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HomeMy WebLinkAbout96-05665 '" ~ >- L! . ( '" ~ - . . ) . - . , _e~_~_~~~~~~_~_~____)~~~_~e~~~~ ~ ._- ------ ~- 8 ~ 8 :1 IN THE COURT OF COMMON PLEAS : ~! ;1 ~' ~ 8 ~ ~ OF CUMBERLAND COUNTY It' STATE OF '.. ". PENNA. - ~ .. l' ,'''1' SHERRY FRY Plaintiff N O,S6~~,c:ivil.~~~.~., ;. ~l ~ll ~. $1 Xi . . , 8; , 5\ leI ...1 81 81 8l 81 8' 81 81 ~l 8 8 8 ~ 81 8( . \ _l \ 8 . , . '<<. . oW. .. .... \'('rsus LARRY FRY Defendant DECREE IN DIVORCE AND NOW. "" ~ (Y...,...,..... 19't\.. it is ordered and decreed that.. . . She.rrr. F.r~.. . . ... . .. .. . . .. . , . ... .. .. . ...... plaintiff. and ' . , .. . . . . .. . . ~.~rry. .F~L . . , . .. . . .. . .. . .. .. . . . . . . . . . .. '. defendant. are 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 a final order has not yet been entered; None ,..,.,./.".....,. ,...... '. , f -j AUral: ..-" 'v t" . H ,.;;'."'7/.. -.;' J. #- .r4..1t.i ....~.- 'c, t(,...~/JCC,f. ''''~''''''' '. I . & . ~ ( (.? --c-' ,.It, ,',',.. . .c~..., A-' X~ " ~ r ..,'.....""ary ~ .:to:. *.... :.: ~: .:.; :.; .,.;. ~; ;<0: .~. 'lO: .~; Yo":O>: .*. s 8 8 8 8 8 8 8 8 8 8 8 I, 8 8 8 8 8 8 8 8 8 8 8 8 8 S 8 ~ ~ S 8 s ~ ~ . ......h ;','fF v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY . PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE SHERRY FRY. Plaintiff LARRY FRY, Defendant : 5",'5 : NO. 96- CIVIL TERM ORDER OF COURT AND NOW. this \l'\"dayof Co., of,! . 1996. upon consideration of the attached complaint, it is hereby directed that the panies and their respective counsel appear before. \-\.. \Jd\f b"~-'ihe conciliator. al II \ 1,\ 1.\. ,Cumberland County Courthouse. on the I? "day of I).", t.,. 1996. at (\.<A m., for a Pre-Hearing Custody Conference. At such conference. an effon will be made 10 resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the coon. and to enter into a temporary order. Either party may bring the child(ren) who is the subject of this custody action 10 the conference, but the child/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for enlry of a temporary or permanenl order, FOR THE COURT: ~). 1 Y / . By: I. "f .... . .r. l/'.*--I. -'-<r Custody Conciliator ,/ t<))1! 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE. 4th Floor CARUSLE. PA J70n 717/240-6200 AMERICANS WITII DISABILITIES ACT OF 1990 The Coon of Common Fleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible fKilities and reasonable accommodations available to disabled Individuals havirll business before the court. please contact our offICI:. All arrangements must be made alleast 72 boon pri<< to any bearinI or business before the court, You must attenJ the scheduled conference or hearing. FllED-OFFICE OF TIlE Frol1lONOTARY 96 OCT 18 AH II: 29 CUMBEiLN+:> COUNtY PENNS'ttVAN!A IO'lf.9~ (Jd. i'df'? .JHd#~ iY'~ ~ /~ K'Y6 ~~ ~~i.:~ ,? ' /Ci'N,<j{, I'~ ~ A4I 7/.Y.li~~' .. . . , v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA : CIVIL ACTION . LAW : IN DIVORCE SHERRY FRY. Plaintiff LARRY FRY, Defendant / /(, I. ., : NO. 96- 'I CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish 10 defend against the claims set fonh 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 Counhouse. Carlisle, Pennsylvania. IF YOU DO NOT ALE A CLAIM FOR AUMONY, 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 AND OUT WHERE YOU CAN GET LEGAL HELP. