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~! IN THE COURT OF COMMON PLEAS 8
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:.:';1 OF CUMBERL-;,ND COUNTY ;
~' STATE OF ~. PENNA. ~
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Barbara Ann Mummert
, N 1l...5..9.9.9............. .............,. 19 97 8
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,Salvatore Roberto, ,Jr,.,
Defendant
DECREE IN
DIVORCE
AND NOW, . , .~~ ' . ~2. . .. " 19,1:1.1", It Is ordered and
decreed that ..~~~~~~~ .~~~ ,~~~~':~~............,',............., plaintiff,
and...., ...,.. Sa~Y~H~.r~, !l-.o~.e.r.t~... J.t',...", ., " ... '" .". ."" 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;
1'/.0111:... . rh.e. Mlld,t/l.l. S.e,t,tl.ement. Agr.ee.ment. .t.he ,pa~t.1es .executed .on ,Octobe.. .28,
~Pjlll. be. .111,cprp.orllt.ed. he,r,e.U\.. h,ut. ,ahall.not ,be ,me~g.e )nto ,aaid .D8cr8e. " .
AII..I:
Prothonotary
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C:IOFFICEIWPWINIWPOOCSIDOMEptW.SA'MUMMERT WPO
Oclober 28, 1997
..
,.....
THIS AGREEMENT, made this 28th day of October, 1997, by and between
BARBARA ANN MUMMERT, of 3952 Brookridge Drive, Mechanicsburg,
Cumberland County, Pennsylvania, 17055 (hereinafter "WIFE") and SALVATORE
ROBERTO, JR., of 3952 Brookridge Drive, Mechanicsburg, Cumberland County,
Pennsylvania, 17055 (hereinafter "HUSBAND");
WIT N E SSE T H:
WHBREAS, the parties hereto were married on May 7, 1983, in Mechanicsburg,
Pennsylvania; and
WHEREAS, there are two children born of this marriage, namely Katharine
Evelyn Roberto, date of birth November 7, 1988; and Nicholas Frederick Roberto, date
of birth August 21, 1991; and
WHEREAS, difficulties have arisen between the parties and it is therefore their
intention to live separate and apart for the l'est of their lives and the parties are
desirous of settling complete the economic and other rights and obligations between
each other, including, but not limited to: the equitable distribution of the marital
property; past, present and future support; alimony, alimony pendente lite; and, in
general, any and all other claims and possible claims by one against the other or
against their respective estates; and
Page 1 of 14
C; IOFFICEIWPWINIWPOOCSIOOME ....'f'MSA \MUMME R T WPO
October 28, 11l1l7
..
,-..,
NOW THEREFORE. in consideration of the covenants and promises
hl:'reinafter to be kept and performed by each party and intendillg to be legally bound
hereby. the parties do hereby agree as follows:
1. ADVICE OF COUNSEL.
The provisions of this agreement and their legal effect have been fully
explained to the parties by their respective counsel. WIFE is represented by Debra
Denison Cantor, Esquire, and HUSBAND is unrepresented, HUSBAND is cognizant
of his right to legal representation and declares that it is his express voluntary and
knowing intention not to avail himself of his right to counsel and chooses instead to
represent himself with respect to the preparation and execution of this Agreement.
The parties further declare that each is executing the Agreement freely
and voluntarily having either obtained sufficient knowledge and disclosure of their
respective legal rights and obligations or, if counsel has not been consulted, expressly
waiving the right to obtain such knowledge. The parties each acknowledge that this
Agreement is fail' and equitable and is not the result of any fraud. coercion, duress,
undue influence or collusion,
Page 2 of 14
C,\QFFICEIWPWINIWPDOCSIlJUMI; '""'f IMSA IMUMMERT WPD
October 28, 1997
fi#""'\4
2. DIVORCE ACTION.
An action seeking the dissolution of the marriage shall be tiled by WIFE
at the Cumberland County COU1't of Common Pleas, The parties hereby agree to
execute Affidavits of Consent for divorce and Waivers of Notice of Intention to Request
Entry of a Divorce Decree, The parties acknowledge the availability of counseling and
both parties have waived their right to counseling. The terms of this Agreement shall
be incorporated into any divorce decree, but shall not be merged with the divorce
decree, The parties agree that the divorce will be finalized no earlier than November
1, 1998, except upon consent of the parties,
3, SEPARATION AND NONINTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter,live separate
and apart. They shall be free from any interference, direct or indirect, by the other in
all respects as fully as if they were unmarried, Each may, for his or her separate use
or benefit, conduct, carryon and engage in any business, occupation, profession or
employment which to him or her may seem advisable, WIFE and HUSBAND shall not
harass, disturb or malign each other or the respective families of each other.
