HomeMy WebLinkAbout01-7235 FX
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IN THE COURT OF COMMON PLEAS
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OFCUMBERLANDCOUNTY
Drew B. Frank, Plaintiff
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STATE OF
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No. 2001 - 7235
Civil Term
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VERSUS
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Tammy S. Frank, Defendant
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DECREE IN
DIVORCE
AND NOW,
D~ (Cf
~;O ~IT IS ORDERED AND
Drew B. Frank
DECREED THAT
, PLAI NTI FF,
Tammy S. Frank
AND
, DEFENDANT,
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ARE DIVORCE:D FROM THE BONDS OF MATRIMONY.
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THE COURT RETAI NS JURISDICTION OF THE FOLLOWING. CLAI MS WHICH HAVE
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BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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YET BEEN ENTERED;
None; The property settlement agreement executed on October 5, 2004, and
Filed October 4, 2004 shall be incorporated but not mer
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ecree.
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PROTHONOTARY
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DREW B. FRANK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: No. 01 - 7235 Civil Term
TAMMY SUE FRANK,
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 &330l(c) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered bv certified mail.
restricted delivery. return receipt reauested on: January 13, 2004.
3. Date of execution of the affidavit of consent required by 3301(c) ofthe Divorce Code:
. By Plaintiff:
October 5, 2004.
By Defendant:
October 5, 2004.
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: October 6, 2004.
Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: October 6, 2004.
-(a /s rJ~
Respectfully Submitted:
Jane Adams, Esquire
LD. No. 79465
36 S. Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
QRIGINAL
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT-LAW
26 W. High Street
Carlisle. P A
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
DREW B. FRANK,
Plaintiff
CIVIL ACTION - LAW
v.
Docket No. 2001 - 7235
TAMMY S. FRANK,
Defendant
(In Divorce)
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT is made this 15.- day of ~,2004, BY
and BETWEEN Drew B. Frank of 5 Ian Drive, Mt. Holly Springs, Cumberland County,
Pennsylvania, hereinafter referred to as Husband,
A
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Tammy S. Frank of 405 Juniper Street, Carlisle, Cumberland County, Pennsylvania,
hereinafter referred to as Wife.
RECITALS
R.I: The parties hereto are Husband and Wife, having been joined in marriage on
July 28, 1984, in Boiling Springs, Cumberland County, Pennsylvania; and
R.2: Differences have arisen between the parties, in consequence of which they
have lived separate and apart since on or about September 4, 1999; and
R.3: The parties have re~olved that it is not possible to continue the marital
relationship between them for reasons known to them, in consequence of which they are
living separate and apart; and
DBF
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Page 1 of 15
TSF J5J.
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SAlOIS
SHUFF, FLOWER
& LINDSAY
A'ITORNEYS.AT.LAW
26 W. High Street
Carlisle. P A
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R.4: It is the desire and intention of the parties, after long and careful
consideration, to amicably adjust, compromise and settle all property rights, and all rights
in, to or against the property or estate of the other, including property heretofore or
subsequently acquired by either party, and to settle all disputes existing between them,
including any claims or rights that they may have under the provisions of the PelUlsylvania
Divorce Code, as amended; and
R.5: The parties also desire to settle their issues of counsel fees and costs, and the
settling of any and all claims and possible claims against the other or against their
respective estates; and
R.6: The parties desire to resolve all claims pending between them, including the
settlement of all of their respective property rights and other rights growing out of their
marriage relationship including, but not limited to, all matters between them relating to the
ownership of real and personal property, claims for spousal support, alimony, alimony
pendente lite, counsel fees and costs; and
R.7: Husband and Wife declare that each has had a full and fair opportunity to
obtain independent legal advice of counsel of their selection; that Husband has been
independently represented by Jane E. Adams, Esquire, and that Wife has been
independently represented by Lindsay Gingrich Maclay, Esquire; and
R.8: Both Husband and Wife each covenant that they have made full and
complete disclosure to the other of his and her respective property holdings and income;
and
DBF~
Page 2 of 15
TSF ,.$,-:+
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT-LAW
26 W. High Street
Carlisle. P A
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R.9: Each party has had an opportunity to verify the financial disclosure of the
other. Discovery, if any, has been conducted to the satisfaction of each party. Each party
has had the opportunity to investigate further the financial disclosure of the other, and has
had access to any desired books and/or records to investigate further. Each party had an
opportunity to do an independent valuation of the assets, liabilities and income of the other
party. To the extent either party decided not to pursue further discovery and investigation,
he or she did so voluntarily and specifically waives the right to challenge this Agreement
based on the absence of full and fair disclosure.
