HomeMy WebLinkAbout01-06826
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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PEN NA.
STATE OF
LORRAINE A. ARINDAIN,
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Plaintiff
No. 01-6826
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VERSUS
JASON P. ARINDAIN,
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Defendant
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DECREE IN
DIVORCE
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2002 ,IT IS ORDERED AND
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AND NOW,
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LORRAINE A. ARINDAIN
, PLAINTIFF,
DECREED THAT
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JASON P. ARINDAIN
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AND
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
All matters have been resolved pursuant to the"'Marital Settlement Agreement
reached by the parties dated March 13, 2002 and incorporated but not merged
into the Decree.
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By
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PROTHONOTARY
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774"1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NQTICE OF INTENTION TO RESl!ME PRIOR NAME
NOTICE is hereby given that Plaintiff in the above-captioned matter, having been
granted a fmal decree in divorce on the 2nd day of April, 2002, hereby intends to resume and
hereafter use the previous name of Lorraine A. Gensemer and gives this written notice avowing
her intention in accordance with the provisions of the Act of 54 Pa. CoSo 9704.
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Lorraine A. Arindain
TO BE KNOWN AS:
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Lorraine A. Gensemer
COMMONWEALTH OF PENNSYLV A1~IA
COUNTYOF~~
On this, theM day of ,2002, before me, a Notary
Public, the undersigned officer, per nallyappeared orraine A. Arindain, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the foregoing Notice of Intention to Resume Prior Name for the
purposes contained therein.
: SS.
SS WHEREOF, I hereunto set my hand and official seal..
NOTARY PUBLIC
My Commission Expires:
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MARTT AL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this \3"'" day of '('(\erl.-h
, 2002, by and
between JASON P. ARINDAIN, hereinafter referred to as "HUSBAND", and LORRAINE A.
ARINDAIN, hereinafter referred to as "WIFE".
WITNESSETH, That:
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in
marriage on April 22, 1996 in Tacoma, Washington;
WHEREAS, one (1) child was born of this marriage being Jaron-Philip 1. Arindain, born
December 3,1996;
WHEREAS, it is the intention of the parties to settle fully and finally their respective
financial and property rights and obligations as between each other arising out of the marriage
relationship or otherwise, including without limitation (I) the settling of all matters between
them relating to the ownership of real and personal property; (2) the settling of all matters
between them relating to the past, present and future support and/or maintenance of HUSBAND
and WIFE; (3) the settling of all matters between them relating to the past, present and future
support or maintenance of their minor child, and (4) the settling of all matters between them
relating to any and all rights, titles and interests, claims and possible claims in or against the
estate of the other.
NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by
03/06/2002
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reference and deemed an essential part hereof in consideration of the foregoing recitals, the
mutual promises, covenants and undertakings herein set forth, and for good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as
follows:
SECTION I
GENERAL PROVISIONS
1. ADVICE OF COUNSEL
HUSBAND and WIFE declare that they have each had a full and fair opportunity to
obtain independent legal advice of counsel of their selection. WIFE has been independently
represented by Barbara Sumple-Sullivan, Esquire. HUSBAND is cognizant of his right to legal
representation and declares that he has chosen not to retain an attorney notwithstanding the fact
that attorney for WIFE has told him that he has an absolute right to be represented by an
attorney. HUSBAND has chosen instead to negotiate directly with counsel and/or with his
WIFE. HUSBAND hereby acknowledges that he has done so willingly and that he fully
understands the facts and has been fully informed and understands that, had a Court decided this
matter, he may have received more or less than is provided for in this Agreement. HUSBAND
knowingly waives his rights, if any, to utilize the lack of his legal representation as a basis to
attack the validity of this Agreement. Each party further declares that they are executing this
Agreement freely and voluntarily, having obtained such knowledge and disclosure of their legal
03/06/2002
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rights and obligations. Each party acknowledges that this Agreement is fair and equitable and is
not the result of any fraud, coercion, duress, undue influence or collusion.
2. PERSONAL RIGHTS
HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each
shall be free from all control, restraint, interference or authority, direct or indirect, by the other in
all respects as if she or he were unmarried, except as may be necessary to carry out the
provisions of this Agreement. Each may reside at such place or places as she or he may select.
Each may, for his or her separate use or benefit, conduct, carry on and engage in any business,
occupation, profession or employment which to him or her may seem advisable. This provision
shall not be taken, however, to be an admission on the part of either HUSBAND or WIFE of the
lawfulness of the causes which led to, or resulted in, the continuation of their living apart.
HUSBAND and WIFE shall not molest, harass, or malign the other or the respective families of
each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any
way interfere with the peaceful existence, separate from each other.
