HomeMy WebLinkAbout96-00773
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....JAl'lll.t.A.. uo.:lOA......_.. ... ",.......
, Plaintiff
.~...............-.~...-~.._..........~~...-..
In the GOU" 01 Co"unon 'PI,,, 0'
Gumberland CQOnlY, Pcnruyh'enla
VI.
:-In. ..7.7i,Civ.i1...
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The purpose of this praecipe is
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to amend the caption' of the above-
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To
Lawrence E. Welker
...._..~............._................__......._.~-~.......-.._.
Prothonotary
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: IN THE COURT OF COMMON PLEAS :
* OF CUMBERLAND COUNTY 8
* .
· STATE OF ~ PENNA. ·
: ~- :
* .
. JANET A.. JO'iCS, .
1?1aintiff No. 77 ~,9~yg ..:Z:~~m.... 1996
. *
* Vcrij\lij .
. RA'iMOND L. JO'iCE, III, .
* Defendant ·
. *
8 ~
* DECREE IN ·
. .
* DIVORCE '
* .
. ~
, AND NOW, .. . .. .. . .. .'1t,.{,; /4.-k. 19.7".., It is ordered and ~
~ decreed that ..Jane~.~. . Joyc,? .. .... ..................., plaintiff, :
. and... .~~Y!l1ond. .~'.. ~oxce,. .HI.. ...... ........ . ....... .., defendant, ij
. are divorced from the bonds of matrimony. .
. ~
"'. The court retains jurisdiction of the following claims which have .
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. been raised of record in this action for which a final order has not yet ".
. been entered; . ..
~
. . . . . .. . . . . . . . . . ...,Vd11.t. . . . , . . . . . . . . . . . . . . . . . . . . ... .. ..... . ~
. . . . .. .. . .. .. .. .. .. .. .. .. .. : . .. .. : : . : : : : : : ~
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. . /\0- /} I JuP: .
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.,)'ANET A. JOYCE,
plaintiff
IN THE COURT 01' COMMON PLEAS
OF CUMBERLMID COUNTY, PENNA.
NO. 96-773 CIVIL TERM
VB.
RAYMOND r... JOYCE, III,
Defendant
CIVIL ACTION - LAW
~RAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following
information, to the court for entry of a divorce decreel
1. Ground for divorce: irretrievable breakdown under
Section (3301(c)) l(:~:>(lCl:1l(>ti~ of the Divorce Code. (Strike out
inapplicable section.)
2. Date and manner of service
certified mail, restricted de1J.very
date of deliverty 2/17/96
3. (Complete either paragraph (a) or (b).)
of the complaint I Sent
2/15/96, return receipt
(a)
required by
6/25/96
6/28/96
Date of execution of the affidavit of consent
Section 3301(c) of the Divorce Code: by plaintiff
I by defendant
(b) (1) Date of execution of the plaintiff's affidavit
required by Section 3301(d) of the Divorce Code:
I
(2) Date of service of the plaintiff's affidavit upon
the defendant;
4. Related claims pending: All claims are settled and
~atisfied bv Marriaqe Settlement Aqreement
5. Date and manner of service of the notice of intention to
file praecipe to transmit record, a copy of which is attached, if
the decree is to be entered under section 3301 (d)( 1) (i) of the
Divorce Code.
6. Date
file praecipe
the decree is
Code
of Notice of
and manner of service of the notice of intention to
to transmit record, a copy of which is attached, if
to be entered under section 3301(c) of the Divorce
, or, date of execution of waiver
Plaintiff - 6/25/96. Defendant - 6/28/96
and date of filing of waiver
Plaintiff - 7/11/96 Defendant - 71 1/96
Intent
'-' r' J..
