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HomeMy WebLinkAbout95-03343 -0 ~ dJ 7 ""0 j cD ( ~ J r<) ::r rO r0 . z $ $ w. '.' $ $ S s " P.' ~ ~ i " ~ ~ ~ $ ~ ~ ... . Plaintiff ..........................-..... v CI"S\lS JOann .M... .B.l1rd , ..-.......... !I .Pefendant d DEe R EEl N ... .., .. 2,..) 'JA : DIVORC~M V' r/V\~ l. /1 <<1 ( ~ AND NOW. .. ,~~.. ." ........... 19....... it is ordered and ! decreed that.., .Qenl:.o.n '~'" .lll,lrA.. .Jr...,..........,...,...,." plaintiff, and" ~?~~~, ~'.. ~~.~~... ............ ..., ..,..".....,.,..,... defendant. 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; ~ <;, . .~~g\l~.s.~. ~!l.ll:~. ~~.X:'1'~. 9.~ .~!'!.t.1;J,4j!!".e.l1~. fI..g:r;~4j!!".e.l1~. !i.ll:~~~. !,!<!y, f.~" ~,9,~~ . .Q~. ~fl.c;QJ;'PP.x:~\:!,!d. .~f.l9. .I1Q\:. !11~J;'g!l.d, .;I,l~~. ~tl!l, .I?;YP.x:q~..",........,..., $ $ ~ ~ " <;, M " ~ ." ~ :1. ~ ~---_.._. _.. . ..~...-.., ..- .- .----........ ." ..... '- .-----. -.."--"-' .. ... 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Cumberland County Court of Common Pleas Docket No. 95-3343 Civil Term MARITAL SETTLEMENT AGREEMENT THIS AGRBBHBN'l' made this .J 3 rei day of I)~ hereinafter ., , 19", called by and between DBN'l'OB BRYAN BURD, JR., "Husband", AND JOANB HARIB BURD, hereinafter called "Wife". fiITNBSSETH: fiHBRBAS, Husband and Wife were married on November 29, 1975 in County, Pennsylvania; and fiHBRBAS, Two children, DENTON BRYAN BURD, III (D.O.B 4-4-76) and MICHELLE MARIE BURD (D.O.B. 2-4-80), were born of this marriage; and fiHBRBAS, certain differences have arisen between the parties as a result of which they separated on August 3, 1994 and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which will distribute their marital property in a manner which is considered to be an equitable division of all joint property, and will provide for the mutual responsibili ties and rights growing out of the marriage relationship; and fiHBRBAS, there has been a complete disclosure of the earnings and property of each party, and each understands his\her rights under the Divorce Code of the Commonwealth of Pennsylvania; and fiHBRBAS, the parties hereto, after being properly advised by their respective counsel, Husband by his Attorney, and wife, having chosen not to retain or seek the advice of counsel, have come to the agreement, which follows, The parties heretofore, intending to be legally bound, covenant, promise and agree as follows: 1. CONSIDERATION. The consideration for this Agreement is the mutual promise, covenants and agreements herein contained. 2. SEPARATION. It shall 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. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart. 3. NO INTERFERENCE. Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. 4. COUNSEL FEES. Husband and Wife agree that all costs attributed to the instant divorce proceedings, including counsel fees shall be paid by the respective parties. 5. DIVISION OF PERSONAL PROPERTY - The parties have heretofore divided their personalty to their mutual satisfaction, and hereafter each shall own and enjoy, independently of any claim or right of the other, all items of personal property of every kind, Which are now owned or held or which may hereafter belong or come to him or her, with full power of disposition as if he or she were unmarried. The following represent specific items and there 2 . allocation: A, REALTY - The parties acknowledge that there is no real estate including appreciated value constituting marital property. B. VEHICLES - Husband and Wife agree that, hereafter, Husband shall be and remain the sole owner of the 1990 Grand Marquis currently titled in Husband's name and will make payments on the loan. Wife shall be and remain the sole owner of the 1990 Topaz currently titled in Wife's name (said title is clear and no payments are due therefore). The model and year of the aforesaid vehicles may not be exact and are used for general identification of the vehicles only. Each party will assume all costs associated with the respective vehicles and both parties will execute any documents necessary to implement the provisions of the section. C. BOAT - Husband shall have exclusive possession of and sole title to the 1986 Wellcraft Scarab I. He will assume all costs associated with said vehicle including those incurred to date, any loan, as well as future expenses. Husband will be responsible for any costs associated with transfer of title, release of liens, or any other documents involved with ownership, maintenance, or transfer of said vehicle. D. INVESTMENTS- 1) Each party shall retain exclusive control and ownership of the following accounts registered in their respective names: IRA (both husband and wife have an account with Vanauard)I Husband's Personal Savings; Wife's Personal Savings; Husband's Personal Checking and Wife's Personal Checking. 