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HomeMy WebLinkAbout95-05187 " . , .~~~~~-~~~-~~~~~~'~-*~')*'~:'~*'~~~~~. ~ __ ___.__. _____.___k______~_"_"_"_.. ._,..,"___o__N_"_- ~ ,. ~ g IN THE COURT OF COMMON PLEAS * ~ ~ 8 8 8 8 8 8 8 8 8 .;, " OF CUMBERLAND COUNTY STATE OF *' PENNA. ,'. * ~ ~ ~ ~ BARBARA J. BAER e/k/B BARBARA JEAN BAER 95-5167 CIVIL TERM i\ (} ,d'd,d II) ~ ~ ,;, " \' P 1'..., I \...; 8 HARRY JAMES BAER ~ ~ ~ " a/k/B H. JAMES BAER ,;, ... I, " ... ~ " ... ~ DEe R f E I Nt l ( · "I.. '2.. 1 J~ ~ D I V 0 R C E t ~;J /f'I"\ ~ ANDNOW,~"~""""'" 19f1" it is ordered and ; " ... ~ ~ (, 8 ~ ~ ~ g ~ ~ ~ g $ ~ ~ " ~ " e ~ 8 ~ ~ ~------ ,~,:.o;.'.oOt' " ,;, ~ decreed that "B~~,~~7~, ,J, ~, ~,a,e:':, ~/.~!? ,~~':~~,~<!, ~~,,,!~, ~,a.e:':, plaintiff, ~ ~ ,~ and, , , " ., ,., ,11,~HY, .J,,!I)1!'l.S, ,~~!3.X: ,'!I'f..l.q, !i,', ,~~~.e,E!, filfl,~X:.,. 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; ,;, " ~ '.' ~ ',' Agreement dated December 4, 1996, which said Agreement is a\:'t:'achE!d 'hereto' firid' l'riciorp.cira1:e'd 'herein' b'y 're'fereilce; , b'ut' not' , m13.r.ge(i. .into, .the, Oivor,ce, De.cree..,. ,. . . , , ,.. , ., , , , , " , , " , , ,. , , " ,.., .. , I~ ',' .. \~ l~ .. ~ I.:. j~ .~ o' ~ P- 0' l~ /'.' . ~ '~--*~**'~"~'**~"~'**'~'~'~"~~*~' , PROPERTY SETTLEMENT AND SEPARATION AGREEMI~NT RELATING TO PIVORCE TillS AGREEMENT, made this d!4 day of i.2/.(l,V /7.~k/ -y19961 by and between IIARRY JAMES BAER hereinafter referred to as "lllIshand", and BARBARA J, BAER hereinafter referred to as "Wife". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on May II 1966; WHEREAS, Husband and Wife are the parents of two adult children; WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to become separate and apart from each other; and WHEREAS, Husband and Wife are desirous of setlling fully and finally their respective finilncial and property rights and obligations as betweeu each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; Ihe settling of ! I I, I I I all matters between them relating to the pastl present IInd fulure support, alimony and/or maintenance of Wife by Husband or Husband by Wife; lind, in general, the settling of any and all claims and possible claims by one allainst the other or against their respective estates, NOW THEREFORE, for and in considernlion of the sum of One ($1.00) Dollar by each of the parties interchangeably in hand paid, the receipt whereof is hereby 'I. acknowledgcd, in considerntion of the mutual promises herein contnined, and in considerntion of other good nnd valuable considerations, and intending to be legally bound hereby, the parties mntunlly promise, covenant and agree as follows: I. ^g!:~~meJt!lM.l!.JJar 10 Divorce Proceedhlll.s: This ^l1lcclI\cnl shnll nnt he considered to affect or bnr Ihe right of Wife or J h.shnnd ItI n divlUce nn Inwfull1lt1unds If such grounds now exist or shnll hereafter exist or to such defense ns II\ny he nvnilnhle to either party, 'nlls agreement Is not Intended to condone nnd shnllnnl he deemed to be a condonation on the pnrt of ellher party hereto of nny nct or nds on the pnrl of Ihe other parly which hnve occasioned the dlspules or unhnppy differences which hnve occurred prior 10 or which may occur subsequent 10 the dnte hereof, Z. Jm"!;.