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HomeMy WebLinkAbout94-05458 " v g-" ~ . If} 7 " ~ j 00 \.() -:t- tD , a= .:+:. ,:.;. .:.;. .;+; .:+;.:.;. .:.:. -:.:. -:.: <+;-.+: -:+:- -:.;. :.;. .'.;' :.; :.;. :.;. .:+;. .;.;. .:.;. .:.;. .:.;. .:.:. ':c- ',4 . "- -._--~." l~ I~ I, THE COURT OF COMMON PLEAS :~ ~ .:+:. .:.:- .:+;. .;+; ~ ~ :~ ~; ~ IN , ~~ I ~:' , I ~' , , , i ~\ OF CUMBERLAND COUNTY STATE OF ;~~. PENNA. ~ ~ ~ Edward E. Page, Jr., Plaintiff ~ \'1'l'.~lh ~ ~ Eileen B. Page, Defendant ~ ~~ 'I ~ ...' ~i , ) ~~ ~I' *1 M( ~I ~l "I ~I ~ :\ II. 94~545B .dd It) DECREE IN DIVORCE AN 0 NOW,. ... M t rc..~ .l.(p, , . , ., 19 'is' '. it is ordered ond . , . , , , , . , . , , , '. plaintiff, . . , . , ., ' , ", defendant, decreed that, ,Edward,E.Pag6!,Jr.,.,. and, Eileen, B. Page" , . ore divorced from the bonds of matrimony. ~ * The court retains jurisdiction of the following daims which have been raised of record in this action for which a final order has not yet been entered; ~ ~ .? ~ ~ ,;, ':'l ~ ~ I~ ~ ~ ~ ~ ~ " I~ 'M ! .' !~ I~ r' I' ;,~ ! . '~ '.~ . , ';~ ; . ;~ I.., i~ :~ I,', )~ ~ ~ tili:; D.ivorce. De.cree. T)leProperty Settlement Agreement dilted Jilnllilry ,41, .\995" is, lncorpI,Jrat'i!d jn ~ ~ ~ ~ ~ ~ ~I ~l ", ~) 7/ f .~;. .~, Ii v T"., C" u).r I ,r I/' I ':""J:~~~~~..t:7.> J , _> ., y" " ' P. { . "<'ji- z: ,,/ /l'r..thollol"ry ~ ~ ~ ~ ~ ~ $ .. ". . ., :.: :.; :.: :.: :.. .~: ..: :t' :"": :.: <.; -:.::.:. .:.: -:.: ~ ,,< II, <;'r '-..... If.' .) c:' I di,} ~ )k"ti", i't.'e~\ _~~ .'/' (.~ I~" l n '''_~ ,<)," '" ,/ / . {:'~., ~ " ~, T'-/-V<,,'''''-'} 3/L-'f<; Il't-h([~ ~ '.5. .(i.d.-., " ~ .j '. ! l~ !' . , i .. 11 ......4 - -- PROPBllTY SB'l'TLBHBNT AGlU!EKBN'l' ! ~ q " THIS AGRBBHEN'l', lIade tbis ?}~I\ day oddll.ll.tl/f' 1995, is by and between: EDWARD H. PAGH, JR., of 704 Alberta Avenue, Hecbanicsburg, Pennsylvania, party of :1 i ithe first part, hereinafter referred to as "Husband"; and I I HILHEN B. PAGB, of 717 Market Street, #409. Le~oyne, Pennsylvania, party of tbe "second part, hereinafter referred to as "Wite." Ii I WITNBSSBTH: I I WHBRBAS, the parties hereto are husband and wife, having been married on 16 August 1:1977 and are the natural parents of one minor child: Edward E. Page, III, born 7 'I " I:January 1990 (hereinafter referred to as "child"); and ,; I; WHERBAS, certain difficulties have arisen between the parties hereto which have " I:llade them desirous of living separate and apart from one another and Husband has filed " :,an action in divorce against wife which is now pending to No. 94-5458 civil Term before , the Court of Co.-on Pleas of Cumberland county, Pennsylvania; and WHBRBAS, the parties hereto, Wife being represented by Samuel L. Andes, Esquire, , and Husband by William Charles Vohs, Esquire, have each exchanged full and complete information as to the property, assets, and liabilities owned and owed by each and have disclosed to each other and to their respective attorneys full information as to the financial status of both parties hereto; and WHBRBAS, the parties hereto have mutually entered into an agreement for the division of their assets, the provision for the liabilities they owe, and provision for the resolution of their mutual differences. after both parties have had full and ample opportunity to consult with tbeir respective attorneys, and the parties now wish to have that agreement reduced to writing. NOW, TIIKREFORE, the parties hereto. in consideration of the above recitals, the mutually made and to be kept promises set forth hereinafter, and for other good and 1 -.., " valuable considerations, and intending to be legally bound and to legally bind their ,heirs. successors, assigns, and personal representatives, do hereby covenant. promise. , and agree as follows: 1. The parties have resolved. at least on a temporary basis, their plans for the legal and physical custody of their child and those matters are part of a separate 'i 'agreement and will not be addressed further in this agreement. Each of the parties ilreserves unto themselves all of their rights relative to the care and custody of their 'iChild. , , 2. The parties will resolve any claim for child support or the other financial 'contribution to the present support of their minor child outside of this agreement. 'Each of the parties reserves unto themselves all of their rights, remedies and defenses relative to any claim for the financial support of their minor child. 