3 E. OTIIER PERSONALTY - The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them. F. BUSINESS Husband shall retain exclusive control, ownership, and responsibility for his share (33 1/3\) of Decibel's- Burd Land, Inc. including, equipment and inventory. Conversely husband shall be solely responsible for his share (33 1/3\) of any obligation associated with said business. Any obligations including debts, credit lines, mortgages, liens, or other obligations involving said business shall be the responsibility of the Husband and Husband will indemnify Wife and save her harmless from any obligations associated with the ownership, operation, or transfer of said business. G. PENSION BENEFITS Husband agrees to provide Wife with one-half of the marital value of Husband's pension (which is defined to mean pension, Silo profit-sharing, or any other plan or account or retirement or deferred income). This amount is to be computed from date of marriage or commencement of pension (whichever comes later) and date of separation. Each party agrees to execute whatever documents are required to effectuate the purpose of this paragraph. Each party appoints the other as attorney-in-fact for the purpose of consenting to any election under any plan under Section 417 of the Internal Revenue Code or Section 205 of the Employee Income Security Act of 1974. Except for the provision outlined above, it is specifically agreed that ,- 4 Wife shall receive a minimum monthly payment of be payable to her monthly from the pension plan husband receives his share of the pension. :f,J. $385.50, which shall at the same time that ~, each party's rights under their respective retirement plans constitute their own separate property. 6. JOINT DEBTS - Parties have mutually agreed to settle their outstanding joint debts in accordance with the following schedule: Husband shall hereafter be solely responsible for and save Wife harmless from responsibility for payment of the following debts: All marital obligations accruing from Nov. 29, 1975 to August 3, 1994. 7. WIFE'S DEBTS - Wife represents and warrants to Husband that she will not contract or incur any debts or liabilities for which Husband or his estate may be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her since the date of the separation. 8. HUSBAND'S DEBTS - Husband represents and warrants to Wife that he will not contract or incur any debts or liabilities for which Wife or her estate may be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him since the date of the separation. 9. TAXES - Husband and Wife agree to indemnify and hold each other harmless should either party have to pay any taxes, interest and/or penalties assessed as a result of any error in the reporting of income and/or in the preparation of any tax return by the other party during the years in which they were married. 10. WAIVER OF WIFE'S CLAIMS AGAINST HUSBAND'S ESTATE - Wife 5 does hereby remise, release, quitclaim and forever discharge Husband and his estate of and from any kind of every claim of any nature and kind whatsoever, including but not limited to any claim arising out of the marital relationship or any alleged business relationship or any constructive or implied trust that she now has or may hereafter have against Husband, or in and to and against his property, estate, whether arising out of any former contracts, engagements or liabilities of Husband, or by way of dower or claim in the nature of dower. widow's rights, or under the intestate laws, or the right to take against Husband's will or any other claims of any nature whatsoever, except only the rights accruing to wife under this Agreement. Wife hereby waives and renounces any preference or right to claim appointment or to qualify as the personal representative of Husband, or to administer Husband's personal estate and effects in the event that Wife survives Husband. This waiver includes wife's agreement to waive spousal support, alimony and alimony Pendente lite( alimony pending 11 tigation) 11. WAIVER OF HUSBAND'S CLAIM AGAINST WIFE'S ESTATE Husband hereby remise, quitclaim and forever discharge Wife and her estate of and from any and every claim that he now has or