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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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Tammy L. Wri,;ht. Plaintiff
No.
430 Civil Term
2001
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VERSUS
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Sta11ley V. Wright, Defelldant
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DECREE IN
DIVORCE
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AND NOW,
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, IT IS ORDERED AND
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Tammy L. Wril!:ht
DECREED THAT
, PLAINTIFF,
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AND
Sta11ley V. Wright
, 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;
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None.
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By THE COURT:
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PROTHONOTARY
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TAMMY L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 430 Civil Term
STANLEY V. WRIGHT,
Defendant
ACTION IN DIVORCE
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this~ day of trlaA.I , 2001, by and between,
TAMMY L. WRIGHT, of Carlisle, Cumt?erland County, Pennsylvani/' hereinafter referred to as "WIFE",
and , STANLEY V. WRIGHT, of , Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as
"HUSBAND".
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on December 15, 1992, in Newville,
Pennsylvania, and;
WHEREAS, there were no children born of this marriage;
WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the
intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties
desire to settle their respective financial property rights and obligations as between each other, including
the settling of all matters between them relating to ownership and equitable distribution of real and
personal property; the settling of all matters between them relating to the past, present, and future
support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all
possible claims by one against the other or against their respective estates;
NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant
and agree as follows:
1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and
fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as
any other fact relating in any way to the subject matter of this agreement. These disclosures are part of
the consideration made by each party for entering into this agreement.
2. ADVICE OF COUNSEL. The Husband is PRO SE. The Wife has employed and had the
benefit or counsel of JANE ADAMS, ESQUIRE, as her attorney. Each party has carefully and completely
read this agreement and has been advised and is completely aware not only of its contents but of its legal
effect.
3. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to
live apart from each other. It is the intention and purpose of this agreement to set forth their respective
rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was
filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run.
The parties have attempted to divide their matrimonial property in a manner which conforms to a
just and right standard, with due regard to the rights of each party. It is the intention of the parties that
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such divisian shall be final and farever determine their respective rights. The divisian af existing marital
property is nat intended by the parties to. canstitute in any way a sale ar exchange af assets.
4. FREEDOM FROM INTERFERENCE. Further, the parties agree to. continue living separately
and apart fram each ather at any place ar places that he ar she may select. Neither party shall harass,
annay, injure, threaten, ar interfere with the ather party in any manner whatsaever. Each party may carry
an and engage in any emplayment, prafessian, business ar ather activity as he ar she may deem
advisable far his ar her sale use and benefit. Neither party shall interfere with the uses, awnership,
enjayment, ar dispasitian af any praperty naw awned and nat specified herein ar praperty hereafter
acquired by the ather.
5. SUBSEQUENT DIVORCE. The parties hereby acknawledge that WIFE has filed a Camplaint
in Cumberland Caunty, claiming that the marriage is irretrievably braken under the na-fault mutual cansent
pravisian af Sectian 3301@afthe Pennsylvania Divarce Cade. HUSBAND hereby expresses his
agreement that the marriage is irretrievably braken and expresses his intent to. execute any and all
affidavits ar ather dacuments necessary far the parties to. abtain an absalute divarce pursuant to. Sectian
3301@ af the Divarce Cade. The parties hereby waive all rights to. request Caurt Ordered counseling
under the Divarce Cade. It is further specifically understaad and agreed by the parties that the provisians
af this Agreement relating to. equitable distributian af property af the parties are accepted by each party as
a final settlement far all purpases whatsaever, as cantemplated by the Pennsylvania Divarce Cade.
Shauld a decree, judgment, ar arder af separatian ar divarce be abtained by either af the parties
in this ar any ather state, cauntry ar jurisdictian, each af the parties hereby cansents and agrees that this
Agreement and all af its cavenants shall nat be affected in any way by any such separatian ar divarce; and
that nathing in any such decree, judgment, arder, ar further madificatian ar revisian thereaf shall alter,
amend, ar vary any term af this Agreement, whether ar not either ar bath af the parties shall remarry (it
being understaad by and between the parties hereto. that this Agreement shall survive and shall nat be
merged into. any decree, judgment, ar arder af separatian.) It is specifically agreed, hawever, that a capy
af this Agreement ar the substance af the pravisians thereaf, may be incorparated by reference into. any
divarce, judgment, ar decree. This incarparatian, hawever, shall nat be regarded as a merger, it being the
speCific intent af the parties to. permit this Agreement to. survive any judgment and to. be farever binding
and canclusive upan the parties.
