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Home My WebLink About95-03636 .:J J J . -7 ~ J J " (Y). ~ rfJ ~ ." .~.~..~*.~**.~.~.*.~..~.~..~..*..~.~..~..*..~~ ~ -,.."....,. ,-., '","" . " ';'1 ~I ~l ~l SI ~ ~ .:+;. -:.:. .~;. .:+:. .:.:. .:.:. .:.:. .:.:. .:t:. .;. " , , , -, 18 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND I~. STATE OF ;~~~! \'......~,,# ....,. M DECREE IN ~ D I V 0 R J? j:" 2- :2.8 Pf'I!: AND NOW. ()(Ji6W-. 20 . . . .. 19..... " I, o,de,ed ood ii I l~ decreed that ,..,.,......., MAR~A~ET. ANN, n~!-f9f'1:1'.r. . . . . . . , . , . . . " p aintiff, 8 and. . . . . .. . . , . . . .. .. . ~qH!'lR.r.~IWW .Q~F:QtfI:~ . , ' . . , , . .. . . .. . ., defendant, ,;, ... are divorced from the bonds of matrimony. 18 ,;" ,,\ ,;, ~ 8 ,;, ... MARGARET ANN BELFONTI, PLAINTIFF ,;, ... ,;, ~, \','1',,,11:1 w '.' JOHN RICHARD BELFONTI, DEFENDAm' ,;, ... ~ .' ;;, ... ,;, ~ ,;, ~ ~l ~ o~ ~ 8 8 8 8 8 ~ ~ ~ 8 w ... M " ~ 8 8 ~ ~ ~- - - " - ..>>:' -:<<. .:.:. .:to:. .:.:. ..~. COUNTY PENNA. i\ t I, 95:-3636 ...,... 11) 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; None It is further ordered and decreed that the Separation and Property Settlement A~reelOO!1t, exe~u.t,ed, by. .a.n,d. .be~w:eEll1 ,t;11El ,P'1t:t;tEl". .QilteQ.September.17,.1997,..is incorporated by reference into this Decree for the purposes of enforcement, PUt:, shall. not, 00. deeJred ,to havo ,boon ,morgod ,with. this, Decree. ' . . . . . , . . , , . . ..1' I, '" . /1/.)/(. .t~ /.-';"~.-"l .I. I .....((,It/I.'' , 1l.t"l1"'1 I . V J /. 1.'/ ,/ ';1:'o/('V, .r ......e'c~' ~~ / .,/ 1'. III I III II II I a 1')' ~ .~.~,.*,~..~.~..~-,~,.~:.~..~,.~"~.~.:.:..~~.: ","'""l~'- ~, ~ ~ w ',' ~ ~ 8 ~ ~ ~ ~ ~ 8 ~ M ,; ~ ~ .w i'.' I~ I' (~ ~ <:" , ,~ I'" I,', ,~ , . :0: ., ~ ~ . ~ :~ ro /I" ,.),.tJ'} c1#1 .tr;, /1:.4/'-;: c;.:-4 ,~t4~ I() ',J/t/) I~llk( tllhJ.J.(/ t,~. x)ldt+wJ,..~r , .. .,.' . IN TIlE COURT OF COMMON PLEAS OF ClJMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LA W MARGARET ANN /IELFONTI, Plmnlln' No. 1)~.3636 CIVIL TERM v, JOHN RICHARD BELFONTI, D~f~ndmll IN DIVORCE lES . )NS ORDER AND NOW, thifll-_ day 01 ___._-,-, 1997,11 appearing to the courtlhat: I, TIle parties herelo are Husband and Wife, having be~n married on May 21. 1961, A Complainl in Divorce has been filed 111 th~ Court of Common Pleas of Cumberland County. Pennsylvania al 95-3636 CI\11. Said dlvorc~ action IS pendll1g; IT IS ORDERED, ADJUDGED, AND DECREED as follows 2. John Belfonti, (SSIII64.30-2073) hereinafter referred to as Defendant, or the Participant, is a participant in the Military Relirement Syslem Pension; 3. Margaret Ann Belfonti (SSII 207.32-~896) hereinaner referred 10 as Plaintiff. or altemate Payee, has rmsed cJanns for, inter alia, equitable distribution of marital property pursuant to the Pennsylvania DIvorce Code. 23 Pa CSA ~IOI, et seq.; 4, Defendanl's current and last known address is 1021 West New Street, Lancaster, Lancaster County. Pennsylvania 17603; 5. Plall1tiff's current and last known address is 1953 Daybreak CircJ~, Harrisburg, Dauplun County, Pennsylvania 171 10; 6 This Court has compelent jurisdiction mthe above captioned action by virtue of the parties' domicile 111 the terrllonal jurisdIction of the Court, 7. All relevanl proVISIons of the Soldiers and Sailors Civil Rehef Act of 1940 have been observed I. A portion of the aforemenllOned Military Retirement System Pension account is marital property subject to distnbUtlon by this Court; 2, '111e plan to which IhlS order applies is Ihe Military Itetirement System Pension or any successor plan. , '111~ sum of S4.1 K UU p~r mouth shnll hI) tnkl)ulrlllllthl) I'nrtlclpant's dlsposnhll) Mlr~ml)nl pny nnd awnrdl)d 10 Altl)mntl) I'nYl)1) I'nyml)nls shnll COnll11l)nCI) nllml)dlnll)ly !'nrticllllll1\ shnll conllnul) to plll\ldl) Altl)mntl) l'aYl)1) wnh SUr\'ll'or Iwnl)lit plllll covernlll) und~r l'artlclpllllt'S nllhlnry rl)lIrl)ml)nl systl)m pl)nSlon plllll 1 Notlllull contnml)d mlhls UOInl)sllC RI)Inlllll1S Ordl)r shnll hI) construl)d 10 rl)quir~ th~ I'lnn or thl) I'lnn Admllllstrnlor n To pro\ldl) to thl) Alll)mnll) PnYl)1) IIIIY tYPI) or limn ofbl)nl)lil, or any option, not olherl\1se al'nllahle under Ihe I'lnn, or b. To pay nllY bl)nefits to the Ahemate I'ayel) which arl) rl)qulred to be paid 10 nnother ahemale pnyee under another domestic rl)lallons order pre\1ously determined by the 1'111I1 Adnllmstrntor to be a QURO; or c To require Ihe 1'111I1 to pro\1de mcrea.~l)d benefits. 4, 'Ille parties shall promptly nollfy th~ Military Relirement System I'ension administrator of nny chllllge to Ihen addresses as set forth in tillS Order 5, TIle parties are directed 10 tnnely submit all documents, including releases, Ihat are required to finalize this Order A Certified copy of Ihis Domestic Relallons Order shall be served upon the I'lnn Administrator IT IS INTENDED that II1Is Order shall qualify as a Qualilied /)omesllc RelatIOns Order under the Retirement Equily Act of 19K4 nnd nllY successor acls or amendmenls 'Ille Court relains jurisdiction to amend this Ordl)r as may be necessary 10 establish or maintain its status as a Qualified Domestic Relalions Order under the Relnemenl Equily Act of \984 This Qualified Domesllc Relations Order has been draned in accordnnce With the marital property distribution agreed 10 by the parties TIle Irnllsler of I'lnn funds pursulll1\ to this Qualified Domestic Relallons Order IS not intended by Ihe parties 10 constitute in nny way a sale or exchnnge of assets, nnd the dl\1Sl0nls being enectl)d wnhoul the introduction of outside funds or other property not conslllutmg a part oflhe manlal I)slat~ h IS recognized that the parties inlend this trnnsfer 10 be non.taxable J ." ,,'" ,I' , ' ,;,' '", : 1,' i, I .' WI.Q) '11()'kl ~II~JM 't. ,rI6~lu\. .., "iH4t1,~,.p . v. I I I I I I I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95"3636 MARGARET ANN BELFONTI I PLAINTIFF JOHN RICHARD BELFONTI DEFENDANT CIVIL ACTI0N - DIVORCE S'lm1LATIO.N AND NOW, thb 7'111.