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HomeMy WebLinkAbout94-05544 II .gJ ] -;11 \ i ~ " 1\ ~ j ? \() \.() .. . r-------------------~'--...----, ~ IN THE COURT OF COMMON PLEAS . i OF CUMBERLAND COUNTY I : STATE OF . PENNA. I . . 8 .....I3l\.R.~X..'1.~....~.l\U[).I.C;,~ ..... .....' .............................. . _ ......................................~l.~~~.t.~.~.~...................... N o. .....~.~.H........ 9.IYJ.k... 1994 . ~. ~~~ ~ CIVIL ACTION - LAW ~ ~ ....'O'F;.~Q~.l\~...~.!....LA.lJ[)~~~~~d~~t..................... IN DIVORCE : ~ ...., ..................................................................... I : DECREE IN : ~ DIVORCE . I AND NOW,... ~~...~...... 19~.C. it Is ordered and ft . decreed that. .. . ~p.r;J;'Y..w.,. ~?\.\(Hg.. .. .. ..... .... ...,.. .... .., plaintiff. ~ . and.... . ..QElQ9j:.a.ll. k...r,.~\IP.i.g.... .. .. .. .. .. .. .. .. .... .. .. '" defendant. ! . are divorced from the bonds of matrimony. ; ~ . . 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; ~ , ~ ! .~nt.cl.!~.iJl1f! .~F.e. .!?~~.t)'?9.... 'c'!Tp~. .ll'H'bt,~El\l",h.i.\'{ei' ~.l\~9\lt.Elq.? .11'!U.i.'l9\'!, ~ 8 ~eL ement Agreement date Novem er ~2, 994, wnich Agreeme~t ~ 'Ah~,s. .q'?~f1.t.~fq.~liq .9fb.r:~ci9.r.c'! .i;l~. .t))~,,~~ thin. . t;~F!f1. .at;lp. .lJl,II)1P.e.r:, . ?l'\q. \'Ipich ~ III greemen sere y ncorporateu' i e ee in Divorce but . .: not mer therein. * i :;:;;;,;~;;;,~::,bll.e;;:/j? J. l ~ XI*..~-?:fI~!(i rtf~~.....p~~t~~~~tary : , / , ~ --it - ------~------~-~----- . [~ THE COURT OF COMlION PLEAS OF CmlBERLAND COUSTY, PENNSYLVANIA BARRY W. LAUDIG, Plaintiff NO. 5544 CIVIL CIVIL ACTION - LAW IN DIVORCE 19 94 va. DEBORAH L. LAUDIG, Defendant PRAECIPE TO T~~S~IT RECORD To the Prothonotary: Trensmit 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) (1l8kOdtx.k~ of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: September 30 , 1994 , by restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by Section 33011 c) of the Divorce Code: by the plaintiff 12/28/94 by defendant 12/28/94 (b) (1) Date of execution of the plaintiff's affidavit required by Section 201(d) of the Divorce Code: (2) date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None. The parties have executed a Marriage Settlement Agreement dated November 22, 1994, which Agreement has been filed of record at the within term and number, and which Agreement is requested to be incorporated in the final ~ecree in Divorce but not merged therein. 0 \ ~~~.~ Date: '0.1>.t ~ 'is"'. \ ~ C{ i Attorney for ~1=~~ . MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT. made this 1994. by and between BARRY W. LAUDIG. of Silver Spring Township. Cumberland County. Pennsylvania. hereinafter referred to as "Husband", and DEBORAH L. LAUDIG. presently of Silver Spring TownShip. Cumberland County. Pennsylvania. hereinafter referred to as .Wife.. '2. Z. ~ day of ~.........,.. ()u h. . WITIlESSETH: WHEREAS. Husband and wife were married on November 24. 1975; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they are living separate and apart from each other; and WHEREAS. Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS. Husband and Wife wish to make provision for the custody and support of their minor daughter. to wit: Kerri Ann Laudig. age 17. born December 23. 1976; and WHEREAS. Husband and Wife desire to settle and determine their rights and obligations with respect to each other. including the disposition and distribution of property rights and interests. including alimony. between them, as well as their rights and obligations with regard to the custody and support of their daughter. NOW, THEREFORE, the parties intending to be legally bound hereby, do covenant and agree: 1. SEPARATION. It shall be lawful for each party at all times hereafter to continue to live separate and apart from the other party at such places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulnese or unlawfulness of the causes leading to their living apart. At the time of the execution of this Agreement, the parties continue to reside in the marital home; however, it is known that Wife has imminent plans to relocate her residence. 2. INTERFERENCE. Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence. separate and apart from the other. 3. WIFE' S DEBTS. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save hannless Husband from any and all claims or demands made against him by reason of debts and obligations incurred by the Wife prior 2 to the date of the delivery of this Agreement, and all further debte incurred by the Wite from and after the date of delivery hereof, shall be the Wife's individual responsibility. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wite or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Husband acknowledges and agrees that all debts and obligations incurred by the Husband prior to the date of the delivery of this Agreement, and all further debts incurred by the Husband from and after the date of delivery hereof, shall he the Husband's individual responsibility. 