I7U1I .. Teleph"ne (711) 737.1300 CERTIFIED COPY . , ... ATTORNEY FOR CUMBERLAND COUNTY. PENNSYLVANIA LISA G. WOLFE. Plaintiff v. NO: 2191 CIVIL 1994 EDWARD E, WOLFE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER II 330ICc) OF THE DIVORCE CODE ; 1. I: cons.ent to the entry of a final decree of divorce without notice, .- 2. I understand that I may lose rights concerning alimony, division of property. lawyer's fees 'or expenses if I do not claim them before a divorce is granted. f 3, I understand that I will not be divorced until a divorce decree is entered by the Court and, that a copy of the decree will be sent to me immediately after it is filed with the prothonotiuy . 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. ~ 4904 relating to unsworn falsification to authorities. Date: ()~ -K. q (, ~. tJ.)6If LISA G, WOLFE Sworn to and subscribed before me this I S day of /T/4(j-' 1996. ~I',J, 'iJ:; a, WI.. 1":' 7J Notary Public W-. : to,QUI14. t. W4.l.Ut. NO~.l f,fPl .IJJDt A. Ill.'ii:':'.-r: !J.::3ry P.';;lic l:a,tIII.1lDro. Cu:~io::;1 Wootf My t .d..... &pits Mer 10, 1999 ! ~ >- - t-- 7' - '3~ li .:r .,... 0: II r- '7 I ~ o:Ui :;r:: ~tJ ~ => ' C) u.. .., ;~ ~ \D a '" '. '. .1/w l?#~w l{/ DEBRA K. WALLET 24 N. 3200 SU<<I Camp Hill, PA 11011 Telephone (717) 737~ ~OO CERTIFIED COPY . , ATTORNEY FOR -. LISA G. WOLFE, plaintif f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-2191 CIVIL TERM ED~IARD E. WOLFE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (cl 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.. 1'consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. ['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. S 4904 relating to unsworn fa~slfication to authorities. . . r' , Date: :)v J <./ ..<:j fc:. (ii., ",4 It. rg - ~ oS ~ - L. ." -';:1; f ..:z o~ :c (J 0- )1 ~ r- . , .'1 1 ,'- ~- .:1 ~ ,n F ~. .... u- .0 ::J q ~ CJ . -. , , . ' '. . . .{tw lpjf~~.r W DEBRA K. WALLET 24 N. 320d S".., Camp Hill. PA 17tJh Telephune (717) 737.1300 . , . . . pERTIFIED COPY - . ATTORNEY FOR '- . LISA G. \'lOLFE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-2191 CIVIL TERM EDWARD E. WOLFE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a decree is granted. :3. :~ understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will b~.-'sent to me. immediately after it is filed with the prothonotary. , I understand that the statements made in this affidavit are brue and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unSworij falsification to authorities. Date: '5-,:}/..{ .eJL {!I;A.(Ud ! I. h;k ;J i ~ ?:; - f .. 5i ..:z i::J - .J - 0.- ~l .,. '-' r- ~;'" ~ , T - ..... lIJ _.. " F ~ ,":) ..-, ~ ~ \D a 0' . . . -, '.. .