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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
CORINNA M. STROMAN,
Plaintiff
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SCOTT S. STROMAN,
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Defendant
DECREE IN
DIVORCE
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AND NOW, ' , f~~,\. '! ,"',1, ,l.L. , , , , , " 19 ~,~ , , " it is ordered and
decreed that ,~or,inn,:" ~', ,s~,roDlap."""""""""""",., plaintiff,
and ,,~C;:9~.t< .$., ,~t;.r9I1\iln"""".,., """"""',.".,..,,'. 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;
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ArtOfllNtvAT U,W
II [MAIN STReET
SM'ReMAHSTOWN, "''' 11'011
7'7-731*1.61
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MARRIAGE SETTLBMBNT AGRBBMBNT
THIS AGREEMENT made this S-#.. day of H-bru.lJfL-, 199', by
and between Scott S. Stroman, (hereinafter referred to as
"Husband,") and Corinna M. Stroman, (hereinafter referred to as
"Wife").
WITNESSETH:
WHEREAS, the Husband and Wife were lawfully married on
November 8, 1985; and
WHEREAS, differences have arisen between Husband and Wife in
consequence of which they intend to live apart from each other; and
WHEREAS, one child was born of this marriage, Cassandra L.
Stroman, born on May 12, 1992; and
WHEREAS, Husband and Wife desire to settle and determine their
rights, obligations, support and custody of the child; and
NOW, THEREFORE, the parties intending to be legally bound
hereby do 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 or
places as he or she 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 as to the lawfulness or unlawfulness of the causes
leading to their living apart.
2 . III'rERFEREHCE
Each party shall be free from interference, authority,
and contact by the other as fully as if he or she were single and
unmarried except as maybe necessary to carry out the provisions of
the 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, nor in any way
interfere with the peaceful existence, separate and apart from the
other, and each of the parties hereto completely understand and
agree that neither shall do or say anything to the child of the
parties at any time which might in any way influence the child
adversely against the other party.
3. DIVISION OF PERSONAL PROPERTY
The parties have agreed to divide between them and
already have divided between them to their mutual satisfaction the
personal affects, household furniture and furnishings and all other
articles of personal property which heretofore have been used by
them in conunon. Neither party will make any claim to any such
items which are now in the possession or under the control of the
other.
4. AUTOMOBILES
The Wife is the owner of a 1990 Nissan Stanza. The
rights and title to the vehicle is to remain with Wife. Wife shall
maintain separate insurance on her vehicle and be responsible for
any and all maintenance and/or related expenses. The Husband is
the owner of a 1992 Pontiac Sunbird, Husband shall maintain
separate insurance on his vehicle and be responsible for any and
all maintenance, expenses and loan payments related thereto.
5. DIVISION OF REAL PROPERTY
The real property previously owned by the parties has
been sold. Each party shall be responsible for reporting 50% of
the capital gain derived from the sale of the marital home on their
applicable tax return, However, notwithstanding the foregoing,
each party shall be entitled to defer the capital gains taxes
pursuant to the rollover or other applicable provisions under the
Internal Revenue Code.
6. MARITAL DEBTS
Husband shall be responsible for all marital debts solely
in his name and Wife shall be responsible for all marital debts
solely in her name. Husband agrees to be responsible for the debt
on the 1992 Pontiac. The jointly owned Sears debt of approximately
$1,200.00 is to be equally divided with Wife establishing her own
account and transferring approximately $600.00 from the sears
account into her individual account. There are no other joint
debts.
7. SHARED CUSTODY
The parties agree that they shall share legal custody of
their child. This means that the parties shall consult with each
other regarding the major parenting decisions affecting the child's
health, education and welfare.
Wife shall enjoy primary physical custody of the parties'
minor child subject to the liberal, temporary physical custody and
visitation of the Husband as follows:
2
a.
child up from
5:00 p.m.
