HomeMy WebLinkAbout95-01052
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA,
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ALIAN S. lolffiRCM, JR,
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KATHLEEN L. MERRa'J
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DECREE IN
DIVORCE
AND NOW, ...~\.2~.%........ 19.~L.,
it is ordered and
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decreed that.... .~.~...~,.~,......................... plaintiff,
and. . . . . .. .. . . . . . .~~ .~'..~ .. . . . . .. . . . . . . . . . . .. . . . ., defendant,
are divorced from the bonds of matrimony.
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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; \H9~
The Decree incorporates, but does not Jrerge, the Marital Settlerrent
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IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA,
: NO. 95-1052
ALLAN S. MERROW, JR,
Plaintiff
KATHLEEN L. MERROW
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
MARITAL SETTLEMENT AGREEMENT
1996,
THIS AGREEMENT, made this ~~ day of ~
by and between KATHLEEN L.MERROW ("Wife") ,
,
of
Mechanicsburg,
Pennsylvania,
and
ALLAN
S.
MERROW, JR.,
("Husband"), of New Cumberland, Pennsylvania.
WITNESSETH
WHEREAS, the parties hereto are Husband and Wife, married
on May 18, 1995 in New Cumberland, Pennsylvania.
WHEREAs, diverse,
unhappy differences, disputes and
difficulties have arisen between the parties and it is the
intention of Husband and Wife to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous
of settling fully and finally their respective financial and
property rights and obligations as between each other including,
without limitation by specification: the settling of all matters
between them relating to the ownership and equitable distribution
of real and personal property, and the settling of any and all
claims and possible claims by one against the other or against
their respective estates, as well as any other matters related
hereto.
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NOW THEREFORE, in consideration of the mutual promises,
covenants and undertakings hereinafter set forth and for other
good and valuable consideration, receipt of which is hereby
acknowledged by each of the parties hereto, Husband and Wife,
each intending to be legally bound hereby, covenant and agree as
follows:
1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to'affect or bar
the right of Husband and Wife to an absolute divorce on lawful
grounds if such grounds now exist or shall hereafter exist or to
such defense as may be available to either party. This Agreement
is not intended to condone and shall not be deemed to be a
condonation on the part of either party hereto of any act or acts
on the part of the other party which have occasioned the disputes
or unhappy differences which may occur subsequent to the date
hereof. The parties intend to secure a mutual consent, no-fault
divorce pursuant to the terms of Section 330l(c) of the Divorce
Code of 1980, as amended February 12, 1988.
2. EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically
provided herein, 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. 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. This Agreement shall be filed with the Court of
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Common Pleas of cumberland County and incorporated into the final
decree of divorce for enforcement purposes only,
3. DATE OF EXECUTION
The "date of execution" or "execution date" of this
Agreement shall be defined as the date of execution by the party
last executing this Agreement.
4. DISTRIBUTION DATE
The transfer of property, funds and/or documents provided
for herein shall only take place on the "distribution date"
which shall be defined as the date of execution of this
Agreement, unless otherwise specified herein.
5, CONSENT OF PARTIES
Husband and Wife acknowledge that they fully understand
the facts as to their legal rights and obligations under this
Agreement. Husband and wife acknowledge and accept that this
Agreement is, under the circumstances, fair and equitable and
that it is being entered into freely and voluntarily, and that
the execution of this Agreement is not the result of any
collusion or improper or illegal agreement or agreements.
6. FINANCIAL DISCLOSURE
The parties confirm that each has relied on the
substantial accuracy of the financial disclosure of the other,
except as set forth herein as an inducement to the execution of
this Agreement.
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7. PERSONAL PROPERTY
Except as set forth hereto, Husband and Wife have agreed
that their personal property, including any and all bank accounts
and motor vehicles, and further including the motor vehicle
currently used by Wife's son, have been divided to the parties
mutual satisfaction and neither party will make any claims to
said property possessed by the other. Specifically, Husband
shall have the items listed in Exhibit "A", which is attached
hereto and made part hereof, and Wife shall retain all other
personal property in her possession.
S. REAL PROPERTY
Husband and Wife agree that Wife shall have exclusive
possession of the former marital residence located at 1113 8aish
Road, Mechanicsburg, pennsylvania. Wife agrees to remove
Husband's name and liability from the current mortgage on said
property on or before July 31, 1997 through refinancing of the
mortgage or otherwise. In the event Wife fails to remove
Husband's name from the mortgage by July 31, 1997, the parties
agree to immediately list the property for sale and sell said
property. Any and all proceeds from the sale of the property
before or after July 31, 1997, shall be given to Wife as her
exclusive property.
