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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
. VIRGINIA D. FAKE,
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No. 2000-1227
Plaintiff
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VERSUS
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MARK A. FAKE,
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Defendant
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DECREE IN
DIVORCE
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2000
, IT IS ORDERED AND
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AND NOW,
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VIRGINIA D. FAKE
, PLAINTIFF,
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DECREED THAT
AND
MARK A. FAKE
, DEFENDANT,
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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 BEEN ENTERED;
All matters have been resolved pursuant to the Marital Settlement
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Agreement dated September 28, 2000 shall be incorporated but:not
merged into this Divorce Decree.
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By THE COURT: 4
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PROTHONOTARY
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made thiVl1!lday of 'I.\...~ m~ ,2000, by and
between MARK A. FAKE, hereinafter referred to as "HUSBAND", and VIRGINIAD. FAKE,
hereinafter referred to as "WIFE".
WITNESSETH, That:
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in
marriage on September 19, 1992, in Mechanicsburg, Cumberland 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 ofthe 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 ofthe 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 goocLand 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:
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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 Diane Sommers Baker,
Esquire. Each party further declares 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. PERSONAL RIGHTS
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 if 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 m~ select. Each may,
for his or her separate use or benefit, conduct, carry on 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 or 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.
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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, 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. To the best of the
parties' knowledge, the parties affirm no joint debts exist.
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, jewelry, clothes, furniture, and
other assets wherever situated whether real, personal or mixed, tangible or intangible, and
HUSBAND agrees that all assets, with the exception of those items listed on Exhibit "A", 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, together with those item listed on Exhibit "A", shall be
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the sole and separate property of HUSBAND.
Each of the parties do 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. REALESTATE
The parties own property as tenants by the entireties located at 206 Reno Street, New
Cumberland, Pennsylvania which is subject to a mortgage with PNC Ballie The approximate
balance of said mortgage is FIFTY-ONE THOUSAND DOLLARS ($51,000.00). Pursuant to
HUSBAND's bankruptcy proceedings, he was released from the PNC Bank Mortgage.
HUSBAND agrees to convey all his rights, title and interests in this real estate to WIFE.
WIFE shall be responsible for the payment of the unpaid balance of the mortgage, together with
any interest, penalties and costs, as well as any other taxes, insurance and any debts associated
with the real estate. WIFE hereby agrees to indemnify and hold HUSBAND hann1ess from any
and all liability as a result of non-payment of the mortgage or any other debt associated with the
real estate by her. HUSBAND agrees to execute a deed simultaneously with the execution of this
Agreement wherein he assigns, conveys and transfers to WIFE all of his interest, right and title in
the marital residence.
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7. MOTOR VEmCLES
WIFE shall have sole title and ownership of the parties' 1997 Mitsubishi Galant. This
vehicle is leased in WIFE's name alone. WIFE shall be solely responsible for said lease and
agrees to indemnify and hold HUSBAND harmless from this obligation. HUSBAND shall have
sole title and ownership of the parties' 1989 Chevy Truck. This truck is not encumbered.
8, PENSION
Each party hereby waives any and all claims that he or she may have against the other to
any pension, employee saving or other stock benefit program of the other, if applicable.
9. BANK ACCOUNTS. INVESTMENTS AND LIFE INSURANCE
Each party shall have sole possession of the bank accounts, investments and life insurance
in their own names.
10. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CLAIMS
CONFERRED BY THE PENNSYL VANIA DIVORCE ACT OF 1980. AS
AMENDED
HUSBAND and WIFE acknowledge and agree that the provisions of this Agreement are
fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in
this Agreement in lieu of and in full and final settlement and satisfaction of lIll claims and demands
that either may now or hereafter have against the other for equitable distribution, alimony,
alimony pendente lite, counsel fees, costs and expenses or other provisions for their support and
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maintenance before, during and after the commencement of any proceeding for divorce or
annulment between the parties.
