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Home My WebLink About00-03936 ", . . ;,;, " .i'"" ,,',-, "'""" '" "- . . ... .. :Ii "" :Ii:+;~:+; :Ii :+;~:Ii:li~"" :+;:+; :+;:Ii ~:+;~~ . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . STATE OF . . . . ~HR'R'RT n 14''RVR . Plaintiff . . . . VERSUS . . PAUL E. FRYE III, PENNA. No. nn ,Q<':; ("IV!];' TERM Defendant . . . . DECREE IN DIVORCE e>1 3.''''df'lYI . . AND NOW,~ 3 , 2001 , IT IS ORDERED AND . . DECREED THAT AND SHERRI D. FRYE , PLAINTIFF, PAUL E. FRYE III , 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 . . . . . . . . ^,m~~ PROTHONOTARY . :Ii :Ii:+;:Ii :+; :Ii :+; .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . "','~ _ - ~~ w 1/. ~-ClI 1,/ #' CJ/ ", i:".1 '.,. ,. '. - < - - --". ," --" ~ ..",,", '-. - I L', "f ~~~'*4~~ w~~z~. ",.",., ".. ," ~'~ J!l\Ill!,IJt,~~"",,,':~ll!l1,~,,,,,,<.,~" l~~~ - '-.,'-'-", ";1'" .,,,,~ >.---~ '" -i<.__'- . __..~ "- J..__" '" "_- - ',-",':;". -" ';:""".' __ ,,'_~.;;: :~"-" -,' HAROLD S. IRWIN, III SUPREME COURT ID NO 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243.6090 SHERRI D. FRYE, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. . . = CIVIL ACTION - LAW PAUL E. FRYE, III, = NO. 00 - 3936 CIVIL TERM Defendant = IN DIVORCE PRAECIPE TO TRANSMIT RECORD Please 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) of the Divorce Code. 2. Date and manner of service of the complaint: On or about August 9, 2000, defendant was personally served with a copy of the divorce complaint. See Affidavit of Service filed by plaintiff's counsel. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: 1'4 ~tC<V- 2~ Z<>c'J I By the defendant: /l?<t.e.u.r 151 "2410 I (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: N/A; and (2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: 1'--lA-1C.L..t{ 7.-7 ~ 1 Date defendant's waiver or Notice in Section 3301 (c) Divorce was filed with the Prothonotary: ):1: /J-rc1." "V 7, V~ I ~/I /tJu-t- l?,. '&J <J I ../) ~ I ,"~., '" ",' " JlWij' ,,,",'" ~- ''''''''''"~''''''iiIl!.--l\...G:lI~~' _,.,,., ,w -~li '. ,""~""n"'0' ~~ ',"." ,-",-' , H'..=' " ,..",....'.. 0 C) C) c: '1 s: ::Jl: -oce :;:C;l;O , mn-: ::.u L.),' r,"" l;--'-i ~S;~ -.j ~ c;.~' -', , -<L c~:i~ r:::CJ ~ 3>() ~ ~~2 tS LCJ 6 -;::::~~m Pc: LJ "~,,-l L, ~ >- =< :JJ ():\ -< ." . -"".' ~<" .=" -"- = ~'C --"___,n/'-""""~__~' "" "," ,;',,,,~. '." ';,',"" .'-0,.; ~"., J"", HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAUL E. FRYE, III, : NO. 00 - 3'i 3(" CIVIL TERM Defendant : IN DIVORCE NOTICE 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 in 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 I , " " . ^ ~::' SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW PAUL E. FRYE, III, : NO. 00 - 3"J '3 (., CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 ~ OF THE DIVORCE CODE NOW, comes the plaintiff, Sherri D. Frye, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce, against the defendant, Paul E. Frye, III, representing as follows: 1. The plaintiff is Sherri D. Frye, an adult individual residing at 88 East Main Street, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Paul E. Frye, III, an adult individual residing at 2 Dranoel Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Both parties have been residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this action in divorce. 4. The parties were married on July 6, 1996, in Newville, Cumberland County, Pennsylvania. m -;.: ~ , --,. ,," ,- ,-' .,,',,~ 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers that the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. 