Every other weekend from Friday when he picks the
day care/school (approx, 5:00 p.m.) until Sunday at
b. The holidays of New Years Day, Memorial Day and
Labor day in odd years and Easter, Independence Day and
Thanksgiving in even years. Holidays will run from 5:00 p.m. the
day before the holiday until 7:00 p.m. the day of the holiday.
c. wife shall have the child in odd years from December
24 at 8:00 p.m. until December 25 at 4:00 p.m. and in even years
from 5:00 p.m. December 24 until 4:00 p.m. December 25. Husband
shall have the child in odd years on December 24 from 5:00 to 8:00
p.m. and every December 25 at 3:00 p.m. until December 26 at 7:00
p.m.
d.
consecutively,
notice.
For two ( 2 ) weeks , either consecutively or non-
provided he gives Wife at least 30 days written
e. Father's Day from 5:00 p.m. the day before until
7:00 p.m. the holiday. Mother would have the child on for Mother's
Day from 5:00 p.m. the day before until 7:00 p.m. the day of the
holiday.
f. Holidays supersede all other periods of physical
custody.
g. At other times as the parties mutually agree.
h. Husband must notify Wife at least two ( 2) weeks
prior to his scheduled periods of Temporary Physical Custody if he
DOES ROT int~nd to exercise his rights to custody.
1. Husband is to provide all transportation for his
periods of Temporary Physical Custody.
j. Neither party shall take the child overnight from
the Harrisburg Area without giving the other parent an address and
telephone number for emergency purposes. In addition, ninety (90)
days prior written notice of relocation of the primary residence of
the child shall be given to the other parent. The ninety (90) days
is intended to allow the parties to negotiate any appropriate
changes necessitated by the proposed move. If an agreement is not
reached either party may petition the court for appropriate relief.
k. Each of the parties acknowledges that the terms of
this Agreement regarding custody and visitation may be modified by
a court of competent jurisdiction upon the application or petition
of either Husband or Wife due to a change of circumstances.
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8. CHILD SUPPORT
Husband agrees to pay the Wife $70.00 each week for the
support of his child. This payment includes Husband's share of the
child care expenses.
Wife currently is providing medical coverage for the
child through her employer. Wife will continue to provide the
medical coverage if such medical coverage is available at a
reasonable cost as part of her employment benefits, whether or not
such benefits are paid for directly by the employer or by partial
contribution by Wife. If Wife is unable to provide medical
coverage through her employer, Husband agrees to cover the child
through his employer or to pay one half of the cost of providing
the child with independent medical coverage. Wife and Husband
agreed to each pay one half of all un reimbursed and deductible
medical expenses related to their child.
The parties agree that in the event of a material change
in the cost of living or the financial circumstances of either
party, or of a change in the custody arrangements set forth herein,
the amount of the support payments shall be subject to an
appropriate adjustment by agreement or, if the parties are unable
to agree, by a Court of competent jurisdiction.
9. PENSION AND RETIREMENT ACCOUNTS
Husband and Wife shall maintain their separate pension
and/or retirement accounts. Husband relinquishes any and all
rights he may have in Wife's pension or retirement accounts and
Wife relinquishes any and all rights she may have in Husband's
pension or retirement accounts.
10. JOINT FILING OF IRS RETURN
Husband and Wife agree to file a joint tax return for tax
year 1995 and separate tax returns all subsequent years thereafter.
The parties shall divide equally between themselves the amount of
any refund received as a result of such joint income tax filing and
shall share equally the amount of any tax liability resulting
therefrom. Each party shall promptly share with the other full,
accurate and complete information as to their respective incomes
and deductible expenses. Pursuant to paragraph 5, if one of the
parties elects not to rollover their share of the capital gains
tax, he or she shall be liable for the tax on the entire gain.
11. DIVORCE
The parties, upon the expiration of the 90 day waiting
period, agree to execute Affidavits of Consent and cause those
Affidavits to be filed with the Court in the Divorce Action which
4
Wife has commenced in the Court of Common Pleas of Cumberland
County and docketed to No. 95-5313. Wife's attorney, Thomas D.
Gould, Esquire, is hereby instructed and directed to take all steps
necessary to obtain a final Decree in Divorce under Section 3301(c)
of the Pennsylvania Divorce Code.
