HomeMy WebLinkAbout99-03996
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THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
,....FRANCIS L....FROME
NT_,
__........
. _........ l? l). ...99-3996 ... .................
Plaintiff
_ .................... ..... _._......__._ ......
....
Versos
LORI E. FROMENT,
.... .
. _.. ... .___. ......._._._. i
.... Defendant
DECREE IN
DIVORCE
AND NOW, ......... !? ?... z !.... , 1997.... it is ordered and
decreed that . . . . . . . . FRANCIS L...FROMENT plaintiff,
................
and ................. LORI. E?. ................................ , defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered; NONE
This Agreement of September 10, 1999 is hereby incorporated into the
.........................................
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By The Court-/
Attest: J
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Prothonotary
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AGREEMENT
THIS AGREEMENT, made this /oI nay of Seftekpe r 1999
by and between FRANCIS L. FROMENT of Cumberland County,
Pennsylvania (hereinafter referred to as HUSBAND), and LORI L.
FROMENT of Cumberland County, Pennsylvania (hereinafter referred
to as WIPE),
WHEREAS, HUSBAND and WIFE w reyrlawfu2ly married on
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November 22, 1980 in Cumberland County, 8enunp4vnrri and;
WHEREAS, three (3) children were born of this marriage,
to wit: .27 /99
Michael, born November Xf, }aS6
Joshua, born NeaembuT-2T, 1983 o0ecember 90? 040
Michelle, born April 2, 1986
WHEREAS, diverse, unhappy differences, disputes and
difficulties have arisen between the parties and it is the
intention of WIFE and HUSBAND to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and property
rights and obligations as between each other, including without
limitation by specification: the settling of all matters between
them relating to the ownership and equitable distribution of real
and personal property; settling of all matters between them
relating to the past, present and future support, and alimony the
implementation of custody and visitation arrangements for the minor
children of the parties; and in general, the settling of any and
all claims by one against the other or against their respective estates.
NOW, THEREFORE, in consideration the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
hereby acknowledged by each of the parties hereto, WIFE and
HUSBAND, each intending to be legally bound, hereby covenant 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 party at
such place as he or she may from time to time chose or deem fit.
The foregoing provisions shall not be taken as an admission on the
part of either party of the lawfulness or unlawfulness of the
causes leading to their living apart.
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 or attempt to endeavor to molest the other, nor
compel the other to cohabit with the other, or in any way harass or
malign the other, por in any way interfere with their peaceful
existence, separate and apart and they agree that neither shall do
or say anything to the children of the parties at any time which
might in any way influence the children adversely against the other
party.
3. SUBSEQUENT DIVORCE: The parties hereby acknowledge
that HUSBAND has filed a Complaint in Divorce in Cumberland County
to docket number 99-3996 claiming that the marriage is
irretrievably broken under the no-fault mutual consent provision of
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Section 3301(c) of the Pennsylvania Divorce Code. WIFE hereby
expresses her agreement that the marriage is irretrievably broken
and expresses her intent to execute any and all aff idavits or other
documents necessary for the parties to obtain an absolute divorce
pursuant to Section (c) of the Divorce Code at the earliest
appropriate time. The parties hereby waive all rights to request
Court-ordered counseling under the Divorce Code. It is further
specifically understood and agreed by the parties that the
provisions of this Agreement as to equitable distribution of
property of the parties are accepted by each party as a final
settlement for all, purposes whatsoever, as contemplated by the
Pennsylvania Divorce Code.
Should a decree, judgment or order of separation or
divorce be obtained by either of the parties in this or any other
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state, country or jurisdiction, each of the parties hereby consents
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and agrees that this Agreement and all of its covenants shall be
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not affected in any way by any such separation or divorce; and that
nothing in any such decree, judgment, order or further modification
or revision thereof shall alter, amend or vary any terms of this
Agreement, whether or not either or both of the parties shall
remarry. It is specifically agreed, that a copy of this Agreement
or the substance of,the provisions thereof, may be incorporated by
reference into any divorce, judgment or decree. It is the specific
intent of the parties to permit this Agreement to survive any
judgment and to be forever binding and conclusive upon the parties.