NOW THEREFORE, with the aforegoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof and in consideration of the covenants and
promises hereinafter to be mutually kept and performed by each party, as well as for other
good and valuable consideration, receipt of which is hereby acknowledged, and the parties,
intending to be legally bound, hereby agree as follows:
(1)
SEPARATION:
It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or places as he or she from time
to time may choose or deem fit, free from any control, restraint or interference from the
other. Neither party will molest the other or endeavor to compel the other to cohabit or
dwell with him or her by any legal or other proceeding. Neither party shall disparage or
discredit the other in any way, nor in any way injure his or her reputation; nor shall either of
them act or permit anyone else to act in any way which might tend to create any disaffection
or disloyalty or disrespect between the members of the family of either party. Each party
shall be free of the interference, authority or contact by the other as if he or she was single
DBF~
Page 3 of 15
TSF..1 s;;.
II
SAIDIS
SHUFF, FLOWER
& LINDSAY
AITORNEYSIAT-LAW
26 W. High Street
Carlisle, P A
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and unmarried exc,ept as maybe necessary to carry out the terms of this Agreement or any
Custody Stipulation and Agreement and/or Order of Court.
(2) DIVORCE: The parties acknowledge that the marriage is irretrievably
broken and that they will secure a mutual consent no-fault divorce decree. Simultaneous
with the execution ofthis Agreement, the parties agree to execute their respective Affidavits
of Consent and Waiver of Notice Forms necessary to finalize said divorce.
If either party fails or refuses to execute and file the foregoing documents, said
failure or refusal shall be considered a material breach of this Agreement and shall entitle
the other party at his or her option to terminate this Agreement.
(3)
REAL PROPERTY:
The parties acknowledge that they are joint
owners of the premises more commonly identified as 5 Ian Drive, Mt. Holly Springs,
Cumberland County, Pennsylvania (hereinafter referred to as the "Marital Residence"). The
appraised value of the Marital Residence on March 1, 1996 was Ninety-Five Thousand
($95,000.00) Dollars. Said Marital Residence is currently encumbered by a first mortgage
with First Union Mortgage Corporation, or its successors. The debt owed on the first
mortgage in or around July of 1999 was Thirty-Eight Thousand Eight Hundred Thirteen and
03/100 ($38,813.03) Dollars. The marital residence is also encumbered by a second
mortgage with Conseco, or its successors. The debt owed on the second mortgage in or
around September of 1999 was Forty-Four Thousand Four Hundred Forty-Nine and 45/100
($44,449.45) Dollars. The parties acknowledge that both mortgages are in both parties'
names. Contemporaneously with the execution of this Agreement, Wife agrees that as part
of this property settlement, she will convey any and all of her right, title and interest in and
to said ff.l>>rty to Husband, free of all encumbrances except the outstanding first and
DBF ~ Page 4 of 15 TSF In.....
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
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second mortgages, which Hnsband agrees to assume and pay in due course, and that Wife
will execute and deliver a Special Warranty Deed to Husband conveying any interest Wife
may have in and to said property to Husband. Simultaneous with the execution of this
Agreement, Wife will receive Two Thousand ($2,000.00) Dollars in exchange for waiving
any interest she may have in and to the Marital Residence. Said payment shall be made to
Wife in the form of a Cashier's Check.
Jane E. Adams, Esquire. agrees to hold the Deed in escrow until such time as
Husband is able to refinance the first and second mortgages solely into his name. Husband
shall attempt to refinance the first and second mortgages into his own name at least once
every calendar year, offering proof to Wife within five (5) days of her request, should she
request such proof, of his yearly attempt to refinance. Until such time as Husband is able to
refinance the first and second mortgages on the Marital Residence, Husband specifically
agrees to hold Wife harmless with regard to all payments associated with the Marital
Residence from the date of separation, forward, including, but not limited to the first and
second mortgage payments, taxes, homeowner's insurance and repairs. Wife agrees to
execute any and all documents, within five (5) days of a request to do so by Husband, in
order to effectuate the refinance of the mortgages solely into Husband's name.