3. FINANCIAL DISCLOSURE
The parties are satisfied with the knowledge or disclosure which they possess in regard to
the extent of each other's income, assets, liabilities, holdings and estate. Each of the parties
acknowledge that he or she is aware of his or her right to seek discovery including, but not
,
limited to, written interrogatories, motions for document production, depositions, and other
03/06/2002
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means of discovery available through the Pennsylvania Rules of Civil Procedure. The parties
acknowledge that they have had the right to have property fully appraised. Each party is fully
satisfied that no additional information is necessary for the execution of this Agreement.
4. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions
of Section 3301(c) ofthe Divorce Code of 1980, as amended and will execute the documents
necessary to effectuate a divorce nnder those provisions concurrently with the execution of this
Agreement.
The parties agree that the Affidavit of Consent and the Waivers of Notice shall be
executed immediately upon the expiration of the ninety (90) day statutory waiting period for a
divorce or on or after March 11, 2002 and WIFE will file a praecipe after that date to finalize the
divorce.
5. SUBSEQUENT DIVORCE
A decree in divorce, entered by the court of Cumberland County, shall not suspend,
supersede or affect the terms of this Agreement. This Agreement, and the terms and conditions
contained herein, as well as the enforcement of said terms and conditions, shall not be contingent
upon the granting of a Divorce Decree to either party by the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. This
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Agreement shall remain in full force and effect even if the parties reconcile, cohabit as
HUSBAND and WIFE, or attempt a reconciliation. This Agreement shall continue in full force
and effect and there shall not be a modification or waiver of any of the terms hereof unless the
parties, in a writing signed by both parties, execute a statement declaring this Agreement or any
term of this Agreement to be null and void. Both parties hereto agree that this Agreement may
be incorporated by reference but shall not be deemed merged into any judgment or decree for
divorce obtained by either party.
6. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
forthwith execute and deliver to the other party, any and all written instruments, assignments,
releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for
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the proper effectuation of this Agreement.
7. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement.
A. Each party hereby absolutely and unconditionally releases and forever discharges
the other and the estate ofthe other for all purposes from any and all rights and obligations
which either may have or at any time hereafter have for past, present or future support or
maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs,
expenses and any other right or obligation, economic or otherwise, whether arising out of the
marital relationship or otherwise, including all rights and benefits under the Peunsylvania
Divorce Code of 1980, its supplements and amendments, as well as under any other law of any
other jurisdiction, except and only except all rights, agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or for the breach of any provision
thereof. Neither party shall have any obligation to the other not expressly set forth herein.
03/06/2002
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B. Each party hereby absolutely and unconditionally releases and forever discharges
the other and his or her heirs, executors, administrators, assigns, property and estate from any
and all rights, claims, demands or obligations arising out of or by virtue of the marital
relationship of the parties or otherwise, whether now existing or hereafter arising. The above
release shall be effective regardless of whether such claims arise out of any former or future acts,
contracts, engagements or liabilities or the other or by way of dower, curtesy, widow's rights,
family exemption or similar allowance, or under the intestate laws, or the right to take against
the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or 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 or the United States, or
any other country. It is expressly understood, however, that neither the provisions of this release
nor the subsequent entry of a divorce decree are intended to defeat the right of either party to
receive any insurance proceeds at the death of the other of which she or he is the named
beneficiary (whe1her the beneficiary designation was made prior or subsequent to execution
hereof), nor to defeat the right of either party to receive any legacy, bequest or residuary portion
of the other's estate under his or her will, or to act as personal representative or executor if so
named by the will ofthe other, whether such will was executed prior or subsequent to this
Agreement.
C. Except for any cause of action for divorce which either party may have or claim
to have, and except for the obligations of the parties contained in this Agreement and such rights
as are expressly reserved herein, each party gives to the other by the execution of this Agreement
an absolute and unconditional release and discharge from all causes of action, claims, rights or
demands whatsoever, in law or in equity, which either party ever had or now has against the
other.
8. SUCCESSOR'S RIGHTS AND LIABILITIES
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit ofthe parties hereto, their respective heirs, executors, administrators, successors or
assigns.
9. SEVERABILITY
If any provision in this Agreement is held by a court of competent jurisdiction to be
invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force
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and effect without being impaired or invalidated in any way.
10. ENTIRR AGREEMENT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
11. BINDING EFFECT OF AGREEMENT/W AIVER
This Agreement shall remain in full force and effect unless and until terminated under
and pursuant to tl1e terms of this Agreement.
The failure of either party to insist upon strict performance of the provisions of this
Agreement shall not be construed as a waiver of any subsequent default of the same or similar
nature, nor shall such failure be construed as a waiver of any other term, condition, clause or
provision of this Agreement.
