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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE Or- i~~~~~
PENNA.
JOlIN \~. CIl\RK, III,
" 95-3002 CIVIL 'rER1
," II, ,
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NllNCY M. CLI\RK,
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DECREE IN 8
decreed that
JOlIN W. CLI\RK, III
NANCY M. CIl\RK
. plaintiff.
. defendant,
and"., .
are divorced from tho bonds of matrimony,
The court retains jurisdiction of tho following claims which have
been raised of record ill Ihis action for which a final ordor has not yet
been entered;
None.
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I.I~MC)YNE, JlENNkYI.\'ANIA 170.1a
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JOliN W. CLARK, III
"lalnllfl
IN TilE COURT m' COHHON I'I,EAS
OF CUHDERI,AND COUN'fY,
l'IlNNSYI.vANIA
CIVil, AC"ION - I,AW
NO. 'J~- 3t<ll.:!CIVIIJ "ERH
IN DIVORCE
VB,
NANCY H, CLARK
Ilelendant
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You have been Bued In court. II you vlsh to delend agalnBt. the claims set 10rth In
the 10regolng pages, YOII must take prompt act.lon. You are varned that 11 you tall to do
&0, the case may proceed vlthout you and a decree In divorce or ~nnulment may be
entered against. you by the court. A judgment may also be entered against you 101' any
other claim or reUel requested In these papern by t.he plalntll1. You may lose IIIOney or
propert.y or other rlght.s Important to you, Including cllstody or visitation 01 your
chlldren.
When t.he ground lor the divorce Is Indignities or irretrievable breakdown 01 the
marriage, you may request marriage counseling, A list 01 marriage counselors Is
available In the olllca 01 the I'rothonotary at:
Olllce ol the l'rothonotary
Cumberland County COllrt 1l0llse
Carlisle, I'ennsylvanla 17013
IF YOU DO NO'f Fl('~; A CLAIH ~'OR ALIHONY, IlIVISION OF I'ROI'ERTY, I,AWYIlR I B FEES OR
EX!'ENSEB BEFORE A lllVORCE OR ANNULHF.NT IB GRAN'fED, VOll HAY LOSE TilE RIGHT TO CLAIM ANY
OF "IlEH.
YOll SIlOll\,\) 'rAKE '1'11I B "AI'ER '1'0 YOllR I,AWYER AT ONCE. H' YOll DO NOT IlAVE A LAWYER OR
CANNOT AFFORll ONE, GO TO OR n;I,llI'Il0NE TilE OFFICE B~;" FORTIl BE(,{)W 'ro FIND OUT WHERB YOU
CAN Oil" I,EOAL IlEI,!'.
court. Administrator, Fourth Floor
Climber laud Count. V Court \lulIse
Cal'\IIIII', l'ellUBylvanla 1'/01]
Telephone: (717) 240-6200
, JOUN W. CLIIRK, III
Plaintiff
IN 'fUE COUR1' 01' COHHON PLEIIS
01' CUHHERLIINIl COUNTY,
PIlNNSYINIINIII
vs.
CIVil, IIC'I'ION - I,IIW
NIINCY H. CLIIRK
Delendant
NO. 9~-
IN 1l1VORCE
CIVIL 1'ERH
NOTICB,..Q!,_~VI\IM.BlkITI.Q1' COU~!H!!,I~l!
TO TilE WITIlIN-NIIHEIl DEI'ENDIINT:
You have been named as the Ilelendant in a Comlllaint in a divorce proceeding tiled
in the Court of COMlon Pieas 01 CUlllberland County. This notice is to advise you that in
accordance with Secllon 3302(d) 01 the Ilivorce Code, you lIay request that the court
require you and your spouse to attend marriage counseling prior to a divorce being
handed down by the court. II list 01 prolessional marriage counselors is available at
the Do_eslic Relations Office, 13 North Uauover Street, Carlisle, Pennsylvania. You are
advised that thla list Is kept as a convenience to you and you are not bound to choose
a counselor 11'011 this list. 1111 necessary arrangements and the cost 01 counselilllJ
sessioos are to be borne by you and YOllr spouse,
11 you desire to pursue counsl!!lng, you IIIUSt make your request lor c(JUnseling
within twenty days 01 the date on which you receive thin notice, Pal lure to do no will
constitute a waiver 01 your right to reqnest counseling,
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8. The Plalntlll requestn thin Court to enter a Decree 01 Divorce.
IIH8I81'0IB, Plalnllll requests this Court to enter a decree In dlvorl'll pursuant to
the Divorce Code 01 Pennsylvania.
COUIIT .ll-I!Q\I!'!'~J1IJB !l!!!T~J!ll!'!'!QH
9. During the courso 01 the Marriage, the parties have acquired nUMerous IteMS of
propert.y, both real and porsonal. which are held In joint nallle6 and In the Individual
naMe6 01 each 01 the parUe6 hereto,
IIH8IBl'OlB, I'lalnllll \,raY6 this Honorable court, alter reqnlrlng lull disclosure
by the Delendant, to equl tabl Y divide t he proper! y, both real and personal f owned by
the parties bereto as Marital property,
1 verily that the ntateMl!lltS lIIade in thin COlllplaint are true and conect. 1
understand that any talse atatelllents in this COIllplalnt are subject to the penalt.les 01
18 Pa. C,B. 4904 (unnworn 1aIBIllcalluIl to authorllles).
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JOlIN W. CORK, 111
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ANDI!B, VAllOIIN 6 llANOS
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8alllUe1 I,. An2s
Attorney lor Plalntill
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,JOliN W. ('I-^R~ , III. I IN TIW 1'11\111'1' OF l'O~l~ION
1'1.1111\ ill ) I'IFAU 01' l'tJ~llIlllIANIl ('llIINTY.
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1l..ll'lId,11I1 ) IN III VOIH'I;
W,uVRR 01" ltOTl.Ct; Of'~TuaJWLTO IlEQUIDlT ENTiY
01" A OIvmu:F. nl';r~RF.E lIND"~R H..~1~1.ION )'1011('1 OF 1'lIE DIVORCE conE
1. C'OllliPllt to 1tuI Pllt.V of it flllitl dp('l'tlp ill dlVot'l'P without
not.jl'l!.