5. JOINT DEBTS. The parties acknowledge that the only item of joint indebtedness which they have is a mortgage upon the marital home held by PNC Mortgage Corporation of America, and the disposition of this indebtedness shall be separately treated in a subsequent paragraph entitled REAL PROPERTY. 6. MUTUAL RELEASE. Subj ect to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or 3 all cause or causes of action for divorce and except for any or all causes of action for breach of any pr.ovision of this Agreement. 7. DISCLOSUR~ OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the parties and, further, have made such full and complete disclosure by the filing by each of them in the pending action in divorce of a formal Inventory and Appraisement. 8. DIVISION OF PERSONAL PROPERTY. The parties agree that the articles of personal property contained in their marital home have already been divided between them and articles have been identified which Wife shall remove with her when she vacates the marital home, thus, it is agreed by the part ies that all personal property remaining within the marital home at the time of Wife's relocation of her residence shall be and become the sole and separate property of Husband. 9. BANK ACCOUNTS. The parties were, heretofore. the joint owners of two savings accounts and a CheCking account maintained at PNC Bank. The parties acknowledge that they already amicably divided between themselves the balances maintained in said account and agree and acknowledge that Wife has received from the said accounts the total sum of $9,216.46 and that the remaining sums in 4 the said three accounts were and are distributed to Husband ae his sole and separate property. 10. AUTOMOBILBS. The 1989 Mercury automobile and the 1988 Chevrolet automobile heretofore owned by Husband ehall be and remain the eole and separate property of Husband. The 1994 Pontiac which was a leased vehicle, leased by Husband, has been assigned and transferred to Wife who hereby agrees that she, alone, shall hereafter be fully and completely responsible for all rights and obligations incident to the said lease agreement and shall indemnify and hold harmless Husband from any further liability or responsibility with regard thereto. 11. LIFE INSURANCE POLICIES. The parties agree that any policy of insurance which is maintained by either party insuring his or her own life shall be and remain the sole and separate policy or asset of the insured. However, the parties further agree that if the non- insured party upon any of the life insurance policies shall be unable to pay the premium thereon, and if the non-insured party shall still be the beneficiary upon said policy, the beneficiary/other party shall have the right, at his or her election, to continue to maintain any of the said life insurance policies in full force and effect by paying the required premiums thereon. 12. REAL PROPERTY. The parties are the joint owners of real estate known as 11 Royal Palm Orive, Silver Spring Township, CUmberland County, Pennsylvania. Wife hereby agrees that she will 5 join with Husband in the execution of a deed transferring to Husband all right, title and interest of the parties in and to the aforementioned real estate and, Husband agrees that, in consideration of his receipt of eole title to the eaid real estate, he, alone, shall hereafter be solely and fully responsible for the payment of the mortgage upon the said property, held by PNC Mortgage Corporation of America, and Husband does hereby agree that he shall indemnify and hold harmless Wife from any further liability or responsibility with regard thereto. 13. STOCK INVESTMENTS. The parties heretofore were the joint 010lTlers of shares of stock in Allstate Corporation and Disney Corporation and do acknowledge that they have caused said stock to be sold and have made a division of the proceeds of the sale of the stock which was agreeable to them; and, by these presents, they do hereby ratify and confirm the division of said stock or stock proceeds. 14. RETIREMENT ACCOUNTS, Wife is the owner of an IRA account and Husband is the owner of a Dean Witter retirement account, as well as being a participant in the Sears Profit Sharing/Retirement Fund established by his employer. The parties agree that each party who is identified as the owner or participant in any of the aforementioned retirement accounts shall be and shall remain the sole and exclusive owner thereof, each party hereby relinquishing any interest which he or she may, as spouse, have with regard to the interest of the other party in any o~ the said retirement 6 accounte. Specifically, Husband releases and waives any interest which he may have in the IRA account of Wife; and Wife releases and waives any intereet she may have in and to the retirement intereets of Husband in the Dean Witter account and the Sears Profit Sharing/Retirement Fund. In the event the Trustee or Administrator of any of the aforementioned retirement funds shall require further written evidence of the waiver of spousal interest in any of the retirement accounts, upon request, the party waiving his or her interest shall execute such documents required for the purpose of confirming said waiver. 