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~ IN THE COURT OF COMMON PLEAS ~
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. OF CUMBERLAND COUNTY ~
I STATE OF '* PENNA. I
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. DECREE IN ·
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~ DIVORCE :
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ii AND NOW, ..... .. ... -:-tnlt".<!o... -?.o. ~...., 19....... it is ordered and 'l!
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& decreed that ... n~JC, ~,. ~;I~J;:),.. ,....... .... . .., .. .... .. ..... plaintiff, ~
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~ and. .. .qYX'I:liU\ .r:~ .r,INOS~ ... .. ...... ... . .. . . .. .. ............, 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 Q
been entered; No Claims Raised ,~
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
- THIS AGREEMENT, made this 13 day of ;:M.,..NA-N! ,
199~, by and between TERRY R. LINDSEY, of Carlisle, Cumberland
County, Pennsylvania, party of the first part, hereinafter
referred to as "Husband" and CYNTHIA E. LINDSEY of Carlisle,
cumberla~,~~unty, Pennsylvania, party of the second part,
hereafter referred to as "Wife".
WITNESSETH:
WHEREAS, husband and wife were married on December 17,
1988, in Brownsville, Pennsylvania; and
WHEREAS, husband and wife are residents of the
Commonwealth of Pennsylvania and have been so for at least the
past six (6) months; and
WHEREAS, certain diverse, unhappy differences have
arisen between the parties hereto which have made them desirous
of living separate and apart from one another; and
WHEREAS, husband and wife desire to settle and
determine certain of their marital rights and obligations, and
make an equitable distribution of their marital property; and
WHEREAS, it is the intention and purpose of this
Agreement to set forth the respective rights and duties of the
parties while they continue to live apart from each other and to
settle all financial and property rights between them; and
WHEREAS, the parties hereto have mutually entered into
agreement for the division of their jointly owned assets, the
provisions for the liabilities they owe, and provisions for the
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resolution of their mutual differences, after both have had full
and amble opportunity to consult with their respective attorneys,
and the parties now wish to have that agreement reduced to
writing.
NOW, THEREFORE, the parties hereto in consideration of
the mutually made and to be kept promises set forth herein and
for other good and valuable consideration, intending to be
legally bound and to legally bind heirs, successors, assigns, and
personal representatives, do hereby covenant, promise and agree
as follows:
ARTICLE I
SEPARATION
1.1
It shall be lawful for husband and wife at all times
hereafter to live separate and apart from each other and to
reside from time to time at such place or places as they shall
deem fit free from any control, restrain, or interference, direct
or indirect, by each other. Neither party shall molest the other
or compel or endeavor to compel the other to cohabit or dwell
with him or her by any legal or other proceedings. The foregoing
provision shall not be taken to be an admission on the part of
either husband or wife of the lawfulness of the causes leading to
them living separate and apart.
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ARTICLE II
DIVORCE
2.1
This Agreement is not predicated on divorce. It is
specifically understood and agreed by and between the parties
hereto and to each of the said parties does hereby warrant and
represent to the other that the execution and delivery of this
Agreement is not predicated upon nor made subject to any
agreement for institution, prosecution, defense, or for the non-
prosecution or non-defense of any action for divorce; provided,
however, that nothing contained in this Agreement shall prevent
or preclude either of the parties hereto from commencing,
instituting or prosecuting any action or action for divorce,
either absolute or otherwise, upon just, legal and proper
grounds; nor to prevent either party from defending any such
action which has been, may, or shall be instituted by the other
party, or for making any just or proper defense thereto. It is
warranted, covenanted, and represented by husband and wife, each
to the other, that this Agreement is lawful and enforceable and
this warranty, covenant, and representation is made for the
specific purpose of inducing husband and wife to execute this
Agreement. Husband and wife each knowingly and understandingly
hereby waive any and all possible claims of this Agreement is,
for any reason, illegal, or for any reason whatsoever of public
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policy, unenforceable in whole or in part. Husband and wife do
each hereby warrant, covenant and agree that, in any possible
event he an she are and ever shall be estopped from asserting any
illegality or unenforceability as to all or any part of this
Agreement.