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For infonnalion about accessible facilities and reasonable accommodations available to disabled individuals havina business before the coun, please contxt our offICe. AU amngements must be made at 1east 72 hours prior 10 any hearin& or business before the court. You must attend the scheduled conference or hearing. Court Administrator Cumberland COUftl)' CounJlouse Ctrlisle, PA 17013 71712.c0.6200 , . During the past five years, the children have resided with the following persons and at the following addresses: Persolll 1. Sheny Fry Address Salvation Army Sheller 20 E. Pomfret Street Carlisle, PA 17013 Data 8191 - 9/91 2. Sheny Fry, Larry Fry Molly Pitcher Hotel 13 S. Hanover Street Carlisle, PA 17013 9191 - 9/91 3. Sheny Fry, Larry Fry lIS S. Hanover St. Carlisle, PA 17013 9/91 - 9/92 4. Sheny Fry liS S. Hanover St. Carlisle, PA 17013 9/92 - 9/93 S. Sherry Fry, Jon Decker liS S. Hanover St. Carlisle, PA 17013 9/93 - 4/95 6. Sherry Fry, Jon Decker 4 E. Louther St. Carlisle, PA 17013 4/9S - present The motber of the children is Sberry Fry. She is married. The father of the children is Larry Fry. He is married. IS. The relationship of the defendant to the child is that of father. The defendant resides with the following persons: CUmberland COUDly Prison. 16. The relationship of plaintiff to the child is that of mother. The p1aInliff c:urreJIIIy resides with the following persons: ~ ....."-.. Joo Decker Travis Fry A.mcw Fry PIaiIltifrs OoyfrieDd Plaiaifrs child Plaiaifrs child . ,..,..........- ,- . 17. Plaintiff has not participated as a partY or witneSS, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no infonnation of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedingS who has physical custody of the child or claimS to have custody or visitation rights with respect to the child. 18. The beSt interest and pennanent welfare of the child will be served by granting the relief requested because: a) Plaintiff bas been primarY ~ of the children sin:e birth; b) Plaintiff provides the children with a homC with adequate moral, emotional and physical sunoundings as required to meet the children's needs; c) Plaintiff is willing to accept custody of the children; d) Plaintiff exerciseS parental duties and enjoys the love and affection of the children; e) DefeMant baS not indicated an interest in accepting custody of the children; f) DefeMant is currently mcarcerated and bas been periodically sin:e 1992. 19. Eath parent whose parental rights to the children have not been termina1Cd .nd the penon wbo bas physical custody of the children have been named as parties to this action. WHEREfORE. plaintiff RqUeSlS the court to pot to ber sole tepl custodY and primarY physical custodY of the chUdrcn. ._"..~" ...-,' ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I verify that the statements made in this Complaint for Divorce and Custody are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 14904, relating to unsworn falsification to authorities. Date: to - 10 - ,,~ ~5ia SHERRY VR .. . COMMONWEALTH V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA ; ./],713 CRIMINAL 1992 CHARGE: RECKLESSLY ENDANGERING ANOTHER PERSON AFFIANT: PTL. DAVID MCKINNEY . ;vI1589 CRIMINAL 1992 CHARGE: (A) KIDNAPPING (B) UNLAWFUL RESTRAINT (C) RECKLESSLY ENDANGERING ANOTHER PERSON (D) TERRORISTIC THREATS (E) FALSE IMPRISONMENT AFFIANT: CPL, RONALD AMON LARRY EUGENE FRY OTN: E002037-0 OTN: E002565-3 IN RE: SENTENCE ORDER OF COURT AND NOW, this 23rd day of November. 1993. on the charge of kidnapping at 1589 Criminal 1992. sentence of the court is that you pay the costs of prosecution and undergo a term of imprisonment to be served in the Cumberland County Prison of not less than two and a half years less one day nor more than five years less one day, This sentence to dote from September 3. 1992. On the charge of terroristic threats at the same term and number. sentence of the court is that you pay the costs of prosecution and undergo a term of imprisonment to be served in the Cumberland County Prison of not less than two and a half years less one day and not more than five years less one day, This sentence to dote from September 3. 