<<':!J1LP!voree Decree: The pnrties ngree thnt unless olherwise specificnlly provided herein, this Agreement shnll conlinue in full force nnd effect aft~r such time as n final decree In divorce mny he eutcred wilh respect to the parties, 3. J'erso!![t1 IUg!lts: A. It shnll he Inwfnl for ench pnrly nt alllillles herenfter to live sepnrnte and npnrl flllll\lhe other pArty, At sneh plAce ns he or she mAY frollltillle 10 time choose or deem fit. The foregoing provisions shnllnol be taken as an ndmiss,ion on the part of either pnrty tlf the lAwfulness tlr unlAwfulness of the cnuses leAding 10 lheir living aparl. 1\, Ench pnrty shnll be free from Interference, RUlhority, nnd contRct by the other, ns fnllY AS if he 01 she were single and unlllarrled exec pi ns mny be necessary 2 ... to carry out the provisions oC this Agreement. Neither party shall molest the other or attempt to or endcavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interCere with the peaceful existence, separate and apart Clom the other, 4. Future UchttU!fJhe I'Rrtles; A, WiCe represents and warrants to Husband that from and arter the date of filing the Divorce Complaint, September 28, 1995, she will not contract or incur any debt or liability for which Ilusband or his estate might be responsible, and shall indemnify and save harmless I lusband fromRny and all claims or demands made against him by reason of any such debts or obligations so incurred by her, D, Husband represents and warrants to Wife that from and after the date of filing the Divorce Complaint, September 28, 1995, he will not contract or incur any debt or liability for which Wife or her estate might be responsible, and shall indemnify and save harmlcss WiCe Cwm any Rnd all claims or demands made against her by reason of any such dcbts or obligations so incurrcd by him, C, WiCe agrees to pay the balance, if any, on the Don-Ton Credit Card and Husband agrees to pay any balance on the Sears Credit Card and all other credit cards which has been signed for solely by Husband and to hold each other harmless for lIIIy claims or demand made against each other by said credilors, " '!\. 1'~rJl9IlRJJ~IS,q~ssJQI!1i A, All of the weAting AppArel, jewelry and personal possessions of Wife, wh~rever silllAtel shAll hercAfter he long to WiCe as her separate estAte, 1\, All of the wCAlillg AppAlel, jewelry and personal possessions o( Husband, wherever silllAte, shull hClcufter helong to HusbAnd as his sepamte cstate, (" 1~I'!!!!!ill.J~!'.911~IJYl IllIshalld alld Wife agree lhat when WI(e departs (rom the IllAritAI home, she may remove Any And alllllarilAI household (urniture and tAngible personAl property which the parties considered Illarital And were used In and about the mAlital home, and that Husband shall retain ownership o( whatever such items she leAves behind unless she arranges wilh Ilushand in writing, to pick up some marital items later. Husband and Wife shall eAch retain his or her pre-marital items, gifts and Inheritances without claim from the other. Each oC the pAr lies docs hereby specifically waive, renounce, release and forever abandon whAtever clAims, if any, he or she Illay have with respeclto the olher's Itellls o( household furnitme and personal properly, and (orever abandon whatever claims, If any, he or she IllAY have wilh respect to any o( the honsehold itellls and any other personAl pWperly in And aboullhe marital home which had been the marital properly of the couple, hnt whkh arc now the