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HomeMy WebLinkAbout95-03376 ~ ~ . -I II) ~ ~ E: ~ J. i , I I I ~! ,.i rO' r0 . o < .:t:. .:.:. .:.:. ,:.;. .:.;. .;.:. .:.:. .:.' .:c. .>>t. :c' ':fI. .:.:. .:.:. .:.:. .;.:. .;.:. .:.;. .:.:. .:.:. :- .:.:. .:.;. .:.:. .:.;. .:.:' .:.:. .:.:. .:.:. .:.:. ';4 .-~~.-~~.__.--...-~~~..,-. '. ,_.~, --. ..-,-" '.-- -~'~'_----'~'~'-'-'--~-- ..' . \~ )~ ~_''''_~ ~.__....~. ..... <0 _._ ...__........... .....__ ~, , , ~\ , \ ~; wI "'1 ~\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '* PENNA, ~ w ~, ~I " " ~ ~ ~ ',' RICHARD E, ADAMS, PLAINTIFF 1\ 0, 95,::3,3.?~.. ............., II) " ~ " ~ VI'I....lIS s BRENDA L. ADAMS, ~ DEFENDANT ~ s ~ DECREE IN ~ w ~, w ~, ~i ~ " ~ ~ ~ 8 g 8 ~, :, decreed that... ....., ~~<::~~I?, ~,'..~I?~~,~ .... .. , ....,.. , ....,. plaintiff, ~ and ' , . . , . , . , . . . , , , , . , . ~~~.~D~. ~,', ,~!l!\!'!~ , , , , , , , , , , , , , , , , . , , " defendant. ~ ~ ore divorced from the bonds of matrimony, The court retains jurisdiction of the following claims which hove been raised of record in this action for which a final order has not yet been entered; ~ ... $ "'" ,~~~~~ ,~~~~LE~,~'l;' ,~~,~f;I,':~,~'l;' . \>I\,'l;'f;1,) , ~.Q~~~,E;~, J,7", ,l~,9,~ ,J~" ,INCORPORATED ,INTO, ,BUT ,IS, NOT, MERGED ,WITH" ,THJ:S ,DECREE., , , " ., , " ~ 8 ~ " " !' 8 $ ~ ", ~ ~ l" ._ _ _._ ,_ ' :'~:' ':.0;' .:.0:, ':.0.' le.t d / ~~ ,...."L J, _ 1'l4/'U"-e.i ~,c. " ~,f1.-r.".. ~~.-jkl r X . f2...~ f '// I)rothonolnry _ .--...., -,-,_. . - ~ ~.**~****.~****~.**~*ro~.~' -- ........ - ~ ',' ~ " . * I ~ ~ ~ ',- M " ~ ~ ',- ~ ~ .' ~ ~ ~ i,' * ~ ~ ~ I~ (:' ;;~ I.,. :~ /' I~ I: I~ , ' ,~ '~ .~ ~ !~ ".' .. ) - "- \ " 1, n,<)fJ (}d'~Iha4/~ ~ ~~ 1/-/) 'c;(, l. ,..,j.. . /1 , .b /.1'./ t1t-ua II~ld!4JI ~ ~d,? ~ .., . ~ , - ..........- ......:_. ".t RICHARD E, ADAMS, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA , , vs. . NO.1 95-3376 CIVIL TERM . , . BRENDA L. ADAMS, , CIVIL ACTION - AT LAW , Defendant , IN DIVORCE . PRAECIPB TO TRANSMIT THB 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 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Acceptance of Service signed and notarized on March 29, 1996. Please see attached Acceptance of Service, 3, Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: Plaintiff - November 8, 1995; Defendant - March l2, 1996. 4, Date of execution of Defendant's Waiver of Notice of Intention to Request Entry of a Divorce Decree: March l2, 1996. 5, Related claims pending: merging, the enclosed Property divorce decree, Please incorporate, without Settlement Agreement into the Respectf ted, shelman, Esquire of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID' 72655 Tel, (717) 763-1800 Data. -*- I ,; n VJ C) c:" Co" :.- I ~ r:.~~ ~.~ -1 2~ ~3 .iI1 /- . I .~m U> C~ ~9 r:: l' .;:'~ t."') ...:.. .. .. -i] r:.:: c- -.,. ~;r..- :~b ~" .:jfil ::-' ,.. U1 ::5 -~. \D -... f , I , I I I I I , i t' , , ,1 1,). :3j7f~ (I.{fj-I.-C MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this /711-.. day of ~ 1995, by and between RICHARD E. ADAMS, hereinafter called Husband, and BRENDA L. ADAMS, hereinafter called Wife; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 4, 1984 in Cumberland County, Pennsylvania; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they have determined to live separate and apart from each other and have consented to a mutual consent divorce; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations, including the settling of their property rights and other rights and Obligations growing out of their marriage in accordance with the provisions of the Divorce Code of Pennsylvania. NOW, THEREFORE, the parties, intending to be legally bound hereby, agree as follows: 1. SeDaration. It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place as he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as admission on the part of either party of the lawfulness or unlawfulness of the causes leading to them living apart. Each party shall be free 1 . .,.' --"--~.'