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HomeMy WebLinkAbout96-00972 ~ 11 o ' 5 J:. U' ;' -;;9 i 3 g <5 , " " "', .~" ) //1 t- I ..'j ~ I ,9 'j !, to r- (J-i I ...9 0- O,! Z i' <~. :..; -:+;. ':41:' .:.;. .;.;. -:.:. <<<. .:<<. .:+:. .:.:. .:.:- .;+;. -:+;. :.;. .:+;. <.:. .:.:. <+:- .:+:. :. .:.:- .:+:. .:+:." .:~;: ~:~::.~ ':+;~._'~~;. ,::!:.~<~:' .;.. ~ ,." . .~ ~ i~ . \ (. :. IN THE COURT OF COMMON PLEAS (: ~ ~ ~ jii, ~l , } ~l ~, '/ a' ~I ...:1 ~) -..' ~~:. .:.;. .:..:. .~: ~i o:'l) ~i ~I .'; ~I ~ .,.. ~ ~ ~ ~l : 1 :'1 ~i ~, . , ~j , 1 ~; , ' ~l ~l ~l ~ ~ ~ ,;, ., ~ ~ ~ ~ OF CUMBERLAND STATE OF *~ ,........."':'J....f COUNTY PENNA. FERN L. CHENOWETH, Plaintiff r\ (),!l(i":,9?;!G~v.t,1..,rE1,~m \' l'I'."tl;{ WILLIAM R. CHENOWETH, Defendant DECREE IN DIVORCE ANDNOW.,..\,~.".l'\,.,'" 19,Yh,. it is ordered and decreed that "fll,I:l), ~,., ,C;benQwel:h , . ' , , . . , , , , . . , , , , " , , , , "'. plaintiff. and ' ,WUUam,R. . Ch~noweth. . , , , . , . , , , , , , . . , , , , . , , , , . , , , , " defendant. ore divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which 0 final order has not yet been entered; Vo ~ ;~ I' . All, matters. have. been, ,r.eso,lved, pUli'suant, to ,the ,Property' 'Sett,1ement ,~ .Agr.eement ,reached .by, the, par.ties ,dated, Ju.1y, a." ,19!l&/and' ,:I:nco-rporate\l" but no rged into the Decree. i~ / Dy The Co\urtj// . ' ......Y-r,'JI/ ---,:;,"'7'" vi/'"": hUe,t: ........_ _, /.) ,,, n -# ~ c.X:J'-C.r("#"~ l. ~!Ld.l'#f, P/tlt'''''.."....r..'-J /), v I ',./ ,,) -." (/ 7.:f:..JII"t~ I' ,~Cr:, XfI:~" I /' Prothonolary :~ ..~.~..~.~.~..~.~~..*..~..~..~..~.*.~..~.~~..~..~..~.~. ~ ',' ~ ~ .. ., ~ ,;, ., ~ .. ::> ~ ~ ~ ., ~ i, ~ ~ ~ ~ /. .~ ~ ',' ~ ~ ~ I~ I. ~ ',' I~ , ' :!! J. , S :~ ~ ~ ,;!, , - / J. .k " ,J .!J . ]'.:>> &'C, (.~,..I. ,p,P/"......IV -e ';;'ft 0t,.'Jl-l<'..s:..d4~ ), /:l ~ 1..,,1-, . / -II 1._. ;;V oJ;;) .,(;., 1,nt.t.~ /l"1"~...ti/ ~ lZPI (~~;; " " - . . ,J ...~. 1,1. ; . .;; lti , c~ \ ( ,. ,,". \" . '.' .1_ -: ~.-- 'i . . ::j ".... (.11, C) ..ff) U\;" ,'~1.-_; ( I, .. i(ll .. !r.." , ---} , " ,r,;'r ) l.,.' 0' U n ~ '" III ~ Z 0 lJ ~ .. ~ :l :!j ::l t; ~ e III .. :i ~ ~ ti ~ ii: .. D. .. z 0 ~ " ffi 0 ~ ::l it D- Ill" , 0( .. c II::~ ~ ffi ", II: ID 0( ::E III :J " U ~ Z ~.' . . . PROPERTY SETTLEMENT AGREEMENT ("") t <'.'--'. 'J THIS AGREEKENT, made this ,l/It day of ',."'L~"t- 1996, by and between WILLIAM RONALD CHENOWETH (herer~aft~r referred to as "HUSBAND"), and FERN LOUISE CHENOWETH (hereinafter referred to as "WIFE") . WITNESSETH, That: WHEREAS, the parties hereto are husband and wife, having been lawfully joined in marriage on August 8, 1994, in Cumberland WHEREAS, no children were born of this marriage. County, Pennsylvania. WHEREAS, it is the intention of the parties to settle fully and finally their respective financial and property rights and obligations as between each other arising out of the marriage relationship or otherwise, including without limitation (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of HUSBAND and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles and interests, claims and possible claims in or against the estate of the other. NOW, THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed an essential part hereof in consideration of the foregoing recitals, the mutual promises, covenants and undertakings herein set forth, and for good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL HUSBAND and WIFE declare that they have each had a full and fair opportunity to obtain independent legal advice of counsel of their selection. WIFE has been independently represented by Barbara Sumple-Sullivan, Esquire. HUSBAND is cognizant of his right to legal representation and declares that he has been independently represented by John Connelly, Esquire. Both parties declare that they are executing this agreement freely and voluntarily, having obtained such knowledge and disclosure of their legal rights and obligations and that they acknowledge that this agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2 2. PERSONAL RI~ HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as is she or he were unmarried, except as may be necessary to carry out the provisions of this Agreement. Each may reside at such place or places as she or he may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. This provision shall not be taken, however, to be an admission on the part of either HUSBAND and WIFE of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. HUSBAND and WIFE shall not molest, harass, or malign the other or the respective families of each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with the peaceful existence, separate from each other. 