Upon Husband successfully refinancing the first and second mortgages into his own
name, Jane E. Adams, Esquire, shall record the Deed conveying the Marital Residence from
Husband and Wife to Husband.
(4)
DEBT: Each of the parties hereto covenants and agrees that he or she has
not in the past and will not at any time in the future incur or contract any debt, charge or
. .
liability for which the other of them, their legal representatives, or their property or estate
DBF ~ . Page 5 of15 TSF 1/rl-
II
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.AT.LAW
26 W, High Street
Carlisle. P A
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may become liable; and each of them further covenants at all times to keep the other free
harmless and indemnified of and from all debts, charges and liabilities hereafter or
heretofore contracted by them, except as hereinafter provided.
A. MARITAL DEBT: Other than those debts enumerated within this
agreement, Husband and Wife acknowledge and agree that there are
no other outstanding debts and obligations which are marital or for
which the other might be liable incurred prior to the signing of this
Agreement.
1. Except as otherwise herein provided, each of the parties will
pay all current bills and outstanding bills incurred on or
before the date of separation of the parties, September 4,
1999, to the same extent that he or she has been paying them
in the past and neither party shall incur any unusual bill
which will bind the other party. Wife hereby agrees to return
to Husband any and all joint credit cards or charge plates that
she may have in her possession. The parties further agree
that any debts incurred on said joint credit cards or charge
plates subsequent to the date of separation, shall be the sole
and exclusive responsibility of the party who incurred said
debts and the debt-incurring party shall save harmless the
other party from any obligation or institutions of suit
thereunder.
B: POST SEPARATION DEBT: In the event that either party
contracted or incurred any debt since the date of separation on
September 4, 1999, the party who incurred said debt shall be
responsible for the payment thereof regardless of the name in which
the debt may have been incurred.
c:
FUTURE DEBT: From the date of this agreement neither party
shall contract or incur any debt or liability for which the other party
or his or her property or estate might be responsible and shall
indemnifY and save the, other party harmless from any and all claims
or demands made against him or her by reason of debts or obligations
incurred by the other party.
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Page 6 oflS
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT-LAW
26 W. High Street
Carlisle. P A
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(5)
MOTOR VEHICLES:
The parties acknowledge that Husband,
individually, holds title to a 2005 Harley Davidson Softail motorcycle and to a 2003 Subaru
Legacy. Wife hereby relinquishes any right, title or interest she may have in and to the
Harley and the Subaru. Husband shall maintain separate insurance on the Harley and the
Subaru. Husband specifically agrees to assume full responsibility for and pay in due
course, anyencumbrance(s) on Husband's Harley and/or Subaru. Husband shall hold Wife
harmless and indemnify Wife from any loss thereon.
The parties also acknowledge that Wife, individually, holds title to a 2000 Ford
Explorer. Husband hereby relinquishes any right, title or interest he may have in and to
Wife's Ford Explorer. Wife shall maintain separate insurance on the Ford Explorer. Wife
specifically agrees to assume full responsibility for and pay in due course, any
encumbrance(s) on her 2000 Ford Explorer. Wife shall hold Husband harmless and
indemnify Husband from any loss thereon.
The parties further acknowledge that the parties, jointly, hold title to a 1996
Chevrolet Blazer. Husband hereby relinquishes any right, title or interest he may have in
and to the 1996 Blazer, currently in possession of Wife. Wife shall maintain separate
insurance on the 1996 Blazer. Within thirty (30) days of the date of this agreement
Husband shall execute any documents necessary to have said vehicle properly registered in
Wife's name with the Pennsylvania Department of Transportation. Wife shall maintain
insurance on the 1996 Blazer received by Husband as a result of this transfer, and shall hold
harmless and indemnify Husband from any loss thereon.
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Page 7 of 15
TSFjJi.7-.
