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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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HOBER'I' C. CAHCIIIDl,
No.
9,5::3,615, PPP"X~XX
Plaintiff
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HENEE M. CARCIIIDI,
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Defendant
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DECREE IN
DIVORCE
AND NOW, . . . .\ .~. .~"\. . . . . . . ., 19.?.7..., It Is ordered and
RODEIl'l' c. CAIlCIIlDl I ff
decreed that ..........,..,...,..,.......,...................., p alntl ,
and. .. .. . ~.~~~~..I-! ~ . ~A.l~Cl.lI.l~I .... .. .. .. .. .. . .. .. .. .... .. .. ., defendant,
are divorced from the bonds of matrimony.
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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;
NONEI the Post-Nuptinl Agreement between tho parties dated
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pOST.NUPTIAL AGREEMENt
THIS AGREEMENT made and entered Into this I V (I> day of
/L Iii , 11l1l7 by and between:
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ROBERT C CARCHIDI, of 7386 Wheeler Street,
Philadelphia, Pennsylvania 11l153, party of
the first part, hereinafter called "husband',
AND
RENEE M CARCHIDI, of 141l Brindle Road,
Mechanlcsburg (Monroe Township), Cumberland
County, Pennsylvania 17055, party of the second
part, hereinafter called "wife'.
WITNESSETH:
WHEREAS, Husband and Wife were married to each other on May
24, 11180 and last resided together at141l Brindle Road, Mechanlcsburg,
Cumberland County, Pennsylvania; and
The parties are the natural parents of one minor child whose name and date of birth Is:
JESSICA LYNN CARCHIDI, born February 6, 11l82.
Certain differences have risen between the parties, aa a consequence of which they have
separated and now live separate and apart from each other; and the Husband has commenced
an action In divorce docketed to No. 1l5.3645 the Court of Common Please of Cumberland
County, Pennsylvania.
DIVISION OF ASSETS. Upon a granting of a final decree of divorce In the
Divorce Action the parties agree to the fOllowing equitable division of the marital assets as
follows
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(A) ASSETS TO HUSBAND:
1. Household goods, furnishings and any other tangible property currently
In his possession;
2. Husband's pension, retirement and/or savings plans through his
employer, the United States Postal Service.
3. The vehicle In his possession.
eBI ASSETS TO WIFE:
1. The marital home located located at 149 Brindle Road which was
purchased by her pursuant to a deed dated February 29, 1996 and recorded In the
Office of the Recorder of Deeds In and for the Cumberland County, Pennsylvania In
Deed Book 135, Page 751.
2. Household goods, furnishings and any other tangible property
currently In her possession.
3. Wife's retiremenUpenslon plan and/or savings plans through her
employer's; and
4. The vehicle currently In her possession.
6. SUPPORT OF MINOR CHILD
A. Jessica shall remained covered by husband's health Insurance
'plan available through his employer until she reaches the age of twenty-one (21)
years.
B. Husband ahall pay to the wiee the amount of, no less than, six
hundred dollars ($600.00) per month for the support oe Jessica until June, 2000.
The Child Support will continue, as per the law, should Jessica attend college
-2-
IN WITNESS WHEREOF, the parties have set their respective hands on the day and
year mentioned above Intending to legelly bind themselves.
WITNESSED BY:
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Robert C Carchldl DATE
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Re ee M Carchldl DATE
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IlUIlEllT Co C^IlCIIIIl 1 ,
1'I1IIntl rr
IN TilE counT OF COMMON I'I.EAB
CUHOIml.AND COUNTY. PENNSYLVANIA
VS.
