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Home My WebLink About95-01262 , " q - . .,", "0(lS .,.,lj , ..<1S < " - I In 0- - --; 'c-~- :_~t~. ";;. ,if: --,- o Z .. r '.:<<. '.:c.'.:.:-'.:.:. .:+:- .:.:," .:+:.' ,:Co <.:.'.~. ,:c-"'.:+:. .:.:. .:.:. .:.:. .:.:. .:+:..:.:. .:+:. ,:,:,,)~:-:,:,:~,:.>::,:,:,:~,:,:,~;,:':'~':.:":':':"',<c-::<4CI::-;4 ~ M_ --- ~ ~ ~ po ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS ~ ~ ~ ~ .'~ ~ ? ~ OF CUMBERLAND COUNTY STATE OF ~~ rio" " , .... ~... \.o.A.t PENNA. ~.; ~ ~ ,'. ~ ,;, ~ ~ ~~ ,'. ~ ~ ~'- ~.; ~ ~ ~~ Q ',' :j ,'. ~ ~ ',' I, " ,'. 8 :'j ,;, ~ $ ~ M , i: W ',' r: ,'. ~ :,1 ~ ~5 ~ ~.~ W '.' ,'. ~ ~ t.~ W ~.I .;; ~ S .....................,......... ......,........ II Ii .." ..........,.......... d 'I ~ '.~ ,'. * ~ ',' ;', ~ ,', ~ : ~(.."h{;, C' tJujj;,., 4.-7f0;M71..;: I, :.:: ,-: '" ' /J' . ~ -? V I'" ~ 0;lJt ~P',../;V<..,e, ~.E'6. '. ' .. , .. (,'. ~ V 7 X)'7"7 Prolhonolnry l~ ~...>:;.~;.:-::.::--;;:w..~~-;::--;;;-;:.:~::+:.' ;:.::-::.;.-;:+:.-::t~' ,:.i. .:.:' .i.:. .:.:' .:.i, .:~:. '.:+:: -;:.i" .:+:. ::~:" .:.:: ::.:. .:.:: ::.;. .:.:,.:~i~ ....ROBERT.., W"..VIGGIANO" N (). ......,~,!?:7,g9.,2 ......"..'".... Il) w ~:~ ~ ~.~ ~ ... Vl'I'Sll:i , " ii , '....,.... ,[ II :1 " ,...A~~,.M...V:t;G,GIANQ , w ~.~ @ " .") w ~.~ ~ ~~ ~ ~.~ ~ ~': DECREE IN C fit 3; ~S-PJ1 ANDNOW.~,~{~,~~ 19 ,~L " it Is ordered and ~ " i, ?: ~ ~ I; ,~ ~ :; ~ ~.' decreed that". ., ..,. ,~9~~.R,~, ~.., .~~~?~~~~,.. .,.""""", " plaintiff, and...,."".... '" ,1\~~, M.., Y.I.qq+i\.N,C?." ",.,.,." .,.""" defendant, are divorced from the bonds of matrimony. The attached Agreement is incorporated herein. Jhg !8tfrt "rlt,.l~r i"r.4esi...I:"," _f tke fell.....:"a ...I....:....:, ..1,:,-1. Rg'W "h8811 I ai588 af rit8r&l fR fl.:.. '-'1\001:",,, fdf .';kie~ 9 fiA81 6. d~f L"",~ Ilvl 1'-o1,f. Riel. eflkr....,.I: ~ ~ ~.~ " ~ ~ ~.' ~ ,.' ~ ~ ,', ~ f-' . ..... ..... ............... ..... .... ...... .... II .0' ..........., . '0' ..... .... ....... ,0' " ...... ............ ..,.......... t;)~ 9~ ad. (bf-'d .i!>>t..1'. ~ 7":tt.tldtu (; 'CJ~ '?5 *10 I~~ tG ~ hu,.:/ tA ~r= ~ :lC' ~'" <>- t.I.Jl~':''1'''' t;;I. 0-- LD .;:~O~ CII '....:1:0> C") n....z-' . "'j>- (:SIt: U"I 'ju.",:z t-.lI _l1JL.J'Z: ~ :c.COW ....:cQ.. "" ...::> =>, 0'" -" ~ ,..I ~ < ~ I ;> ;!:; ;:: . . ~~I~i ~~ > I d<e~>j~~ I ~! ~! ~~ . 6 ~I::. :3: ei lQo:, I::.~ I . ,..I < ~ I ~ :s o . i < ' " , . ..' i .., it PROPERTY SETTLEMENT AGREEMENT TillS AGREEMENT, made this 'b ~ day of ~lA~ , 1995, by and between ROBERT W. VIGGIANO (hereinafier called "Husband") and ANN M. VIGGIANO (hereinafier called "Wife"). WITNESSETH: WHEREAS, Husband and Wife were legally married on October II, 1986, WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations, NOW THEREFORE, in consideration of the premises and covenants contained herein. it is agreed by and between the parties hereto that: (I) SEPARATION. It shall be lawful for each party at all times hereafier to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit, The foregoing provision shall not be laken as an admission on the part of eilher party of the lawfulness or unlawfulness of the causes leading to their living apurt, (2) DIVORCE ACTION. The parties acknowledge that they arc signing simultaneously herewith Affidavits of Consent indicnting their ngreement to the entry of n linnl divorce decree in the " ,. ! action for divorce between them filed by Ilusbllnd in the Court of Common Pleas of Cumberland I , i i I I I I ,j I I I County, Pennsylvllnlu, Vigldllno v. Vh!ldllno. No. 