15. MISCELLANEOUS PROPERTY. Except as otherwise set forth in this Agreement, it is the intent and the agreement of the parties that all property, whether real or personal, not otherwise specifically identified in the previous paragraphs of this Agreement, shall be and remain the sole and separate property of the party who was or is the owner of said property upon the date of the execution of this Agreement and, to the extent any residual spousal interest may exist on the part of the other party with regard to any of such unidentified property, the non-owner spouse does hereby disclaim and waive any spousal interest which he or she may have therein. A specific intent of this paragraph is that the stock interest of wife in Green Grow Corp. shall be and remain the sole and separate property of Wife, and Husband does hereby waive and relinquish any interest which he may have or may have acquired therein by virtue of his marriage to Wife. 7 16. CUSTODY. The parties acknowledge that their 17-year-old daughter, Kerri Ann Laudig, a high school senior, will attain adulthood on December 23, 1994, and, they deliberately choose not to dictate any custodial arrangements to or on behalf of their daughter, leaving to their daughter the decision of her choice of residence with one or the other of the partiee. Nevertheless, the parties do hereby agree that neither of them shall speak critically of the other in the presence ot their daughter and each shall encourage their daughter to maintain a parent/child relationship with the other party. 17. SUPPORT OF KERRI. No provision is herein made tor the payment of child support by one of the parties to the other. tor the benefit of Kerri. In3tead, each party agrees, voluntarily, that he or she will render such financial support as may be necessary from time to time for and on behalf of their daughter. Notwithstanding the foregoing, in the event Kerri should enroll in a college or university for post-high school education, the parties do agree that they will payor contribute to the total cost of such higher education by Kerri, Husband agreeing to contribute two-thirds (2/3) of such cost and Wife agreeing to contribute one-third (1/3) of such cost. The parties further agree that the ratio of their contribution to the educational costs of Kerri may be modified; however, any such modification shall be in writing, signed by both of the parties, and attached to this Marriage Settlement Agreement as an Addendum thereto. In no event shall either party be required 8 to contribute to the educational costs of Kerri beyond her attainment to the age of twenty-three (23) years. Wife agreee that she shall continue to maintain Kerri as a beneficiary upon the Blue Crose/Blue Shield health ineurance which she has available to her at her place of employment, subject, however, to the obligation on the part of Husband that, so long as Kerri is lawfully maintained as a beneficiary upon Wife's Blue Cross/Blue Shield insurance, he will pay to or reimburse to Wife one-halt (1/2) of the cost which Wife incurs in continuing to maintain Ker~i as a beneficiary. In addition to the foregoing, Wife agrees to continue to maintain Husband as a beneficiary upon her Blue Cross/Blue Shield health insurance until such time as a Divorce Decree between the parties has been entered. 18. TAX EXEMPTION. In the event the parties are still married at the end of calendar year 1994, they agree that they shall file a joint Federal income tax return, shall jointly claim Kerri Ann Laudig as their exemption, and shall equally pay any income tax obligation due or equally share any tax refund received. In the event a Divorce Decree shall be issued prior to the end of calendar year 1994, Wife agrees that Husband shall be entitled to claim Kerri Ann Laudig as his tax exemption upon his Federal income tax return for 1994. In addition, Wife agrees that, so long as Kerri is a student and is entitled to be claimed as an exemption by one of her parents, such claim of exemption of Kerri shall be 9 accorded to Husband. Wife agrees that she shall execute the IRS form 8332 for the purpose of evidencing the right of Husband to claim Kerri as his tax exemption for 1994 and all future years. 