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:1 IN THE COURT OF COMMON PLEAS :
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.... .The. . Marriahge. Set.UelTll!nJ:. r.g~~~n.t. .o.f. .I;Q~ ~I:I;~Il~,. .<lC\t;~C! .ijQV~~ .~l 1995, I~
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shall have the same force and effect as if it had been originally entered as an I ~
Order of Court, provided, however, that said Agreement shall not merge with thisl..,
Order, but shall retain its contn';ctlldh!j,f.9Id r;i&nC!" as well. / : ~
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OF CUMBERLAND
STATE OF '*'
PENNA.
COUNTY
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.KIRK."..~,.
Plaintiff
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Defendant
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DECREE IN
DIVORCE
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AND NOW, .. .. .J\t l' /J....... ...... ., 19!1fi...., it is ordered and
decreed that .... ~ J(.. ~ .. .. .. . . . .. . . .. . .. .. .. .. .. .., 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;
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MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this 2 not day of /"l.(\ l^{.rj< 6.2 ~ ,
1995, by and between LISA M. SHUMAKER ("Wife") - AND - KIRK M.
SHUMAKER ("Husband"), at Harrisburg, Pennsylvania.
WHEREAS, the parties hereto are husband and wife having been
married on September 3, 1992, at Mechanicsburg, Pennsylvania.
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 desire to settle fully
and finally their respective financial and property rights and
obligations as between each other including, without limitation by
specification: settling of all matters between them relating to
the ownership and equitable distribution of real and personal
property; settling of all matters between them relating to the
past, present and future support, alimony and/or maintenance of
Wife by Husband or of Husband by Wife; and in general, the settling
of any and all claims and possible claims by one against the other
or against their respective estates.
NOW, THEREFORE, in consideration of the foregoing premises and
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, Wife and
Husband, each intending to be legally bound hereby, covenant and
agree as follows:
L Divorce and Separation. The parties agree to the entry of
a decree in divorce pursuant to Section 3301(c) of the Divorce Code
of 1980. Husband and Wife shall at all times hereafter have the
right to live separate and apart from each other and to reside from
time to time at such place or places as they shall respectively
deem fit, free from any control, restraint, or interference
whatsoever by the other. Neither party shall molest the other or
endeavor to compel the other to cohabit or dwell with him or her by
any legal or other proceedings. The foregoing provision shall not
be taken to be an admission on the part of either Husband or Wife
of the lawfulness or unlawfulness of the causes leading to their
living apart.
2. Division of Property. Husband and Wife agree that the
following constitutes an equitable distribution of the marital
property.
A. The following property shall become the sole and exclusive
property of Husband:
1) All property listed on Schedule "A" which is attached
hereto and incorporated herein
B. The following property shall become the sole and exclusive
property of Wife:
I) All property listed on Schedule "B" which is attached
hereto and incorporated herein.
C. Any remaining personal property not listed on Schedule
"A" or Schedule "B" shall be divided equally between the Parties as
they may agree.
D. The following real property shall be sold and the net
proceeds shall be subject to the distribution contained in
paragraph 2E of this Agreement:
1) Marital residence located at 14 Austin Street,
Wellsboro, Pennsylvania.
E. The parties hereby agree to an equal distribution of the
net proceeds from the sale of the marital residence in the Amount
of $17,903.73, the net equity in Husband's 1994 Silverado Club Cab
and the net equity of Wife's 1993 Wave Runner Jet Ski. The net
equity of Husband's 1994 Silverado Club Cab is hereby established
in the amount of $9,000.00 and shall be credited to husband's
equitable distribution account and the net equity in the 1993 Wave
Runner Jet Ski is hereby established in the amount of $2,000.00 and
shall be credited to Wife's equitable distribution account. The
total equity of 28,903.73 shall be distributed as follows:
Husband's share of $14,451.86 shall consist of the the $9,000.00
equity in the Silverado Club Cab and $5,451.86 in cash; Wife's
share of $14,451.87 shall consist of the 2,000.00 equity in the
WaveRunner Jet Ski, $10,219.10 in cash and the sum of $2,232.77
used at settlement on the marital residence to payoff the loan on
the WaveRunner Jet Ski.