1992. and to run concurrent to the sentence previously imposed, . EXIHBIT A ,- l\ \ - -0 ... '.J t..; ! ~ - ~ \. ~k' ~ c. ~ f l' " LL ,- L I, '.' '; ~ ;;Jobf- SHERRY FRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA : CIVIL ACTION . LAW : IN DIVORCE v. LARRY FRY, Defendant 5'~S' : NO. 96- CIVIL TERM AFFIDAVIT SUPPORTING PKIII10N FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my fmancial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, bx:luding my family and associates, to pay the costs of litigation. 3. I represent that the information below relating 10 my ability 10 pay the fees and costs is true and correct, <I> Name: Sherry Fry Address: 4 E. Louther Street, Carlisle, Pennsylvania 17013 Social Sea1rity No,: 161-56-9202 (b) Employmmt If you are presently employed, slale Employer: Hardees Address: 310 N. Hanover Street Salary or wages per month: $962.00 Type of work: CashIer If you are presently unemployed, slate Date of last employment: N/A Salary or wages per month: Type or wort: (c) Other irM:ome wilbin the past twelve months Business or profession: NI A Other self-employment: N/A (JltUest: None Ohidtftlh: NODe Pcnsioa and IMIlit~: NODe Social security beIlcflt.'I: None Support payments: None Disability payments: None Unemployment compensation and supplemental benefits: None Workman's compensation: None Public Assistance: None Other: None (d) Other contributions to household support (Wife)(Husband) Name: If your (wife)(husband) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other contributions: from Jon Decker, boyfriend: 5100 (e) Propeny owned Cash: Checking account: Savings account: $2.15 Certifu:ates of deposit: Real estate (including home): Motor vehicle: Make, Year NONE Cost , Amount Owed 5 Stocks; bonds: Other: (I) Debts and obligations Mortgage: Rent: $425 Electric: $49 Food: 5320 Kid's Clothing: $40 C1othina: $20 Loans: (J) Pmons dependent upon you for support (Wife)(Husband) Name: Children, if any: Name: Ace: Travis FI)' 9 years old Andrew FI)' 6 years old Other persons: Name: Relationship: ... I WIdt.1tland that I have I toIllimIlna obIiaatioo to inform the c:oun of impro~anent in my financ:ial cil'tlll1lStllUS whkh wookI permit me to pay the costs incumd bemn. " ~-,~ - . ---- S. 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. 14904, relating to uns om falsificat on to authorities. Date )0- IQ - q {, ~ ....--- -- ,.-.".., . . . . ' . SHERRY FRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CML ACTION. LAW : IN DIVORCE : / . ,.. . '/," : NO. 96-" CIVIL TERM LARRY FRY, Defendant PRAECIPE TO PROCEED IN FOR.\fA PAUPERIS To die Prothonotuy: Kindly allow Sherry Fry. Plaintiff. to proceed in forma pauperis. I, Stephen A. Metz, of die Family Law Clinic, ~ attorney for die party p~111I in forma pauperis. certify that I believe die party is unable to pay the costs and that I lID providina free Iep1 service 10 die party. The party's aff'Jdavit showing inability 10 pay the costs of litigation is attaclM'd hereto. Date: 10 J.d q" qrh.t~, ~ ~A. Metz Certif'~Lepllntcm tJA,')'m ,~ ROBERT E. RAINS lltOMAS M, PLACE KAmERINE C. PEARSON Supmisina Attorney GAIL R. SHEARER Staff Attorney TIlE FAMILY LAW CUNlC 4.S Nonh Pin Street Carlisle, PA 17013 (117) 243-2961 ~. C"'. I lu -, .. r L I , .. ..' ". I '- ,. J ~ .....r.-..... - v SHERRY FRY, Plaintiff tIN THE COURT OF COMMON PLEAS OF tCUMBERLAND COUNTY, PENNSYLVANIA t :CIVIL ACTION - LAW : tNOt 96-5665 t IN CUSTODY V LARRY FRY, Defendant COURT ORDER AND NOW, this .J.' tl, day of ;"t /"t uolb. , 1997, upon consideration of the attached Custody Concili.tion Report, it is ordered and directed as follows: 1. The Hother, Sherry Fry, shall enjoy primary legal custody and primary physical of Travis Fry, born February 14, 1987 and Andrew Fry, born October 27, 1989. 