19. SPOUSAL SUPPORT, AL::MONY, ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES. Both parties hereby waive and relinquish any right which each of them may have to seek or to receive from the other party the payment of any sums of money as epousal support, alimony, alimony pendente lite or counsel fees and expenses. Husband acknowledges that he has caused to be instituted the presently-pending action in divorce in the Court of Common Pleas of Dauphin County and agrees that he, alone, shall be responsible for all attorneys' fees and Court costs associated with said divorce action. 20. IMPLEMENTATION OF AGREEMEN'f. The parties agree that, upon the execution of this Agreement, each of them will sign all documents contemp:'.ated by the terms of this Agreement and necessary to provide for the transfer of any asset intended to be transferred to one or the other of the parties under the terms of this Agreement and shall cause such executed documents to be delivered to each other upon the entry of a final decree in divorce. 21. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights 10 under this Agreement, or seek such other remediee or relier as may be available to him or her. 22. ENTIRE AGREEMENT. This Agreement contains the entire understanding or the parties and there are no representations, warranties, covenants or undertakings other than those expressly set rorth herein. 23. MODIFICATION AND WAIVER. The modirication or waiver or any or the provisions of this Agreement shall be effective only ir made in writing and executed with the same formality as this Agreement. The failure or either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 24. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 25. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 26. APPLICABLE ~. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 27. VOID CLAUSE. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, 11 condition, clause or provision ehall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 28. ENTRY AS PART OF THE DECREE. Husband has initiated an action in divorce under Section 330l(c) or 3301(d) of the Pennsylvania Domestic Relatione Code, filed in CUmberland County to No. 94-5544 Civil Term. It is the intention of the partiee that the within Agreement shall survive the aforementioned action for divorce, and that no order, judgment or decree, temporary or interlocutory, final or permanent, shall affect or modify the financial terms of this Agreement. Both parties agree to execute Affidavits of Consent for the purpose of entry of a Divorce Decree under Section 3301(c) of the Pennsylvania Domestic Relations Code. This Agreement shall be made part of any such judgment or decree of final divorce, but shall not be merged therein. Husband agrees to provide to Wife, at his expense, a certified copy of the final Decree in Divorce. 29. VOLUNTARY EXECUTION. Husband and Wife both acknowledge that Carl G. Wass, Esquire, has played no role in the negotiation of the terms of the Agreement herein set forth but, instead, has simply acted as scrivener, reciting herein the mutual agreement of the parties privately made between them. Both parties do acknowledge that they have entered into this Agreement with full knowledge of their respective rights as spouses under the Domestic Relations Code of Pennsylvania, particularly, with regard to the 12 equitable distribution ot property, the right ot either party to receive alimony or to receive alimony pendente lite, or to receive the payment ot their respective counsel tees and Court costs. Both parties acknowledge that, prior to the execution ot this Agreement, a copy thereot has been received, read, understood. and each has had the opportunity to discuss and review the terms thereot with any attorney ot his or her choosing. Both parties do acknowledge and declare that each does underatand the full legal ettect ot this Agreement, especially with regard to the fairness and equitable nature of the distribution of marital property between them and the waiver of spousal support and/or alimony payments provided in this Agreement. Both parties acknowledge that their execution ot this Agreement has been done voluntarily and knowingly and that their execution is not the result of any duress or undue influence. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above wI'itten. WITNESS: :-- :r;.~~' Barry . Laud! Qk"LhL ACl.Llcl,8' Deborah L. Laudig 13 AFFIDAVIT COflMlNWBALTH OF PENNSYLVAN:i:A SS: COUNTY or On this, the day of , 1994, before me, a Notary Public, the undersigned officer, personally appeared BARRY W. LAUDIG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public ] t1 . . . . AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF SS: On this, the day ot , 1994, Detore me, a Notary Public, the undersigned otticer, personally appeared DEBORAH L. LAUDIG, known to me (or satistactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same tor the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public ~ \ G:\DATA\CGW\0Z330\94574\41071.1 -:T" t.).,,~ ,-~.... ro....: tl . , . ~." ,'.J , , . ., 0.."," . . . . '. . . .. .. . , . f . ! ~ \ " .I jo" 1 "," Plaintiff