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: IN THE COURT OF COMMON PLEAS :
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OF CUMBERLAND COUNTY
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STATE OF
t PENNA.
CHARLES E. PAINTER, JR.
i\ II, 3064.
(1)95
Plaintiff
\'l'r.~lh
SANDRA M. PAINTER
Defendant
AND NOW, . ,
DECREE IN
DIVORCE
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it is ordered and
decreed that" ,Charles ,E. .Paioter, .Jr.""""".." .".,.,.., plaintiff.
and. , ,~al1\1r:a. 14", Pil~nj:.e~. , . . , , . , " . . , " , ' . ' , . , , , , , , , , , . . . ' . , , , defendont.
are divorced from the bonds of matrimony,
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;
"~, Separation and Property .SettlementAgreement,dated,June,7.. 1995.""
, ' is. eh. lncar.parat.ed .by ,reference. , , . , ' ' , . , , , .
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 7th day of June, 1995, by and
between CHARLES E. PAINTER, JR., of Cumberland County,
Pennsylvania, party of the first part, hereinafter referred to as
"Husband" and SANDRA M. PAINTER of Cumberland County,
Pennsylvania, party of the second part, hereafter referred to as
"Wife".
WITNESSETH:
WHEREAS, husband and wife were married on July 24,
1981, in Panama city, Panama; and
WHEREAS, husband and wife are residents of the
Commonwealth of Pennsylvania and have been so for at least the
past six (6) months; and
WHEREAS, the Parties are the parents of three (3)
children, STEPHANIE MARIE PAINTER (DaB 4/29/81), STACY MARINA
PAINTER (DaB 2/7/83), and SARAH MARINA PAINTER (OOB 1/20/87); and
WHEREAS, certain diverse, ~nhappy differences have
arisen between the parties hereto which have made them desirous
of living separate and apart from one another; and
WHEREAS, husband and wife desire to settle and
determine certain of their marital rights and obligations, and
make an equitable distribution of their marital property; ond
WHEREAS, it is the intention and purpose of this
Agreement to set forth the respective rights and duties of the
parties while they continue to live apart from each other and to
settle all financial and property righte between them; and
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provision shall not be taken to be an admission on the part of
either husband or wife of the lawfulness of the causes leading to
them living separate and apart.
ARTICLE II
DIVORCE
2.1
This Agreement is not predicated on divorce. It is
specifically understood and ogreed by and between the parties
hereto and to each of the said parties does hereby warrant and
represent to the other thot the execution and delivery of this
Agreement is not predicated upon nor made subject to ony
agreement for institution, prosecution, defense, or for the non-
prosecution or non-defense of any action for divorce I provided,
however, that nothing contained in this Agreement shall prevent
or preclude either of the parties hereto from commencing,
instituting or prosecuting any action or action for divorce,
either absolute or otherwise, upon just, legal and proper
grounds I nor to prevent either porty from defending any such
action which has been, may, or sholl be instituted by the other
party, or for making ony just or proper defense thereto. It is
warranted, covenanted, and represented by husband and wife, each
to the other, that this Agreement is lawful and enforceable and
this warranty, covenant, and representation is mode for the
specific purpose of inducing husband and wife to execute this
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Agreement. Husband and wife each knowingly and understandingly
hereby waive any and all possible claims of this Agreement is,
for any reason, illegal, or for any reason whatsoever of public
policy, unenforceable in whole or 1n part. Husband and wife do
each hereby warrant, covenont and agree that, in any possible
event he an she are and ever shall be estopped from asserting any
illegality or unenforceability as to all or any part of this
Agreement.
2.2
It is further specifically understood and agreed that
the provision of this Agreement relating to the equitable
distribution of property of the parties are accepted by eoch
porty as a final settlement of for all purposes whatsoever.