Jan ~.A'l~X~ (. -.'tC" d~
Att rney for P1aintiff/Z8~IKdanx
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CL'.,."aya..~.y'.~I'
AGREEMENT
TBIB ~RZEMZHT, made thiB
If" day of
~
_, 1996,
by and between JANET A. JOYCE, of Cumberland County, pennsylvania,
(hereinafter referred to as "wife"), and RAYMOND L. JOYCE, III,
of Cumberland County, pennsylvania, (hereinafter referred to BB
"HUBband") ,
WITNESSETHI
WHEREAS, Husband and Wife were lawfully married on June 4, 1983,
and
WHEREAS, no children have been born of this marriage, and
WHEREAS, diverse unhappy differencee, disputes and difficulties
have arisen between the parties and it ie the intention of Wife and
Husband to live separate and apart for the rest of their natural
lives, and the parties hereto are desiroue of settling fully and
finally their respective financial and property rights and obligations
as between each other including, without limitation by epecification:
the settling of all matters between them relating to the ownership and
equitable distribution of real and personal property; the eett1ing of
all matters between them relating to the past, preeent and future
support, alimony and/or maintenance of Wife by Husband or of Husband
by Wife; the settling of all matters between them relating to the
past, present and future support and/or maintenance of the children;
the implementation of custody/visitation arrangements for the minor
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children of the parties; and in general, the settling of any and all
claims and possible claims by one against the other or againBt their
reBpective eetateB.
HOW THEREFORE, in consideration of the premises and of the mutual
promises, covenants and undertakings hereinafter set forth and for
other good and valuable consideration, receipt of which is hereby
acknowledged by each of the parties hereto, Wife and Husband, each
intending to be legally bound hereby, covenant and agree as follows:
1. Dilclo.ure of A..et.. Each party asserts that he or she
has made a full and fair disclosure of all of the real and personal
property of any nature whatsoever belonging in any way to each of them
of all debte and encumbrances incurred in any manner whatsoever by
each of them, of all sourceB and amounts of income received or
receivable by each party, and of every other fact relating in any way
to the subject matter of this agreement. These disclosures are part
of the consideration made by each party for entering into this
agreement.
2. Advice of Counsel. Each party has been represented by
an independent attorney, who was ee1ected by the party whom he
represents, in the negotiation and preparation of this agreement.
This agreement has been fully explained to each party by that party'B
attorney. Ea.ch party has carefully read this agreement and ie com-
pletely aware, not only of its contents, but also of its legal effect.
3. Lawfulne.. of SeDaration. It eha11 be lawful for each
party at all timee her.eafter to live separate and apart from the other
-2-
,
party at Buch place as he or she may from time to time choose or deem
fit. The foregoing provisions eha11 not be taken as an admiBsion on
the part of either party of the 1awfu1nese or unlawfulness of the
causes leading to their living apart.
4. Freedom from Interference. Each party shall be free
fr'om interference, authority, and contact by the other, as fully as if
he or she were single and unmarried except as may be necessary to
carry out the provisions of this agreement. Neither party shall
molest the other or attempt to endeavor to molest the other, nor
compel the other to cohabit with the other, or in any way harass or
malign the other, nor in any way interfere with the peaceful exis-
tence, eeparate and apart from the other.
5. Release of Claims. wife and Husband each do hereby
mutually remise, release, quit-claim and forever discharge the other
and the estate of such other, for all time to come, and for all
purposes whatsoever, of and from any and all rights, tit1eB and
interests, or claims in or againet the property (including income and
gain from property hereafter accruing) of the other or against the
estate of ~uch other, of whatever nature and wheresoever situate,
which ehe or he 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, contracte, engagements or liabilities of such
other or by way of dower or curtesy, or claims in the nature of dower
or curtesy of widow's or widower's rights, family exemption or Bimi1ar
allowance, or under the intestate laws, or the right to take against
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the spoule's willI or the right to treat a lifetime conveyance by the
other ftl testllll\entary, or all other rights of a surviving spOUBe 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 Wife
may have or at any time hereafter have for past, present or future
support or maintenance, alimony, alimony pendente lite, counsel 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
Wife and Husband to give to each other by ~he execution of this
agreement a full, complete and general release with respect to any and
all property of any kind or nature, real, personal or 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,
subject, however, to the implementation and satisfaction of the
conditione precedent as set forth herein above.