--- ......-. ,.~....."':'1 " from interference, authority and control, direct or indirect, by the other as fully as if he or she were single and unmarried, Neither shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 2, Division of ProDertv and Debts. The parties have divided between them to their mutual satisfaction the personal effects, tools, equipment, household furniture and furnishings, and other articles of personal property which have heretofore been used by them, individually or in common, and neither will make any claim to any such items which are now in possession or control of the other, except as otherwise set forth herein. The parties will keep the respective automobiles in their possession as their sole property and assume the costs of maintenance and insurance. Wife shall retain as her separate property, the parties' mobile home. When the loan on same is paid off in October 1995, Husband agrees that he will execute any and all documents so as to convey the title of the mobile home to Wife. Wife shall retain all contents currently in the mobile home, the shed and its contents. The parties have the following debts which shall be assumed and paid until October, when the mobile home loan is paid off. At that time, the parties shall renegotiate the payment of the remaining balances on the respective loans recognizing that the 2 ~-'-..~....' "-" mobile home loan of $210 per month is no longer an obligation of the parties, Husband to pay: commercial credit, Northwest, Q-Card, three Finger Hut bills and Core states. Wife to pay: Mobile home loan, Discover, Beneficial and Penney bills. The parties agree that they each waive any claim that they may have to the other parties' employment pension retirement accounts and agree to execute any documents to acknowledge same. 4. Child Custodv, and Child Support. Husband is currently paying the sum of $455,00 per month which represents $347 for child support: and, $108 for child care expenses. The parties acknowledge that the child support obligation may be modified by the court for changes in circumstances arising in the future. Husband and wife shall share joint legal and physical custody of their daughter, Lakiesha. While Wife shall have primary physical custody of Lakiesha, she agrees that Husband may have liberal custody of his daughter according to the following terms. 1) Husband shall have custody of Lakiesha on all days that he is not obligated to work, provided that he gives wife twenty- four (24) hour's notice of his intent to exercise his custody. 3 I 2) Husband may have partial custody on his work-days provided Wife agrees to same. 3) The parties shall share custody on the following holidays: New Years Day, Presidents Day, Easter, Memorial Day, July 4th, I.abor Day, Thanksgiving and Christmas. 4) Every Fathers Day shall be spent with Father and every Mothers Day with Mother. 5) Husband shall have fourteen (14) days, consecutive or split, during the year. Husband shall give Wife at least thirty (30) days advance notice of his intent to exercise this time. 6) Neither parent shall remove the child from Pennsylvania without the consent of the other parent. 5, Debts. Except for the debts and obligations created hereunder, each party agrees to pay and hereby agrees to hold the other harmless from any and all personal debts and obligations incurred by him or her subsequent to the date of separation which occurred in 1995. If any claim, action or proceeding is hereafter brought seeking to hold the other party liable on account of such debts or obligations, each party will at his or her sole expense defend the other party against any such claim, action or proceedings, whether or not well-founded, and indemnify the other party against any loss or liability resulting therefrom. 4 6, Eauitable Procertv. This agreement constitutes an equitable division of the parties' marital property. The parties have determined that the division of this property conforms with regard to the rights of each party. 