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HomeMy WebLinkAbout95-04898 . , .. .~.~.~.~.*.~.*_a~~**~,***.~*~.i~'~~'~.~_~~~~ ~. """.,._,__________".A.__. ._.,_.". _"."._____-..,_ --,~ \ . ~.:' I~ (.,f ~ ~ '.f, ~', ',0 ( . , ~p . , , ~j ~. ~ ~i ',': . , ~I ~ ~; ~~ ~~ ~; ~: . , ~ ~ ~ ~ 0', ~; ~ ~' ~, :e!'. ~ ~ ~. ~ ~ .' . , , ;.' 1 ~ ~ .. .. ;, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ STATE OF ~ PENNA, MARY CATHERINE ZEIGLER, Plaintiff I'll. 95-4898 11)95 y i'r... II.... CHRISTOPHER J. ZEIGLER, Defendant DECREE IN DIVORCE ANDNOW...M~~~.."...... ,19<:16 it is ordered and decreed that ..... t1A.RY . CA.THERI.t~E . ZE.IGLE~ . and . CH.RISTOP.HE~. .J.. ZE.IG~~.R . . . . . , " plaintiff, . . . . . '. defendant, are divorced from the bonds of matrimony. The Marital Settlement Agreement of February 26, 1996 is incorporated into the Final Divorce Decree. 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. .. , " " . Ii, Th': iJj~" tJL f "",.,10 .\ ',/, .,....\; .:.7:.u J J. 1 ~.<4 -, . .,', ( U,,;. 't<','T~'", '&/, '1(:;';~~n.~ F ~A - ~f' I 1'1 nthnnnlar)" $ I,., ,~ . (~ I,', ,~ /. ,~ , . .~ , . :~ ~ ~ .~ .~ '.~ .~ "0- .~ i'," ~ ~ ",' ~ ~ ~ ~ ~ ~ ~ ~ .~ ,; .. ~ . '. . . . . " . . . . . . . . . . . :.: ~ ,~ ~ . ~ . ;~ ~: ~ ,~ . '~ .~ -~ . . , . . I , . , ,.11 MARITAL SETTLEMENT AGREEMENT ,-..- THIS AGREEMENT, made this ;;1u ~~, day of ,- \; \ ~ --}~\.\l\' \... --' 1996, by and between MARY CATHERINE ZEIGLER (hereinafter referred to as WIFE) and CHRISTOPHER J. ZEIGLER (hereinafter referred to as HUSBAND). KBEREAS, WIFE and HUSBAND were lawfully married on February 16, 1991 in Duncannon, Pennsylvania, and; KBEREAS, there have been no children born of this marriage; and KBEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of WIFE and HUSBAND to live separate and apart for the rest of their nature lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to past, present and future support and alimony; and in general, the settling of any and all claims by one against the other or against their respective estates. .--. . - NOH, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth hereby acknowledged by each of the parties hereto, WIFE and HUSBAND, each intending to be legally bound, hereby covenant and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as she or he may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as if she or he were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, or in any way interfere with their peaceful existence, separate and apart. 3. SUB810UIRT DIVORCI: The parties hereby acknowledge that WIFE has filed a Complaint in Divorce in Cumberland County indexed to docket number 95-4898, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of section 3301(c) of the Pennsylvania Divorce Code. HUSBAND 2 .. ~ . hereby agrees that the marriage is irretrievably broken. Both parties hereby waive all rights to request Court-ordered counseling under the Divorce Code. Both parties agree to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section (c) of the Divorce Code at the time they execute this Agreement. It is specifically agreed that this Agreement may be incorporated by reference into the Final Decree of Divorce. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. MUTUAL RELEASE: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for termination of the marriage by divorce or annulment and except any or all causes of action for breach of any provisions of this Agreement. WIFE and HUSBAND specifically release and waive any and all rights she or he might have to raise claims under the Divorce Code including, but not limited to claims for equitable distribution or marital property, alimony, alimony pendente lite, counsel fees or expenses. 3 ~. " 5. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of her or his property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitations, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate, and each agrees, at the request of the other, to execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 6. ADVICB OF COUNSBL: Each party acknowledges that she or he has received independent legal advice from counsel of her or his selection or has knowingly and voluntarily given up that right. Further, each party to this Agreement acknowledges and declares that she or he respectfully: (1) Is fully and completely informed as to the facts relating to this subject matter, this Agreement, and as to the rights and liabilities of both parties; (2) Has given careful and mature thought to the making of this Agreement; 4 ~ '. (3) Has carefully read each provision of this Agreement; and (4) Fully and completely understands each provision of this Agresment, both as to the subject matter and legal affect. WIFE and HUSBAND accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full accounting of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purpose of this Agreement. Each party agrees that she and he 3hall not at any future time raise as a defense, or otherwise, the lack of such disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraudulently withheld. 7. WIPE'S DEBTSI WIFE represents and warrants to HUSBAND that as of the date of separation she has not incurred, and in the future she will not contract or incur, any debts or liability for which HUSBAND or his estate might be responsible and shall indemnify and save harmless HUSBAND from any and all claims or demands made against him by reason of debts or obligations incurred by her, and save harmless HUSBAND from any loss he may 5 ~. sustain, including attorney fees, as a result of any default in payment by WIFE. 8. HUSBAND'S DEBTS: HUSBAND represents and warrants to WIFE that as of the date of the separation he has not incurred, and in the future he will not contract or incur, any debt or liability for which WIFE or her estate might be responsible and shall indemnify and save harmless WIFE from any and all claims or demands made against her by reason of debts or obligations incurred by him, and save harmless WIFE from any loss she may sustain, including attorney fees, as a result of any default in payment by HUSBAND. 9. JOIST DBBTS: WIFE hereby assumes sole responsibility for the following loans, and/or debts incurred by the parties during the marriage and shall indemnify and save harmless HUSBAND from any loss he may sustain, including attorney's fees, as a result of any default in payment by WIFE. The debts WIFE assumes are: (a) Auto lease with Dauphin Deposit Leasing, account number 2709803319. HUSBAND hereby assumes sole responsibility for the following loans, and/or debts incurred by the parties during the marriage and shall indemnify and SAve harmless WIFE from any loss she may sustain, including attorney fees, as a result of any default in payment by HUSBAND. The debts HUSBAND assumes are: 6 ...... . (a) Mortgage on the real property located at 70 Sam Snead Circle, Etters, York County, Pennsylvania with Prudential Mortgage, account number 246714-0; (b) Commercial Credit loan, account number 38813- 530691; (c) Chevy Chase Bank Visa, account number 4246171005021048; (d) Chevy Chase Bank Mastercard, account number 5407301005134473. 10. DIVISION OF PBRSONAL PROPBRTY: The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any other such items of marital property, or to the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to effect this Paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. WIFE and 7 """ HUSBAND shall be deemed to be solely and individually in the possession, control and ownership of any pension or other employee benefit plans or other employee benefits of any nature to which either party may have a vested or contingent right or interest, apart from the provisions of the Divorce Code, at the time of the signing of this Agreement. 11. AUTOMOBILES: The parties agree to retain the automobiles of which they are currently in possession. Specifically, HUSBAND agrees to waive and give up any right, title, or interest in WIFE'S 1994 Jeep Wrangler and HUSBAND shall become the sole and exclusive owner of the 1990 Chevrolet Blazer. The titles to said automobiles shall be executed by the parties to effect transfer as herein provided immediately upon request after the date of execution of this Agreement. 12. REAL ESTATE: WIFE hereby agrees to waive and give up any right, title, or interest in the real property located at 70 Sam Snead Circle, Etters, York County, Pennsylvania. 13. PENSION PLANS: WIFE and HUSBAND hereby waive and give up any and all interest each may have in any pension, IRA, 401K, retirement plan, or other deferred compensation rights of the other. 