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HomeMy WebLinkAbout02-4242 BRUCE L. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0;;.. '1.:l'f-L Civil Term VIRGINIA S. LONG, Defendant :ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 requested 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty A venue Carlisle, Pa, 17013 (717) 249-3166 BRUCE 1. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0.2 - 4:1.. 'f:L- Civil Term VIRGINIA S. LONG, Defendant :ACTION IN DIVORCE COMPLAINT UNDER SECTION 3301 of the DIVORCE CODE I. Plaintiff is Bmce L. Long, who currently resides in Cumberland County, Pennsylvania, with a primary address of I 10 Long Road, Newville, Pennsylvania. 2. Defendant is Virginia S. Long, who currently resides at 110 Long Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona tide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married in June 1968 in Carlisle, Cumberland County, Pennsylvania. 5, There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff and Defendant have two children together, however, both are adults over the age of eighteen. 9. Neither Plaintiff and Defendant are a member of the military. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities, ~/;/ /L Bruce L. Long, Plaintiff t7 Respectfully submitted: Date: r, ,.O~ Adams, Esquire . No. 79465 36 South Pitt Street Carlisle, Pa. 17013 ATTORNEY FOR PLAINTIFF (") C) ~ C (".J ll'~~': '-/) l1]r':-: ,"r'l "0 ~ ~ fl ~_,-1 I"'::::; ~i ..,.... , , I ,- 'rrl UJ cr; 'c.~ ~;;~, () -<:. "\) ;:; '6? ... 3f~.~ -~ " C') ~ '- N (jrn "-7 ~ .'" ;;:::-1 '" c.... 5~j ~ , (~) -< L-- C BRUCE L. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 02 - 4242 Civil Term VIRGINIA S. LONG, Defendant :ACTION IN DIVORCE ACCEPTANCE OF SERVICE PURSUANT TO PA.R.C.P 4 02m) AND PA.R.C.P. 1920.4 I, the undersigned attorney for the Defendant in the above-captioned action, being duIy authorized by said Defendant, hereby accept service of the Divorce Complaint filed in the above- captioned matter on July 16, 2002. Date:~ ~~/l;)J~ J ifer Lehman, Esquire 27 South Arlene St. P.O. Box 6130 Harrisburg, Pa. 17112 Id. No. (717) 671-1200 o s;.~: ~.G:~ ;;~J: (..r:"j .... ;:$ <- -'> 0[S '- 2 =<.1 r--- rz:; U) --" o '-0 ~'..... '..: J"\) .. :.,,,, -' ~::' -{ ~!::' ..D -< SEPARATION AGREEMENT BETWEEN VIRGINIA S. LO#G AND B~CE L. LONG THIS AGREEMENT, made this t6 day of V v I ~ 2002, by and between VIRGINIA S. LONG, of Newville, Cumberlarffl County, Pennsylvania, hereinafter referred to as "WIFE", and BRUCE L. LONG, of Newville, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND". 1'1A" 0.(, If ~ V J..... G;;.J -r-,- WITNESSETH: WHEREAS, Husband and Wife were lawfully married in June 1968, in Carlisle, Cumberland County, Pennsylvania, and; WHEREAS, there were two children born of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1, FULL DISCLOSURE OF ASSETS, Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Jane Adams, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Jennifer L. Lehman, Esquire, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. Wife has been advised of her right to counsel, ...oh:IAtarily eleeteEl te ~re~e Fel3rescntstion, and understands that Jane Adams, Esquire is only representing Husband. ~ #~F. ~;t~, ,~ , , 3, SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5, DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 6, MUTUAL RELEASE OF ALL CLAIMS, HUSBAND and WIFE each do hereby mutually remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, or whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in the decease spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any rights which Wife may have or at any .P~'z' v-4 time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of any 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. 7, WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. 8. OUTSTANDING JOINT DEBTS, (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. Wife agrees to pay all debts owed to the following: Chrysler Corporation J.C. Penney Sears Bon-ton. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. 9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the fact that it is the first marriage for both Husband and Wife; the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each party to the education, training, or increased earning power of the other party; the opportunity for each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciation of themarital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to )J,;t~ ~ constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically wavier, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. 10. OTHER PERSONAL PROPERTY, The parties agree that the following personal items shall be divided as follows: Husband shall retain all farm machiners housed on Parcel No.4, including all tractors and trailers. Husband shall retain sole and exclusive possession of any accounts, equipment or personal items which are related to his business known as Bruce Long Stables. Wife shall retain the household goods and items contained in the former marital home located on Parcel NO.1. 11, MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The JEEP shall be and remain the sole and exclusive property of Wife. (b) The Ram 3500 Deisel Truck shall be and remain the sole and exclusive property of Husband. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the date of execution of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12, MARITAL HOME. HUSBAND and WIFE hold title as Tenants by the Entireties property in North Newton Township, Cumberland County, identified and described in a Deed filed at Deed Book 0, Page 489. The property described was subdivided pursuant to a subdivision plan prepared by Carl D. Bert & Associates on June 14, 1999. The property was subdivided into four parcels, parcel #2 & parcel #3 have been sold, leaving parcel #1 and parcel #4 in the marital estate. Regarding parcel #1 and parcel #4, the parties agree as follows: /Jjj. w (a) Wife shall have sole and exclusive possession of parcel #1, commonly known as 110 Long Road, Newville, Pennsylvania, which includes the marital home. Within days of the execution of this agreement, Husband shall deliver a Deed, conveying to Wife all of his right, title and interest in and to the marital residence. As of the date of separation, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense. Wife shall be entitled to all income generated from this property except as described within this agreement. (b) Husband shall have sole and exclusive possession of parcel #4, as described within the subdivision plan as well as the barn and any other structures or equipment thereon. Within days of the execution of this agreement, Wife shall deliver a Deed, conveying to Husband all of her right, title and interest in the property. As of the date of separation, and without regard to when bills for such items are incurred, received or due, Husband shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and Husband shall keep Wife and her successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense, Husband shall be entitled to all income generated by the property except as described within this agreement. (c) Husband shall be responsible for all filing fees and other fees associated with the transfer of the properties described within this agreement. This shall include preparation of both Deeds. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions, retirement plans and Incentive Savings Plans. Specifically, Husband waives any right which he may have to Wife's State Employee Retirement System Plan. The parties agree never to assume any claim to such benefits of the other at any time in the future. 14, ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to alimony pendente lite, except as described within this agreement. Each party agrees to be responsible for his or her own legal fees and (SIt ~ expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. The parties acknowledge that they are named Lessors in a Communications Site Agreement Lease dated , with Nextel Communications of the Mid- Atlantic, Inc. This lease agreement is referred to as Site No. PA-350. Pursuant to the terms of said lease, Nextel currently pays $1,092.00 per month to the parties. The parties agree to cooperate with Nextel to do everything necessary so that the monthly rental fee may be divided equally between the parties and that separate checks may be issued directly from Nextel to each party. This arrangement shall continue for the remainder of said lease. ~d Wife ~I e proptir com~'t ny net!g nt o~t ntio~tion~. h causes el to quit eir lease the prope ,Wife s II pay to usban as ali ny, a lump s amount i shall q I one- I he las e t pa e t fro xte \~. ;t. multipli b sixty. /:f. ~ . 15. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for calendar years 1968 through 2001 have been filed and that no notices have been received from the Internal Revenue Service which remain unresolved. Each party further represents to the other that to the best of his or her knowledge, the information set forth in the joint tax return for these calendar years was and remains accurate as relates to his or her sole income and acknowledges that the other party relied on such representations in signing those returns. Therefore, if any deficiency in federal, state, or local income taxes is proposed, or any assessment of any such tax is made against the other party by reason of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax, interest, and penalties or expenses shall be paid solely and entirely by the responsible party as determined to be attributable to that party on account of misrepresentation or failure to disclose relevant information of income on the aforesaid joint returns. 16. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 17. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may Bti ~ reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 18. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the Comtnonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 21, NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 22, SEVERABILITY. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provisions 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 obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 23. BREACH. If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 24. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. B;tl. ~ IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: ,L~ VIRGINIA . Date: '(.- "l' .-- 0 ~ COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the day of , 2002, before me, the undersigned officer, personally appeared VIRGINIA S. LONG known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My commission expires: SEAL p~ ~ BRUC~cr-' Z ~ Date: 'i-/6-0J- COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the (0 fA day of J u 1'1r-- , 2002, before me, the undersigned officer, personally appeared BRUCE L. LONG known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and N tary Public NOTARL6l.SEAL MIA,~E E. ADAMS, Notary Public My commission expir . Cariilil!e Bcro, CU.'1'1oorland Counly My Comml~"ion Elqiiros Sept. 6,2004 SEAL 7J~z. : ~ r.;;. ~ f-.> c..., ~O) !'TJ '. rr, '0 'I:it~ -,.. ;z"u 1"0.) ""1;17'1 CI:i~ --):1 W ~.' . .. ~6 '"lJ ~j ~'r: <:: ~8 :J\:: ,.~, :n ~5 (") i'\) 15m ~ .. ~ ~ m -< BRUCE L. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 02 - 4242 Civil Tenn VIRGINIA S. LONG, Defendant :ACTION IN DIVORCE AMENDED ACCEPTANCE OF SERVICE PURSUANT TO PA.R.C.P 4 02(B) AND PA.R.C.P. 1920.4 I am the undersigned attorney for the Defendant in the above-captioned action and have been duly authorized by said Defendant; I accepted service of a certified true copy of the above- captioned Divorce Complaint on September 10, 2002. ~\;J~ J ifer Le an, Esquire 27 South Arlene St. P.O. Box 6130 Hanisburg,Pa.17112 Id. No. (717) 671-1200 . .. ._"'_.'"....'^~..,.,_~._..~~'_..~.L,__ o I" C> ;:"'l -4 I 1'0 Q ~ -otf C!) q:\ ~- z.e ~,/-~ ~Ei ""- ~Q ..~\.' J>' c:: 2- 2 -.:J "$ o -n '-\ :.';-.-::' "r ,";c:.\ \~~; ;",)' < ~ '-< - r:~ :.,....) (Jl - . g ;z: -0 fi:' lJ}t:p, ~r' -,'" '>-, v2~.< ,,:., ~CJ :P'C: '?;c'::' J:>c ~ c:::> ,,, o (") -4 I N o -n -0 3 r:? :"") en '""'" r :~:,t? =\Ll -~)-~, ..-7.....1 5f"!'1 ...:..{ -:po 7-:l ;..<.:, ~ . . BRUCE L. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : No. 02 - 4242 Civil Term VIRGINIA S, LONG, Defendant :ACTION IN DIVORCE AFFIDA vir OF CONSENT 2002. 1. A complaint in divorce under section 3301(c} of the Divorce Code was filed on September 5, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service 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. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: /2 - I 0 - 0 '2- ~~ Bruce L. Long, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301 te) OF THE DIVORCE CODE 1. I consent to 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. ~4904 relating to unsworn falsification to authorities. ~ 0 L /:;J,~ ~ __ . ~/ " Date: / 2. --It) ~~____ ~~ Bruce L. Long, Plaintiff /" o c:: ? '"U r[; !TIP-' ~~~:-::1 C7l~" ~[~, ~-~( .<-:=r-:: S:>C ~ -... ~;-- C r+0 CJ i'." C) ;;~ \0 --C' "'-> ['.) ~ -< "' - BRUCE L. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : No, 02 - 424:2 Civil Term VIRGINIA S. LONG, Defendant :ACTION IN DIVORCE AFFIDA vir OF CONSENt 2002. 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on September 5, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service 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. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~ - l~ -, t~ ~ !L . .(~ L . ~- ...j, ~ 'x Virginia S. CO g, Defendant (,) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 13301 (c) OF THE DIVORCE CODE 1. I consent to 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 decnee 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. ~4904 relating to unsworn falsification to authorities. Date: 1 ~ - 1 '1- [) d...., ~~;;S, L~s Virginia SU9' Defendant 6 (') ~ -u i~r. mlT z-r Zl,~ ~~~ - c:~- ~~2 /...: -"1 -(. C) r"..;) CJ "'i C") C') .-=i1 \.,c - .. J'V tv ,-" <") :< BRUCE L. LONG, Plaintiff vs, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No, 0 ~ - Lf .~ lj ~ Civil Term :ACTION IN DIVORCE VIRGINIA S. LONG, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~3301 (c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receipt requested. delivered on: q _[ D _ 0 ~ 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff: \:l. - I D - 0 ~ By Defendant: \ ~ -l rt - 0 ~. 4. Related claims pending: None, 5. Date Defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: \ ~ - l q - 6 ~ Date Plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: t d- - t q~()~ Date: (Z-ICi -O~ Respectfully Submitted: ,aJ~ a e Adams, Esquire . . No. 79465 36 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff p s:: ""0 ,~ rnl:-:-',: <;,?: ~~~. <.', OJ "', rs ;~--~~. f;~; s;;; :3 " -- " ,'\,) c.,) <"') r~ ,~ {q \.0 ;~;.i -0 '""" ~~~~~~~~~~~~ ~~~ ~ 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STA,TE OF PENNA. Bruce L. Long, Plaintff No. No. 02 - 4242 Civil Term VERSUS Virginia S, Long, Defendant DECREE IN DIVORCE AND NOW, J)~ Bruce L. Long .<7~ IT IS ORDERED AND .ttsD -z.- , - DECREED THAT , PLAINTIFF, AND Virginia S. Long , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The property settlement agreement is incorporated but not merged into this Decree, PROTHONOTARY ~ ~~~~~~~ ~~~~~~~~~~~~~~~~~ ~~ J. .,. ~!Pt. ~ ~ [(:JoD( 0"pJ7?? lr 'j% r:- ~ .pJWo F'./ " ~" . " ... 'l; '" l "