4, DATE OF EXECUTION.
The "date of execution" or "execution date" of this Agreement shall be
defined as the date upon which it is executed by the parties if they have each executed
Page 3 of 14
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C IClFFICEIWPWINIWPDOCSIDOMFr 'V'MSA"MUMMERT WPD
Ocl_ 28, Illll7
t""'\~
the Agreement on the same date. Othel'wise. the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
II. MUTUAL RELEASES.
Each party absolutely and unconditionally releases the other and the
estate of the other from any and all rights and obligations which either may have for
past, present, or future obligations, arising out of the marital relationship or otherwise,
including all rights and benefits under the Pennsylvania Divorce Code of 1980, and
amendments,
Each party absolutely and unconditionally releases the other and his or
her heirs, executors and estate from any claims arising by virtue of the marital
relationship of the parties, The above release shall be effective whether such claims
arise by way of widow's or widower's rights, family exemption, or under the intestate
laws, or the right to take against the spouse's will, or the right to treat a lifetime
conveyance by the other as testamentary, 01' all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under the laws of
Pennsylvania, any state, Commonwealth, or territory of the United States, or any other
country.
Except for any cause of action for divorce which either party may have or
claim to have, each party gives to the other by the execution of this Agreement an
Page 4 of 14
C;IOFFICEIWPWINIWPDOC S\06ME. ".-<; fMSA 'MUMMERT WPD
0<101>0,28, 11l1i7
,....,.
absolute and unconditional release from all claims whatsoever, in law or in equity
which either party now has against the other.
6, WARRANTY OF DISCLOSURE.
Each party hereby confirms that he 01' she fully understands the terms,
conditions and provisions hereof and believes same to be fair, just, adequate and
reasonable under the existing facts and circumstances, The parties acknowledge their
respective rights pursue-nt to the Pennsylvania Divorce Code of 1980 to obtain formal
valuation9 and appraisals and to engage in formal discovel'Y, including interrogatories.
The parties have detennined that they will not undertake this expense and rely on the
disclosures thus given,
7, OTHER DOCUMENTATION.
Within ten (10) days after demand therefore, the parties will execute any
and all written instruments. assignments, releases, satisfactions, deeds, notes or such
other writings as may be reasonable. necessary or desirable for the property
effectuation of this Agreement.
8. NO WAIVER OF DEFAULT.
This Agreement shall remain in full force and effect unless terminated
under the terms of this Agreement. The failure of either party to insist upon strict
Page 5 of 14
,
C;\OFFIC E IWPWINIWPDOC SIOOME' ...,IMSA \MUMMERT WPD
October 28, 1997 '
,-, #
perfomlance of any of the provisions of this Agreement shall in no way affect the right
j.
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of such party thereafter to enforce the same, nor shall the waiver of any breach of any
,
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provision hereof be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be consh'ued as a waiver of strict performance of any other
obligations herein.
9. ATTORNEYS' FEES FOR ENFORCEMENT.
In the event that either party breaches any provision of this Agreement
and the other party retains counsel to assist in enforcing the terms thereof, the
breaching party will pay all reasonable attorneys' fees, court costs and expenses
(including interest and travel costs, if applicable) which are incurred by the other party
in enforcing the Agreement, whether enforcement is ultimately achieved by litigation
or by amicable resolution. It is the specific Agreement and intent of the parties that
a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses
and reasonable counsel fees incurred by the non breaching party in protecting and
enforcing his or her rights under this Agreement.
10, PERSONAL PROPERTY.
HUSBAND and WIFE wiII divide the personal property as agreed upon
by the parties,
Notwithstanding the above, WIFE shall keep all appliances,
Page 6 of 14
C:IOFFICEIWPWINIWPDOCSIOOME """'YiMSA iMUMMERT, WPD
Oclober 20, 1997
,.....,.
WIFE ill the owner of a 1983 Volvo. HUSBAND is the owner of a 1987
Ford Bronco, Each party hereby waives their right, title and interest in the other's
vehicle.