95-1262, on the grounds oflhe irretrievable breakdown of their murriage, and to hereby settle their respective related claims raised in that action, (3) INTERFERENCES. Each party sholl be free from interference, authority and control by the other, as fully os if he or she were single and unmarried. except os may be necessary to corry out the provisions of this Agreement. Neither party shall molest or attempl to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and aport from the other. (4) DIVISION OF REAL PROPERTY. The marital home at4110 Nantucket Drive has been sold with settlement projected to be on May 31, 1995, with eSlimated proceeds of $43,320. The net proceeds from the transaction sholl be adjusted SO/50 subject to 0 disproportionate adjustment which may be " i I I required in favor or Wife in order to cffectuate a SO/50 division of all of the marital assets. ~ ~l (5) DIVISION OF PERSONAL PROPERTY. The parties have dividcd betwcen themselves to their mutual satisfaction, personal effects, household goods and furnishings and all other articles of personal property which hove heretofore becn used in common by them, and neither party will make any claim to uny such items which arc now in the possession or under the control of the other, Should it become ..2.. .~ ! ncccssllry, cllch pllrty IIgrccs to sign IIny title or doculllcnts ncccssllry to give effect to this pllrugrnph, upon request. The distribution of the lll11jor IIssels of the Pllrties is 115 follows: To Ann: New York Life 20th Century [RA 403(b) Account $ 2,709.45 3.754,62 13.243,59 $19,707.66 (14,017,10) 5,690.56 30.165.4 I Less student 10lln IIssumed Sub-Totlll House proceeds. Totlll $35,855.97 To Robert: Stllte Fllrm Life EDS Pension 20th Century IRA's US SlIvings Bonds Merck Stock Abboll Stock $ 4,686.25 11.509.00 14,833,02 1,000,00 1,524.58 2.303.12 Totul $35,855.97 .Pllrties willlllso equlllly divide proceeds from house which exceed $30.165.41 to be pllid to Ann to equulize other IIssets. (6) TAX ON PROPERTY DIVISION. Husbllnd hereby IIgrees to PIlY 1111 income tllxes IIssessed IIgllinst him. ifllny, liS II result of the division of the property of the Pllrties hereunder. Wife hereby IIgrees to PIlY 1111 income tuxes ussessed uguinst her, if IIn)', liS II result of the division of the property of the -3. ,- ! purties hereunder, , , , The purties ucknowledge that they huve filcd u joint tux rcturn for 1994 , (; i' with the tux due puid und glned by Victor A. Viggiano for which the parties havc no t' 11 , I, I, I j responsibility, Husband agrees to indemnify and save hnrmless Wife with respect to any claim by Viclor A, Viggiuno concerning the same. The parties acknowledge thai they have previously filed joint income tax ! returns. [n the evel1l that uny additional tox liability, penalties or interest arc at any time hereaner assessed with regard to their said joint tax returns for failure 10 declare income or as a result of the disallowance of a claimed deduction. all such tax liability, penalties or intcrest shall be paid by and solely auributable to the party failing to dcclare the income or claiming the deduction, Each party shall indcmnify and save the other harmless from any lax liability, penalties or interest so assessed, as well as any other costs associated with an audit or other proceedings with the Internal Revenue Service or any other taxing authority, Each party shull be required to claim 1/2 of the capital gains on the house, shall be solely responsible for paying any laxes imposed on that share