From the date of this Agreement hereto, Wife shall be
fully responsible for any and all mortgage payments, insurance,
taxes or any other expenses related to said property, In the
event Wife defaults in any manner on said mortgage, Wife hereby
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agrees to hold Husband harmless and indemnify Husband for any
liabilty arising from said default. In the event said default is
not cured by Wife, Wife agrees to list the property for sale and
sell said property prior to July 31, 1997.
9, ALIMONY -r;J.p.1-700 ,Ol> IYf>U.St: ...be.. /I Vil, ~~~. JrJ;ttj~
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Husband and Wi~e agree that Husband shal~ pay to W fe e
amount of $700.00 per month in alimony through December 1, 1997,
at which time Husband's alimony obligation and payments shall
terminate. In the event~fe re~arries, er Qa hubiLQL~b w!Lh~
aRa~R~/nt..(i~t.!!l))"dor r:~ecember 1, 1997, alimony Shall,~'r!t
terminate as of the date of marriage <:,r aa1:_ vi _v habu;a1:~on" ~/ ~
:~e~': =::::~ hereto, .e 0' Februery 24,~~
1995, the date of final separation, each of the parties shall own
and enjoy, independently of any claims or right of the other,
all items of personal property, tangible or intangible, and/or
real property, acquired by him or her, with full power in him or
her to dispose of the same as fully and effectively, in all
respect and
unmarried.
for all purposes, as though he or she were
11. MARITAL DEBTS
Husband hereby agrees to be fully responsible for the
payment of the fOllowing marital debts:
A. Boscov's credit card
B. New CUmberland Federal Credit Union
C. Bonton credit card J
D. Ward's credit Cardl~JkJ5. c:~-j;. In... N'"'~ ~
E. VISA credit card)l'o D ,- O~- 'rJ"-'C.. lJ Q--.T--
F. Eyeglasses debt of $ 5 .00 ,,~t7aA JJ Jfq~
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12, WIFE'S DEBTS
Wife represents and werrants to Husband that since the
date of final separation, on or about February 24, 1995, she has
not contracted or incurred any debt or liebility for which
Husband or his estate might be responsible and Wife further
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represents and warrants to Husband that she will not contract or
incur any debt or liability after the execution of this Agreement
for which Husband or his estate might be responsible. Wife shall
indemnify and save harmless Husband from any and all claims or
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demands made against Husband by reason of debts or obligations
incurred by Wife.
13. HUSBAND'S DEBTS
Husband represents and warrants to Wife that since the
date of final separation, on or about February 24, 1995, he has
not contracted or incurred eny debt or liability for which Wife
or her estate might be responsible and Husband further represents
and warrants to Wife that he will not contract or incur any debt
or liability after the execution of this Agreement for which Wife
or her estate might be responsible. Husband shall indemnify and
save harmless Wife from any and all claims or demands against
Wife by reason of debts or obligations incurred by Husband.
14. PENSION AND RETIREMENT BENEFITS
The parties hereto, Husband and Wife, hereby specifically
waive their respective rights, title and interest in any and all
pension and retirement benefits of any kind of the other party.
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Said benefits shall become the sole a~d separate party of the
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said party in whose name the benefits are currently carried, free
and clear of all claims of the other party.
15. WAIVER OF RIGHTS
The parties hereto fully understand their rights under
and pursuant to the Divorce Code, Act of 1980, No. 1980-26, as
Amended February 12, 1988, particularly the provisions for
alimony, alimony pendente lite, spousal support, equitable
distribution of marital property, attorney fees and expenses.
Both parties agree that this Agreement shall conclusively provide
for the distribution of property under the said law and the
parties hereby waive, release and forever relinquish any further
rights they may respectively have against the other for alimony,
alimony pendente lite, spousal support, equitable distribution of
marital property, attorney fees and expenses.
16. PERSONAL RIGHTS
Husband and Wife may and shall, at all times hereafter,
live separate and apart. They shall be free from any control,
restraint, interference or authority, direct or indirect, by the
other in all respects as fully as if they were unmarried. They
may reside at such place or places as they may select. Each may,
for his or her separate use or benefit, conduct, carryon and
engage in any business, occupation, profession or employment
which to him or her may seem advisable.
Husband and Wife shall not molest, harass, disturb or
malign each other or the respective families of each other nor
compel or attempt to compel the other to' cohabitate or dwell by
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any means or in any manner whatsoever with him or her.
17. MUTUAL RELEASE
Husband and Wife each do hereby mutually remise, release,
quitclaim and forever discharge the other and the estate of each
other, for all time to come, and for all purposes whetsoever, of
and from any and all rights, title and interests, or claims in or
against the property (including income and gain from property
hereafter accruing) of the other or against the estate of each
other, of whatever nature and wheresoever situate, which he or
she now has or at any time hereafter may have; or any rights
which either party may have or at any time hereafter have for
past, present or future spousal support or maintenance, alimony,
alimony pendente lite, spousal support, equitable distribution of
marital property, attorney fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except,
and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any provision thereof.