3. Husband and Wife mutually represent that their child may and probably will incur substantial medical, hospital. dental, orthodonture. or related expenses during the time that he is dependent upon the parties hereto for support. Both parties hereto agree to contribute. in proportion to their financial ability to do so at the time of such medical or related treatment. to the direct costs of such treatment. beyond that paid by insurance coverage then in effect. 4. Husband and Wife mutually represent that their child may wish and desire formal education beyond normal high school completion. Both parties hereto agree to contribute, in proportion to their incomes at the lim~ of such formal education, to the direct costs, including but not limited to, tuition, room and board or other living expenses. and books of the child incurred in the college or other legitimate formal education following high school. 5. The parties qereto mutually covenant and agree that the real estate they own jointly, as tenants by the entireties, and being known and numbered as 704 Alberta Avenue. Mechanicsburg, Pennsylvania, shall be sold for the highest obtainable fair 2 .-" /'"' , market price therefor. To effectuate such sale, the parties hereto covenant and Dgree that they shall, within after the date of this Agreement, list said property for sale "with a realtor selected by their mutual agreement and agree to pay a reasonable and fair market co~ission for such realtor's services and will, further, cooperate to the .'fullest extent possible with such realtor and his agents, or any other persons viewing , " ;,or visiting the property for the purposes of showing it for sale so as to effectuate ~ ! :the sale of the property promptly at the highest reasonably obtainable market price. I :The parties agree that the proceeds of the sale of said real estate, after the payment , , lof the expenses of said sale. to include a reasonable realtor's commission. shall be ',applied to pay the mortgage on the property and to pay any and all other liens or Ilencumbrances of record so as to give and deliver a good and marketable title at the ;i time of settlement. The net proceeds of sale of such settlement after the payment of 'ithe expenses of the sale and of all liens and encumbrances on said property, shall be divided equally between the parties. Until such time as the property is sold, Husband , shall have the right to occupy and live in the said residence, without any obligation ,to pay rent, and Husband shall pay the mortgage, utilities, real estate taxes. and other charges and expenses relating to the house until such time as it is sold and settlement is held on such sale. 6. Husband does hereby grant, convey, transfer, assign, and deliver and set-over unto Wife the following assets, which said assets shall be and remain the sole and separate property of Wife hereafter, free of any claim by or interest of Husband, regardless of whether such assets were deemed by either of the parties to be marital property or non-marital property before: A. Wife's tax deferred savings plan with her former employer, IBH, and any and all nonies withdrawn from said account. B. Wife's savings account with the IBH Pennsylvania Employes' Federal Credit Union. having a balance ot approximately $3,000.00. 3 .-, --- I: II II 'I !I c. Any and all severance payor salary continuation payments received I' II by Wife from IBH. D. wife's account with the Hid-America federal Credit Union, having a ,I balance of approximately 8400.00. E. Wife's account in and benefits from the IBM retirement or pension 'I II Ii liAnd further, Husband does hereby waive, release, relinquish, and surrender forever any Iland all claim to or interest in said assets, which shall be and remain the sole and I :;separate property of Wife hereafter. system. 1. Wife does hereby grant, convey, transfer, anslgn, and deliver and set-over ,I ,unto Husband the fallowing assets, which said assets shall be and remain the sole and separate property of Husband hereafter. free of any claim by or interest of Wife, ':regardless of whether such assets were deemed by either of the parties to be marital property or non-marital property before: A. Husband's pension benefits with the Commonwealth of Pennsylvania. B. Husband's account with the Pennsylvania State Employes' Credit Union. C. Husband's 1949 antique Ford truck. And further, Wife does hereby waive, release, relinquish, and surrender forever any and all claim to or interest in said assots, which nhall be and remain the sole and separate property of Husband hereafter. S. Husband shall, at the time the residence is sold and the parties divide and distribute the proceeds of that sale, pay to Wife, from his separate funds, the sum of Five Thousand 185,000.00) Dollars, as part 01 the equitable distribution and division of the parties' marital property. 