may hereafter have against Wife or in and to and against her property, estate, whether arising out of any former contracts, ~ngagements or liabilities of Wife, by way of courtesy, or claim in the nature of courtesy, widower's rights, or under the intestate laws, or the right to take against Wife's will or any other claims of any nature 6 7 whatsoever, except only the rights accruing to husband under this Agreement. Husband hereby waiver and renounces any preference or right to claim appointment or to qualify as the personal representative of Wife, or to administer Wife's personal estate and effects in the event that Husband survives Wife. 12. SUBSEOUENT DIVORCE - Nothing herein contained shall be deemed to prevent either of the parties from maintaining suit for absolute divorce against the other in any jurisdiction based upon any past or future conduct of the other, nor to bar the other from defending any such suit. In the event any such action is insti tuted, the parties shall be bound by all terms of this Agreement. 13. EQUAL DIVISION OF PROPERTY - By this Agreement, the parties have intended to effect an equal division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 14. MUTUAL RRI.EASE - Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, or 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 have, or ever had against the other. 15. BREACH - If either party breaches any provision of this Agreement, then he or she shall have the right at his or her election to sue for damages for such breach, or seek such other remedy or relief as may be available. Counsel fees of the prevailing party shall be paid by the defaulting party. Both parties are aware and agree that non compliance with this agreement permits either party to seek appropriate legal remedy, including as set forth in 23 Pa. C.B.A. S 3105. 16. ADDITIONAL INSTRUMENTS - Each of the parties shall, from time-to-time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments including deed(s) or releases which may be reasonably required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION - The provisions of this Agreement and their legal effect have been fully explained to the parties 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. The parties acknowledge that full disclosure has been made and they have been furnished with all information relating to the financial affairs of the other which has been requested and that counsel for the respective parties have reviewed the document or, in the absence of counsel, the party has waived its right to counsel. 18. ENTIRE AGREEMENT - This Agreement contains the entire understanding of the parties, and there are no representations, waiver, covenants or undertakings other than those expressly set forth herein. 19. MODIFICATION AND WAIVER - A modification or waiver of any of the provisions of this Agreement shall be effective only if 8 9 made" in writing and executed with the same formality as this Agreement. The failure of either party to insist on strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default for the same or similar nature, 20. SITUS - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 21. PARTIAL INVALIDITY - If any provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effects. 22. BINDING EFFECT - Except as otherwise stated within, all the provisions of this Agreement shall be binding upon the respective heirs, next of kin, executors, and administrators of the parties. 23, INTENT OF PARTIES - It is the intention of the parties hereto that this Agreement is a complete and final disposition of their property rights and not a mere Separation Agreement. 24. INCORPORATION - The parties agree that the terms of this Agreement shall be incorporated but not merged into any Decree of Divorce which may be entered. The parties understand and agree that this Agreement shall survive any such final Decree of Divorce and shall be independent thereof. Said incorporation shall be for the sole purpose of obtaining additional rights of enforcement and the parties understand that the provisions of this Agreement shall not be subject to any modification, unless specifically provided for in the relevant paragraph. IN WITNBSS WHBREOF, the parties have signed, sealed and acknowledged this instrument the day and year first above-written. WITNBSSBS: Q WITNBSS ~ .- (? -:? V,l)~ ....._.J..... .-:;,. . DBN'l'ON B. BURD, JR. ~ v~" - "1tt. .6-. C J1N H. BURD 10 8- .0 ~ ..., ,... ~ ~~ [Tolr.1 r:= :.e: ~;- ~(-' Iv ;:~ CI!~-:.