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 effectuated without the introduction of outside funds or other property not constituting the matrimonial estate. Each party hereby aCknowledges that this agreement adequately provides for his or her needs and is in his or her best interest, and that the agreement is not the result of any fraud or undue influence exercised by either party upon the other or by any other person or persons upon either party. Both parties hereby waive the following procedural rights: A. The right to obtain an inventory and appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code. B. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code. C. The right to have the court determine which property is marital and which in non-marital, and equitably distributable between the parties that property Which the court determines to be marital. 5 D. The riqht to have the court decide any other. riqhts, remedies, privileqes, or obliqations covered by this aqreement, includinq but not limited to possible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony), and counsel fees, costs and expenses. 7. Mutual Release. Husband relinquishes his inchoate intestate riqht in the estate of Wife, and Wife relinquishes inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assiqns, does remise, release, quit-claim and forever discharqe the other party hereto, his or her heirs, executors, administra~ors or assiqns, or any of them, of any and all claims, demands, damaqes, actions, causes of action or suits at law or in equity, of whatsoever kind or nature, for or because of any matter or thinq done, admitted, or suffered to be done by said other party prior to and includinq the date hereof; further, the parties hereto have been advised by their leqal representatives, respectively, of all their riqhts under the Pennsylvania Divorce Code, and such riqhts as are not specifically incorporated herein are hereby expressly waived, Notwithstanding the foregoing languaqe of this paragraph, this release shall in no way exonerate or discharqe either party 6 hereto from the obligations and promises made and imposed by reason of this Agreement and shall in no way affect any cause of action in absolute divorce which either party may have against the other. S, Release of All Claims, Each party, except as otherwise provided for in this Agreement, releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been incurred, or may be incurred, relating to or arising from the marriage between the parties, including waiving any claim to their respective pensions or retirement accounts, However, neither party is relieved or discharged from any obligations under this Agreement or under any instrument or document executed pursuant to this Agreement. 9. Breach. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and seek any other remedy allowed in law or equity. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. waiver by one party of any breach of this Agreement by the other party shall not be deemed a waiver of any subsequent, similar breach or other breaches. 7 10, Full Disclosure. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, of the source and amount of the income of such party of every type whatsoever and all other facts relating to the subject matter of this Agreement. 11, Divorce. This Agreement shall not be construed to affect or bar the right of either Husband or wife to a true and absolute divorce on legal and truthful grounds as they now exist or may hereafter arise. It is understood, however, that Husband, as of the signing of this Agreement, has filed an action in divorce in the Court of Common Pleas of Cumberland County, in which she alleges that the marriage is irretrievably broken. Both parties understand and agree that Husband shall pursue said divorce on the grounds that the marriage is irretrievably broken, and that both parties will execute, deliver and file the necessary affidavits and all other petitions or documents necessary to effectuate the divorce pursuant to Section 330l1c) of the Divorce Code on or before September 29, 1995. Wife agrees that the marriage is irretrievably broken. 