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HomeMy WebLinkAbout95-01701 . .', V) '7 :f:-:7i.--'. "~ iiit ',rW' 0" . ;" c""".:: ;.;i:'_ ~i:' . ~~(.~t "iV'_," c'~..,. : ~.\". € ~ J - o C- - ~**-~~**-**~*~'-*'~**'~~~-*'**~**--"9 . ~ ~_.-..-----.....----. -......~-----....-..----........-,-~ -... .......'~ --........---..~.----:-~..-~-~'-~:~---.-~,.-... ~_.......- ~_. ,...~. '-'~~-~'--'-'~-- -. ~ '...-~_....__.~.~ ~._~. ~-'-'-.~~-' ~, ~ M ' . : IN THE COURT OF COMMON PLEAS : ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ " ~ ~ ~ ~ ~ -.'" '".. '" .~:. .>>:. .:.:. .:.;. .:.:. .:.:. -:.:. .>>:. .:.:. ~ ~ " ~ ~ lil " ~ 8 ~ ~ s;, ... s;, " OF CUMBERLAND COUNTY STATE OF ,,~. ~J~~;A- . '( ..~.~, I' .... ~ ". ~ ',,.~.1 ...(' PENNA, LUCILLE G, DRAKE, ~ ;'\11, 95-1701. II) Plaintiff 8 ""1'..;11'; ~ " STEVEN C. DRAlm, w ... Defendant ~ $ s;, " DECREE IN I DIVORCE~JJJ..~S-A AND NOW.~ ..1k ..... 19"... ;",",d.,ad and decreed thot "',', ,L\1~r.,"l;~, ,q., ,!1~,~~~, , , , , , , , , , , , . , , , , , , . , , " plaintiff, and,,,..,,,,,, ,,~T~Y,Ef'!, C.., .t?~~!"E, "",..,. ..""" defendant. ore divorced from the bonds of matrimony. s;, ... The court retains jurisdiction of the following claims which hove been raised of record in this action for which a final order has not yet been entered; ,~~P,'1r:~ ~,i,qr), ~I.nd. pr,op,!r ty . S!~t,t, 1, ':'!I1.er)l, l\,qr'=''='!I1!~n t , d,aled, ,7 ,P~.1~~ll~r~ Ilr,e.l?Y ,I n,c9rp,qr: i) t~,d , , n,t,q , PH:> ,I:'! nil) ,Di.~or~,e, DeC:,r ee, , , , " ~... - ~+. /0,..4........ o-d.., yj:,'4 -' II" 111'1111101101,,1\' :!. .. .~~,.~,.~.~~.,~,.~,~,.~.,~,.~"~,.~.,:~.,~..~.~:-.~:,.~:.:~, ~ ',' w ',' ~ ',' ~ W ':0 *- ',' ~ ~, ~ ',' ,', ~ ,', ~ ~ .,. .. $ I, ~ ',' 8 ,;, " ~ ~, ~ ~ ',' ~ ,', $ .', ~ .', i': .. ,', \~ , (., I~ i' '.~ , , , ~ '~ , ' ,I. ,~: ~ ~ ~ '. .~ ,I SEPARA710N AND PROPERTY SETTLEMENT AGREEMEN1' THIS AGREEMENT, mude this l day of ...FeW(L 'C-' 1996, by and betwcen Steven C, Drake, hcreinafter referred to lIS "Husband", and Luellle G, Drake, hercinafter referrcd to as "Wife", WITNESSETH: WHEREAS, Husband and Wife werc lawfully married on July 5, 1980; and WHEREAS, two children were bom of this marriuge; and WHEREAS, certain differences have arisen between the partics as a result of which they scparated in October 1994 and now live separate and apart from one another, and arc d~irous, therefore, of entcring into an Agrcement which will distribute their marital property in a manner which is considered to be an equitable division of nil joint property, and will provide for the mutual responsibilities and rights growing out of the marriage rclationship; and WHEREAS, therc has been a complete disclosure ofthc eamings and property of each party, and each understands hislher rights undcr the Divorce Code of the Commonwealth ofPcnnsylvania; and WHEREAS, the parties hereto, after being properly advised by their respcctive counsel, Husband by his attomey, John W, Purcell, Jr, and Wifc by her attorney, Max J, Smith, Jr, have come to the agreement, which follows: NOW, THEREFORE, in consideration ofthc above rccitals and the following covenants and promises mutually made and mutually to be kept, the parties hcretofore, intending to be legally bound, covenant, promise and agrce as follows: I. Separation, It shall be lawful for cach Purty at alltimcs hereaftcr to live separatc and apart from the othcr purty at such place that he or shc may from lime to time choose or dcem fit. TIlc foregoing Sepantlon and Properly Settlement Agreement Page 2 provision shall not be taken lIS an admission on the part of either party of the lawfulness of the causes leading to their living apart, 2, Interference. Each party shall be free from interference, authority and contact by the other, lIS fully lIS if he or she were single and unmarried, except as may be necessary to cart)' out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other. nor in any way harass or malign the other, nor in uny way interfere with the peaceful existence, separate and apllrt from the other, 3. WIfe's Debts, Wife represents and WlUTlll1ts to Husband that since the separation she hIlS not und in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shull indemnify and save Husbund hunnless from uny und all claims or demands made - against him by reason of debts or obligations Incurred by her. 4, Husband's Debts, Husbund represents and WlUTlll1ts to Wife that since the sepamtion he hIlS not und in the future he will not contract or incur uny debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife hunnless from uny and all claims or demunds made against her by reason of debts or obligations incurred by him, 5, Outstanding Joint Debts. The parties acknowledge und agree that they have no outstanding debts und obligations incurred prior to the signing of this Agreement, except as follows: (a) EDS Deferred Compensation Loan (b) First Mortgage (c) Second Mortgage (d) Texaco (e) Choice (I) First USA (g) Sears (h) Discover (I) JC Penney 0> GMAC Vun Loan Separallon and Properly SeUlemenl Agreemenl Page 3 Wife hereby agrces to assume full responsibility for the payment and ultimate satisfaction of all of the above referenced dcbts and agrccs to indemnify, defcnd and hold husband harmless by reason of the same, such indemnification to include reasol1able allorney's fees, In the event that either party contracted or incurred any debts since Ihe date of separation, the party who incurred said debt shall be responsible for the payment thereof, rcgardless ofthe name in which the account may have been charged, and such party sholl indemnify, defend and hold the other party harmless from any claim or demand mode against that purty by reason of such debt. 6. Equitable Distribution or Marital Property. The parties hove attempted to distribute their marital property in a manner which confonns to the criteria set forth in ~350 I et. seq, of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that - it is the first marriage for Husband and Wife; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the purties; the contribution of each party to the education, training or increased earning power of the other party; the opportUnity of each party' for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party ,in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intendcd by the parties to constitute in any way a sole or exchange of assets, and the division of being effected without the introduction of outside funds or other property not constituting marital property, The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. A, Distribution or Person,al Property, The purties hereto mutually agree that they have effected a satisfactory division of the furniture, household fumishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and after the dale hereof be the sole and separate owner of all such tangible . personal property presently in his or her possession, and this Agreement shall have the effect of an Separation and Property Seulement Agreement Page 4 assignment or bill of sale from each party to the othcr lor such property as may be in the individual possession of euch of the parties hereto, The parties hereto havc divided bctwecn themsclvcs, to their mutual satisfaction, all items of tWlgible and intWlgiblc marital property. Ncither purty sholl make any claim to any such items of marital property, or of the separate personal property of either purty, which arc now In the possession WId/or under the control of thc othcr, Should it bccome necessary, thc partics each agrec to sign, upon rcquest, any titles or documents necessary to give elTectto this paragruph, Property sholl bc deemcd to be in the possession or under the control of either party if, in the case of tangible pcrsonal property, thc item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the CllSe of intangible personal property, if any physical or written evidence of ownership, such as passbook, - checkbook, policy or certificate of insurWlce or other similar writing is in the possession or control of the party. HusbWld WId Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits, except as stated herein, From and after the dote of the signing of this Agreement, both parties shall have complete freedom of disposition lIS to their separate property and any property which is in their possession or control, pursuant to this Agreement, WId may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or 811er marriage, WId neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to sllch disposition of property, B, Distribution of Real Estate, Husband sholl transfer to Wife concurrent with the execution of this Agreement, all of his interest in WId title to their jointly owned real estate at 245 Rich Valley Road, Mechanicsburg, Cumberland County, Pennsylvania in exchange for which Wife agrees to be solely responsible for the mortgage obligations, to GMAC Mortgage Corporation and l'ennsylvWlia State Bank as well as for the payment of all current and future taxes, insurance and utility bills relative to said real estate, Wife