- day of ((J(! .J(}/;"r , 1997, oounsel for the parties in the above referenoed aotion hereby stipulate and agree that the Order attached hereto encompasses the intent of their respective olient and that it may be adopted as a Court Order. IKIOIL, DeARMOND , DeARMOND By: Ann ,Lev n, EsqU re LD. No. 70259 2917 North Front street Harrisburg, PA 17110 (717) 234"2401 Attorney for Plaintiff By: . Ke I.D, 2800 Camp Hill, PA 17011 (717) 730-9394 Attorney for Defendant :8 Q a ... I:> OJ :!1 u :~ .'~ fti , ;,. ~o! ~ -;, ~," ~., .. hI In . " MARGARET ANN llELFONTI. PLAINTIFF . IN THE COURT OF COMMON PLEAS OF . CUMUERLAND COUNTY, PENNSYLVANIA VS. . NO. 95.3636 CIVIL TERM . CIVIL ACTION - LAW JOHN RICHARD llELFONTI, DEFENDANT : IN DIVORCE BE.PARATION t\ND PROPE.RTY SElTLEMENT AGREEMENT This Agreement made this -11- day of ~.Je.'\J , 1997, by and between Margaret Ann Belfonti, 1953 Daybreak Circle, Harrisll rg, Dauphin County, Pennsylvania 17110, pany ofthe first pan, hereinafter referred to as "Wife" and John Richard llelfonti, 102] West New Street, Lancaster, Lancaster County, Pennsylvania 17603. party of the second pan, herinafter referred to as "Husband". WITNESSETH: WHEREAS, Husband and Wife were married May 21, 1960 in Washington, District of Columbia; and WHEREAS, there are two children born of this marriage: John Richard Belfonti, Jr., date ofbinh, December 2, 1964 and Jill Renee' Belfonti, date ofbinh, December 12, ]966; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania, and have been so, for al least the past six months; and WHEREAS, this Court has competent jurisdiction in the above-captioned divorce action by virtue of the parties' domocile; and WHEREAS, as Husband has been a member of the Anned Forces of the Uniled States, and through government services has acquired certain benefits as described herein, all relevant sections of the Soldier and Sailor's Civil Relief Act of 1940 have been observed during this action; and WHEREAS I certain differences have arisen between the parties hereto and as a consequence, they have lived separate and apart since October of 1994; and WHEREAS, Ilusband and Wife desire to scllle and detcrmine certain of their marilal rights and obligations, and make on equilable distribution of their marital. property, determine their rights to alimony. support and other mailers which may be considered under the Divorce Code; and \ , WHEREAS, it is the intention and purpose of this Agreement to set forth the respective ri!!hts and duties of the parties while they continue to live apart I[orll each other and to settle all financial and property rights between them; allll WHEREAS. the parties hereto have ntutually entered into an agreement for the division of their jointly owned assets, the provision for the liabilities they own, and provision for the resolution oflheir mutual din1:renccs, after both have had full and ample opportunity to consult with attorneys of their respective choice, the parties now wish to have that a!!reement reduced to writing, NOW THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth hereinafter and for other good and valuable consideration, and Intending to be legally bound and to legally bind their heirs, successors, assigns and personal representatives, do hereby coven anI. promise and agree as follows: ARTICLE I ~EMRA TION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each olher and to reside from time to time as such place or places as they shall respectively deem fit, free from any control. restraint, or interference, direct or indirect, by each other. Neither party shall molest the other or compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions 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 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 actions for divorce, whether absolute or otherwise, upon just, legal and proper ground, nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party. or Irol1\ making any just or proper delense thereto, It is warranted, covcnanted, and represented by Husband and Wife, each to the other that this Agreement is lawlhl and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife 10 execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason, illegal, or unenforceable in whole or in part. Husband and Wife do each hereby . ....- -." .