12. 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
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relief as may be available to him or her, and the party breaching this contract shall be responsible
for payment of reasonable legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
13. CONTROLLING LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
SECTION II
EQUITABLE DISTRIBUTION
During the marriage, the parties have accumulated various assets and liabilities, the
disposition of which is intended as follows:
1. ASREIS
HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the
non-marital and marital property, including but not limited to financial accounts and
investments, vehicles, pension, employment benefits, insurance benefits and tangible personal
property, including jewelry, clothes, furniture, and other assets. HUSBAND agrees that all
assets in possession of WIFE or titled in WIFE's name shall be the sole and separate property of
WIFE and, WIFE agrees that all assets in the possession of HUSBAND or titled in HUSBAND's
name shall be the sole and separate property of HUSBAND. Each of the parties do hereby
specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may
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have with respect to any of the above said items which are the sole and separate property ofthe
other.
This document shall constitute a bill of sale for said sole property.
2. DEBTS
Each party represents that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable except as otherwise provided
herein, and that except only for the rights arising out of this Agreement, neither party will
hereafter incur any liability whatsoever for which the other party or the estate of the other party
will be liable. Each party agrees to indemnify and hold harmless from and against all future
obligations of every kind incurred by them, including those for necessities.
The parties further aver that each party shall be responsible for all debts in his or her
name alone. Each party agrees to indemnify and hold the other harmless from each of the
aforementioned debts and agrees to be responsible for all attorneys' fees incurred by the other in
defense of any claim or suit brought against him or her arising from any debt incurred during the
mamage.
To the best of the parties' knowledge, the parties affirm that no jointly titled debt exists
and all joint credit cards or other obligations have been terminated.
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SECTION III
CHILD SUPPORT
1. SUPPORT
Child support shall be due and payable pursuant to the action pending at 749 S 2000,
PACSES Case Number 477102542, as may be amended from time to time.
2. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT AND MAINTENANCE
Both parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and arc
accepted by them in lieu of and in full and final satisfaction of any claims or demands that either
may now or hereafter have against the other for support, maintenance, alimony or alimony
pendente lite. HUSBAND and WIFE further, voluntarily and intelligently, waive and relinquish
any right to seek from the other any payment for spousal support, alimony, alimony pendente lite
and maintenance.
SECTION IV
CHILD CUSTODY
The parties agree that sole legal and physical custody of their minor child, Jaron-Philip 1.
Arindain shall be with Lorraine A. Arindain. Notwithstanding the above, in the event that Jason
03/06/2002
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P. Arindain is able to come to Pennsylvania, he shall be given flexible rights of visitation with
the child at the residence of Lorraine A. Arindain. Jason P. Arindain shall endeavor to give
Lorraine A. Arindain reasonable notice of his travel plans but in no event shall said advance
notice be less than ten (10) days.
SECTION V
1. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS
The parties acknowledge that this Agreement shall become effective when actually
signed by both parties.
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COUNTY OF
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared JASON P. ARlNDAIN, who being duly affirmed according to
law, deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
MBE ssgt USAF
JESSE D. BAS,?010 US' C.,1044a
PubIC . .
Notary St'lf Judge Advocate
~';;~:~ea~h. United Kingdom
My commission expires: 1'6 J'jy J.iJ & 6
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CUMBERLAND
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared LORRAINE A. ARINDAIN, who being duly affirmed according
to law, deposes aitd says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief.
d bscribed to before me this ~ day o~k
(SEAL)
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
Counsel for Plaintiff
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: Irretrievable breakdown under ~3301(c) ofthe Divorce Code.
2. Date and manner of service of the complaint: Acceptance of Service on December
11, 2001.
3. Date of execution of the affidavit of consent required by ~ 3301 (c) of the Divorce
Code: by Plaintiff: March 22,2002; by Defendant: March 13, 2002.
4. Related claims pending: All matters have been resolved between the parties
pursuant to an Agreement of record reached on March 13, 2002 and incorporated, but
not merged into the Decree.
5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with Prothonotary:
March 27,2002. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with
Prothonotary: March 27,2002.
Dated: March 27,2002
Barba Ie-Sullivan, . re
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
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Barbara Sump Ie-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTlFICA TE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy ofthe foregoing Plaintiff's Praecipe to Transmit Record, in the above-
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captioned matter upon the following individual by first class mail, postage prepaid, addressed as
follows:
Mr. Jason P. Arindain
PSC 41 Box 798
APO, AE 09464
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
DATED: March 27,2002
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
; NO. O/~ t Y'.u. ~ I~
LORRAINE A. ARINDAIN,
Plaintiff
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so the
case may proceed without you and a decree of divorce or annulment may be entered against you
by the Court. A judgement may also be entered against you for any other claim or relief
requested in these papers by the Plaintiff. You may lose money or property or other rights
important to you, including custody and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HA VB 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
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Barbara Sump Ie-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
; NO. DJ- (" '1J.<' ~-r~
LORRAINE A. ARINDAIN,
Plaintiff
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Lorraine A. Arindain, an adult individual residing at III South 24th Street,
Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant is JASON P. ARINDAIN, an adult individual residing in the RAF Laken
Heath, United Kingdom, with a mailing address ofPSC 41 Box 798, American Post Office, America
Europe 09464.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth
of Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on April 26, 1996 in Tacoma, Washington.