6. DATE OF EXECUTION. The "date af executian" ar "executian date" af this agreement shall
be defined as the date upan which it is executed by the parties if they have each executed the Agreement
an the same date. Otherwise, the "date af executian" ar "executian date" af this Agreement shall be
defined as the date af executian by the party last executing this Agreement.
7. DISTRIBUTION DATE. The transfer af praperty, funds, and/ar dacuments pravided far herein
shall anly take place an the "distributian date" which shall be defined as the date af executian af this
Agreement unless atherwise specified herein.
8. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do. hereby mutually
remise; release, quit-claim and farever discharge the ather and the estate af the ather, af and fram any
and all rights; titles, and interests, ar claims in ar against the praperty (including incame and gain fram
praperty hereafter accruing) af the ather ar against the estate af such ather, ar whatever nature and
wheresaever situate, which she ar he naw has ar at any time hereafter may have against such ather, the
estate af such ather ar any part thereaf, whether arising aut af any farmer acts, cantracts, engagements,
ar liabilities af such ather ar by way af dawer ar curtesy, ar claims in the nature af dawer ar curtesy af
widaw's ar widawer's rights, family exemptian ar similar allawance, ar under the intestate laws, ar the right
to. take against the spause's will; ar the right to. treat a lifetime canveyance by the ather as testamentary, ar
all ather rights af a surviving spause to. participate in the decease spause's estate, whether arising under
the laws af Pennsylvania, any state, cammanwealth, ar territary af the United States, ar any ather cauntry,
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or any rights which Wife may have or at any time hereafter have for past, present or future support or
maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result
of any 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.
9. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants represents that
they have not contracted any debt or liability for the other or which the estate of the other party may be
responsible or liable, and 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 or hold harmless from and against all future obligations of every
kind incurred by them, including those for necessities.
10. OUTSTANDING JOINT DEBTS.
(a) Wife agrees that the following debts are her own personal responsibility and therefore agrees
to completely and finally pay on the following debts and obligations.
Wife will pay any and all amounts due and owing on the couple's 1994 Saturn, to equal
$95/month biweekly until all.amounts due and owing are paid off. Upon payment of
outstanding amounts, the title of the 1994 Saturn shall be transferred to wife's name
alone.
(b) Husband agrees that the following debts are his own personal responsibility and therefore
agrees to completely and finally pay on the following debts and obligations.
All debts relating to the couple's repossessed 1998 Dodge Ram.
11. DIVISION OF PERSONAL PROPERTY. Husband and Wife do hereby aCknowledge that
they have previously divided their tangible personal property including, but without limitation, jewelry,
clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works
of art, and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees
that all of the property of Husband or in his possession shall be the sole and separate property of
Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and
separate property of Wife. The parties do hereby specifically waiver, release, renounce, and forever
abandon whatever claim, if any, he or she may have with respect to the above items which shall become
the sole and separate property of the other.
12. OTHER PERSONAL PROPERTY. The parties agree that the following items have been returned to
HUSBAND:
Divorce decree from Valerie Wright, photo album, paperwork, movie projector, trumpet
letter jacket, army clothes, ironing board and iron, Christmas decorations, fish tank,
bicycle, weber grill, tools, automotive items, stereo, radio, speakers, child's wooden sled, suitcase.
Computer: Old computer monitor, PC, keyboard, computer books, disks, and programs.
Furniture: 2 end tables, 2 kitchen tables, TV stand, shelving unit, and lamp.
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13. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the
parties, they agree as follows:
(a) The 1994 Saturn shall be and remain the sole and exclusive property of Wife.
(b) The 1992 Buick Century shall be and remain the sole and exclusive property of Husband.
Upon payment of all amounts owed on the 1994 Saturn, the parties will cooperate in transferring
legal title of the 1994 Saturn to Wife's name alone. Husband and Wife shall cooperate to obtain separate
auto insurance policies and will each pay any amounts required to maintain their own separate policies.
14. MARITAL HOME. HUSBAND and WIFE hold title to the premises identified as756 N.
Middleton Road, North Middleton Township, Cumberland County, Carlisle, Pennsylvania. The parties
agree as follows with respect to the marital residence:
(a) On or with thirty (30) days of this agreement, HUSBAND shall deliver a warranty or quitclaim
deed, conveying to WIFE all of his right, title and interest in and to the marital resiqence.
Thereafter, WIFE shall be the sole owner of the marital residence and shall be permitted to record
the deed and take any other action with respect thereto that she deems appropriate.