- ., warrant. covenant and agree that, In any possible event, he and she arc and shall forever be estopped from assel1ingany illegality or unenlorceability as III all or any pal1 of this Agreement. The pal1ies acknowledge that a Divorce action has been tiled in the COUI1 of Common Pleas of Cumberland County. I'ennsylvania at No. 95-3636 The pal1ies agree lhatthey have executed Aftidavils of Consent in the aforementioned mailer 2,2 II is fUl1her specifically understood and agrced that the provisions of this Agreement relating to the equitable distribution ofpropel1Y of the pal1ies are accepted by each party as a final selllement for all purposes whatsoever. Should either of the pal1ies obtain a decree, judgment or order of separation or divorce in any other state, country, or jurisdiction, each of the pal1ies to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be affected in any way by any such separation and divorce, and that nothing in any such decree. judgment. order or fUl1her modlncation or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the pal1ies should remarry, it being understood by and between the panies that this Agreement shall survive and shall not be merged into any decree. judgment or order of divorce or separation. 2.3 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 either of the pal1les hereto. such incorporation, however. shall not be regarded as a merger. it being the intent of the pal1ies to permit this Agreement to survive any such judgment or decree. ARTICLE III EQ.IDTADLEllillBIPUTION Of MARITA~ PROPt:RTY 3.1 The pal1ies have allempted to divide their marital propel1y In a manner which conforms to the criteria set fol1h in Section 3502 of the Pennsylvania Divorce Code and taking into account the following considerations the length of the marriage. the prior marriages of the pal1ies. the age. health. station. amount and sources of income, vocational skill, employability. estate, liabilities, and needs for each of the parties. the contribution of one party to education, training or increased earning power of the other pal1y, the oppol1unity of each party for Ihture acquisition of capital assets and income, the sources of income of both parties. including but not limited 10 medical. retirement. insurance or other benents, the contribution or dissipation of each party In the acquisition, preservation, depreciation. 1II appreciation of marital property, Including the contribution ofa pal1y as a hOlllemaker, the value of the propel1y set apart to each palty.the standard ofliving oflhe pal1ies established during their marriage, the economic circumstances of each pal1y, Including lederal, state and local tax ramifications. at the time of the division of the prllpel1y is to become ellective ., 3.2 The division of exisling marital property is not intended by the pal1ies to constitute In any way a sale or exchange of assets. The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribulion of the pal1ies 3.3 Tangible Personal Property. Husband and Wife acknowledge that they have divided their personal property to their mutual satisfaction including all furniture, jewelry, automobiles and other tangible property. Therefore, Husband waives all right, title and interest in all personal property currently in the possession of Wife. Wife waives all right, title and Interest in all personal property currently in the possession of Husband. 3.4 The parties acknowledge that they are owners of three cemetery plots located in the Gate to Heaven Cemetery. Husband agrees to transfer all right, title and interest in two of the plots to Wife. Wife agrees to transfer all right, title and interest in one cemetery plot unto Husband. Said pIotto be one adjoining the cemetery plot of the pal1ies deceased daughter. ARTICLE IV RmREMENT INTERESTS ANI> DENEFIT& 4.1 Husband and Wife acknowledge that Wife is a participant in the Pennsylvania Blue Shield Retirement Plan with a present value 01'$82,287.00 and the Pennsylvania U1ue Shield Voluntary Investment Plan with an accumulated value 01'$45,522.00 Husband is a pal1icipant in the Military Retirement System Pension with a prescnt value earned during the marriage of $151,58000 and a State Employee's Retirement System Pension, the present value of the marital portion for which is $181,45700 In ordcr to effectuate an cquitable distribution of thc aforementioned Rctiremcnt and Pcnsion Plans, the parties have agreed to a 50/50 distribution to be carried out as follows: a Husband waives nil right, title and intcrest in Wile's Pennsylvania Blue Shicld Retircment Plan and Pennsylvania /lIue Shicld Voluntary Invcstment Plan; b. Husband shall transfer to Wile, utilizing a COUI1 Order, a monthly benent 01'$43800 from the pension provided by the Military Retirement System A copy of the Court Order which will be utilizcd to accomplish thc distribution of Husband's Military Retircment System Pension is all ached heretll and Incorporated herein by reference as Exhihit "A"; c. lIusband shall continue to providc WIfc with Sill' bcnelits undcr Husband's Military Rctirement Systcm Pcnsion Plan, current cost IlIllusband of said benelit is $86 27. and d. Wifc waivcs all right, titlc and intcrcst in Ilusband's Statc Employce's Retirement Systcm Pcnslon. 