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IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
STATE OF W, PENNA,
Stacy lU10ne
~ II. 95-3079
... II)
Plaintiff
\' l'I',~II"
Michael Rhone
lXlfendant
DECREE IN
DIVORCE
-=-[(1'}"L~'~(), I 3,.,. 19 (I f(.
It is ordered and
AND NOW,
decreed that ". ' , Stacy Rhone.
and, , , , , ' , , , . , , , .. , , ,Michael,lU1one
are divorced from tho bonds of matrimony,
, , , , .. , , '. plaintiff.
. , , , . ' , '. defendant.
The court retains jurisdiction of tho following claims which have
been raised of record In this action for which a Iinal order has not yet
been entered; It is further ordered that the provisions of the Marriaqe
Settlement Agreement dated ~lY 13. 1997 between the Plaintiff and Defendant
ill1d filed in this action are Inco.rporated herein and nnde apart hereof by re-
ference' thereto. but shall not merge' herein. Tlcol;Y of saId 'Aqrcel1lJ'nt 'fa' '
attached hereto. as F.xhiblt A,
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Pllllh0l111tUIV
Atlt'llt:
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IN TIlB COURT OF COtoI4ON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
, .
NO. ct5 -307ct eLl.\. \
CIVIL ACTION - LAN
IN DIVORCB
STACY ROONS,
Plaintiff,
MICHABL RHONS,
Defendant
MARRIAGB SB'l"l'LRMBNT AGRBBMBNT
THIS AGREEMENT is made and entered into between STACY RHONE
and MICHAEL RHONE, hereinafter referred to as Husband and Wife,
The parties were married on February 2, 1992.
As a consequence of disputes and unhappy differences, the
parties have separated.
The parties desire to confirm their
separation and make arrangements in connection therewith, including
the settlement of their property rights, and all other rights and
obligations arising out of the marriage relationship.
It is therefore agreed:
1. CONSIDBRATION
The consideration for this Agreement is the mutual promises
and agreements herein contained.
"'".~
2 . SBPARATION AND NONINTBRPBRBNCB
A. It will be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or
places as he or she may from time to time choose or deem fit.
B. Each party shall be free from interference, authority and
control, direct or indirect, by the other, as fully as if he or she
Initials ~ ~~
were single and unmarried, Neither shall bother the other or
compel or endeavor to compel the other to cohabit or dwell with him
or her.
3 . MUTUAL RBLHASB
Subject to the provisions of this Agreement, each party has
released and discharged, and by this Agreement does for himself or
herself, and his or her heirs, legal representatives, executors,
administrators, and assigns, release and discharge the other of and
from all causes of action, claims, rights, or demands whatsoever,
in law or equity, which either of the parties ever had or now has
against the other, except any or all cause or causes of action for
divorce.
4 . FULL DISCLOSURB
The provisions of this Agreement and their legal effect are
fully understood by each party to this Agreement, and each party
acknowledges that the Agreement is fair and equitable, that it is
being entered into voluntarily, and that it is not the result of
any duress or undue influence. Husband and Wife each represent and
warrant to the other that he or she has made a full complete
disclosure to the other of all assets of any nature whatsoever and
of all other facts relating to the subject matter of this
Agreement. Both parties represent that the terms of this Agreement
have been fully
2
Initials MAlL '::.l-\<.
explained to them by their respective counselor that both parties
have had the opportunity to have legal counsel review and fully
explain the terms of this Agreement. Wife is represented by
Michael J. Pykosh, Esquire of the Law Offices of Darrell C.
Dethlefs. Husband is represented by Charles Petrie, Esquire.
5. ROOITABLB DIVISION
By this Agreement, the parties have intended to effect an
equitable division of their marital property. This division is not
intended by the parties to constitute in any way a sale or exchange
of assets.