2.2
It is further specifically understood and agreed that
the provision of this Agreement relating to the equitable
distribution of property of the parties are accepted by each
party as a final settlement of for all purposes whatsoever.
Should either of the parties obtain a decree, judgment or order
of separation or divorce in any other state, county, or
jurisdiction, each of the parties to this Agreement hereby
consents and agrees that this Agreement and all its covenants
shall not be effected in any way by any such separation or
divorce; and that nothing in any such decree, judgment, order or
further modification or revision thereof shall alter, amend or
vary any term of this Agreement, whether or not either or both of
the parties should remarry, it being understood by and between
the parties that this Agreement shall survive and shall not be
merged into any decree, judgment or order of divorce or
separation.
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2.3
It is specifically agreed that a copy of this Agreement
may be 'incorporated by reference into any divorce judgment or
decree if or whenever sought by any of the parties hereto. Such
incorporation, however, shall not be regarded a merger, it being
the intent of the parties to permit Agreement to survive any such
agreements.
ARTICLE III
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property
in a manner which conforms to the criteria set forth in Section
3502 of the Pennsylvania Domestic Relations Code, and taking into
account the following considerations: the length of the
marriage; the prior marriages of the parties; the age, health,
station, amount and sources of income, vocational skills,
employability, estate, liabilities, and need for each of the
parties; the contribution of one party to the education, training
or increased earning power of the other party; the opportunity of
each party for future acquisition of capital assets and income;
the sources of income of both parties, including, but not limited
to medical, retirement, insurance or other benefits; the
contribution of dissipation of each party in the acquisition,
preservation, depreciation, or appreciation of marital property,
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including the contribution of a party as a homemaker; the value
of the property set apart to each party; the standard of living
of the parties established during their marriage.
3.2
The division of existing marital property is not intended by
the parties to constitute in any way a sale or exchange of assets
and the division is being effected without the introduction of
outside funds or other property not constituting marital
property. The division of property under this Agreement shall be
in full satisfaction of all rights of equitable distribution of
the parties.
3.3
The parties shall retain sole and exclusive right, title and
possession of all personal property currently in their
possession. Except as provide for herein, Husband shall make no
claim whatsoever for any personal property in wife's possession.
Additionally, except as provided for herein, Wife shall make no
claim whatsoever for any personal property in Husband's
possession. Should it be necessary for either party to execute
any documents to convey tile to any such personal property in the
other party's possession, they shall do so within thirty (30)
days of the execution of this Agreement or within thirty (30)
days of the request from the opposing party.
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3.4
Husband and Wife agree to waive and relinquish any and all
right that he or she may now have or hereafter acquire in any
real or tangible personal property subsequently acquired by the
other party. Husband and Wife specifically agree to waive and
relinquish any right in such property that may arise as a result
of the marriage relationship.
ARTicLE IV
DEBTS OF THE PARTIES
4.1
Each party represents to the other that except as otherwise
specifically set forth herein, there are no major outstanding
obligations of the parties, that since the separation neither
party has contracted for any debts for which the other will be
responsible and each party indemnifies and holds harmless the
other for all obligations separately incurred or assumed under
this Agreement.
In the event either party contracted for or incurred any
debts since the date of separation, the party who incurred said
debt shall be responsible for the payment thereof regardless of
the name in which the account may have been charged. Husband and
Wife acknowledge and agree that they have no outstanding debts or
obligations of the Husband and Wife incurred prior to the signing
of this Agreement.
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4.2
Each party relinquishes any right, title and interest he or
she may have to any and all motor vehicles currently in the
possession of the other party. The Parties hereby agree that
Husband shall have sole ownership of the 1987 Ford Tempo. The
Parties hereby agree that Wife shall have sole ownership
(including sole obligation for the payment of the current loan on
said vehicle) of the 1988 Dodge Dakota Truck, as well as the Pop-
Up Camper. Each party shall execute the necessary documents to
have said vehicles properly registered in the other party's name
with the Pennsylvania Department of Transportation.
