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NO.........: - ..................19 99
DECREE IN
DI V 0 R C E
AND NOW . ............ ./1.,??ry . ?('„ L4Oe it is ordered and
decreed that , Janet L. Fazzini . , . , , , • , , plaintiff,
. J. Faz. zini .
and . . . . .....Lawrence .
............................................ defend
. ant,
are divorced from the bonds of matrimony.
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IN THE COURT OF COMMON FLEAS
OF CUMBLERLAND COUNTY
STATE OF -, PENNA.
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;
This agreement of December 5, 1999 is hereby incorporated
...........................................................................
into the final divorce decree.
i
By The! ourt:
Attest
rothonotary
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this _SIday of December, 1999, by and
between JANET L. FAZZINI, hereinafter referred to as "Wife", and
LAWRENCE J. FAZZINI, hereinafter referred to as "Husband".
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on April 6,
1991; and
WHEREAS, on May 27, 1999, Wife filed a complaint in divorce
against Husband at the Cumberland County Court of Common Pleas,
docketed at 99-3124;
WHEREAS, certain differences have arisen between the parties
as a result of which they have separated and now live separate and
apart from one another, and are desirous, therefore, of entering
into an Agreement which will provide for equitable distribution of
their marital property, and for their mutual responsibilities and
rights growing out of the marriage relationship; and
WHEREAS, Husband, after having been informed of his legal
right to counsel and the benefits of having legal representation
has decided to proceed without counsel to review this property
settlement agreement.
WHEREAS, Wife has retained Clayton W. Davidson, Esquire to
represent herself only. Husband understands that Clayton W.
Davidson, Esquire, has only rendered services to Wife and has not
represented Husband in any manner.
WHEREAS, Husband and wife have come to the following
agreement:
NOW, THEREFORE, in consideration of the above recitals and the
following covenants and promises mutually made and mutually to be
kept, the parties heretofore, intending to be legally bound and to
legally bind their heirs, successors and assigns thereby, covenant,
promise and agree as follows:
1. SEPARATION:
It shall be lawful for each party at all times hereafter
to live separate and apart from the other at such place or places
as he or she may from time to time choose or deem fit.
2. INTERFERENCE:
Each party shall be free from interference, authority and
contact by the other, as fully as if he or she were single and
unmarried, except as may be necessary to carry out the provisions
of this Agreement. Neither party shall molest the other nor
attempt to endeavor to molest the other, nor compel the other to
cohabit with the other, nor in any way harass or malign the other,
nor in any way interfere with the peaceful existence, separate and
apart from the other in all respects as if he or she were single
and unmarried.
3. WIFE'S DEBTS:
Wife represents and warrants to Husband that since their
separation on May 27, 1999, she has not, and in the future she will
not, contract or incur any debt or liability for which Husband or
his estate might be responsible and shall indemnify and save
Husband harmless from any and all claims or demands made against
him by reason of debts or obligations incurred by her.
4. HUSBAND'S DEBTS:
Husband represents and warrants to Wife that since their
separation on May 27, 1999, he has not, and in the future he will
not, contract or incur any debt or liability for which Wife or her
estate might be responsible and shall indemnify and save wife
harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him.
5. OUTSTANDING JOINT DEBTS:
Husband and Wife acknowledge and agree that they have no
outstanding debts and obligations of the Husband and Wife incurred
prior to the signing of this Agreement other than those listed in
their joint bankruptcy court petition (No. 98-4702), totaling
$28,795.
6. MUTUAL RELEASE:
Subject to the provisions of this Agreement, each part
waives his or her right to alimony and any further distribution of
property inasmuch as the parties hereto agree that this Agreement
provides for an equitable distribution of their marital property in
accordance with the Pennsylvania Divorce Code of 1980, as amended.
Subject to the provisions of this Agreement, each party has
released and discharged, and by this Agreement does for himself or
herself, and his or her heirs, legal representatives, executors,
administrators and assigns, release and discharge the other of and
from all causes of action, claims, rights or demands whatsoever in
2
law or equity, which either of the parties ever had or now has
against the other, except any or all cause or causes of action for
divorce and except in any or all causes of action for breach of any
provisions of this Agreement. Each party also waives his or her
right to request marital counseling pursuant to Section 202 of the
Divorce Code.
7. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
The parties have attempted to distribute their marital
property in a manner which confirms to the criteria set forth in
Section 401 of the Pennsylvania Divorce Code, and taking into
account the following considerations: the length of the marriage;
the fact that it is the first marriage for both Husband and Wife,
the age, health, station, amount and sources of income, vocational
skills, employability, estate, liabilities and needs of each of the
parties; the contribution of each party to the education, training
or increased earning power of the other party; the opportunity of
each party for future acquisitions of capital assets and income;
the sources of income of both parties, including but not limited to
medical, retirement, insurance or other benefits; the contribution
or dissipation of each party in the acquisition, preservation,
depreciation or appreciation of the marital property, including the
contribution of each spouse as a homemaker; the value of the
property set apart to each party; the standard of living of the
parties established during the marriage; and the economic
circumstances of each party at the time the division of property is
to become effective.
The division of existing marital property is not intended
by the parties to constitute in any way a sale or exchange of
assets, funds or other property not constituting marital property.
The division of property under this Agreement shall be in full
satisfaction of all marital rights of the parties.
A. DISTRIBUTION OF PERSONAL PROPERTY:
In consideration of the full settlement of Wife's marital
rights and the other promises and covenants made in this Agreement,
Husband agrees to transfer his interest in the parties 1991
Atlantic Champion Mobile Home to Wife. Husband further agrees that
he will execute all paperwork necessary to effectuate this
agreement in a timely manner.
The parties also mutually agree that they have effected
a satisfactory division of the furniture, household furnishings,
appliances, 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 tangible personal
property presently in his or her possession, and this Agreement
3
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 s
possession of each of the parties hereto.
The parties hereto have divided between themselves, to
their mutual satisfaction, all items of tangible and intangible
marital property. Neither party shall make any claim to any such
items of marital property, or of the separate personal property of
either party, which are now in the possession and/or
control of the other. Should it become under the agree to sign necessary, the parties each
, upon request, any titles or documents necessary to
give effect to this paragraph. Property shall be deemed to be in
the possession or under the control of either party if, in the case
of tangible personal property, the item is physically in the
possession or control of the party at the time of the signing of
this Agreement and, in the case of intangible personal property, if
any physical or written evidence of ownership, such as passbook,
checkbook, policy or certificate of insurance or other similar
writing is in the possession or control of the party. Husband and
Wife shall each be deemed to be in the possession and control of
his or her own individual pension or other employee benefit plans
or retirement benefits of any nature with the exception of Social
Security benefits to which either party may have a vested or
contingent right or interest at the time of the signing of this
Agreement, and neither will make any claim against the other for
any interest in such benefits.
From and after the date of the signing of this Agreement,
both parties shall have complete freedom of disposition as to
his/her separate property and any property which is in their
possession or control pursuant to this Agreement and may mortgage,
sell, grant, convey, or otherwise encumber or dispose of such
property, whether real or personal, whether such property was
acquired before, during or after marriage, and neither Husband nor
Wife need join .in, consent to, or acknowledge any deed, mortgage,
or other instrument of the other pertaining to such disposition of
property.
B. RETIREMENT BENEFITS/PENSION
Neither Husband or Wife will transfer ownership of any
outstanding individual retirement account and/or pension benefit. I
Husband and Wife shall each be deemed to be in the sole possession
and control of his or her own individual pension or other employee
benefit plans or retirement benefits of any nature with the
exception of Social Security benefits to which either party may
have a vested or contingent right or interest at the time of the
signing of this Agreement, and neither will make any claim against
the other for any interest in such benefits.
B. ALIMONY:
No alimony will be paid by either the Husband to Wife or Wife
to Husband. Both parties agree to waive all claims or rights to
any alimony payments in light of the economic distribution of the
marital property that has been effectuated by this agreement.
COUNSEL FEES AND EXPENSE:
Husband and Wife acknowledge and agree that the
provisions of this Agreement providing for the equitable
distribution of marital property of the parties are fair, adequate
and satisfactory to them. Both parties agree to accept the
provisions set forth in this Agreement in lieu of and in full and
final settlement and satisfaction of all claims and demands that
either may now or hereafter have against the other for counsel fees
or expenses and maintenance before, during and after the
commencement of any proceedings for divorce or annulment between
the parties.
10. INCOME TAX RETURNS:
The parties have heretofore filed joint federal and state
tax returns. Both parties agree that in the event any deficiency
in federal, state or local income tax is proposed, or any
assessment of any such tax is made against either of them, each
will indemnify and hold harmless the other from and against any
loss or liability for any such tax deficiency or assessment and any
interest, penalty and expense incurred in connection therewith.
Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who is finally determined to be the
cause of the misrepresentations or failures to disclose the nature
and extent of his or her separate income on the aforesaid joint
returns.
