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HomeMy WebLinkAbout02-5891JONATHAN T. FENDER, Plaintiff, ROBIN A. FENDER, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. .. : CIVIL ACTION - 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. Your 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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 OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 JONATHAN T. FENDER, Plaintiff, ROBIN A. FENDER, Defendant. : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. ~),2 ~ ; ; : CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301 {C} OF THE DIVORCE CODE COUNTI 1. Plaintiff is Jonathan T. Fender, who currently resides at 4406 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Robin A. Fender, who currently resides at 1020 Morris Ave., Lakewood, Ocean County, New Jersey. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 12, 1978 in Colony, New York. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301(c) of the Divorce Code. COUNT II--EQUITABLE DISTRIBUTION 9. The Plaintiffincorporates by reference Paragraphs I through 8 of the Complaint for Divorce as fully set forth herein. 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1980, as will be fully set forth in the Plaintiffs Inventory and Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure. 11. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. COUNT III--CUSTODY 12. The Plaintiff incorporates by reference Paragraphs 1 through 11 of the Complaint for Divorce as fully set forth herein. 13. There was one(l) child bom during this marriage, to wit: Joshua Fender, born 6/23/1987. 14~ During the past five (5) years, the child has resided with the following persons and at the following addresses: Person(s) Robin A. Fender Jonathan T. Fender & Robin A. Fender Jonathan T. Fender & Robin A. Fender Address 1020 Morris Ave. Lakewood, NJ 08701 4406 Chestnut St. Camp Hill, PA 17011 1020 Morris Ave. Lakewood, NJ 08701 Dates Sept. 2002 - present Nov. 2000 - Sept. 2002 1997 - Nov. 2000 15. The Court of Common Pleas of Cumberland County, Pennsylvania, Family Division, has the sole and exclusive jurisdiction in this matter, pursuant to the Uniform Child Custody Jurisdiction Act, and the Commonwealth Child Custody Jurisdiction Act for the following reasons: a) Cumberland County, Pennsylvania, has been the child's home county within six (6) months before the commencement of the instant proceedings. b) It is in the best interest and welfare of the child that the Court of Common Pleas of Cumberland County, Pennsylvania, assume jurisdiction because the child has a significant connection with this jurisdiction, and there is available in this jurisdiction substantial evidence concerning the child's present or future care, protection, training and personal relationships. c) No other state has jurisdiction in this matter under the requirements of the Uniform Child Custody Jurisdiction Act and the Commonwealth Child Custody Jurisdiction Act. 16. 17. 18. The Plaintiffhas not participated in any capacity whatsoever in any other litigation concerning the custody of the minor child in this or any other state. The Plaintiff does not know if any other person than the Defendant herein claims to have custody or partial custody rights with the minor child. The Plaintiff submits that it is in the best interest and welfare of the child that the Plaintiff be granted custody of the child, and that the Plaintiff can best provide the minor child with a more stable, healthful, religious, and proper environment. WHEREFORE, Plaintiff prays that the Honorable Court grant custody of the minor child of the Parties to Plaintiff. Respectfully submitted, Date: ROBINSON & GERALDO Gerald S. Robinson,---7'Esquire Attorney I.D. #27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff VERIFICATION I verigy that the statements made in this Complaint 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 £alsification to authorities. Jo~5~than T. Fender JONATHAN T. FENDER, Plaintiff, ROBIN A. FENDER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - IN DIVORCE CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the~'-'day of December, 2002, I caused a tree and correct copy of the Complaint for Divorce to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Robin A. Fender 1020 Morris Ave. Lakewood, NJ 08701 Respectfully submitted, ROBINS~ & GERA~_~ By: ~ Q.~d S. Robinson, E~uire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 JONATHAN T. FENDER Plaintiff, ROBIN A. FENDER, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02-5891-Civil : CIVIL ACTION -- IN DIVORCE PROOF OF SERVICE The undersigned makes the fbi.lowing return of service: the Complaint in Divorce was served upon Robin A. Fender, tb,~ Defendant, on December 18, 2002 at 1020 Moms Avenue, Lakewood, Ocean County, Pennsylvania. The signed receipt is attached as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to . this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Dated: I?_.-zq-c>Z_ By: Respectfully submitted, ROBINSON & GERALDO Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for' Plaintiff · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. N Pdnt your name and address on the reverse so that we can return the card to you. · Attach thi~ card to the back of the mailplece, or on the front if space permits. w~ed by t/=$esse Print B. Date of Delivery [] t~:ldmes~ D. Is delivery address different from item 17 [] Yes If YEs, enter delivery address below: [] No · Restricted Delivery? (Extra Fee) ,~yes 2. Article Nu. rr~-~.., 7001 1940 0004 1686 6751 PS Form 3811, Mamh 2001 ~ Return Rer~ipt 102595-01-M-1424 [].