2. The Father, Larry Fry, shall enjoy periods of temporary physical custody with the minor children at such times and under such circWllstances as he might be able to agree with the Hother, Sherry Fry. 3. In the event Hr. pry is dissatisfied with his periods of temporary custody that are afforded to him by the Hother after Hr. Fry's release frOll prison, Hr, Pry uy petition the Court at that time to have the case again scheduled for a Conference with the Custody Conciliator. At that time, Hr. Fry can raise all issues relating to custody including whether this situation should be a shared custody order. eet Tina Houkoulia Faaily L4w Clinic 45 NOrth Pitt Str.et Carlial., PA 17013 . - . ~.t. :J./-l'll"'l l'~- ...&,f, "ayJor P. Andren, BaquJre 7. V.at Pa.lret Str.et Carlial., PA 17013 ". SHERRY FRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW V LARRY FRY, Defendant , . :NO: 96-5665 :IN CUSTODY CONCILIATION CUaIl~CE stlHKARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Travis Fry, born February 14, 1987; and Andrew Fry, born October 27, 1989. 2. A Conciliation Conference was held on February 20, 1997, with the following individuals in attendance: 'the Hother, Sherry Fry. ",ith her counsel, Tina Houkoulis, of the Dickinson School of La", Family La", Clinic. 'the Father, Larry Fry, did not attend. The Father is incarcerated in the Cumberland County Prison. His counsel, Taylor P. Andrews, Esquire, contacted the Conciliator by phone and indicated his client's position relative to his desire to see the children upon his release from prison and other matters. 3. The Cancilla tor recOllllJlends an order in the form as attached. ~ / J. vI q7 DArB .. . SHERRY FRY, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 96 - 5665 CIVIL . , , LARRY FRY, : Defendant . IN DIVORCE . ORDER OF COURT AND NOW, this I} If( day of (.\}1 LL..........._- , 1997, no economic claims having been raised in the above captioned divorce proceedings, and the parties having agreed to conclude the divorce by the filing of mutual affidavits of consent under Section 3301(c) of the Domestic Relations Code, the appointment of the Master is vacated. BY THE COURT, k. { \., / 'L.- Ha 01 E. Shee , P,J. cel Tina Moukouli., Student Attorney and Gail R. Shearer, Statt Attorney, Family Law Clinic Attorney. for Plaintiff Taylor P. Andrew. Attorney for Detendant c....,-.- ~-A 3/13/'" .A " , '- ."~ . '- ... ..., i.. lo. , t.} U?\. , C'. ;::: ':.i t.'. C' ~ ,-.) ,. u' ..j ~ "- . .~ 1'.,- ,- , \.. ~. C. ..; - ----... ." - SHERRY FRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. LARRY FRY, Defendant : NO. 96-5665 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record. together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) 01 the Divorce Code. 2. Date and manner of service of the complaint: served by Sheriff on November 8. 1996. 3. Date of execution of the Affidavit of Consent and the Waiver of Notice required by Section 3301(c) of the Divorce Code: by the plaintiff, February 17, 1997: by the defendant, February 8, 1997. 4. Related claims pending: none, ^ Date ~4/'//91 I l. T' Mouk.ou I S1:,A~~ ~4~ ~. , lOMAS ~t pl.An Supcnislnj' Attorney OAIL R. SIIF..ARER Staff Attorney FAMILY LAW CUNIC 4' NMh Pitt Street Carlisle. PA 17013 7171240-'104 ~ ~ --..........- -- /.-:':1- - ,. . .". . 't<,,", . .. . SHERRY FRY, Plaintiff : IN TUB COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : CIVIL ACTION . LAW : IN DIVORCE LARRY FRY, Defendant . : NO. 96-S66S CIVIL TERM AFFIDAVIT OF CONSENT J. A. Comp1.in~ in Divorce under 1330I(c) of the Divorce Code was filed 011 ();:tOOtz IS, 1996, 2. The marria&e of Plaintiff and Defendant is irrettievably btokal and ninety (90) days ba~ ~ from the date of filina the CompIainL 3. I CClllJCIll to the entry of a final decree of divorce after IerVi<:e of notice of Illteootioo to request entry of the decree. I verify that the t"te-u made in this affidavit are trUe and correct. I Ioudt....d that fabe ,t--., All berdn are made SIIbject to the penalties of 18 PLC.S. 14904, platt. 10 IIDS1oOI1l tilIiftclliaa 10 autborities. .....~.