11. REAL PROPERTY.
HUSBAND and WIFE acknowledge that they are the owners of real
property located at 3952 Brookridge Drive, Mechanicsburg, Cumberland County, PA
17055, The parties also acknowledge WIFE's premarital contribution of $21,000 to the
purchase of the home. HUSBAND hereby agrees to waive his right, and title to the
home and to transfer his interest in the home by special warranty deed, WIFE hereby
agrees to refinance the home within six (6) months of the execution of this Agreement
and remove HUSBAND's name from the mortgage obligation,
HUSBAND shall execute a deed prepared by WIFE's attorney. Said deed
shall be held in escrow until such time as the refinance is scheduled, In exchange for
his interest, WIFE agrees to pay HUSBAND the sum of $49.000 at the time of
refinance. HUSBAND agrees to be responsible for one-half (V,) of the closing costs
associated with the refinance, Said costs are to be deducted from HUSBAND's
proceeds.
HUSBAND and WIFE agree to continue to live at the marital residence
together until such time as the refinance is completed, During this period of time,
HUSBAND and WIFE agree to share the costs associated with the home, equally,
Page 7 of 14
C:\OFFIC ~\WPWIN\WPOOCSICIOME' ~;IMSA 'MUMMERT WPO
October 28, 1997
.
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including the mortgage, utilities, insurance and taxes, Any unpaid costs shill be
deducted from HUSBAND's share of the proceeds at the time of refinance. HUSBAND
agrees to leave the home no later than one (1) day after the completion of the refinance.
12. LIFE INSURANCE.
The parties acknowledge that HUSBAND has a whole life insurance
policy with an approximate cash value of $1,800 and WIFE has a whole life insurance
policy with an approximate cash value of$l,900, HUSBAND hereby waives any right,
title and/or interest in WIFE's insurance policy, WIFE hereby waives any right, title
and/or interest in HUSBAND's insul'8nce policy.
The parties agree to each maintain $100,000 term life insurance on their
lives and agree to name their children as equal beneficiaries on said policies until both
children reach twenty-one (21) years of age, The premium costs shall be equally
divided between the parties,
13, HEALTH INSURANCE.
HUSBAND agrees to maintain WIFE on his health insurance until such
time as the divorce is finalized,
Page 8 of 14
C;\oFFICEIWPWINIWPOOCSIOOME ~''MSA 'MUMMERT WPO
~28, lQll1
,....4
14. RETIREMENT ACCOUNTS.
HUSBAND is the owner of a 40 lK through Square D with an approximate
balance of $26,000. WIFE is the owner of an IRA with an approximate balance of
$20.000 and a TSA through Holy Spirit Hospital with an approximate balance of
$8,000, WIFE also has an employer driven pension with Holy Spirit Hospital.
HUSBAND hereby waives any right, entitlement 01' interest in WIFE's IRA, TSA and
pension. WIFE hereby waives any right, entitlement or interesL in HUSBAND's 401K.
15, CUSTODY
A. The parties hereby agree to shared legal custody of their children,
Katharine Evelyn Roberto and Nicholas Frederick Roberto. Except in the case of an
emergency, all major decisions affecting said children's growth and development
including health and medical treatment, psychological counseling, education and
scholastic activities shall not be made without each parent consulting with the other.
Communication may be achieved through any means which the parent believes will
allow the other to obtain a complete view of the circumstances underlying the decision
to be made, The method of communication may include direct contact or written
correspondence, Each parent shall act reasonably with the other in regard to the
decision, by listening to his 01' her viewpoint, and by making every effort to reach a
decision which is agreeable to all, In every instance when a major decision is being
made, each parent will make every effort to act in the best interests of the children.
Page 9 of 14
. C;\OFFIC E\WPWINIWPOOC S\OOME~'M5A 'MUMMERT WPO
october 28, 1997
,..,,'
B. While in the children's presence, neither parent shnll make or nllow
any other person to make any remarks 01' do anything which could be construed as
derogatory or uncomplimentary to the other parent. It shall be the express duty of
each parent to uphold the other parent as one whom the children should respect and
love, Each parent therefore agrees to make every reasonable attempt to show support
for the other parent in his or her role as a caring and concerned parent.
C, When emergency decisions must be made, the parent who has
physical custody at the time shall be permitted to make the decision necessitated by
the emergency without consulting the other in advance, The custodial parent shnll
also be responsible for informing the other of the emergency as soon as it is reasonably
possible to do so.