14 . APPLICABILITY or TAX IA" TO PROPERTY 'l'RA1ISfBR8: The parties hereby agree and express their intent that any transfers 8 ..... , of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (herein the "Act"), specifically, the provisions of said Act pertaining to transfers of property between spouses or former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement, without recognition of gain on such transfer and subject to the carry-over basis provisions of said Act. 15. WAIVER OF ALIMONY PENDENTE LITE AND LEGAL FEES: Each party hereby waives any right to alimony pendente lite. WIFE agrees to be responsible for her own attorney's fees. 16. FULL DISCLOSURE: Each party asserts that she or he has made a full and complete disclosure of all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources of and amounts of income received or receivable by each of the parties, and of every 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. 17. NAIVlR or ALIMONY: The parties herein acknowledge by this Agreement that they have respectively secured and maintained 9 ~. , substantial and adequate funds with which to provide for themselves and have sufficient financial resources to provide for their comfort, maintenance and support, in the station of life to which they are accustomed. WIFE and HUSBAND do hereby waive, release and give up any rights they may respectively have against the other for alimony, spousal support or maintenance. From the date of execution of this Agreement it shall be the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 18. HAIVER OF 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. 19. MUTUAL COOPERATION: Each party shall 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 reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 20. APPLI~Rt,R LA": This AgreEment shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 10 21. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 22. INTEGRATION: 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 warranties other than those expressly set forth herein. 23. 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 provisions hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 24. SIVIRABILITt: 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 provision Bhall be stricken from this Agreement and in all other respects this Agreement shall be valid 11 MARY CATHERIRE ZEIGLER, . IR THE COURT OF COMMOR PLEAS . Plaintiff : CUMBERLARD COURTY, PERRSYLVARIA . . v . RO. 95-4898 . . . CHRISTOPHER J. ZEIGLER, . CIVIL ACTIOR - LAK . Defendant . IR DIVORCE . PRAECIPE TO TRARSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section ( X I 330llcl 3301 Idllll of the Divorce Code. 2. Date and manner of service of the complaint: United States Certified Mail, Restricted Delivery on September 23, 1995. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff 02/22/95 ; by defendant 02/26/95 . (b)(l) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: N/A . , (2) date of service of the Plaintiff's affidavit upon the Defendant: N/A . 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A . /) JL (/i / hit ';" Richard F. Maffett, Jd; Attorney for Plaintiff S8quire [-~~ a '..:: lL': r:) - p:: ~- . , -' :' . . ~ J 1 ~ ~1 p ~ () ',; \. "l ~ " "1 ~ 'vi' .... ... '" .. .... ;- ~ ~ <% ~ ~i ai: ~t;cl ;" .. M"'I~.,., . :', ,c',. .~ ,: ....~iliJ~i:'r.,.:~;,i~:,~~\';{.::)':~ . '..,;s~~':', ..,d."".'....'-,....4'[~"'~ \.' '~'''-'>' ~.~~~;;:< i:~';;}: . .~:::.,.::~:::~~ ;;< ~". :~~; '~-. )~': " }:L. '.' '.r ,~ '. ../',' . . . ','ii '" c... ~ ~i ~.~' ~ -;'; " ,--,~, '-~>~g~?-'~:; ,,! .' tL:'-,-:;.~_ ~ ~:\~'.:~~, 'F -c.,~," \h.- -....._: ,. -~.- . , -,~ : :,. ., :1 ~:.i; V' , .' ~ )'t;.(;:" "'.i'~:, . .~ :'~(~~~.i>~~:. ;.b::,:~~~:~~:' " "" - ~~ :"-~; - ^ -',,-:-,:,.-': ;' 't-.--- . .~ :.'-~:~:~.~:-....: ;:.~ #'~_: 'j< -',.' ,"-; ,,0. . . -~- .:-- ~i s. ..:'.~ ..~.~ .Il loot alii a l>IW 'W o ... - n - Ir Ii I; ~.. I~O . = ~!.. 