4.2 Real Propel1y It is acknowledged thatllusbanu has already executed a waivcr of any interest in certain real propcrty own cd by Wife located at 1953 Daybreak Circle, Harrisburg, Dauphin County, Pennsylvania 17110. Pal1ies acknowledgc that they were owners of certain rcal propel1y located at21 5 NOl1h 26th Street. Camp Hill. Cumbcrland County, Pennsylvania 170 II, but said propcrty has been sold and the proceeds have been divided to the parties' mutual satisfaction. Therefore. the pal1ies hereby waive all right, title' and intcrest in any and all proceeds derived from said sale. ARTICLE V DEBTS OF TII..E PI\RTI~ 5.1 Husband and Wife will remove each other from any joint accounts which include checking, saving, retirement accounts, and each releases the other from any obligations or claims on said accounts. ARTICLE VI ALIMONY AND SUPPORT 6.1 Husband and Wife hereby waive any and all right to receive payments on account of spousal support, maintenance, Alimony Pendente Lite, Alimony, counsel fees or costs or any other payments ofa similar nature to which he or she, in the absence of this Agreement, might be entitled by statute including rights arising pursuant to the Divorce Code of 1980 as amended, or similar law ofany jurisdiction which may be applicable now or at any fhture time. AlntCLE VII MISCELLANEOllS PROVISIONS 7.1 Advice of Counsel. The provisions of this Agrccment and their legal effect are fully understood by the pal1ies The pal1ies understand their Icgal rights and o,bligations. Husband has been represented in this mailer by Keith n. DeAmlOnd, Esquire of Camp lIill. Pennsylvania. Wife has been represented in this mailer by Ann V. Levin, Esquire ofHarrisburg, Pennsylvania. .. , , I Thc pal1ics acknowlcdgc and acccptthat this Agrccmcnt Is, in thc circumstanccs, fair and equitablc, that is bcing entcrcu into Ircely and voluntarily, aner having rcceivcd such advicc and with such knowlcdgc that cxccution of this Agrccment is not thc rcsult of any duress or unduc inlluence and that it is not the result of any collusion or improper or illegal agreemcnt or agrcements. 7.2 Counsel E~fi Thc pal1ies agree Ihatthey will each be responsible for their respective costs and allorneys fees associated with this action 7.3 Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other. for alltimcs to come and for all purposes whatsoever, of and from any and all rights. title and interest. or claims in or against the property (including income and !lain from propeny hereal\er accruing) of the other or a!lainstthe estate of such other. or whatever nature and wheresoever situate. which he or she now has or at any time hereafter against such other. the estate of such other, or any part thereof, whether arising out of any former acts, contacts, engagements, or liabilities of such other as by way of dower or cUl1esy, or claims in the nature of dower or curtesy or widow's or \vidower's rights, family exemption, or similar allowance. or under the intestate laws, or the right to take against the spouse's estate, whether arising under the laws of (a) Pennsylvania. (b) any state. commonwealth or territory of the United States. or (c) any country, or any rights which eirher party may have or at any time hereafter have for past, present, or future SUPPOI1 or maintenance, Alimony, Alimony Pendente Lite, counsel fees, costs or expenses, whether 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 each other by execution of this Agreement a full, complete, and general release with respect to any and all propel1y of any kind or nature. real or personal, or mixed, which the other now owns or may hereaner 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 7.4 Release ofTestamentary ClailM. Except as provided for in this Agreement, each of the pal1ies hereto shall have the rights to dispose of his or her property by Last Will and Testament, or otherwise, and each of them agrees that the estate of the other, whether real, personal or mixed. shall be and belong to the person or persons who would have become entitled hcreto as if the descendant had been the last to die. This provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's last Wills undcr the present or Ihture laws of any jurisdiction whatsoever and is intended to confer third party beneliciary rights upon the other heirs and benenciaries of each other party hereto Either pal1y may. however. make such provisions for the other as he or she may dcsire in and by his or her Last Will and Testament. Each of the parties fhrther covenants and agrees that he or she will permit any Will of the other to be probated and allow administration upon his or her personal. real or mixed estate and effects to be taken out by the person or persons who would have been entitled to do so had Husband or Wile died during the Iiletlme of the other and thatncither lIusband nor Wile will claim against or contesllhe Will and the estate of the other. Each of the par1ies hereby releases, relinquishes and waives any and all rights to act as executor or execulrix or administrator or administratrix of thc other party's estatc Each ofthc parties hereto fill1her covenants and agrees lor himself and herself and his or her heirs. executors, administrators and assigns, that hc or she will never al any time hercaller suc thc olhcr pal1y or his or her heirs, executors, administrators. or assigns, for the purpose of enforcing any of thc rights rclinquishcd undcr this Paragraph 7,~ WArranties Each party rcpresents that they have not herctolorc incurred or contracted for any debt or liability or obligations lor which the estate of the other party may be responsible or liable, except as may be provided for in this Agrecment Each pal1y agrees to indemnitY or hold the other pal1y 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 warrants, covenants. represents and agrees that each will, now at all times