12. ReDresentation of Parties bv Counsel. Each party has had the opportunity to have legal counsel to represent each of them in the negotiation and preparation of this Agreement and has either been so represented or has voluntarily chosen not to be represented. Each party has carefully read this Agreement and is 8 completely aware, not onlJ of its contents, but also of its legal effect. 13. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with the provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably incurred as a result of such failure. 14. MOdification and Waiver. MOdification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 15. DescriDtive Headinas. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 16. Successors and Assians. This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assignees and successors in interest to the parties. 9 17. Governina Law. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 18. Order of Court. With the approval of any court of competent jurisdiction in which any divorce proceeding may now be pending or which may hereafter be instituted, this Agreement shall be incorporated in any decree of absolute divorce which may be passed by said court. In the event the court shall fail or decline to incorporate this agreement or any provisions thereof in said decree, then and in that event the parties, for themselves and their respective heirs, personal representatives and assigns, agree that they will nevertheless abide by and carry out all of the provisions thereof. It is further agreed that regardless of whether said agreement or any part thereof is incorporated in any such decree, the same shall not be merged in said decree, but said agreement and all the terms thereof shall continue to be binding upon the parties and their respective heirs, personal representatives and assigns. 10 Wri~~ RICHARD E. ADAMS IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have hereunto set their hands and seals the day and year first above ~~ STATE O~ pennsylvania COUNTY O~ Cumberland ( SEAL) ~-'t ~OJ~~ BRENDA -L. DAMS (SEAL) . , I SS. I AND NOW, this 17th day of /lJ..-(.I-e',,,h.A,., 1995, before me, the undersigned officer, personally appeared RICHARD E, ADAMS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. seal. IN WITNESS WHEREO~, I hereunto set my hand and official G NotuI.~&lllI AroeIa F.lJno1<, r%l,'Y Pt.llIc CMiio Iloto, CClI'.born.. d eo, .. ""--.-'. --- ..' . ".~C~.~::n ~'::'~O.:t :.:.1.rtJ6 ,J.;J ,.t, I 1.I:1"",.,~",,,, ~._.:.'- '::'_'~, . u' j STATE O~ Pennsylvania COUNTY O~ Cumberland . . I SS, I AND NOW, this day of , 1995, before me, the undersigned officer, personally appeared BRENDA L. ADAMS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREO~, I hereunto set my hand and official seal. Notary Public 11 r:'- .-''''" . .. ~~:',-: t:? ,) wll :I .,~ '1'-< -,' "'( n ,!;,-, ',7) :-\.' ;..,i-n :..1 :"1 ..... r', r , " ~. -.. r --"I : J I (~ .' ..!'" ,~J' \0 'I ~ RIQIARD E, ADlIMS, Plaintiff IN 'llIE CXllRI' OF cx:KDl PIEA9 OF aJMBERI.1INO CXXlNI'lC, PmNSYLVANIA CIVIL lICI'IOO - IJ\N 00, 95-3374> CIVIL '.l'EDI IN DIVORCE VB, ~ L, ADlIMS, Defen:lant OOl'ICE rro DEFEND AND CIAIM RIGHIS You have been sued in court. If you wish to deferxl against the claims set forth in the following pages, you nust: take pratpt action, You are warned that if you fail to do so, the case may prcceed without you an:1 a decree of divorce or annulInent may be entered against you by the court. A judgment may also be entered against you for arrj other claim or relief requested in those papers by the Plaintiff, You may lose m:mey or property or other rights inportant 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 coonseling. A list of marriage coonselors is available in the Office of the Prothonot:azy at the OJmberland County Court House, Carlisle, Pennsylvania. IF