3. The parties agree to execute any deeds, assignments,
titles or other instruments necessary and appropriate to accomplish
the aforesaid division of property.
4. Unless otherwise stated herein, all property transferred
hereunder is subject to any existing lien or liens whether set
forth herein or not. The respective transferee of such property
agrees to indemnify and save harmless the other party from any
claim or liability that such other party may suffer or may be
required to pay on account of such lien or encumbrance.
5. The parties represent and warrant to each other that the
property described in this Agreement represents all of the property
in which they have any right, title and interest, and that such
property is subject to no mortgage, pledge, lien, security
interest, encumbrance or charge except those which are disclosed
herein.
6. By this Agreement the parties have intended to effect an
equitable division of their jointly owned property. The parties
have determined that an equitable division of such property
conforms to a just and right standard, with due regard to the
righte of each party. The division of existing marital property is
not intended by the partiee to constitute in any way a sale or
exchange of assets, and the division is being effected without the
introduction of outside funds or other property not constituting a
part of the marital estate. It is the intention of the parties to
treat all transfers herein as non-taxable.
7. Except as expressly provided herein, Husband forever
relinquishes any right and interest he may now or hereafter have in
any assets now belonging to Wife, and Wife forever relinquishes any
right or interest she may now or hereafter have in any assets now
belonging to Husband.
S. Each of the parties shall hereafter own and enjoy
independently of any claim or right of the other, all items of
property, be they real, personal or mixed, tangible or intangible,
which are hereafter acquired by him or her, with full power in him
or her to dispose of the same as fully and effectively, in all
respects and for all purposes as though he or she were unmarried.
9. Debts. Husband and Wife agree to be responsible for the
joint debts of the parties as follows:
A. Husband shall be solely responsible for the payment of
the Penn Central Federal Credit Union for the purchase of his
truck, Wife shall be responsible for the payment of the remaining
balance on account of the Wave runner Jet Ski. Husband shall
refinance the truck loan with Penn Central Credit Union.
10. All debts, contracts, obligations or liabilities incurred
at any time in the past or future by either party will be paid
promptly by said party, unless and except as otherwise specifically
set forth in this Agreement; and each of the parties hereto further
promises, covenants and agrees that each will now and at all times
hereafter save harmless and keep the other or his or her estate
indemnified and save harmless from all debts or liabilities
incurred by him or her, as the case may be, and from all actions,
claims and demands whatsoever with respect thereto, and from all
costs, legal or otherwise, and counsel fees whatsoever pertaining
to such actions, claims and demands. Neither party shall, as of
the date of this Agreement, contract nor incur any debt or
liability for which the other or his or her property may be
responsible, and shall indemnify and save harmless the other from
any and all claims or demands made against him or her by reason of
debts or obligations incurred by him or her and from all expenses,
legal costs, and counsel fees unless provided to the contrary
herein.
11. Full Disclosure. The respective parties do hereby
warrant, represent and declare and do acknowledge and agree that
each is and has been fully and completely informed of and is
familiar with and cognizant of the wealth, real and/or personal
property, estate and assets, earnings and income of the other and
that each has made a full and complete disclosure to the other of
his or her entire assets and liabilities and any further
enumeration or statement thereof in this Agreement is specifically
waived.
12. Releases. Each party does hereby remise, release,
quitclaim and forever discharge the other and the estate of the
other from any and every claim that each other may now have, or
hereafter have or can have at any time, against the other, or in
and to or against the other's estate, or any part thereof,
including any present or future pension benefits whether arising
out of any former contracts, engagements or liabilities of the
other, or by way of dower or claim in the nature of dower, widow's
rights, or under the intestate laws, or the right to take against
each other's will, or for support or maintenance, or of any other
nature whateoever, except any rights accruing under this Agreement.