11. WAIVERS OF CLAIMS AGAINST ESTATES:
Except as herein otherwise provided, each party may
dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now have
or hereafter acquire, under the present or future laws of any
jurisdiction, to share in the property or the estate of the other
as a result of the marital relationship, including without
limitation, dower, curtesy, statutory allowance, widow's allowance,
right to take in intestacy, right to take against the will of the
other, and right to act as administrator or executor of the other's
estate. Each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights and claims.
12. SUBSEQUENT DIVORCE:
Wife has filed a no-fault complaint in divorce against
Husband. Husband and Wife each agree to sign an affidavit of
consent and waiver of notice to be filed in said divorce action.
The parties further agree that each party will be responsible for
their respective attorney's fees. In the event such divorce action
is concluded, the parties shall be bound by all the terms of this
Agreement which may be incorporated by referenced into the Divorce
Decree, shall not be merged in such Decree, and shall not be
modified, but shall in all respects survive the same and be further
binding and conclusive upon the parties.
l h intention
of the shall survive any action for divorce which e may h be instituted e
or
prosecuted by either party and no order, judgment or decree of
divorce, temporary, final or permanent, shall affect or modify the
financial terms of this Agreement. This Agreement may be
incorporated in but shall not merge into any such judgment or
decree of final divorce, but shall be incorporated for the purposes
of enforcement only.
13. BREACH AND ENFORCEMENT:
If either party breaches any provision of this Agreement,
the other party shall have the right, at his or her election, to
sue for damages for such breach, or seek such other remedies or
relief as may be available to him or her, and the party breaching
this Agreement should be responsible for payment of legal fees and
costs incurred by the other in enforcing his or her rights under
this Agreement.
A. It is expressly understood and agreed by and between the
parties hereto that this Agreement may be specifically enforced by
either Husband or Wife in Equity, and the parties hereto agree that
if an action to enforce this Agreement is brought in Equity by
either party, the other party will make no objection on the alleged
ground of lack of jurisdiction of said Court on the ground that
there is an adequate remedy at law. The parties do not intend or
purport hereby to improperly confer jurisdiction on a Court in
Equity by this Agreement, but they agree as provided herein for the
forum of equity in mutual recognition of the present state of the
law, and in recognition of the general jurisdiction of Courts in
Equity over agreements such as this one.
B. Notwithstanding anything to the contrary herein, Husband
and Wife may also proceed with an action at law for redress of his
or her rights under the terms of this Agreement, and in such event
it is specifically understood and agreed that for and in specific
consideration of the other provisions and covenants of this
6
Agreement, each shall waive any right to a jury trial so as to
expedite the hearing and disposition of such case and so as to
avoid delay.
C. Each party further hereby agrees to pay and to save and
hold harmless the other party from any and all attorney's fees and
costs of litigation that either may sustain, or incur or become
liable for, in any way whatsoever, or shall pay upon, or in
consequence of any default or breach by the other of any of their
terms or provisions os this Agreement by reason of which either
party shall be obliged to retain or engage counsel to initiate or
maintain or defend proceedings against the other at law or equity
or both in any way whatsoever; provided that the party seeks to
recover such attorney's fees, and costs of litigation must first be
successful in whole or in part, before there would be any liability
for attorney's fees and costs of litigation. It is the specific
agreement and intent of the parties that a breaching or wrongdoing
party shall bear the burden and obligation of any and all costs and
expenses and counsel fees incurred by himself or herself as well as
the other party in endeavoring to protect and enforce his or her
rights under this Agreement.
14. ADDITIONAL INSTRUMENTS:
Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other
party any and all further instruments that may be reasonably
required to give full force and effect to the provisions of this
Agreement.
15. VOLUNTARY EXECUTION:
The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective
counsel, and each party acknowledges that the Agreement is fair and
equitable, that it is being entered into voluntarily, with full
knowledge of the assets of both parties, and that it is not the
result of any duress or undue influence. The parties acknowledge
that they have been furnished with all information relating to the
financial affairs of the other which has been requested by each of
them or by their respective counsel.
16. ENTIRE AGREEMENT:
This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein. Husband
and Wife acknowledge and agree that the provisions of this
Agreement with respect to the distribution and division of marital
and separate property are fair, equitable and satisfactory to them
based on the length of their marriage and other relevant factors
which have been taken into consideration by the parties. Both
parties hereby accept the provisions of this Agreement with respect
to the division of property in lieu of and in full and final
settlement and satisfaction of all claims and demands that they may
now have or hereafter have against the other for equitable
distribution of their property by any court of competent
jurisdiction pursuant to Section 401(d) of the Divorce Code or any
other laws. Husband and Wife each voluntarily and intelligently
waive and relinquish any right to seek a court ordered
determination and distribution of marital property, but nothing
herein contained shall constitute a waiver by either party of any
rights to seek the relief of any court for the purpose of enforcing
the provisions of this Agreement.