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JOliN W. CLARK, I II ,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF'
CUMBERLAND COUNTV, PENNSVLVANIA
NO. 95 - 3002
NANCV M. CLARK,
Dsfendant
IN DIVORCE
ORDER OF' COURT
,
AND NOW, this '. I ',I
day of
" , r, J J(
1996, the economic claims raised in the proceedings having been
resolved in accordance with a separation and property settlsment
agreement dated October 10, 1996, the appointmsnt of the Master
is vacatsd and counsel can file a praecipe tranemitting the
record to the Court requesting a final decree in divorce.
BV THE COURT,
fur \t
lIarold E. shellY, P.J.
cc:
Samuel L. Andes
Attorney for Plaintiff
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Paul J. Espoeito
Attorney for Defendant
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SEI)AltATION ANI> pnOl'EltT\' SE'U'LEMENT AGREEMENT
TillS AGREEMENT, made this J LJ I.L day uf 0 l,lt.. L" / ,1996, by and
between JOliN W. CLARK III, (hereinafter referred tu as "Husband") and NANC\' M.
CLAnK, (hereinafter referred to as "Wife"),
HilT""'" C "'1'1 J,
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WHEREAS, the parties hereto arc Husband and Wife having been married on
September 18, 1970 at Harrisburg, Pennsylvania; and
WHEltEAS, twu children were burn uf this marriage, namely, Andrew Patrick
Clark, born April 24, 1975, and Jushua Paul Clark, born l\larch 12, 1982.
WHEREAS, certain differences, disputes and difficulties have arisen between the
parties as a result of which they intend tu live separate and apart fur the rest of their natural
lives, and are desirous of sellling fully and finaliy their respective financial and property rights
and obligatiuns as between each other, including, without limitation by specification: the sellling
of all claims between them relaling to the ownership and equitable distribution of their real and
personal property; the sellling of all mailers 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 5ellling of any and all claims and pmsible claims by one against the other or againsl
their respective estate.
NOW THEREFORE, in consideration of Ihe premiscs and of the mutual
promises, covenants and undertakings hereinafter set forth, Husband and Wife each intending
to be legally bound and to legally blnll Ihelr heirs, successors anll assigns hereby covenant,
promise and agree as follows:
1. SEPARATION
Husband and Wife shall at all times have the right to live separate anll apart from
each other and to resllle from time to time at such place or places as they shall respectively deem
lit, free froll1ll11Y control, restraint or interference whatsoever by the other, subject to the further
provisions of this Agreemcnt. Thc forcgoing 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 Iheir living apart.
2. HUSBAND'S nEill'S
Husband represents and warrants 10 Wife that he has not, and in the future, will
not contracl or incur any debt or liability for which Wife or her estate might be responsible llIId
shall indemnify llIId save Wife harmless from any and all claims or lIcmands made against her
by re.1son of debts or obligations incurrcd by him.
3. WII'E'S UEUl'S
Wife represents and warrants to Husband that she has not, and In the future, wlll
2
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 her.
4. OUTSTANDING .JOINT DEBTS
Husband and Wife acknowledge and agree that they have no debts which were
joinlly incurred during their marriage.
S. DISPOSITION OF MARITAL RESIDENCE
Husband and Wife acknowledge that the marital real estate located at 4950 Janelle
Drive, Lower Pax Ion Township. Dauphin County, Pennsylvania, has been sold to William and
Judith Costello and that settlement occurred on August 6. 1996. The parties acknowledge that
\he oulstandlng balance on the loan from Harrisburg Belco Federal Credit Union has been paid
in full. Wife shall receive no credit for the reduction in principal on said loan which was eaused
by her payments since the separation of the parties. The parties further agree that they shall
divide equally. after payment of W1Y and all closing costs, the remaining proceeds which are
currenlly being held in escrow by Frank Zulli in an accounl at Dauphin Deposit Bank & Trust
Company.
6. DIVISION OF I'ERSONAL I'ROI'ERTY
Husband and Wife acknowledge that they have effectuated a mutually satisfactory
3
division of all of their separate and marllal personal property.
7. DIVISION OF MISCELLANEOUS ASSETS
The parties hereby agree that Wife shall relain as her sole and separate property,
any and all bank accounts in her name, Belco savings account #059230, all of the Sun Bancorp,
Inc., Keystone Financial, Inc., Bell Atlantic, NYNEX, AT&T, Amerilech, U.S. West, Bell
South, Pacific Telesys and SBC Communications, Inc. stocks, her Savings & Securlly Account
with Bell Atlantic, her Bell Atlantic pension, any policies of life insurance of which she Is the
owner of rc~~ord and the 1991 Honda Accord EX.
The parties further agree that Husband shall retain as his sole and separate
property, all of tlle personal property presently in his possession, the 1977 MGB, 1984 Jeep
Cherokee, the Lincoln Continenlal, his Defined Benefit Pension Plan with H.P. McGinley, Inc.,
the proceeds from the profit-sharing plan with H.P. McGinley, Inc., any policies of life
Insurance of which he is the owner of record and Beleo savings account # 133350.
The parties shali immcdialely make arrangements to meet and execute any and ali
documents necessary to effectuate the transfer of ownership provided for in this provision.
8. EQUITABLE I>ISTRIBUTION OJ. MARITAL PIWI'ERTY,
SI'OUSAL SUI'PORT, ALIMONY, ALIMONY I'ENDENTE
LITE ANI) COUNSEL FEES
Husband and Wife acknowledge and agree that the provisions of this Agreement
providing for the division of their marital property are fair, adequate and satisfactory 10 them
4
and conform to the criteria set forth in the Pennsylvania Divorcc Codc, as amended, taking into
account all relcvant considerations, including those set forth In the Pennsylvania Divorce Code,
as amended. Husband and Wifc further agree to accept Ihe provisions set forth in this
Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands
that either may now or hereafter have againsl the other for equitable distribution of marital
property, spousal support, alimony, alimony pendente lite and counsel fees. Each party shall
indemnify, defend and hold Ihe other harmless against any fulure action for equitable distribution
of marital property, alimony, alimony pendente lile or counsel fees, such indemnity to include
the actual counsel fecs of the successful party in any such future action. Husband and Wife
acknowledge that Husband has instituted an action in divorce against Wife, which action is
docketed 10 No. 95-3002 Civll Term in the Court of Common PIcas, Cumberland Counly,
Pennsylvania. Husband shall proceed with said divorce action and the parlies agree that each
will execute an appropriale Affidavit of Consent imllledlately upon presentation of said
document.