of the gain, and shall indemnify and save harmless the other with rcspeetto it. By this Agreement. the parties have intended to effectuate and by this Agreement have equally divided their marital property. The parties have detcrmined that such cquitable distribution conforms to a right nnd just standard with regard to the rights of each party. The division of existing marital properlY is nol intended by the parties to constitute in any way .4- I I ! i , I I' I ,. n snle or exchnnge of nsscts. and the division is bcing efTectcd withoutthc introduction of outside limds or olhcr propcrty not constituting a pnrt of thc mnrital estale. Neithcr party shal1 make any liIing with any tux uuthority or tuke uny position contrury to the provisions and intent of this pnrllgrllph. In thc evenlthat eithcr party breaches this provision, that party shal1 indcmnify and snve the other party hnrmless from any taxes, penalties or interest which arc assessed against the other pnrty as a result of that breach. (7) MOTOR VEIIICLES. Wife shal1 relain sole ownership of the 1987 Chevy Nova, and Husband shal1 retain the 1989 Chevrolet Blazer. (8) PENSIONS. Each of the parties shal1 retain his or her respective pensions, Wife waives any and al1 interest which she might have in Husband's EDS pension or retirement account. Husband waives any and al1 interest which he might have in Wife's 403(b) accounts (both T[AA. CREF and Vanguard), Both parties specifically. waive any and al1 rights each may have with regard to the other's pensions or retirement accounts under the Employee Retirement Income Security Act, as amended; and both promise to execute any spousal waivers or other documents as may be required to effectuate the provisions of that paragraph. (9) BREACH. I I' eithcr party breaches any provision of Ihis Agreement, the other party shall have the right, at his or her elcclion. to sue for damages for slleh breach, The party -, .5- ,- .. brellehing this eontrllet shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be availnble to him or her, (10) FULL mSCLOSURE. Husband nnd Wife each represent and warrant to the other thnt he or she has made a fullllnd complete disclosure to the other of nil nssets of any nature whatsoever in which such party of every type whntsoever nnd all other facts relating to the subject matter of this Agreement, (I I) ADDITIONAL INSTRUMENT. Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary on insurance policies, tux returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. I I' either party fails on demand to comply with this provision, that pnrty shnll pay to the other nil nttorneys' fees, costs and other expenses reasonably incurred as a result of such failure. (12) WIFE'S DEBTS. Wife represents and warrants to Husband that since the parties' 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 Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by " -6. , : her. (13) HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any deb I or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all elaims or demands made against her by reason of debts or obligations incurred by him. (14) WAIVERS OF CLAIMS AGAINST ESTATES. 