(b) As of the date of separation, and without regard to when bills for such items are incurred,
received or due, WIFE shall be solely responsible for all past, present, and future costs or
liabilities associated with or attributable to maintaining the marital residence (except as provided
herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and
telephone service, homeowner's insurance, and gardening expenses and repairs, and WIFE shall
keep HUSBAND and his successors, assigns, heirs, executors, and administrators indemnified
and held harmless from any liability, cost or expense, including attomey's fees, which are incurred
in connection with such maintenance, costs, and expense.
(c) There is presently an outstanding mortgage against the martial residence in favor of Homeq
Servicing Corporation. Commencing on the date of this agreement, WIFE shall be solely
responsible for timely payments of all past, present, and future principal, interest and other fees
under the first mortgage with Homeq Servicing Corporation.
(d) WIFE shall make reasonable and continuing efforts to have the residence at 756 N. Middleton
Road, Carlisle, Pol. 17013 refinanced or assume the current mortgage and have HUSBAND
removed from any liability for the lien of that debt, it being the intention of the parties that husband
and the property be released from the lien as conveniently as possible. HUSBAND and WIFE
shall cooperate in taking all steps necessary to have the appropriate loan and mortgage
transferred to WIFE or refinanced by WIFE.
15. MUTUAL WAIVER OF EMPLOYMENT BENEFITS and OTHER CLAIMS. The parties
agree to Waive any and all rights they have in and to each other's employment benefits, including but not
limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree
never to assume any claim to such benefits of the other at any time in the future.
WIFE waives any right to Husband's Workers Compensation Claim and award (Claim #675768),
which was awarded in a decision rendered by Judge Karl H. Peckmann, before the Pennsylvania
Department of Labor and Industry, on October 4, 2000.
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16. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any
right to alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and
expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and
maintained a substantial and adequate fund with which to provide for themselves sufficient financial
resources to provide for their comfort, maintenance, and support in the station of life to which they are
accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively
have against the other for alimony, support, or maintenance. It shall be from the execution of this
Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking
any support from the other party.
17. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their
knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for
calendar years 1992 through 2000 have been filed and that no notices have been received from the
Internal Revenue Service which remain unresolved. Each party further represents to the other that to the
best of his or her knowledge, the information set forth in the joint tax return for these calendar years was
and remains accurate as relates to his or her sole income and acknowledges that the other party relied on
such representations in signing those returns. Therefore, if any deficiency in federal, state, or local
income taxes is proposed, or any assessment of any such tax is made against the other party by reason
of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife
shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense
relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax,
interest, and penalties or expenses shall be paid solely and entirely by the responsible party as
determined to be attributable to that party on account of misrepresentation or failure to disclose relevant
information of income on the aforesaid joint returns.
18. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the
terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach
hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar
nature.
19. MUTUAL COOPERATI.ON. Each party shall, at any time and from time to time hereafter,
take any and all steps and execute, acknowledge, and deliver to the other party any and all further
instruments and/or documents that the other party may reasonably require for the purpose of giving full
force and effect to the provisions of this Agreement.
20. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement.
21. INTEGRATION. This Agreement constitutes the entire understanding of the parties and
supersedes any and all prior agreements or negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
22. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith
execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other
writings as may be necessary or desirable for the proper effectuation of this Agreement.
23. NO WAIVER OF DEFAULT. This Agreement shall remain in full force arid effect unless and
until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist
upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such
party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof
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by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be
construed as a waiver or strict performance of any other obligations herein.
24. SEVERABiliTY. If any term, condition, clause, or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or
provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid
and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her
obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the
conditions precedent, shall in no way avoid or alter the remaining obligations of the parties.
25. BREACH. If either party breaches any provisions of this agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief
as may be available to him or her, and the party breaching this contract should be responsible for payment
of legal fees and costs incurred by the other in enforcing their rights under this agreement.
26. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges
and declares that he or she is fully informed as to the facts relating to the subject matter of this
agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or
duress of any kind, has given careful thought to the making of this agreement, has carefully read each
provision of this agreement, and fully and completely understands each provision of this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year
first above written:
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AMMY L. W HT itne
Dates < /6' ())
COMMONWEALTH OF PENNSYLVANIA )
):ss
COUNTY OF CUMBE~~ )
On this, thejO day of m~, 2001, before me, the undersigned officer,
personally appeared TAMMY L. WRIGH . wn to me, (or satisfactorily proven) to be the person whose
name is subscribed to the within instrumen , and acknowledged that he/she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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JANE. E.!'tDP:i;iS;'IWfiIY~,.~
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COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF CUMBER~ . )
On this, the 15 day of ~' 2001, before me, the undersigned officer,
personally appeared STANLEY V. W IG, n to me, (or satisfactorily proven) to be the person
whose name is subscribed to the within in ment, and acknowledged that he/she executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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TAMMY L. WRIGHT,
Plai ntiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 430 Civil Term
STANLEY V. WRIGHT,
Defendant
: ACTION 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) of the Divorce
Code.
