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HomeMy WebLinkAbout95-05997 '.J I a Q! ". l '" , I ! I i , V r- , 0-' ~ ' t n .j "- .. ~ '" ... '" '" ...; v; <> .. . 4\ ~ ' ;:::.~;,,--;:+~;. ";~~;"";:E;-"'~":"-;::'~;"'-;~"-~~_;-"-'~-~'-'-'.3::;--'~;::.::;-" ,':::+::;- - ;::+>";::+::.',.::+;;.::+::;' >::+;.' _,.::+::;.- _ .::+:>,. F: >::.x,:'''c-~~~>~~~~~.,~::.::i-::..:::c<,,-~::Ct~._-~::c.'c-,:;t ~ - , . ~ ~ ~ IN THE COURT OF COMMON PLEAS ~ ~ ~ ~ OF CUMBERLAND COUNTY ~ I ~ ~ * ~ ~ STATE OF_, .' "PENNA. ~ ~ ,1 . ~ ~ ~ ~,' ~ 'I." S ~,.,. N~~'~~U,~':l'H" 'uUH""uuu'uuU'''''H'' 1,1 N 5997 1995 S~",~",. .. Plaintiff (). H'''''''''"""""", '"'' """" " " S H"''''''''U'''','" .U".",. '''H''''''''''''''"". II W ". ,,", S Versus " I ; ~~u~~,~':l, JR., D~f~~~~~~" u"" II I s HU..,UU. "H"""" UUU....U.." ~ ~ ~ ~ ~ ~ DECREE IN ~ ~ ~l D I V 0 R C E : : AND NOW, . . . . . . . F.4-.b.,.....1oI 1, . . .']. . '. 19, ~~. . " it is ordered and ! I x ~ decreed that ................. ~~.C!. .F.', .R!<.Y. , . . . . . . . ' . . . . . . . . . '. plaintiff, ~ ~ and,..............,... ..~I:~.I?: .~'!~ .'!~:......,.,........... defendant, I ~ are divorced from the bonds of matrimony. The Marital Settlement Agreement ~ ~ dated January II, 1996 is incorporated herein, but not merged. ~ ~ 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; '.' ~ ~ ~ ~ ~ $ ~ 8 : ::.;..~ hJE e. ,~?' i~ , H' H" H' ~2:[u, 'H~'~notarY' ~ 11.,_ ;':E"'O>>:, '.3:, 0>>:.'0>>:"31:" ''''':E''3:' .,.:. .,.,. ".~ .,.:.-'~~~~..,..,.,.. ".,. """. .,.;::-:,.;~ .. ,. .........,...... ............. ......... .......... ,...................... f".. w ~.~ ,..... '... -,... ..- ..... ",..... .... ..... ..... .......... .,...... ...... ......... 8 $ #\ ~ ~ .. MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this llth day of January, 1996, by and between NANCY F. RAY of 45l Garden Drive, Mechanicsburg, Pennsylvania, l7055 (hereinafter "WIFE") and ALLAN D. RAY, JR. of 674 Laurel Drive, Boiling Springs, Pennsylvania, l7007 (hereinafter "HUSBAND") 1 WIT N E SSE T H: WHEREAS, the parties hereto were married on June 5, 1971 in Russellton, Allegheny County, Pennsylvania 1 and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the said parties and it is therefore their intention to live separate and apart for the rest of their lives and to settle fully and finally their financial and property rights and obligations between each other. NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree as follows: l. ADVICE OF COUNSEL Both parties acknowledge that they have been afforded the opportunity to consult with an attorney of their choice prior to signing this Agreement. WIFE is represented by Debra A. Denison, Esquire. HUSBAND is unrepresented. HUSBAND is cognizant of his J\ .... ~ r right to legal representation and declares that it is his express voluntary and knowing intention not to avail himself of his right to counsel and chooses instead to represent himself with respect to the preparation and execution of this Agreement. Each party acknowledges that this Agreement is being entered into freely and voluntarily and that it is not the result of duress, undue influence or collusion. 2. SUBSEOUENT DIVORCE An action seeking the dissolution of the marriage is pending in the Cumberland county Court of Common Pleas and bears docket number 95-5997. The parties hereby agree that the consents to this divorce action will be executed no later than l20 days after the filing of the divorce complaint. 3. EFFECTIVE DATE This Agreement shall be effective on the date above first written if both parties sign on the same date; otherwise, it shall become effective upon the signing by the last party to do so. 2 ~ .. ,. .. 