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Home My WebLink About95-00572 \.. . " " ~.. I .. .. . _.. ......-.--;1 ...,.......,'. , ,_~ .... H', '/ ,- ,. _T71'_~ . . I , h~ ,)1. . , .L.. ,'t. ....;.......... ,~-; tIQd........~,.i1IPI'M~~''"l.~....:; ......!I~~ ~~..-,--.....- . ..--.... 'v '. . -. .~;:;;::;::"_ ..., .......... ".'- , }t/;,;.':it "'~ ;'qJ ~-.J' iE, .~ .... iJ ~ 'Q.... ~. ",n ,. ,', r;/!;:~'--'" ',,\:''',.'' ;V\\ ':> j~{ fJ~ ~;';:~., '::0' ~;;.. tw'" ''<' t~):}?,.~ \>\ j~t~r; j(;,~; .', t;l,ie;' ",", ,'i-.' t~:~ ~' ; ,,',z.--'.-.', ':,', .-:'-','-> . iJf' ~; ~J/::"'; ,'.:+:.' '.:.:.' - .:+:. '.:+:. -.:.:. > - .:.:. .:+:." '.:.~. <<<. .:t> .:.:. - - .:+:. - .:+:. .:+:. .:+:. .:+:. .:.:. .:.:. .:+:. .:+:.' ~~ :.:+:.: ;':+f': :.~>: :.:+:.; ~.:.>:' .:+> - .:+:. :.:.:.::-:+:-: :..~ ,', ----- -- - ,.:, ~ ~ . ~ W,' . ~ M : IN THE COURT OF COMMON PLEAS : !', ~ ~ ~ .. OF CUMBERLAND COUNTY ~ ~ ^ ;'; ~itt- ~ a ~ y ~ ~ STATE OF ~. ~.,. t PENNA, ~. ;~ "7\',"'II'!'; ..r ',"'., .~ ~ ~ ,.' ~ ',' ..,BO~I.TA.~~..B.O!TOMLEY, " ,..p..pP..... P1.aintiff, I' 'I 'i N (), .p~?,~,5..?2..... 9.~.Y.I.~... It) Y 5 ~ '.~ ~'. ~ ~j ~ ~ ~~ ~ i:i ~ ,:; " f~ ~ ~ j< ~ ~ S iO: W. :~ S " W ~ ,', ~ ~ '.~ ,', ~ w '.' w '.' ~ '.~ ,', ~ ~ ',' ;', ~ W ',' Q ~.~ ~ .'~ t :.~ W ',' Vl'I""illS MARC W. BOTTOMLEY ..... .-..... .. - .... .-.".-. - ,---.. , Defendant ;i " " .... ~ t :.- ~ ~.: i :.' AND NOW, ..' ... DECREE IN -fi- D I V 0 R C~ IA 2-: 2.-0 fA ;),~ ~( . ."...".,...,..." 19.,.,... it Is ordered and M ,0: " ~ ~ ~ ~ ~ $ decreed that .... .eON. fl.!...,. .130'}.',T.QMLIW" . , . . . . . . .' . , , . ., . . '" plaintiff, and. . , , . " ,.,. . . ,~~.~9. !~.'. ,~9!~~~I~~X., . ., , . ., . . . , . . , . ., . . '" 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; The Separation and Property Settlement Agreement dated .......... .............. ... ..... .., ....... ............. ..................., ~.l!~:t. ,l.~ ~ . ~~.9.~,. i.s. .l1p:.a,c;l)9~. .I1c;Ff!,t,q. \l!1,d, .~!l. )1,qJ;li!PY. .~I,1PP,1;)?c;>r!W~9. .i.nto this Decree. ,', ~ ~.~ ~ ~ 8 ~ ~ ~ .,' 8 ~ ~ I .'..-;-;~ {', t~~'I. /.;~,,~. ~~kfJ4 . Pr~nolnry ^ !li: '.' !~ ~ '.' . . la .:+:. .:.:. .:t:. .:~:. .:.:. .:.:. .:.:. .:.:. .:+:. .:.:. ~ '.' 7.,;25.95 tJcI, t"l'1 /HJt'.JJ/~ ,i(j ~ /';)5,tlS' '1lit0. 1~1':.AI ~ df" ,I r~'. ! \ MARITAL SETTLEHEN~GREEMENT THIS AGREEMENT is made this ~ day of ~ '/ ' 1995, by and between BONITA L, BOTTOMLEY, ("wife") and MARC W. BOTTOMLEY, ("Husband"). WHEREAB, the parties were married on Ootober 20, 1984, and have remained married sinoe that time; WHEREAS, certain differenoes have arisen between the parties and, as a consequenoe, they have lived separate and apart from eaoh other sinoe the filing of the Divorce Complaint; WHEREAS, the parties are the parents of one ohild born to their marriage, SHAWN H. BOTTOMLEY, born January 25, 1990; and WHEREAS the parties wish to set forth oertain covenants and understandings regarding their separation, their child, and their respeotive property rights; NOW THEREFORE, in consideration of the mutual promises and undertakings contained herein, the parties hereto, intending to 'be legally bound, covenant and agree as follows: 1. VOLUNTARY AGREEMENT: It is acknowledged by the parties that this Agreement is entered into voluntarily and after due deliberation by each of them. 2. SEPARATION AND NON-INTERFERENCE: It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at suoh place or places as they shall respeotively deem fit, free from any control, restraint, harassment or interferenoe, indirect or direct, from each other. The foregoing provieions shall not be . ' taken to be an admission on the part of either party of the lawfulness or unlawfulness of the causes leading them to live apart. 3. DIVORCE ACTION: The parties acknowledge that an action for divorce between them has been filed by Wife in the Court of Common Pleas of Cumberland County, Pennsylvania, Bottomley v. Bottomley, No. 95-572, In Divorce. The parties agree that at the time of execution of this Agreement, they are also executing affidavits, consenting to the entry of a Divorce, with incorporation of this Agreement. 