'I" .'il ~"'II .; ';;:. i'l < ill, g,g gCoj rt< = I ~ ~. ,. '-j IICIUJU) ,. IIAJIIIITT. .lA, Marney .. Law ., NaIll..... en. n.,'1\ ~ ~.4.;tL.. 17"0 (7'''' f>>.4,. . .. . MARl CATHERINE ZEIGLER, Plaintiff : IN THE COURT OF COMMON PLIAS CUMBERLAND COUNTY, PENNSYLVANIA v NO. fl{- ./ J"li r ,i.,1 1~.., CHRISTOPHER J. ZEIGLER, Defendant CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFENDANT AND CLAIM RIGHTS YOU RAVE BEEN SUBD 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania. IF IOU DO NOT FILE A CLAIM FOR ALIMONI, DIVISION OF PROPERTI, LANIER'S FBBS OR UPENSES BBFORB A DIVORCE OR AHHULMBHT IS GRANTBD, IOU MAl LOSE THB RIGHT TO CLAIM ANI OF THIM. IOU SHOULD TAKE THIS PAPBR TO lOUR LAKIER AT ORCE. IF IOU DO HOT RAVE A LAKIER OR CAIflIOT AFFORD on, GO TO OR TBLBPHOIIB THB OFFICB SBT FORTH BBL01f TO FIRD OUT lfJIERB IOU CAR GET LEGAL HELP. COURT ADMINISTRATOR Fourth Floor Cuaberland County Courthous. On. Courthous. Square Carlisl., PA 17013-3387 (717) 260-6200 NOTICIA AVISO PARA DBFBNDBR Y RBCLAMAR DBRBCBOS USTBD SA SIDO DBMAHDADO BN LA CORTE. Si deBea defenderBe de laB que jaB expueBtaB en laB paginaB BiguienteB, debe tomar ace ion con prontituBd. Se Ie aviBa que Bi no Be difiende, el caBo puede proceder Bin uBted y decreto de divorcio 0 anulamiento puede Ber emitido en BU contra por la Corte. Una deciBion puede tambien Ber emitida en BU contra por cualquier otra queja 0 compenBacion reclamadoB por el demandante. UBted puede perder dinero, 0 propiedadeB u otroB derechoB importanteB para uBted. Cuando la baBe para el divorcio eB indignidadeB 0 rompimiento irreparable del matrimonio, uBted pluede Bolicitar conBejo matrimonial. Una liBta de conBejeroB matrimonialeB eBta diBponBible en la oficina del Prothonotary, en la Cumberland County Court of COD\Dlon PleaB, One CourthouBe Square, CarliBle, PennBylvania. SI USTBD NO RBCLIl.J1A PBHSION ALIMBHTICIA, PROPIBDAD MARITAL, BONORARIOS DB ABOOADO U OTROS GASTOS ARTBS DB QUE BL DBCRBTO FIlIAL DB DIVORCIO 0 AllULAHIBHTO SEA BHITIDO. USHD PUEDB PBRDBR BL DBRBCBO A RBC~..R CUALQUIBRA DB BLLOS. USTBD DBBB LLBVAR BSH PAPBL A UN ABOGADO DB IIOIBDIATO. SI NO TIBIIB 0 NO PUEDB PAOAR UN ABOGADO, VAYA 0 T.uD A LA OFICIIIA I.CICADA ABAJO PARA AVBRIOUAR DONDB PUEDB OBTBlIBR ASISTBlICIA LBOAL. COURT ADMINISTRATOR Fourth Floor CuaberlaDd CouDty Courthou.. OD. Courthou.. SquaA Carli.l., PA 17013-3387 (717) 2&0-6200 HARY CATHERINE ZEIGLBR, I IN THE COURT or COMMON pLEAS plaintiff . CUMBERLAND COUNTY, PEHHSYLVAHIA . I v . NO. '/'1 ... "I j 'j j CI.L-U (j.---- . . . CHRISTOPHER J. ZEIGLBR, I CIVIL ACTION - LAM Defendant . IN DIVORCE . COMPLAIH'r UNDER SECTION 3301(c) or THE DIVORCE CODE AND NOlI comes the plaintiff, MARY CATHERINE ZEIGLER, by her attorney, Richard F. Maffett, Jr., Esquire, and seeks to obtain a Decree in Divorce pursuant to section 3301(c) of The Divorce Code, upon the grounds hereinafter more fully set forth: 1. The Plaintiff, MARY CATHERINE ZEIGLER, is an adult individual who resides at 349 Regent Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, CHRISTOPHER J. ZEIGLER, is an adult individual who resides at 70 Sam Snead Circle, Etters, York County, pennsylvania 17319. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 16, 1991 at Duncannon, pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. The Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. Plaintiff avers that there are no children of the parties. coon I - DIVORCB 10. The Plaintiff avers that the grounds on which the action is based are as follows: (al The marriage is irretrievably broken. (bl That Defendant has offered such indignities to the Plaintiff, the injured and innocent spouse, so as to make Plaintiff's condition burdensome and life intolerable; 2 COURT II - BOUITABLB DISTRIBUTION 11. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. KBBRBPORB, Plaintiff requests this Honorable Court: (a) Enter a Decree in Divorce; (b) Equitably distribute all property, both personal and real, owned by the parties; (c) Grant such further relief as the Court may deem equitable and just. Dated: ~}hf Respectfully submitted, ;2ur J 111ft! t Richard F. Maffett, 'Jr., Bsquire 2201 North Second Street Harrisburg, Pennsylvania 17110 (717) 233-4160 Attorney for Plaintiff 3 RICttAlIO F. IIA.....II .,JR. . AltonlIYIIU... ......I~ 8tcand'" 1..,-_'1'ii~,,""__1n10 . . . (71'1) ....,eo . I . .. .