D, Each parent shall be entitled to receive information, including
written reports, from any hospital, doctor, dentist 01' mental health professional
treating the children, or any authority in their schools, Both parents may attend
school conferences and activities, Father's name shall be listed with the school as the
alternative parent to be contacted in the event of an emergency. Each parent is
responsible for notifying the school of his 01' her address so that he 01' she may receive
reports regarding the children's academic work.
E. WIFE shall maintain primary physical custody oCthe children.
F. HUSBAND shall have periods of partial custody as the parties
agree.
Page 10 of 14
C:\OF FICE IWPWINIWPOOCSIOOME """'i 'MSA 'MUMME RT WPO
October 28, 1997
,.,..,'
16. SPOUSAL SUPPORT. ALIMONY PENDENTE LITE. AND
ALIMONY.
The parties hereby expressly waive, release, dischal'ge and give up any
and all rights or claims which either may now or hereafter have for alimony, alimony
pendente lite, support or maintenance, The parties further I'elease any rights that
they may have to seek modifications of the terms of this Agreement in a court oflaw
or equity, with the understanding that this Agreement constitutes a final
determination for all time of either party's obligations to contribute to the support or
maintenance of the other, From the execution date of this Agreement forward, it shall
be the sole responsibility of each party to sustain himself or herself without seeking
any support from the other.
17. A'ITORNEY FEES. COURT COSTS.
HUSBAND and WIFE agree to equally divide all court costs and attorneys
fees associated with this action, including the preparation and filing of the divorce
complaint, the preparation of the marital settlement agreement, and the finalization
of the divorce.
Page 11 of 14
C:\OF FICEIWPWINIWPOOCSIOOMEf""'MSA 'MUMMER T WPO
October 28, 1997 '
"..,'
18. MUTUAL COOPERATION.
WIFE and HUSBAND shall mutually cooperate with each other in order
to carry through the tenus of this Agi'eement, including but not limited to, the signing
of documents,
19, AGREEMENT BINDING ON HEIRS.
This Agreement constitutes the final agreement of the parties and is
binding upon their heirs, assigns and successors in interest.
20. VOID CLAUSES.
If any term, condition, clause 01' provision of this Agreement shall be
detenuined or declared to be void 01' invalid in law or otherwise, then only that term,
condition, clause 01' provision shall be stricken from this Agreement, and in all other
respects this Agreement shall be valid and continue in full force, effect and operation.
21. APPLICABLE LAW.
This Agreement shall be construed under the laws of the Commonwealth
of Pennsylvania.
Page 12 of 14
C:\OFFICEIWPWINIWPDOCSIOOME ~ oMSA'MUMME R T WPD
October 28, 11l1l7
,.....
22. ENTIRE AGREEMENT.
This Agreement contnins the entire understnnding of the parties, and
there are no representations, wnl'l'nnties, covennnts or undertakings other than those
expressly set forth herein,
23, CONTRACT INTERPRETATION.
For purposes of contrnct interpretntion nnd for the purpose in resolving
any ambiguity herein, the parties agree that this Agreement was prepared jointly by
the parties,
IN WITNESS WHEREOF, the parties hereto have set their hands and
seals of the day first above written,
This Agreement is executed in duplicate, and in counterparts. WIFE and
HUSBAND acknowledge the receipt of a duly executed copy hereof.
~~
/JaA,iuJ ,,Ll .4/ll4-1 ~W-
Barbara Ann Mummert
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Witness
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Salvatore Roberto, Jr.
Page 13 of 14
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C:\OFFICE\WPWIN\WpobCS\OOMESTIC\/TIWIlITlUrl-b Irc1ns wpcJ
January 12, 1999
BARBARA ANN MUMMERT,
PI"intiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLV ANIA
v,
NO. 97-51)91)
CIVIL ACTION - LA W
IN DIVORCE
SALVATORE ROBERTO, JR"
Defend"nt
I'RAECIJ>E TO TRANSMIT RECORD
TOTHE PROTHONOTARY:
Tmnsmit the record, together wilh the following inform"tion, to the court for entry of "n
appropriate divorce decree:
1.
Ground for divurce: Irretrievahle hreakdown under ~ 3301(c) of the Divorce Code.
Date and m"nner of service of complaint: The Complaint was med on October 29,
1997, and was served on Salvatort. Roherto, Jr. by certified mail on November 3,
1997.