~-17. 1l'1_ x ~ 'hl~' , >- 0 to; C\; }~. .. ~, - ~j fi: . ,. c . , -.. c- I , L'.', - u:: r " . ,. " -. ; .' ..... C 0. '-1 .. , .. . . .. , . .. . SHERRY FRY, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . . . v. . CIVIL ACTION - LAW . . IN DIVORCE . LARRY FRY. . . Defendant . NO. 96-5665 CIVIL TERM . ftXVBIl 01' IIO'l'ICB 01' III'lBll'l'IOII 'fO amUU'l' lDI'l'Ily 01' A DIVOJlCB 0-- mma ISS01fa) 01' ~ DIVOJlC. COD. 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I ..y lose riCJbts concerninq alillOny, division of property, lawyer's fees or expena_ if I do not claia th_ 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 _ i-ediately after it is filed with the prothonotary. I verify that the stat_nts ..de in this affidavit are true and correct. I understand that false stat...nts berein are ..de subject to the penalti_ of 18 Pa.C.S. 54904 relatin; to unsworn falsification to authorities. Date: -,. r1. q7 ~.~.. "- .::- u .... ! '. ~~ H.: cr; <: (: ':j .'. C - , ,... ., ['; L.. ;;.,... -' r U u.. . ::l.. ~ - I ~ ...' L' U .. , '- .:r C:',-; N " ~-, i'; .-';~ UJ-l.. (', : .. .' [~; - ,- '~2 0; 8, :-.... , -i,..". I [;": r, ^- 'J .. ~ '" :.: ~ " Ii; _J V f..J .- . .. . . - . . -. . SHERRY FRY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE LARRY FRY, Defendant : NO. 96-5665 CIVIL TERM MOTION FOR APPOINTMENT OF MASTEJJ Sherry Fry, Plaintiff, moves the court to appoint a master with respect to the following claims: (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Ute ( ) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses and in support of the motion states: 1, Discovery is complete as to the claim for whic:h the appointment of a matter is requested. 2. The defendant has not appeared in the action but was served on November 8, 1996. 3. The statutory ground for divorce is 23 Pa.C.S,A, 3301(a)(5). 4. The action is contestt:d with lespec;t to the following claims: Divorce. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to lake one (I) hour. 7. Additiooal information, if any, relevant to the motion: A certified copy of the Order of Court repn1iII& Larry Fry's scnlenCe was flied with the Court OIl October 15, 1996 aJona with the Complaint. Larry Fry was SCIltelIad to imprisoamcnt for not less lhall two and a balf years less one day nor more than five yean less one day. ... ..:r "',..~ f': \..~ ;.. .. U,,!! ~ N g~, ..' ~( '.:C1 ~" ('0., !. t, - l'_ , 1 \..; ,;,~ " .. ~<<:"' ; ~,:;; -, : ~ . ! , c:'J 'J .... .-.............:,~. ,-. -- SHERRY FRY, . rN THE COURT OF COMMON PLEAS OF , Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA , CIVIL ACTION - LAW . . . 96-5665 VB, NO. CIVIL 19 LARRY FRY, Defendant , IN DIVORCE . STATUS SHEET DATE: 1--(17 (1~ ~ ACTIVITIES: Ua..LJ# .tl...,..I' L~ tHe..!:"" tl.u, (l~1 H~~:._;~. (. . (..... ./21.1 -, ,)3/", r. l<<h;'" .;>..,J,;r.~_ .. -"'~/:L\i" , C~ .. ......-.... . ~-.-.-. f'-w..-.,,,,....- - r Mr. Metz, Ms. Shearer, Attorney at Law and Mr. Fry, Defendant 17 December 1996 paqe 2 hearinq if he plans to be present to offer testiaony or to rebut or contradict the testiaony of the Plaintiff. very truly yours, E. Robert Elicker, II Divorce Master ',+r ~ ...r'-"_ - . SHERRY FRY. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNl'Y, PENNSYLVANIA v. : CIVIL ACTION . LAW : IN DIVORCE - - LARRY FRY, Defendant : NO. 96-5665 CIVIL TERM ~ AFFlDA vrr OF CONSENT .' 1. A Complaint in Divorce under 13301(c) of the Divorce Code was filed on October 15, 1996. 2. The marria&e of Plaintiff and Defendant is inetricvably broken and ninety (90) clays have elap-t 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. I verify that the Cl2lf'm1'ftts made in this affidavit are true and correct. I understand that false statements herein are made subject to the paWties of 18 Pa.C,S. 14904, ~l.ti"110 unsworn falsifacation to authorities. Date2-17. 'll - .A.~ . S1leny FryO b