9. HATE QIo' EXECUTION
The "date of execution" or "execution datc" of this Agreement shall be defined
as the date upon which it is executed by Ihe parties if they havc each executed the Agreement
on the 5.1me date. Otherwise, the "date of execution" or "execution date" of this Agreement
shall be defined as the date of execution by Ihe party last executing this Agreement.
5
10. ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained
to the parties by their counsel, Paul J. Esposito, Esquire, for Wife and Samuel L. Andes,
Esquire, for Husband. Each party confirms that he or she fully understands the terms,
conditions and provisions of this Agreement and believes them to be fair, just, adequate and
reasonable under the existing circumstances. The parties further confirm that each is entering
into this Agreemenl freely and voluntarily and that the execution of this Agreement is not the
result of any duress, undue innuence, collusion or improper or illegal agreement or agreements.
11. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
A. Each party hereby absolutely and unconditionally releases and forever
discharges the other and his or her heirs, executors, administrators, assigns, property and estate
from any and all rights, claims, demands or obligations arising out of or by virtue of the marital
relationship of the parties or otherwise, whether now existing or hereafter arising. The above
release shall be effective regardless of whether such claims arise out uf any former or future
acts, contracts, engagements or liabilities of the other or by way uf dower, curlesy, widow's
rights, family exemption or similar allowance, or under the inteslate laws, ur the right to take
against lhe spouse's will, or the right to treal a lifetime conveyance by lhe other as testamentary,
or all other rights of a surviving spuuse to parlicipate in a deceased spouse's estate, whether
6
arising under the laws of Pennsylvania, any slate, commonwealth or lerrilory of the Unlted
Slates, or any other country.
8. Except for any cause of action for divorce which either party may have or
claim to have, and except for the obligations of the parties contained In this Agreement as such
rights as are expressly reserved herein, each parly gives 10 the other by the execution of this
Agreement an absolule and unconditional release and discharge from all causes of action, claims,
rights or demands whatsoever, in law or in equity, which either party ever had or now has
against the other.
12. WAIVER OR MOIHFICA TION TO DE IN WRITING
No modification or waiver of any of the lenns of this Agreement shall be valid
unless in writing and signed by both parties.
13. NO WAIVER 01' UEI'AUllr
The failure of eilher party to insist upon strict performance of any of the
provisions of this Agreement shall in no way arfectthe right of sllch party hereafter to enforce
the SlIme.
14. LAW OJlI'EN!'iS.YLYMl'IA AI'I'L1CAIlLE
This Agreement shall he cunstrued In accordance wilh lhe laws of lhe
Cnllllnonwealth of I'ellnsylvanla,
7
15. AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be binding and shall
inure to the benefit of the parties hereto and Iheir respective heirs, executors, adminislrators,
successors and assigns.
16. INTEGRATION
This Agreement constitutes the entire understanding of the parties and supersedes
any and all prior agreemenls and negotiations between them. There are no representations or
warranlies other than those expressly set forlh herein.
17. OTIIER DOCUMENTATION
Husband and Wife covenant and agree that they will, (not more than ten (10) days
after demand therefor), execute any and all wrillen instruments, assignments, releases,
satlsfaclions, deeds, note or other such wrillngs as may be necessary or desirable for the proper
errecluation of Ihis Agreement.
18. HEAI>INGS NOT PART OF AGREEMENT
Any headings preceding the lext of the several paragraphs and subparagraphs
hereof are Inserted solely for convenience of reference and shall not conslitute a part of this
Agreement nor shall they affect its meaning, construction or effcct.
19. Al.0RNEYS FEES I'Olt ENI;ORCEl\mNT
In the event that eilher party breaches any part of this Agrecmcnt and the other
H
party retains counsel to assist in enforcing the terms hereof, the parties hereby agree that the
breaching parly shall pay all attomey's fees and court costs incurred by the other party in
enforcing Ihe Agreement, providing the enforcing party is successful in establishing that a breach
has occurred.
IN WITNESS WHEREOF, the parties hereto have setthcir hands and seals the
day and year lirsl above written.
WITNESSETH:
\ /-
(~'1tdl---___
. __JSBAL)
JOHN . CLARK III
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NANCY M. CLARK
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( ,1' !, (SEAL)
9
JOliN W. CLAR~ , IJJ. ) IN THE COUR'r 01' COMMON
I' Iii llIli II ) I'LEAU OF ClJMIIERI.ANIl COlJN'l'\' ,
) I'I,NNflYI,V AN lA
I
VII. I C1VJI. ACT JON - LAW
I
I NO. 9~-3002 CJ VI I. 'I'ERM
NANCY M. CLARK. I
Ue I endilllt I IN III VllRC (,
PLAINTIFF' 0 PilE-Till AI, OTATRMRNT
Plaintilf. by hill ilttorney. Samuel L. Andeu. fileu this Pre~rrial
statement in accordilllce with Pa, R,C.I'. 19~O.JJ(b):
1. ABOETO. Attached hereto alld marked as Exhibit A Is a !lilt ot
. the mat'itai asuetll 01 the partioll. Attached het"oto i\lld marked as Exhibit.
B is a list of the non-marila 1 assetll at the pal'lleu.
2. RXPB.lT 11I1'1'1I1':001':0. Plaintiff hopeu that export wltnessell will not
be necellllary becaulle the parties may be able to agree upon the value ot
their assets. 11 they Cilllllot agree, he I'enervell the dght. t.o call t.he
following expert witnellsell:
A. An apprailler t.o "utablillh tile value of the marital
residence.
B. An aPIlI'aluer to eutablillh tho value 01 the houllehold
conLentu and furllishings alld, If lIeCellllal'Y, the automobiles
oWIHHI by tho partlell,
C. An ,wtual-y to eutilbllllh tho villue of each partY'1l
pennlon.
U. An ilccoulILallt 01' otlll'r export Lo tnlce the lIoll-mal'ltal
lISSI!tU cOIlt.l'ol led by Wit n ami CiI leulat!! the amount by which
thon!! lIon-mal'IUII illHlnt B i IIC\'I',IIII!II dill' i IIg tlll! millT j age.