13. Indemnification. Each party represente and warrants to
the other that he or she hae not incurred any debt, obligation, or
other liability, other than deecribed in this Agreement, on which
the other party ie or may be liable. Each party covenants and
agreee that if any claim, action or proceeding ie hereinafter
initiated seeking to hold the other party liable for any other
debts, obligations, liability, act or omission of such party, such
party will at his or her sole expense, defend the other against any
such claim or demand, whether or not well-founded, and that he or
she will indemnify and hold harmless the other party in respect of
all damagee as resulting therefrom. Damages as used herein shall
include any claim, action, demand, loss, cost, expense, penalty,
and other damage, including without limitation, couneel feee and
other coets and expenses reasonably incurred in inveetigating or
attempting to avoid same or in opposing the imposition thereof or
enforcing this indemnity, resulting to Husband or Wife from any
inaccurate representation made by or on behalf of either Husband or
Wife to the other in thie Agreement, any breach of any of the
warranties made by Husband or Wife in this Agreement, or breach or
default in performance by Husband or Wife of any of the obligations
to be performed by such party hereunder. The Husband or Wife
agrees to give the other prompt written notice of any litigation
threatened or instituted against either party which might
constitute the basis for a claim for indemnity pursuant to the
terms of this Agreement.
14. Waiver of Pension Benefits. Husband and Wife agree that
each of them shall execute any and all documents necessary to
release and waive forever any right, title or interest Husband or
Wife may have in any present or future benefits each may have in
the other's retirement plan (which is defined to mean any pension
plan or account, Profit Sharing Plan or account, IRA account, 401
(K) account, or any other plan or account for retirement or
deferred income. It is specifically agreed that each party's
rights under his or her respective plans constitutes his or her
separate property. Specifically include in this waiver are
Husband's Employee Savings plan and Prudential Variable
Appreciation Life plan.
15. General Provisions. 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.
16. Fair and Equitable Contents. The provisions of this
Agreement and their legal effect have been fully explained to the
parties by their respective counsel. Each party acknowledges that
he or she has received independent legal advice from counsel of his
or her selection and that each fully understands the facts and has
been fully informed as to his or her legal rights and obligations.
Each party acknowledges and accepts that this Agreement is, under
the circumstances, fair and equitable, and that it is being entered
into freely and voluntarily after having received such advice and
with such knowledge, and that execution of this agreement is not
the result of any duress or undue influence and that it is not the
result of any collusion or improper or illegal agreement or
agreements.
17. Breach. It is expressly stipulated that if either party
fails in the due performance of any of his or her material
obligations under this Agreement, the other party shall have the
right, at his or her election, to sue for damages for breach
thereof, to sue for specific performance, to rescind this
Agreement, or to seek any other legal remedies as may be available,
and the defaulting party shall pay the reasonable legal fees for
any services rendered by the non-defaulting party's attorney in any
action or proceeding to compel performance hereunder.
18. Execution of Documents. Each party shall on demand
execute any other documents that may be necessary or advisable to
carry out the provisions of this Agreement.
19. Applicable Law. This Agreement shall be construed under
the laws of the Commonwealth of Pennsylvania.
20. Non-Herger. This Agreement shall not merge with any
subsequent decree in divorce between the parties but shall survive
such decree and be entirely independent thereof.
IN WITNESS WHEREOF, the parties hereto have set their hands
and seals the day and year first above written.
Witnessl
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L . SHUMAJ(
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COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF DAUPHIN
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Personally appeared before me, a Notary Public in and for the
aforesaid Commonwealth and County, Lisa H. Shumaker, who being
duly sworn according to law deposes and says that she is a party of
the foregoing Agreement and she executed same for the purposes
therein contained. 1_ r: . I
Witness my hand and seal this fI' day of 1/ ,AA,
1995.