It is the intention of Husband and Wife to give to each
other by the execution of this Agreement a full, complete and
general release with respect to any and all property of any kind
or nature, real, personal or mixed, which the other now owns or
may hereafter acquire, except and only except all rights and
agreements and obligations of whatsoever nature arising or which
may arise under this Agreement or for the breach of any provision
thereof.
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18. WAIVER OR MODIFICATION TO BE IN WRITING
A modification or waiver of any of the terms of this
Agreement shall be effective only if in writing, signed by both
parties and executed with the same formality as this Agreement.
No waiver of any breach hereof or aefault hereunder shall be
deemed a waiver of any subsequent default of the same or similar
nature.
19. MUTUAL COOPERATION
Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge and
deliver to the other party, any and all future instruments and/or
documents that the other party may reasonably require for that
purpose of giving full force and effect to the provisions of this
Agreement,
20. INTEGRATION
This Agreement constitutes the entire understanding of
the parties and supersedes any and all prior agreements and
negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
21. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective legatees,
devises, heirs, executors, administrators, successors and assigns
in the interest of the parties.
22. OTHER DOCtlMENTATION
Wife and Husband covenant and agree that they will
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forthwith and within thirty (30) days after demand or due date,
execute any and all written instruments, assignments, releases,
satisfactions, deeds, notes, stock certificates, or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement, and as their respective counsel
shall mutually agree, should be so executed in order to carry out
fully and effectively the terms of this Agreement,
23. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect
unless and until terminated under and pursuant to the terms of
this Agreement. The failure of either party to insist upon
strict performance of any of the provisions of this Agreement
shall in no way affect the right of such party hereafter to
enforce the same, nor shall the waiver of any subsequent default
of the same or similar nature, nor shall it be construed as a
waiver of strict performance of any other obligations herein,
24. BREACH
.
If either party breaches any provision of this Agreement,
the other party shall have the rights, at his or her election, to
sue in law or in equity to enforce any rights and remedies which
the party may have, and the party breaching this Agreement shall
be responsible for payment of attorney fees and all costs
incurred by the other in enforcing his or her rights under this
Agreement.
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.
25, SEVERABILITY
If any term, condition, clause or provisions of this
Agreement shall be determined or declared to be void or invalid
in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement and in all other
respects this Agreement shall be valid and continue in full
force, effect and operation. Likewise, the failure of any party
to meet his or her obligations under anyone or more of the
provisions herein, with the exception of the satisfaction of the
conditions precedent, shall in now way avoid or alter the
remaining obligations of the parties.
26. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania.
27. HEADINGS NOT PART OF AGREEMENT
Any headings preceding
the
text
of
the several
paragraphs/provisions and subparagraphs hereof, are inserted
.
solely for convenience of reference and shall not constitute a
part of this Agreement nor shall they affect its meaning,
construction or effect.
28. DIVORCE
The
parties
hereto
agree that their marriage is
irretrievably broken, and both parties agree to enter into a
mutual consent divorce under section 3301(c) of the Pennsylvania
Divorce Code of 1980, as amended February 12, 1988. The parties
further agree to sign the necessary documents, including any and
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.
.
Affidavit of Consent end Waivers required by law.
IN WITNESS WHEREOF, the parties hereto, have set their
hands and seals the day and year first above written.
witness:
,
12
ALLAN S. MERROW, JR. . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNA.
.
:
v. : NO. 95-1052
KATHLEEN L. MERROW . CIVIL ACTION - LAW
.
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit
the
Record,
together with the following
information, to the Court for entry of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under
Section (xl 3301(cl (I 3301(dl of the Divorce Code.
2. Date and manner of service of the Complaint: Qn
8/5/95 bv certified mail: see attached Affidavit of Accectance
of Service.
3. (Complete Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent
required by section 330l(c) of the Divorce Code: by Plaintiff on
6/20/96; and by Defendant on 6/21/96.
(b) (1) Date of execution of the Plaintiff's Affidavit
required by Section 3301(d) of the Divorce Code: N/A
(.2) date of service of the Plaintiff's Affidavit upon the
Defendant: N/A
4. Related claims pending: None/See attached Marital
Settlement Aareement.
5. Date and manner of service of the Notice of Intention
to File Praecipe to Transmit Record, a copy of which is attached
if the decree is to be entered under section 330l(d)(i) of the
Divorce Code: N/A
6, Date and manner of service of Notice of Intention to
file Praecipe To Transmit Record, a copy of which is attached, if
the decree is to be enterd under section 330l(c) of the Divorce
Code ; OR, date of execution of Waiver of Notice of
Intention 6/21/96; date of filing Waiver 6/24/96.