5. There is one minor child born of this marriage, Jaron-Philip I. Arindain, born
December 3, 1996.
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6. The parties separated on August 1,2000.
7. There have been no prior actions for divorce or annulment between the parties.
8. Defendant is in the military of the United States or its allies but expressly waives
any protection from the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress
of 1940 and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAlJI.T
10. The averments in paragraphs 1 through 9, inclusive, of Plaintiff's Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff, Lorraine A. Arindain, prays this Honorable Court to enter
judgment:
A. Awarding Plaintiff a decree in divorce; and
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Dated: /I/:).C( /01
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Barbara umple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court LD. No. 32317
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717)774-1445
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO. (J f.- ~ l? J...L ~ '[Lv....
LORRAINE A. ARINDAIN,
Plaintiff
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT REGARDING COUNSELING
1. I have been advised of the availability of marriage counseling and understand that
I may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A
Section 4904 relating to unsworn falsification to authorities.
~~~
LORRAINE A. ARINDAIN
Dated: :2 8 N <J \I () I
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717)774-1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I, LORRAINE A. ARINDAIN, hereby certify that the facts set forth in the foregoing
COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
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LORRAINE A. ARINDAIN
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Barbara Sump1e-Sul1ivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
November 30, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
5. I verify that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904
relating to unsworn falsification to authorities.
DATE:3 Jd. a-/oQ....
'd e'1MiN. 0. - 0 II AfV'IA'kwv\
LORRAINE A. ARINDAIN
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Barbara Sumple-Sul1ivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 30, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
5. I verifY that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904
relating to unsworn falsification to authorities.
DATE: \3~OI
tr
P. ARINDAIN
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared JASON P. ARINDAIN, who being duly affirmed according to
law, deposes and says that the facts and matter set forth in the Within and foregoing
AFFIDAVIT OF CONSENT are true and correct to the best of his knowledge, information and
belief.
Affirmed and subscribed to before me this I -; day of tIA""J,- , 2002.
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My Commission Expires: ~ :SJy ~6"6
. BASCOMBE, SSgt, USAF
Notary Public, 10 U.S.C. 1044a
.Office of the Staff Judge Advocate
RAF Lakenheath, United Kingdom
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Supreme Court #32317
549 Bridge Street
New Cumberland, pA 17070
(717)774-1445
LORRAINE A. ARINDAIN,
Plaintiff
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn
falsification to authorities.
DATE: 3 b,=J.)6Q...
~Anll'r\q (}.. ~1rv1
LORRAINE A. ARINDAIN
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717)774-1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
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 statement herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn
falsification to authorities.
~
DATE: 13mOO.o z,.
N P. ARINDAIN
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared JASON P. ARINDAIN, who being duly affirmed according to
law, deposes and says that the facts and matter set forth in the within and foregoing WAIVER
OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) OF THE DIVORCE CODE are true and correct to the best of his
knowledge, information and belief.
Affirmed and subscribed to before me this ( -; day of t11~ r: t----. , 2002.
~~~
My Commissi6n Expires: J.6
(SEAL)
JESSE D. BASCOMBE, SSg!, USAF
Notary Public, 10 U.S,C. 1044a
Office of the Staff Judge Advocate
RAF Lakenheath, United Kingdom
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
LORRAINE A. ARINDAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 01-6826
JASON P. ARINDAIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, JASON P. ARINDAIN, hereby personally accept service and acknowledge receipt of
the above-captioned Complaint in Divorce, having received said Complaint on the ...ll- day
of (kLLW\I..,0( ,2001.
C' 9~
JASO~P. ARINDAIN
COUNTY OF
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared JASON P. ARINDAIN, who being duly affirmed according to
law, deposes and says that the facts and matter set forth in the within and foregoing
ACCEPTANCE OF SERVICE are true and correct to the best of his knowledge, information
and belief.
Affirmed and subscribed to before me this 1.1 <f\o.- day of ~bE';y , 200 I.
(SEAL)
JOANNE M. DEUERMEYER S-Scd- \,t:;,tT I-
Paralegal, t.{ 15 FW (JA- I iJ' f
NOTARY BY FEDERAL STA1UI'E
10 V.S.C. 1044a
IA W AFI 51-504
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