9. Tbe parties herelo mutually agree lhat they have effected a satisfactory di v Ision of the furni ture. hour'I'hold llll'nluhings. appliances. and other household and -I I 'personal property between them and they mutually agree that each party shall, from and ! :iafter the date hereof, be the sole and separate owner of all such tangible personal . i " ;property presently in his or her possession, whether said property was heretofore owned ;1 ::jointlY or individually by the parties hereto, and this agreement shall have the effect tlOf an assignment or receipt from each party to the other for such property as may be in I the individual possessions of each of the parties hereto, the effective date of said I bill of sale to be contemporaneous with the date of the execution of this Agreement. I 10. The parties acknowledge that they are aware of the income, education, income 'I llpotential, and assets and holdings of the other or have had full and ample opportunity , lito become familiar with such items. Both parties acknowledge that they are able to , ,!support and maintain themselves comfortably, without contribution from the other except lias expressly provided for in this Property Settlement Agreement, upon the income and Ilassets owned by each of them. The parties hereby accept the mutual covenants and terms of this Agreement and the benefits and properties passed to them hereunder in lieu of any and all rights to support or alimony for themself, counsel fees, and alimony ,:pendente lite at this time and during any and all further or future actions of divorce brought by either of the parties hereto and the parties do hereby remise, release, quit claim, and relinquish forever any and all of their said rigbts to support for tbemself, : counsel fees, alimony, and alimony pendente lite during the pendency of or as a result of any such actions, as provided by tbe Divorce Code of Pennsylvania or any other applicable statute, at this time and at any time in the future. 11. Except as berein otherwise provided, each party hereto may dispose cf his or her property in any way, and each party hereby expressly waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any 1urisdiction, to share in the property or the estate of the other as a result of tbe marital relationship, including, without limitation. the right to equitable division of marital property, alimony, alimony pendente lite, and counsel 5 .. .." -' . . , . . .-.., , fees, except as provided for otherwise in thLs Agreement, dower, courtesy, statutory "allowance, widow's allowance, right to take in intestacy, right to take against the ',will of the other, and right to act as adminLstrator 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 I' , waiver and relinquishment of all such interests, rights, and claims. ii 'I , , 12. Husband releases his inchoate intestate rights in the estate of Wife and Wife Ilreleases her inchoate intestate rights in the estate of Husband, and each of the ,!parties hereto by these presents for hLmself or herself, his or her heirs, executors, , !,administrators, or assigns, does remise, release, quit claim, and forever discharge the I, ';other party hereto, his or her heirs, executors, administrators, or assigns, or any of !i I!them, of any and all claims, demands. damages, actions, causes of action or suits of Illaw or in equity, of whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to be done by such other party prior to the date hereof; except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this agreement and shall in no way affect any cause of action in absolute divorce which either party may have against the otber. 13. The parties hereto mutually represent to the other that neither of them bas incurred any debts in the name of the other not previously disclosed or provided for in this agreement. Each of the parties hereby represents to the otber that neither one of them has incurred or contracted for debts in the name of the other or for which the other is or would be legally liable from and after tbe date of the parties' separation. 80th parties hereto mutually agree and promise that neither will contract or otberwis~ incur debta in the other's or joint names without the prior permission and consent of tho other party herelo. 