4. WARRANTY OF DISCLOSURE Each party hereby confirms that he or she fully understands the terms, conditions and provisions hereof and believes same to be fair, just, adequate and reasonable under the existing facts and circumstances. The parties further declare that each is executing the Agreement freely and voluntarily, having either obtained sufficient knowledge and disclosure of their respective legal rights and obligations or, if counsel has not been consulted, expressly waiving the right to obtain such knowledge. 5. DEBTS AND OBLIGATIONS WIFE represents and warrants to HUSBAND that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which HUSBAND or his estate might be responsible, and she shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. HUSBAND represents and warrants to WIFE that, since the separation he has not, and in the future he will not, contract or incur any debt or liability for which WIFE or her estate might be responsible, and he shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of such debts 3 jJ ~ f , or obligations incurred by him since the date of said separation, except as otherwise set forth herein. WIFE and HUSBAND recognize that the only existing marital debt is the mortgage, line of credit and car loans which have been distributed in this agreement. 6. REAL PROPERTY The parties hereto acknowledge and agree that the residence located at 674 Laurel Drive, Boiling Springs, Pennsylvania, l7007 is marital property to be divided among the parties. WIFE hereby agrees that HUSBAND will refinance the property and remove WIFE's name from any and all encumbrances against the home. Said encumbrances include a mortgage in the amount of approximately $22,535.00. upon refinancing, WIFE hereby agrees to execute a deed transferring her interest in the home to HUSBAND. HUSBAND agrees to remove WIFE's name from the line of credit secured by the home which has a current balance of O. The home has been appraised at a value of $l53,000.00. In consideration of the transfer of WIFE's interest in the home to HUSBAND, HUSBAND agrees to pay WIFE the amount of $65,232.00 at the ~ of refinancing of the marital home. This transfer is pursuant to a marital, separation and is intended to qualify for section l04l(c) status as a tax free transfer. 4 J\ .. ~ , 7. PERSONAL PROPERTY The parties acknowledge that they have heretofore agreed upon an equitable distribution of all items of personal property. It is understood and agreed that each party shall retain his or her sole and separate property free and clear of any claim of the other. All those items of personalty which each now has in his or possession and control, respectively, without the necessity of any document for further assurance except as otherwise provided herein. 8. VEHICLES WIFE owns a 1995 Honda Prelude which is encumbered by a jointly held loan. WIFE hereby agrees to refinance the vehicle and remove HUSBAND's Obligation. WIFE further agrees to indemnifY and hold harmless HUSBAND for any obligation arising from this debt. HUSBAND owns a 1995 Mazda Navagon which is encumbered by a jointly held loan. HUSBAND hereby agrees to refinance the vehicle and remove WIFE's obligation. HUSBAND further agrees to indemnify and hold harmless WIFE for any obligation arising from this debt. 9. PENSION. RETIREMENT AND OTHER EMPLOYEE BENEFITS WIFE and HUSBAND recognize that each holds civil Service Retirement Funds and TSP funds which can be considered marital 5 .