6. Warranty as to Future Obliqations. Each party repre-
sents that they have not contracted any debt or liability for the
other for which the eetate of the other party may be responsible or
liable, and that except only for the rights arising out of thia
agreement, neither party will hereafter incur any liability whatsoever
for which the other party or the eetate of the other party, will be
-4-
.
liable. Each party agrees to indemnify or hold the othsr party
harm1eBB from and against all future ob1igatione of every kind \
incurred by them, including those for necessities. t
7. per.onal prouertv. Wife and Husband do hereby acknow1- I,
edge that they have heretofore divided the marital property including,
but without limitation, jewelry, clothes, furniture and other person-
alty AS more fully eet forth in the attached Exhibit "A" and "B".
Each of the partiee does hereby specifically waive, release, renounce
and forever abandon whatever c1aime, if any, ehe or he may have with
respect to any of the above items which are the eo1e and separate
property of the other.
8. Hueband Bnd W~f. Peneion Plane. Neither party hereto
shall make a claim upon the other for accumulated pension, profit
sharing, retirement support, retirement benefits, insurance policies,
IRA's or any other retirement related benefits. Husband specifically
waives any right or claims to any interest in Wife's 401K type plan
with CP02. Wife hereby specifically waives any right or claims to any
intereBt in Husband's 401K type plan with Liberty Mutual.
9. Automobile to Hueband. The Husband shall be the sole
owner, free and clear from any claim on the part of the Wife, of the
1994 Rodeo. Wife shall deliver executed certificate of title, Bales
and use tax form and any other documents neceesary to convey title
within ten days of the execution of this agreement.
10. AutomobUe to wU.. The Wife shall be the Bole owner,
free and clear from any claim on the part of the Husband, of the 1984
-5-
.
Ford Bronco II. Husband shall deliver executed certifioate of title,
Ba1eB and UBe tax form and any other documents necesBary to convey
title within ten days of the execution of this agreement.
11. prooertv Not Provided 'or. The parties hereto agree
that they have, by the terms of this agreement, settled, to their
mutual Batisfaction, all rights that either may have in their proper-
ty, whether owned by them jointly or eeparate1y, real and personal,
and wheresoever situated. Any property not epecifica11y provided for'
in this agreement, which the Hueband or Wife owns or has the right to
control or possess, shall be and remain his or her property, free and
clear from any claim on the part of the other.
12. Real Bstate Husband agrees to use his best efforts to
refinance the partiee' real estate located at 209 South Arch Street,
Mechanicsburg, cumberland County, Penneylvania. At closing, Wife
agrees to convey, transfer and grant to Husband her right, title and
interest in the real estate located at 209 South Arch Street, Mechani-
csburg, Cumberland County, Pennsylvania. From the proceede of the
refinance, the first mortgage to Firet Federal Savings and Loan shall
be paid in full, the second mortgage to Mellon Bank shall be paid in
full, and the Mellon Bank credit card in both parties' names shall be
paid in full. In addition thereto, one half of the net value of the
real estate shall be paid to Wife. The net value of the real estate
shall be defined as the appraieed value ae determined by Husband's
refinancing bank's appraiser lees the above etated three payoffs.
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In the event that Husband is unable to refinance the
property as aforeBaid, the property shall be listed for sale with a
realtor and Bold. The proceeds of the sale after payment of all
c10Bing costs and the above stated payoffs shall be divided equally
between Husband and Wife.
13. Waiver of Alimony. The parties herein acknowledge that
by this agreement they have each respectively secured and maintained a
substantial and adequate fund with which to provide themselves suffi-
cient financial reeources to provide for their comfort, maintenance
and support in the station of life in which they are accustomed. Wife
and HUBband do hereby waive, release and give up any rights they may
respectively have against the other for alimony, support, alimony
pendente lite or maintenance. It ehal1 be from the date of this
agreement the sole responsibility of each of the reepective parties to
sustain themselves without seeking any support from the other party.