YOO 00 NOr FIIE A CIAIM FOR ALlMJNY, MAIU'l1\L PRJPERlY, CXXJNSEL FEES OR EXPmSES I2OrUl<l:O 'llIE FINAL rm::m:E OF DIVORCE OR ANNUIMENl' IS GRANTED, YOO MAY IDSE 'llIE RIGIfl' rro CIAIM ANY OF 'lllEM. YOO SKXlID TARE 'lHIS PAPER rro YOOR ATroRNEY AT WCE. IF YOO 00 NOr HAVE 1lN ATroRNEY OR C1lNNCIl' AFFURO ONE, GO rro OR '1'EI.EFHCt-lE 'llIE OFFICE SEl' roRIH BEI.CM rro FIND <X1l' WHERE YOO CAN GEl' !mAL HELP. Court Jldministrator OJmberlan:1 County Court House Fourth Floor Carlisle, PA 17013 Telephone: (717) 240-6200 '1he Court of Cl::.mn:m Pleas of OJmberlan:1 County is required by law to OC1T(Jly with the 1Imericans with Disabilities 1Ict of 1990. For information about accessible facilities an:1 reasonable a~",lOdations available to disabled individuals having bJsiness before the court, please contact our office. All arr<m;Jements nust: be made at least 72 hours prior to arrj hearing or bJsiness before the court. You nust: attend the scheduled conference or hearing. , " ! " l,," ,I I II I! I, RIaIARO E, AIllIMS, Plaintiff ... IN 'DiE 0XlRl' OF c:aM::N PIFA9 OF aJMBERU\NO CXXJNI'l(, ~ I vs, BREND.\ L. AIllIMS, Defendant : CIVIL ACTIOO - U\W NO, 95-33740 CIVIL TmI IN DIVORCE a:MPIAINl' UNDER SElCl'IONS 330ltCI AND 3301101 OF 'IlIE DIVORCE CDDE 1. Plaintiff is Richard E. lldams, an adult in:llvidual who currently resides at 615 Woodlan:l Avenue, Mt. Holly Sprirgs, Olrnberlan:l Coonty, Pennsylvania. 2. Defendant is Bren:UI L. lldams, an adult in:llvidual who currently resides at Big Sprin:J Terrace, Lot 146, Newville, Olrnberlan:l Coonty, Pennsylvania. 3, Plaintiff am Defendant have been bona fide residents in the Oatm:lnwealth of Pennsylvania for at least six IOOllths iImnediately previous to the filin;J of this 0:IIp1aint. 4. 'Ihe Plaintiff am Defendant were married on July 4, 1984, in Olrnberlan:l Coonty, Pennsylvania. CXXJNl' I - DIVORCE Plaintiff hereby incozplrates by reference averments 1 tiu:'ou;Jh 4 as if each avement were set forth fully hereun::ier. 5, '!here have been no prior actions of divorce or for annulment between the parties as to their current marriage. 6. Neither Plaintiff nor Defendant is in the Atmed Forces of the united states. 7. Plaintiff avers that the marriage between the parties is iITetrievably broken. 8. 'Ihe Plaintiff has been advised of the availability of oounselin;J ani , I \1 I that he may have the right to request that the court require the parties to participate in ocunselirg, 9. 'Ibis action is not collusive, o:xJNl' II - DIVISION OF PROPERl"i AND DEIJl'S plaintiff hereI:ly incorporates by reference all of the avenrents contained in co.mt I of this a:.tplaint. 10. 'the parties have acquired a ndJile hane located at Big Sprirg TerraO!l, Lot 146, Newville, Olmberlard county, PA, durirg the course of their marriage. 11, 'the parties have acquired hane furnishirgs, motor vehicles, bank aoocunts, ard misoellll1'll!Q.\S items of personal ptqlerty. 12. 'the aforesaid items are marital ptqlerty ard the Plaintiff requests that they be equitably divided. 'the parties have also aCCl.ll1Ulated marital debt ard this shoold be equitably divided also. WHE:RE:roRE, Plaintiff prays that a decree be entered in favor of the Plaintiff ard against the Deferdant as follows: a) 'Ihat a decree in divorce be entered; b) 'l11at the herein described marital ptqlerty owned by the Plaintiff ard Defendant be cllstrihrt:ed aooordirg to law; c) 'l11at the marital debts be cllstrihrt:ed aooordirg to law; ard, d) SUch other additional relief as the Court deell'S neoe<3'?ry, Respectfully sul:tnitted, O'BRIEN, BllRIC & SCHERER ~~~. Robert L, O'Brien, ~ Attorney for plaintiff I " I verify that the statements made in this OcITplaint are true and correct, I understan:l that false statements herein are made IlUbject to the penalties of 18 Pa, C.S, S 4904, relating to unsworn falsification to authorities, tP~ !$I~ RIOfARD E, ADAMS D:lte: ~. )J.9, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (j) JUN ZZ I Z4 f'H '95 COMPLAINT IN DIVORCE , , :)1 flOt: 0;' '.,' ,'rlluN')lA~l CU"",e"Lt,Hl' Ct':!ilY ~tHli~\'L"MI'A RICHARD E. ADAMS, Plaintiff -$ 175,50 pdQtb.t 5 ,00 So...