3. DEBTS Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable except as otherwise provided herein, and that except only for the rights arising out of this Agreement, 3 neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party will be liable. Each party agrees to indemnify and hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. 4. WAIVER OF APPRAISAL AND INVENTORY The parties acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and inventory of same, and no statement or representation by either party as to value shall be deemed a misstatement or misrepresentation to the other or be deemed fraudulent. 5. MARITAL AND NON-MARITAL ASSETS HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non-marital assets and marital assets including but without limitation, business interests, jewelry, clothes, furniture, stocks, bonds, pensions and other assets wherever situated whether real, personal or mixed, tangible or intangible, and HUSBAND agrees that all assets in the possession of WIFE shall be the sole and separate property of WIFE; and, WIFE agrees that all assets in the possession of HUSBAND shall be the 4 sole and separate property of HUSBAND. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to any of the above said items which are the sole and separate property of the other. This document shall constitute a bill of sale for said sole property. 6. REAL ESu.:n; WIFE owns property at 68 Cumberland Road, t,emoyne, Cumberland County, Pennsylvania. Said house is encumbered by a mortgage by PHH US Mortgage Corporation. WIFE shall be the sole owner of said home and HUSBAND specifically quitclaims all rights, title and interest which he may have in said home to WIFE. WIFE shall be solely responsible for the existing mortgage and all other real estate related expenses and agrees to indemnify and hold HUSBAND harmless from same. HUSBAND agrees to grant to WIFE exclusive ~ po"o',ion 0' tho homo on 0< bo'o<o J",y.fl. 1996. HUSBAND '"<tbo< ~ agrees to contribute FOUR HUNDRED FIFTY ($450.00) DOLLARS towardC~ the mortgage for June 1996. HUSIlAND further warrants that all utilities and other household expenses will be paid in full as of the date of his vacating the property. 5 7. VEHICLES WIFE shall have sole title and ownership of the parties' Pathfinder. The Pathfinder is currently encumbered with a loan from Members United Federal Credit Union in HUSBAND's name alone. WIFE agrees to transfer said debt to her name or otherwise refinance said debt in her name alone within forty-eight (48) hours of HUSBAND's execution of this Agreement. All payments on the Pathfinder through said credit union shall be paid current by HUSBAND as of the date of delivery of the vehicle to WIFE. HUSBAND agrees to immediately deliver the vehicle to WIFE upon notification that said debt has been transferred. HUSBAND shall have sole ownership of the parties' pontoon boat. 6. PENSION The parties warrant that no pensions are at issue for distribution. 9. BANK ACCOUNTS AND iNVESTMENTS Each party shall have sole possession of the bank accounts in their own names. 6 same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 13. ALIMONY. SUPPORT AND MAINTENANCE Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. HUSBAND and WIFE further, voluntarily and intelligently, waive and relillquish any right to seek from the other any payment for spousal support, alimony and maintenance. 14. CASH PAYMENT Upon HUSBAND's execution of the consent for entry of the divorce, WIFE shall pay to HUSBAND the sum of FIVE THOUSAND ($5,000.00) DOLLARS. This sum is paid as equitable distribution. Said sum has been deposited into the escrow account of WIFE's attorney and will be released upon actual entry of the divorce decree. 8 15. SUBSE~UENT DIVORCE A decree in divorce, entered by a court of competent jurisdiction to either party, shall not suspend, supersede or affect the terms of this Agreement. Upon the expiration of the appropriate ninety (90) day period, both parties agree to enter a Consent Decree for Divorce concerning the provisions of this Agreement in the Court of Common pleas of Cumberland County, Pennsylvania, at docket number 96-972 Civil Term, or any other Court of competent jurisdiction, as a part of a resolution of any divorce action filed. This Agreement, and the terms and conditions contained herein, as well as the enforcement of said terms and conditions, shall not be contingent upon the granting of a Divorce Decree to either party by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. Furthermore, both parties hereto agree to timely execute the appropriate affidavits and consents to secure a No-Fault Divorce as may be required by the Divorce Code of 1980, as amended. Both parties hereto agree that this Agreement may be incorporated into a separate Court Order but shall not merge in such order in the Court of Common Pleas of Cumberland County, Pennsylvania. 