3. FACT WITNEBBEB. I'lnllltllf IlIlnll<lll t.o call himuolf IIU t.ho fact
willtellS III tI\I! t'aIHl. Ill. I'PlIl!rVllU tlw 1'1qht t.o call a<lellt.iollal WIt.IJ>'BIIIlU
to I'eupolld t.o allY 1~lillmll 01' I!vldl'llI'f' 6ubmltll!d by Wile au Ilelelldanl.
4. F.XlnnITB. 1'1i11111111 Inl."lIllB I.Il oll.l'l' illlo evld(!lIc(! lhe
followll1Y exhlblt.o:
A. 'I'ux l'I't.III'IIB 01 lhe Pdl'lleu IUI' ill IC!alll till! 1,10t j iVI!
yeal'o.
II. A lIollce oj plan h"lll!litu IIhowillY lhe !J"lwf its he hao
e.ulled w1thill t.he 11.1'. McGilllf,y. IlIc.. Ill'filled Delletil I'ension
I'lall.
C. An employee helleflt. statemelll ullowing t.he bnlallcll In
hl6 accollnt. wllhlll t.he 11.1'. MI'UIlIll!Y Il1'olit.-shlll'illg plan.
Il. A documellt. uhowillY t1w lll!lIef1t1l Wilu hila "Ilrlleel with
UII! lIell Atlnntic penalon plall.
E. IJocumenla showlny lite halallce In WHo'a Dell Atlantic
oavll1Yll and aecul'it.y piau alld ESOP.
F. Vill'louu slnlmnelll.u uhuwIIIY lhe value 01 lhe group of
slol!ku O\.llH'd Joll1l1y by the PUI'I.l(!S.
11. A 1)I'OUIJ III doculllent.u BhoWIIllJ lhe lIulIIIlI!l' 01 ahar'eo of
~eyut.one ~"III/tlwlal f'C!I',dved hy Will! /tu it t.1'illlUl el' Il'om her
lill.hel' <llld t hI! 11II'''''illl'' in Villi'" itlltl numlll!l' of r.hal'ell of that
II tlll'k l\lll I Ill) t hI! III ill 'I' j i\lJP.
II. A l)l'oUP 01 dlll'UIII('III11 IIhowlll'l I III' 111111I1)(>1' 01 6h.11'I'U of
lIulI lIi1neol p 1111', r"l'ld v 1'<1 hv W il,' il5 i' Il'nllB 11'1' I n)m hp-I' I ather
i11111 tht; 111I'\I'illlO III v'lllll' ,11111 IIUIIII"'I III Ilhd\lHl 01 thnt llt.ock
IIUI I 1111 t I'" mill 1 I ill) I' ,
!). 1I1l~()MH Q1'A'fF.MF.N1', IIl1l1h,'lId'll '/1"1111 11I"lIln" III uhuWII llll lhe lrllJome
<1\111 EXI"'IIIl" 1I1,11"lOl'nl \.11111'11 III '11\,11'111'" 111'11>\" "lid lIIillk.." illl hxhlhlt c.
b. RXPRIIRR DTATRMRNT. lIusbllnd'lI '!l\llllllUI!S III'.! uot ou\. on the Ineome
I and ExpenBe Iltatement att.llched hereto and marked as Exhibit C.
'1. PRIIDIOIiI INFORMATION. 1'111 ill 1.1 1f doeu not ye\. know \.ho lump Bum
value of the pennion benefits earlled by eaeh o( the par\.ieu. If the
partien cannot stipulate to a value, hI! lutelldll to call an actuary to
establish the value of tllose penBion benefits,
Il. COlDlRRl, FRED, Ne ither party has made iI e laim for counsel fees
or eosts.
9, PRRDOIJIAL PROPERTY. In the event the partieu cannot stipulate as
to the value and distribu\.ion o[ theue itemn, Plaintiff intends to have
them apprained and offer the testimony of an appraiser at the hearing.
The itemu consist of typical household furnishings and appliances.
10. "".ITAL DEBTR. 'rtle marital debtu known to Plaintiff have been
! listed on Exhibit A.
iI. PROPORBD RHROLt1l'IOIiI OF ECOIIOMIC URUER. Until such time as we
know the exact value of all the marital assets, ineluding the portion of
Wife's non-marital inveutments, it iB difficult \.0 formulate a firm
settlement proponal. However, it appears elearly tllat Wife enjoys
greater earnings than Husband and \.ha\. uhe enjoys far more substantial
investments because of the generosity of her father and, therefore, has a
far grea\.or ability \.0 acquire asue\.u in the future. Accordingly, a
division of the assets whereby lIusband receives 60 percent of the marital
asse\.s would he IIPPl'oprlu\.u Ullcll!l' the elrculllu\.ilnceu of thtu caue.
~~~;-^~----,--
A\.torlley 101' 1'1i1ln\.I((
Ilupreml! COllI'\. lU 1'1225
~)25 Nor! h l:.llh Illree\.
Lemoynl!. PA 1'/04:l
('fl'/) '/61 - ~):lh 1
RIHtRIT I - KlllTlL PIOPRRIY
DATE OF IWUTAL AIlOUJIT OF
ASSET VALUE VALUATION PORTION LIENS LIEN
Residence at 49~0 S20U,OOU.lJU 12/9~ 100\ Ill!! co S20,OOO.00
Janelle Dr! ve. (esl .) FI,deru1 (upprox. )
1I0rrisburg, \)Ruphln CTl'dl t
County, PA Union
lIousehold furnlshlnRs S20,OOO.OO 2/9~ 100\ None known N/A
and contents (eat. )
lIusband's Intereat In S21,790,44 2/95 100\ None known N/A
11.1'. McGinley, Inc. .
proClt-shoring plan
Wife's pension with Unknown N/A 100\ None known N/A
8ell Telephone
Wife's Interest In $13,2111. ~:l IU:11/9~ 100\ None known N/A
8ell Atlantic Savings
and Security Plan and
ESOP
Portfolio of $3,bf:l9.f:l1) ~/9~ 100\ None known N/A
corporate stocks:
bed tech, ATtrT, 8e 11
South. Nynex, Pacific
Telesis , S8e
eo..uulcotlous, Bnd
U.S. West
1,5UO.597 shores oC S42,Olb./2 11/9~ 100\ None known N/A
Keystone Financial
stock held In WICe's
na.e
An unknown nn.ber oC Vallie unknown N/A 100\ None known N/A
shares or Sun BanCorp
Inc.