herealler, save harmless and keep thc other indemnified from all debts, charges, and liabilities incurred by the other aileI' the e~ecution date of this Agreement. except as is otherwise specifically provided for by the terms of this Agreement and that neither of them hereafter incur any liability whatsoever for which the estate of the other may be liable 7.6 No waiver or modification of any of the terms of this Agreement shall be valid unless In writinll and signed by both pal1ies and no waiver of any breach hercof or default hereunder shall be deemed a waiver of any subsequent default of the same nature 7.7 Ilusband and Wile covenant and agree that they will fOl1hwith execute any and all written instruments. assignments, releases, satisfactions, deeds, notes or such other wrilinlls as may be necessary or desirable for the proper implementation of this Allreement. and as their respective counsel shall mutually agree should be so executed in order to carry fully and ellectively the terms of this Allreemenl 7,8 This Agreement shall be construed In accordance with the laws of the Cml1monwealth of I'ennsylvanla which arc in enec~ as of the date of thc execution of this Agreement 7.9 This Allreement shall be bindlnll and shall inure to the benefit oflhe parties hereto and their respeclive heirs, executors, administrators. successors and assigns, 7.10 This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warrantles other than those expressly set forth herein. 7.11 Severability. 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 any party to meet his or her obligation under any or more ofthe articles and sections shall in no way void or alter the remaining obligations of the parties. 7.12 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 Divorce Code of the Commonwealth of Pennsylvania. 7.13 Disclosure. The parties warrant and represent that they have made a full disclosure of all assets prior to the execution of this Agreement. . 7.14 Enforceability and Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties, and any independent action may be brought, either at law or in equity. to enforce the terms of the Agreement by either Husband or Wife until it shall have been tully satisned and performed. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties of the other. The adequacy Ill' the consideration for all agreements herein contained and stipulated is confessed and admitted by the parties, and the pal1ies intend to be legally bound hereby. In the event either party breaches the aforesaid Agreement and it is detemline(through appropriate legal action that the alleged party has so breached the agreement the breaching party shall be responsible lor any and all al\omeys' fees as well as costs and expenses associated with litigation incurred by the non-breaching party to enforce this Agreement againstlhe breaching party. 4<<J.I..IPAAII<.1PU 111 TAANSMITIAVIAIoIIWUll'lll:.."", MARGARET ANN BELFONTI, PLAINTIFF I IN TilE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSVLVANIA I I NO. 115-3636 I I I CIVIL ACTION - DIVORCE v. JOHN RICHARD BELFONTI, DEFENDANT PRAECIPE TO TRANSMIT RECORD TO THI PROTHONOTARY' Transmit the record, together with the following information, to the Court for entry of a divorce decree I 1. Ground for divorcel Irretrievable breakdown under 53301(c) of the Divorce Code. 2. Date and manner of service of the complaintl The complaint was mailed (certified mail, restricted delivery, return receipt requested) to Defendant on July 11, 1995. Defendant accepted service of the complaint on July 14, 1995. 3. (I) Date of execution of the Affidavit of Consent required by 5 3301(c) of the Divorce Codel by Plaintiff on September 17, 1997/ and by Defendant on September 23, 1997. 4. Related claims pending I None. 5. Complete either (a) or (b). (b) Date Plaintiff's Waiver of Notice in 5330l(c) Divorce was filed with the prothonotary I October 7, 1997. Date Defendant's Waiver of Notice in 53301(c) Divorce was .. filed with the prothonotaryt september 30, 1997. Datel october 8, 1997 BYI .. 2 - , SAOItS . 'r-~') ;{.:....~j Esqu re _~\ - 1o_~J [- LeR y 8m gel, I.D. 109617 Ann V. Levin, Esquire I. D. #70259 2917 North Front street Harrisburg, PA 17110-1223 (717) 234-2401 Attorneys for Plaintiff .. ,./ 4' ~J ;.'1 ~, i; 7,} .J .'1 -Ii'., <1"1 :) ~ ,J, : ;~I -~ r'1 ',;1\ . j ." :'1 '"" ... ~:} '\1 ,".. ~/ \.\ 11.1 IlIVllMCI\ l'IMI'IAIHTIA VI/ro, U1ltU/VI'.llam MARG~BT ANN BELrONTI, PLAINTIFF IN THB COURT or COMMON PLEAS CUMBBRLAND COUNTY, PENNSYLVANIA NO. II 'j' kl (., C ,,;i/ 11 ,.~ v. I I I , , , , CIVIL ACTION - DIVORCE JOHN RIOHARD BBLFONTI DEFENDANT TO THB HONORABLE, THB JUDGES OF SAID COURT' AND NOW, comes Plaintiff, MARGARET ANN BELFONTI, by her attorneys, SMIGEL, ANDERSON' SACKS, and represents as followSI COUNT I DIVOROE UNDER SECTION 3301101 OR 3301141 or THE DIVORCE OODE 1. plaintiff is Margaret Ann Belfonti, who currently resides at 215 North 26th street, Camp Hill, cumberland county, Pennsylvania 17011 and has resided there since May 1976. 2. Defendant is John Richard Belfonti, who currently resides at 210 Senate Avenue, Apt. 216, camp Hill, Cumberland county, Pennsylvania 17011 and has resided there since October 1994. 