sole and sepamte properly of the possessor as il\llirutcd herein, 4 " 7, I'crsonlll Vchlclcs nnll I'crsonnl Property: Husband hcrchy rclcascs any and allmarilal inlerest which he may have or may claim in 1992 Olds Ilmvadal lillcd in wife's name Wlfc hClchy IclcllSCS lIny lInelllllmnrltllllnlerestshe may hnve or mny clnim In the 1993 ('nclillm' Scelnn Dcville lInellhe 1996 Pord Plck-ufl, both titlcelln Husband's nnmc only. Ilnshnnel will ('nntlnnc In he ohllgnlellto mnke the monlhly p"yments for snid veh/e1cs nll<l will hnl<l Wif,' hllnnless from nny nnd nil rinnnciRI e1elrhncnt which may accrue to her RS n resnll of Ilnshnnel's fnllure to make prompt pnymenls on snid loan, 8, Jtetll'en~Jl!i Wlfc spedfknlly rclenscs, rcmlscs, renonnces and quit dR/ms Rny inlerest which she may hnvc in IIushnnel's relhclllcnt nnd pension, as Indicated in Ihls Agreement. Hushnnel sJlcriricnlly rclenses, remisesl renounces and quit c1nims any Interest which he mny have ill Wife's relircmcnt nnd pension, as indicated In this Agreement. 9, Rcal Estnte: Ilnshnnel Rnel Wlfc nl'knlllvlcelgc Ihnt they own, ns tenants hy Ihe entlrelles, mnrllnl rcal ('511111.' 511111I11'111 101 Snnscl Dllve, Norlh Mldelleton Township, Cumberland County, I'cnnsylvnnin nnel consisling of a sJllillevcl dwelling, Wife ngrccs 10 transfer her inlerest Ihclcin 10 11nshnllll nnel sign a sJlerinl wnrmnty deed therefor in cxchange for n cashier's chcck, 1lI nHomcy chCl'k of rifly Ihousnnd ($~O,OOO,OO) Dollnrs, The signcd e1l'('e1 shnll hI' plcflnled hy 11ushnnd's aUorney nnd delivl'Ied to Wife's aUorney fUI due Cxc('ulinn and Ihcn fllnced inlo escrow by hushnnd's nUorney nntil Husbllnd's nlltl! ncy ICl'civcs Ihc fifty ($~lJ,OlJlJ) dollnrs nnd signed Conscnls to divorce ~ '. the estate of such other or any part thereofl whether arising out of IIny former acts, contracts, engagements or liabilities of such olher or by WilY uf dower or courtesy, or claims in the nature of dower or courtesy or widowls rights or widower's rightsl family exemption or similar allowance I or under the Intestate Lawlor the rights to take against the spouse's Will, or the right to treat iI Iifetimc convcyancc by the other as testamcntary, or all other rights of the slIIviviug spousc to participatc in a deceased spouse's CSllltCI or auy right which a wife or a husbaud mllY hllvc or at any time hereafter lIlay have for past, present or future support or maintenancel alimony, alimony pendente litel counsel fees, costs or expenses, whcther arising liS a result of the marital separation or olhelWise, except, and only exccpt, 1111 rights lIud IIgreements and obligations of whatsoever nature arising or which may arise undcr this Agreement or for the breach of any part hereof, It is the intention of Ilusband IInd Wife to give each other by the execution of this Agreement a full and complete general release with respect to any and all property of any kind or nature, which the other now owns 01' may hereafter acquire, except, llnd only except, all rights and agrecmcnts IInd obligations of whatever nature IIrising or which mllY arlsc undcr this Agreemcnt or for the breach of any pllrt of this Agrccmenl, subjcct howeverl 10 thc IlIlplemcnlntious IInd slItisfaction of thc conditions prcccdentlls sct forth herein abovc, 13, Mutlllll Cooperallon: Husband IInd Wife IIgree thllt ellch will forthwith (IInd within no more than thirty (30) days lifter demand therefore) execule IIny and 1111 writingsl instfllmcntsl assignments, or releascsl satisfactions, dceds, mortgages or such othcr writings liS may be desirable 8 ". , or necessary for the proper effectuation o~ !his Agreement, including a release required by any financial institution for the purpose of Husband and/or Wife individually acquiriug real estate or olher assets or for refinancing the mortgage obligation, For purposes of tmnsferring Ihe nrl'yfus accounts and the Newbold's accountsl Ilusband and Wife agree to go together to Ne,vbold's with the stock certificates and sign all documents IIl'l"CSsn.y 10 effel'llInle the trnnsfer of the stock and to obtain signature guarantees flU holh the D..eyfus and Newbold's accounts within thirty (30) days of the date of this agreement. 14, Advice of Counsel & Lel!al Fees: TIlis Agreement contains the entire understanding of the parties who expressly acknowledge that this Agreement has been entered into by his or her own volition, with full knowledgl' of the fncts ami full information as to the legal rights and liabilities of each other, arter consllltnlion with counsel of his or her own choosing, or being Informed to retain counsel of his or her own choosing, and each believes this Agreement to be reasonable under the circumstances, being fully informed of all property owned by each other, and each herehy acknowledges that there have been and are no representations, warranties, covenants or agreements other than those expressly set forth herein, Wife is represented by Judith T. Walz of Walz & Walz Law Office, 341 Market Street, Newport, Pennsylvania, Husband is represented by Michael L. Dangs, 302 South 18th Street, Camp I I ill, Pennsylvania 17011. IS, Al!l'eement IIlndlnl! on lIelrs: This Agreemc1ll shall he binding upon the heirs, executors, administrators,legal represenlllli\'cs alld llssi~ns of hoth parlies hereto, 9 Agreement is deemed iIIegnl 01 IInenforcenble, the enllre remnining pOI lion of the Agreement shnll, neveltheless, Icmain enforceable as a valid contrnct, 21. SIU'\'h'J!!lIU9J!!1 U1vorce Decree: The Jlllltil's hl'll'hy Iwknll\vll'dge Ihnllhry hnve nCCl'pledlhe within separallon agreement ns n finnl s('lIll'nll'nl for nil pmposes whntsoever belween themselves as cOlltemplntl'd hy Ihl' Pl'nnsylvnnin Divorce Code, Should n Decreel Judgment, or Order of Sepnratinn nf n Divn,,'l' hr nhtnined hy either of Ihe parties in this or nllY olher slate, ench of the pnl'lies hl'l'eby conscllts And Agrees thAt Ihls Agreement nndAII its covenants shall not bc nffel'led in nllY wny hy any sllch separation or divorce; nndnothlng In any such Decrel', Judgmcnt. Olltl'l of funher modificalion or recision Ihereof, shall alter, Amend or VlllY nny Il'Il11l.lf Ihis Agreement, whether or not ellher or botb of the parties shall remnny, it being understood by and between the parlies that this Agrf:lment shall survive and shall not hc Illl'l'gl'd into nny Decree, Judgmenl, or Order of Divorce or Separalion, 1\ Is spccifknlly agleed, howcver, that a copy of this Agreement or the substancc of the plllvisions thcreuf, mny be incorporated by reference Into any Divorce, Judgment nl 1l1'I'1l'l' fl1l Ih,' pnlposcs of cnforeeablllly only, This incorporallon, however, shllllnol he Il'gnllled ns a merger, It being the specific intent of the parties to permit this Agreemcnltn sUlvive :lny Jlldgmcnt or Decree, and to he forever binding and conclllsive lI(1on the (lilrties, II . IN WITNESS WllEHEOr, thc p"rlics havc signcd this Agrccmcnt on the d"y and YCM firsl "hovc wrillcn, WITNESS: p,;, t, J J /'( I l k(,t.