4. CUSTODY OF CHILD: a. Wife and Husband hereby covenant and agree that the Wife will have primary legal and primary physical custody of the minor child of the parties, SHAWN M. BOTTOMLEY. b. Wife and Husband hereby covenant and agree that the Husband will have periods of partial custody as agreed upon by the parties. 5. CHILD SUPPORT: The parties acknowledge that an action for support for their child, SHAWN M. BOTTOMLEY, has been filed by Wife with the Domestic Relations Office of Cumberland County, Pennsylvania, to the caption, Bottomley v. Bottomley, DR No. 23,767. The rights and obligations of the parties with regard to support of SHAWN shall be determined in that proceeding except as may be otherwise provided for herein. 6. COLLEGE EXPENSES: The parties hereto acknowledge and agree that it is their hope and expectation that SHAWN will attend undergraduate college or its equivalent after high school. They agree that they shall contribute to the expense of his education in accordance with the needs of their child and their respective incomes and abilities at the time. 7. MEDICAL AND HOSPITALIZATION INSURANCE: a. Husband agrees to provide their child with health insurance benefits equivalent to that presently enjoyed by SHAWN as his dependent, or as otherwise available through Husband's employer. b. Husband agrees to provide Wife with health insurance benefits equivalent to that presently enjoyed by her as his dependent through his employer. Such coverage shall continue, unless the right thereof is waived in writing by Wife, until a final divorce decree is entered terminating the marriage of the parties. B. ALIMONY: a. The parties acknowledge that an action for spousal support has been filed by Wife in the Domestic Relations Office of Cumberland County, Pennsylvania, a the same action number listed above with respect to the child. b. The obligations of the Husband with regard to spousal support of Wife shall be determined in that proceeding except as may be otherwise provided for herein. Commencing upon entry of a divorce decree, at which time the spousal support obligation terminates, Husband agrees to pay to Wife $54.00 per week in alimony for a period of five years. This amount may be modified upon request of either party to reflect an appropriate alimony amount, consistent with the Support Guidelines, and taking into account child support being paid for the minor child. The alimony may also be oollected by entry of a wage attachment against Husband. 9. PERSONAL PROPERTY: Exoept as provided for within this Agreement, the parties acknowledge that there has been distribution between them of their items of personal, tangible and intangible property, including various bank accounts, and motor vehicles, and they agree that the division thereof is to their mutual satisfaction. Each of the parties shall hereafter own and enjoy, independentlY of any claim or right of the other party, all items of personal, tangible and intangible property now or hereafter owned or held by her or him with full power to dispose of the same effectivelY and for all purposes as if she or he were unmarried. 10. LOANS: a. There currently exists a consolidated loan of the parties with an approximate balance of $6,200. The parties acknowledge that effective May 1, 1995, Wife agrees to make payment of $3,000.00 against the principal balance of this loan over an la-month period, plus any interest accruing on this $3,000.00 amount during said period of time, by making regular payments on said loan, thereby reducing the loan balanoe to $3,200. Thereafter, the parties acknowledge that Husband will assume full and sole responsibility for the remaining balance of the loan. b. Any existing loans or indebtedness, other than that stated above in subparagraph (a), shall become and are the -. " sole responsibility of the party currently possessing the property, motor vehicle, credit card, or item of value attributable to the loan. c. Each party agrees to