12. INCORPORA'l'ION INTO DIVORCE DECREE
This agreement is to be incorporated into any subsequent
Degree in Divorce.
13. CONTINUED COOPERATION
Each party agrees to execute such assignments, titles, or
other documents as may be reasonably necessary or desirable to put
into full effect the terms of this Agreement and shall do so
upon the reasonable request of the other party. Each of the
parties expressly agrees to execute the joint tax return or returns
for tax year 1995 as hereinabove provided and to cooperate in the
endorsement of any refund check or checks that the parties may
receive consistent with the terms hereof.
14. BREACH
If either party breaches any provision of this agreement,
the other party shall have the right, at his or her election, to
sue for damages for such breach, and the party breaching this
contract shall be responsible for the payment of legal fees and
costs incurred by the other in enforcing their rights under this
agreement or for seeking such other remedies or relief as may be
available to him or her.
15. VOLUNTARY AGREEMBN'l'
The provisions of this agreement are fully understood by
both parties and each party acknowledges that the agreement is fair
and equitable, that it is being entered into voluntarily, and that
it is not the result of any duress or undue influence.
16. WAIVER or CLAIMS
Except as herein otherwise provided, each party may
dispose of his or her 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 limitation,
alimony, alimony pendente lite, counsel fees and expenses, and
right to claim equitable distribution of marital property.
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17. BIIIDIRG AFFECT
This agreement shall be binding upon the parties' heirs,
successors and assigns.
18. MODIFlCATIOR ARD WAIVER
Any modification or waiver of any of the provisions of
this agreement shall be effective only if made in writing and
executed with the same formalities as this agreement. The failure
of either party to insist upon strict performance of any of the
provisions of this agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
19. PRIOR AGRlIMIR'J.'S
It is understood and agreed that any and all prior
agreements which may have been made or executed or verbally
discussed prior to the date and time of this agreement are null and
void and of no affect.
20. BR'J.'IRI AGRlIMIR'J.'
This agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein.
21. DESCRIPTIVE HBADIRGS
The descriptive headings used herein are for convenience
only. They shall not have any binding affect whatsoever in
determining the rights or obligations of the parties.
22. APPLICABLE LAW
This agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
IN WITNESS WHEREOF, the parties set their hands and seals
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Corinna M. Stroman
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Commonwealth of Pennsylvania:
County of Cumberland
PERSONALLY APPEARED BEFORE ME, this..:ff+tday o~ 19!M,
a notary public, in and for the Commonwealth of Pennsylvania, Scott
S. StromaD, known to me (or satisfactorily proven to be) the person
whose name is subscribed to the within agreement and acknowledged
that he executed the same for the purposes herein contained.
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IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
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Notary Public
Commonwealth of Pennsylvania:
: as
County of Cumberland
:
PERSONALLY APPEARED BEFORE ME, this c9C*day of ~~ 199.,
a notary public, in and for the Commonwealth of Pennsylvania,
CoriDDa M. StromaD, known to me (or satisfactorily proven to be)
the person whose name is subscribed to the within agreement and
acknowledged that she executed the same for the purposes herein
contained.
julo tIJ, 0~b
Notary Public
I'banaI Seal
l.lIaIa M. ('.oalS, NcUIy P\dc
~Boro,ClIlTtlel1arlJCany
MyCorn.,._ ~ l\p.~ S, 1996
7
v.
IN THB COURT or COMMON PLEAS
CUMBBRLAHDCOUHTY, PBHHSYLVAHIA
NO. 95 - 5313 Civil Term
CORIHHA M. STROMAN,
PlaiDtiff
SOOfT S. STROMAN,
Defendant
IN DIVORCB
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record, together with the following
information, to the Court for the entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of service of the complaint:
October 6, 1995, by certified U.S. Mail, restricted delivery, on
the Defendant.
3. Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Code: by plaintiff February 20,
1996; by defendant February 5, 1996.
4. Related claims pending:
None, the property Settlement
Agreement dated February 5, 1996 is to be incorporated into the
Decree in Divorce.