17. DISCLOSURE:
Husband and Wife each represent and warrant to the other
that he or she has made disclosure to the other party of the assets
necessary to enter this agreement.
The parties hereto acknowledge that they were aware of
their right to pursue discovery, including issuing interrogatories,
and with this knowledge, the parties have waived their right to
undertake discovery.
18. MODIFICATION AND WAIVER:
A modification or waiver of any of the provisions of this
Agreement shall be effective only if made in writing and executed
with the same formality as this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall not be construed as a waiver of any subsequent
default of the same or similar nature.
19. PRIOR AGREEMENT:
It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the
date and time of this Agreement are null and void and of no effect.
20. DESCRIPTIVE HEADINGS:
The descriptive headings used herein are for convenience
only. They shall have no effect whatsoever in determining the
rights or obligations of the parties.
21. INDEPENDENT SEPARATE COVENANTS:
8
It is specifically understood and agreed by and between
the parties hereto that each paragraph hereof shall be deemed to be
a separate and independent covenant and agreement.
22. APPLICABLE LAW:
This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
23. VOID CLAUSES:
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 be valid and continue in full force,
effect and operation.
24. AGREEMENT BINDING ON HEIRS:
This Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs,
executors, administrators, successors, and assigns.
IN WITNESS WHEREOF, the parties hereto have set their hand and
seals the day and year first above written.
Clayton W. Davidson, Attorney
for Janet L. Fazzini
QielNcz 42:= (SEAL )
Ja t L. Fazzini, f
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Lawrence Jv Fa zini, (Witness)
Husband, pro-se
9
JANET L. FAZZINI,
Plaintiff
V.
LAWRENCE J. FAZZINI,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99 - 3124
Civil Action - Divorce
Transmit the record, together with the following information,
to the court for entry of the appropriate divorce decree:
1. Ground for divorce: Irretrievable breakdown under
section 3301(C) of the Pennsylvania Divorce Code.
2. Date and manner of service of complaint: The Complaint
was filed on May 27, 1999, and was served on Lawrence J. Fazzini,
via United States, first class, certified mail, Restricted
delivery, return receipt requested on June 3, 1999. Plaintiff
contends that 90 days have elapsed from the date of the filing and
service of the complaint.
3. Date of execution of the affidavit of consent: by
Plaintiff December 8, 1999; by Defendant December 12, 1999.
4. Date of waiver of notice of intention to request entry of
a divorce decree: by Plaintiff December 8, 1999; by Defendant
December 12, 1999.
5. Related Economic Claims Pending: There are no economic
claims pending and distribution of all personal and real property
has been settled by agreement of the parties. Enclosed is the
parties marriage settlement agreement which should be incorporated,
but not merged, into the divorce decree.
Respectfully Submitted,
Clayto W. Davidson, Esquire
Attorney I.D.# 79139
2201 North Second Street
Harrisburg, PA 17110
(717)-233-4141
Date: January 6, 2000 Attorney for Plaintiff
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A
JANET L. FAZZINI, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
V. No 3.21Y of 1999
LAWRENCE J. FAZZINI,
Defendant Civil Action - Divorce
NOTICE TO DEFEND AND CLAIM OF RIGHTS
You have been sued in court.
If you wish to defend against
the claims set forth in the COMPLAINT herein, 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 may be entered against
you for any other claim of relief requested in these papers by the
Plaintiff. You may lose money or property or other rights
important to you.
WHEN THE GROUND FOR 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 AT THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE,
PENNSYLVANIA.
If you do not file a claim for alimony, division of marital
property, lawyers fees or expenses before the final decree 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
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717)-240-6200
JANET L. FAZZINI, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
V. No. 99.3.,11/ of 1999
LAWRENCE J. FAZZINI,
Defendant Civil Action - Divorce
COMPLAINT IN DIVORCE
The Plaintiff, Janet L. Fazzini, by and through her attorney,
Clayton W. Davidson, Esquire, hereby files this complaint against
the Defendant, Lawrence J. Fazzini, and hereby avers the following:
1. The Plaintiff, Janet L. Fazzini, is an adult individual
residing at 8 Hidden Noll Road, Carlisle, Pennsylvania, 17013,
Cumberland County.
2. The Defendant, Lawrence J. Fazzini, is an adult
individual whose last known residence was 20 E Pomfret Street,
Carlisle, Pennsylvania, Cumberland County.
3. The Plaintiff and Defendant were married on April 6, 1991
in Carlisle, Pennsylvania.