80th parties hereto represent and warrant to the other party 6 ,""' II I,that they have not so contracted any debts unbeknownst to the other up to the time and " " i Idate of this Agreement. I: 14. The parties acknowledge that this agreement is made in contemplation of the conclusion by both of them of an action in divorce which has been filed or will be ;Ifiled shortly by one of the parties h~. Both of the parties hereto agree that they i! f../3P 13 r",b,..ual'lIl'/<l~ lishall, on or before-iT-Betemeerl199l, execute and deliver to their respective attorney Ilor attorneys, an affidavit of consent under Section 3301(c) of the Divorce Code, Iconsenting to the entry of a final decree in divorce. Both parties agree that they ishall accept the terms and provisions of this agreement in full satisfaction of any Iclaims they may have under the Divorce Code of the Commonwealth of Pennsylvania, , I ;including, but not limited to, alimony, alimony pendente lite, counsel fees, equitable Idistribution, and the like. , , II 15. In the event that any of the provisions of this agreement are breached or I violated by either of the parties, the other party shall be entitled to enforce this agreement by an appropriate action in law or in equity or to take any other action to i'which they are l~wfully entitled to enforce this agreement or otherwise protect their rights. In the event that such action is commenced by one of the parties and the other party is found to have breached or violated any of the terms and provisions of this ;'agreement, the party having so violated or breached the agreement, shall be responsible , for and shall promptly pay upon demand the reasonable attorney's fees incurred by the other party to enforce their rights hereunder. 16. This Agreement shall be interpreted and construed in accordance with the laws of the Commonwealth of Pennsylvania. 17. If for any reason whatsoever any part of this Agreement shall be declared void or invalid, only such part shall be deemed void and in all other respects this Agreement shall remain valid and fully enforceable. 7 '..... r-, 18. The waiver ot any term, condition, clause, or provision ot this Agreement ,shall in no way be deemed or considered a waiver ot any other term, condition, clause or provision ot this Agreement. IN WITNESS WHEREOP, the parties hereto have set their hands and seals the day and I I,year first above written. I 1,,~fI&!tI , !I'l<!.!.tl at J 0k/- II i! Ii Ii ,I rLJlCJ!f ~ EDWARD E. PAGE, JR. ~~huJ A A EILEEN B. PAGE ~ i: " ,I 8 . COMHONWEALTH OF PENNSYLVANIA ) ( 8S.: 'COUNTY OF CUHBERLAND ) On this, the 07. day of ~lIfO.(J. , 1995, before .e, the undersigned officer, personally appeared EDWARD E. PAGE, JR. knovn to .e (or satisfactorily proven) i'to be the person vhose name is subscribed to the within instrument, and acknowledged " ilthat said person executed sa.e for the purposes therein contained. !i aJld.-afld.-&f-H t.IQT'WAI. SEAL C"::~ :"l. vOUi't~;;' (:~D. ~!ct2ry Public P.,,.,.. 1';11 e. I ' -, .- r'l'~ 1"10"0'" l.""ll'l'. ~'.;' ' L..L:,-.:":J': h..I,u LI :.. 'I H 'WJ.' IN WITNESS WHEREOF, I hereunto set , I; COHHONWBALTH OF PENNSYLVANIA ) ( SS.: COUNTY OF CUHBERLAND J On this, thea1L~day of lllllCLltr, 1995. before .e, the undersigned officer, personally appeared EILEEN B. PAGE known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed sa.e for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. J-- NOTAPIAl ![Al V:ENa't S. 8'.A'R, N(.'.lry Public lermlyn.: Bore. C...lf,t;Jr:.U1C Co!';nly, PI!. hit (cnuni:...lon bpinu h\dy 6. 1995 9 ;) ....; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDWARD E. PAGE, JR., Plaintiff vs. CIVIL ACTION--LAW IN DIVORCE EILEEN B. PAGE, Defendant NO. 94-5458 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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) cf the Divorce Code. 2. Date and manner of service of the complaint: Attorney Samuel L. Andes acceptance of service filed October 17, 1994. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff--February 21, 1995 (filed February 24, 1995); by the Defendant--February 27, 1995 (filed March 7, 1995). 4. Related claims pending: No claims raised. 5. Attached is a copy of the Property Settlement Agreement dated January 27, 1995, entered into by the parties. Said Agreement should be incorporated into the Divorce Decree. Respectfully submitted, HANFT & VOHS Date: March 8, 1995 Wi\~J VJ:E"qui" Attorney ID #65208 11 West Pomfret Street, suite 2 Carlisle, PA 17013 (717) 249-5373 i \ , r i r 'I II I. 