6, BUBSBOOBNT DIVORCB
A. AGRBBMBNT NOT PRBDICATBD ON DIVORCB - It is specifically
understood and agreed by and between the parties hereto and each of
the said parties does hereby warrant and represent to the other
that the execution and delivery of this Agreement is not predicated
upon nor made subject to any agreement for institution,
prosecution, defense, or for the non-prosecution or non-defense of
any action for divorce; 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
3
Initials ~ ~
actions for divorce, upon just, legal and proper grounds; nor to
prevent either party from defending any such action which has been,
mayor shall be instituted by the other party, or from making any
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 made for the specific purpose of inducing Husband
and Wife to execute the Agreement. Husband and Wife each knowingly
and understandingly hereby waives any and all possible claims that
this Agreement is, for any reason, illegal of for any reason
whatsoever, unenforceable in whole or in part, Husband and Wife
each do hereby warrant, covenant and agree that, in any possible
event, he and she are and shall forever be stopped from asserting
any illegality or unenforceability as to all or any part of this
Agreement.
8. BHTRY AS PART OF DBCRBB - It is the intention of the
parties that the Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order,
judgment or decree of divorce, temporary, final or permanent, shall
affect or modify the financial terms of this Agreement, This
Agreement shall be incorporated in but ehall not merge into any
such judgment or decree of final divorce, but shall be incorporated
for the purpose of enforcement only,
4
Ini t ial s MM.- '"l g
C, MUTUAL CONSBNT DIVORCB The parties agree and
acknowledge that their marriage is irretrievably broken, that they
do not desire marital counseling, and that they both consent to the
entry of a decree in divorce pursuant to 23 Pa.C.S ,A. Section
3301(c), Accordingly, both parties agree to forthwith execute such
consents, affidavits, or other documents and to direct their
respective attorneys to forthwith file such consents, affidavits,
or other documents as may be necessary to promptly proceed to
obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(C).
upon request, to the extent permitted by law and the applicable
Rules of Civil Procedure, the named defendant in such divorce
action shall execute any waivers of notice or other waivers
necessary to expedite such divorce,
7. DIVISION OF PBRSONAL PROPBR'l'Y
Wife agrees that all of the property in the possession of
Husband as of April 1, 1995, shall be the sole and separate
property of Husband; and Husband agrees that all of the property in
the possession of Wife as of April 1, 1995, shall be the sole and
separate property of Wife, The part ies do hereby specifically
waive, release, renounce and forever abandon whatever claims, if
any, he or she may have with respect to the above items which
shall become the sole and separate property of the other.
5
Initials ~ ~j~ck
8. DIVISION OF MOTOR VRHICLBS
With respect to the motor vehicles owned by one or both of the
parties, they agree as follows:
Both parties shall retain the motor vehicle presently in their
possession, more specifically husband shall retain the 1985 Gold
Pontiac Grand Am. Wife shall retain the 1989 Blue Pontiac Grand
Am.
The titles to the said motor vehicles shall be executed by the
parties, if appropriate, for effectuating transfer as herein
provided, on the date of execution of this Agreement or at any time
thereafter at the request of either party.
9. AVl'BR.-ACOUIRRD PRRBONAL PROPRRTY
Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other, all items .)f
personal property, tangible or intangible, acquired by him or her
after April 1, 1996, 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.
10, DISPOSITION OF PROPBRTY
From and after the date of the signing of this Agreement, both
pbrties shall have complete freedom of disposition as to his/her
separate property and any property which is in their possession or
control pursuant to this Agreement and may mortgage, sell, grant,
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conveyor otherwise encumber or dispose of such property, whether
real or personal, whether such property was acquired before, during
or after marriage, and neither Husband nor Wife need join in,
consent to, or acknowledge any deed, mortgage, or other instrument
of the other pertaining to such disposition of property.
12. PAYMBNT OF SPBCIFIBD OBLIGATIONS
The parties agree that the following constitute joint marital
obligations which shall be paid by the following person:
A.
WIFB -
All debts incurred by Wife since the
parties separation,
2. All debts associated with the motor
vehicle in Wife'S possession at the time
of the signing of the Agreement.
1.
8,
All debts incurred by Husband since the
parties separation.