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYSIATILt\W
26 W. High Street
Carlisle. PA
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(6) TANGIBLE PERSONAL PROPERTY: Except as otherwise herein
provided, the parties hereto mutually agree that they have effected a satisfactory division of
the furniture, household furnishings, appliances, tools and other household personal
property between them, and they mutually agree that each party shall from and after the
date hereof be the sole and separate owner of all such property presently in his or her
possession whether said property was heretofore owned jointly or individually by the
parties hereto. This Agreement shall have the effect of an assignment or bill of sale from
each party to the other for such property as may be in the individual possession of the
parties hereto.
Simultaneous with the execution of this Agreement, the following items currently in
possession of Husband shall be transferred to Wife:
The entire Cherished Teddy Collection;
Wife's jewelry box, including all jewelry contained therein and specifically
including Wife's high school ring;
Wife's high school yearbooks and memorabilia;
Heather and Zachary's baby clothes;
Wife's pre-marital pictures and photo albums;
Half of the marital pictures and family videos;
All Christmas ornaments bought by Wife's parents for Heather and Zachary;
and
All Avon Christmas ornaments.
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Page 8 of15
TSFJ/FJ
II
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SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.AT.LAW
26 W. High Street
Carlisle, P A
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(7)
INTANGIBLE PERSONAL PROPERTY:
Each party hereto
hereby relinquishes any right, title or interest he or she may have in or to any intangible
personal property currently titled in the name of or in the possession of the other party,
including, but not limited to, stocks, bonds, insurance, bam, accounts, individual retirement
accounts, employment benefits, including retirement accounts, savings plans, pension plans,
stock plans, 401K plans, and the like.
Wife acknowledges that the marital property of the parties includes any marital
portion of Husband's retirement account through Seligman. The approximate value of
Husband's retirement account as of December 31,1999 was Six Thousand Fifty-One and
45/100 ($6,051.45) Dollars, all of which was vested. See Account Statement dated January
I, 1999 through December 31, 1999, which is attached hereto as Exhibit "A" and is
incorporated herein by reference. Wife further acknowledges that she has been informed of
her right to obtain an independent appraisal of Husband's retirement, and any marital
interest therein.
Simultaneous with the execution of this Agreement, Wife shall receIve Two
Thousand Seven Hundred Fifty ($2,750.00) Dollars for any interest she may have in and to
Husband's retirement account. Said payment shall be made to Wife in the form of a
Cashier's Check. Upon receipt of the above-referenced payment, Wife shall forever waive
and relinquish any right, title, interest or claim she might otherwise have in and to
Husband's aforesaid retirement plan through Seligman.
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Page 9 of 15
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II
SAlOIS
SHUFF, FLOWER
& LINDSAY
AlTORNEVS'AT'UW
26 W. High Street
Carlisle. PA
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Husband acknowledges that the marital property of the parties includes any marital
portion of Wife's retirement account through Lear, Inc. At or around the date of separation,
the value of Wife's retirement account was minimal, no amount of which was vested.
Husband hereby forever waives and relinquishes any right, title, interest or claim he might
otherwise have in and to Wife's retirement plan through Lear.
(8) LIFE INSURANCE: To the extent that either party has a life insurance
policy(ies), each party shall retain their respective separate policies and will be permitted to
name anyone they wish as the designated beneficiary under their respective policies.
(9) WAIVER of ALIMONY: The parties acknowledge that each has income
and assets satisfactory to meet his and her own reasonable needs. Each party waives any
claim he or she may have, one against the other, for alimony, spousal support or alimony
pendente lite.
(10) ATTORNEY'S FEES:
Except as otherwise provided herein, each of
the parties waives the right to receive a payment for counsel fees from the other, and each
shall be responsible for his or her own counsel fees, costs and expenses, if such fees or
eX]Jenses are incurred.
(11) ADVICE of COUNSEL:
The parties hereto acknowledge and declare
that each has had a full and fair opportunity to obtain independent legal advice of counsel of
their selection; that Husband has been independently represented by Jane E. Adams,
Esquire, and that Wife has been independently represented by Lindsay Gingrich Maclay,
Esquire.
DBF~
Page 10 of 15
TSF J) j,
II
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS'AT'LAW
26 W. High Street
Carlisle, PA
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Each party acknowledges and accepts that this agreement is, under the
circumstances, fair and equitable, and that it is being entered into freely and voluntarily
after having received such advice and with such knowledge as each has sought from
counsel, and the execution of this agreement is not the result of any duress or undue
influence, and that it is not the result of any improper or illegal agreement or agreements.