,
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My Commission Expiresl
Not.llal Soal
Ellen Rosenbloom, Nolary Public
H.nllburg. Dauphin County
My Commission E'plros May 8. 1999
SCHEDULE A
1. Kitchen table and matching chairs
2. Refrigerator
3. Various kitchen utensils, pots, pans, dishes, etc.
4. Couch and matching chair
5. Black chair
6. 31" TV and stand
7. Coffee table and two end tables
B. Living room drapes
9. Various bed and bath linens, towels, washcloths, etc.
10. All lawn equipment (lawnmower, handtools, etc.)
11. Weight set
12. Freezer
13. Dehumidifier
14. Computer and computer table
15. Mantel clock
16. Wet suit, water skis, beach chair
17. Dining room table and chairs.
KIRK W. SHUMAKER .
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Plaintiff .
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v. .
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LISA M. SHUMAKER .
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Defendant .
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IN THE COURT OF COMMON ?LE~
CUMBERLAND, COUNTY, P~/: 2::
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95 1721 !:~: I
No. - ci;' C"
CIVIL ACTION -
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DIVORCe: ,
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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. Ground for divorce: Irretrievable breakdown under section
or 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: P~I'S""~'- kt.,c.1..
tJ-H t:L6 'It I f~t. .
3. Date of execution of the Affidavit of Consent required by
section 3301(c) of the Divorce Code:
by Plaintiff on ~u#'
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and by Defendant on
4. Related claims pending: NONE.
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Date: 'Jvc.)f >,. I fft.
BY~ S. L-
Mark S. Fenice, Esquire
l.D. .21358
2917 North Front Street
Harrisburg, PA 17110-1223
(717) 234-2401
Attorney for PLAINTIFF
KIRK W. SHUMAKER I
Plaintiff I
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v. .
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LISA M. SHUMAKER .
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Defendant .
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qj-- /7 2.{ ~e.....JJ.-w~
CIVIL ACTION - DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the 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 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, 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
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013-3387
(717) 240-6200
v
. '
KIRK W. SHUMAKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PA
v.
No.
LISA M. SHUMAKER
Defendant
CIVIL ACTION - DIVORCE
COMPLAINT UNDBR SBCTION 3301(c) OR 3301(4)
OF THB DIVORCB CODB
TO THB HONORABLB, THB JUDGBS OF SAID COURT:
AND NOH, comes Plaintiff, KIRK W. SHUMAKER, by his attorney, Mark
S. Fenice, and represents as follows:
COUNT I
DIVORCB UNDBR SBCTION 3301(c) OR 3301(4)
OF THB DIVORCB CODB
1. Plaintiff is Kirk W. Shumaker, who currently resides at 121
Lancaster Blvd., Mechanicsburg, Pennsylvania and has resided there
since on or about February 1, 1995.
2. Defendant is Lisa M. Shumaker, who currently resides at 904
Apple Drive, Mechanicsburg, Pennsylvania, and has resided there since
on or about February 1, 1995.
3. Both Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six (6) months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 5, 1992,
at Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties.
- 1 -
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and
that Plaintiff may have the right to request that the Court require
the parties to participate in counseling.
8. Plaintiff requests the court to enter a decree of divorce.
COUNT I
BOUITABLE DISTRIBUTION
9. Plaintiff repeats and real leges the averments of paragraphs I
through 8 which are incorporated by reference herein.
10. Plaintiff and Defendant possess various items of both real
and personal marital property which is subject to equitable
distribution by this Court.
WHBREFORE, Plaintiff requests this Court to equitably distribute
the marital property after an inventory and appraisement has been
filed by the parties.
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Me, . '
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Mark S. Fenice, Esquire
1.0. #21358
2917 NORTH FRONT STREET
By:
HARRISBURG, PA 17110-1223
(717) 234-2401
ATTORNEYS FOR PLAINTIFF
- 2 -
VERIPICATION
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. Section 4904, relating to unsworn
falsification to authorities.