14. Enforcement. If either party shall bring an action or
other proceeding to enforce this agreement, or to enforce any judg-
ment, decree or order made by a court in connection with this agree-
ment or the divorce of the parties, the prevailing party shall be
entitled to reasonable attorney'e fees from other party.
15. payment of Atto~nev F.... Each party of thie agreement
hereby agrees that each of them will be solely responsible for the
full payment of all attorney's feee and other costs heretofore and
hereafter incurred, respectively, by each of them in connection with
the negotiation, preparation, and execution of thie agreement, and in
-7-
conn~ction with any action commenced by either party with reBpoct to
the divorce of the parties. Each party further agrees hereby to
indemnify and hold the other party harmless from any demand, claim,
lOBS, cost and expense (including additional attorney's feeB) arising
from a failure to pay all of the aforesaid attorney's fees and other
cOStB.
16. Informed snd Vo1untarv Execution. Each party to thia
agreement acknowledges and declares that he or she, respectively:
a. Is fully and completely informed as to the factB
relating to the subject matter of this agreement and as to the rights
and liabilities of both parties.
b. Enters into this agre6ment voluntarily after
receiving the advice of independent counsel, free from fraud, undue
influence, coercion or duress of any kind.
c. Has given careful and mature thought to the making
of this agreement.
d. HaB carefully read each provision of this agree-
ment.
e. Fully and completely understands each provision of
thiB agreement.
17. aeadinq.. The headings or captions preceding the
paragraphs in this agreement are ineerted for convenience of reference
only and shall not be construed in interpreting this agreement.
18. Mutual CooDeration. The Husband and the Wife shall
each concurrently herewith, or at any time hereafter on the demand of
-8-
.
the other, execute any other documents or inetrumente, And do or caUBe
to be done any other acte and things as may be necessary or convenient
to carry out the intents and purpoees of this agreement.
19. Severability. If any provision in this agreement is
held by a court of competent jurisdiction to be invalid, void, or
unenforceable, the remaining provisions shall nevertheless continue in
full force and effect without being impaired in invalidated in any
way.
20. Reconciliation. If there should be a reconciliation of
the parties after the date of execution of this agreement, this
agreement shall nevertheless continue in full force until it is
modified or abrogated by another written inetrument to that effect
signed by each of the parties hereto.
21. Future EarninQ8. All income, earnings or other
property received or acquired by either party to this agreement on or
after the date of execution of this agreement shall be the sole and
separate property of the receiving or acquiring party. Each party, as
of the effective date of this agreement, does hereby a.nd forever
waive, release and relinquish all right, title and intereet in all
such income, earnings or other property so received or acquired by the
other.
22. Waiver of Riqbt.. Each of the parties hereby irrevoca-
bly waive all rights which he or ehe may have to request any court to
equitably distribute the marital property of the parties or to have
alimony / alimony pendente lite or counee1 fees awarded to either
-9-
party, it being the expreBS intention of the parti~B her~to to fully
Bett1e all c1aimB which they have with respect to each other in this
agreement. Each of the partiee further agree to consent to the entry
of a Decree in Divorce.
23. Waiver of Breacb. The waiver of any term, condition,
c1auee or provision of thie agreement shall in no way be de~med or
considered a waiver of any other term, condition, clause or provision
of thiB agreement.
24. Survival of Aqr.lment. If any term, condition, clause
or provision of thie agreement eha11, by its reasonable interpreta-
tion, be intended to survive and extend beyond the termination of the
marriage relationship presently existing between the parties hereto,
said term or terms, condition or conditione, clause or clauses,
provision or pr.:>vieions, shall be so construed, being the express
intention of both parties hereto to have this agreement govern their
relationship now or hersafter, irrespective of their marital status.