~/( ..~ ' ) ? .~~~k ~ rl--:;I"" ~/'~l!AL) , IIAny JIIIII BACI' q" (jurAc1Ji!j '\) ,\ Q. \t'l..\-,n \1, ~V-f'11L Ul\~ v(SEAL) BArhArn JeAn BAe'~ COMMONWEALTlI OF PENNSYLVANIA COUNTY OF ~erR( On Ihis, thc ~ day orJxCQnJ:cr- , 1996, before me, the undersigncd officcr, pcrsonlllly IIppeared ~~lm Jftn I~'LY-, known to me, or 55, satlsractolily provcn to hc, onc or thc pcrsons whose name is subscrihcd to Ihe within instrllmcnt, and acknowlcdged 111A1 ~'r-Yexecllted the SAmc for Ihe pllrposes therein contained, IN WI'I NESS WllEltEOFI I havc set my hand and notarial seal, te .yJC\ I /)./l NotAry I'nhlic My Commission Expires: I ~~IIAL 1 "'" ,. ZeIdn,....., Nllla My~;: lii1:; =~r;.. 12 BARBARA J. BAER a/kla BARBARA JEAN BAER PlalntllT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA V8. : No. 95.5187 Civil Term IIARRY JAMES BAER a/kla II. JAMES BAER Defendant : Civil Actlon.Dlvorce PRAECIPE TO TRANSMIT RECORD TO TilE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I. Ground For Divorce: Irretrievable breakdown under !i3301(c) of the Divorce Code filed on September 28, 1995. 2. Date and Manner of Service of Complaint: The original Complaint was served upon Defendant by Certified Mail No. P 644 272 255, Return Receipt Requested, on October 3, 1995. Said Complaint was received by Defendant on October 5, 1995, as evidenced by the Return Receipt Card. ... 3. Date of Execution of the Affidavit of Consent Required by the Divorce Code: By Plaintiff: February 17, 1997 By Defendant: February 17, 1997 4. Related Claims Pending.: All matters relating to divorce have been settled by Property Settlement and Separation Agreement dated December 4, 1996. 5. Date and Manner of Service of the Notice of Intention to file Praecipe to Transmit Record: Waiver of Notice of Intention to Request Entry of a Divorce Decree signed by Defendant: February 17, 1997. and by Plaintiff: February 17, 1997. (~--'Jl',a- (/1. 04 ..~' Jj\dlth T. Walz, Esq. ~l WALZ & WALZ 341 Market Street Newport, PA 17074 (717) 567.6993 Attorney for Plaintiff " WALZ &: WALZ ATfOlNE'n AT tAW NEWpORT, PAt BARBARAJ.BAER a/kla BARBARA JEAN BAER PlalntllT V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO 1:;' j/ J 7 (7 AAJ-lC "JL"-,,'-.- : CIVIL ACTION.DlVORCE HARRY JAMES. BAER a/k/a H. JAMES BAER Defendant J'lOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the fol1owing 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. I}YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEFl 'ONE THE OFFICES SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 4th Floor Carlisle PA 17013 7/7 - .,) 4 (j f.r 2,oC') " . 7. There has been no prior action of divorce or annulment of marriage between the parties in this or any other jurisdiction. 