3. Both Plaintiff and Defendant have been bona fide residents in \t il [I j II If the commonwealth for at least SiK (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on May 21, 1961, at Washington, D.C. . , Ii 'I I " 'I Ii II I I I II II Ii I. There have been no prior action. of divorce or for annulment between the parties. a. The marriage is irretrievablY broken. 7. Plaintiff has been advieed that counseling is available and that Plaintiff may have the right to request that the Court require the parties to partioipate in counseling. WHBRBFORB, Plaintiff requests the Court to entsr a Decree of Divorce. COUNT II EQUITABLB DISTRIBUTION t. Plaintiff rspsats and real leges the averments of paragraphs 1 through B which are incorporated by reference herein. 10. Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by this Court. WHBRBFORB, Plaintiff requests this Court to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. BYI SMIGEL, ANDEnSON & SACKS '~L::J LeR Y SMIGEL, ESQUIRB 1.0. 109617 ANN v. LEVIN, ESQUIRB 1.0. 170259 2917 North Front street Harrisburg, PA 17110-1223 (717) 234-2401 Attorneys for Plaintiff ,I " Ii I' .1 I' " 'I !i - 2 - . VERIFIOATION I verifY that the etatements made in this Complaint are true and correot. I understand that false statements herein are mads sUbjeot to the penalties of 18 Pa.C.S. section 4904, relating to unsworn falsifioation to authorities. Datel 1'.,';. j;- I. .~ i'" 1/ It. '/.7 I I S)1I0BL, ANIUAHNON .. HM'IlH ATTORNEVS AT LAW 2911 NOATH fRONT STREET HARRISBURG, PENNSVI.VANIA 17110 1223 (7171 234' 2401 ..~-;;'~-";-" '1'"" ,~~_ W, . . ., ~_. ---. . (0 1(, \ ~IJ I .-, III tll) h" ju.,./', 'i vU ~d. .'. - , 1".-----' ...---.> lio\LJ ''l''ll ,,,"-- "j if 5 (t) ~) UI aii 195 (I"."., f~. AC',.l . /.( (In, I JUl ., i f ',rf 1\ CJc.. I J.. '11..3 ..- -" - HAKOlalT lMM BILrONTI, 'LAIHTIrr IN THI COUIT or COKKON 'LIAS CUKBllLAND COUNTY, PINNSYLVANIA v. I I I I I I I NO. 11I-3131 JOKN RICHARD BILrOHTI DlrlHDANT CIVIL ACTIOH - DIVORCI M AND HOW, this J~ day ORDER of February, 1996, having reviewed the attached stipulation, the parties are hereby granted leave to withdraw their consents and waiver of counseling in the above captioned matter. J. \', ',"; ~~.tl II' t"1 , ::...., r, Ij 11/ ": 7 I ,.J . : ,\~....,: '" ;1",<.1.,".; ....,.: WI,I~//IIlpdIIloo I", w........a11 (Jf C.,."""AVIJKI,U Ill/Ill"'" IlIIra' MARGOIT AIOI BILrOIlTI, I 1M THI COURT or CONHON PLIAS PLAINTIrr I CUMBERLAND COUIITY, PENNSYLVANIA I v. I NO. 111-36H I JOHN aICHARD BILrONTI I DEreNDANT I CIVIL ACTION - DIVORCE STIPULATION rOR WITHDRAWAL or ArrIDAVITS or CONSENT AND WAIVER or COUNSELING MID NO', tllis ~r' day ()f February, 1996, the parties hereto agree by and between their counsel, to enter into a stipulation for the Withdrawal of Affidavits of Consent and Waiver of Counseling. WHEREAS, Plaintiff filed a Petition for Leave to Withdraw Affidavits of Consent and Waiver of Counseling on or about January 19, 1996. WHEREAS, the Honorable Judge George E. Hoffer signed a Rule to Show Cause on or about January 25, 1996. WHEREAS, the parties have agreed through their counsel to withdraw the Affidavits of Consent and Waiver of Counseling filed in this matter. NOW, THEREFORE, Plaintiff and Defendant agree through their counsel that this Stipulat:ion should be submitted to the Court and made an Order of Court. ~.i~SqUire Attorney for Defendant ) Attorney for Plaintiff ;~~~:~!~~tl;~ .:~?~';~; ~:I;; ~.'C,r ",,' ,".:~", . ~~,~~~i{~~-_'~Y\_;;-r:',-_, ._ " ~~f;:k; ,"~'O.~I A......o... .A~.. ..v.>>-',': ,-,'--: ,'. ....,...-. ..--'" ,', "" ,," _' " ',I,h": ATTO"~IV' AT l.AW "~ii, ;0:" " i" , ,eeI7.No"Tu PlIoHT IY""T "iH~.~!lI'_'iJ"O; PI~~'VI.VA~'. 11110. U!23.. 'i,.~,~.'{:<::/~ 1117113401401 . P,,', "",'>.:~!~,i- tkttff..f:_c':." .'.-, -,\ ~_'h>~;-q':,i:ltti,~ " ,;t' j'"n ":", _:<<;i ... . ~ (' , ....- .?'..... , .' @I' .UU.I."IO)WUtr!\VI.IK111 \111I"'/~ft I HI11Il MARGARET ANN BELFONTI, , IN THE COURT OF COMMON PLEAS PLAINTIFF , OUMBERLAND COUNTY, PENNSYLVANIA , v. , NO. 95-3636 , JOHN RICHARD BELFONTI , DBFENDANT , OIVIL ACTION - DIVOROE QlUlliR AND NOW, this ____ day of , 1996, Plaintiff is hereby granted leave to withdraw her Affidavit of Consent and Waiver of Counse ling. BY THE COURT' J. ~UI.I.~IIHJlI! 10 NIIUW 1'''lI,'I'h~VIJI\III tll:I'I'1If114hl'1ll MARGARET ANN BELFONTI, I IN THE COURT OF COMMON PLEAS PLAINTIFF I OUMBERLAND OOUNTY, PENNSYLVANIA I v. I NO. 95-3636 I JOHN RICHARD BELFONTI I DEFENDANT I CIVIL ACTION - DIVORCE AND NOW, this , 1996, upon consideration of the attached Petition for Leave to Withdraw Affidavit of Consent and Waiver of Counseling, a Rule is hereby issued on Defendant to show cause, if any there be, why the relief requested should not be granted. I~ RULE RETURNABLE~ DAYS FROM SERVICE. J. ",,"',.\ v.~.:~\h..~.' '""- ,,\_ ',' , I ',,_J 11'1''''{() \.. ,..' \ .., 11.\ o "" ;,. .! .' l -\ r. G j, ~ t .. " 1,"li'" " I :.... ;~'. ;,(:.1"; '. \; I. ::..,1.::....' .... Utll_H'l'lIl1l1NltllllL'\\'III)"'lIII1HI-\\\^lll'i\\"I."11I UII'I'I(IJ\lI'Ul MARGARET ANN BELFONTI, I IN THE COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 95-3636 I JOHN RICIIARD BELFONTI I DEFENDANT I CIVIL ACTION - DIVORCE AND NOW, comes Plaintiff, MARGARET ANN DELFONTI, by and through her counsel, SMIGEL, ANDERSON' SACKS, and avers as follows: 1, A Complaint in Divorce was filed on July 7, 1995 under section ]]01(c) or ]]01(d) of the Divorce Code, 2, Plaintiff and Defendant executed Affidavits of Consent which were filed with the Court on or about December 15, 1995. ]. Plaintiff wishes to preserve the claim for equitable distribution which has been asserted in her divorce complaint. 