2. All debts associated with the motor
vehicle in Husband's possession at the
time of the signing of the Agreement.
HUSBAND - 1.
13, LHGAL FBBS
Each party is responsible for their own legal fees with
respect to this matter.
14. ALIMONY
Both parties acknowledge and agree that the pt'ovisions of this
Agreement providing for equitable distribution of marital property
are fair, adequate and satisfactory to them and are accepted by
7
Initials ~ ....&.t.
them in lieu of and in full and final settlement and satisfaction
of any claims or demands that either may now or hereafter have
against the other for support, maintenance, alimony pendente lite
or alimony, Husband and Wife further, voluntarily and
intelligently, waive and relinquish any right to seek from the
other any payment for spousal support, maintenance, alimony
pendente lite or alimony,
15, PBHSION PROGRAM
Each party hereto shall maintain sole ownership over his or
her individual pension plan, profit sharing or similar retirement
plan acquired individually or as the result of contributions by his
or her employer. Wife hereby releases any interest that she has in
the retirement benefits of Husband accumulated as the result of
his employment including but not limited to husband's 401k
retirement plan and any other additional benefits he many have
accrued. Husband hereby releases any interest that he has in the
retirement benefits of Wife accumulated as the result of her
employment and any other additional benefits she may have accrued.
This waiver is a full and complete discharge of each parties'
marital claim.
16. INCOMB TAX RBFUND AND MBDICAL RXPBHSBS
Husband acknowledges that the sum of $745.71 was deducted from
Wife'S 1995 Income Tax Return was a sum which was owed to the
Internal Revenue Service by Husband and not Wife. Husband aho
agrees that prior to the date of
B Initials ll1tIL ~~l
separation, Wife had incuned medical bills in the amount of
$3,165.19 of which husband is responsible for one half (1/2) of said
medical bills, Husband therefore agrees to pay to Wife Two
thousand three hundred twenty-eight ($2,328,3I) Dollars and 31/100
in the following mallner: Fifty ($50,00) Dollars per month
commencing on June 15, 1997 and continuing on the 15th day of each
month thereafter until the said Two thousand three hundred twenty-
eight ($2,328,31) Dollars and 31/100 is paid in full.
17. MISCRLLANBOUS
All assets including, but not limited to, savings accounts,
Checking accounts, certificates of deposit and life insurance
policies shall be the sole and separate property of the title
holder of said asset.
The parties believe and agree, that the division of property
hereto made by this Agreement is a non-taxable division of property
between co-owners rather than a taxable sale or exchange of such
property, Each party promises not to take any position with
respect to the adjusted basis of the property aBsigned to him or
her or with respect to any other issue which is inconsistent with
the position set forth in the preceding sentence on his or her
federal or state income tax returns,
18, GKNRRAL PROVISIO.O
A, WARRANTY AS TO BXISTlHO OBLIGATIONS Bach 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
9 Initials ~ ~
for in this Agreement. Each party agrees to indemnify or hold the
other party harmless from and against any and all such debts,
liabilities. or obligations of every kind which may have heretofore
been incurred by them. including those for necessities, except for
the obligations arising out af this Agreement,
B. WARRANTY AS TO FUTURB OBLIGATIONS - Wife and Husband each
covenant, warrant, represent, and agree that each will now and at
all times hereafter save harmless and keep the other after the
execution date of this Agreement, except as may be otherwise
specifically provided for by the terms of this Agreement and that
neither of them shall hereafter incur any liability whatsoever for
which the estate of the other may be liable.