Should either of the parties obtain a decree, jUdgment or order
of separation or divorce in ony other state, county, or
jurisdiction, each of the parties to this Agreement hereby
consents and agrees that this Agreement ond all its covenants
shall not be effected in any way by any such separation or
divorce; and that nothing in any such decree, judgment, order or
further modification or revision thereof shall alter, amend or
vary any term of this Agreement, whether or not either or both of
the parties ehould remarry, it being understood by and between
the parties that this Agreement sholl survive and shall not be
merged into any decree, judgment or order of divorce or
seporation.
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2. J
It is specifically agreed that a copy of this Agreement
may be incorporated by reference into any divorce judgment or
decree if or whenever sought by any of the parties hereto. such
incorporation, however, shall not be regarded a merger, it being
the intent of the parties to permit Agreement to survive any such
agreements.
ARTICLE III
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property
in a manner which conforms to the criteria set forth in section
3502 of the Pennsylvania Domestic Relations code, and taking into
account the following considerations I the length of the
marriage; the prior marriages of the parties; the age, health,
station, amount and sources of income, vocational skills,
employability, estate, liabilities, and need for each of the
parties; the contribution of one party to the education, training
or increased earning power of the other party; the opportunity of
each party for future acquisition 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 of dissipation of each party in the acquisition,
preservation, depreciation, or appreciation of marital property,
including the contribution of a party as a homemaker; the value
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of the property set apart to each party; the standard of living
of the parties established during their marriage.
3.2
The division of existing marital property is not intended by
the parties 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 marital
property. The division of property under this Agreement shall be
in full satisfaction of all rights of equitable distribution of
the parties.
3.3
The parties shall retain sole and exclusive right, title and
possession of all personal property currently in their
possession. Except as provide for herein, Husband shall make no
claim whatsoever for any personal property in wife's possession.
Additionally, except as provided for herein, Wife shall make no
claim whatsoever for any personal property in Husband's
possession. Should it be necessary for either party to execute
any documents to convey tile to any such personal property in the
other party's possession, they shall do so within thirty (30)
days of the execution of this Agreement or within thirty (30)
days of the request from the opposing party.
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3.4
Except as provided herein. Wife waives any right or interest
she may have in Husband's employment benefits, including any
pension benefits, retirement plan, stock option purchase plan,
profit sharing plan or related matters. Except as provided
herein, Husband waives any right or interest he may have in
wife's employment benefits, including any pension benefits,
retirement plan, stock option purchase plan, profit Sharing plan
or related matters.
3.5
Husband and Wife agree to waive and relinquish any and all
right that he or she may now have or hereafter acquire in any
real or tangible personal property subsequently acquired by the
other party. Husband and Wife specifically agree to waive and
relinquish any right in such property that may arise as a result
of the marriage relationship.
3.6
contemporaneously with the execution of this Agreement, Wife
ehall transfer to Husband any and all of Wife's right, title and
interest in and to that parcel of real estate located at 19 Heidi
Terroce, Camp Hill, Cumberland county, Pennsylvania, heretofore
owned by the parties as tenants by the entireties. said transfer
is subject to those liens, judgments or mortgages of record as of
the date of conveyance, all of which shall thereafter become the
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sole and exclusive obligation of Husband. Husband shall
indemnify and hold Wife harmless from any and all cloims
regarding the property located at 19 Heidi Terrace, Camp Hill,
cumberland county, Pennsylvania.
3.7
The parties hereto agree that the title to the 1985
Chevrolet Cavalier owned jointly by the parties shall be
transferred solely to Wife. Any other vehicle owned by the
parties shall be transferred solely to Husband.
ARTICLE IV
RELEASE OF SUPPORT FOR HUSBAND AND WIFE
4.1
The parties herein acknowledge that by this Agreement they
have respectively secured and maintained a substantial and
adequate fund with which to provide themselves sufficient
resources to provide for their comfort, maintenance, and support
in the station of life in which they are accustomed. Husband and
Wife do hereby waive, releose and give up any rights they may
respectively have against the other for alimony, support, or
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maintenance.
