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HomeMy WebLinkAbout95-01061 :~. . 71 -g ~ , I', , , ;' " , " -, , ~ I ~ , J - -.9 o - I La a- . ~ , 'J,~ "r} ';, :,'< ,'" , ':j~Xt ,:;~L' ,"( ,', '~:~;.:< ,;~'" ~~: ,", :'~'/,;" :',:,j,;c',. )', ~F:,-~,'~~<('2::~>:'~:i;{~> ,',' ]T: " : _,/::"::'i.."d,: ,r,;:~' .' .,-'..... ,'" ". " ." .. Y:~"::f: . , . '.' .' " "..,~. " " . ' ',' .. ":.,:,::, " . .' .':::,;;..,..'.< :;:.. ,> '.. '" '" : .'''; ;..} I';' ': ',J','" ",', " ',,'....',' ,'. " ,:,::',' " : ,'::;';,.'';; ~.~,::,' ',,', ,:;:"'" ,'j' . , .','",..,: ." "" ;.." ,."" ',:, , ..' .. .'." , ",:'.. ;, ," " '" ",,:,,;\,,';'~:;;::'/,;:,:" ," ,):.;: :",',' ",". "'.':...,,','.',:,..,4. , ',.' :.' ',' ,,</>C";", "..' , . , "," " .. :.',',',".' "':: ".,::, , , '".,' <';;~; ',,:, :,''-' ',";:";,', , " ;:' ',: ',':,:, '..' ,:' "i,,'."":'" ' ;;, ,,;',' ..,',;' ; ...'. '; ,,". >. ',' :>/.',' ""'>;,<';: "..~,.,::.:;.. .. ,'" ", ,'., ::~~;: ': ':.:.'" :: ",' ",':, .'..,':, ,.:,.',' :' .',': ".",;'-:-;'C::, ";'} ;, ..." 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DECREE IN D I V O)R C E AND NOW, .~Ja#....l~.O.~.~.., left.Gt is ordered and decreed that ....~ A.. .<W.Il . .. . . . . . . . . . .. . . . . . .. . . . . . . .. . ., plaintiff, and..,......... .~~~.~: .~............................., defendant, are divorced from the bonds of matrimony. ~ '.' ~ '.' w '.' ~ ,; $ ~ ~ ~ S The court retains jurisdiction of the following claims which have been raised of ,~eFord in this action for which a final order has not yet been entered; \VO~ The parties hereby incorporate their Separation .,..,.... . A&reenettt'dated' AiJgtiSt. 25; .199S.into.t!ilii)decree;...' ....................................,..;-:..~.:'............. $ $ ~ ,o' S 8 " ~ , ~ ,'. ~ " " ,~ ~ ~ 9 a70 4f ad-, ~ ~ ~ (l. 7't~~'&111 9'~ ~ '71~ ~ ~ 'zlf /J'/~~..a/ .... ~ . STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-1061 DEBORAH B. GOOD, I Defendant I IN DIVORCE ~CIPE TO THE PROTHONOTARY I Please file the attached Separation and Property Settlement, dated August 25, 1995, to the above-captioned matter. Respectfully Submitted, ARTHUR T. MCDERMOTT & ASSOCIATES ~/;ty) Arthur T. McDermott, 50 East High Street Carlisle, PA 17013 (717) 243-7807 (, ~ . - Esq. CCI Roger Morgenthal, Esquire Attorney for Defendant 11 East High Street Carlisle, PA 17013 ~ ., SEPARATION AND PROPERTY SETTLEMENT AGREEMENT ft. A THIS AGREEMENT Made this 2.5- day of 111-\~ 1995 by and between Deborah B. Good, (hereinafter referred to as Wife) and Steven A. Good, (hereinafter referred to as Husband)i WITNESSETH I WHEREAS, the parties hereto were married on November 25, 1989, in Cumberland County, Pennsylvaniai have been and are Husband and Wifei and as a result of this union, one child was born to wit I Benjamin David Good, born November 10, 1992, hereafter referred to as the "child". WHEREAS , diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of WIFE and HUSBAND 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 specificationi the settling of all matters between them relating to the ownership and equitable distribution of real and personal propertYi settling of all matters between them relating to the past, present and future support and/or maintenance of the wife, the settling of any and all claims and possible claims by one against the other or against their respective estate. NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which 1 ~! " is hereby acknowledged by each of the parties hereto, WIFE and HUSBAND, each intending to be legally bound, hereby covenant and agree as follows I 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS I This Agreement shall not be considered to affect or bar the right of WIFE or HUSBAND to a limited or absolute divorce on lawful grounds as 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 occurred prior to the date hereof. The parties intend to secure a mutual consent divorce. 2. EFFECT OF DIVORCE DECREEI 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. 3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE I The parties agree that the terms of this Agreement shall be incorporated into any divorce decree which may be entered with respect to them. 4. SEPARATION I It shall be lawful for each party at all times hereafter to live separate and apart from the other party as such place 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 lawfulness or unlawfulness of the causes leading to their living apart. 2 ~! . 5. INTERFERENCE I 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. 