CIVil. DIVISION
IlENEE fl, C^IlCII III I ,
Derendant
NO. 9',-](,1,',
CIVIL TERM
:
PRAECIPE TO TRANSMIT IlECORD
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 53301(cl
))'S\n~~~~1 of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint:
July 10, 1995 by Cerlifh.d flail. Ill.turn Ill'cdpl Ill'qul'ull'd
J. Complete either paragraph (a I or (b).
(al Date of execution of the affidavit of consent required
by SJJOl(cl of the Divorce Codc: by plaintiff July 18, 1997
by defendant July lB, 1997
(bl(l) Date of execution of the affidavit required by 53301(dl
of the Divorce Code: I (ZI Date of filing and
service of the plaintiff's affidavit upon the raspondent:
4. Related claims pending:
NONE.
5. Complete either (a I or (b I.
(al Date and manner of service of the notice of intention to
file praecipe to transmit rllcord. a copy of which is attached:
(bl Date plaintiff's
filed with the Prothonotary:
Date defendant's
filed with the Prothonotary:
Waiver of NoHce in 5330l(c) Divorr-e was
.July 2'1. 1997
.
Waiver of Notice in 53301(01 Divorce was
.July n. 1997
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LAW OFflCLI
6NELOAKEA
.
DAENNn4AN
ROBER'r C. CARCIIIDI, I IN TilE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
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vs. I NO. (/.ej ')j({ljtJCIVIL TERM
I
RENEE M, CARCllIDI, I
Defendant I IN DIVORCE
By
NOTICE TO DEFEND AND CLAIM RIGIITS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages/ you must take
prompt action. You are warned that if you fail to do so/ the
case may proceed without you and a decree of divorce or
annulment may be entered against you by the Court. A judgment
may also be entered against you for any other claim or relief
requssted in these papers by the Plaintiff. You may lose money
or property or other rights important to you, including custody
or visitation of your children,
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request that the court
require you and your spouse to attend marriage counseling prior
to a divorce decree being handed down by the court, A list of
marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Court 1I0use, Carlisle.
You are advised that this list is kept as a convenience to you
and you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are
to bs borne by you and your spouse.
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 TilE RIGIIT TO CLAIM ANY OF
THEM,
YOU SHOULD 1'AKE 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 WHERE YOU CAN GET LEGAL HELP.
Court Administrator
One Courthouse Square
carlisle, PAnnsylvania 17013-3387
(717) 240-6285
SNELBAKER & BRENNEMAN, P.C.
ROBERT C, CARCHIDI,
Plaintiff
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. /..'. !;, ,/ CIVIL TERM
RENEE M. CARCHIDI,
Defendant
IN DIVORCE
COMPLAINT
COUNT I - DIVORCE
1. The Plaintiff in this action is ROBERT C. CARCHIDI, an
adult individual currently residing at R.D. 1, Box 272, New
Bloomfield, Perry County, Pennsylvania 17068.
2. The Defendant in this action is RENEE M. CARCHIDI, an
adult individual currently residing at 149 Brindle Road,
Mechanicsburg, (Monroe Township) cumberland County, Pennsylvania
17055.
3. Both the Plaintiff and Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully joined in
marriage on May 24, 1980 in Harrisburg, Dauphin County,
Pennsylvania.
......w OHICE:.
SNELOAKER
.
BRENNEMAN
5. There have been no prior actions of divorce or
for annulment between the parties hereto in this or any other
jurisdiction since the date of the marriage averred in Paragraph
4, above.
LAW O"ICU
SNELDAKER
.
BRENNEMAN
(c) order such other relief as the Court deems just
and reaeonable.
SNELBAKER & BRENNEMAN, P,C.
Datel JV~~ 1 1~9S
BYlp\;{IJ2Jfd/IVd.. (
P lip H. spaJte, Esquire
44 West Main street
Meehanicsburg, PA 17055-0318
Telephonel 717-697-8528
Attorneys for Plaintiff
Robert C. Carchidi
-3-
LAW o'''cn
SNELDAKER
.
IlRENNE",AN
VERIFICATION
I verifY that the statements made in the foregoing complaint
ars true and oorreot. I understand that falso statements herein
are made subjeot to the penalties of 18 Pa. C.S. S 4904 relating
to unsworn falsifioation to authorities.
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Datel "J -7- q~-
U.N OffICI..