C, SBVBRABILITY If any term, condition, clause. or
provision of this Agreement shall be determined or declared to be
void or invalid in law or otherwise. then only that term,
condition, clause, or provision shall be stricken from this
Agreement and in al other respects this Agreement shall be valid
and continue in full force, effect. and operation, Likewise, the
failure of any party to meet his or her obligations under anyone
or more of the paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way void or
alter the remaining obligations of the parties,
D. OTIIBR OOCUMBNTATION - Wi fe and Husband covenant and agree
that they will forthwith execute any and all written
10
Ini t ial s I1lAL- .:&.l.
iBstgoments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement, and as their respective counsel
shall mutually agree should be so executed in order to carry out
fully and effectively the terms of this Agreement,
B, BNTIRB AGRBBMBNT - This Agreement contains the entire
understanding of the parties, and there are no representations,
warranties, covenants, or undertakings other than those expressly
set forth herein.
F. WAIVBR OR MODIFICATION TO DB IN WRITING - No modi! ication
or waiver of any of the terms hereof 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
subsequent default of the same or similar nature.
G, MUTUAL COOPBRATION - Each party shall, at any time and
from to time to time hereafter, take any and all steps and execute,
acknowledge, and deliver to the other party any and all further
instruments and/or documents that the other party may reasonably
require for the purpose of giving full force and effect to the
provisions of this Agreement,
/I, LAW GOVBRNING - This Agreement shall be construed and
governed in accordance with the laws of the Conunonwealth of
Pennsylvania.
11
Initials flfA~ '_Jl.K
I. BINDING BFFBCT - Except as otherwise stated herein, this
Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors,
administrators, successors, and assigns,
J, NO WAIVBR OR DB FAULT - This Agreement shall remain in
full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the same, nor shall the waiver of any breach
of any provision hereof be construed as a waiver of any subsequent
default of the same or similar nature, nor shall it be construed as
a waiver of strict performance of any other obligations herein.
X, HBADINGS NOT PART OF AGRBBMBNT - Any heading preceding
the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience or reference and shall not
constitute a part of this Agreement nor shall they affect its
meaning, construction, or effect.
L, ADDRBSS OF PARTIBS - Each party shall at all times keep
the other informed of his or her place of residence, and shall
promptly notify the other of any change, giving the address of the
new place of residence,
M. WAIVBR OF CLAIMS AGAINST BSTATBS - Except as herein
otherwise provided, each party may dispose of his or her property
in any way, and each party hereby waives and relinquishes any and
12 Initials ~ ~R
all rights hs or she may have or hereafter acquire, under the
present or future laws of Pennsylvania or another jurisdiction, to
share in the property or the estate of the other as a result of the
marital relationship, including, without limitation, dower,
curtesy, their statutory equivalents, widow's allowance, homestead
rights, right to take in intestacy, right to take against the will
of other, and right to act as administrator or executor of the
others estate, and each party will, at the request of the other,
execute, acknowledge, and deliver any and all instruments which may
be necessary or advisable to carry into effect this mutual waiver
and relinquishment of all such interests, rights and claims,
N. ATl'ORHBY 'S FBBS FOR BNFORCBMBNT - In the event that
either party breaches any provision of this Agreement, and the
other party retains counsel to assist in enforcing the terms
thereof, the parties hereby agree that the breaching party will pay
all reasonable attorneys' fees, court costs, and expenses incurred
by the other party in enforcing the Agreement.
IN WITNESS WHEREOF, and intending to be bound hereby, the
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parties have signed and sealed this Agreement on the ~ day of
,
ma~ ' 199,6,
In the prese40:;2'
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Stacy Rhone
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(SEAL)
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Michael Rhone
(SEAL)
13
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IN THE COURT OF COttttON PLEAS
CUttDEIlLAND COUNTY. PENNSYLVANIA
ST ACY RHONE.
Plelntlff
NO. 95-3019
Y.
ttlCHAEL RHONE.
CIVIL ACTION - LAW
IN DIVORCE
Ol,.dlnt
PIIAlEtIP( TO TII..SHIT R([OIlD
TO THE PROTHONOT ARY:
TransmIt the record. together with the following Information to the court for
entry of 0 DIvorce Decree;
I, Ground for dIvorce: Irretrtevoble breokdown under
Sectlon ()() 33011c) I) 330 lId) 11) of the Divorce Code,
(Check I!IPpltcllble section).