-'\ .. ;"" r property. HUSBAND holds a retirement fund valued at approximately $5l,848 and a TSP fund valued at approximately $28,639.38. WIFE holds a retirement fund valued at approximately $47,739 and a TSP fund valued at approximately $24,93l.l5. HUSBAND also holds an IRA valued at approximately $l,395.98 with Equitable Life and two IRA's with Members lst valued at approximately $8,924.38 and $4,669.5l. WIFE holds two IRA's with Members lst Credit Union valued at approximately $l3,789.00. WIFE and HUSBAND are both cognizant of their right to have the above retirement accounts formally appraised and specifically waive such right. WIFE and HUSBAND hereby waive any and all interest in each other's retirement accounts. lO. SPOUSAL SUPPORT AND ALIMONY WIFE anq HUSBAND do hereby waive, release, discharge and give up any rights which either may have against the other to receive alimony or other post divorce maintenance or support. From the execution date of this Agreement, it shall be the sole responsibility of each party to sustain himself or herself without seeking any support from the other. 6 ~ .& . ll. TAX PROVISIONS The parties agree to file a joint tax return in 1995 and agree to file separately thereafter. Any refund from the 1995 tax return shall be divided equally. The capital gains on the marital home shall be divided equally between the parties. All transfers which occur pursuant to this Marital Settlement Agreement are intended to receive ~l04l status under the Internal Revenue Code. l2. LIFE INSURANCE WIFE and HUSBAND each hold life insurance Pblicies with Equitable Life. HUSBAND's cash value is approximately $3,046 and WIFE's cash value is approximately $650. WIFE and HUSBAND are cognizant of their right to have the current value of the life insurance appraised. WIFE and HUSBAND waive their right to a formal valuation and to any and all interest in each other's life insurance policies. l3. ATTORNEY FEES. COURT COSTS Each party herebY agrees to be solely responsible for his or her own counsel fees, costs and expenses. Neither shall seek any 7 .' ~ ... . contribution thereto from the other party except as otherwise expressly provided herein. 14. ~ WIFE and HUSBAND own two cats: Jazbo, a siamese and Aretha, a tabby. The parties have agreed to share ownership of the cats on a bi-weekly schedule. All costs and expenses of ownership are to be shared equally between the parties. l5. MUTUAL RELEASE HUSBAND and WIFE do hereby release each other from any other claims with respect to the marital and non-marital assets of the parties. Additionally, each party hereby releases any interest that he or she may have in the estate of the other. l6. MUTUAL COOPERATION HUSBAND and WIFE shall mutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of documents. 8 ,. r Ii" , l7. AGREEMENT BINDING ON HEIRS This Agreement constitutes the final agreement of the parties and is binding upon their heirs, assigns and successors in interest. 18. VOID CLAUSES 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 shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 19. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 9 J . " r 20. ENTIRE AGREEMENT 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. 2l. BREACH OF AGREEMENT HUSBAND and WIFE hereby agree that if either party breaches any of the t~rms of this Agreement and a claim or further legal action is required, the breaching party shall reimburse the other all legal fees and costs incurred as a result of said breach or claim. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. This Agreement is executed in duplicate, and in counterparts. HUSBAND and WIFE acknowledge the receipt of a duly executed copy hereofoL !fL- .itne', L .itoe..' ~ eJut-U-l J tio Nancy F. :R'ay ~ f).R 9J Allan D. Ray, Jr. lO . . < i' . SS. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. ~~ JcWMML J! ~tiu- Notary Public My Commission Expires: ~SIIII ~K.SaIt1er.',"",,-"'''''' "",,,..HiIlBom.~~ MyCCmmloslon ~Aug. ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF &mher/o;?d . i 'on the ~ day of /J/.,. - .~, 19~, before me, a Notary Public in and for the commo~ 6f Pennsylvania, the undersigned officer, personally appeared ALLAN D. RAY. JR., known to me (or satisfactorily proven) to be one of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and deed. :SS. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. ~ ,..,... . .,< )/JIAA t1M/K.L ~ ~J:,/~ otary Public My Commission Expires: -' .- ~ _SIIII a- K. SaIt1er. NcIlryN:llo ~HIIBom.~Olur1W My co." ,1IsoIoo , ElIpiles Aug. 25. 19l17 II . .. J{:~~. g~"..-,,',..~-~. fI ,:'Y~ ~- ::: ........~ . '" \i':~$ ~~,~~~-- rnn'\ \J.J: ::;.: :JJ :.-;::.c ' 0}';'_::: - -<.~.;:- yC) 'J"O ~O :P'!2. ~ -0 =r.: w .' V1 CP . ~-.;. .~,.' ---;:;1 . i\~ -:11" .'.J~ ., ,~J o"e11 ."'),",' '''<''$ Om "" !Q ;;<, /:',~~:.:'. ! :f/~~---" :::: .......~ '.~ ~; -:; :..:::/ ~ ../ - " , ~<::.,.v~:t'=:-,"--- ~. .' , .' , DAGBR " ADLER, PC BYI DBBRA A. DBNJ:SON, ESQUJ:RB Attorney 1.0. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (717) 763-l383 Attorneys for Plaintiff NANCY F. RAY, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . v. NO. 95-5997 . . ALLAN D. RAY, JR., CIVIL ACTION - LAW . . Defendant : DIVORCE PRABCJ:PB TO TRANSMJ:T RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate divorce decree: 1. Ground for divorce: Irretrievable breakdown UDder section 3301(0) or the Divorce Code. 2. Date and manner of service of complaint: The complaint was riled on Ootober 19, 1995 and vas served on Allan D. Ray, Jr. on october 28, 1996 by oertiried mail. 3. Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: by plaiDtirf JaDuary 30, 1996; by Derendant January 27, 1996. 4. Related Economic Claims pending: There are DO ecoDomic claims pending as the distribution of all personal and real property has been settled by agreement or the parties. Respectfully submitted, DAGER " ADLER, PC Datel January 31, 1996 ...~ 'DB . SON, BSQUJ:RB ,r . .. (') <.0 ~ C 0" ~""- " ~ -Urn ,..., Si~!.;i '..':':0 r"i"ifQ ~~~ , "'"-'r" ,;0 ~~C) -0 ~~ "';:0 ~": (::::C) <;~ :~.~ -1>S 0 ~ ::"1 Ul ~ -<. CO ! 5 1 ! ].1 "1- <ff -s. 0 ~ () If) - :.- 0 0 ,:) l!g . "'~ 8 tJ) 0' ..,~ l() 0 If) 0 <:l :Ie ~:!....t (~ -s UJ<'..~, '. t<) r- '? z.;:..:,:r \J" V) 2 ~') \() ii " LL... c'" r.:l :.... x: "~1 j (...... , r cr "- c::::r ,.:::,..... ,..,) ,T:I~ ~ iIO en - ~;2 ... = ~~!ii~ ~!;(~i2lil <~~~~ :':!!~:f;; ~~::E:E5 ;lil:;l:i~ a:-"'<3 . . , , . , . . . ___IL_' A~SIL.' ,e.aIL.' .nIL_ 'ONlWO;I'OOA'\ddfIS~U"'.lS-TJ\' __~--=--=--~....,..---c=,..=-._ . i' t . . " i . -~. . . ,. . '" . RBAGBR (0 ADLBR, PC BY: DEBRA A. DElf:ISON, ESQU:IRB Attorney 1.0. No. 66378 2331 Market street Camp Hill, PA l7011 Telephone: (7l7) 763-1383 Attorneys for Plaintiff NANCY F. RAY, IN THE COURT OF COMMON PLEAS : CUMBERlAND COUNTY, PENNSYLVANIA Plaintiff : V. . . NO. 95 - 5997 ~ 7€. V'l CIVIL ACTION - LAW ALLAN D. RAY, JR., Defendant 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. 