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4. DATE OF EXECUTION: The "date of execution" or I
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"execution date" of this agreement shall be defined as the date
upon which it is executed by the parties if they have each executed
the agreement on the same date. otherwise the "date of execution"
or "execution date"' of this agreement shall be defined as the date
of execution by the party last executing this agreement.
5. DISTRIBUTION DATE: The transfer of property, funds
and/or documents provided for herein, shall only take place on the
"distribution date" which shall be defined as specified herein.
6. MUTUAL RELEASE: HUSBAND and WIFE each do hereby
mutually remise, release, quitclaim and forever discharge the other
and the estate of such other, for all time to come, and for all
purposes whatsoever, of and from any and all rights, title and
interests, or claims in or against the property (including income
and gain from property hereafter accruing) of the other or against
the estate of such other, of whatever nature and wheresoever
situation, which he or she now has or at any time hereafter may
have against the other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts,
engagements or liabilities of such other or by way of dower or
curtesy, or claims in the nature of dower or curtesy or widow's or
widower'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 (a) Pennsylvania, (b) any State, Commonwealth or
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territory of the United States, or (c) any country, or any rights
which either party may have or at any time hereafter shall have for
past, present or future support or maintenance, alimony, alimony
pendente lite, counsel fees, property division, costs or expenses,
whether arising as a result of the marital relations or otherwise,
except, all rights and agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or for the
breach of any provisions thereof. It is the intention of HUSBAND
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1 and WIFE to give to each other by the execution of this Agreement
a full, complete and general release with respect to any and all
property of any kind or nature, real, personal or mixed, which the
other now owns or may hereafter acquire, except and only except all
rights and agreements and obligations of whatsoever nature arising
or which may arise under this Agreement or for the breach of any
f provision thereof. It is further agreed that this Agreement shall
be and constitute a full and final resolution of any and all claims
which each of the parties may have against the other for equitable
division of property, alimony, counsel fees and expenses, alimony
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pendente lite or apy other claims pursuant to the Pennsylvania
Divorce Code or the divorce laws of any other jurisdiction.
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7. ADVICE OF COUNSEL: HUSBAND is represented by Judith
A. Calkin, Esquire. WIFE has been advised of her right to separate
counsel and being so advised she waives that right.
HUSBAND and WIFE accept that this Agreement is, in the
circumstances, fair and equitable and that it is being entered into
freely and voluntarily and that execution of this Agreement is not
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the result of any duress or undue influence and that it is not the
result of any collusion or improper or illegal agreement or
agreements. The parties further acknowledge that they have each
made to the other a full accounting of their respective assets,
estate, liabilities, and sources of income and that they waive any
specific enumeration thereof for the purpose of this Agreement.
Each party agrees that he and she shall not at any future time
raise as a defense or otherwise the lack of such disclosure in any
legal proceeding, involving this Agreement, with the exception of
disclosure that may have been fraudulently withheld.
8. JOINT DEBTS: HUSBAND will be solely liable for the
payment of the following joint debts:
Account Account # Balance Tyoe of Account
Gordon's Jeweler's 087300797344 $ 495 .35 Credit Card
Gordon's Jeweler's 088300787568 117 .66 Credit Card
Sallie Mae Servicing 035-44 -43 76 -1 1981 .29 Student loan
Student Loan 035-44-4376 555 .12 Student loan
Student Loan 035-44 -43 76 1179 .00 Student loan
Student Loan 035-44-4376 1821 .00 Student loan
AAFES DPP 601944000092688 1643 .40 Credit Card
Sears 0363496213648 1132 .01 Credit Card
Members First 54385 Loan 07 1377 .76 Unsecured Loan
Members First 54385 Loan 08 6065 .56 Used Vehicle
Lowe's 82222390003386 715 .89 Credit Card
Meineke 731743010 486 .27 Credit Card
Kay Jewelers 3026672303 118 .33 Credit Card
Chrysler Financial 1143223923110 7263 .94 Auto Loan
WIFE will be solely liable for the payment of t he following debts:
NorWest Financial 27428369 1766. 51 Loan
Loves 82221391022122 544. 39 Credit Card
WIFE will be solely liable for all utilities in her
individual name on the home located at 5 Woods Drive,
Mechanicsburg, Pennsylvania that have accrued up to September 1,
1999.