covenants and agrees to pay WId discharge said obligations on said premises, and agrees to indemnify Husband from any loss by rellSon of her default in the payment thereof, and agrces to save Husband harmless from any future S,parallon and Property Selll<",'1I1 AltrfO",'1I1 Page S liability with regard thereto, including the cost of defense und aClUal counsel Ices incurred to defend against an action brought IIllllinst him by virtue of her deflluh, NotwithstUllding the above, Ilusband shall PIlY the two mortgllgc obligations for the month of January 1996, and any portion of Februllry for which he remains in the home, in addition to the second mortguge for the month of Decembcr 1995, Wile shall be responsible for any other payments on account of said mortgages. C. Cash Distribution, In consideration for the transler of the above referenced real estate, Wife shall pay to Husband the sum of $16,000,00 upon the execution of this Agreement, and UII additional $4,000,00 on or before November 30,1996, Failure to pay the $4,000 by November 30,1996 shall resuh in the accrue of interest - at the rate of 10 percent from November 30, 1996, until the actual payment. 7, V chicles, Notwithstanding Paragraph 6 of this Agreement, Wile shall retnin possession and ownership of the 1990 Pontiac VUII presently in her possession, Husband hereby transfers all of his right, title and interest in said vehicle to Wife, In consideration thereof, Wife shall assume full responsibility for payment and eventual satisfaction of any and all liens presenl1y encumbering the vehicle, and to indemnify, defend and hold HusbUlld harmless for the same, Husband hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle at any time, upon demand, and further shall indemnify Wife for any costs, including actual counsel fees, incurred by Wife to enforce this provision, 8, Alimony. Both purties acknowledge and agree that the provisions of this Agreement providing for equitable distribution ofmnrital property arc fair, adequate and satisfactory to them, and are accepted by them in lieu of and in full and final seulement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony, Husband UIId Wife further, voluntarily and intelligemly, waive and relinquish any right to seek from the other any payment for support or alimony, Each purty shall indemnify, defend UIId hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indemnity to include the actual counsel fees of the defendant in any such future action, I), Custody, Legal custody of the purties' minor children shall be shared equally by the purties, with Wife retuining primary physical custody, and Husband having such temporary custody for purposes Separation and Property Settlement Agreement I'agc 6 of visitation as the parties may from timc to timc mutually lIgree, provided that Wifc ~hall filster and encouragc an ongoing relationship bctween Husband nnd his Children, 10, Alimony Pendente Lite, Counsel Fees and Expenses, Husbund nnd Wifc acknowledge nnd agree that the provisions of this Agrcemcnt providing for the cquitablc distribution ofmllrital property ofthc parties is fair, adequatc and satisfactory to them, Both purties shallnccept the provisions sct forth in this Agrccment in lieu of and in full and final seulemcnt and satisfaction of all claims and demands that either may now or hereancr havc againstthc other for alimony pendente lite, counsel fecs or expenscs, or any other provision for their support and maintenance bcfore, during and aner the commenccment of any procecdings for divorcc or annulment between the partics, Each party shall be responsible for his or her - own counsel fees, and each agrees to indemnify, defend and save the other harmless from any action commenced against the other for alimony pendente litc, counsel fees and/or expenses, II. Divorce, A Complaint in Divorce has been filed to No, 95-170 I Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, and either party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an Affidavit evidencing their consent to the divorce, pursuant to ~330l(c) of the Divorce Code, In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a Consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted, 12. Time of Distribution. The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transfcrred to the respective parties immediately upon the execution of this Agreement. All spousal support and other such obligations, including alimony, shall immediately terminate, The parties shall cooperate by executing whatevcr documents nrc