2, Dete llnd mll'lner of service of the Co~lo1 nt:
JUNE 10, 1995 BV CERTIFIED HAIL
3. Complete either pllrll!Tllph (II) or Ib),
Ill) Dllte of eMerotton of the AHldllvlt of Consent required by Secllon
330 Hc) of the DIvorce Code:
by Pllllntl If Novemll.er.12.122.L__--
by Defendllnt ~L5..J.22l
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STAC' RHONE,
: IN THE COURT OF C0t1t10N PLEAS
Plelntlff ; CUt1BERLAND COUNn, PENNSYLVANIA
. .. t ~
: NO. ~ - j 0 '''l.:L{V!.L(.. TH.'Y>v
Y.
t1tCHAEL RHONE, ; CIVIL ACTION - LAW
Defendent ; IN DIVORCE
NOTICE TO DEFEND AND CLAIt1 RI6HTS. You heve been sued In court
If you WIsh to defend IIgelnstthe cllIlms set forth In the following peglS, you must
tllke prorr,pt ecllon You ere werned thllt If ~u fIll to 00 so, the clISe moy proc.d
without ~u end I decree of divorce or Innulment mllY be entered IIgelnst you by the
COIrt. A Judgment moy ello be entered IIglllnst you for IIny other cllIlm or relief
rllJjested In the.. pepers by ths plllntlff. You mllY 1018 money or property or other
rights tmportent to ~u Including custody or vlsltlltlon of YOIr chlll"n,
Whll1the grolllds for the dtvorce Ire lndllJlltles or trretrtIYlble 1...llIkdown of
thl mlrrlege, you mey rlqueet mlrrlsge counseling, A lilt of merrtlge cOlllsllors Is
IYlIllbleln thl OffiCI of thl Protlllnotery It the Cuntllrlend County Courthousl.
IF 'OU DO NOT FILE A CLAI" FOR ALlt10N', DIVISION OF
PROPERTY, LAW'ER'S FEES OR ElPEIISES BEFORE A DIVHCE OR
A"'Lt1E"T IS &RAIfTED, 'OU t1A' LOSE THE RI6HT TO CLAIt1 All' OF
THEt1.
'OU SHOULD TAkE THIS PAPER TO 'OUR LAWYER AT O"CE. IF
'OU DO "OT HAVE A LAWYER OR CANIIOT AFFORD OIlE, &0 TO, OR
TELEPHO"E, THE OFFICE SET FORTH BELOW TO FIIID OUT WHERE 'OU CAli
&ET LE&AL HELP.
Cumberlllnd COunty LlIWyer Refsrrel Service
One Courthouse SqUIre
FOlrth Floor
ClIrllsle,PA 17013
(717) 697-0371
STACY RHONE, : IN THE COURT OF CO""ON PLEAS
Plllntlff : CU"DERLAND COUNTY, PENNSYLVANIA
Y. : NO.
"ICHAEL RHONE, : CIVIL ACTION - LAW
Dlflndlnt : IN DIVORCE
COHPLAIIIT .M DIVOICI: PUIUiU..T TO S(CTIOIII ]]Olh:}
OF TN( DIVORCE CODE OF IGIIO
COUIIT I
DIVORCE:
AND NOW, comes lhe PlaIntiff, Slacy Rhone, by end lhrough her altorne\lll,
Tho Law Offtces of OlIrrell C, Delhlefs, and seeks lo oblaln a Decree tn Dlvorte from
lhe Booos of Malrimony with lhe aboye-nll'l1ed Defeooanland avers lhe followIng
1. Platnllff, Slacy Rhone, Is an awltlndtvtdual who currently rnldl8 al
149 Ashford Drive, Enola, Cumberland Counly, PennsylvanIa 11025,
2. Defeooenl, Mlch.l Rhone, Is en adult loolYlduel cllTenlly residing al
122 Hurrvnel Avenue, Lemoyne, Cumberland counly, Pennsylvania 11043.
3, Both Plalnllff and Defenda'lt hsve bellll bonlfled resldenls of the
ccrnmlllweallh of PllIlnsylYllnla for alleesl sl~ (61 monlhs lrrvnedlalely lI'ecedlng lhe
11IIng of lhls Complalnl.