8. Plaintiff requests the Court to enter a Decree of divorce. WHEREfORE, Plaintiff prays for divorce from the bonds of matrimony existing between Plaintiff and Defendant. COUNT II INDIGNITIES SECTION 3301(a) Of TilE DIVORCE CODE 9. Paragraphs I through 8 of this Complaint are incorporated herein by reference as though set forth in full. 10. Plaintiff avers that shc is entitled to a divorce on the ground that Defendant has offered such indignities to the person of thc Plaintiff, the injured and innocent spouse, as to rendcr her condition intolerable and life burdcnsome. II. This action is not collusive. WHEREFORE, Plaintiff prays that a Decrec in Divorcc be entered. COUNT III - EOUITABLE DISTRIBUTION 12. Paragraphs 1 through 1 ~ of this Complaint are incorporated herein by reference as though set forth in full. 13. Plaintiff and Defcndanthave acquired property and incurred debt, during their marriagc. 14. Plaintiff and Defendant havc been unable to agree as to an equitable division of said property and debt. WHEREFORE, Plaintiff requcsts the Court to equitably divide all marital property, and to enjoin the Defendant from transferring, encumbering, concealing, selling, removing, disposing or alienating any property owned by Plaintiff and Defendant individually, in co- owncrship, or in any othcr person's namc until further Order of Court, exccpt by Agreement of thc parties. 2 . . " . COUNT IV - ALIMONY 15. Paragraphs I through 14 of this Complaint arc incorporated hercin by referenee as though set forth in full. 16. Plaintiff claims alimony for thc following reason: (a) Plaintiff makes less than Defendant's Income (b> Plaintiff nceds sufficient fnnds to estahlish herself independently of husband after the divorce. 17. Plaintiff rC1luircs reasonable alhnony to adeqnately maintain herself in accordance with the standnnl of living established in the marriage. WHEREFORE, Plaintiff requests this Court to enter an award of Alimony to Plaintiff. COUNT V - COUNSEL FEES. COSTS AND EXPENSES . 18. Paragraphs I through 17 of this Complaint are incorporatcd herein by reference as though set forth In full. 19. Plaintiff has retained an attorney to bring this action and has agreed to pay a reasonable fee for legal scrvices. 20. Plaintiff is not financially able eithcr to meet the expenses and costs of prosecuting this action or the fccs to which her attorney will bc entitled. WHEREFORE, Plnintiff seeks paym~nt by Defcndant of both legal fees, cxpenses and costs of this action. WllEREFORE, Plaintiff prays that a judgmcnt or dccree be cntcred in favor of the Plaintiff and against the Dcfcndant as follows: a. As to Count I and II, that a decrce of Divorce be entered. b. As to Count III, that all marital proJlcrty and debts be equitably divided. c. As to Count IV, that Alimony be entercd in Plaintiffs favor and against Defendant. 3 " " . ., " ,..., BARBARA J. BAER a/kla BARBARA JEAN BAER PlalntllT V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO 95.5187 Civil Term HARRY JAMES. DAER a/kla H, JAMES BAER Defendant : CIVIL Act'ION.DlVORCE AFFlDA VIT OF SER VICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF PERRY :SS. Melissa M. Zeiders, Secretary for Judith T. Walz, Attorney for the Plaintiff, being duly sworn according to law, deposes and says that she mailed a true and correct eopy of the Complaint in the above-captioned action to the Defendant at his address: 101 Sunset Drive, Carlisle, Pennsylvania 17013, by Certified Mail No. P 644 272 255, Return Receipt Requested, on October 3, 1995, and that Defendant did receive same on September 5, 1995 as evidenced by the signed Return Receipt Card attached hereto. '-1fuOtl/)tl f)1. 