6. WIFE'S DEBTS I 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 harmless HUSBAND from any and all claims or demands made against him by reasons of debts or obligations incurred by her. 7. 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 WIFE 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. B. MUTUAL RELEASE I Subject 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 any or all causes of action from breach of any provisions of this Agreement. 9. REAL PROPERTY I The marital home at 21 Big Spring Terrace, Cumberland County, Newville, ahall be the property of Husband, Steven A. Good. Husband shall purchase Wife's equity in the property for the sum of One ($1.00) Dollar and no/cents. The property is currently up for sale, upon settlement the Wife will execute any and all documents required for her interest in the property. The Wife will further release any interest in the proceeds from this sale. 10. DIVISION OF PERSONAL PROPERTY: (a) The parties have heretofore divided their personal property to their mutual satisfaction. Henceforth, each of the parties shall own, have and enjoy, independently of any claim of right of the other party, all items of personal property of every kind, nature and description and wheresoever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE respectfully, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. All items of personal property shall be divided between the parties as provided hereinl (b) Personal Effects: All items of personal effects such as, but not limited tOI jewelry, luggage, sports equipment, hobby collections and books, but not including furniture or any property, personal or otherwise specifically disposed of pursuant to this agreement, shall become the absolute and sole property of 4 ~, -, that party who has had the principal use thereof or to whom the property was given or for whom it was purchased, and each party hereby surrenders any interest he or she may have in any such tangible personal property of the other. (c) Intangible Personal prol?erty (other than Life Insurance), All stocks, bonds, cash, and sums on deposit in checking and saving accounts (owned by either or both parties) have been or will be divided to the mutual satisfaction of the parties. (d) Furniture and other Tangible property, All furniture and other tangible personal property not disposed of pursuant to other paragraphs of this agreement shall be the property of the Wife. (f) Debts: The Husband shall be responsible for for the following joint debts and liabilities incurred by the parties, to wit: PNC Credit Card, Farmers Trust Credit Card, Ford pickup truck and 5th wheel camper financed by PNC Bank. The Husband shall also be responsible for any and all debts in regards to the property at 21 Big Spring Terrance. THe Husband shall also be responsible for all existing debts and liabilities incurred in his own name prior to the separation. The Wife shall be responsible for all existing debts and liabilities incurred in her own name prior to the separation. (g) The parties further agree that neither will incur any future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, 5 ~ . that party incurring such debt will hold the other harmless from any and all liability thereon. 11. AFTER ACQUIRED PERSONAL PROPERTY' Each of the parties shall hereafter own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, hereafter 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 for all purposes, as though he or she were unmarried. 12. CUSTODY, The parties shall share legal custody of their son, Benjamin David Good, born November 10, 1992. Wife shall have primary physical custody of said child, and husband shall be entitled to liberal vistation with the said child, at such times, places and for such amounts of time as the parties may mutually agree between them. Neither party shall permanently remove the said child from the CODllllonwealth of pennsylvania without the consent of the other, or without a specific Court Order permitting the same. In the event that the parties are unable to resolve any controversies which may arise in the future as to the custody or vistation concerning said child, either party shall have the right to apply to a court of competent jurisdiction for a hearing on the matter. 13. ALLOWANCES TO WIFE AND CHILDREN, The HUSBAND agrees to pay to the WIFE, the sum of $45.00 per week for the maintenance and support of the child during the period when the child is in the WIFE's custody. It 6 " is the Wife's intention to deposit $25.00 per month into the child's college fund. 14. COUNSEL FEESI Each party shall pay his or her counsel fees and expenses. 