EXHIBIT B - NON-MAIlITAI, PROPERTY
DA'I'E OF AMOUN'I'
ABllE'l' VALUE VALUATION LIENS OF
LIEN
1.686 shares 01 $47.208.00 4/95 None known N/A
Keystone Financial
stock
'i An unknown number 01 Unknown N/A None known N/A
shares 01 Bun DanCorp
Inc.
i NOTE: These items are recognized as non-marital property belonging to WHe becasue she
! received them as a gift Irom her lather during the marriage. Plaintiff has Included in
Schedule A, as marital property, the additional shareu o[ stock in these corporations
which were issued as stock dividends during the marriage and which, lor that reason,
, recognize the increase in value 01 the stock.
JOliN W. CJ.ARK. III, ) IN Tim COUll'!' 01' COMMON
1'lillnUll ) PLEAS Of ClIMlIEIlI,ANIl COllN'rY.
) PENNSYLVANIA
)
VII. ) CIVil. ACTION - I.AW
)
) NO. 9~-300~ CIVIL TEIlM
NANCY M. CI.ARK. )
Ilelendant ) IN III VORCE
nl~ aun RIPIDIIBB 8t'1'HIImIT OP PI~larrIPP
; I. 'lIlD1R
Mr. Clark is employed by Robert G. lIartman & Associates, Inc. lie is paid 814.00
an hour and is paid every two weeks. For a lull 80 hour pay period. his incoRle and
deductions are as follows:
Gross Pay (814.00 x 80 hourll)
LESS:
81.120.00
FIT
FICA
Medicare Tax
PIT
I.IT
Pa. UC
TOTAL TAXES
8113.12
869.44
816.24
831. 36
SlI.20
ll..ll
S242,,48
NET PAY EVERY TWO WEEKS
SSl'I.52
That equates to 81,901.29 per month.
UP"."
Attached hereto III a 11111.11 Plallltlll's monthly expenllen.
I understand Ulat lalse st.ltements herein ,He made subject to the penalties ot 18 Pa.
C.S. 4904, relatinq to unsworn lalsillcation to authorities.
IlATE:
,JOItN W. CI,ARK, 1 J 1
1
MONTHLY EXPKNOHO
Home
Mortgage/Rent.._...__.__......... _.. _...,___. ' _6b75.00
Maintenance. ...." . .. .. .... 6
Uti 11 ties (tefeiillone -;- hUI;l.lnlJ-'--eTp.I~irle. 'l;t(;:r=:'690. 00
i,
'! Employment (transportation, lunches),
_. G
. Taxes
Real Eotate ...." $
Personal Prnperty _~=.:..~~___.. _.~,===__-:::'''':'::-~__.__===~ $
Income_____.__.... _._., .,__..__...,.._____"."...... ....6
Ii
I
i Insurance
: Renters ... ........ " $I~.OO
Automob i le-..--'''-.-'''~=====~.=..~.:.-=..,='.:.~~__:=:=__==$
Li fe/Accident/Helllth_.. ____.._. ..._____,_ . _.... .".$
Other ,_____.,. ...._._.___._.__.___0
Automobile (payments, tuel, 1'0pllirs) ".....,"
Medical
Doctor/Dentist/Ortllodontlst).. .. .... $40.00
Hoopita 1__., ,,,_ .__....-.:.:.:.__,,_ ,___,,:_-::.:---==_:$
Opecial Needu (glauseo. hearing aid). ._....."'. $~O.OO
Educa tion
Private/Parochial
COllege__"
Schoo 1 )
(1
$
. Personal
Clothing.,_______ _,
Food
Other. (llarber;.lloliileIiCiTII lIuppi illS)
Credit paYlllonts and loan8""..
(Amerlclln Express, JC PunnIJY. MOllt.
$150.00
$~50.00
6fl!>.OO
$;J~~.OO
Walda & lloH~OV'U)
Miscellaneous
Household lIulp/Chlid ~ar"
Enter't.alnmllnt (papol'l;. 1J0(lkH. vacatlonB).
OirtH, ChllrllillJlro COlltrllJut j01l1l
Lc!ga 1 Feeu
Child Bllr1port/AllmollY pllymCJllt II
Other (ColIlIBollngl
t,
Y
$'/5.00
(l
(l
OW:!. ()Il
1/ :If,() , Illl
'1'01 a I MOllt hi Y !-:XIJIlII II IHi
$~.',!"~.Illl
t. .,
a.4. 01'1'.0"
KATZMAN Be SHI.....AN. P,C.
bolo "....IIT IIT..IIT .
.,..."'.....t !IOU,,"
1'. 0. !KI. ....
. ...aal.aUan. ".Il".""VA"'A IfIO.'III."
.
..
,
...
.
.
INCOME AND EXPENSE STATEMENT
OF
NANCY M. CLARK
INCOME
Employer:
IIELI, ATL^NT I C-PA, 1 NC
Address:
210 PINE STIlEET, 9TII FLOOR, IIAIlRISIIURG, PA 17101
Type of Work: CONFJIlENTI^L SENIOIl CLEIlK
Payroll Number: ']2']0
Pay Period (weekly, biweekly, etc.):
WEEKLY
Gross Pay per Pay Period:
Federal Withholding
Social Security
Medicare Tax
s
Biweekly
S
WEEKLY
Year-To-Date
572.
90.56
35.46
8.30
(School)
Local Wage Tax
2.86
State Income Tax
Ur: Tax
Retirement
School Tax
Savings Bonds
401K
Dues
16.01
.17
2.86
30.00
Life Insurance
Health Insurance
2.16
Supplemental Group Life
.10
Uental
Gl'OUp Hospital and
Major Medical
Net Pay per Pay Period:
s
s
$383.52
IlIVIIlENIlS FHOH STOCK
APPI{()XlfIATELY $I,IJIJIJ.IJIJ PEIl Ill/ART Ell
BXPENSES
Weekly Monthly Yeady
( Fill in appropdate colunUl)
Home
Mortgage $ $ $
Maintenance 544.
Utilities
Electric - PPbl. I()~.