necessary to effectuate a divorce under ~330I(c) or ~330l(d) of the Pcnnsylvania Divorcc Codc, and this Agrcemcnt to cooperate shall bl. enforceable by an assumpsit action for specific pcrformance, Howevcr, upon refusal to consent, all distributed property shall bc returncd to the Purty originally in posscssion, until thc timc of linal Dccree, Separallon and Property Setllement Agreement Page 7 13, Release. Subject to the provisions of this Agreement, each party has released and discharged, UIId by this Agreement does for himself or herself, and his or hcr hcirs, legal representatives, executors, administrators and assigns, release, indemnify (including actual legal fees) and discharge the other of and from all causes of action, claims, rights, 01' demands, whatsoever in law or equity, including equitable distribution, spousal support, alimony, counsel fees, alimony pendente lite, and expenses which eithcr of the purties against the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or under UIIY other statutory or common law, except any and all causes of action for divorce UIId all causes of action for breach of UIIY provisions of this Agreement. Each purty also waives his or her right to request marital counseling, pursuant to ~3302 of the Divorce Code, 14, Waivers of Claims AgaInst Estates, Except as herein otherwise provided, each party may - ' dispose of his or her property in UIIY way, UIId each party hereby waives UIId 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 allowUllce, widow's allowance, right to take in intestacy, right to take against the Will of the other, UIId right to act as administrator or executor of the other's estate, and any right existing now or in the future under the PennsylvUllia Divorce Code, as amended from time to time, 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 UIId relinquishment of all such interests, rights UIId claims, 15, Rights on Execution, Immediately upon the execution of this Agreement, the rights of each purty against the other, despite their continuing marital status, shall terminate and be as if they were never married, 16, Dreach, In the cvent of breuch of any of the terms of this Agreement, the nonbreaching party shall be paid, as purt of any award or judgment against the breaching party, all costs, including actual counsel fees paid to his or her attorney, 17, Incorporation In Final Divorce, Thc tcrms of this Agrecment shall be incorporated but shall not merge in the final dlvorcc decree between the partics, This Agreement shall survive in its entirety resolving the spousal support, alimony, property and othcr interests and rights of the parties under and pursUlmt to thc Divorce Codc of the Commonwcalth of Pennsylvania, This Agrccmcnt may be enforced Separallon and Property Selllement Aareement Paae 8 independently of Wly support order, divorce decree or judgment Wld its terms shall take precedence over same, remaining the primary obligation of each party, This Agreement shall remain in full force and effect regardless of any change in the marlin I status of the parties, It is warranted, covenanted and represented by Husband and Wite, each to the other, that this Agreement is lawful and enforceable and this warranty, covenunt and representntion is made for the specific purpose of inducing the parties to execute the Agreement. 18, Additional Instruments, Each of the purtles 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 reasonably required to give full force and effect to the provisions of this Agreement. 19, Separability. In case Wly provision of this Agreement should be held to be contrary to, or - invalid under, the law of Wly country, state or other jurisdiction, such i\1egality and invalidity shall not in Wly way affect the other provisions hereof, all of which shall continue, ncvertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate Wld undisputed covenWlt and agreement. 20, EntIre Agreement. This Agreement contains the entire understanding of the parties Wld there are no representations, warranties, covenants Wld undertakings other than those expressly set forth herein, HusbWld Wld Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution WId division of marital and separate property are fair, equitablc and satisfactory to them, based on the length of their marriage and other relevant factors which have been taken into consideration by the parties, Both parties hereby accept the provisions ofthis Agreement with rcspect to the division of property in lieu of and in full and final settlcment and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any Court of competent jurisdiction pursuant to Scction 3502 of the Divorce code or any other laws, Husband Wld wife each voluntarily and intelligently waive and relinquish any right to seek a Court ordered determination and distribution ofmnrital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agrecment. 