hold harmless and indemnify the other party should any legal proceedings be brought against either or both of the parties based upon failure to make timely I I I l I I I , ! and complete payments on any loans. ll. PENSION RIGHTS: The parties agree that they each waive any and all claims to or interest in any pension rights or retirement funds of the other party. l2. DEBTS OF THE PARTIES: The parties agree that they will not in the future contract nor incur any debt or liability for which the other party, or his or her property or estate, might be responsible and each further agrees to indemnify and save harmless the other party against any claims that may be asserted by anyone against the other party by reason thereof. l3. NON-MERGER IN DIVORCE DECREE: The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement, and neither this Agreement, nor the terms hereof, shall be deemed to have been merged in any decree or judgment granted in the divorce action, but shall survive and be forever binding upon the parties. l4. EXECUTION OF DOCUMENTS: Each of the parties shall, from time to time at the request of each other, execute, acknowledge and deliver to the other party any and all further instruments that may reasonably be required in order to give full , :..,' . . ." . ,f' . " <, , . force and effect to the provisions of this Agreement. 15. COUNSEL AND COUNSEL FEES: Each party hereto agrees that he or she shall individually be responsible for any and all counsel fees and expenses incurred by him or her in connection with the preparation of this Agreement and the divorce between the parties. Each party also agrees that he or she understands they have the right to be represented by their own attorney in this divorce action, including an attorney to review this Agreement, and that in entering into this Agreement, they have either consulted with an attorney or have decided not to obtain separate representation. I I . I , i' \1 \' i I l6. MUTUAL RELEASE: Except as provided for in this Agreement, the parties hereby remise, release, quit-claim and forever discharge each other and the estate of each other, ~or all time to come, and for all purposes whatsoever, from any and every claim, including alimony, alimony pendente lite, spousal support, equitable distribution of marital property, counsel fees or costs under the Divorce Reform Act, or otherwise, that they make or hereafter make in and to or against each other's estates or any parts thereof, excepting any rights by way or dower or curtesy, or under the intestate laws, or the right to take or elect against the other's will, which the parties agree will remain in effect unless and until a final divorce decree is entered terminating the marriage between them, except only such rights as accrue pursuant to this Agreement. l7. NON-WAIVER: The failure of either party to insist in anyone or more instances upon the strict performance of any of , . the terms hereof in this Agreement shall not be construed as a waiver or relinquishment of such term or terms in the future. lB. BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court costs and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her, including equitable enforcement of the Agreement. 19. ENFORCEMENT AND ENTRY AS ORDER: The parties agree that any portions of this Agreement may be entered as an independent Order of Court, separate from and in addition to the incorporation this Agreement into the Divorce Decree. Further, this Agreement, or any part or parts hereof, including separate Orders, may be enforced in any court of competent jurisdiction. 20. APPLICABLE LAW AND EXECUTION: The parties hereto agree that this Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and shall bind the parties hereto, and their respective heirs, executors and assigns. This Agreement shall be executed as original in triplicate. 2l. ENTIRE AGREEMENT: The parties acknowledge and agree that this Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. . _. 