~ ~ r-t" -n or.... d~ 2"(". -~ -" ." t::e, w ~ .P!;, .. ~, oJ' ~ :< \D DBllTOII B. BURD, JR. I III THB COURT OF COMMOII PLEAS Plaint:iff I CUMBBRLAND COUllTY, PBlIlISYLVAlIIA I VB. I 110. 95-33t3-Clvl1 Term I JOA1Of M. BURD, : CIVIL ACTIOII - LAW Defendant: I IN DIVORCB PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section (xl 3301 (cl (I 3301 (dl (11 of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: June 23, 1995. Certified Mail . 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff on June 3, 1997; by the Defendant on May 15, 1997, (b) (1) required by (2) date Defendant: Date of execution of the Plaintiff's Section 3301 (d) of the Divorce Code: of service of the Plaintiff's affidavit affidavit , upon the 4. Related claims pending: Request that terms of Settlement Agreement dated May 23. 1997. and executed by the parties be incorporated and not merced into the Divorce, 5. Date and manner of service of the notice of file praecipe to transmit record, a copy of wh'ch,is to Sanford A. Krevsky, Attorney for Plaintiff Defendant uire (X) ( ) ~ ~ 0 on ~ '- ~:n ~~ c :>:: ~2 - c. N ~t: r.') "'J ""0 53] ~~ 2 ~~ r- oo ~ 0 ~ -< c::l DENTON B. BURD, JR. Plaintift IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Cf'i. 3:3 'U c..,;.;; ~ VS. JOANN M. BURD, CIVIL ACTION - LAW IN DIVORCE Detendant HQTXCE TO DEJi'lnIP->>flLC.LAIM RIGImi You have been sued in Court. It you wish to detend against the claims set torth in the tollowing pages, you must take prompt action. You are warned that it you tail to do so, the case may proceed without you, and a Decree ot Divorce or Annulment may be entered against you by the Court. A judgment may also be entered against you tor any other claim or reliet requested in these papers by the Plaintitt. You may lose money or property or other rights important to you, including custody or visitation ot your children. When the ground tor divorce is indignities or irretrievable breakdown ot the marriage, you may request marriage counseling. A list ot marriage counselors is available in the Ottice ot the Prothonotary, First Floor, 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 CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 .' vs. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. q 5'- j J 'f.3 C(,;;.t "lLL.- DBH'l'OH B. BURD, .JR. PlaintUf Defendant CIVIL ACTION - LAW IN DIVORCE JOANN M. BURD, COMPLAINT IN DIV.oaCR UNDBR SECTION 3301 ICI OF THE DIVORCE CODE AND HOW, comes the Plaintiff, Denton B. Burd, Jr. by her attorney, Sanford A. Krevsky, and seeks a Decree in Divorce and related relief from the Defendant, and in support thereof, sets for the following: 1. The Plaintiff is Denton B. Burd, Jr. an adult individual who currently resides at, 5 Briar Lane, Camp Hill, Cumberland county, Pennsylvania 17011. 2. The Defendant is, Joann M. Burd, an adult individual who resides at 502 A Bridge street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the f1ling of the Complaint. 4. The Plaintiff and Defendant were married on November 29, 1975, Philadelphia, Pennsylvania 5. There has been no prior action for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. "'-'V",_.." 'l~~~-< I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made sUbject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Respectfully submitted, Date: Go- \'~ . a. '7 ~A~~ Sanfor A. Krevsky, E ui e Attorney for Plaintiff 1101 North Front street Harrisburg, PA 17102 (717) 234-4583 Atty. 1.0. No. 15560 , Derendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. '15- .3 )'/ j ~ "l.Lr..- CIVIL ACTION - LAW IN DIVORCE DBHTON B. BURD, JR. Pla1ntitt vs. JOANN M. BURD, VERIFICATION I, DBHTON B. BURD, JR., hereby verify that the information contained in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATE: ul/~ /9';- . ':)~~8 GJJ DBHTON B. BURD, JR. "(1"" - .. - ..- DBM'l'OH D. BURD, .:JR. P.Laintirr IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO.'1\.~ '3 '1.3 Q.;,..:.( 'T.LV- vs. JOANN M. DURD, CIVIL ACTION - LAW IN DIVORCE Derendant CERTIFICATE OF SERVICB j~ AND NOW, th1s day of June, 1995, I, Lisa A. Rice, for the Law Office of Sanford A. Krevsky, hereby certify that a copy of the foregoing complaint in Divorce was sent by Cert1fied U.S. Mail First-Class, postage prepaid, on the following: JOANN M. BURD 502 A BRIDGE STREET NEW CUMBERLAND, PA 17070 (;8~ t\2.u Lisa A. Rice 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 , / \ \ - -.'- .. -'-. IN THE COURT'OF COMMON PLEAS UMBERLAND COUNTY, PENNSYLVANIA (e) u:b1 11.S'.~U IlJ,tro P... ~. ~.,rtl SJ''L- ----,t}~O, .