(12) ADDITIONAL INSTRUMENTS: Except as othelWise herein provided.
each of the parties shall from time to time, at the request ofthe other, execute, aclmowledge
and deliver to the other party, within five (5) days of any request to do so, any and all
further instnl1llents that may be reasonably required to give full force and effect to the
provisions of this Agreement.
(13) INCOME TAX:
The parties hereto agree to file separate income tax
returns for all ongoing years, specifically including 2004 and 2005.
(14) BANKRUPTCY:
The parties hereby agree that the provisions of this
Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any
and all obligations contained herein. In the event a party files such bankruptcy and pursuant
thereto obtains a discharge of any obligations assumed hereunder, the other party shall have
the right to declare this Agreement to be null and void and to terminate this Agreement in
which event the division ofthe parties' marital assets and all other rights determined by this
Agreement, including alimony, shall be subject to court determination the same as if this
Agreement had never been entered into.
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Page 11 ofl5
TSF1A1.
II
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS'AT'LAW
26 W. High Street
Carlisle, P A
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(15) COMPLETE DISCLOSURE:
The parties do hereby warrant,
represent, acknowledge and agree that each is fully and completely informed of, and is
familiar with, the wealth, real and personal property, estate and assets, earnings and income
of the other and has made any inquiry he or she desires into the income or estate of the other
and received any such information requested. Each has made a full and complete disclosure
to the other of his and her entire assets, liabilities, income and expenses and any further
enumeration or statement thereof in this Agreement is specifically waived.
(16) WAIVER of APPRAISALS:
The parties acknowledge that they are
aware of their respective rights pursuant to the Pennsylvania Divorce Code to obtain formal
valuations or appraisals of the real estate, the personal property, the vehicles, retirement
accounts and businesses, some or all of which were acquired during the marriage and
therefore constitute marital property. However, the parties have determined that they will
not undertake the expense to have these items appraised and/or valuated, and that the
division of property as set forth in this agreement, represents a fair and equitable
distribution.
(17) RIGHTS and RESPONSIBILITIES: Husband and Wife acknowledge that
each of them has read and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no compulsion to do so but as
a voluntary act.
(18) FULL SETTLEMENT:
Except as herein otherwise provided, each
party hereby releases the other from any and all claims, or demands up to the date of
execution hereof. It is further specifically understood and agreed by and between the
parties hereto that each party accepts the provisions herein made in lieu of and in full
DBF ~ Page 12 of 15 TSF 1;1 ::;
Ii
1i
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT.LAW
26 W. High Street
Carlisle, PA
, - ~ ~ c. ' c"> ",' ": ,"'-_ c
'_"';: _' ~ , '- , '" I . __ "
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settlement and satisfaction of any and all of said party's rights against the other for past,
present and future claims on account of spousal support, maintenance, alimony, alimony
pendente lite, counsel fees, costs and expenses, equitable distribution of marital property
and any other claims of the party, including all claims which have been raised or may be
raised in an action for divorce.
(19) RELEASE of ALL CLAIMS:
Except as otherwise provided herein,
each party releases and discharges completely and forever the other from any and all right,
title, interest or claim of past, present or future spousal support, division of propeliy,
including income of gain from property hereafter accruing, right of dower or curtesy, the
right to act as administrator or executor of the estate of the other, the right to a distributive
share of the other's estate, any right of exemption in the estate of the other, or any other
property rights, benefits or privileges accruing to either party by virtue of their marriage
relationship, or otherwise, whether the same are conferred by statutory or common law of
the Commonwealth of Pennsylvania, or any other state, or of the statutory or common law
of the United States of America. Except as provided herein, the parties specifically waive
any and all rights that they may have to equitable distribution of marital property and/or
alimony and counsel fees, except those counsel fees sought in the event of a breach of this
Agreement, or any other marital rights as provided in the Pennsylvania Divorce Code, Act
26 of 1980 or any amendment thereto.
It is further specifically understood and agreed by and between the parties hereto,
that each party accepts the provisions herein made in lieu of and in full settlement and
satisfaction of any and all of said parties' rights against the other for any past, present and
DBF~
TSF :1)1.