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4.2
Husband ond Wife specificallY waive, release and give up any
rights for alimony that they may be entitled to pursuant to
Chaptsr 37 of the pennsylvonia Domestic Relations Code.
ARTICLE V
DEBTS OF THE PARTIES
5.1
Each party represents to the other that except as otherwise
specificallY set forth herein, there are no major outstanding
obligations of the parties, that sincs the separation neither
party has contracted for any debts for which the other will be
responsible and eoch porty indemnifies and holds harmless the
other for all obligations separately incurred or assumed under
this Agreement.
In the event either porty contracted for or incurred any
debts since the date of separation, the party who incurred said
debt shall be responsible for the payment thereof regardless of
the nome in which the account may have been charged. Hueband and
Wife acknowledge and agree thot they have no outstanding debts or
obligotions of the lIusband and Wife inourred prior to the signing
of this Agreement.
Husband shall assume and be solely responsible for all
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disclosed maritol debt thot was incurred before June 6, 1995.
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5.2
t:ach porty relinquishes any right, title and interest he or
eho moy havo to any and all motor vehicles currently in the
possossion of the other party. Each party shall execute the
necsssory documents to have said vehicles properly registered in
tho other party's name with the Pennsylvania Department of
Transportation.
CUSTODY
6.1
The parties agree thot Husband shall have primary legal and
physical custody of the children of the marriage, except os
follows I
1. Husband shall have primary phyeical and primory
logal custody of STACY MARINA PAINTER and SARAH MARIA PAINTER,
SUbject to Wife's periods of temporary physical custody.
2. Wife shall have primary physical custody of
STEPHANIE MARIE PAINTER, subject to Husband's periods of
temporary physical custody.
6.2
Each party agrees to keep the other apprised of any and all
matters rslating to the children's health, education, welfare,
ond octivities.
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ARTICLE VII
MISCELLANEOUS PROVISIONS
7.1
The provisions of this Agreement and their legal uffect have
been fully explained to the parties by their respective counsel
or the parties have waived their right to have legal advice
regarding the meaning and implication of this Agreement. The
parties acknowledge and accept that this Agreement is, in the
circumstances, fair and equitable, that it is being entered into
freely and voluntarily, after having received such advice ond
with such knowledge thot 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.
7.2
Husbond and Wife do hereby mutually remiee, release,
quitclaim, and forever discharge the other and the estate of the
other, for all times to come and for all purposes whatsoever, of
and from any and all legal right, title and interest, or claims
in or against the property of the other or against the estote of
the other, of whatever nature and wheresoever situate, which he
or she now has or at ony time hereafter may have against such
other, the estate of such other, or any part thereof, whether
arising out of any former acts, contracte, engogements, or
liabilities of such other as by way of dower or curtesy, or
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claims in the nature of dower or curtesy or widow's or widower's
rights, family exemption, or similar allowance, or under the
intestate laws, or the right to take against the spouse's will;
or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under
the laws of (a) Pennsylvania, (b) any state, commonwealth, or
territory of the united states, or (c) any other country, or any
rights which either party may have or at any time hereafter have
for past, present, or future support or maintenance, alimony,
alimony pendente lite, source fees, costs or expenses, whethsr
arising as a result of the marital relation or otherwise, except
and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any thereof. It is the intention of Husband
and Wife to give to each other by execution of this Agreement a
full, complete, and general release with respect to any and all
property of any kind or nature, real or personal, not mixed,
which the other now owns or may hereafter acquire, except and
only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any thereof.
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7.3
Each party represents that they have not heretofore incurred
or contracted for any debt or liability or obligation for which
the estate of the other party may be responsible or liable,
except as may be provided for in this Agreement. Each party
agrees to indemnify and hold the other party harmless from and
against any and all such debts, liabilities or obligations of
each of them, including those for necessities, except for the
obligations arising out of this Agreement. Husband and Wife each
warrant, covenant, represent and agree that each will, now and at
all times hereafter, save harmless and keep the other indemnified
from all debts, charges, and liabilities incurred by the other
after the execution date of this Agreement, except as is
otherwise specifically provided herein.