7. There has been no prior action for divorce or annulment between the parties. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. June ~ ' 2000 S~~i~A;~$E ~)J!-, Plaintiff HAROLD S. IRWIN III Attorney for Plainti '" ~ " = - '..', ,> ,,'--~ '- ~,~ ~-) SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA y. : CIVIL ACTION - LAW PAUL E. FRYE, III, : NO. 00 - .3 93(.. CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 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 Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. June /(P,2000 ~hAfA{" YJ ~ S ERRI D. FRYElaintiff ~~ll'e~'~> ~ -~ .' h". "-' .... "<'~ ,- - ~'"'~Ji~'" ," ,.-., ", ^.' " o c ~.;: UCi if I r."t ~(~,: rr, ,', v."'", -<,~- f-- ,-- <'--.- ~ z:C) """,-. Pc -7 ~ c:; ,".'-, ,~,~ <"0 '" c..J --l'--'i CJ ')~~l (:;J,~~ ;:;.;:,~'n :';; :n -< ;1:-'" '-'J J'v (,,) ",--,1 ~~ ' . ,: ,'-"-'., ;-'Cj - ;' ' -,;'~ ~--j SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAUL E. FRYE, III, : INO. 00 - 3936 CIVIL TERM Defendant : UN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about June 23, 2000 and served personally upon defendant on or about August 9, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statement!> made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. /L1/J1l5:.u 'Z, <.. ~., I . ~ )h.,rA'A D. 1e< ft ~ERRID.FRYE "";,,(,;:;,,-~-,,,., ',- -,- , ",-".--~ '"'~'MIlilIlliiII ",'X,;"",,"'" "" -~ , " - "....."~.">'. ,,"' ,'~, >-,~"",,,..,'-'" (") f'''';.l 0 C .1 -7 ~';;o,. ::b -OW :,'~ ~~: rnm :;:'::'1 Z:I) -, ~~.: ;"'..) L. - CJ m -' '< ,'-, !;2 C :='" ~~_:l j> c; ~~ ~ .._~ ::::-c; "--- Pc. 0 0 Z j;1 -. '- :Il -< ,..) -<:. "- , .0 i(~t;:, SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAUL E. FRYE, III, : NO. 00 - 3936 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE )JNDER SECTION ~30~ OF THE DIVORC~ 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. MJlR...<:L./- U} G.-<>.. I ~. 0 1P~Z HERRI D. FRYE ~___>7_ -',dl,=- ","",.-" ;1 "'\"""",.' --~ ,'~' ,;",", " . -~.-~ ,~........" _.."Si,~".,,,,,,,., J ... l' .--~ ""'""'.'. (') c: S:-_ -oCP fllr,-., ~(~~' 01"7 r-:G Y-. '")7n 'bO .YC~ '7' :2 <.- c' -- ,-,., ~:;':,l ::'0 r-J .-, .'j -, _.'", 'cd~"~ '-c_,_"", ~ -.o' ? .-,c - - c:: "j;() ---,.' "-\, r~. ;~:~, (~ 'V- ~ :;:" t,) --' ~ ' - ~- , ' SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : : CIVIL ACTION - LAW PAUL E. FRYE, III, : NO. 00 - 3936 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRmAGE COUNSELING AFFIDAVIT 1. 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 Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. jI1/)lt...U-/- l<.) L.<HJ I ~Au; (Q 4' SHERRI 0: FRYE '- -,.,,,,;.,:,, ~- ~,,~;..;. ';0 '" ~'""'-~~+'''_,~. ililfifili~cd.:" -~~;:",,;;-;\;qj~<-.>,.>\', \--2.-;':""':;;" -.; ~- " 'Cd " " -.,,,,,," I 0 c::> 0 c " ;?' ::N: -003 >> Plf-;-, :::D ." ~s:' r0 ~]~ .....J "r' ~<....:::.. .__1-, U r:::: l::; :0,'" -r, ::c.. ..;::> C) ~ " , 20 a C~) rn );.">c ---I 2 J:'" ~ ,-< -< 4=- -< ',._' ,;< ,,_ ,"io>'" , - .'~ - ~,"",,<.' ~ ' ".'0 ~~. .'-"_,_l SHERRI D. FRYE, Plaintiff : UN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : CIVIL ACTION. LAW PAUL E. FRYE, III, : NO. 00 - 3936 CIVIL TERM Defendant : UN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1, A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on' or about June 23, 2000 and served personally upon defendant on August 9, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. ':J/!S-!Ol "';';~".,,> " , ~-'"" "" ~~ .wf ~,; "~,,,,,,,,,,,",,;, ,-, :;""~ __6';"_ ~_ __~ ,^" M, ~ " _." ~,__:l._," " '"~'"" "",,,,,;';." == ~~-, 0 C> 0 C --n ~ -I" -."'" ; ""OCC .J~ i ;:;;2 rnfT: ;.CI Z:::t! :'~\\23 :zr;; 0" ~z ("1 ' .'010 !