1
3,
(Complete either paragraph (a) or (h):
(a) Date of execution of the affidavit of consent required by * :nOI(e) of the Divoree
Code: by l'lalntlff November 19, 1998; hy Defendant November 17, 1998,
(1l){I) DHle Ill' exccllti<lR of Ihe affitlHvit rellHiretl Ily ~ 3301(11) <If lhe Divsree
Cetle: ;
(2) DHte Ill' filiRg aRtI :;el'\'iee of the PIHintiff's HITitla'iit llpllfl-.11Ie
FeSptlRtleRt:
4. Related claims pending: None.
5, (Complete either (a) or (b).)
(0) DHte aRtI mllORer of service of Ihe Rotice of iRteRtiun lB file prllecipe ta IraRsmit
Fecaftl, H capy uf which is allachetl: '
(b) Date Plaintiff's Waiver of Nutice in * 3301(c) Divorce was filed with the
Prothonotary: November 23,1998.
Date Defendant's Wai\'er uf Notice in * 3301(c) Divurce was filed with the
Prothunutary: November 23, 1998.
Respectfully Submilled.
REA<;ER & ADLER, PC
Dale: January 12, 1999
By:
I'"~ , /~j
l.,j t r L.". ~ '~ {r?-
ImlJlf,\ 1 ~NISON \ TO ,ES'QUIRE
Allilmey I.D. Nd. 663 8
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C;IOFFICEIWPWINIWPDOCSIDOME9TICICOMPLAINIMUI,IMER T WPD
Oct_a,11lll7
BARBARA ANN MUMMERT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
NO.
CIVIL ACTION - LAW
DIVORCE
v,
SALVATORE ROBERTO, JR.,
Defendant
AVISO PARA DEFENDEI~ Y RECLAIMAR DERECHOS
USTED IJA OIS0 DEMANDANDO EN LA CORTE, Is desea defenderse de las guejas
expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende,
el caso purde proce<ler sin usted y decreto de divorcio 0 anulamiento puede ser emitado en su contra por
la Corte, Una decisi6n puede tambicn ser emitida en Sll contra por caulquier otra queja 0 compensacllon
reclamados por el demand ante, Usted puede perder dinero, 0 sus propiedades 0 otros derechos
importantes para usted.
Cuando la base para el divorcio es indignadades 0 rompimiento irreparable del matrimonio, usted
Iluede solicitar consejo matrimonial. Una Iista de consejeros matrimoniales eSlli disponible en la oficina
del Prothonotary, en la Cumberland County Court OfCOl11l1l0n Pleas, Room 101, Cumberland County
Courthouse, I Courthouse Square, Carlisle, Pennsylv<lnia,
SI USTED NO RECLAMA PENSION ALlMENTACIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL
DECRETO FINAL DE D1VORCIO 0 ANULAl\IIENTO SEA EMITIDO. USTED
PUEDE PERDER EL DERECIIO A I~ECLAI\IAR CUALQUlERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEOIATO,
SI NO TIENE 0 NO PUEDO PAGAR UN AnOGADO, VA Y A 0 LLAME A LA
OFICINA INDICADA AnAJO PARA A VERIGUAR DON DE SE PUEDE
OBTENER ASISTENCIA LEGAL.
Cumberland County Lawyer Referml Service
Court Admilllstmtor
South Hanover Street
Carlisle, PA 17043
(717) 240-6200
C:IOF FICEIWPWINIWPDOCS\oOMESTICICOMPLAIN'MUMME R T WPD
Cd_a,lgg7
REAGER" ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
AlIomey I.D. No 66378
2331 Market Street
CampHiII,PA 17011
Telephone: (717) 763.1383
AlIomeys for Plaintiff
BARBARA ANN MUMMERT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO.
v,
SALVATORE ROBERTO, JR,
Defendant
CIVIL ACnON - LAW
DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 330110 OR to) OF TilE DIVORCE CODE
I. Plaintiff is Barbara Ann Mummert who currently resides at 3952 Brookridge Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17055,
2. Defendant is Salvatore Roberto, Jr. who currently resides at 3952 Brookridge Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17055.
l Plaintiff and Defendant have been bona tide residents in the Commonwealth for at least
sil( (6) months immediately previous to the tiling of this Complaint.