10 22. INCORPORATION IN JUDGMENT FOR DIVORCE: In the event that either Husband or Wife at any time hereafter obtain a divorce, this Agreement and all of its provisions shall be incorporated into any such judgment for divorce, either directly or by reference. The court, on entry of judgment for divorce shall retain the right to enforce the provisions and the terms of the Agreement. IN WI~NESS WHEREOF, the parties hereto have set their hands and seals as of the day and year first above written. ~ "'/ x:J:,~",p ~~.' BOTTOMLEY !. ,--= BONITA L. BOTTOMLEY ,. I COMMONWEALTH OF PENNSYLVANIA . . :55: COUNTY OF CUMBERLAND ~ On this, the ~ day . . , 1995, before me, a Notary public in and of ' ~ ~ 1 for the aforesard commonwealth and county, personallY appeared BONITA L. BOTTOMLEY, known to me, or satisfactorily proven, to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOT Y PUBLIC My commission Expires: ,,'jif..~W.t ~f:t\L fA!~Cr.t \'1. \JU~r~.li.~ll/'.r:~ ru~t.-:C. Cl~~:J\'..":.. r.~.~~L (.~.u3.~\....~'ii) r.:.'Li"il~ 1,':1 c~:\~..\~j:\i.\rl f):r'l\1~.J .\\,\t Y ,,. tl)1.} ~___~_-'..~ v__ .. ., COMMONWEALTH OF PENNSYLVANIA I : ss: COUNTY OF CUMBERLAND I On this, the \O-b-day of S~ y , 1995, before me, a Notary public in and for the aforesaia Commonwealth and County, personally appeared MARC W. BOTTOMLEY, 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 purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Expires: . ........'T...,fC"Jl..~'e.<.l ';!lTf.JiW.. ~;:~t UM.'lIE' v: 1111'1,1: '1""""""""" ;.I.. ....""......",. ."t.." I' crl:\ut;~~r::lril. q"i:",;.i!/i:;) t~:;"'- i'i ~ fl'rr...,....,h-,... .. '.' ' ,. j ......"... ....', , .,~ '". I. t -" . ~ '.' I . ". I. ~.~,.""".W.,"""'.I:"'.W...-....., .J~ '-.........,,41'.....-... t. ._ '-':" '- c~ ,- t.CI , . ", . .(~ ~ ~. ,-~ ~.: .:: ~" c', 10... ; ~ . Tl ..~ '~- ''<:::; .e <::> ~ u'; ..,., . BONITA L, BOTl'OMLEY, Plaintiff IN THE COURT OF COMMONM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, OG.G72 CIVll.. TERM VB, MARC W. BOTTOMLEY, Defendant CIVIL ACTION. DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following informlltion, to the Court for entry of Il divorce decree: 1. Ground for the divorce is irretrievllble breakdown under Section of 330l(c) of the Divorce Code. 2, The Complaint WIl8 served by U,S, Mail, certified, restricted, return receipt requested, to the Defendant, and Ilcknowledgement of acceptance of service WIl8 executed by Defendant, February 23, 1995, 3, Plaintirra Affidavit of Consent required by Section 3301(c) of the Divorce Code Wl18 executed by the Plaintiff on July 10, 1995, and by Defendant on July 10, 1995. .. Tl.'" "'" ,0 "I.ted cl_ poodiD" An .........t ,r tb. porll" da.... July 10, 199'. is to be incorporated in the Decree in Divorce, RespectfullY submitted, SAMUEL ~~lLKE~ 7(1"::\'15 JACOBSEN & MILKES 52 E, High Street Corlisle, pA 17013 (717) 249-6427 Attorney for Plnlntiff <- ,:: .- u:> , r. ,,:.;' 0 -0 ::x: " _' I..D U'1 . f \~ I I i ,I I , ., BONITA L. BOTIOMLEY . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS. . NO. C) 5 - 51 d- . C~ T~f\(l' . . MARC W. BOTIOMLEY, . . Defendant . CIVIL ACTION - DIVORCE . NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set forth in the fol1owing pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed withou t 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 othcr claim or relief requested in these papers by the plaintiff. You may lose money or property or othcr rights important to you, including custody or visitation of your children, When thc ground for the divorcc 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 Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013, 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, THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249.6200 , ", BONITA L. BOTIOMLEY Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . VB. ~ NO.9-5-5? J CtLJ} T-0L/71 MARC W. BOTIOMLEY, Defendant : CIVIL ACTION. DIVORCE COMPLAINT UNDER SECfION 330HCl OR 3301(0) OF THE DIVORCE CODE COUNT I 1. Plaintiff is Bonita L. Bottomley, who currently residcs at 203 Bridge Street, Apt, 2, New