7.4
No waiver or modification of any of the terms of this
Agreement shall be valid unless in writing and signed by both
parties and no waiver of any breach hereof or default hereunder
shall be deemed a waiver of any subssquent default of the same Dr
similar nature.
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7.5
This Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania which are in effect as
of the date of execution of this Agreement.
7.6
This Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
7.7
This Agreement constitutes the entire understanding of the
parties and supersedes any and all prior agree~ents and
negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
7.8
If any term, condition, clause, section, or provision of
this Agreement shall be determined or declared to be void or
invalid in law or otherwise, then only that term, condition,
clause, or provision shall be stricken from this Agreement, and
in all other respects, this Agreement shall be valid and continue
in full force, effect, and operation. Likewise, the failure of
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any party to meet his or her obligation under anyone or more of
the articles and sections herein shall in no way void or alter
the remaining obligations of the parties.
7.9
It is specificallY understood and agreed that this Agreement
constitutes an equitable distribution of property, both real and
personal, which was legally and beneficially acquired by Husband
and Wife, or either of them, during the marriage as contemplated
by the Domestic Relations Code of the commonwealth of
Pennsylvania.
7.10
The parties warrant and represent that they have made full
disclosure of all assets prior to the execution of this
Agreement.
7.11
This Agreement shall survive any aotion for divorce and
decree of divorce and shall forever be binding and conclusive on
the parties I and any independent action may be brought, either at
law or in equity, to enforce the terms of this Agreement by
either Husband or wife until it shall have been fully satisfied
and performed. The consideration for this Agreement is ths
mutual benefits to be obtained by both of the parties hereto and
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the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein
contained is stipulated, confessed, and admitted by the parties,
and the parties intend to be legally bound hereby.
IN WITNESS WHEREOF, the parties have set their hands and
seals the day and year first above written.
WITNESSED BY:
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Charles E. Painter, Jr.
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Sandra M. Pa nter
(SEAl,)
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VI
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. PAINTER, JR.,
Plaintiff
CIVIL ACTION--LAW
IN DIVORCE
vs.
SANDRA M. PAINTER
Defendant
NO. 95-3064 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record, together with the following
information, to the Court for entry of a divorce decree:
1. Ground for divorcel irretrievable breakdown under
section 3301(C) of the Divorce Code.
2. Date and manner of service of the complaint: certified
mail, restricted delivery, return receipt requested on June 6,
1995. signed for by Defendant on June 8, 1995.
3. Date of execution of the affidavit of consent required
by section 3301(c) of the Divorce Codel by the Plaintiff--
September 10, 1995 (filed September 15, 1995)/ by the Defendant-
-September 10, 1995 (filed September 15, 1995).
4. Related claims pendingl No claims raised.
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5. Attached are copies of the Separation and Property
Settlement Agreement entered into by the parties. Said Agreement
should be incorporated into the Divorce Decree.
Respectfully submitted,
HANFT & VOHS
Datel September 15, 1995
Mif::!;.'~aJ~ F~uire
Attorney ID 157976
11 West Pomfret street, suite 2
Carlisle, PA 17013
(717) 249-5373
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. PAINTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
SANDRA M. PAINTER,
Defendant
NO. 95- ~lv tf- l\,,-cC ';>Ju',\
NOTICI TO Dlf.ND AMD CLAIM RIGHTS
YOU HAVI BI.N SUID 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 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 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.