-\. , v. BRENDA L. ADAMS, Defendant 'J J SO . 50 pd a:tbt / 5' . OD e~rcl.. COVl\.{; CIVIL ACTION - LAW - .~ I C) 5, 5 c) p:J a.Ttct c..u.. tI: .; 3 3 3 ~~ ~~q:l~ ' lAW omcr.:r. O'BRIEN. IWIIC rr SCHERER 17 wr.sT ~I SoTKt.r:T CAllLISu:. fI'.liNSYLVNlI^ 17013 . . '.-0'.--.. . , , rIOIIlQ,D E. Af)t\l.As, ~ :1 AJ ,Ht" ('cv/Cr of rOM41tJ).J Pt~"':, , 'Plc.,.d./f . (UMBCRl-A.AJD cw'ill, FtIJJJo;'ILV,I\.AJ '4 0 ~ \J~, , C I \/( L .A cr/oA..) AJo q$""- 33"7' ~ , &~[)4. L, AJ>i~~., . k1ioIJ :r:N .D/VO~GC , :r;e.{; ,cl,.r{ ~ /lr l.;tw u ACCfrTAJVCE- OF S:EJ<L/IC~ .T ~ccep+eJSen.dCJL Jfk. Cc'~~I't1+ vvtkr ~diC)\1.S 3?i)/(c) aVId ,3S? I (J) vHAe_J)lJoru..~ ~ ~ V\ ~ UVle. cf /qq,<)Q ~ bAte ~'YI.r:hc. ;::I, ~~ "'1 :Er<<IVM L. AM,.,S J J)cFcNi;),1JJ\ l.\,\l.l:.~ ~Cl1o. ").'9< <\E'J.<) ~J:.J ,m~ iJU.cl.fq ').Q,ia~ 1111,1 4AJ1f? -4 [)];Rcs S .s~.v /0 ~~1> S'U~S'(RV3ED J3fF~ ft1E, T It~ /JIJ~(.W"'" AJCl7.-tf$Y'Pv13 LIC TfllS ~rlll 11ly or- iJu,~* /990" C {J/ftYl NOI ' al Seal MaUheW J, esh Ima", Notary PublIC Camp Hili Bo'o, Cllmbe~8od cau~ My commlll'n' F,.!'.' Nov, 15,19 Member, PennsylVanl. An~"110n 01 NOlirleS . . n F' 'Tl :: ~;~ '-:-'. \,1)," r::r, ;,:; -- ....-. .;, -. -, ...... t..:) oJ) n -;, -. '~::g 01.,., .0 ;('1 :'j] .;:.u ,~n '~~ITI '_:~ ....- I',~ ';'.,. :~ ,- I C? -::' (,) " <..<1 C) ".'. RICHARD E. ADAMS, IN THE COURT OF COMMON PLEAS plaintiff . CUMBERLAND COUNT~,PENNS~LVANIA . v, CIVIL ACTION-LAW . . BRENDA L. ADAMS, NO, 95-3376 CIVIL TERM Defendant . CIVIL ACTION-IN DIVORCE . AFFIDAVIT OF CONSENT 1, A complaint in Divorce under section 3301 (c) of the Divorce Code was filed on June 22, 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. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or 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. 5. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 6. I am not a member of the armed forces, nor in active military service, of the United States of America or the Commonwealth of Pennsylvania. 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., unsworn falsification to Date: II-o~-9S r I .:' .- ,:~ -, '- r-. i .:~ ~;:' :'..:;. '~, ~ ~.-. :r - p.:: ~.. --; ...... '~Q - "' "' , '-. C>'. <= ~~~ "':;.1"'1.-: z;J""'JfT1 :r.. ~'l~ ~~~':'JO I.... .,. .:oi. ':" '.e- "'_ r _. :" '"~ :;.-.:. _~ f1" X" .'", -< ;.. ~i ( \.-: ~ , r. ~ c..D ..ro = C> '"" = = N .... - :s: - lU:I c.n I -:--:" ..............-.'...--.. RICHARD E, ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA 1 vs, I NO.1 95-3376 CIVIL TERM 1 BRENDA L. ADAMS, . CIVIL ACTION - AT LAW , Defendant IN DIVORCE DEPENDANT'S AFFIDAVIT OF CONSBNT UNDBR SBCTION 330lfcl OF THB DIVORCB CODB 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on the 22nd day of June 1995, 2, The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of 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. 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, S 4904 relating to unsworn falsification to authorities. Signature: ~ d~..L1 Brenda L: Adams Dated::!:,II;)..l q (", ~, ,':) . , C) ,"-' Q-. , -n ::..,. ~~l: ~ 11 "J :.:~ ;~: r- I {n~ <::' ~_:. .:fl -., ~ -"~ :-~;; . .,:a ....l ,-.() .J.... ~~ (,) ".jln ;-1 ~.n ~ .' Cl;l .... RICHARD E, ADAMS, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs, I NO,I 95-3376 CIVIL TERM I BRENDA L, ADAMS, I CIVIL ACTION - AT LAW Defendant I IN DIVORCE DBPENDANT'S WAIVER OF NOTICB OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREB UNDBR SBCTION 33011cl OF THE DIVORCE CODB 1. I consent to the entry of a final decree of divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, 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, S 4904 relating to unsworn falsification to authorities, Signature I ~ '/ ~~ Brenda L. Adams Dated:.'3 I J;./ q(p ~:'.. ...._ i ,- :-~.':.. -~ ~ ~-} -' ~~< :-j w .. (Jl m tf"l t..;.:l :-~ ~'~.J .:; I c:> :::> "tl 1 .;;G; :;0 _'ir1) .;:0- ....'. ) '1 .~) .jrr, ,-I ,~ ::t 7'