'I II I I EDWARD E. PAGE, JR. plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94- ') * 5 J Civil Term EILEEN B, PAGE, Defendant IN DIVORCE NOTICE You have been sued in court. I f 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 at the Cumberland County Court House, High and Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE PROPERTY, LAWYER'S FEES ANNULMENT IS GRANTED, YOU THEM. A CLAIM FOR OR EXPENSES MAY LOSE THE ALIMONY, DIVISION BEFORE A DIVORCE RIGHT TO CLAIM ANY OF OR OF YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator One Courthouse Square Carlisle, PA 17013 (71'/) 240-6200 SAlOIS, GUIOO, SHUFF & MASLAND 26 w. High 51r<<'1 Carlisle. PA SAIDruS, . UIDO, SHUFF & MAS LAND c.L' i }/"- By: .- I William . ohs, Esquire Supreme Ct. I.D. # 65208 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff I I Ij EDWARD E. PAGE, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- Civil Term EILEEN B. PAGE, Defendant IN DIVORCE COMPLAINT UNDER SECTION 33011c) OR 33011d) OF THE DIVORCE CODE 1. Plaintiff is Edward E. Page, Jr. who currently resides at 704 Alberta Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Eileen B. Page, who currently resides at an undisclosed address in Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 16, 1977 in Cornelia, Georgia. 5. There have been no prior actions of divorce or for annulment between the parties. 26 W Hillh Slreel Carlille. VA , i 6. The Plaint iff has been advised of the availability of II I' il marriage counseling and the Plaintiff may have the right to I' Ii request that the Court require the parties to participate in :1 'I counseling. Having been so advised Plaintiff does not desire I, SAIDIS, GUIDO. SHUFF & MASLAND the Court to order counseling. ~ 7. The marriage is irretrievably broken. ,i 2 , i II I II I I I I WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Date: q11: H~\ Respectfully submitted, SAIDIS, GUIDO, SHUFF & MAS LAND d " i 'f ~ I C ' I II By: wi liam C. Vohs, Esquire Supreme Ct. I.D. * 65208 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff (' SAlOIS, GUIDO. I SHUFF & 'II MASLAND 11 II II [I Ii il " II I '! , !I " 26 W High Street Carlisle. P.<\ 3 11 !I II 'I I AFFIDAVIT I, Edward E. Page, Jr., being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I milY request. that the enllr!: require that my spouse and I participate in counselling. (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 counsell ing prior to a divorce decree being handed down by the court. 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. Dated: Vr:llyJ~ ~ Edward E. Page, Jr ,I i SAID IS. GUIDO. SHUFF & MASLAND 26 W Hijh SI~c1 C.ulisle. PA 4 :or:. ..... ,/) l--, I"J V) .~J.'\) .~ ~ r\~ - .., ..... ~ f':..'"') I ' r-. l'") '-' > ......... > ~ l<:) '-. ~ " \'-- ' .... Q~. ~ ~ ' ) 1'('\ ...... -,," ~~~~ .:;.. ; ,I v i\~ '.'-. --_J EDWARD E. PAGE, JR. plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94- sl/J8 Civil Term EILEEN B. PAGE, Defendant IN DIVORCE ACCEPTANCE OF SERVICE ! accept service of thtl divorce Complaint on behalf of Defendant, Eileen B. Page and certify that I am authorized to do so. Dated: b \)~bu 1"i~lJ- By: Samue ANDES', VAUGHN & BANGS 525 North Twelfth Street Lemoyne, PA 17043 SAlOIS. GUIDO. SHUFF & l\IASLAND 26 w. Uilh Slrect C.:ulidc. PA I EDWARD E. PAGE, JR.. :, P laintitt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW EILEEN B. PAGE, Defendant NO. 94-5458 CIVIL TERM IN DIVORCE I Ii i' APFIDAVIT OF CON8ENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed Ii on 23 September 1994. " 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety : days have elapsed from the date of filing the Complaint. i I, 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counsellors and tbat I may request the Court require my spouse and I to participate in counseling and, being 50 advised, I do not request that the Court require that my spouse and I partiCipate in counseling prior to the divorce becoming final. 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. J jJ.ihs Da lEt ' C'~C'12 EDWARD E. PAGE. JR. ~ ~ EDWARD E. PAGE, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW vs. EILEEN B. PAGE. Defendant NO. 94-5458 CIVIL TERM IN DIVORCE AFFIDAVIT OP CON8~ 1. A Complaint in Divorce under Section 33011c) of the Divorce Code was filed on 23 September 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 'days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerning alimony. division of property, . lawyer's.tees or expenses if I do not claim them before a divorce is granted. 5. 'I'have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counsellors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and 1 participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 reiating to unsworn falsification to authorities. February 27, 1995 Date (I,. y. /) fi If t/J(j,() r(1~C/ EILEEN B. PAGE ( :1 i1 .\ J :J "' ..