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
Fourth Floor, Cumberland county Courthouse
carlisle, PA 17013
(717) 240-6200
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. PAINTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
SANDRA M. PAINTER,
Defendant
NO. 95-
COMPLAINT IN DIVORCE
COUNT II DIVORCE
AND NOW, this 6th day of June, 199~ comes Plaintiff, Charles
E. Painter, Jr., by and through his attorneys, HANFT & VOHS, and
files the following Complaint in Divorce, and in support thereof
avers as follows:
1. The Plaintiff is Charle E. Painter, Jr., who currently
resides at 19 Heidi Terrace, Camp Hill, Cumberland county,
Pennsylvania.
2. The Defendant is Sandra M. Painter, who currently resides at
19 Heidi Terrace, camp Hill, Cumberland county, Pennsylvania.
3. The Plaintiff and Defendant are sui juris, and both have been
bona fide residents of the Commonwealth of Pennsylvania for a
period of more than six (6) months immediately preceding the
filing of this Complaint in Divorce.
4. The parties were married on July 24, 1981 in Panama city,
Panama.
5. The marriage is irretrievably broken. The foregoing facts
are averred and brought under sections 3301(c) or 3301(d) of the
Divorce Code of 1980, as amended.
6. The Plaintiff has been advised of the availability of
counseling, and that the Plaintiff may have the right to request
that the court require the Parties to participate in counseling.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
a Decree in Divorce, divorcing the Plaintiff from the Defendant.
COUNT II: EQUITABLE DISTRIBUTION
7. Paragraphs 1 through 6 are incorporated herein by reference
as though the same were fully set forth herein.
8. Ths Plaintiff and Defendant have acquired personal property
during their marriage.
9. The Plaintiff and Defendant have been unable to agree as to
an equitable division of said property.
VIRIrICATION
I VERIFY that the statements set forth in the attached
document are true and correct to the best of my knowledge,
information and belief. I understand that false statements
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herein are made subject to the penalties of 18 Pa. Section 4904
relating to unsworn falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. PAINTER, JR.,
plaintiff
CIVIL ACTION - LAW
IN DIVORCE
v.
SANDRA M. PAINTER,
Dsfendant
NO. 95-3064
CIRTIWICATI or SIRVICI
AND NOW, this 31st day of July, 1995, I, Michael J. Hanft,
Esquire, hereby certifY that the following person was served with
a True and Correct copy of the Divorce Complaint filed in the
above-rsferenced matter.
The Divorce complaint was mailed on June 6, 1995, but actual
service took place on June 8, 1995 by Defendant signing for a
copy of the Divorce complaint which was mailed in the united
States Mail, certified Mail--Return Receipt Requested, Restricted
Delivery, postage prepaid, addressed as follows!
Sandra M. Painter
19 Heidi Terrace
camp Hill, PA 17011
A copy of the signed Domestic Return Receipt is attached
hereto as Exhibit nAil and by reference incorporated herein and
made a part hereof.
HANFT & VOHS
M chael J. H nft, squ re
Attorney ID No. 57976
11 West pomfret street, suite 2
Carlisle, PA 17013
(717) 249-5373
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IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. PAINTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
SANDRA M. PAINTER,
Defendant
NO. 95-3064 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the
Divorce Code was filed on June 6, 1995.
2. The marriage of the Plaintiff and Defendant is
irretrievably broken and more than ninety (90) days have elapsed
from the dats of the filing of the complaint in Divorce.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
5. I understand that the costs of these proceedings will be
paid for by Plaintiff.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: I c~W ~5
~~'~~;~r,
Jr.
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. PAINTER, JR.,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
SANDRA M. PAINTER,
Defendant
NO. 95-3064 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the
Divorce Code was filed on June 6, 1995.
2. The marriaye of the plaintiff and Defendant is
irretrievably broken and more than ninety (90) days have elapsed
from the date of the filing of the Complaint in Divorce.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
5. I understand that the costs of these proceedings will be
paid for by Plaintiff.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subjeot to the penalties of 18 Pa. C. S. section 4904 relating to
unsworn falsification to authorities.
/ /-"
~~~~,~
San ra M. a nter
D)t~l
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