Page 13 of 15
II
SAlOIS
SHUFF, FLOWER
& LINDSAY
AlTORNEYS-AT-LAW
26 W. High Street
Carlisle. PA
F" - ,.~ ,~ _ ""
J.:
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future claims on account of spousal support; maintenance; alimony; alimony pendente lite;
counsel fees, costs and expenses, except those counsel fees, costs and/or expenses sought in
the event of a breach of this Agreement; equitable distribution of marital property and any
other claims of each party, including all claims raised by them in the Divorce action to be
filed between the parties.
(20) SEPARABILITY of PROVISIONS:
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 provision shall be stricken from this
Agreement and in all other respects this agreement shall continue in full force, effect and
operation.
(21) GOVERNING LAW:
All matters affecting the interpretation of this
Agreement and the rights of the parties hereto shall be governed by the laws of the
Commonwealth of Pennsylvania.
(22) INCORPORATION into DIVORCE DECREE: The Parties agree that
this Agreement shall continue in full force and effect after such time as a final Decree in
Divorce may be entered with respect to the parties. Upon entry of the Decree, the
provisions of this Agreement shall be incorporated by reference or in substance, but they
shall not be deemed merged into such Decree. The Agreement shall survive any such
Decree in Divorce, shall be independent thereof, and the parties intend that all obligations
contained in this Agreement shall retain their contractual nature in any enforcement
proceedings, whether enforcement is sought in an action on the contract itself at law or in
equity, or in any enforcement action filed to the Divorce Caption.
DBF (tl/?J
TSF1JJ1.
Page 14 of 15
II
. "
'.
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT.LAW
26 w. High Street
Carlisle. P A
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(23) BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred to enforce the
Agreement, including, but not limited to, court cost and counsel fees of the other party. In
the event of breach, the other party shall have the right, at his or her election; to sue for
damages for such breach or to seek such other and additional remedies as may be available
to him or her.
(24) ENTIRE UNDERSTANDING:
This Agreement constitutes the entire
understanding between the parties and there are no covenants, conditions, representations,
or agreements, oral or written, of any nature whatsoever, other than those herein contained.
(25) AGREEMENT BINDING on PARTIES and HEIRS: It is understood
and agreed that not only the parties hereto, but also their heirs, administrators, executors and
assigns, shall be bound by all the terms, conditions and clauses of this Agreement.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound
hereby, have hereunto set their hands and seals to this Agreement the day and year first
above written.
WITNESS:
Jl~~
Drew B. Frank
.I
i
~~1.1/lM.J(
DBF~
TSF.l.J.L. ,
Page 15 of15
II
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INVESTORS FIDUCIARY TRUST CO TTEE
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DREW B. FRANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
v.
NO. 0\- ia35'
TAMMY SUE FRANK,
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 within twenty (20) days. 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 import to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary, Cumberland County Courthouse, One
Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
(717) 240-6200
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DREW B. FRANK, . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND CO'lJN'l'Y, PENNSYLVANIA
.
:
v. : NO. (3 (- 7:2'05
.
.
TAMMY SUE FRANK, . CIVIL ACTION - LAW
.
Defendant . IN DIVORCE
.
COMPLAIN'!' IN DIVORCE
UNDER SECTION 3301(aD OF THE DIVORCE CODE
1. plaintiff is DREW B. FRANK, an adult individual who
currently resides at 5 Ian Drive, Mt. Holly springs, Cumberland
County, Pennsylvania.
2. Defendant is TAMMY SUE FRANK, an adult individual who
currently resides at 405 Juniper Lane, Carlisle, Cumberland
County, Pennsylvania.
3. Both plaintiff and Defendant have been bona fide
residents in the Commonwealth for at lease six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 28,
1984 in Boiling Springs, Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
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7. Neither the Plaintiff or Defendant is a member of the
Armed Services of the United States or any of its Allies.
8. The Plaintiff avers that the ground on which the action
is based is that the parties have been separated for over two (2)
years.
9. Plaintiff avers that there are two children of the
parties under the age of eighteen (18).
WHEREFORE, Plaintiff requests this Honorable Court to enter
a decree in Divorce dissolving the marriage between the parties
pursuant to Section 3301(d) of the Divorce Code of 1980, as
amended.