4. Plaintiff seeks full disclosure of the marital assets before a divorce decree is entered, WHEREFORE, Plaintiff requests this Honorable Court grant her leave to withdraw her Affidavit of Consent and Waiver of Counseling, SMIGEL, ANDERSON & SACKS BYl " J j (-.. "- . I" \ , ) , ,~\ I ' I I ,_ ) La OY SMIGEL, ESQUIRE 1.0. #09617 ANN V. LEVIN, ESQUIRE 1.0. #70259 2917 North Front street Harrisburg, PA 17110-122] (717) 234-2401 Attorneys for Plaintiff VBRIrIOATION I verifY that the statements made in this pleading 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. " Datel I ~-~ . a !ff c.. t;1 \;1 'I t,... ~ tilL. ':\:,. ,;0 '!v ;:.It (.1(' ...... CJ,,>;, \D .~ .... r1t;--; "';1 ",1 "' . . .'''{i. ~. Il(~l f.' " ~ '. ~ c::.., ILl - . MARGARET ANN BELFONTI, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3636 I I I I I I I CIVIL ACTION - DIVORCE v. JOHN RICHARD BELFONTI DEFENDANT M'fl'IDA VIT OF CONSENf AND WAIVER OF COUNSELING 1. A Complaint in Divorce under 53301(c) ot the Divorce Code was tiled on July 7, 1995. 2. The marriage ot Plaintitf and Defendant is irretrievably broken and ninety (90) days have elapsed trom the date ot tiling and service of the Complaint. 3. I consent to the entry of a tinal Decree of Divorce after service ot notice ot intention to request entry of the decree. 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 have been advised of the availability of marriage counssling, and understand that I may requeet that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list ot marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being entered by the Court. - ~ ... I verifY that the .tatemente made in thie Affidavit are true and oorrect. I underetand that falee etatemente herein are made subject to the penaltiee of 18 Pa.C.s. section 4904 relating to unsworn fa18ifioation to authoritiee. Date: r,/l1/'/1 .. - IS ;OJ ',1 I P j.! "1 ., .:j~ ~l.l , ,i-) )"1 \':1 ,; ;~ri ~'i i~ ~~~ ~; ttt 11;\ 4441.1~_ oI_'AV\AWI.........17. 1997 , MARGARET ANN BELFONTI, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-3636 v. JOHN RICHARD BEL FONT I DEFENDANT CIVIL ACTION - DIVORCE WAIVER or HOTICI or INTENTIOH TO REQUEST IHTRY or A DIVORCB DECREI UNDER SECTION 3301(0) or THI DIVORCI COOl 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. 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. Datel 1j;~/91 tf1 t~ ',' ! t,,"! q ! "il:" .\'1!~ b , (1) "l'J .: ~IA ~t... i\! 1\'j U1 IU IN TIm COllin OF roMMON 1'l.EAS OF CUMBElU.AND COUNTY, l'ENNSn.VANIA Cl I" Margaret Ann Uellontl, Plaintifl' No lJ5-3b3CJ 1:- "','i v, I,', CIVIL ACTION - LAW . , -' John Richard Dcllonli, Defendanl IN DIVORCE ~. J '., A "'limA VIT OF CONS":NT I, A Complaint in Divorcc undcr Section BOl(c) of the Divorce Code was filcd on July 7, 1995 2 The marriage of the Plaintifl'and Delendant is irrctrievably broken and ninety days havc clapsed from thc datc of the filing and scrvicc of the Complaint 3, I consent to the entry of a final Dccrcc of Divorce allcr scrvice of Notice of Intention to request entry or the decrec 4, I understand that I may lose rights concerning alimony, division or property, lawyer's fces or cxpcnscs if I do not claim thcm bcfore a dlvorcc is granted I veri/)' that the statcments made in this aflidavit arc true and correct I understand that false statements herein are made subject to the penalties of 18 PaC's Section 4904 rclalinglo unsworn falsification to authoritics Date 'l/J!'l1 -~- ,~e~ hn Richard Belfontl, D fendant .:0 n .J I' t'l "I .., ' .q ) ,It' '.J "'J 'l: 1:*" : t~) J'" .,' . ~,.\ . :,') r...' '-,In .. i,l (,) '..1 "- , , " , IN TilE COllin OF COMMON PLEAS OF ClJMIlEIU.ANI> COUNTY, I'ENNS\'I. VANIA Margaret Ann Belfonti, Plaintifl' No IJ5-JClJb v CIVIL ACTION - LAW John Richard Bcllbnti, Defendant IN DIVORCE (", 1'< ~--:. WAIVER OF NOTICE OF INTENTION TO ItEQUEST ENTRY OF A DIVORCE DE(,IU~E UNDER lilifIlillU1Q I tel OETlIJ;JJIYQRllifQIm ..0 ..J "'.f ' :!) J j"" 11 :., ,- '\, .. r) '" 'I 'iC) II.') t, l i i() '-., d'l 'I) .~i I q :;i ;;j I. I consent to the entry of alinal Decree of Divorce without notice:;; c.) 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fces or expcnses if I do not claim them belorc a divorce is grantcd, 3, I undcrstand that I will not be divorccd until a divorcc decrce is entered by the Court and that a copy of the decree will he sent to me immediately aller it is tiled with the Prothonotary, I verify thatthc statemcnts made in this al1ldavit arc truc and corrcct, I understand that false statements herein are made subject to the penalties of 18 Pa C,S ~4904 relating to unsworn falsitlcation to authoritics, Date:~l ~~ 12 /,~ 0111 Richard Oelfonti, De endant <<ll.I~I^YIJp""'l'"lifk... 0/,5<I>../luI111, 1991 MARGARBT ANN BBLlONTI, PLAINTIFF I I I I I I I IN THB COURT OF COMMON PLBAS CUMBBRLAND COUNTY, PENNSYLVANIA NO. 95-3636 CIVIL TERM v. JOHN RIOHARD BBLlONTI DBFENDANT CIVIL ACTION - DIVORCB I, ANN V. LBVIN, BSQUIRE, Attorney for Plaintiff, do hereby certifY that on the 11th day of July 1995, I served a true and correot copy of the complaint Under section 3301(C) Or 3301(d) Of The Divorce Code upon JOHN RICHARD BELlONTI, DEFENDANT, by depositing same in the united States First Class Mail, certified Mail - Return Receipt Requested, Restricted Delivery, postage prepaid, addressed as followSI JOHN RICHARD BELlONTI 210 SENATE AVENUE APT. 216 CAMP HILL, PA 17011 The complaint was picked up on the 14th day of July 1995 as evidenced by the attached signature card. SMIGEL, ANDERSON & SACKS BYI ) 1,---.., 1'......... l, /f',...........J V. LEVIN, ESQUIRE 2917 North Front street Harrisburg, PA 17110-1223 (717) 234-2401 -I>" ,- P /lIt', 1,:lIt 'I. ~ Certified Mall Receipt No 1I1luranc:o Covorago Provided '. 