Gas - I.effler -- 128.
oil
Telephone - M, ee 11111111' b APC 1112.
Water
Sewer 240.
Trash 115.
Homenwner'H AtHiOcinttnn 19.
Employment
Public Transportation $ 10. $ 85. $ 2118,
Lunch '15.
Taxes
Real Estate - 1.1' b Dallphln e$
Personal Property -Schnnl HI';
Income
Occupation - City of IIIUIt:
Personal Property - 1I11Il(;
In.uranca
$
$ 1.002.
1.125. 1l1SCOUNTIm
210. III SCOllNTF.ll
10.
14.
Homeowners - llSFbG
Automobile - (;eneral
Life - Protected I.1f.
Accident
Health
Other
$
Accldenl
$
$
lb8._
820.
102.
Automobile
Payments
Fuel
Repairs
Medical
$
$
- $---
w.
400.
Doctor - She Invn 1,1 b SIIiIl'kH $
Dentist
Orthodontist
Hospital
Medicine
Special needs (glasses,
braces, orthopedic)
$
!In.
80.
50 .
290. ANIlR~:W IIn1 y
.lllsh b NMC In
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MARITAL LIABILITIES
Item Description of Names of Names of
No. Liability All Creditors All Debtors Balance Due
1. Home Equity Belco Federal H & w $14/186.25
Line of Credit Credit Union as of 12/28/95
2. Charge Account Boscov's H & W
3. Visa Account Belco Federal H & W
Credit Union
,JOliN W. CLAIlK, III,
Plaintiff
I N 'I'll E COU Il'l' tH' Cl1~lMON I' LEAS Ill,'
ClIMIlElll.ANIJ COUNTY, PENNSYLVANIA
CIVIl. ACTIUN - LAW
.:.Lv 5 .
NANLi'i(Y M. CI.ARK,
Defendant
NO. 3002
CIVIl.
19 95
IN IJIVOIlCE
STATUS SIIEE1'
D^TE:
AC'I'IVJ'I'IES:
__ ___ _. .'.u._
1/16/96 R).'"/~;,,~ j~L'~' .:.:.?-/ Z<A;~.' .____,'___ ___,
- ,;-;--,;t:'n' ::';;k./IK-i "u_ /))It-/,--'/.}I(--- e;;~~ C 'el . m -
___L- 2J-L
f~i~'~7' '~ nn_,_ ,I.~-;~I ;1~~iJ~-'r~-:';-~-~:1;-(/ ).lj~/'-;-~~':-;:"-;--::-~~,7r'7~,~:fl..~.
.,'(}/ " ... " I 'i . . , I'Y'; . \ i
_ ____~~__~__,_______ ___).~~~..:..I_,:..__.,__ '~_"__I_r_!_:...__~L_.__,__.~____~.______~__________._______ ____.., ... __. _____
..
.
OFFICE OF OIVORCE MASTER
CUMUE JU flNU COUN I Y
COUll! OF COMMON PLEAS
9 North Hanovor Stroot
Carlislll, P^ 17013
(71712406535
E. Robert Elicker, II
Divorce Mast.,
Tracl .10 Colwer
Ollie. Managa"nepOller
Samuel L. Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
Wel' Shore
697,0371 Exl, 6535
January 18, 1996
Paul J. Esposito, Esquire
GOLDBERG, KATZMAN & SHIPMAN
320-E Market Street
Harrisburg, PA 17101
RE: John W. clark, III vs. Nancy M. Clark
No. 95 - 3002
In Divorce
Dear Mr. Andes and Mr. Esposito:
By order of Court of President Judge Harold E. Sheely
dated January 17, 1996, the full-time Master has been appointed
in the above referenced divorce proceedings.
A divorce complaint was filed on June 2, 1995, raising
grounds for divorce of irretrievable breakdown of the marriage
and the economic claim of equitable distribution. I assume that
grounds for divorce are not at issue so that wo are left with
the economic issue as raised in the complaint of equitable
distribution.
In accordance with P.R.C.P. 1920.33(b) I am directing
each counsel to file a pre-trial statement on or before Monday,
February 12, 1996. upon receipt of the pre-trial statements I
JOliN W. CLAnK, Ill,
Pl,lintiff
IN TilE counT OF COMMON PI.I,:AS UF
CUMBEnLMD COUNTY, I'ENNHYI.VANI^
VB.
CIVI I. ^CTJON - I.^W
NO.
J002
CIVIL
l'i 95
NANCY M. C 1.^,lK,
Defendant
IN IJIVonCE
ORnEll AND NOTICE SETTING HEARING
1'0:
Jolin W. Clark, I I I
Samuel L. ^ndes
, Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
Nancy M. Clark
Paul J, Esposito
You are directed to appear for a hearing to take
testimony on the outstanding issuos in the above captioned
divorce proceedillgs at the Office of tho Divorce Master, 9 Nortll
Hanover Street Carlisle, Pennsylvania, on the _---18th__
day of ~uly__, 1996, at 9:00 a.m, at which place and
time you will be given the opportunity to present witnessos aliI!
exhibits in support of your case.
By the Court,
~a..--J \~
lIarold E. Sheely,
.Iud,:](...!
Date of Order alld
Notice I _5Ll1 !/,fJ,__
By:
lJivorce- Mauler
IF VOU IJO NOT IIAVE A LAWYEn on C^NNOT AFFOnlJ ONE, GU TO Oil
TELEPIIONE TilE OFFICE SET FOll'l'lI BELOW TU FIND OUT ImEIlE VUU
CAN GET I.EG^L IIELI'.
Courl ^dmiIlIHll"illul'
Fourlh 1,'1001", E,lIlt IHntj
Cumber lalld County COllrlholw"
Car1lu!e, PA I7IlI j
Teleplll11l1' ('117) 2411-(,21l11
JOHN W. CLARK, IIl, IN TilE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLANn COUNTY, PENNSYLVANIA
vs. NO. 95 - 3002
NANCY M. CLARK,
Defendant IN DIVORCE
REI Pre-Hearing Conference Memorandum
nATE: Wednesday, May 1, 1996
Present for the Plaintiff, John W. Clark, III, was
attorney Samuel L. Andes, and present for the Defendant, Nancy
M. Clark, was attorney Paul J. Esposito.
A divorce complaint was filed on June 2, 1995,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claim of equitable distribution.