4. The parlles were marned on February 2, 1992 In DUllCannon, Stale of
Pemsylvenla,
5. There haYS been no prIor 8cllons of dIvorce or annulmenl belwellll lhe
plW'tles In thIs or any olher lurisdlctllll,
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6. PlaIntIff avers thllt she Is entitled to a dIvorce m lrounds that the
mllTlage Is Irretrlevllblll broken and Plaintiff Is proceedIng lIlder Sections 3301(c)
and/or (d) of the Divorce Code.
7. OefendCllt Is not a member of the Armed ServIces of the United States
oranyof Its allIes,
B, Plaintiff has been advIsed of the avat1l1blllty of counsellng and
understands thllt she IlllIY hlIve the rIght to request that the Court require the plrt tes
to particIpate In counsellng, BeIng so advised, Plaintiff does oot request that the
Court I'IlJllre that the partIes particIpate In counseling prl~ to a divorce decree betng
handed down by the COlrt.
9, PlaIntIff avers that there Is one cht1d to the mllTlage, DanIel Joseph
Rhone, born on September 23, 1992,
WHEREFORE, PlaIntiff respsclfully requests thIs Honol'8ble Court to enter a
Oecreetn DIvorce,
Respectfully SUbmItted,
LAW OFFICES OF DARRD.L C. DETHLEFS
Date: June. \ I \qqS
--i /J
BY-'Z ' 0
MIchael J, Pykosh, . Ire
WalJler Building - SuUe
355 Nlrth 21 st Street
CampHtll,PA 17011
(717) 975-9446
AttornSll f~ Plaintiff
,...
VERIFICATlO.
I here~ verify thetlhe statements of fact made In the foregolr.tj Answer are
true and comct to the best of my knowledge, lnfll1l1atloo and beltef. I understand
thllt any false statements theretn are Slmject to the cnmlnal penalties contaIned In 1 e
Pa. C,5, 114904, relating to unsworn falslflcatlon to authorltles,
Dated:
, .
STACY RHONE,
IN THE COURT OF COMMON PLUS
CUMDERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plllntlff
v.
MICHAEL RHONE,
NO. 95-3079
ACTION IN DIVORCE
Defendent
AFFIDAVIT OF CONSENT
1. A compllllnt In Dtvorce IIlder Section 330 Hc) of the DIVorce Code WIIS filed
on HIY B, 1996.
2, The mlrrlllJll of Plllnttff 1100 Defendll'lt Is trretnevlbly broken Ind ninety
(00) llIys hIve elllpsed from thl! dlte of fll1ng of the Complllnt.
3. I consent to the entry of II flnlll decree of dIVorce,
4, I understlnd thlt If II clllm for Illmony, Iltmony pendente lIle, IlllIrltlll
pr~erty, counsel fees, or elCpenses hIS not been fl led WIth the Court before the entry
of I flnllllecree In divorce, the rtght to clllm Iny of them will be lost.
I verify thllt the stltements mlllle In this Afftdllvlt Ire true Ind correct.
underltlnd thllt flllse stltements heretn lI'e IlllIde subject to the penaltIes of 18
PaC.$,A, Sectton 4904 relltlng to unsworn flllslf1clltlon to luthorittes,
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STACY RHONE.
IN THE COURT OF CO""0N PLEAS
CUt1BERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
Plelntlff
v,
"ICHAEL RHONE.
NO, 95-3019
ACTION IN DIVORCE
Defendent
WAIVER OF MOllCE OF INTEIITIOII TO REOUEST
EURV OF A DIVORCE DECREE UMOER
SECTIOM ]]OI(C) OF THE DIVORCE CODE
1. I consent to the entry of II flnel deern of dIvorce without nottce,
2. I understllnd that I mllY lose rtlflts concerning ellrnony. dlYlslon of
prl1!.rty, lllwyer's fees or el<P.ns.s If I do not clelm th.m before e dlyorc.,e
grented.