~ MARl CATHERIHE ZEIGLER, . IN THB COURT OF COMMON PLEAS . Plaintiff . CIDIBBRlAIID COURTI, PBHHSILVAHIA . . . v . NO. 95-&89B . . . CHRISTOPHER J. ZEIGLER, . CIVIL ACTION - LAK . Defendant : IH DIVORCE CERTIFICATB OF SBRVICE I, Richard F. Maffett, Jr., Esquire, do hereby certify that I served the Complaint in the above matter upon Christopher J. zeigler, Defendant, by placing a true and correct copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on September 14, 1995, marked Certified Mail No. Z720048353, Return Receipt Requested, Restricted Delivery, addressed to: Christopher J. Zeigler 70 Sam Snead Circle Btters, PA 17319 Said Complaint was received on September 23, 1995, as evidenced by the return receipt card attached hereto and signed by Christopher J. Zeigler. Dated: ~'f -:....'bt.1 L r , 1995 /lrjj / IL.ll-lf~ Richard F. Maffett, Jr., Ssq. 2201 Horth Second Street Harrisburg, PA 17110 (717) 233-4160 Attorn.y for Plaintiff MARY CATHERINE ZEIGLER, . IN THE COURT OF COMMON PLEAS . plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . V I CIVIL ACTION - LAN . . CHRISTOPHER J. ZEIGLER . NO. 95-&898 . Defendant . IN DIVORCE . AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 14, 1995. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of this Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904, relating to unsworn falsification to authorities. Date: .;;..\ 0110 \ "\ t , plaintiff II MARY CATHERINE ZEIGLER, Plaintiff I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAN v CHRISTOPHER J. ZEIGLER Defendant : NO. 95-&898 : IN DIVORCE NAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 33011c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a 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. 54904, relating to unsworn falsification to authorities. Date: ,:;I\";;ll,' \" r.r R, Plaintiff :,>, ' ....~:~,:~~'.>:.1 . ';.;...--~~~'J; RtCHARD~ IIAFFE11: JA \\~t;,;~:,:,,~,: ......~.U...' . ,.,..;..~,..,....,..,. "fIQ1'u;...;~8INtt ~Ifi{fl;~.~~~~'~tL ;.P~;: :e--' -iA~ ~~_ n, - - - . -' ,,,,,,,,'q"<::i;;;J~.~.~.~17'1D. . o,..,J/;:i;fJilc..\.:,'0n....'.... . t~,-.t<J."i1!;.~~._:~,: >:t<:;:i~r> )':_~'_:>; " ... ~~~~:tii~~;i~,;:: :;.: t~~~1~X~';::;:-:- ,.. .', ~.','~.-j."'iU . ,--,-:,,:'l:(:-_J."!>"~'r""?Pd7~"'!~'(~~'~~ .... . , . '!;--:';~''-<~:~'>;:' ;'-~ " . ,;~~,~~~:~~":j.'.-'. MARY CATHERINE ZEIGLER, IN THE COURT OF COMMON PLEAS plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v : CIVIL ACTION - LAN . . CHRISTOPHER J. ZEIGLER . NO. 95-&898 . Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301(c) of the Divorce Code was filed on September 14, 1995. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of this Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904, relating to unsworn falsification to authorities. Date: UJ-J6 - 9.6 '- f' . ,. l!J~ ('. L-O:, l~: : C) _ ,~ l:...: L r,., I.'. (.; c. ) (- . MARY CATHERINE ZEIGLER, IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . v CIVIL ACTION - LAN : CHRISTOPHER J. ZEIGLER NO. 95-4898 Defendant IN DIVORCE NAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 33011c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a 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. 54904, relating to Ol/,l; ) '11/ ( ) l !~ / .j.. I , J / I Date: OJ - J<:;" f'" unsworn falsification to authorities. -, '- I' , /.." ' (). L:. ,. C~ C L . , k ,"OJ MARY CATHBRINE ZEIGLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95"'9!18 4 5 r,f (I ~ t.'t t v CHRISTPHER J. ZEIGLER, Defendant : CIVIL ACTION - LAN : IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR NAME COMMONKBALTH OF PENNSYLVANIA :SS COUNTY OF DlIUPHIN MARY CATHERINE ZEIGLER, being duly sworn according to law, deposes and says that she is the Plaintiff in the above suit in which a final decree from the bonds of matrimony was entered and she elects to resume her prior name of MARY CATHERINE KNODE, and, therefore, gives this written notice avowing said intention in accordance with the provisions of the Act of May 25, 1939 P.L. 192, as amended July 13, 1953 (23 P.S. 98). 'Jfrlt~- 1 I It W'/ I rt1I1JU ' IP.RY RIn ZEI (Marr d Nue) to be kQcnm a.: '--?1Jl IUUtY (Pri SWorn and .ub.cribed to befon _ thb :}\~" day of 1~: b".. ~~, :J ' 1.996. ..... '-.", .ota...,Pult.llc Lisa M. ~.,',i..., '\ktlNv p~ H..lrn5buf(~ l':t....1t'1f1 f.olln!y ')~ l:{lfTlm'SSllJ". f '~I"t'S ....Jy t\ 1 m .' -- . . .~ ['-, -:::;.... .:-s: "'-' "'-l "<. .-:1 t..:: ',':~ . 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