Counsel have advised that the parties will sign and file
affidavits of oonsent prior to the hearing to be soheduled so
the divorce can be concluded under section 3301(c) of the
Domestic Relatione Code.
The parties were married on September 18, 1970, and
separated June 1, 1995. They are the natural parents of two
ohildren, Andrew, who is a college student at the University of
pittsburgh in his junior year. The other child, Joshua, 14
years of age, lives with his mother. Husband is paying support
for Joshua through the nauphin County Domestic Relations Office
in the amount of $65.00 per week. Husband has not been
assisting with the cost of educational expenses for Andrew since
the separation.
Husband is 46 years of age and resides at 9 Stone
spring Lane, camp Hill, Pennsylvania, in an apartment where he
lives alone. He is a high school graduate with technical
training, having attained a two year associates degree at HACC.
He is employed by Robert G. Hartman' Associates, Inc. as an
engineering associate with a net income per month of around
$1,900.00. Husband has not raised any health issues.
Wife is 44 years of age and resides in the marital
home at 4950 Janelle Drive, Harrisburg, Pennsylvania, where she
lives with the younger child of the marriage. Wife is a high
school graduate and is employed with Bell Atlantic as a
confidential senior clerk with a net weekly income of $38J.52.
Her counsel indicated that her gross annual income is around
$JO,ooo.OO. Wife also has additional income from investments
from stocks in the approximate amount of $1,000.00 quarterly.
Wife has not raised any health issues.
The marital real estate located at 4950 Janelle
Dr1ve, lIarr1sburg, Pennsylvania, hae been appraised by an
appraiser hired by wife, Robert Ensminger, who has indicated in
his opinion the market value is $150,000.00. Mr. Andes
indicated that he will review the appraisal with his client to
see if they can agree to the appraisal; otherwise, Mr. Andes can
have the property appraised prior to the hearing. The property
is subject to a lien in favor of Belco Federal credit Union. As
of March 25, 1996, the payoff on the lien was $1),)62.00. Wife
claims that she did not benefit from the total amount of money
borrowed from Belco, which was around $20,000.00, asserting that
at lsast $10,000.00 of the money that was borrowed husband used
for his own benefit. Husband denies the claim and indicates
that some of the funds at least were used for the payment of
college expenses for Andrew.
When the parties bought the property they had a
larger mortgage which was then paid off by wife's father. The
parties signed a note in favor of wife's father in the amount of
$52,000.00/ however, prior to the separation (probably in 199))
wife's father forgave the obligation of the parties on the loan
that he made to them. Wife claims that she should be given some
consideration for the contribution from her family toward the
value of the marital real estate. The Master inquired of
counsel as to whether or not wife wanted to remain in the house,
and Mr. Esposito indicated that to the best of his knowledge
wife wanted to retain the house/ Mr. Andes thought, however,
that as a result of a conversation between the parties, that
wife was willing to list the house for sale. counsel need to
indicate their respective client's position with regard to the
retention of the house by ~ife or the sale.
The household tangible personal property has not
been appraised and counsel may have to have an appraisal to
determins the value of the items remaining in wife's possession
after the separation and the value of the items which husband
took. Husband should provide a list of the items Which he has
in his possession which he removed from the premises.
lIusband previously was employed by 11.1'. McGinley,
Inc. and before the separation changed employment. At the time
that he left H.P. McGinley, Inc., lie was participating in a
profit sharing and pension plan. Mr. Esposito provided a value
for the profit Sharing plan as of February 27, 1995, of
$27,790.00 and a value for the pellslon plan as of March I, 1995,
of $lB,167.00. Inasmuch as huabiltlll left the employment of 11.1'.
McGinley, Inc., prior to separation, there have been no
contributions made to either of those plans since the parties
separated.
Husband is not participating in any pension plan
with his current employer Robert G. Hartman & Associates.
Wife, as indicated, is employed by Bell Atlantic
and is a participant in the Bell Atlantic pension plan which
needs to bs valued. She is also participating in a savings and
security plan. Mr. Esposito indicated that as of December 31,
1994, the value of that plan was $9,405.75.
The parties have a number of shares of stock which
were derived from the split up of AT&T inclUding some AT&T
stock. The value of those shares are between $3,600.00 and
$4,000.00.
A difficulty to the parties and counsel is trying
to arrive at the marital and nonmarital portion of the Keystone
Financial stock and the Sun BanCorp stock. A portion of the
shares were wife's individual assets and we would be looking at
the increase in value, if any, of those shares. There is also
some question as to whether or not any of the shares of either
of those corporations can be characterized as marital and the
number of those shares, if so characterized, that would be part
of the marital estate. counsel may have to hire a person to do
an analysis if these two stock accounts inasmuch as there have
been some sales out of the accounts during the marriage as well
as purchase of shares as a result of a stock dividend
reinvestment.
Husband owns two vehicles, a 1984 Jeep and a 1977
HGB, and according to wife a 1986 - 1988 Lincoln Continental.
Hr. Andes is not aware of the Lincoln Continental and is going
to talk to his client about whether or not he owns that vehicle;
however, apparently that vehicle was purchased subsequent to the
separation so in any event may be nonmarital and not included in
the equitable distribution. Wife owns a 1991 1I0nda Accord. The
three marital vehicles, the Jeep, HGB, and Accord, need to be
valued for purposes of equitable distribution.
Counsel indicated that wife's father passed away
within the last two years and wife was a beneficiary of his
estate. The Master has inquired as to whether or not we know
what the extent of wife's inheritance was from her father's
estate and counsel are going to try to obtain that information
by looking at the inheritance tax return or account filed in the
estate. It is noted that wife's separate estate is a factor
that can be looked at in terms of how a distribution is
accomplished of the marital ilssets.
Mr. Esposito has listed a life insurance policy
with Protected Life on his inventory but has not indicated any
other information. He is going to inquire about the existence
of the policy and whether or not there is any cash value in the
policy. Mr. Esposito believes that both parties have a policy
with the company.
A hearing is scheduled for Thursday, July 18, 1996,
at 9:00 a.m. Notices will be sent to counsel and the parties.