ARTICLE V
REAL ESTATE
Contemporaneously with the execution of this Agreement, Wife
shall transfer to Husband, by special warranty deed, any and all
of Wife's right, title and interest in and to that parcel of real
estate located at 78 Boyer Road, Carlisle, Cumberland County,
Pennsylvania, heretofore owned by the parties as tenants by the
entireties. Said transfer is subject to those liens, judgments
or mortgages of record as of the date of conveyance, all of which
shall thereafter become the sole and exclusive obligation of
Husband. Wife hereby waives any rights that she may have to
equity or proceeds from the sale of said home. Furthermore,
Husband shall indemnify and hold Wife harmless for all
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obligations incurred with the purchase of said property,
including but not limited to the repayment of the mortgage with
Fleet Mortgage Company.
ARTICLE VI
MISCELLANEOUS PROVISIONS
6.1
The provisions of this Agreement and their legal effect have
been fully explained to the parties by their respective counsel
or the parties have waived their right to have legal advice
regarding the meaning and implication of this Agreement. The
parties acknowledge and accept that this Agreement is, in the
circumstances, fair and equitable, that it is being entered into
freely and voluntarily, after having received such advice and
with such knowledge 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.
6.2
Husband and Wife do hereby mutually remise, release,
quitclaim, and forever discharge the other and the estate of the
other, for all times to come and for all purposes whatsoever, of
and from any and all legal right, title and interest, or claims
in or against the property of the other or against the estate of
the other, of whatever nature and wheresoever situate, which he
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or she now has or at any time hereafter may have against such
other, the estate of such other, or any part thereof, whether
arising out of any former acts, contracts, engagements, or
liabilities of such other as by way of dower or curtesy, or
claims in the nature of dower or curtesy or widow's or widower's
rights, family exemption, or similar allowance, or under the
intestate laws, or the right to take against the spouse's will;
or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under
the laws of (a) pennsylvania, (b) any state, commonwealth, or
territory of the United states, or (c) any other country, or any
rights which either party may have or at any time hereafter have
for past, present, or future support or maintenance, alimony,
alimony pendente lite, source fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except
and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any thereof. It is the intention of Husband
and Wife to give to each other by execution of this Agreement a
full, complete, and general release with respect to any and all
property of any kind or nature, real or personal, not mixed,
which the other now owns or may hereafter acquire, except and
only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any thereof.
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6.3
Each party represents that they have not, after November 19,
1994 (the date of separation) heretofore incurred or contracted
for any debt or liability or obligation for which the estate of
the other party may be responsible or liable, except as may be
provided for in this Agreement. Each party agrees to indemnify
and hold the other party harmless from and against any and all
such debts, liabilities or obligations of each of them, including
those for necessities, except for the obligations arising out of
this Agreement. Husband and Wife each warrant, covenant,
represent and agree that each will, now and at all times
hereafter, save harmless and keep the other indemnified from all
debts, charges, and liabilities incurred by the other after
November 19, 1994 (the date of separation) or execution date of
this Agreement, except as is otherwise specifically provided
herein.
6.4
No waiver or modification of any of the terms of this
Agreement shall be valid unless in writing and signed by both
parties and no waiver of any breach hereof or default hereunder
shall be deemed a waiver of any subsequent default of the same or
similar nature.
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6.5
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.
6.6
This Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
6.7
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.
6.8
If any term, condition, clause, section, 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. Likewise, the failure of
any party to meet his or her obligation under anyone or more of
the articles and sections herein shall in no way void or alter
the remaining obligations of the parties.
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6.9
It is specifically understood and agreed that this Agreement
constitutes an equitable distribution of property, both real and
personal, which was legally and beneficially acquired by Husband
and Wife, or either of them, during the marriage as contemplated
by the Domestic Relations Code of the Commonwealth of
Pennsylvania.
6.10
The parties warrant and represent that they have made full
disclosure of all assets prior to the execution of this
Agreement.
6.11
This Agreement shall survive any action for divorce and
decree of divorce and shall forever be binding and conclusive on
the parties; and any independent action may be brought, either at
law or in equity, to enforce the terms of this Agreement by
either Husband or Wife until it shall have been fully satisfied
and performed. The consideration for this Agreement is the
mutual benefits to be obtained by both of the parties hereto and
the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein
contained is stipulated, confessed, and admitted by the parties,
and the parties intend to be legally bound hereby.