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, Cumberland County Courthouse, 1 Courthouse Square, carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER I 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 Lawyer Referral Service Court Administrator South Hanover Street Carlisle, PA 17043 (717) 240-6200 ... , . t , . NO'1'J:CJ:A Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siquientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE. S1 NO T1ENE ABOGADO 0 S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10N, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA. AVER1GUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. , . , , . , .' RBAGBR r. ADLBR, PC BY: DBBRA A. DBNJ:SON, BSQUJ:RB Attorney I.D. No. 66378 233l Market street ' Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff NANCY F. RAY, IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . v. : NO. : ALLAN D. RAY, JR., CJ:VJ:L ACTJ:ON - LAW . . Defendant . . DIVORCE COMPLAJ:NT J:N DJ:'\fORCB UNDER SBCTJ:ON 33011C) OR ID) OF THB DJ:VORCE CODB 1. Plaintiff is Nancy F. Ray who currently resides at 451 Garden Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Allan D. Ray, Jr., who currently resides at 674 Laurel Drive, Boiling Springs, Cumberland County, Pennsylvania, 17007. 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 June 5, 1971 in Russellton, Allegheny County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United states or its allies within the provisions of the Soldiers' & Sailors' civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that no children were born of this marriage. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit 2 , .' " consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to section 330l (c) or (d) of the Divorce Code. COURT :I: BOU:l:TABLB D:l:STR:l:BUT:l:OR ll. Paragraphs one (1) through ten (lO) of this Complaint are incorporated herein by reference. 12. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt. Respectfully submitted, RBAGER " ADLER, PC Date: October 18, 1995 By'~~ . , A. R OR, BSQU:l:RB 3 . .' . . . . . VERIFICATION I, Nancy Ray, 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 l8 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. aL-~c1~!!u Date: 100Ilii/'l'Y;- 4 t......1 , ..... ,. ....0..... en 2z:oz ...0 ... ... ka:Co~ '= ot-z>- og'5U11 UoJu..a:;Z ..... -Jwl.U% i:;:xcnw .....%0- - ::> CO ~u = ~ ~ tu J .: w i !;( ~ ~ lil rJ) ~ ~ ~ 011 i:; ~ J rr: z t:: w rr: =! ~ 0 " t:::. ~ ~ 0.. :i rr: <5 ... , .... , - , . " , , , . , _'KlLe. .l.n-sliil Le ,,.'C1ii lLe. ...nIL. ON.wOII.OOA1oWrl$'I'Wta'IU....lS-TI'W ----=-~--,--~_. ~- -- - - - ---..- ----._"--- .~~ i , , .~ , , ...'" . ~, . ... . ... , ,;::.. 'j. ~~ ., ,i.. RBAGBR , ADLBR. PC BY: DBBRA A. DBNXSON. BSQUXRB Attorney 1.0. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (7l7) 763-1383 Attorneys for Plaintiff NANCY F. RAY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . NO. /Qcr5 - () 5997 v. . . ALLAN D. RAY, JR., CIVIL ACTION - LAW . . Defendant DIVORCE AFFXDAVIT OF SBRVICB I, Debra A. Denison, Esquire, being duly sworn according to law, depose and state that service of the Complaint in Divorce in the above-captioned matter was served by certified mail, restricted delivery, on the Defendant, Allan D. Ray, Jr., on October 28, 1995. The certified receipt is attached hereto as Exhibit "A". Respectfully submitted, RBAGBR , ADLBR. PC Date: NovemJ:ler 1. 1995 By: ~~.:z~... BSQUXRB . , . - , r, ". -~ , > . . > .....:' Z "If? 1f30 Olf3 ~ Receipt for ~. Certified Mall No Insurance Coverage Provided ~~~~~s 00 not use for International Mail f I; J pi " i a 11 r- 111 I c I 0 ~ i l'l MR ALLAN 0 RAY JR 674 LAUREL DRIVE BOILING SPRINGS PA l7007 L:" 1$ 0.55 CertifiedFeo 1.10 Special Delivery Fee Restricted OeIiv'llryFee 2.75 Return Receipt Showing 1.10 to Whom and Dale Delivered Return Receipt Showing to Whom, Date, and Addressee's Address TOTAL Postage $ 5.50 ."'" ~ :> " Ii' g> ,r'. 10/20/95 Z 847 430 043 , ,,. "\. .- ,", i RBAGBIt Ii ADUlt, PC BY: DBBRA A. DBNXSON, BSQt1XRB Attorney I.D. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff NANCY F. RAY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . v. : NO. 95-5997 ALLAN D. RAY, JR., : CIVIL ACTION - LAW . . Defendant DIVORCE AFJ!'XDAVZT OJ!' CONSBIIT 1. A Complaint in divorce under section 3301 (c) of the Divorce Code was filed on October 19, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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. - f r" ,,-. .. l"'\ , 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. S 4904 relating to unsworn falsification to authorities. ~o'w Allan D. ay, Jr. Dated: f 1"1~ 2 , " .. (') s u.ri3 rnn; ;':-::1) 6-; S~ -~...:.- r::Cl ;;.~~ e~;,:~ :i:;8 ~ "'. ~ \.0 C... -., :-, CO I ':) ", -< ;i~ "".'6 ::.::1 '-) .., -r::B 00 om ;;! ~ ::g y.' c.... co .. .. j"" ~ ~ ... 't \ RBAGER r. ADLBR, PC BY: DEBRA A. DBII:ISON, ESQU:IRB Attorney 1.0. No. 66378 2331 Market street camp Hill, PA 170ll Telephone: (717) 763-1383 Attorneys for Plaintiff NANCY F. RAY, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . v. . . : NO. 95-5997 ALLAN D. RAY, JR., CIVIL ACTION - LAW . . Defendant : DIVORCE AFF:IDAV:IT OF CONSBNT 1. A Complaint in divorce under section 330l(c) of the Divorce Code was filed on October 19, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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. 2: 9661 'Of; ,(;nmul'f' :pa~va ~~.~ / f" . 'saT~T~oq~nv o~ uOT~voT~Ts1v~ u~o~sun o~ 6uT~v1a~ ~06~ ~ 'S'O'Vd 81 JO saT~lvuad aq~ o~ ~oa~qns apvm a~v uTa~aq s~uama~v~s aS1v~ ~vq~ puv~s~apun I '~oa~~oo puv an~~ a~v ~T^VPTJJv sTq~ uT apvm s~uama~v~s aq~ ~vq~ ~~T~a^ I ... r,. .. . fI \ .. - '. >- cr: ~~ wy gt~_i L1-__', Lt. ['-2" 9,,, 8L E~~-: F lL. o - co u' (-.~ ?: -7 :.3 <" (1::,-"" 0"-:; 0=~ "'.....f-,'? ---,! "'" ~ ~~~i ~ ::s o 0- (7) L:-:. L>- V) C', ~ "'.. r .. . "' .. 'Ii ...... .. . ". l RBAGBR " ADLBR, PC BY: DBBRA A. DEIJJ:SON, ESQUI:RE Attorney I:.D. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NANCY F. RAY, . . v. : NO. 95-5997 . . ALLAN D. RAY, JR., CIVIL ACTION - LAW Defendant . . . . DIVORCE WAIVER OF NOTI:CE OF I:NTENTI:ON TO REOUEST ENTRY OF A DI:VORCE DECREE UNDER SECTI:ON 3301(C) OF THE DI:VORCE 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 ! 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. l: 9661 'Of: A~"nU1ir :pa~-ea ~'~A~ 'sat~l~oq~n-e o~ uOl~'eolJtstaJ U~OAsun O~ 6ut~-e!a~ ~06~ ~ 'S'~'-ed 8t JO sat~t-euad aq~ o~ ~oa~qns ap-ew a~'e uTa~aq s~uawa~'e~s as!'eJ ~'eq~ pU'e~s~apun I '~oa~~oo pU'e a~~ a~'e ~tA'ePtJJa Stq~ uT apaw s~uawa~a~s aq~ ~'eq~ ^JT~aA I . rtl> 'I . .. . " >- ~ ,.. IJ.JQ ot: e;::. ~ 2;11~ ~-~ (-, :'",'.-- U.)L.... cr:!y r- lL o c:> In 0') ?; :'5.". C'\-:;.' u;S; ~~ 2;:-j ~r~ ....1!..L. ""'-'> ::5 o ::: C:...- I c::~ L:.J u. ....0 C!. .. . . 'lIt....iIII - . " . .. .. .. . ') '" RBAGBR r. ADLBR, PC BY: DBBRA A. DBNJ:saN, BSQOJ:RE Attorney J:.D. No. 66378 2331 Market street Camp Hill, PA l7011 Telephone: (717) 763-1383 Attorneys for Plaintiff NANCY F. RAY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 95-5997 : ALLAN D. RAY, JR., : CIVIL ACTION - LAW : Defendant DIVORCE WAJ:VER OF NOTJ:CB OF J:NTENTJ:ON Ta REOOEST BNTRY OF A DJ:VORCB DBCREB ONDBR SBCTION 33011C) OF THB DJ:VORCB CODB 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. l!: 1bJ LeI J :pa~'QO '~~ 'A9a '0 U'QTTY 'fJ ~~ (j -or() 'sa,~,~o~~n'Q o~ uo,~'QO,~,ST'Q~ u~o~sun o~ 6u,~'QTa~ ~06~ ~ 's'~'ed 8t ~o sa,~Teuad a~~ o~ ~oa~qns ap'Qm a~e u,a~a~ s~uama~'Q~s aST'Q~ ~'Q~~ pue~s~apun I '~oa~~oo pue an~~ a~'Q ~,^ep,~~'Q s,~~ U, apem s~uama~'Q~s a~~ ~'Q~~ ^~,~a^ I ;.: ",- to " " ... ~ >- co ">- 0; u, b; ~~ ;F.__ lu8 cry -., o~ 0..-....- ~-....... ccS,-' ,1:: o::? ~.,J: ..-");> C.' ..~ r: ~ ~30 U;L I "J?:.. _J." CC', ::.::7 U:,. U)'_U L...J f..:::JtL. ....- L~_ ,f) :5 C) c....'\ U 4" '.... "" ''III~'' ii .