SNHBAktn
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DnUmtMAN
ROBERT C. CARCHIDI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO.
CIVIL TERM
RENEE M. CARCHIDI,
Dsfendant
IN DIVORCE
AFFIDAVIT
ROBERT c. CARCHIDI, being duly sworn according to law,
dsposes and saysl
1. 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.
2. I understand that the court maintains a list of marriage
counselors in the Office of the Prothonotary, which list is
available to me upon request.
3. Being so advised, I do HQI request that the court
require my spouse and I participate in counseling prior to a
divorce decree being handed down by the court.
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.
r)(c()e~~ C'} C2/LL. .
Robert C. Carohidi
(Plaintiff)
DateI7-7-'Jt:/
IN 'mE CXX.IRT 01' <llof.m PLEAS OF
ClllGfUND COONl'Y, PmN~riLVJ\NJA
00. CML Tl'IlM
JNDIVOJa.:
00BERr C. CAIOtIDI,
Plaintiff:
\IS.
RIim:E M. CAOCHIDJ.
Defen:lant
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SNEL'8AKi:R. 8 BR.ENNEMAN
, - ^. ~PUWONAL COJl.POMnON
i'lTfOIWEY$ AT LAW
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,MtcHAWICS.\.lIlG, PENNSYLVANIA 17055
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6m ~ OAKER,
BRENNEMAN
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ROBER'!' C. CARClllDI,
!'lainti ff
IN TilE COUR'I' OF COMMON PI,EAS 01'
CUMBERLAND COUN'I"{, !'ENNHYINANIA
v.
NO, 95-3645 CIVIl. ,!'ERM
RENEE M. CARCIIIDI,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF
PENNSYLVANIA)
I
CUMBERLAND)
SS,
COUNTY OF
Philip Il. Spare, Esquire, being duly sworn according to law
deposes and saysl that he is a principal in the law firm of
Snelbaker, Brenneman & Spare, p, C" being the attorneys for
Robert C. Carchidi, Plaintiff in the above captioned action in
divorce/ that on July 7, 1995, he did send to Defendant Renee M,
Carchidi by certified mail, return receipt requested, restricted
delivery, a duly certified copy of the complaint in Divorce which
was filed in the above captioned action as evidenced by the
attached cover letter of the same date and Receipt for certified
Mail No, Z 115 697 383/ that said Complaint and cover letter were
duly received by Renee M. Carchidi, Defendant herein, as
evidenced by the return receipt card for said certified mail
dated July 10, 1995/ that a copy of the aforementioned cover
letter dated July 7, 1995, is attached hereto and incorporated by
reference herein as "Exhibit A" and that the original Receipt for
Certified Mail and the Domestic Return Receipt are attached
hereto and incorporated by reference herein as "Exhibit 8"/ and
that the foregoing fncts are true and correct to the best of his
LAW OFfiCES
SNELOAKER.
BRENNEMAN
a 6PAnE
knowledge, information and belief.
Sworn to and Bubscribed before
me this 23rd day of July, 1997.
Notnrlallleal
PalrIclaJ. Thomaon. NaIIry ~
~ Iloro, CurOOelt8nd ColIllY
My CommI EkplrOl Dee 31. ,\lOI
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p p. Spare
SNELDAKER. 8 BRENNEMAN
^ .."mU!lIOt~Al COIU'OMIIOH
ArrOIUIEY~ AT ,-^W
.... \IIur MAIN !lT1UET
MECH~ICBURG, PENN~YlV^NI^ 17055
POBOX 318
M~IMIU Cllll 6;"'681
IUCHMO c, ~Ntl8AXtR
Jl1I1li 0 ."tNNtMAN
PHIUP H ~MRt
II1.ngl 8!i28
July 7, 1995
Renee M. Carchidi
149 Brindle Road
Hechaniosburg, PA 17055
Dear Ms. Carchidil
Enclosed for service upon you is a certified copy of the
Complaint in Divorce which was filed earlier this date on behalf
of your husband, Robert C. earchidi. Attached to the Complaint
you will also find a copy of the Affidavit relating to the
availability of marriage counseling signed by Mr. Carohidi.