2. Date and manner of the service of the Complaint: Delivered by certified mail.
restricted delivery. return receipt reauested. delivered on: January 24. 2001.
3. Date of execution of the affidavit of consent required by 3301 (c) of the
Divorce Code:
By Plaintiff:
May 15, 2001
May 14, 2001.
By Defendant:
4. Related claims pending: None: marriage settlement agreement filed May 16.
2001.
5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: May 16, 2001.
Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: May 16, 2001.
Date: 0 '0. OJ
ne Adams, Esquire
.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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TAMMY L. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
No. 01 - 430
Civil Term
STANLEY V. WRIGHT,
Defendant
: ACTION IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME.
To the Prothonotarv:
Notice is hereby given that the Plaintiff in the above matter:
prior to the entry of a Final Decree in divorce.
OR X after the entry of a Final Decree in Divorce
hereby elects to resume the prior surname of GAGE and gives this written notice avowing her
intention pursuant to the provisions of 54 P.S. s704.
Date: '/~10~ Q~l{AALJ~
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TAMMYL. GAGEO ~
Signature of Name being resumed.
COMMONWEALTH OF PENNSYLVANIA )
):ss
COUNTY OF CUMBERLAND )
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On this, the '-{ day of v~ ,20011 before me, the undersigned officer,
personally appeared TAMMY L. WRIGHT/T~ L. GAGE personally know to me, (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the same for the purposes therein contained., .,; '.
IN WITNESS WHEREOF, I h
My commission e
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TAMMY L. WRIGHT,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; No. 01- <i&J c.; vi I
STANLEY V. WRIGHT,
Defendant
: 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. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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, Pa. 17013
(717) 249-3166
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TAMMYL. WRIGHT,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 0 1- 'i 30 CW<J, -r UA"'-
STANLEY V. WRIGHT,
Defendant
: ACTION IN DIVORCE
COMPI,AINT IN DIVORCE
1. Plaintiff is Tammy L. Wright, an individual sui juris, who has resided at 756 N.
Middleton Road, Carlisle, Cumberland County, Pa., since 1984.
2. Defendant is Stanley V. Wright, an individual sui juris, who has resided at 133 South
Pitt Street, Carlisle, Cumberland County, Pa., since February 2000.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on December 15, 1992 in Newville,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have no children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken; and/or
(b) That the Defendant has offered such indignities to the Plaintiff, the innocent
and injured spouse, as to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
I verify 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. g4904 relating to unsworn
falsification to authorities.
Respectfully submitted,
Date: I-:;>"d- - 0 I
e Adams, Esquire
l.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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TAMMYL. WRIGHT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01 - 430 Civil Term
STANLEY V. WRIGHT,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF
NOTICE TO DEFEND AND COMPLAINT.
AND NOW, this January 25,2001, I, Jane Adams, Esquire, hereby certify that
on January 24, 2001, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT
were served, via certified mail, restricted delivery, return receipt requested, addressed to:
Stanley V. Wright
133 S. Pitt St.
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
J e Adams, Esquire
.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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OF THE PROTHONOTARY
01 JM!25 P~II:42
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....II!!. Print your name ancl address on the reverse
--;"0 tHat -we carl_ return the card to you.
.' -l\.ttach this card to the back of the mail piece,
Or on the-front if space permits.
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2. Article Num.ber (Copy from service labe. Q ,q "a
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TAMMY L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 430 Civil Term
STANLEY V. WRIGHT,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
2001.
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 22,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of 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.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification
to authorities.
Date: .1J=. / ~- (J /
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER '3301/cl OF THE DIVORCE CODE
1. I consent to 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:
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TAMMY L. WRIGHT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 430 Civil Term
STANLEY V. WRIGHT,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 22,
2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of 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.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification
to authorities.
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Date:U . .' L(, CJ J
<~ U..~~
Stanley V. Wrig t, Defel)llBnt.
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER '3301 leI OF THE DIVORCE CODE
1. I consent to entry of a final decree of divorce without notice.
2. I understand that I may 16se 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: S '(C/. 0/
)L.tf/~~
Stanley V. Wright, efen nt.
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