11. AFTER ACOUIRED PERSONAL PROPERTY/FUTURE EARNINGS
Each of the parties shall hereafter own and enjoy independently of any claim or right of the
other, all items of personal property, tangible or intangible, hereafter acquired by HUSBAND or
WIFE, with full power in him or her to dispose of the same as fully and effectively, in all respects
and for all purposes, as though he or she were unmarried.
12. 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 relinquish any right to seek from the
other any payment for spousal support, alimony and maintenance.
13. TAX RETURNS
The parties agree that, in the future, if any penalties or interest or any liability for failure to
declare income or the wrongful claiming of any deduction shall be assessedoy the United States
Internal Revenue Service or the Commonwealth of Pennsylvania, or any other state as a
consequence of the parties' Federal and State income tax returns which were filed jointly by the
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parties, said tax, penalties or interest shall be paid and solely attributable to the party who failed to
provide the required information. The responsible party agrees to hold the other party harmless
from any penalty, interest or liability assessed or any attorney fees, costs or expenses necessary to
defend themselves from said action.
14. SUBSEOUENT 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. Both parties agree to enter a Consent
Decree concerning the provisions of this Agreement in the Court of Common Pleas of
Cumberland County, Pennsylvania, 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 N 0- Fault
Divorce as may be required by the Divorce Code of 1980, as amended. Both parties hereto agree
that this Agreement may be incorporated for purposes of enforcement into a separate Court Order
but shall not merge in such order in the Court of Common Pleas of Cumberland County,
Pennsylvania.
15. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
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forthwith execute and deliver to the other party, any and all written instruments, assignments,
releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the
proper effectuation ofthis Agreement.
16, 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.
17. 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 oragainst the estate of
such other, of whatever nature and wheresoever situate, 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 curtesy, or claims in the nature of dower or curtesy 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
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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 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 ofthe 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 covenahts and agrees for himself and herself and his or
her heirs, executors, administrators and assigns, that he or she will never, at any time hereafter,
sue the other party or his or her heirs, executors, 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 and allow
administration upon his or her personal, real or mixed estate and allow effegs to be taken out by
the person or persons who would have been entitled to do so had HUSBAND or WIFE died
during the lifetime of the other. 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 ofthis
Marital 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 no~ owns or may
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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
18. SUCCESSOR'S RIGHTS AND LIABILITIES
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit of the parties hereto, their respective heirs, executors, administrators, successors or
assIgns.
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 or invalidated in any way.
20. ENTIRE AGREEMENT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
21. BINDING EFFECT OF AGREEMENT/WAIVER
This Agreement shall remain in full force and effect unless and until terminated under and
it:
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pursuant to the terms of this Agreement. The failure of either party to insist upon strict
performance of the provisions ofthis 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.
22. 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.
23. CONTROLLING LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
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24. CONDffiON PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS
The parties acknowledge that this Agreement shall become effective when actually signed
by both parties.
WITNESS
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MARK A. FAKE
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COMMONWEALTH OF PENNSYL VANIA
COUNTY OF J>" ,,/),/-1
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared MARK A. FAKE, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
scribed to before me this Z"L day of ~t-, 2000.
M commissimrrelllpimsa
DlA~.!E l$. ~1{;:~, t'~::~rr P'~};~;:
Low~ Pu.:.ron v'ttp.~ [.1c;;;..;:..1.'J Cu~F.~
My Commiosian ~ ~ 10. :ma
(SEAL)
COMMONWEALTH OF PENNSYL VANIA
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COUNTY OF L.IJ-mb.trlo..rd
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared VIRGINIA D. FAKE, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief
ed and subscribed to before me this~~ day ~2000.
NOTARY PUBLIC
My commission expires:
(SEAL)
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8lIIIIaIa SIllllllllallulll.BI.1Ill\lIy AdD
New Q/lmIl8Il8Ad BaR:>, ~lb.,1Mil CounIy
Camrnlssion EJcpiI8S November 15,
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EXHIBIT A
HUSBAND'S PERSONALTY
1. Family Pictures and albums
2. Ramps for loading and unloading
3. Fishing Rods
4. Tackle Boxes
5. Cameras (35mm and instant)
6. RCA 31" Television
7. Tools
8. Sleeping Bags
9. Clothing/personal items
10. Air Conditioner
11. Radio (old)
12. Led Zeplin picture
13. Wood cutting board (made in school)
14. Panasonic walkman
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VIRGINIA D. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-1227
MARK A. FAKE,
Defendant
IN DIVORCE
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 ~3301(c) ofthe Divorce Code.