1h,;,H c,.A 'r') )(/~.,u f 1
Thomas D. Gould
Attorney foe Plaintiff
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111-731-1"15'
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CORIHHA M. STROMAH, . IN THE COURT OF COMMON PLEAS
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Plaintiff . CUMBERLAND COUNTY, PEHHSYLVANIA
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. 95 - .tJIJ
v. . NO. Civil Term
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SCOTT S. STROMAH, IN DIVORCE
Defendant .
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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.
When the ground for is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Court Administrator's
Office, Fourth floor, Cumberland County Courthouse, Hanover and
High Streets, 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. 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 Court Administrator
Cumberland County Courthouse
Fourth Floor
Hanover and High Streets
Carlisle, PA 17013
(717) 697-0371
CORIHHA M. STROMAR, . IN THE COURT OF COMMON PLEAS
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Plaintiff . CUMBERLAHD COUNTY, PEHHSYLVAlfIA
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Y. . NO. 95 - J'JJJ Civil Term
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SCOTT S. STROMAR, . IN DIVORCE
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Defendant .
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COMPLAINT UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Corinna M. Stroman, who resides at 815
Old Silver Spring Road, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. The Defendant is Scott S. Stroman, who resides at 609-A
Geneva Drive, Apartment 32, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
3. The Plaintiff and Defendant have been bona fide residents
of the Commonwealth of Pennsylvania for at least six months
immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 8,
1985 in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
CORIIDIA M. STROMAH, : IR ~HB COUR~ OF CONNOR PLEAS
Plaintiff I CUMBERLAIID COUIITY, PEIDISYLVABIA
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v. . RO. 95 - 5313 Civil ~ena
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ScenT S. S~ROMAB, . IR DIVORCE
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Defendant .
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AFFIDAVI~ OF CO.SER~
1. A complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on October 5, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety ( 90) days have elapsed from the date of the
filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses, if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED: oJ" ~c,
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CORIIOIA M. STROMJUl, . IN THE COURT OF COMMON PLEAS
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Plaintiff . CUMBERLAND COUNU, PEIOISYLVAlfIA
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v. . NO. 95 - 5313 Civil Term
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SCOTT S. STROMJUl, . IN DIVORCE
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Defendant .
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WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c\ OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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 subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
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Corinna M. Stroman
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CORINNA M. STROMAN
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SCOTT S. STROMAN
Defendant
NO. 95-5313 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENT TO REQUEST
ENTRY OF DIVORCE DECREE UNDER
SECTION 3301(C) 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 I understand that false statements
herein are made subject to the penalties of 18 Pa, C.S. 4904
::~::in~t~~:~;:;rn falsification ~t~~ ~
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CORIDA M. S~ROMAII, . IN ~HE COUR~ OF COMMON PLEAS
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Plaintiff . CUMBERLAHDCOUH~Y, PENNSYLVANIA
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v. . NO. 95 - 5313 Civil ~eJ:lll
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SCOT~ S. S~ROMAII, . IN DIVORCE
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Defendant :
CERTIFICATE OF SERVICE
I, Thomas D. Gould, attorney for Plaintiff, in the above
captioned action for divorce, hereby certify that a conformed and
certified copy of the Complaint in Divorce was served upon the
Defendant by Certified Mail No. Z 435 660 514, restricted delivery,
return receipt requested, by depositing the same in the United
States mail on October 6, 1995, pursuant to Rule 1920.4 of the
Amendments to the Pennsylvania Rules of Civil Procedure relating to
the Divorce Code. As indicated by the green return receipt card
attached hereto, the Complaint was received by the Defendant on
10/7/95.
1hJrnFvl]) &J~
Thomas D. Gould
ID # 36508
Attorney At Law
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
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CORIIIIIA M. S'iROMAH, . IN 'iRE COURT OF COMMON PLEAS
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Plaintiff . CUMBERLAND COUNTY, PEIIIISYLVANIA
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v. . NO. 95 - 5313 Civil Term
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SCOT'i S. S'iROMAH, . IN DIVORCE
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Defendant .
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on October 5, 1995,
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) 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.
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.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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