15. DIVORCE I The parties hereto agree to enter into a mutual consent divorce. HUSBAND agrees to pursue the divorce and to be the Plaintiff therein. WIFE agrees to sign the necessary documents, including an Affidavit of Consent and further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 16. WAIVER OF CLAIMSI Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she shall now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, 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 administrator 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 waiver and relinquishment of all such interests, rights and claims. 17. BREACH I 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 or seek such other 7 remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 18. VOID CLAUSES I 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, 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. 19. DESCRIPTIVE HEADINGS I The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 20. INDEPENDENT SEPARATE COVENANTS I 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. 21. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonable required to give full force and effect to the provisions of this Agreement. 22. APPLICABLE LAW I This Agreement shall be construed under the laws of the COJlllllonwealth of Pennsylvania and more specifically under the Divorce Code of 1980. 8 23. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and ehall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 24. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 25. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict I I I I i 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. 26. WAIVER OF RIGHTS. The parties hereto have been informed of their rights or have been advised to seek counsel to inform them of their rights under and pursuant to the the Divorce Code, Act of April 2, 1980, Number 1980-26, particularly the provisions for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. From the date hereof, each party may acquire either 9 Steven A. Good Plaintiff IN TIlE COORT OF CO+ION PLEAS OF Ct.MBERLM'D COlMt'Y. PENNSYLVANIA NO. 95-1061 CIVIL 19 \'5. Deborah B, Good Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Trans~it the record. together ~ith the following information. to the court for entry of a divorce decree: 1. 'Grounds for divorce: irretrievable breakd~n under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Restricted delivery. certifiprl mAil nn MAr~h ~J 1QQ~ 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff July 7, lqqc; by the defendant September 7. 1995 " B. (1) Date of execution of the plaintiff'S affidavit required by 'J Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: none I 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code ~-~-- >-~,r' c L ____-~--,~~ ~"-_ Attorney for Plaintiff/~ STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 'i ';. lOt. I C4rJ -ru- DEBORAH B. GOOD, I Defendant I IN DIVORCE NOTICE TO DEPEND AND CLAIM RIGHTS YOU HAVE BEEN SUBD IN COURT. If you wish to dafend 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT PILE A CLAIM POR ALIMONY, DIVISION OP PROPERTY, LAWYER'S PEES OR EXPENSES, BEPORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OP 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 TBLBPHONE THE OPPICE SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Arthur T. McDermott, Esquire ARTHUR T. MCDERMOTT & ASSOCIATES Pifty East High Street Carlisle, PA 17013 (717) 243-7807 STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. DEBORAH B. GOOD, I Defendant I IN DIVORCE COMPLAINT IN DIVORCE COMES NOW, plaintiff STBVBN A. GOOD, through his attorney, Arthur T. McDermott, Esquire and avers as follows: COUNT I - DIVORCE 1. Plaintiff is Steven A. Good, who currently resides at 21 Big Spring Terrace, Newville, Cumberland County, pennsylvania. 2. Defendant is Deborah B. Good, who currently resides at 144 peach Lane, Carlisle, 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 November 25, 1989 in Cumberland County, pennsylvania. S. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. 7. Neither party is a member of the United States Armed Forces. - f'oo ... <.:) , ;S ~ f~ ..... .......0.3 J '..... VI o p. (:) ?, '" "" . ..,.; " II' 0 .J ., . 'I ~ iR "'.. ~.... f-~ UI",.,..:,., C,)2:C..~ l;:\~t.>...t_ "-~q;:" ,~,'h 'l:".1 . <: "": >- r;~.ft:;;j~ -:~ 14J It I J': ~:r::o~ . "'h.'