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IN WITNESS WHEREOF, the parties have set their hands and
seals the day and year first above written.
WITNESSED BY:
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Commonwealth of Pennsylvania
county of tt/H1&t"I1t-f'1'IJ)
d~(? ~ ~~~'~~'l
Terry R indsey
(~ ._Q. f",~
cyrlthla E. Ii asey
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On this, the 1~1"Jf day of :J~'f , 1996',
before me, the undersigned officer, personally appeared TERRY R.
LINDSEY, known to me or satisfactorily proven to be the person
whose name is subscribed to the within instrument, and
acknowledged that he executed the within instrument for the
purpose herein contained and with the intent to be legal bound.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial
seal.
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My commission Expires:
Notarial.:.ull
Mlchlel J. Hlnh. Notary Pubeo nc
Carllale Sora. Cumblrlarid unty
My Commlulon Expltal AprIl1:!. 199P
Mantl8t.PIl.....~olNollltel
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Commonwealth of Pennsylvania
county of C..v~<<& If/! <-A-.Nt>
On this, the Is rH day of ;:r TtNIIM-y ,199 S,
before me, the undersigned officer, personally appeared-cYNTHIA
E. LINDSEY, known to me or satisfactorily proven to be the person
whose name is subscribed to the within instrument, and
acknowledged that she executed the within instrument for the
purpose herein contained and with the intent to be legal bound.
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IN WITNESS WHEREOF, I have hereunto set my hand and notarial
seal.
Not~ Jlllr
My Commission Expires:
NOlarlal Seal
Michael J, Hanh. Nolary PubIIo
Carlllla Bora. Cumberlarid Countv
My Commllllon Elt)lIreIAprfI13.1898
MImber.I'Im)MniIA........., III NoclltII
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: CIVIL ACTION - LAW
IN DIVORCE
NO. 95-6648 civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY,
Plaintiff
CYNTHIA E. LINDSEY,
Defendant
PRABCIPB TO TRANSMIT RBCORD
To the Prothonotary:
Please transmit the record, together with the following
information, to the Court for entry of a divorce decree:
1. Ground for divorce: irretrievabls breakdown under
Section 3301(C) of the Divorce Code.
2. Date and manner of service of the Complaint: via hand
delivery on November 22, 1995, Defendant signed an Acceptance of
Service.
3. Date of execution of the affidavit of consent required
by section 3301(C) of the Divorce Code: by the plaintiff--March
6, 1996 (filed March 7, 1996); by the Defendant--March 4, 1996
(filed March 5, 1996).
4. Related claims pending: No claims raised.
5. Date and manner of service of the notice of intention to
file praecipe to transmit record: Waiver signed by Plaintiff on
March 7, 1996 and filed March 8, 1996; Waiver signed by Defendant
on March and filed March 13, 1996.
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6. Attached are copies of the Separation and Property
Settlement Agreement entered into by the parties. said Agreement
should be incorporated into the Divorce Decree.
Respectfully submitted,
HANFT & VOHS
Date: March 13, 1995
Michael J. H
Attorney ID 57976
11 West Pomfret Street, suite 2
Carlisle, PA 17013
(717) 249-5373
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
NO. 95- t.t.'f{ CWJ -r~
CYNTHIA E. LINDSEY,
Defendant
NOTXCE TO DEFEND AND CLAIM RIGHTS
YOU HAVB BBEN 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 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,
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.
Court Administrator
Fourth Floor, Cumberland county Courthouse
Carlisle, PA 17013
(717) 240-6200
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY,
Plaintiff .
.
. CIVIL ACTION - LAW
.
v. . IN DIVORCE
.
.
. 95- t,G 'If 6,"'-.1 .,.~
CYNTHIA E. LINDSEY, . NO.
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Defendant .
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COMPLAINT IN DIVORCE
AND NOW, this 21st day of November, 1995 comes Plaintiff,
Terry R. Lindsey, by and through his attorney, Michael J. Hanft,
Esquire, and files the following Complaint in Divorce, and in
support thereof avers as follows:
1. The Plaintiff is Terry R. Lindsey, who currently resides at
78 Boyer Road, Carlisle, Cumberland County, Pennsylvania.
2. The Defendant is Cynthia E. Lindsey, who currently resides at
667 South Fileys Road, Dillsburg, York County, Pennsylvania.
3. The Plaintiff and Defendant are sui juris, and both have been
bona fide residents of the Commonwealth of Pennsylvania for a
period of more than six (6) months immediately preceding the
filing of this Complaint in Divorce.