Very truly yours,
Philip H. Spare
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Enclosures
eCI Robert e. earchidi (w/enclosure)
Via certified mail, restrioted delivery, return
receipt requested, Parcel No. Z 115 697 383
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LAW "frler.s
RNElbAKEh,
anfNNEMAN
t\ SPAnE
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Z 115 6'17 383
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149 Brindle Road
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95-3645 CIVIL TERM
IN DIVORCE
RObERT C. CARCHIDI,
Plaintiff
RENEE M CARCHIDI,
Defendant
affiDAVIT QF COtiHHI
1. A Complaint In Divorce under Section 3301 c of the Divorce Code was flied on 7 July
1995 and was served upon the Defendant on or about 11 July 1995
2. The marriage of Plaintiff and Delendant Is Irretrievably broken and ninety (90) days
have elapsed from the date of IIlIng 01 the complaint and the dale of service of the complaint on
the Defendant.
3. I consent to the entry 01 a final decree In divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing my Waiver 01 the Notice of Intention to
Request Entry of the Decree.
4. I have been advised 01 the availability 01 marriage counseling and understand that the
Court maintains a list of marriage counselors and that I may request the Court to require my
spouse and I to participate In counseling and, being so advised, do not request that the Court
require that my spouse and I participate In counseling prior to the divorce becoming Ilnal.
I verify that the statements made In this Alfldavlt are true and correct and I understand
that false statements herein are made subject to the penalties 0118 Pa. C.B. Section 4904
relating to unsworn falsification to authorities
,July lB, 1997
DATE
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ROBERT C. CARCHIDI,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 95-3645 CIVIL TERM
IN DIVORCE
VI.
)
)
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)
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RENEE M. CARCHIDI,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301 c of the Divorce Code wal filed on 7 July
1995 and wal served upon the Defendant on or about 11 July 1995,
2. The marriage of Plalnllff and Defendant Is Irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the complaint on
the Defendant.
3. I consent to the entry of a final decree In divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing my Waiver of the Notice of Intention to
Request Entry of the Decree,
4. I have been advised of the availability of marriage counseling and understand that the
Court maintains a list of marriage counselors and that I may request the Court to requlra my
spouse and Ita participate In counseling and, being so advised. do not request that the Court
require that my spouse and I participate In counseling prior to the divorce becoming final.
I verify that the statements made In this Affidavit are true and correct and I understand
that falae statements herein are made subJect to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
.
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ROBERT C. CARCHIDI, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
vs. ) CIVIL ACTION. LAW
)
) NO. 95.3645 CIVIL TERM
RENEE M. CARCHIDI, )
Defendant ) IN DIVORCE
1. I consent to the entry of 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.
I verify thai the statements made In this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 16 Pa. C.S. Section 4904 rellllng
to unsworn falslflcallon to authorities.
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ROBERT C. CARCHIDI,
Plalnllff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO, 95-3645 CIVIL TERM
IN DIVORCE
VI.
RENEE M, CARCHIDI,
Defendant
WAIV~R Of NOTICE OF INTENTION T9 R~gy~U ~
QF A DIVORCE DECREE YNg~R SECTION 3391 C OF~
1. I consent to the entry of final decree in divorce without nollce,
2, I understend that I may lose rlghtl concerning alimony, dlvlllon of property, lawyer'l
feel, or expense I If I do not claim them before a divorce II granted.
3. I understand that I will not be divorced until a divorce decree II entered by the court
and that a copy of the decree will be sent to me immediately after It II filed with the
Prothonotary.
I verify that the statements made In this Affidavit are true and correct. I underltand that
false statements herein are made subject to the penalties of 16 Pa, C,S. Secllon 4904 relallng
to unsworn falsification to authorllles,
July 18, 1997
DATE
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~Ol3ERT O. C RC 101
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