25. Juri.diction. This agreement shall be construed under
the laws of the Commonwealth of Pennsylvania, and both partiee consent
and agree to the jurisdiction of the Court of Common pleas of
Cumberland County, Pennsylvania, on account of any suit or action
brought with respect to this agreement or any provisions or matters
referred to in any provisions thereof.
26. Aqreement Bindinq on Partie. and Heir.. This agreement
shall be binding in all its terms, conditions, c1auseB and provisions
;
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JANE'!' A. JOYCE, I IN THE COURT OF COMMON PLEAS
Plaintiff I OF CUMSERLAND COUNTY, PA
I
VS. I IN DIVORCE I
: i
RAYMOND L. JOYCE, I CIVIL ACTION _ LAW ), I
Defendant : No. 1& nJ (t l<": {" L l,~~
I
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 I
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. il. Judgment Inay also be entered
aqainst you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money of property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indiqnities or irretriev-
able breakdown of the marriage, yoU may request marriage counsel-
ing. A list of marriage counselors is available in the office of
the Prothonotary at the Adams County Court House, 111-117
Baltimore Street, GettYsburg, Pennsylvania 17325.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPER-
TY, 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 FOR'l'H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COurt Administrator
Cumberland County Court House
Fourth Floor
(:arlisle, PA 17013
(717) 240-6222
JAN8'1' A. JOYCB, r IN 'l'HB COURT OF COMMoN PLEAs
Plaintiff OF ClJM.BERtANo COl/N'ry, PA
:
VB.
. DIVORCB
.
.
.
RAlnI>ND L. JOYCE, III, : CIVIL ACTION - r.AW
Defendant : NO.
COMPLAur.I' UNDER SBCTION 3301 ( c) OF THE DIVORCE COD.!
AND HOW, this 6th day of February, 1996, comes the
"aintiff. J'n.t A. Joyc.. 'y h., .tto,n.y, J.n... ".x.nd.,.
'.qui,. .nd fil.s this comPI.int in Di,o". upon , c.us. of
action of which the fOlloWing is a statement.
1. Plaintiff is Janet A. Joyce, 36 years of age, who
cu,rantly "'id.s .t 175, "yto, "ndOlph Ct.. N.. Cumb""nd. ..
17070.
2. D.f.nd.nt" "YoOnd t. Joyc.. III. J8 Yee" of .... 'ho
cU".ntly "sid.s st 2D, S. "ch St,..t. "'hsnicsb',.. 'A 17D55.
J. Plaintiff and Defendant have both resided in the
common""th of '.nnsYI.sni. fa, ,t ".st six C', mo'ths "io, to
the filing of the Complaint in Divorce.
-. Th. "'i'tiff and Def.nda't We,. ."'i'd 0, J'na _,
"'3, in St. Jos"h'. C.thOli, Ch"'h. "ch.nics.u,.. .. by
Father Miller..
5. There were no children born between the Partie..
i
,
, i
6. There were no prior actions in divorce or annulment
commenced by the parties.
7. The parties have not entered into a written agreement as
to alimony, counsel fees, costs and property division.
8. 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.
9. While the parties were domiciled within the commonwealth
of Pennsylvania, and through no fault of Plaintiff, the innocent
and injured spouse, the Defendant, in violation of the marriage
vows and the laws of the commonwealth, has offered auch indigni-
ties to the person of the Plaintiff as to render her condition
intolerable and life burdensome.
WHEREFORE, the Plaintiff prays your Honorable Court to enter
a Decree of Divorce from the bonds of matrimony.
I .COUNT II
10. The allegations of paragraphS one (1) through nine (9)
are incorporated herein by reference and made a part hereof.
11. The marriage is irretrievably broken.
WHEREFORE, the plaintiff prays your Honorable Court to enter
.'
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I, I verity that the statements made in this Complaint in
I
, ~J.vor(le 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.
Datel February 6, 1996
ul {/.~.
net A. Joyce
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF YORK
S.S.