4. The Plaintiff and Defendant were married on May 7, 1983, at Mechanicsburg,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
C,:IOFFICEIWPWINIWPDOCSIOOME9TICICOMPLAINiMUMMERT WPD
Ocl_a, 1997
12, Plaintiff and Defendant have acquired property, both real and personal, during their
marriage.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all
marital property and debt.
Respectfully Submitted.
REAGER & ADLER, PC
Date: Octobert.1l, 1997
By:
UlRE
Attorneys for Plaintiff
3
C.IOFFICEIWPWINIWPDOOSIOOMES TICICOMPLAIN'MUMME RT WPD
Octobo< 8, 1997
VF.RIFICA TION
I, Barbara Ann Mummert, verify that the statements made in this Complaint are true and correct
to the best of my knowledge, information and belief.
1 understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section
4904, relating to unsworn falsification to authorities.
Date: / () / ~ ? / f' 7 ,
~A~n. "f~vr.
. Bar ara Ann ummert
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: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY. PENNSYLVANIA
NO, 97-5999
CIVIL ACTION - LAW
IN DIVORCE
BARBARA ANN MUMMERT.
v,
SALVATORE ROBERTO, JR,.
Defendant
AH'IDA VIT OF q>NSENT
I. A Complaint in divorce under section 3301 (c) of the Divorce Code was filed on
October 29. 1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) day~ have
elapsed from the date of 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 propeny.lawyer's fees
or expense. if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject 10 the penalties of 18 Pa,C.S, ~ 4904 relating to unsworn falsification
10 authorities.
~uttliw~
A NN IMERT
Dated: 1III q /If 1'.
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BARBARA ANN MUMMERT,
Pluinliff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 97-5999
DefendUnl
CIVIL ACTION - LA W
IN DIVORCE
SALVATORE ROBERTO, JR..
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A D1VOnCE DEClum
UNDER SECTION 33111(Cl OF TilE DIVORCE CODE
I. I consent 10 the enlry of u finul decree of divorce without nolice,
2. I understund thul I Oluy lose rights concerning ulirnony, division of property, luwyer's fees
or e'penses if I do nol c1uim them before u divorce is gnlOted.
3, I underslund lhul I will not be divorced unlilll divorce decree is entered by the Court und
thut II copy of lhe decree will be senlto me immediutely lifter it is filed with the Prothonotury,
I verify lhallhe slUlemenls rnllde in Ihis affidllvilllre true lInd correc!. I understand that flllse
stlltemenls herein lire Olllde subject 10 lhe penllhies of 18 Pa,C.S. * 4904 reluting 10 unsworn falsiliclltion
10 lIuthorities.
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BARBARA ANN MUMMERT
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: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97-5999
CIVIL ACTION - LAW
IN DIVORCE
BARBARA ANN MUMMERT,
Plaintiff
v,
SALVATORE ROBERTO, JR"
AFFmA VIT OF CONSENT
I. A Complaint in divorce under section 3301(c} of the Divorce Code was filed on
October 29, 1997,
2, The maniage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of 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 thutl may lose rights eonceming alimony, division of property, lawyer's fees
or expenses if I do not claim them before a divorce is granted,
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein arc made subject to the penalties of 18 Pa.C,S, ~ 4904 relating to unsworn falsification
to authorities,
d~R~~'
Dated: ~,/ 7, ''f''Y'
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: IN HIE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-51)1)1)
BARBARA ANN MUMMERT,
Plaintiff
Defendant
CIVIL ACTION - LA W
IN DIVORCE
SALVA TORE ROBERTO, JR.,
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A IHVORCE DECREE
UNI>I<:R SECTION 3301lC) OF TilE IHVORCE CODE
1, I consent to the entry of a final decree of di vorce without notice.
2, 1 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.
~~~A
Dated: /ftw-. I 7, 111 r
BARBARA ANN MUMMERT.
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 97-5999
CIVIL ACTION - LAW
IN DIVORCE
SALVATORE ROBERTO, JR.,
Defendant
PRAECII'E
TO THE PROTHONOTARY:
The Social Security number of the Plaintiff, Barbara Ann Mummert, is 202-46-7465,
The Social Security number of the Defendant. Salvatore Roberto, Jr" is 175-52-3077,
Respectfully Submitted,
REAGER & ADLER, I'C
Date: January 12, 1999
By:
{~L
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No, [717] 763.1383
Attorneys for Plaintiff