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 may 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, curtesy, statutory allowance, widow's allowance, righlto 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 inlo elTect this mutual waiver and relinquishment of all such interests, rights and claims. (15) Iml'RESENTATION. It is recognized by Ihe parties hereto that Ann M, Viggiano is represented by Constance P. Brunt. Esquire. and that Robert W. Viggiano is represented by Louis J. Adler, Esquire. It is fully understood and agreed that the parties have the right to have advice of .7. " counscl prior to thc signing of this Agrccment. By the signing of this Agreement, cach of the parties understands the legal impact of this Agreement, and further intends to be legally bound by the terms of this Agrcement. (16) VOLUNTARY EXECUTION. The provisions of this Agreement arc fully understood hy both parties, nnd each party acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. (17) MUTUAL RELEASE. Except as provided for in this Agreement, the parties hereby remise, release, quit-claim and forever dischargc each other and the estate of cach other, for all time to come, and for all purposes whatsoever, from any and every claim, including alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or costs under the Divorce Reform Act or spousal support, or otherwise, that they make or hereafter make in and to or against each other's estates or any parts thcreof, whether by way of dower or curtesy, or under the intcstate laws, or the right to take or clect against the other's will, except only such rights as accrue pursuant to this Agreement. (18) ENTIRE AGREEMENT. This Agreement contains the enlire understanding of the parties, and there nre no representalions. wnrrunties. covcnnnts or ullllertakings other than those cxpressly sct forth herein. -8- l .' . , (19) NON.MEIWER IN I>IVORCE DECREE. The parties agree that in the event of obsolute divorce between them, they shall nonetheless continue to be bound by 011 the terms of this Agreement, ond neither Ihis Agreement, nor the terms hereof, shall be deem cd to hove been mcrged in ony deeree or judgment granted in the divorce action, but shall survive ond be forever binding upon the parties. (20) INCORPORATION IN JUDGMENT FOR DIVORCE. This Agreement and 011 of its provisions shall be incorporated into ony judgment for divorce obtoined by either party, eithcr directly or by reference. The court, on entry of judgment for divorce, shaH retain the right to enforce the provisions ond the terms of the Agreement. .. (21) PRIOR AGREEMENT. It is understood and agreed that ony and all property settlement ogreemenls which mayor have been executed prior to the date and time of this Agreement are null ond void and of no effect. (22) MODIFICATION AND WAIVER. Any modification or waiver of any provision 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 performance of any of the provisions of this Agreement shall not be construed as 0 waiver of any subsequent default of the same or similar nature. .9. .' . I I I 1 I j I I (23) GOVERNING LAW. This Agreement shall be governed by and shall be construed in accordance wilh the laws of the Commonwealth of Pennsylvania. (24) INDEPENDENT SEPARATE COVENANTS. 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 , i i agreement. :1 . (25) 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 void and continue in full force, effect and operation. (26) ENTRY AS PART OF DECREE. It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or proseeuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be made a part of any such judgment or decree of final divorce. (27) DOMESTIC RELATIONS CODE OF THE COMMONWEALTH OF PENNSYLVANIA. Except as specifically provided in this Agreement, both parties waive any -10. " . This agreement shall be binding upon the parties, their heirs, administrators, claims they may have against the other under the Domestic Relations Code of the Commonwealth of Pennsylvania including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable distribution of marital property. (28) 81NDlNG UPON ESTATE executors, successors and assigns. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written, WITNESS: '-zCl~ L?;JE Constance P. Brunt, Esquire ft! fj"r!:tpduj) o.4~fv 9n , V,'~~L--l) Ann M. Viggiano ' -11. . ,I . . COMMONWEALTH OF PENNSYLVANIA, COUNTY OF Dc1""'f\....''', )SS. ,...-( c- BE IT REMEMBERED, that on . :Jl.'-'<-'- -u , 1995, before me the subscriber personally appeared ROBERT W. VIGGIANO, known to me (or satisfactorily proven) to be the person whose name is subseribed to the within instrument and acknowledged that he cxecuted the same for the purposes therein contained. WITNESS my hand and seal the day and year aforesaid. , NOT ARIAL SEAL JODY GOLDRING, Notary Public Ilatrlcbilro, Dauphin County PA My Cetnmllllon expires No. 3. 11197 s~~~ Nota~y P~blic ) ( COMMONWEALTH OF PENNSYLVANIA, COUNTY OF JJI).<fJL-. )SS. , BE IT REMEMBERED, that on TL<-I Z- , 1995, before me the subscriber personally appeared ANN M. VIGGIANO, known to mc (or satisfactorily proven) to be thc person whose namc is subseribed to the within instrument and acknowledgcd that she cxeeuted thc samc for the purposes therein eontained. WITNESS my hand and sealthc day and year aforcsaid, ~~ Notary Public NcMNI s.l ConIllIt'CI p, BnJt. ~ PIda ~~~~~~~7 .12- ~: ... iE l!l M ~r:: t- ;r. ~~, t"l~~ _sr..~:1'" u.o-... ~~~'~'~I ; .;. 11I\" .'~ (t' ..,VI j;:u..,,';.rt N ;'~h,h;;t:I' _ h,......)~ ..: J: ,..'" (It,) ~ &! ofil ....I . 0 ~ ~ ~ fol8 ~! " ~ ~ rs:lr:! ~5 j;!. g;~ PI d" '!p~. ~ . HE< > ~ UH ~!8~1 N~ . ~ffi :x ~ "'0 F:'I::. PI~ ~ < ~ "' 0 ~ Cl . ....I. u; :I: t:l III ~ -< li! , - ,- .,' ...- .............-.. ....._._-~._.._.--_.---_.-_..- --_.~~--.~._.~.-... - -_...~_...... " , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 95-1262 ROBERT W. VIGGIANO, Plaintiff ANN M. VIGGIANO, Defendant I IN DIVORCE 0: ,~ '0 ACCEPTANCE OF SERVICE ..-,~ < ..;~. l .~, " , :," III ;~,!., . ...<.~.::i.' :;: 1". ,:'1"" .:-~ ~ ;::~ 1-.. ,., .-.-... ,- -to;'" ...... co , . I' <=> z: ...... =- = - c..c ....... I, Constance P. Brunt, Esquire, hereby acknowledge that I accepted service of theN~omplaint in Divorce filed in the above- captioned matter on 11A<J!6... ,r ' 1995, being authorized to do so on behalf of Ann M. viggiano, Defendant in the above-captioned matter. Date: J~tl?!- b~ Constance p, Brunt, Esquire 3901 North Front Street Harrisburg, PA 17110 (717) 232-7200 ROBERT W. VIGGIANO, Plaintiff v. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I I I I No. 95 - I du>:2 ANN M. VIGGIANO, Defendant IN 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 following pages, you must take prompt action. You are warned that if you fail to do GO, 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. 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, 1 Courthouse Square, 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. PROTHONOTARY'S OFFICE CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 , , ROBERT W. VIGGIANO, Plaintiff IN THE COURT OF COMMON PLEAS CUMB. COUNTY, PENNSYLVANIA v. No, ANN M, VIGGIANO, Defendant IN DIVORCE WAIVER OF COUNSELLING I, Robert W. Viggiano, being duly sworn according to law, depose and say: 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 counsellors 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. Sworn to and\subscribed before me this c"l \,- day of (f\(d'L_h , 199ft-';>. \ '::.A-~v, -,~"t ('}.,\..':'--'r NotarY\Public H01M\~M. SE,\L JOOY GOLOI!"," HQl,,1' ~"bllc Hlm.bult. O.up~ln Counly PA My C.mnlllilun ["pl,., Hu. 3, WJ1 ROBERT W. VIGGIANO, Plaintiff I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I No. I I I IN DIVORCE v. ANN M. VIGGIANO, Defendant ,gQMR!d~!H! COUNT I (Reauest for a No-Fault Divorce) Under Section 3301(0) (d) and (e) (6) of the Divorce Code 1. Plaintiff is Robert W. Viggiano, who currently resides at 3006 Market Street Road, Harrisburg, Dauphin County, pennsylvania, and has so resided since June 25, 1994. 2. Defendant is Ann M. Viggiano. 3. The last known residence and present whereabouts of the Defendant is 4110 Nantucket Drive, Mechanicsburg, cumberland County, Pennsylvania. 4. Plaintiff and Defendant have been bona fide residents in this Commonwealth for at least six months immediately previous to the filing of the Complaint. 5. To the best of ~laintiff's information, knowledge and belief, the Defendant herein is not in the military service of the United States of America nor any of its allies. 6. The parties married on October 11, 1986, at Harrisburg, ~ennsylvania. 7. There are no children of the parties under the age of eighteen. 8. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other . I jurisdiction. 9. This action is not collusive as defined by ~3309 of the Divorce Code. 10. ~laintiff has been advised of the availability of counseling and of his right to request such counseling. 11. The marriage of the parties is irretrievably broken. 12. the filing Affidavit After ninety (90) days have elapsed from the date of of this Complaint, Plaintiff intends to file an consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. 13. Should Defendant not file an Affidavit consenting to a divorce, then Plaintiff will submit an Affidavit at the appropriate time alleging that the parties have lived separate and apart for at least two (2) years. 14. In the event both parties do not submit Affidavits consenting to a divorce as indicated in Paragraph 13 above, it is averred that Defendant has offered such indignities to the Plaintiff (who is the innocent and injured spouse) as to render Plaintiff's condition intolerable and life burdensome. WHEREFORE, if both parties file Affidavits consenting to a divorce after 90 days have elapsed from the date of the filing of this Complaint, Plaintiff requests this Honorable Court to enter a Decree in Divorce pursuant to 93301(c) of the Divorce Code; or, should the parties fail to file said Affidavits consenting to a divorce, Plaintiff requests the entry of a Decree in Divorce , . . . pursuant to fi3301(d) or fi3301(a) (6) of the Divorce Code. I l:l DATED: ~\'\\9) yW Louis J. Adler, Esquire Attorney for plaintiff ADLER << CLARAVAL 125 Locust Street P. O. Box 11933 Harrisburg, PA 17108 Telephone: (717) 234-3289 Attorney 1.0. No. 07040 I , . . . : . , YEB!!!!gAI!QH I verify that the statements made in this Complaint 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. .W~t ., .) . 'ROBERT W. VIGGIANO, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBo COUNTY, PENNSYLVANIA NO. 95-1262 ,) ANN M. VIGGIANO, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 23 Pa. C.S.A. ~3301(c) of the Divorce Code was filed on March 10, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's 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. ~4904 relating to unsworn falsification to authorities. Dated: ~I 9\9< -mMr,J ~~~UiJ Robert W. Viggia~ Plaintiff " ",0 c:.., x-.. ;::UI:X: ." :r:M"'r~' ;,r.:U "T,l III U,r- ~u 1":"1 ~,,1-. -::'J ; rZ.....O ..:<.7:1; __I :;(")~~ i:g/.,~ ;.r:-f ...'