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James W. Abraham, Esq.
Attorney for Plaintiff
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ALLAN S. MERROW, JR. . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNA.
.
v. . NO. 96' -/~6';; {~tJ!~'tJ'"
.
KATHLEEN L. MERROW . CIVIL ACTION - LAW
.
Defendant . IN DIVORCE
.
NOTICE
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 may
proceed without you and a decree in 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, Cumberland County Courthouse,
Carlisle, Pennsylvania, and the Cumberland County Domestic
Relations Office, 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 BELCH TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Court Administrator
Cumberland County Courthouse, 4th Floor
1 Courthouse Square
CarliSle, PA 17013
(717) 240-6200
c-~
James W. Abraham, Esquire
Abraham Law Offices
116 Locust Street
HarriSburg, PA 17101
(717) 232-7825
Attorney for Plaintiff
ALLAN S. MERROW, JR.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA.
v,
: NO.
KATHLEEN L. MERROW
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT
AND NOW, comes Plaintiff, Allan S. Merrow, Jr., by and
through his attorney, James W. Abraham, Esquire, Abraham Law
Offices, HarriSburg, Pennsylvania, and files the fOllowing:
COUNT I
DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiff, Allan S. Merrow, Jr., is an adult
individual who
currently resides
at 1313
Oak Lane, New
Cumberland, Cumberland County, Pennsylvania.
2. Defendant, Kathleen L. Merrow, is an adult individual
who currently
resides at
1113 Baish Road, Mechanicsburg,
Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident of the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on May 18, 1985
in New CUmberland, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties hereto.
6. The marriage is irretrievably broken.
CERTIFICATE OF SERVICE
. ., .
I, James W. Abraham, Esquire, the undersigned, hereby
certify that I have served a true and correct copy of the
foregoing document, by certified mail, return receipt, upon the
following person(s), on the date indicated below:
Kathleen L. Herrow
1113 Baish Road
Hechanicsburg, PA 17055
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DATE: /l.. ~i'-9r
JAMES W, ABRAHAM, ESQ.
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ALLAN s. MERROW, JR. . IN THE COURT OF COMMON PLEAS
.
Plaintiff CUMBERLAND COUNTY, PENNA.
v. . NO. 95-1052
.
.
,
KATHLEEN L. MERROW . CIVIL ACTION - LAW
.
Defendant . IN DIVORCE
.
AFFIDAVIT OF SERVICE
I, James W. Abraham, Esquire, the undersigned, attorney
for Plaintiff hereto, hereby certify that Complaint in the
above-captioned action, was served upon Defendant on september 5,
1995, by certified mail, as evidenced by the green return
receipt card, from the U,S. Post Office, attached hereto and made
part hereof:
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DATE: 6/24/96
ABRAHAM, ESQ.
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: IN THE COURT OF COMHOM PLEAS
CUMBERLAND COUNTY, PENNA.
: NO. 95-1052
, '
ALLAN S. MERROW, JR,
Plaintiff
KATHLEEN L. MERROW
Defendant
: CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on February 28. 1995.
2. The marriage of Plaintiff
broken and ninety (90) days have
and filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after
service of notice of intention to request entry of the decree.
and Defendant is irretrievably
elapsed from the date of service
I verify that the statements 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. Section 4904, relating to
unsworn falsification to authorities.
DATE:
I/~-f'
, 1996
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ALLAN S. MERROW, JR.
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 95 1052
KATHLEEN L. MERROW
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTBNTION TO REQUEST
ENTRY OF A DIVORCB DBCREB UNDBR SBCTION
3301(c) OF THE DIVORCE CODB
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 divorce is granted.
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 th~
prothonotary.
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.A SECTION 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES.
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: IN THE COURT OF COMMOM PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 95-1052
ALLAN S. MERROW, JR,
Plaintiff
KATHLEEN L. MERROW
Defendant
: CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301(c) of the
Divorce Code was filed on February 28. 1995.
2. The marriage of Plaintiff
broken and ninety (90) days have
and filing of the Complaint,
and Defendant is irretrievably
elapsed from the date of service
3. I 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 the 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.
'-
D"E~1 I1"'Q a I
, 1996
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 95 1052
CIVIL ACTION - LAW
IN DIVORCE
ALLAN S. MERROW, JR.
Plaintiff
KATHLEEN L. MERROW
Defendant
WAIVER OF NOTICB OF INTENTION TO REQUEST
BNTRY OF A DIVORCB DBCREB UNDER SBCTION
3301(c) OF THE DIVORCB CODB
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 divorce is granted.
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
prothonotary.
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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.A SECTION 4904 RELATING
'TO UNSWORN FALSIFICATION TO AUTHORITIES.
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