Cumberland, Cumbcrland County, Pennsylvania, and has since 1984, 2, Defendant is Marc W. Bottomley, who currently resides 59 S. Water Spring, Spring Grove, York County, Pennsylvania, since October 24, 1994, 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 October 20, 1984, in New Cumberland, Cumberland County, Pennsylvania, 5, Thcre have becn no prior actions of divorce or for annulment between the parties, 6. The marriage is irretrievably broken, 7, Plaintiff has becn advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8, Plaintiff requests the court to cnter a decree of divorce. WHEREFORE, the Plaintiff requcsts this Court to: a, Enter a final Decree of Divorcc divorcing the Plaintiff from the Defendant; and b. Grant such further relief as it shall deem proper and just. Rcspectfully submitted, f2(~ 13Y: Samue , Nlilkes, Esquire JACOBSEN & MILKES 52 E, High Strect Carlisle, PA 17013 (717) 249,6427 Attorney No. 33130 -. BONITA L, BOTTOMLEY Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. VS. . . MARC W. BOITOMLEY, Defendant : CIVIL ACTION. DIVORCE WAIVER OF COUNSELING Bonita L, Bottomley, Plaintiff herein, hercby states and certifies as follows: 1. I have been adviscd of the availability of marriagc counseling and understand that I may request , that the Court require that my spouse and I participate in counscling. 2, I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3, Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements hcrein are madc subject to the penalties of 18 Pa.C,S, Section 4904, relating to unsworn falsification to authorities, Dated: ~!t~ , / "- ., false statemcnts herein nrc made subjcct to the penalties of 18 Pa,C,S, M904. relating to unsworn I vcrify that the statemcnts made in this Complaint are true and corrcct, I understand that falsification to authorities, ..,.,..,.-"/ --7- ,,-- :6 (';11 ~ - , (lJu;;{I< : lIlt, - BONITA L, BOTIOMLEY (/ 4 ~ ~ p:: fl:. ?J :::J - 0 .>Q lJ.I o(l " ~ "' co ttl -./i:J - i ..J \ In(,J\ - . . ~ 0 CJ1 0 0 VI ~-a. 0 ~b ,} ~ ~ it- N :: ~~ -r.l 1 ::..:;. ...:... - <-0 V1 BONITA L. BOTIOMLEY Plaintiff VS. MARC W. BOTIOMLEY, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . NO. qj-- :5 72 ~~ . . . . : CIVIL ACTION. DIVORCE ACCEPTANCE OF SERVICE I, Marc W. Bottomley, Defcndant in the above matter, hercby acccpt service of the COMPLAINT UNDER SECfION 3301(C) or 3301(0) OF THE DIVORCE CODE. Date: ~L0.5 ,1995 ~""6'w>-~ RC W, BOlTO Y '", .- ~*~"'~.""-"" - ..-...... '( oj o " .. '. ::c ,~ "" ....., '..',. .,1 .;,' ,~ ." '41 .t:.. ,0 .&: -n := ~- .t' ~' ,- - o<JD &Jnl BONITA L. BOTfOMLEY . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS. NO. 95.572 CIVIL TERM MARC W. BOTfOMLEY, . . Defendant . CIVIL ACTION - DIVORCE . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under the Divorce code was filed on February 2, 1995, on the grounds that the marriage of the parties is irretrievably broken. 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 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. I verify that the statcments made in the 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, ~ (/ -.eX. // / >'~. DONITA L. BO'11'OMLEY/' DIIIC: -t)ol1r ,1995 ,- .""" - ,..,"~" _.c:.,:i.i<1- ~, " .:;,. " .~ ~~\ ~;\ .- }" :( ~: <- = .- - u:> I'.'. .r. c ~ - ~ BONITA L. BOTTOMLEY . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS. . NO. 95.572 CIVIL TERM . . . MARC W. BOTTOMLEY, . . Defendant . CIVIL ACTION. DIVORCE . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under the Divorce code was filed on February 2, 1995, on the grounds that the marriage of the parties is irretrievably broken. 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 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, I verify that the statcments madc in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, ~ 4904 rclating to unsworn falsification to authorities. Dille: ~,A.s ,1995 - '",~~_l""""~ c~,t.~ MARC W. 1l0'IVI'OMLEYp . ",'. u:> (' '.-' I, .-;: <- c:: .- , ," ~I. . ~ ~ I . -~ ;.;..., .. _. ,~, I" .:.' ~ I .' ~ , ,~ -",..,' -.</'. ,J: -0 , "'" = .= uur1