"
4. The parties were married on December 17, 1988 in Brownsville,
Pennsylvania.
5. The marriage iy irretrievably broken. The foregoing facts
are averred and brought under sections 3301(C) or 3301(d) of the
Divorce Code of 1980, as amended.
6. Alternatively, Plaintiff avers that the Defendant has offered
such indignities to him, the injured and innocent spouse, as to
render his condition intolerable and his life burdensome. The
foregoing facts are averred and brought under section 3301(a) (6)
of the Divorce Code of 1980, as amended.
7. The plaintiff has been advised of the availability of
counseling, and that the plaintiff may have the right to request
that the Court require the Parties to participate in counseling.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
a Decree in Divorce, divorcing the Plaintiff from the Defendant.
Respectfully submitted,
HANFT & VOHS
M chael J. H ft, squ re
Attorney ID No. 57976
11 West Pomfret street, suite 2
Carlisle, PA 17013
(717) 249-5373
VERIFIC:lATION
I VERIFY that the statements set forth in the attached
.
document are true and correct to the best of my knowledge,
information and belief. I understand that false statements
herein are made subject to the penalities of 18 Pa. section 4904
relating to unsworn falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY,
Plaintiff .
.
. CIVIL ACTION - LAW
.
v. . IN DIVORCE
.
.
.
CYNTHIA E. LINDSEY, NO. 95-6648 civil Term
Defendant .
.
CBRTIFICATB OF SBRVICB
AND NOW, this 22nd day of November, 1995, I, Cynthia E.
Lindsey, hereby certify that on November 22, 1995 I was served
with a True and Correct copy of the Divorce Complaint filed in
the above-referenced matter. The Divorce Complaint was handed to
me by Michael J. Hanft, Esquire.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY,
plaintiff
v.
CYNTHIA E. LINDSEY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NO. 95-6648 civil Term
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(C) of the
Divorce Code was filed on November 21, 1995.
2. The marriage of the Plaintiff and Defendant is
irretrievably broken and more than ninety (90) days have elapsed
from the date of the filing of the Complaint in Divorce.
3. I consent to the entry of a final decree in 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.
5. I understand that the costs of these proceedings will be
paid for by Plaintiff.
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. section 4904 relating to
unsworn falsification to authorities.
Date: .3/ fo J'i'
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Terr~~LindSey
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY, .
.
plaintiff .
.
. CIVIL ACTION - LAW
.
v. . IN DIVORCE
.
.
.
CYNTHIA E. LINDSEY, . NO. 95-6648 civil Term
.
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the
Divorce Code was filed on November 21, 1995.
2. The marriage of the plaintiff and Defendant is
irretrievably broken and more than ninety (90) days have elapsed
from the date of the filing of the complaint in Divorce.
3. I consent to the entry of a final decree in 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.
5. I understand that the costs of these proceedings will be
paid for by Plaintiff.
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. section 4904 relating to
unsworn falsification to authorities.
Date: 3-"1-"
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IN THB COURT OF COMMON PLBAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRYR. LINDSBY, .
.
plaintiff :
CIVIL ACTION - LAW
v. . IN DIVORCE
.
.
.
CYNTHIA B. LINDSBY, . NO. 95-6648 civil Term
.
Defendant .
.
tlAIVE:~:' N~I;E ~: i::ENTI~~ T~:<~UEST
~:::y ;:~ "g; '~HE DECREE UNDER
~o oj DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce
without notice.
2. 1 understand that 1 may lose rights concerning alimony,
division of property, lawyer's fees or expenses if 1 do
not claim them before a divorce is granted.
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3. 1 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.
1 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: 3b/q~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TERRY R. LINDSEY,
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
NO. 95-6648 Civil Term
CYNTHIA E. LINDSEY,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(cl 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: 1 ~i" - "t
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