J. I unljerstend that 1 will not be divorced untlle dtyorceljecre,'e ent....d
by the Cwrt end thete c~y of e decree will be sent to me Immedletely efter It Is
fH.d with th. Prothonotery,
I yerlfy thet the stetements melje In thIs effldllylt ere true end correct
uncleretlllld thet felse stetemenls hereIn ere melje sublect to the peneltles of Ie Pe,
C,5,,\, 5ectloo <904 reletlng to unsworn felslflcetton to euthor1tles,
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STACY R E. PLAINTIFF
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Plaintiff
IN TIIB COURT OF C<MtON PLIWI
COMBBRLAND COUNTY, PBNNSYLVANIA
CIVIL ACTION - LAW
NO. '1 ~i - :)C:l<.\
ACTION IN DIVORCB
STACY RHOMB,
v,
MICHABL RHOMB,
Defendant
AFFIDAVIT OF CONSIDIT
1, A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on June 7, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing of
the Complaint.
3, I consent to the entry of a final decree of divorce.
4. I understand that if a claim for alimony, alimony pendente
lite, marital property, counsel fees, or expenses has not been
filed with the Court before the entry of a final decree in divorce,
the right to claim any of them will be lost.
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.A. Section 4904 relating to
unsworn falsification to authorities,
Date: /</r/r7
By: n:......-,~'C\.....'" Q.\I,.,-,,-
Michael Rhone, Defendant
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STACY RHONK,
IN TIlB COURT or C<M<<>N PLRAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
CIVIL ACTION - LAW
NO, '(s- '~('7'1
ACTION IN DIVORCB
Plaintiff
v,
MICHAIIL RHONK,
Defendant
WAIVBR OF NOTICE OF INTBNTION TO RBOUBST
BNTRY OF A DIVORCB DBCRBB UNDBR
SECTION 3301(c) OF THB DIVORCE COOS
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.
J. I understand that I will not be divorced until a divorce
decr.. is entered by the Court and that a copy of a decree will be
..nt 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,B.A. Section 4904 relating to
unsworn fallification to authorities,
Datel
11/1/'1/
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Michael Rhone, Defendant
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No. 95-3079
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Sl Af:V RHONF.
PllllntlH
v.
MICHAEL RHONE,
Defendant
Civil Action - Law tn
Dtyorce
The ebove ceptloned Defendant wes served with the DIvorce
ComplaInt In thIs metter on June 10, 1995 vIa U.S. Mell certtfled
return receIpt. The orlgtnel green card sIgned by the Defendent elong
wIth the receIpt for certIfIed mall, ts attached hereto, lllbeled
Exhibit "A" ami made aplIrt hertlor.
I\lchael J, Pykosh, E6 ulre
1.0,-56651
Wegner BuildIng - SuIte 205
355 North 21 st. street
Camp Hill, Pa 17011
(717) 975-9446
Date: Jenuary 5, 199B
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~ Receipt for
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.tl':trl'IU\ Ofl n.lI Will lor Illh.,nnlmnAI Mall
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STACY RHONE,
IN THE COURT OF COMMON PLEAS OF
CUMBERl.AND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: %-3079 CIVIL TERM
Plaintiff
vs.
MICHAEL RHONE,
Defendant
IN :.>IVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divarce under Section 330l(c) af the
Divorce Code was filed on June 7, 1995.
2. The marriage of plaintiff and defendant is
irretrievably broken and ninety days have elapsed from the date
of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce.
4. I understand that 1 may lose rights concerning alimony,
di vis ion of property, lawyer I s fees or expenses if I do not claim
them before a divarce is granted.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to. the penalties of 18 Pa.C.S. 5 4904 relating to unsworn
falsification to autharities.
Date:
I z.1 z,.ct 1'1 S-
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MICHAEL RHONE, DEFENDANT