2 c /rtR;xJ Mclissa M. zeidersJecretary for Judith T, Walz, Esq. 341 Market Street Newport, PA 17074 (717) 567.6993 Attorney for Plaintiff Sworn to and subscribed before me this /#1, day of ( U)e. I- ,1995. ~ -) "} '} ... .' ~-/h,--,'L",t:..c. / ot'L./.'l NO\l\fY Public My Commission Expires: HOT AR!AL SEAL -'1 JUDmi T.Ii/t.LJ. N~lIry Public I ....n !lore. fillY Colur,IY, Pol. i Iti ClllIlRinlon ~~,~!,~~9,:,'2._~:?L. ./ '" " I .110 Wllh 10 roc.l.. 1/11 ::r,W'n(I ..rvl... \lor In IldI. i,., I, 0 Addll-'1 Addr." ! 2. 0 IIl1lri.1ed o.nvllV I ConlUlt .lmlllll lor I... 4''P~lqttr17J JS6" I 4b. Slrvlcl Type o 11191111lad 0 In.urad ~CIl'lilIad 0 COO I o bp.... M.n 0 IIolUm II Ipl lor . . 7. Oil' 01 ~tr 5 . 1995 t B. Add..".... Addll" (Only II ,aquIIlad 'I .nd III II plldl ~ 1; i i ~" ' I .. ' I'" ~_'ondI..alor"""""'-" ,. ComIIlIIt _ a. ond 41 · _. I .. """--....-..............'....'-............... \ . mum UQ '*4 ,. you. \ ..~...... ............ ...._.,............, ....,... - It_ ..... not pormll. , I . - ........ft-'t>t-....... ..................... ......-- . 1'1to_~...........w_...._....--........4... I~' \ .3. ArtlctyAdd.. ""'" 10' i . 11' Qnes gaer l ./0 9Ae'/ or, ~ '. Carti~~ fA no 13 , , , ! .0...mbo"88' "".l-OI'llI,,,,,,,-1I4 DOMESTtC RETURN RECE11'T -_.,..,.,;,"';"""...~,--". aa:~ ~ ._ 'Oll:I CI/ -;; u ~h ,~, 0- & LI1 -..: ~ LI1 a: QI 2 '~) '13 Oln; \ nJ = ~ E \ .. r--. - ra dI Ol -- /~ --.. fI} ::i: 8 - ", nJ .E........~ .. ro- "- -,.-:t; lU 0 Ql , - nJ -g g -;; ~ '--,'.J \: l;~~" ~ ,(: ::r ._::J ~ ' ..... ::r 1:: ~oa: ~ .::::. .~ 1 .D ~ - c" (:" .,,-\1 ~ . 1 ooJ! ') . c.. ~- " I f ., P:" '.'1 ...... "'" -: ~ - ~ III . !. .-'- 1 ~ 0, " ~ ,J " ~ ~ ~ . ~ -..... Vl"- i ., 0' j If ~ ~ ,; ~ y ~ ~. ~~ ~ . . , ! ~ -~ ~ u '" Jo 066\ .unr '008!: wJO~ Sd ,I Lr> ~n or:: ~.-:"t '" C) - "'" .......'--' ;.1 . .' '" = ~,j - ,-, = ! ! f , f -' ",. ", I .v, ~ ~~ J~ ~ ~ j j ... ~. r-I ~J J~ J t<') g.L \ ~ j ~ ~e r-- C) (.::t , " ~ ~ ~ ~ -~~ ~ 1~ ~ &j '" :;;: ~ ,- \ -(. ~ -.JJ ~ l'- ~~ ~ . .. , ~ . I . . ...' vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA BARBARA J. BAER a/k/a BARBARA JEAN BAER, Plaintiff NO. 95-5187 CIVIL TERM HARRY JAMES BAER a/k/a H. JAMES BAER. Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT I, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was flied on SFlpt ?R 11)qo:; and was served upon the Defendant on or about eeteeer s, 1995 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint and the date of service of the Complaint on tha 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 of my Waiver of the Notice of 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 counseling, underatand that the Court maintains e list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised. I 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. I understand that falsa statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, /'1f/iVJfl. q,,4m ~~ / {/ YtARRY E BAER .-/ ,1jJl/9'/ Date I , .. . t .. .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA J. BAER a/k/a BARBARA JEAN BAER, Plaintiff ) ) ) ) ) ) ) ) ) CIVIL ACTION - DIVORCE NO, 95-5187 CIVIL TERM vs. HARRY JAMES BAER a/k/a H. JAMES DAER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33011cl OF THE DIVORCE CODE 1. I consent to the entry of a 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 that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~JI'lh7 . .Il) . ~ / .0/ l~~04~ 0 ~/ (HARRY JAMES AER Dated ~ ~ -\'I tj ~~ ~ Q '- . , f\J ...a ~J I<) ~ .... \ ~ ~ ,d l1~ t"- o- . ..... ., , .