00 nol UBt! lor InlHfnnllllnal Mall 11>I11.' '/:1\ ISu. Rove,.." "'1m f?ttll!2f'tI f II Nu ~I dellait' Ivt PO&t;',l';"'~# 1~",IIQ11 , C,rtlllelfrn 6pIK;"10el,~'.1.. n."fMI-.Jo.Jlwf"'W'H Rtturn Uec,tp1 8h<Mmv Ii to Wlk)IYI & 011. Oeh~!~ S!! n,h,lf" Retttlp! 6hcMtI\Q to Vfhll"l . :-.:::' ~ ~"'" $ ~...-/I 8 &rH' J....Jv N Pbllm'l~ or OIl, ~ 1'-//.;6--- Ie ."'....... -......-.,... ...", '~I ' It. Complet. tttml , .nctlor J lor .ddlllDnll MtVIIIt, , I' Complttl h..... 3. Ind 41 a b f . Print t'our ""'" .nd Iddlln on ,he rewtIt of Ihll form ICI thIt WI un ,.turn Ihle card 10 \ QU. I . ""'th IhI. fOlm 10 lhe bont 0' IhI mallplln, 01 on thl bid. If .plt' t dOH not "'mil. I . Wrtl.........-rurn RecliPI "tQUIII'd" on t~ mtilpi,CI below the "lid. number 2. "" Re8trlcledD81fvllry I . The R.tuI" R.Cllpt wID .how to v.tl(lm ttlt .rticl. WI. d,lIvII.d .nd thl dill r 8 d.II....'.d. Conlult 0ltmal18' for fee. I \3. ArO~"..~i&mt ~di' ::, ~:?~~~o1~J (JtJ/{) ~aIe lill~ 0 Regl.llred Olnlurld Apt. ' cJ I~ j!I Ce'lIlled 0 COD 'i eMf litH, fll /1tJ / / ~ Ekp,." MIll 0 Heturn Receipt 10' ! l 8, Addrl. 1'1 dd,"" IOnlv If 'Iqulllld .. Ind fll II plldl ~ , I ~ 11.0 wllh to '"Cllvl the .wlng Ilrvlc.. 1I0r In I."a j' filII ,. 0 Addrl.oa:&.Addrl.. ,Dlclmber 1881 BU,a.opo: 'III 1IU.ooI DOMESTIO RETURN REOEIPT i ,. , r ( ( ( ..., ~ I: f .-~ 't;;. :,. .', ~'h' ";... ... 11 .".. !a - c;,;, "l .I:: UI ~ 1::1: .. ~ 1 MARGARET ANN D1iFONTI, l'lalnlifl' IN TIlE COURT OF COMMON PI.EAS OF CUMIIElU.ANI> COLJNTY,PENNSYI.VANIA v JOHN IUCIIARI> UELFONTI, I>efendant CIVIl. ACTION -I>1VOIU'E . NO lJ5-.16.1h ('lVII, TERM I'RAECIPE "'OR ENTR\' 01<' APPEARANCE TO THE PROTHONOTARY Please enter my allpearance on behalf of I>efendanl in the above-captioned action Respectfully submilled, UeArmond & l>eArmond ,h-{ h~ Dateh I i/w:t Keith 11 DeArmond, ESl\u re 2800 Market Street Camp 1I111,1)A 170lt (717) 730-1)31)4 Allorney II) II 58878 / . 4441.1-41" VIAId/CrrtifiClk of lkn-krIJanuaf)' 26. 1m MARGARET ANN BELrONTI/ PLAINTIFF IN THI COURT or COKMON PLEAS OUMBERLAND COUNTY/ PBNNBYLVANIA NO. '5-3636 OIVIL TBRM v. I I I I I I I CIVIL ACTION - DIVORCB JOHN RICMARD BBLrONTI DBFENDANT CERI.IDCA11~ I, ANN V. LEVIN, BSQUIRB, Attorney for Plaintiff, do hereby certify that on the 26th day of January 1996, I served II true And correct copy of the Rule to Show Cause and Petition for Lellve to withdraw Affidavit of Consent and Waiver of counssling upon Keith DeAr.ond/ Ilq., by depositing same in the United States First Clus Mail, postage prepaid, addressed liS followe; KBITH DEARMOND, BSQ. 2800 MARKET BTRIET CAMP HILL/ PA 17011 SMIGEL, ANUElt80N & SACKS J,.J! I~Q__._.u V. LBVIN/ BSQUInl 1.0,' 70259 2917 North Front street Harrisburg, Ph 17110-1223 (717) 234-2401 Attorney for Plaintiff BYI . . 8 ~~ 0 .il s~; r_ "1 iJ)fU ':.i_ ;, '0 b! 1 . t[Fi;.~ N tot l,o, \.0 'J'. ',;1 .:le,~ ....,..i -'1-,! .'J(.. 6--:.1 ,ii... "ll . ('d 'i1' ~j "'''c,, ..::r l' ~~ r;:'I ti;J ....) 0 . ." ;:..:" MARGARET ANN BELFONTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 95-J6J6 JOHN RICHARD BELFONTI, Defendant CIVIL ACTION - DIVORCE Aji'l<"(DA VIT OF CONShN'l' AND W AIVEU OF COUNSELING 1. A Complaint in Divorce under section JJ01(c) of the Divorce Code was filed on July 7, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. J. I consent to the entry of a final Decree of 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 have boen advised of the flvRilability of marriage counseling, and understand that I may request that the Court require that my opouse and I participate in counseling. I further understand that the Court maintains a list of marriago couneelors in the Prothonotary's Office, which list is aVflilable to me upon request. Deing so advised, I do not request that the Court require that my spouse and I partioipate in counseling prior to a divorce decree being entered by the Court. . - 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 falsifioation to authorities. Datel III/~//.:J~ I , 'i' t JI -" .-......<_ BELFONTI / I rem ~ ~ ~ t~(:J - l'i.-,l UI rt' i" , ..,1 ."~ .....J c\ t1: t;:.(~ ,..~ - .. ~ C' P j. ) ,i . MARGARET ANN BELFONTI, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PA I v. I No. 95-3636 I JOHN RICHARD BELFONTI, Defendant CIVIL ACTION - DIVORCE AFFIDA vrr OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on July 7, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 I may lose rights concerning alimony, division of property, lawyer's fees or e~penses if I do not claim them before a divorce is granted. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being entered by the Court. . .. " 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 Datel lIlt? /1:;- I I authorities. ~;2,/)~~.. HN RICHARD BELFo~J fa ~.\l t;'\ mm ~ ]pD m!tJ ~1 ~"'J:' i \'~i~' t:l _.....J "'n i; ~ ;:I.: [:1 1; . - (1 1'J .. 51 t::j .r.- :'it ..... c .... . , '.