.:l: '" ~l",.," ~ iE "" <Y) C"') ~ ~ L..: STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-1061 DEBORAH B. GOOD, I Defendant I IN DIVORCE AFPIDAVIT OP SERVICE BY HAIL PURSUANT TO Pa. R.C.1P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA I I SS COUNTY OF CUMBERLAND I Arthur T. McDermott, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaintiff, STEVEN A. GOOD, and that he did serve a true and correct copy of Plaintiff's Complaint in Dh'orce and Notice filed in the above matter, by mail certified, restricted delivery, return receipt requested, to the Defendant, DEBORAH B. GOOD, on March 6, 1995. The receipt form is attached hereto as Exhibit "A". ~~~ Arthur T. McDe ott, Esquire - "J 1/ Sworn to and subscribed before me this .:.L day of March, 1995. c:. J...,J 8EAI. llEBM L. ~I..r.. HaTNff ~ CAfUIl,J: BORO. CUMIIEJI>>lD COUNN t.ft'COlie is:IN..... .1l5lt .~JNIII.1_ . "........_MoMloCW~;" ot H"'_ ; I :>:~}i.,~~'.fj3};~{_;;:!iJ~<:':j)J~vr::0~~ t~~~~;~, _ -;< , ' <:\wp51\\lDpr\PIdI\Oood.p\III!' , . n L , , ( STEVEN A. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 1061-95 IN DIVORCE v. DEBORAH B. GOOD, Defendant TO THE PROTHONOTARY: Kindly enter my appearance In the above-captioned divorce action on behalf of Deborah B. Good, Defendant. FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for Defendant Dated: ~' J I (-/q ,- I ' By:--/~1MIl~ Roger M. Morgenthal, Esquire 10 # 17143 11 East High Street Carlisle, PA 17013 (717) 243-5513 STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-1061 DEBORAH B. GOOD, I Defendant : 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 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 statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties unsworn falsification to ting to Date: 'J--7-'1.i'(' ~ Sworn \~, , to and , 1995. subscribed before me this I~ day of ~ ) -' ~~ Notary Pub~ c ~ Notanal Seal , Daniel J, Morton,S... Nolary Public t Silver Spring Twp.. Cumberland coun~ My Commission exnl'es Oct. 24, 199 Me!rIler, Ponnsytvar~oI """"... ~ Ln~)->.... - C'"') ..t~ u_.". :c - W~:':,'--:". -:z :t: -r. ~':""' (. -~ --J".I _'. ~ &,l:::~::,,_.::.._. ..". N.. or.._ ~ .-:. ,~,' ,~ "'- 1 " ~.~' >-- .::'l~! en ~ i:Xt'l.. --- -:;:) .....C. :5 ..~,=-' -, -~ 2. I understand that the court maintains a list of counselors in the Domestic Relations Office, which available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the Court. marriage list is STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. : CIVIL ACTION - LAW I NO. 95-1061 DEBORAH B. GOOD, I Defendant I IN DIVORCE WAIVER OF COUNSELLING STEVEN A. GOOD, being duly sworn according to law, deposes and saysl 1. I have been advised of the availability of marriage counselling and understand that I may request that the Court require that my spouse and I participate in counselling. I understand that false statements to the penalties of 18 Pa. C.S. sectio falsification to authorities. subject unsworn A. GOOD -r- \ Sworn \I U Y to and 1995. L ~ subscribed before me this 7-/1... dal' of \ -- ....~ ""- ----- Notary Public --- Notarial Soal '1 Danlol J. Morton, Sr.. Notary Publl~ ' Silvor Spring Twp., c~mborlai1d C~~::: My Commission ExplroS Oct. 24.., , ,. Morrbof, pennsytv.................. 01 Nab'" ~ - ;.... -'L.... ...-,-;. ,~J;:~:; ~.::?.::: ,...I 'r ~.;v,.! ~ "'I'...=t- :z:= ~ "', N' - - en - -Sf .. ~~; STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-1061 DEBORAH B. GOOD, I Defendant I IN DIVORCE AFPIDAVIT OP CONSBNT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 28, 1995. 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 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 authoritie~ ' ~ Date I ~/ 7/90- ~RAH ~~{d _ ' d ~ JSworn to and subscribed before me this 1 eJ\ day of \,...A J!l -1::.. ,1995. , Lr)QLlLe.StznrY~~~'-~ ----, Notary pub~ NOT NlIAI. &EN. llEllfHE IlARHE'IlCA -, N>Ic CIlIIIt,~CoIny,P1. ltt~EJIlfto'" STEVEN A. GOOD, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-1061 DEBORAH B. GOOD, : Defendant I IN DIVORCE WAIVER OF COUNSELLING DEBORAH B. GOOD, being duly sworn according to law, deposes and saysI 1. I have been advised of the availability of marriage counselling and understand that I may request that the Court require that my spouse and I participate in counselling. 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 counselling 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. \. c; xJl r QLJelfl cd. ~d 2!!:- day of Sworn to and subscribed before me this e 1995. "-- ~ n::yA ~all C~ ~ otarJ lic !i~&EAL lIEllEHE IIAIlHE'IKI. ....., NIIIc C:-cr.i.C:-~