DATE:
December 21, 2001
Respectfully submitted
CL~s~,>L~
2201 North Second Street
Harrisburg, PA 17110
717/233-4141
Attorney for Plaintiff
DOMESTIC/FRANK ,COM
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VERI:FI:CATI:ON
I, DREW B. FRANK, verify that the statements made in the
foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that any false
statements therein are subject to the criminal penalties
contained in 18 Pa. C.S. Section 4904, relating to unsworn
falsification to authorities.
!l4J~
DREW B. FRANK
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DREW B. FRANK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: No. 01 - 7235 Civil Term
TAMMY SUE FRANK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
]. A complaint in divorce under section 330](c) of the Divorce Code was filed on Oec.. J,f a..col.
)
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date ofthdiling and service of the Complaint.
3. ] consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of
the decree.
] 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: / D/S/o'f
~g~
Drew B. Frank, Plaintiff
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A,DIVORCE DECREE
UNDER &3301(c) AND &3301(d) OF THE DIVORCE CODE
]. ] consent to entry of a fmal decree of divorce without notice.
2. ] understand that] may lose rights concerning alimony, division of property, lawyer's fees or expenses
if] do not claim them before a divorce is granted.
3. ] understand that] will not be divorced until a divorce decree is entered by the Court and that a copy of
the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. ] understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities.
D.ate: lo(s-joi
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DREW B. FRANK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: No. 01 - 7235 Civil Term
TAMMY SUE FRANK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) ofthe Divorce Code was filed on December 28, 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 fmal decree of divorce after service of notice of intention to request entry of
the decree.
I verilY 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: /0 I fjk cj
~,~~ant?Mfil-
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER &3301(c) AND &3301(d) OF THE DIVORCE CODE
I. I consent to entry of a fmal 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 verilY 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 authori~es.
Date: 10) 5/ J t/
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DREW B. FRANK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: No. 01 - 7235 Civil Term
TAMMY SUE FRANK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ACCEPTANCE OF SERVICE
PURSUANT TO PA.R.C.P 4 02(B) AND PA.R.C.P. 1920.4
I, Tammy Sue Frank, Defendant in the above-captioned matter, hereby accepted service
of the Notice to Defend, and Complaint in Divorce, and Affidavit of Separation on or about
January 13, 2002. I hereby waive any and all defects in service ofthe aforementioned documents
or any amendments hereto.
Date: /Df~/o c../
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DREW B. FRANK, . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
. NO. 0/- 7;1&-
v.
.
.
TAMMY SUE FRANK, . CIVIL ACTION - LAW
.
Defendant . IN DIVORCE
.
NOTICE TO DEFENDANT
If you wish to deny any of the allegations set forth in this
Affidavit, you must file a counterclaim within twenty (20) days
after this affidavit has been served on you or the allegations
will be admitted.
AFFIDAVIT OF PLAINTIFF UNDER
SECTION 3301Cd) OF THE DIVORCE CODE
1. The parties to this action separated on September 4,
1999 and have continued to live separate and apart.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights, concerning
alimony, division of marital property, attorney's fees
or expenses if I do not claim them before a divorce is
granted.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE
TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND
BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO
UNSWORN FALSIFICATION TO
AUTHORtt~
Drew . Frank
DATED:
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DREW B. FRANK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: No. 01 - 7235 Civil Term
TAMMY SUE FRANK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Jane Adams, Esquire as Attorney of record for Drew
B. Frank, Plaintiff, in the above-captioned matter.
Date: ~ - J.S .0 'I
Adams, Esquire
LD No. 79465
36 South Pitt Street
arlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT'LAW
26 W. High Street
Carlisle, P A
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DREW B. FRANK,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-7235 CIVIL TERM AND
NO. 02-562 CUSTODY
PLAINTIFF
V5.
TAMMY S. FRANK,
DEFENDANT
IN DIVORCE
PRAECIPE TO WITHDRAW MY APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the Defendant, Tammy S. Frank
in the above captioned case.
Respectfully submitted,
Date: 114-#"2--
By:
PRAECIPE TO ENTER MY APPEARANCE
Please enter my appearance on behalf of the Defendant, Tammy S. Frank
in the above captioned case.
Respectfully submitted,
SAlOIS, SHUFF, FLOWER & LINDSAY
Date:
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