Defore me, the undersigned officer, a Notary PUblic, in and
for the said Commonwealth and County, personally appeared
Janet A. Joyce, who, being affirmed according to law, deposes and
says that the facts and matters set forth in the foregoing
Complaint are truly and correct to the best of her knowledge,
information and belief.,
Sworn to and subscribed
I'. betore me this 6th day
of February, 1996.
I ' ()!j(~J \ -;i~:;
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J ANB'.l' A. JOYCE, . IN THE COURT OF COMMON PLEAS
.
Plaintiff I OF CUMBERLAND COUNTY, PINNA.
VS. I
. IN DIVORCE
.
RAYMONJ> L. JOYCE,
Defendant . CIVIL ACTION - LAW
.
No. 96-773 CIVIL TERM
AFFIDAVIT OF SERVICE
AND NOW, this
~lst day of February, 1996 personally
appeared Jane M. Alexander, Esquire, who swears according to law,
that a true and correct copy of a COMPLAINT IN DIVORCE was caused
to be served by certified mail with return receipt requested upon
I the said,
Raymond L. Joyce
209 S. Arch Street
Mechanicsburg, PA 17055
on February 15. 1996 by leaving the same at the Di11sburg Post
Office with poetage pre-paid thereon as evidenced by the mailing
receipt and return receipt hereto attached and made a part
hereof.
re
Sworn and subscribed
before me this 21st
day 0' Feb:u~, ~~96
I~/' l.[ticJ;"t-/
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, JMfBT A. JOYCB,
VS.
plaintiff
l IN THE COURT OF COMMON PLEAS
I OF CUMBBRLAND COUNTY, PENNA.
l
l IN DIVORCE
RAYMOND L. JOYCE,
Defendant
CIVIL ACTION - LAW
No. 96-773 CIVIL TBRM
~ROOF OF SERVICE
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Pri following ..,vlc.. lfor In 11(1r1 i
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)3, Article Addresled to; .... Artlcl. Number
f RAYMOND L. JOya. Z 713 7\1 .152.. J
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i; JMmT A. JOYCB, : IN THE COURT OF COMMON PLEAS
plaintiff . OF CUMBBRLAND coUNTY, PENNA.
, .
I' .
.
i I VB. . IN DIVORCE
.
:
i I RAYMOND L. JOYCE, III, : CIVIL ACTION - LAW
Defendant : NO. 96-773 CIVIL TERM
, I
, ,
I
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under section 3301 (c) of the
Divorce Code was filed on Febr.uarv 13. 1996.
2. The marriage of plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from date of filing of
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 if a claim for alimony, alimony
pendente lite, marital property or counsel fees or expenses has
II
not been filed with the Court before the entry of final decree in I
I
divorce, the right to claim any of them will be lost.
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:, r.,j:J. ') ! (I (,:
c
I:
JAIIB'l' A. JOYCB, I IN THE COURT OF COMMON PLEAS
Plaintiff I OF CUMBERLAND COUNTY, PINNA.
I
VS. . IN DIVORCB
.
.
.
RAYMOND L. JOYCB, III, I CIVIL ACTION - LAW
Defendant I NO. 96-773 CIVIL TBRM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301 (c) of the
Divorce Code was filed on February 13. 1996.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from date of filing of
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 if a claim for alimony, alimony
pendente lite, marital property or counsel fees or expenses has
not been filed with the Court before the entry of final decree in
divorce, the right to claim any of them will be lost.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn
falsification to authorities.
DATE I
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R on L. yee, III
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JANft A. JOYCB, t IN THI COURT 01' COMMON PLIAS
plaintiff I or CUMBBRLAND COUNTY, PINNA.
I
, VB. . IN DIVORCE
.
.
.
RAYIIOIID L. JOYCE, III, I CIVIL ACTION - LAW
Defendant NO. 96-773 CIVIL TERM
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER CODE 53301(c) OF THE DIVORCE CODE
1.1 consent to the entry of a final decree of divorce
without notice.
2. 1 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 prothonota-
ry.
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. S4904 relating to
i unsworn falsification to authorities.
II
Date I
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