9 16. OTHER DOCUMENTATION HUSBAND and WIFE covenant and agree that upon request of the other party, they will forthwith execute and deliver to the other party, any and all wri t ten instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 17. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CLAIMS IN ESTATE Each party hereby releases, waives and relinquishes any and all rights which he or she may now have, or may hereafter have, against the other party under the present or future laws of any jurisdiction (a) to share in the estate of the other party upon the other party's death and (b) to act as executor/rix or administrator/rix of the other party's estate. 18. MUTUAL RELEASE HUSBAND and WIFE each do hereby mutually remise, release, quitclaim 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, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such 10 other, of whatever nature and wheresoever s~tuate, which she 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, contracts, engagements or liabilities of such other or by way of equitable distribution, dower or courtesy, or claims in the nature of dower or courtesy of 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 ter'ritol'y of the United States, or (c) any other country, or and rights which HUSBAND or WIFE may have or at any time hereafter have for the 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. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators 1 1 and assigns, that he or she will never, at any time hereafter, sue the other party or is or her heirs, execut~rs, administrators and assigns, for the purpose of enforcing any of the rights relinquished under this paragraph. Each of the parties further covenants and agrees that he or she will permit any will of the other to be probated "nd allow administration upon his or her personal, real or mixed estate and allow effects to be taken out by the person or persons who would have been entitled to do so had ~USBAND or WIFE died during the lifetime of the othe.. Each of the parties hereby releases, relinquishes and waives any and all right to act as executor or executrix or administrator or administratrix of the other's estate. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Property Settlement 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. 12 22. BINDING EFFECT OF AGREEMENT/WAIVER This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, nor shall such failure be construed as a waiver of any other term, condition, clause or provision of this Agreement. 23. 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 or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 24. CONTROLLING LAW This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 14 25. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS The parties acknowledge that this Agreement shall become effective when actually signed by both parties. o " U{Ii~4 :2 cL~J- LOUISE CHENOWETH WI ~- , "- ( ~/~"~:d. yj~ . WITNESS / 15 " . ',' ." ,.... -, I II,' I' ,l :' (r~ : (. 11;' iL' " " " .," '.~ ,. , , ..~ . , .,,; '-:.") ,":,1 " J;"~ .~ , ;,] ~ , ..~I J '. ) '.' - .. co - o Z B ~ ... 3 ~ jt;~ U}=t:i ~ ~ Ii ~ I&. 11. III Z ~ :I ~ ffi it j ~ II. ::lUl.o 4(~Z O:"j ~ ffi 0: 1D ~ ~ u ~ z FERN L. CHENOWETH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW No. 96-972 Civil Term WILLIAM R. CHENOWETH. Defendant IN DIVORCE , " CERTIFICATE OF SERVICE I, Barbara Sumple.Sulllvan. Esquire. do hereby certify that on this date, I served a true .imd correct copy of the foregoing Plaintiff's Praecipe to Transmll Record. in the above. captioned mailer upon the following individuaUs) by first class mail. postage prepaid. addressed 'Us follows: John J. Connelly. Esquire Connelly. Reid and Spade 108.112 Walnut Street P.O. Box 963 Harrisburg. PA 17108 . DATED: Julv 10. 1996 Barbara Sumple-Sullivan. Esquire 549 Bridge Slreel New Cumberland. P A 17070 (717) 774-1445 Supreme Court I.D. No. 32317 ERN L. CHENOWETH. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA vs. ~~:1~7~CTI~N;)LAWa ,". ( "j" I' ._ ILLlAM R. CHENOWETH. Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. if you wish to defend against the claims set orth in the following pages. you must take prompt action. You are warned that if you fail to o so the case may proceed without you and a decree of divorce or annulment may be entered gainst you by the Court. A judgement may also be entered against you for any other claim or eHef requested in these papers by the Plaintiff. You may lose money or property or other rights mportanlto you. including custody and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, ou may request marriage counseling. A list of marriage counselors is available in the Domestic elations Office at the County Courthouse. I i IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY. I fA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS i RANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. I I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCK IF YOU I o NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE, HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I ELP. I I I Court Administrator. Cumberland County Courthouse. 4th Floor I Courthouse Square Carlisle, PA 17013-3387 Telephone No. (717) 240-6200 ERN L. CHENOWETH. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTfON - LAW No. ILLlAM R. CHENOWETH. Defendant IN DIVORCE AFFIDAVIT REGARDING COUNSELING I. I have been advised of the availability of marriage counseling and understand that may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic elations Office. which list is available to me upon request. 3. Being so advised. I do not require that the Court require that my spouse and I articipate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 P A. CSA ection 4904 relating to unswom falsification to authorities. ATE: 2-/~/;r.; E RN L. CHENOWETH ERN L. CHENOWETH. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA I IL' vs. , ILLlAM R. CHENOWETH. Defendant CIVIL ACTION - LAW No. IN DIVORCE VERIFICATION I. FERN L. CHENOWETH, hereby certify that the facts set forth in the foregoing bOMPLAINT IN DIVORCE are true and correct to the best of my knowledge. information ~ ",,,,. 1.......00 ... wy ,,'~ ,""moo. _ ""',. '" ....j". '" ,....11'..' 18 P.. .S.A. !i 4904 relating to unsworn falsification to authorities. ated: l /;S/f{; , , ,fa. it.-~ JlRN L. CHENOWETH / I"~ . ; /, I ( (, " (') " '. ~~') , , "7 , . ), j ) \'4 , , t, 'I ,'.!,.. ,., '.. ..1 ; III - ci :z .... ~ ~ 3 ~ :I ti ~ UI .. ~ ~ ~ ~ ~ ~ ~ ~ ffi ~ :I a: 11. jUl"ci <(:; z II: WI :s <( 0: III w II: m <( 2 III a ~ z .- ,- -. . . ,,-.--- L _^ " ("..-...._---~ vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION. LAW No. 96-972 Civil Term ERN L. CHENOWETH. Plaintiff ILLlAM R. CHENOWETH. Defendant IN DIVORCE PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of William R. Chenoweth, the Defendant in the hove-captioned maUer. I, JOHN J. CONNELLY. Esquire hereby accept the Complaint In Divorce. on behalf f the above named Defendant. William R. Chenoweth. Respectfully submitted. '::J k)'i: I (11 ated:~ '-,. ~~ r .\ .....-' i t;:l !: ~ IJ I ~:: ( 1 , ...:.. I'~ . , :':'" . - -. ::-~ C' ,. , ..:;:, .. '~.'1 , .., l~ , ~':i ~ -;] -.. "'- .. .' . ::j (J FERN L. CHENOWETH. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA vs. CIVIL ACTION - LAW No. 96-972 Civil Term WILLIAM R. CHENOWETH. Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under !i330I(c) of the Divorce Code was filed on February 22. 1996. 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. DATE: 7/\'/~p / /'. F- (~, Jl c/( ...~:~ WILLIAM R. CHENOWE COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF ) Before me. the undersigned officer, a Notary Public in and for said Commonwealth and County. personally appeared WILLIAM R. CHENOWETH. who being duly affirml';d according to law. deposes and ~ays that the facts and mailer set forth in the within :lOd foregoing WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER A330J(c) OF THE DIVORCE CODE and AFFIDAVIT OF CONSENT areA,ue and ~orr~t ib~I'f'~nowledge. information and belief. (i<1 '~( /~~-- ILilAM .'CtIE .TtI I , Affirmed and subscribed to before me this \.l j i-ii t ~i NO'TARY PUBLIC day or 1.( ( (~. 1996. I 'J '(.l _ \ My (0 (SEAL) ,.. NOT RIAL SEAL JEAN L KOSIER, N<llar)I PubUc , CIty ~ Hem,butg. OaulJhln County L~'f-Eam~:,~ EIl~~.~~.._~~.l ~_, q FERN L. CHENOWETH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION. LAW No. 96.972 Civil Term . WILLIAM R. CHENOWETH, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER llJ30Uc) OF THE DIVORCE CODE J I. il " \' , ij ~ ! , 2. , ! , I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, i 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 statement herein are made subject to the penalties of 18 Pa.C.S. !i4904 relating to unsworn falsification to authorities. DATE: '7 /),~/~(, ~~,-:/ce..'-w;.L .~. CHENOWETH ;-. , , I , " , , j 'o;' - ., ;,(1 l. , ~ . c~ , iJ . .,:J~ . " '. . :j FERN L. CHENOWETH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA vs. CIVIL ACTION - LAW No. 96-972 Civil Term WILLIAM R. CHENOWETH. Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNllER lIJ301lc) 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 statement herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. , DATE: ;0'. /.7' {, l I