* ...'" .., ? a: - r-.l w o on --0 .:>:: c..D U'1 . ," , ".' ROBERT W. VIGGIANO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 95-1262 v. ANN M. VIGGIANO, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 23 Pa. C.S.A. 53301(c) of the Divorce Code was filed on March 10, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer'S 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. ~4904 relating to unsworn falsification to authorities. Dated: / ,. /";' ;: ....- V'I t' ~;J^ , '? S " ,,); ) l,C/L-'_' 7 (~jl,\ (~,a.~'~U Ann M. Viggiano y___ Defendant . .. , , .' <-- $ ,II o c>.., C.. "\1 'X::r...' f"~~fn ;:' 7.!U "~J I" 7i-:t11.;' 1.(1)",(:10 .....,r. -t." r:-:4:JE"~ \..",~('] ;r.o(",.,;." '-t:';_, ".;I.p ~.~ - ,...... ,e...> .~ ,-<:] ~ ... ~ ... -. ,-..-, ~ .. .-.,.... .~ . ..! I. f.. l' v, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I No. 95-1262 I I I IN DIVORCE ROBERT W. VIGGIANO, plaintiff ANN M. VIGGIANO, Defendant Date: .f~~/~!- i2-iJir Constance P. Brunt, Esquire 3901 North Front Street Harrisburg, PA 17110 (717) 232-7200 ACCEPTANCE OF SERVICE I, Constance P. Brunt, Esquire, hereby acknowledge that I accepted service of theH~omplaint in Divorce filed in the above- captioned matter on lUlU/... lor ' 1995, being authorized to do so on behalf of Ann M. viggiano, Defendant in the above-captioned matter. . . . \~~ <:: >0.\:.:1 ;~!;~,,~, J" ;r:;a . t"~: ;," . ' ':. t;::r; ~i h...~n'" ""-:,:r. ::. b -.,.."tl"~ J:'; "-ojJ.. .,,')1 ., . . . ~ "" I'.> = C5 .t: W :bo ::c ...; l.r1 ., \ i .~ r '~...;-~s CONSTANCE P. BRUNT ATT'llllNTlY AT lAW ii NOTICE OF ELECTION TO RETAKE FORMER NAMF. ('qiE~ f;~f~~ '{t~ ,", ,~\ :l"i<" ,~;t{ "P" ''''t ~;t..! ~~j "f~ J ,'/i'iI' v'O.;-?::! r~ .i"~~i (I!l( :-i~.iij i~~~~ ,.:~,\ :"'" " ROBERT w. VIGGIANO, . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . CIVIL ACTION - LAW . . . ANN M. VIGGIANO, . No. 95-1262 Civil Term . . . Defendant . IN DIVORCE . Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in divorce bonds of matrimony on the c.?-1;:"~ay of --:fu Iu;._ from the 1995, " ~L//h '~Wc>' ~^-0 A N M. VIGGIANO " a~/Ji.~c~ , ANN M. McGEE " - ;~ '\l~_ , ~~ f :Y;l}>:' .~~ ',~'i~ ~] ....,..."... :!~~ Ji~t?~ ;/.<:,";,; q.," h'({ Iri;';~;; .~~1 -'1ft~;j l,;:.,~;;. ';:f,;~.~~ .h,'-~'.: I,;~" 1>."',\ !-(~:~ f"\ I) "H,_, !.;.:~i; f'" hereby elects to retake and hereafter uce her previous name of ANN M. McGEE. To Be Known As: COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS f)/.J/:! On the 7' day of Notary Public, personally ppe ed ANN be the person whose name is sUDscribed and acknowledged that she executed the therein contained. , 1995, before me, a M. MCGEE, known to me to to the within document, foregoing for the purpose IN WITNESS WHEREOF, I have Seal. hereunto set my hand and Notarial -~1.-dk\~,d~/l'-J ~ry Public ',';, Ilor:,r.tI,L ~EAL .",.,~U~D~ S.HEiiMMI, fl~lory ru~r,c H~rrlthu,u, Dauphin County tot c;aT.:.1ti.!.~fijC!tC~ Nc\'. 2"- !'.Hl ,- IN 'lllE OJ\JRT OF C(l.M)N PLEl\S OF CUMBERLAND rouNl"i, PENNSYLVANIA No. 95-1262 Civil Term ROBERT W. VIGGIANO, I, Plaintiff v. ANN M. VIGGIANO, Defendant NJI'ICE OF ELEXJ1'ION TO RETAKE FORMER NI\ME I CONSTANCE P. BRUNT All'llRNF.Y AT lAW J.9'113f1/11t Nnuh fmnl Succt U.rrlsbur~, I'A 17110 MX:171712.11,U155 1'1I0NE:171711Jl,71IKJ '" ~UG 1 3 30 \'Ii '95 :'. l~rnC€ \) r l' ..! "~J II:: ;\1,)' i',lWi":' J-Hf' (:"1'iT~ l'lhl,fi:\.J'~ t. ,i I(() 7 '" 0/ /).3:5 ;2p J ) f~ l r C~// I i, t