4. The Plaintiff has been a bona fide resident of the
Commonwealth of Pennsylvania at least six (6) months immediately
prior to the filing of this Complaint.
5. There has been no prior action for divorce or annulment
of marriage between the parties in this or in any other
jurisdiction.
6. Neither party is a member of the armed services.
COUNT I
IRRETRIEVABLE BREAKDOWN OF MARRIAGE
7. The Plaintiff incorporates herein, by reference, the
allegations set forth in paragraphs 1 through 6 of this Complaint.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised of the availability of
marriage counseling and she may have the right to request the Court
to require the parties to participate in marriage counseling.
WHEREFORE, the Plaintiff requests that your Honorable Court
enter a Decree of Divorce under section 3301(c) or 3301(d) of the
Pennsylvania Divorce Code.
Respectfully Submitted,
Clay on W. Davidson
2201 North Second Street
Harrisburg, PA 17110
(717)-233-4141
I.D.# 79139
Attorney for Plaintiff
Date: May 26, 1999
VERIFICATION
I, Janet L. Fazzini, Plaintiff, hereby verify that the
facts contained in the foregoing Complaint in Divorce are true and
correct to the best of my knowledge, information and belief. I
understand that false statements herein are subject to the those
criminal penalties contained in 18 Pa.C.S.A. §4904, relating to
unsworn falsification to authorities.
JANIUA. FAZZINI a /g ?
Date:
JANET L. FAZZINI, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
V. No. 99-3214
LAWRENCE J. FAZZINI,
Defendant Civil Action - Divorce
AFFIDAVIT OF SERVICE
I,, Clayton W. Davidson, Esquire, being dulv sworn according to
law, depose and state that service of the Complaint in Divorce in
the above-captioned matter was served by certified mail, restricted
delivery, on the Defendant, Lawrence J. Fazzini, at 20 East Pomfret
Street, Carlisle, PA 17013 on June 3, 1999. The original certified
receipt is attached hereto as Exhibit "A".
Respectfully Submitted,
C
Clayto W. Davidson, Esquire
Attar ey I.D.# 79139
2201 North Second Street
Harrisburg, PA 17110
(717)-233-4141
Attorney for Plaintiff
Date: June 7, 1999
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Exhibit A
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JANET L. FAZZINI, . IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
V. No. 99-3124
LAWRENCE J. FAZZINI,
Defendant Civil Action - Divorce
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under section 3301(C) of the
Pennsylvania Divorce Code was filed on May 27, 1999.
2. The marriage of the Plaintiff and Defendant is
irretrievably broken and ninety (90) days elapsed from the date of
filing 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, lawyers fees or expenses if I do not claim
them before a divorce is granted.
5. I hereby waive my rights to marriage counseling.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements made herein are
made subject to the penalties of 18 Pa.C.S. 54904 relating to
unsworn falsification to authorities.
JANE &,L. FAZZINI,
PLAI. TIFF
Date:
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JANET L. FAZZINI,
Plaintiff
V.
LAWRENCE J. FAZZINIr
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99-3124
Civil Action - Divorce
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements made herein are
made subject to the penalties of 18 Pa.C.S. 54904 relating to
unsworn falsification to authorities.
Q&tclAr,t--
JANELT/L. FAZZINI,
PLAINTIFF
Date:
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JANET L. FAZZINI, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY
V. No. 99-3124
LAWRENCE J. FAZZINI, ,
Defendant Civil Action - Divorce
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under section 3301(C) of the
Pennsylvania Divorce Code was filed on May 27, 1999.
2. The marriage of the Plaintiff and Defendant is
irretrievably broken and ninety (90) days elapsed from the date of
filing 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, lawyers fees or expenses if I do not claim
them before a divorce is granted.
5. I hereby waive my rights to marriage counseling.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements made herein are
made subject to the penalties of 18 Pa.C.S. 54904 relating to
unsworn falsification to authorities.
LAWRENCE J. (/FAZZINI/
Date: i L - 1 2 `r i
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JANET L. FAZZINI,
Plaintiff
V.
LAWRENCE J. FAZZINI,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99-3124
• Civil Action - Divorce
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements made herein are
made subject to the penalties of 18 Pa.C.S. 54904 relating to
unsworn falsification to authorities.
LAWRENCE J FAZZI
Date: i'2- ! 2 `/ L
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: January 6, 2000
DOCKET NUMBER: 99-3214
PLAINTIFF/PETITIONER SS# 208-42-3553
NAME: Janet L. Fazzini
DEFENDANT/RESPONDENT SS # 186-42-8000
NAME: Lawrence J. Fazzini