Date:
5-23 -''is
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KIRK W. SHUMAKER : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PA
:
v. : NO. 95-1721 CIVIL
.
.
LISA M. SHUMAKER :
DEFENDANT . CIVIL ACTION - DIVORCE
.
ACCBPTANCB OF SBRVICB
I, LISA M. SHUMAKER, the above named defendant do hereby accept
Date:
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Camplaint filad!~~ ~~~
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service of the Divorce
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KIRK W. SHtJMAl(ER
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
.
.
v.
: No. 95-1721
.
.
LISA M. SHtJMAl(ER
Defendant
: CIVIL ACTION - DIVORCE
M'JfIDA vrr OF CONSENT AND
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on April 4, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) 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'. fees or expenses if I do not claim them
before a divorce is granted.
5. I have been advised of the availability of marriage
counseling, and understand that I may request that the Court require
that my spouse and I participate in counseling. I further understand
that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
Being so advised, I do not request that the Court require that my
spouse and I participate in counseling prior to a divorce decree being
entered by the Court.
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KIRJ<: W. SHUMAI<ER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 95-1721 CIVIL
LISA M. SHUMAI<ER,
Defendant
CIVIL ACTION - DIVORCE
A}l'}i'wA VIT OF CONSENT AND
WAIVER OF COUNSELING
.
1. A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on April 4, 1994.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) 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.
5. I have been advised of the availability of marriage
counseling, and understand that I may request that the Court require
that my spouse and I participate in counseling. I further understand
that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
Being so advised, I do not request that the Court require that my
spouse and I participate in counseling prior to a divorce decree being
entered by the Court.
KIRK W, SHUMAKER,
Plaintiff
va.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1721 Civil
LISA M. SHUMAKER,
Defendant
CIVIL ACTION-DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on April 4, 1994.
2, The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing of this Complaint,
3. I consent to the entry of a Final Decree in Divorce
after service of notice of intention to request entry of the
decree.
I understand that false statements herein ara made
subject to the penalties of 18 Pa.C.S,
unsworn falsification to authorities,
1 ~ .
DATE: I'f~._.~ ~.rr,c.
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KIRI< W. SHUMAKER IN THE COURT OF COMMON PLEAS
PLAINTIFF . CUMBERLAND COUNTY, PA
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v. No. 95-1721
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LISA M. SHUMAKER .
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DEFENDANT CIVIL ACTION - DIVORCE
WAIVER OP ROTICE OP IMTENTIOR TO REQUEST
ENTRY OP A DIVORCE DBCRBE UNDER SBCTIOR 3301(0)
OP 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.
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
falsification to authorities.
Date:
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: NO. 9';-1721 Civil Term
LISA M. SHUMAKER
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De:endant.
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~Fr!DAV!~ OF I~~~N~.ON TO
RESUME PRIO" ~AME
::)MNC~HEA:'':t: 0: PENUSY:"VAN:A:
SSe
CO~!'\TY. OF
Dauphin
Lisa M. Shumaker
ae:o:-cir.;
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~eing duly sworn
='~:ses ~nc says :~a: 3r.e is the
in :h~ ab~ve ~~l~ l~
Defenrlant
~r.~:~ a fina: d2:~ee ::orn ~ne ~~nds of ~a::iQ~n~ ~a3 en~E~&C a~c ~h~
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Lisa M. Wood
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=.~t:"~~cr:? ,
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w=i::e~ ~ctice av:~lng sale
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ac.::.rdance
;:)'::,vi!lions :;):
0: May 25,
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:.ne
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the
a~en=ec ~~:y ~3, ~9:3 (2; P.S. 98).
Vu~
Lisa M. Shumaker
!~=rn :0 and suoscr!bed :0
~e:e:"e me tor::.s
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Notarial Seal
Ellen Rosenbloom, Notary Public
Harrisburg. Dauphin County
My Commission Exp"e. May 8. 1999
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