<o :1:" ~~5I} ?2.0 :;1: :.-.c.{) -0 \R 6'" YC >4 Z ~ ~ 1(J'l . - ,".~,--' ".~ . '"", " -, ,',~"'-- SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW PAUL E. FRYE, III, : NO. 00 - 3936 CIVIL TERM Defendant : liN DIVORCE WAIVER OF IlIOTICE OF INTENTION TO REQUES! ENTRY OF A DIVORCE DECREE ""~ER SECTION 3i301{J;j OF TtlE DIVORCE CODE 1 . I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 5//10 I (") c ;;;: -0-0.:'1 rn o :Jl: ",. ;;0 o -n 'f? -l ii~;g ..-:::1!,,:n ..:00 ()...L '-'-I\~ :c-r-, r...) :!J ':70 cFTI ~ ~ ,..A.,i ZC -<(J) "c;: .c.::'., ,<c >'0 ~o Pc: :z: ~ 0" ",. ::Jl: Ul f;iii;~~--". ,",' ""iI".:- m'~' ~ """ Iii' , ~ , -- """,,ur,," """." "~ 'C,-~ __o,"'';'',;;'~~ , , , p '"" 0 <:;) 0 C .," s:: :JJ:: '-I -aD":1 :l:>. ;~~j;g nlrn ~1;J Z;:o '~i:JITI 2;;:' 0> :!;Jy en .,: "'-", -<'".,cO'_ ':::~O ~C') ~ ",,~ ..., ~-'-:):!J >0 ~ '~~'? C) 20 1.0 cjrn Pc: ;-:::! 2 :n =<! (J1 -< . ,L..;J '_ , '..~ . SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAUL E. FRYE, III, : NO. 00 - 3936 CIVIL TERM Defendant : iN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defenda_n,!. being duly sworn according to law, deposes and says: 1 . 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 Prothonotary's Office. which list is available to me upon request. 3. Bflil1g so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. () a 0 c '"f'l . ~!I f(o s: :::-;:: -ora """ I mrn -i1 ~- ,---. E, III ZC;::- ~Bt? ~5?: en ~:,:) (~~ !<,D ".. ~~~ ~8 :J:: )>c 'f? c5f'n Z --{ =< U1 5j -< ",;;,,;;' ",'. ~,' . ~-~~"~~~ ~, - , -",",. ~. ",', ,," , '''''""''#f~ .1I:~tilllIl'" ,~ ," '-., " v O"""'~J,,-iii~'o\" .._... i ,,,,.'-~- "" ,~~ "~-- ~ - " , () &; fl?iZ., ;<f7-; 13('" S f:'-,::;" "iff 6 ;;?:C) ;s:0 [.:: !j ,,0, "" e~ . " ... , c:; - o ,.', ;:tt .0.- "0 - 0, .'~};;P ".(-.f (j,[" ,J'-!'~~ 0:;],(5 rl') ;g -.;: """ ~ 1.0 .. - 0) ...',"~ <;':,' ill. . . , , HAROLD S. IRWIN, III ESQ. ATTORNEY ID NO. 82585 35 EA5T HIGH 5TREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF SHERRI D. FRYE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW PAUL E. FRYE, III, : NO. 00 - 3'93'- CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 C!ill1lill NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on August 9, 2000, at 12:15 p.m., by personal service at his place of employment, the YMCA, 311 South West Street, Carlisle, PA 17013. 3. That a copy of State Constable Irving Wallace's return of service is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. August 11, 2000 Harold S. I in, III Attorney for . ~' . , . -' l!, . , " . grvin!l Waflace :JJennsylvania C5lale Conslable .5 0asl Boul.l1er C5lreel CarlIsfe, !RJ/ 17013 Harold S. Irwin, III, Esq. 35 E. High Street Suites 201/202 carlisle, PA 17013 R~ Paul E. Frye III 2 Dranoel Drive Carlisle, PA 17013 REMARKS: S e r v e d P a u l E. Frye, II Ion 8 - 9 - 0 0 at 1 2 : 1 5 PM Documents were served at YMCA, 311 S. West Street, Carlisle, PA 17013 PLEASE REMIT FEE OF: $ 25.00 ))Jv~ Irving Wallace Pennsylvania State Constable 5 East Louther Street Carlisle, PA 17013 'Y.I1one 717-243-67U :JJa!ler 717-241-7.5.57 ::lax 717-243-7937 in,;;;, ,;, ""';' ' '\ r't: Dl( ..sa - ~iIlil ~c- .'" "'"'."''' ,'%<;';"1;'4'"-,,,' - ~,' '" ' ~ ,~ . .. - .'. '," , ,'"' c. (";,,,~ ' "",,,,,,,,,, ""'~"'! I . 0 0 0 c:: c:> -n s:: ?- --~t -UCO -- ~,Yi~ mrrl C;..., Z:-.O ,,;-m t.5~ ::Y? (Jr: C<., c-;i ;?, ~CJ -0 ',----n ?fa :z ~~ ;;;;2 r:-? 9. ~ r. :;p- C" ~ ,