2. Date and manner of service of the complaint: United States Mail, Certified Mail,
Restricted Delivery on March 6, 2000.
3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce
Code: by Plaintiff: September 28,2000; by Defendant: September 22,2000.
4. Related claims pending: All matters have been resolved pursuant to a Marital
Settlement Agreement reached by the parties dated September 28, 2000 and incorporated,
but not merged iuto the Decree.
5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with Prothonotary:
October 10, 2000. Date Defendant's Waiver of Notice in ~3301 Divorce was filed with
Prothonotary: October 10, 2000.
Dated: October 9,2000
Barbara Sump Ie-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ill #32317
Attorney for Plaintiff
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VIRGINIA D. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-1227
MARK A. FAKE,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy of the foregoing Plaintiff's Praecipe to Transmit Record, in the above-
captioned matter upon the following individual by first class mail, postage prepaid, addressed
as follows:
Diane Sommers Baker, Esquire
P.O. Box 6443
27 South Arlene Street
Harrisburg, PA 17112-0443
Barbara Sump1e-Sullivan, squire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
DATED: October 9,2000
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VIRGINIAD. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
· NO. JlfX)- \6.8.1 Gw.QTE'r\fY1
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so the
case may proceed without you and a decree of divorce or annulment may be entered against you
by the Court. A judgement 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 and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LmERTY AVENUE
Carlisle, Pennsylvania 17013
(717) 249-3166
VIRGINIAD. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. Jooo- Iddf ~T0\fY\
CIVIL ACTION - LAW
IN DIVORCE
MARK A. FAKE,
Defendant
AFFIDAVIT REGARDING COUNSELING
1. I have been advised of the availability of marriage counseling and understand that I
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
Relations 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
participate 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 Pa. C.S.A
Section 4904 relating to unsworn falsification to authorities.
Dated: 3J-,)cJtfO
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Virginia D. Fake
VIRGINIAD. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: NO. (Jrxx)- /J..di
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is VIRGINIAD. FAKE, an adult individual residing at 206 Reno Street, New
Cumberland, Pennsylvania 17070.
2. Defendant is MARK A. FAKE, an adult individual residing at 568 Magaro Road,
Enola, Pennsylvania 17025.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on September 19, 1992 in Cumberland
County, Pennsylvania.
5.
There are no minor children born of this marriage.
6.
The parties separated on August 7, 1999.
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7. There have been no prior actions for divorce or annulment between the parties.
8. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940
and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAULT
10. The averments in paragraphs 1 through 9, inclusive, of Plaintiff's Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with
S 3301 of the Pennsylvania Divorce Code.
INDIGNITIES
12. The averments in paragraphs 1 through 11, inclusive of Plaintiff's Complaint are
incorporated herein by reference thereto.
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13. Plaintiff is the innocent and injured party, and Defendant has offered such indignities
to the person of the Plaintiff and has been physically and mentally cruel to her so as to make her life
burdensome and her condition intolerable, in violation of the marriage vows and of the laws of the
Commonwealth.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with
the Pennsylvania Divorce Code.
COUNT IT
EOUITABLE DISTRIBUTION
14. The averments in paragraphs 1 through 13 of Plaintiffs Complaint are incorporated
herein by reference thereto.
15. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties in such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance
with Section 40 1 (d) of the Pennsylvania Divorce Code.
COUNT ill
SUPPORT. ALIMONY PENDENTE LITE AND ALIMONY
16. The averments in paragraphs 1 through 15, inclusive, of Plaintiffs Complaint are
3
incorporated herein by reference thereto.
17. Plaintiff requires reasonable support to adequately sustain herself with the standard
ofliving established during the marriage.
WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite.