~ 0 JUH Z I 2 56 rK '95" NOTICE TO DEFEND AND CLAIM RIGHTS , ;LV.' orner CI'r: .: i,..T!\O"or^~V ~u.",mL!,"O OOUIi1Y f'f""~ lLVAkl.l. COMPLAINT IN DIVORCE UNDER SECTION 3301 (cl OF THE DIVORCE CODE NO. qS - 33 LJ3 DENTON B. BURD, Plaintiff v. JOANN M. BURD, Defendant ~altforb J\hm ~eu9h\! ATTORNEY AT LAW 1101 N. FRONT STREET HARRISBURG, PENNSYlVANIA 17102 717.234-4583 chlo(.1Q ..' ......-- DEIfTON B. BURD, JR. I IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . VB. . NO. 95-33&3-Civi1 Term . . . JOAIflf M. BURD, : CIVIL ACTION - LAW Defendant . IN DIVORCE . AFFIDAVIT OF CONSENT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 21. 1995. 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of final decree of divorce, 4, I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce 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, ~ 4904 relating to unsworn falsification to authorities. DATE:\ll\'\~ ':). ,qC\ '\ , Q'~~"Lf- DENTON B. BURD, JR ' n ~ 9. r::: ...., l' ~ 11 - <. N ~(: ~ ~("", ~c. ~ 0 !;~ .c U1 ~ =< co DENTON B. BURP, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. . . NO. 95 - 3343 CIVIL TERM JOANN M. BURP, . . Defendant . . LAW - DIVORCE ArPIDAVIT OP CONSENT 1. A complaint in divorce under section 3301(C) of the Divorce Code was filed on June 21, 1995. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. S 4904 relating to unsworn falsification to authorities. Date: pill '( I'J I q '1 '( , f!CL~A- JO M. BURP AI Z, .I.~ [3 \D !?, ~ ~w ~ Jii l- ::d' - - ] iE. N ~".. 0 ,....l::~ "t) .~:B -- . Ie. :I: C ~ 6~ t.~" -.~ "t;! "- UI .~ :q .., elO "'" I DENTON B. BURD, JR. I IN THE COURT OF COMMON PLEAS plaintiff I CUMBERLIUfD COUNTY, PENNSYLVANIA . . va. . NO. 9S-3343-Civi1 Term . I JOARR M. BURD, I CIVIL ACTION - LAW Defendant . IN DIVORCE . WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 eCI OF THE DIVORCE CODE 1, I consent to the entry of a final decree in divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, 4, 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: JVL\'1e... 3, l qq 1 ':)M=~\O" 4 DENTON B, B D, JR .,',,^,...~ P \D ~ -.I ~ffi t- =.t c:: il ~ ::.:: ~;t'. N ~f-;', .:..! "'tl -1 -~ I ~r :J: .::J C z ~; ~ ~ ::! VI ;<<: \0 2l .. . DENTON B. BURP, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUllTY, PENNSYLVANIA vs. NO. 95 - 3343 CIVIL TERM JOANN M. BURP, LAW - DIVORCE Defendant DIVER 01' NOTICE 01' INTEllTION TO REQUEST ENTRY 01' A DIVORCE DECREE UNDER S 3301(0) 01' THE DIVORCE CODE 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 decree is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I understand 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. S 4904 relating to unsworn falsification to authorities. Date: 1'1/ It -( (i' ( C; tj ~( : 11 N).... u, 41 gJ ~ G_.. JO~N M. BURP .- f: 10 ~ " ~Etl f: l :.:: In "!P( - ~ t5" N is'' :;) ~l...; ""t1 ~ fro :J; -c, t.) ~ C .. .~ ~ ?5 =<! \D ::< , It . . '. I DENTON B. BURD, JR. PlaintiU IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3343-Civil Term vs. JOANN H. BURD, CIVIL ACTION - LAW IN DIVORCE De.tendant CERTIFICATATION OF SERVICE I, Sanford A. Krevsky, Esquire, attorney for the Plaintiff, Denton B. Burd, Jr., hereby certify that a copy of the Complaint for a Divorce was served by Certified Mail, Return Receipt Requested on JUNE 28, 1995, on the following: JOANN H. BURD 502 A BRIDGE STREET NEW CUMBERLAND, PA 17070 DATE: "l-?J- c:r S .5 San for A. Krevsky, E q Attorney for Plaintif 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 Atty. 1.0. NO. 15560 ~"-.l!W ~ ...,1.') "... t~ or, :-~ ." ,- -~ ", ;';:"'--1;'1.. ~~(:.;t: , ..- ,.-<lel ..' ~;I ;1: -', -:'::~;;; 1"':"')''1 ..~ :1 -.- ...'" ..., -.J W Q .... -0 ::II: - c.o ..,., i{IJ=~~ ::~~___~. . ,,~,:,fI,;w':'~:::;th.7J;ir ",. ~-3.W4tlb, 'jallowlng "me..llor lIle.w. I"'J"; I. [.I'rtnt--W-....dlo........'INoI......thot".... IHI: .... " \'::..<', l, '~.::.:.~;"......IO'dlo-...........""_II._ "OAdd_'IAdchu'; , -..,_ t I.. WrtlI._IIocolptIloquooW'..dlo__dlo__ 2 0 R '-'-od D ,....... J . I 1I..'IIlo_IIocolpt..._to.._""_".._Wdlo..... ,. Ilu.." e..:", '.::' f 8 _. ConlUlt """"tll lor In. . I: 3. Artlcll Add....od tOI 41, Article Numbe, :,? JOANN 'M. BURD 4b. Service TV'" t... j. (' 'S02A BRIDGE STREET 0 Reglltlrod Olnlurod f' f '.NEW CUMBERLAND, PA 17070 lQCertlflod 0 COD I 0 Exp.... Mill, 0 Retum R""lpt IOf . " 1 7, Dltl 01 Deu.I:JUN 2 8 1& (: LB.,. SIgnotu.. lAdd'_1 8. Add..._'1 Add.... (Onlv Ifroqu"lod I' i' Indl"'"plldl " ;: h II f.. . ;. fif ::;~ I ,lU. ;I~I' 11-: ' '/ I.J '~'t4 ' .' DOMESnC RETURN RECEI!,,! .' . .. .