IN THB COURT OF COMMON PLEAS CUMBBRLAND COUNTY, PENNSYLVANIA No. (iy - 55Lj.4 C.i.lS To..t.u> \ CIVIL ACTION - LAW IN DIVORCE BARRY W. LATJDIG. VS. DSBORAH L. LAUDIG, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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 made proceed without 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, Room 101, Dauphin County Court House, Front and Market Streets, Harrisburg, 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE COURT ADMINISTRATOR Third Floor, Cumberland County Court House Carliele, PA 17013 (717) 249-1133 , '. BARRY W. LAUOIG, Plaintiff IN THE COURT OF CO~DN PLBAS CUMBERLAND COUNTY, PBNNSYLVANIA VB. No. DBBORAH L. LAUDIG, Defendant CIVIL ACTION - LAW IN DIVORCB COMPLAINT UNDBR SBCTION 3301(c) OR 3301(d) OF THE DOMESTIC RELATIONS CODE 1. Plaintiff is Barry W. Laudig, an adult individual who resides at 11 Royal Palm Drive, Mechanicsburg, cumberland County, Pennsylvania, 17055, 2. Defendant is Deborah L. Laudig, an adult individual who resides at 11 Royal Palm Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the fi.1ing of this Complaint. 4. The Plaintiff and Defendant were married on November 24, 1975, in cumberland County. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Defendant is not a member of the armed forces of the United States or any of its allies. 7. The Plaintiff avers that the marriage is irretrievably broken. . VERIFICATION I, BARRY W. LAUDIG, verity that the averments made in this Complaint are true and correct. I understand that talse statements herein are made subject to the penalties ot 18 Pa. C.S. 4904, relating to unsworn talsitication to authorities. Date: ~ ;;:}'i,-) lql{~ ~~ , . ..,.,. en . '1"-;: , en In ~ ".J - u t;;;:> !f Ul. Zo): 0:;0( .c:.... kif.... ~. 0( o ~ u 11I1 J ~ -'=.... .Joz 1a.I~1I: ~.O O~I- o I- .J"o( <( ~ U Q E ::; ~ .. z e ~ UI oJ ~ ~ · III o Z " Z ~ W r Q. ~ . " " o II: . :) ;; II " III " if II: 0( X ...... . .. ... . . # .' Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 94-5544 CIVIL TERM BARRY W. LAUDIG ve. DEBORAH L. LAUDIG, Defendant CIVIL ACTION - LAW IN DIVORCB AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: Personally appeared before me, a Notary Public in and for said Commonwealth and County, CARL G. WASS, ESQUIRE, who being duly sworn according to law, states that he served a certified copy of the Complaint in Divorce, with attached "Notice to Defend and Claim Rights", upon the Defendant, Deborah L. Laudig, pursuant to Pennsylvania Rules of Civil Procedure 403 and 412 by mailing to the said Defendant at her residence, 11 Royal Palm Drive, Mechancisburg, Pennsylvania, 17055, by certified mail, restricted delivery, return receipt requested, said certified mail piece being No. Z 151 904 949; that service of the foregoing was made on September 30, 1994; and that attached hereto and incorporated herein by reference is the return receipt, bearing the signature of the Defendant, acknowledging receipt of the aforementioned documents by the Defendant. Sworn to and subscribed before ~.this ~~ day Of~~or:;v , 1994. /)&-(! . k~ NotfY Public NOTARIAL SEAL T:~LYC KOlUS. Notary Public HarrisburQ. Daupnin County My Commission bpires Nov. 28. 1996 '1~,'E;Z1i:~:::::.";:~ 9~=::ri;,i , ,-IIIIl,,",*, J 11~;'J ;..":..!..~-:.:-_-=::::= C.,1h_~...~, ,,' il ~;~o;;~;:~m Lorr::d19" ~' ~ ~ J Mechanicsburg. PA 17055 I o R_ "-'" for ' --.I I r'l J I I I , I I L. . I e; IlgneIuN CAgoml : j,.FOlIII .0__1..1 . Ml.&VQt_ _lM -or en J' n - .- L: m '" ('-J t.:J (-..J CJ ," c_..;; Q VI E z . .. . 0 w 0: ; . w i ~ . . .. . . ..J .. ~ 0 .. x: . t- o .. >- 0 . . Ul Id u Ul 0 Z . >- .. Z . ... .J . .., .., .J 0 Z . Q. .. W ii IZ a: .; ~ " 0 0 w IZ 0 ~ t: z ;] 0 ;; .I 0 . lD ~ . .. Ul U . ,., it IZ . r ., (I . " " . ...... . .. . " .."'.....' _ -,. .:' ...,., .11- OIJ' ~.... .., ..i.... C.. "'WO. "-,, '.~..r.. ....')1' ,..,\ ,'. . . . BARRY W. LAUDIG, Plaintiff VB. IN THE COURT OF COMMON PLEAS CUMBBRLAND COUNTY, PENNSYLVANIA No. 94-5544 Civil Term CIVIL ACTION . LAK IN DIVORCE DEBORAH L. LAUDIG, Defendant AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: I, DEBORAH L. LAUDIG, being duly sworn according to law, deposes and says: 1. A Complaint in Divorce under Section 3301 (c) of the Domestic Relations Code was filed on September 28, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree of 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 and understand that I may request that the Court require that my spouse and I participate in counseling; I understand that the Court maintains a list of marriage counselors in the Domestic ....;r rr> ,. l"'~ ," ',.,J t'..1 ." ',..-' III Zg II: . ~ ~~j ~~I- o -c ~~1Il oJ." -J~~ 1&I~a: ~:o oat: oJ . -c c( . u' " -. .' .... ",^ .~. .,.' ........ -" '--. - .' "'". ,'J '.. ".K, ,......, >~.:,' ,,,,'. .,~ , , ~ Q E ~ -c '" i cr ~ ~ Hi o :z: cr z .. w ~ II. cr ~ o a: z :;) 1'111 0011I 1'1 it a: -c :r ~. .