COUNT IV
ATTORNEY'S FEES AND COSTS
18. The averments in paragraphs 1 through 17, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
19. Plaintiff is unable to sustain herself during the course of this litigation and has
employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses.
WHEREFORE, Plaintiff requests an award of counsel's fees and expenses.
WHEREFORE, Plaintiff, Virginia D. Fake, prays this Honorable Court to enter judgment:
A. Awarding Plaintiff a decree in divorce;
B. Awarding Plaintiff support, alimony and alimony pendente lite;
c. Awarding Plaintiff counsel fees, costs and expenses;
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D. Equitably distributing the marital property; and
E. Awarding other relief as the Court deems just
rbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, P A 17070-1931
(717) 774-1445
Supreme Court J.D. No. 32317
Dated: March 3, 2000
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VIRGINIAD. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO.
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I, Virginia D. Fake, hereby certuy that the facts set forth in the foregoing COMPLAINT
IN DIVORCE are true and correct to the best of my knowledge, information and belief I
understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section
4904 relating to unsworn falsification to authorities.
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VIRGINIAD. FAKE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-1227
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 3, 2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service 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 I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
5. I verilY that the statements made in this affidavit are true and correct. I understand
that false statements are made subject to the penalties of18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
DATE: ~/cJO
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VIRGINIA D. FAKE
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VIRGINIAD. FAKE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-1227
MARK A. FAKE,
Defendant
CIVll. ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 3, 2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service 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 I may lose rights concerning alimony, division of property,
lawyer's fees or expenses in do not claim them before a divorce is granted.
5. I verifY that the statements made in this affidavit are true and correct. I understand
that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
DATE: q-~-Oo
1Y\a,L 1L?!d
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO: 2000-1227
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) 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! 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.
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Plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA.
v.
: NO: 2000-1227
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) 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! 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. 94904 relating to unsworn
falsification to authorities.
DATE: q-~-oo
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VIRGINIAD. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2000 - 1227
MARK A. FAKE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the
Complaint In Divorce in the above-captioned matter by United States Mail, Restricted
Delivery, Certified No. P 377 421 194, Return Receipt Requested, on the above-named
Defendant, Mark A. Fake, on March 6, 2000, at Defendant's last known address: 568
Magaro Road, Enola, PA 17025. The original receipt and return receipt card are attached
hereto as Exhibit "A".
I hereby certify that the facts set forth above are true and correct to the best of my
knowledge, information and belief. I understand that any false statements made herein are
subject to penalties of 18 Pa. C.S.A. S4904 relating to unsworn falsification to authorities.
Dated: March 9, 2000
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
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Mr. Mark A. Fake
S1ree1& Number
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Post Ofi,ice, Sta1e~ ZIP Code
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EXHIBIT "A"
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VIRGINIA D. FAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Civil Action - Law
MARKA. FAKE,
Defendant
NO. 2000-1227
In Divorce
NOTICE OF INTENTION TO RESUME PRIOR NAME
NOTICE is hereby given that Plaintiff in the above-captioned matter, having been
granted a final decree in divorce on the 18th day of October, 2000, hereby intends to resume and
hereafter use the previous name of Virginia D. Brooks and gives this written notice avowing her
intention in accordance with the provisions of the Act of 54 Pa. C.S. g704.
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TO BE KNOWN AS:
Virginia D. Brooks
COMMONWEALTH OF PENNSYLVANIA
;SS. /8'7- D~-78~1
COUNTY OF CUMBERLAND
On this, the o? r/-t day of od.o-/~ , 2000, before me, a Notary
Public, the undersigned officer, personally appeared Virginia D. Fake, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the foregoing Notice ofIntention to Resume Prior Name for the
purposes contained therein.
TNESS WHEREOF, I hereunto set my hand and official seal.
'NOTARY PUBLIC
My Commission Expires:
NolBIlal8eal
Ba1baIa Sumple-SulllvaA, NoIIIfy PublIc
QtilllboldaJld Boro, CumberIarid County
CommIssIon ExpiI8s NlMmber 16, 2003
(SEAL)
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