21. Modll1catlon and Waiver, A modification or wuivcr of any of the provisions of this Agreement shall be effcctivc only if mude in writing and executed with the same formality as this Pa e 9 Se ration and Pro rt Settlement A reement Agreemenl. The failure of either party 10 insist upon strict performance of Ihe provisions of Ihis Agreement shall not be conslrued as a waiver of any subsequent default of the same or similar nature. 22. Intent. It is the intent of the parties by this Agreement to fully and finally foreclose any resort to the Courts for relief on the bllSis of any statute or case law presently existing or which may exist at some time in the future within the Commonwealth of Pennsylvania, including but not limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended. This Agreement has been drafted and accepted on the basis that such resorl1Vould constitute a breach under this Agreement, entitling the nonbreaching party to reimbursement for actual counsel fees. Other than as provided by the terms of this instrument, it is intended that the Court shall treat the parties as if they had never entered into a marital relationship. This Agreement shall be interpreted and governed by the laws - of the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms of this instrument shall govern. 23. Voluntary Execution. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counse\. 24. Descriptive Headings. The dcscriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 25. Agreement Binding on Heirs. This Agreement shall be binding and shall inure to the benefit ofthe parties hereto, and their respective heirs, executors, administrators, ,successors and assigns. 26. Reconciliation. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent II writing signed by the parties stating that this Agreement is null and void. NO. 95-1701 Civil Term CUMBERLAND COUNTY. PENNSYLVAN A CIVIL ACTION - LAW IN DIVORCE LUCILLE O. DRAKE. Plaintiff VB. STEVEN C. DRAKE. Defendant DECREE IN DIVORCE LAW OFFICE JAMES, SMITH & DURKIN p, 0, ROX 650 HERSIlEY. PENNSYLVANIA 17033.()MO . - --.. .... ". ,.'. . -.- NO. 95-1701 civil Term IN THJ:; COURT OF CO~lMON PLJ:;A~ CUMBERLAND COUNTY. PENNSYLVAN A CIVIL ACTION - LAW IN DIVORCE I':" ( ,.' . .' ...~. ..,.." ,. , I: I ~I . ' ,. LUCILLE G. DRAKE, Plaintiff " . I.... I. ......\ VB. STEVEN C. DRAKE, Defendant PRAECIPE TO TRANSMIT RECORD AFFIDAVIT OF SERVICE 1..\11' OFFICE JAMES. SMITH & DURKIN I', o. nox MH IWRSIIE\', I'ENNsYI.V,INIA 1711,1,1.IIMII ...... " vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- 17IJ/Civil Term CIVIL ACTION - LAW : IN DIVORCE LUCILLE G. DRARE, Plaintiff STEVEN C. DRARE, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following page., 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 ground for the divorce is indignities or irretrievable breakdown of marriage, you must request mar- riage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE 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 CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 3387 (717) 240-6200 (i) lit ! ():d{\-)) MAX J .SMIIIT~,.' 16R., Esquire Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN CIVIL ACTION - LAW IN DIVORCE . If L ~PR 3 3 3~ i'll '95 LUCILLE G. DRAKE, Plaintiff II ,'r I'I(:~ l, . '101'" If' f' _1 ~ . _ ' f ,II, .' I I - ~ i ,I 'l, \ '. ;; [' I .! I I r I t 1,', f,.,~',.~ V. STEVEN C, DRAKE, ~ ,___ {Uj Defendant /d5. J5SV ~~ J' /0. 0, 7ft]" ~-3i,- COMPLAINT IN DIVORCE c/!, ~jL( 1 til' Cq: S 7 t 3 3 ~w OFFICES JAMES, SMITH 8 DURKIN 20 VALLEY ROAD P. O. BOX 650 HER.\IlEY. PENNsYLV^NI^ 17033,0650 , " " " I " ,'1 '-1 I '! ~ l , , ' () 1"1 ;:-! .c. - ,If I .. I '_...i '! -', NO. 95-1701 Civil Term IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVAN A CIVIL ACTION - LAW IN DIVORCE FIEI1-"r,.,c,. ('" T'...... L:/I'/ Jr' .;0 -- . 1"'_ "! '. , I .1;',\,')_,....\.1 " J/..Ir % F\",129 h" 3: 113 LUCILLE G. DRAKE, Plaintiff L;'/;'.., , '--<'r ',- .,'t:./ .: t ..:' ',\ ,.,. l(j\"";:'\-~I\'\/"IJ\t.."'d , . "".j ..";,l vs. STEVEN C. DRAKE, Defendant AFFIDAVITS OF CONSENT WAIVERS OF NOTICE Li\W OFFICI: JAMES. SMITH & DURKIN 1',0, RlIX 650 HI:RSllliY. l'I:NNSYI.Vi\NIA 171133.11Mll