~press Mail [] Registered ~[~Retum Receipt for Merchandise [] Insured Mail [] C.O.D. JONATHAN T. FENDER, Plaintiff, V. ROBIN A. FENDER, Defendant. : IN THE COURT (:IF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02-5891 CV : : : CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce trader 3301 (c)ofthe Divorce code was filed on December 10, 2002, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed fi.om the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities~ Date: ~o~a~ ,~ ~o5 Jl~na-than T. Fender JONATHAN T. FENDER Plaintiff ROBIN A. FENDER Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.02-5891 CV CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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. §4904 relating to unsworn falsification to authorities. Date: /73 Jonathan T. Fender, Plaintiff JONATHAN T. FENDER, Plaintiff, V. ROBIN A. FENDER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-5891 CV CIVIL ACTION - LAW IN D1VORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under the Divorce code was filed on December 10, 2002, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: Robin A. Fender JONATHAN T. FENDER Plaintiff ROBIN A. FENDER Defendant. IN THE COURT ,OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.02-5891 CV : CIVIL ACTION -. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divome decree is entered by the Court and that a copy of the decree will be sent to me immediately after it iis 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. §4904 relating to unsworn falsification to authorities. Date: Robin A. Fender, Defendant JONATHAN T. FENDER, Plaintiff, ROBIN A. FENDER, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02 - 5891 Civil _. : CIVIL ACTION - IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~'.3 day of ~.~Oc_~ ¥ 200~, by and between / Jonathan T. Fender, of Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Husband," and Robin A. Fender, of Lakewood, Ocean County, New Jersey, hereinafter referred to as "Wife." WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 12, 1978; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of each other; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to Jonathan T. Fender by his respective counsel, Gerald Robinson, and Robin A. Fender has been advised of her right to seek independent legal advice from counsel of her choice. The Parties acknowledge that they have received independent legal advice from counsel of their selection or have had the opportunity to receive independent legal advice from counsel and that they fully understand the facts and have been informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstance fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 2. SEPARATION. It shall be lawful for each Party at all times hereafter to continue to live separate and apart from the other Party. The foregoing provisions shall not be taken as an admission on the part of either Party of the lawfulness or unlawfulness of the causes leading to their living apart. 3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The Parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be 2 entered with respect to them at the request of either Party. The Parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania, shall retain continuing jurisdiction over the Parties and the Agreement for the purposes of enfomement of any of the provisions thereof. The Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the Parties, although this Agreement shall be incorporated into said Decree, this Agreement shall not merge with, but shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the Parties and may be enforced in an action independent of the Divorce Decree. The Parties agree and it is the intent of each of them that even though this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent of the Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code, the provisions of this Agreement regarding the disposition of existing property rights and interests betwean the Parties, alimony, alimony pendente lite, counsel fees and expenses shall not be subject to modification by any Court. 4. SUBSEQUENT DIVORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section3303(c) of the Pennsylvania Divorce Code. 5. INTERFERENCE. Each Party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither Party shall molest the other or attempt to molest 3 the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 6. WIFE'S DEBTS. Husband shall assume and make payments on Wife's current student loans, current car payments and current credit card bills. Wife represents and warrants to Husband that she will not contract or incur any future debt or liability for which Husband or his estate might be responsible and she shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of any future debts or obligations incurred by her. 7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that he will not contract or incur any debts or liability for which Wife or her estate might be responsible, and he shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party has released and discharged, and by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the Parties had or now has against the other, except fi~r any and all causes of action for divorce and except for any and all causes of action for breach ,of any provisions of this Agreement. 4 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the Parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the Parties and, further, that the Husband and Wife voluntarily and intelligently agree to waive any fights which they may have to receive an Inventory and Appraisement of all property owned or possessed by them, either jointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. 10. EQUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors that have been taken into consideration by the Parties. a. REAL PROPERTY. The Parties acknowledge thai: Husband and Wife have a legal interest in a house located at 4406 Chestnut Street, Camp Hill, Pennsylvania. Wife shall relinquish all interest she has in the house. Husband shall assume sole financial responsibility for the costs associated with the home, including but not limited to the lease, insurance and utilities associated with the upkeep of the house. The Parties also acknowledge that Husband and Wife have a legal interest in rental property located at 1020 Morris Avenue, Lakewood, New Jersey. Wife shall relinquish all interest she has in the house on Morris Avenue. Husband shall assume sole financial responsibility for the costs associated with the home, including but not limited to mortgages, taxes, insurance, utilities, repairs and improvements associated with the upkeep. Husband shall indemnify Wife and hold her harmless for any claim made against him relative to the rental property. Upon retirement or at an earlier date agreed to by the Husband and Wife, the property will be appraised and sold. All proceeds from the sale of the Morris Avenue property shall be divided 50/50 between the parties. b. PERSONAL PROPERTY. The Parties have divided between themselves, to their mutual satisfaction, all items of tangible, personal property previously used by them in the marital home. Neither Party shall make any claim to any such item of tangible personal property whether said items are marital property or said items are separate personal property of either Party. c. ALIMONY. Husband shall pay to Wife Four Hundred ($400.00) Dollars each month, beginning April 5, 2004 and ending at the time of Husband's retirement. d. RETIREMENT. At the time that Husband retires, Wife shall receive 50% ora calculated amount of Husband's retirement. The amount shall be calculated as 1% of the Average of Husband's three highest pay years multiplied by 20 years. 11. ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES. Both Parties accept the provisions of this Agreement in lieu of and as full and final settlement and satisfaction of all claims and demands that they may now or hereafter have against the other for alimony, alimony pendente lite, counsel fees or expenses, or for any other provision for support and maintenance before, during or after the commencement of any proceedings for the divorce or annulment between the Parties. 12. CUSTODY. It is the intention of the parties, and the parties agree, to share joint legal custody of the minor child with Husband having primary physical custody of the minor child and 6 Wife having partial physical custody as the parties mutually agree. With regard to any emergency decision~ which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated by the emergency. However, that parent shall inform the other parent of the emergency and consult with him or her regarding the emergency as soon as practicable. 13. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise provided, each Party may dispose of his or her property in any way, and each Party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy, right to take against the will of the other's estate, and who will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 14. 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 advisable to him or her, and the Party breaching this Contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 7 15. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the Panics and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 16. MODIFICATION AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either Party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 17. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the fights or obligations of the Parties. 18. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 19. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 20. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both Parties and each Party acknowledges 8 that this Agreement is in all respects fair and equitable, that il: is being entered into voluntarily and knowingly, and that it is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF, the Parties have hereunto set their hands and seals the day and year first above written. Gerald S. Robinson, Esquire Witness J~athan T. Fender, Plaintiff (SEAL) Robin A. Fender, Defendant 9 JONATHAN T. FENDER, Plaintiff, V. ROBIN A. FENDER, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5891 CV : : CIVIL ACTION--LAW IN DIVORCE .PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the 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: First Class Mail on or about December 6, 2002. 3. Date of execution of the affidavit required by section 3301(c) of the Divorce Code: by Plaintiff on June 2, 2003 and by Defendant on June 19, 2003. 4. Related claims pending. The economic claims have been settled by agreement. 5. Date the Plaintiffs waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: June 4, 2003. 6. Date the Defendant's Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: June 24, 2003 Respectfully submitted, ROBINSON & GERALDO By Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 532(} Harrisburg, Pe~msylvania 17110 (717) 232-8525; Attorney for Plaintiff. IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE Of ~~~, PENNA. ,Tmnm~hmm T. Fender, Plaintiff, VERSUS 2obln A. Fender, NO. ~I2-5891 CV DECREE IN DECREED THAT ~ W~'n~l'~F __, PLAINTIFF, aND Robin A. Fender , 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; + + + ++ + + + + + +