E. Robert Elicker, II
Divorce Master
cc: Samuel L. Andes
Attorney for Plaintiff
Paul J. Esposito
Attorney for Defendant
15 ~'ebrua ry 1996
n!.l.tll'llllNIl
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l.Hr-IUYSE, J1HNSH\'I.\'ANI.\ 17UTI
...
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E. Robert Elicker, Esquire
Office of the Divorce Haster
9 North Hanover Street
Carlisle, PA 17013
RE: John W. Clark, III vs. Nancy H. Clark
No. 95-3002 Civil Term
Dear Hr. Elicker:
Enclosed you 11111 find a Pre-Trial Statelllenl IIhlch 1 file on behalf of
the Plaintiff, John W. Clark, Ill. In the above matter. 1 have, this day,
sent a copy to Paul Esposito, Esquire, IIho represents Hrs. Clark. Please
schedule a pre-trial conference at your earliest convenience. Thank you for
your cooperation.
Sincerely,
~~~. A~des
Ie
Enclosure
cc: Paul Esposito, Esquire
'.
';^~1l1l~1. I.. ANIlES
COpy
^ldIIlIfNHY ^'I I.AW
not!'\ NlIlIll!l"'''lrll1 HI II I'. I! I
I'll IIOX 11111
UMll~t. L ""1I1\!111
"'~~fO\'NI~, I'HNNMYI.\'ANIA 1'0.&:1
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1,,'I,nl..-tu
17 June 1996
Lawrence E. Welker
Prothonotary
Cumberland County Court Ilouse
Carlisle, M 17013
RE: Clark v. Clark
No. 9.5.3002 Civil Tenn
Dear Mr. Welker:
Enclosed you will find on Affidavit of Consent and a Waiver of Notice which I flIe
on behalf of the Plaintiff inlhe above llIaller.
Sincerely,
Sallluel L. Andes
rq
Enclosure
cc: E. Rober1 Elicker, II, Esquire
Paul J, ESJlosito, Esquire
,JOHN W. CLARK, III,
Pliltlltl f I
IN '1'11I\ COUIl1' Of' CON~I()N
PI,EAB Of' cUNnmlLANIl COUNTY,
I'F:NNBYI,V AN I A
Vii.
CIVIl, ACTION - I,AW
NANCY M. CI,ARK.
DefeJ1llillll
NO, '.l!i-3110:.l CIVIl. 'I'BllN
IN UIVoJ{CI>
AFFIDAVIT OF CON BENT
1. A Complaillt III Ulvorc!e ulHler flectioll 3301 (e) o( t.he Ulvon!e Code
waD r lIlHl on 2 June 1l)9~) a III I WUIl IH!I'v..d upon till! llufeJulallt on 01' lIhoul 22
June 199!J.
2. 'fhe mal'l'iRgo of
and nlllety (90) c1ayn havll
Platllt.Jff alld Oefelldilnt. in Irrot.rillvahly bruklln
elaplwd [n)m thll dale or filing of the
complalllt Rnd t.he dulo of IlUI'VJCI! of t.tlll eomplaint Oil t.hf! Defendant.
3. 1 eOIlSf!nt t.o tIlB ent.ry o( a I illal del!I'ee III divorce eit.her a[tel'
sel'vlce of u Noticll o[ Int.elll.loll 1:0 Request Entry of t.he Dec/'ee 0/' U110f!
filing of my Wlllve/' of 1.I1e Not.Jl'e o( Intf!nt.1ol1 lo Request Ellt/'y of 1I1A
Deeree.
4. 1 have been advlBf!d of 1.I1ll IIvililahl Ilt.y of mllrrlayo l!ol/lIBeling
al\(l ullclerolanu thaI. tlw Court. maintalllo It llsl. of ma/'l'laye l!OIlIlIlelors and
thill: I IIII1Y /'equeul. tho Court to requJI'f! lilY RpUIIIle Blld I to 1I/1I'Uclpllte 1n
cOllllaetlllY and. helllY 110 II<1VI'lf>II. do 1101 request t.hal t.11l" Cuu/'t. I'equire
lhat. my /lll11URe and I pal'Utllpnt.o JII counflellny pl'lol' t.o tho .IJvorce
hecom J IIY f 11111 t .
I verify Ihut. t.ho fllat.llmenlH lIIi1do In lhfH AffJ<1i1vJt are t.rue Blld
I!orroct. ii/HI t underllllHHI t hill rill flp flllIlplIIPul r. hp!,!! III Ill'll mBllp ullhjp.ct to
lhe penlllt:les Ilf 10 I'll. c.n, 111,.,1,1011 4'l04 .'ol.ll.1ny t.1l III111WII/'1I
flltUi[JCBtillll III alllhlll'II!PfI.
_SliJ.1l. 9 f!._'__~______,___,_~,
llA1' 1\
"~'{V'
u...~t--
'OIiN~ ",:iRK:
I "
, II-----~---
JOliN W. CI,ARK, 11 I, ) IN TIm COURT OF' CmlMON
Plililltjf[ ) PLEAS OF' CUNIlERLANIl COllN'rY.
) I'ENNBnVAN1A
)
VII. ) CIVil, AC'I'ION - LAW
)
) NO. 95-300~ C I V II, TI'RM
NANCY 1'1. CI,ARK. )
Dofolldllllt ) IN III VORCE
WAIVER OF NOTICE-OF INTENTION TO REOUERT ENrBY
OF A "IVOReR DRCRRR lJNDRR 8ECTION ]:\011", OF THB "'VORel'": conE
I. I conRellt to the entry of II final decree in divorce without
noll ce.
:I. I understillld that I may lU80 rJghta concerllinC} allmuny, division
of property, lawyer I s f eell. 01' expllnRHII if ] do 1I0t el a 1m them before II
divorce is grRnted.
3. I understand that I will 1I0t. hI! dlvurced 11/11,11 II divorce decree
i8 entered by t.he court IIlId that. II I~O\lY of t.he deeree will he sellt. t.o me
immediately lifter it ,iu filed with the PI'othl1llot.al'Y.
1 verify thllt the utat.emellt.u made Ln thin Affidavit lire t.rue IInd
correct. I undel'stand that. fill lie stat.nmellts herein are lIIade lluhJect to
the penal\.iea of 18 I'a. c.n. Beellon 4904 rnllll.\lIC} 1.0 1I111lWOrll
falaificatioll to authurJtins.
6/17/96
Dat.edl
'it~L
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