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Each party indemnifies and saves harmless the other party
for and against the debts they have assumed as outlined above.
9. WARRANTY AS TO FUTURE OBLIGATIONS: WIFE and HUSBAND
each covenant, warrant, represent and agree that with the exception
of obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable. Each party shall indemnify and hold
harmless the other party for and against any and all debts, charges
and liabilities incurred by the other after the execution date of
this Agreement, except as may be otherwise specifically provided
for by the terms of this Agreement.
10. PERSONAL PROPERTY: The parties hereto have divided
between themselves, to their mutual satisfaction, all items of
tangible and intangible marital property. WIFE shall be the sole
owner of all items in Exhibit "A°. HUSBAND will be the sole owner
of all other items located in the marital home.. Neither party
shall make any claim to .any other such items of marital property,
or to the separate personal property of either party. Should it
become necessary, the parties each agree to sign, upon request, any
titles or documents necessary to give effect to this paragraph.
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 that item shall be that party's
sole and separate property.
11. PENSION AND RETIREMENT: HUSBAND has been an active
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member of the armed forces and is currently an active member of the
reserve. HUSBAND and WIFE agree that WIFE will receive pursuant
to a Qualified Domestic Relations Order, 50% of HUSBAND'S military
pension which accrued from the date of the marriage (November 22,
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1980) until Gtr $, 1999. HUSBAND and WIFE agree that HUSBAND
will not select a survivor's annuity when the pension goes into pay
status. WIFE acknowledges that site understands that she will begin
to receive her portion of HUSBAND'S pension when it goes into pay
status.
12. LIFE INSURANCE: HUSBAND and WIFE agree to name
their children as irrevocable beneficiaries on any life insurance
policy they receive as an employee benefit until the youngest child
reaches the age of twenty-two (22).
13. COLLEGE: FATHER and MOTHER acknowledge the
importance of a college education, and they agree to contribute to
the children's post high school training based on their respective
incomes at the point when the child begins post high school
education. Expenses are defined as tuition, room and board and
books and fees. The child shall apply for all available loans and
scholarships.
14. MOTOR VEHICLES: HUSBAND shall be the sole and
separate owner of the 1996 Plymouth Breeze and the 1992 Chrysler
Town and Country Van. HUSBAND will be solely liable for the
payment of any loans on these vehicles and will refinance said
liens within six (6) months of the execution of this Agreement.
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WIFE will execute a Limited Power of Attorney transferring her
interest in the vehicles to HUSBAND which will be released to
HUSBAND when the liens are put into HUSBAND'S name alone.
15. REAL ESTATE: HUSBAND and WIFE own, by the entireties
a home located at 5 Woods Drive, Mechanicsburg, Cumberland County,
Pennsylvania. The mortgage on said home exceeds its fair market
value. WIFE agrees to transfer to HUSBAND all her right, title and
interest in said home. HUSBAND agrees to be solely liable for the
payment of the mortgage on said home due GMAC which has an
outstanding balance of approximately $102,800.00, and he
indemnifies and saves harmless WIFE for an against said debt. WIFE
agrees to vacate the marital home no later than Seger 1, 99.
HUSBAND agrees to refinance the mortgage removing WIFE'S name no
later than two (2) years from the date of execution of this
agreement.
16. AFTER ACQUIRED PERSONAL PROPERTY: Each of the
parties shall hereafter own and enjoy, independently of any claims
or right of the other, all items of personal property, tangible or
intangible, hereafter acquired by him or her, with full power in
him or her to dispose of the same as fully and effectively, in all
respects and for all purposes, as though he or she were unmarried.
17. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS:
The parties hereby agree and express their intent that any transfer
of property pursuant to this Agreement shall be within the scope
and applicability of the Deficit Reduction Act of 1984 (herein the
"Act"), specifically, the provisions of said Act pertaining to
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transfers of property between spouses or former spouses. The
parties agree to sign and cause to be filed any elections or other
documents required by the Internal Revenue Service to render the
Act applicable to the transfers set forth in this Agreement without
recognition of gain on such transfer and subject to the carry-over
basis provisions of said Act.
18. WAIVER OF ALIMONY PENDENTE LITE AND LEG&L FEES:
Each party hereby waives any right to alimony pendente lite. The
parties agree to be responsible for their own attorney's fees.
19. FULL DISCLOSURE: Each party asserts that she or he
has made a full and complete disclosure of all the real and
personal property of whatsoever nature and wheresoever located
belonging in any way to each of them, of all debts and encumbrances
incurred in any manner whatsoever by each of them, of all sources
and amounts of income received or receivable by each of parties,
and of every other fact relating in any way to the subject matter
of this Agreement. These disclosures are part of the consideration
made by each party for entering into this Agreement.
20. WAIVER OF ALIMONY: The parties herein acknowledge
that by this Agreement they have respectively secured and
maintained a substantial and adequate fund with which to provide
for themselves sufficient financial resources to provide for their
comfort, maintenance and support, in the station of life to which
they are accustomed. WIFE and HUSBAND do hereby waive, release and
give up any rights they may respectively have against the other for
alimony, spousal support or maintenance. It shall be from the
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execution of this Agreement the sole responsibility of each of the
respective parties to sustain themselves without seeking any
support from the other party.
21. INCOME TAX PRIOR 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.
22. CHILD CUSTODY: The parties will share legal custody
of the minor children. The parties agree that major decisions
concerning their children, including, but not necessarily limited
to, the children's health, welfare, education, religious training
and upbringing shall be made by them jointly, after discussion and
consultation with each other, with a view toward obtaining and
following a harmonious policy in the children's best interest.
Each party agrees not to impair the other party's rights to shared
legal custody of the children. Each party agrees not to attempt to
alienate the affections of the children from the other party. Each
party shall notify the other of any activity or circumstance
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concerning their children that could reasonably be expected to be
of concern to the other. Day to day decisions shall be the
responsibility of the parent then having physical custody. With
regard to any emergency decisions which must be made, the parent
having physical custody of the children at the time of the
emergency shall be permitted to make any immediate decisions
necessitated thereby. However, that parent shall inform the other
of the emergency and consult with him or her as soon as possible.
Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have
copies of any reports given to either party as a parent.
FATHER shall have primary physical custody of Michael and
Joshua. MOTHER will have primary physical custody of Michelle.
FATHER does not object to MOTHER and Michelle relocating outside
of Pennsylvania.
23. WAIVER OR MODIFICATION TO BE IN WRITING: No
modification or waiver of any of the terms hereof shall be valid
unless in writing and signed by both parties and no waiver of any
breach hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
24. M=AL COOPERATION: Each party shall, at any time
and from time to time hereafter, take any and all steps and
execute, acknowledge and deliver to the other party any and all
further instruments and/or documents that the other party may
reasonably require for the purpose of giving full force and effect
to the provisions of this Agreement.
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25. APPLICABLE LAW: This Agreement shall be construed
in accordance with the laws of the Commonwealth of Pennsylvania
which are in effect as of the date of execution of this Agreement.
26. AGREEMENT BINDING ON HEIRS: This Agreement shall be
binding and shall inure to the benefit of the parties hereto and
their respective he executors, administrators, successors and
assigns.
27. INTEGRATION: This Agreement constitutes the entire
understanding of the parties and supersedes any and all prior
agreements and negotiations between them. There are no
representations or warranties other than those expressly set forth
herein.
28. OTHER DOCUMENTATION: WIFE and HUSBAND covenant and
agree that they will forthwith execute any and all written
instruments, assignments, releases, satisfactions, deeds, notes or
such other writings as may be necessary or desirable for the proper
effectuation of this Agreement.
29. NO WAIVER ON DEFAULT: This Agreement shall remain
in full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the same, nor shall the waiver of any default
or breach of any provisions hereof be construed as a waiver of any
subsequent default or breach of the same or similar nature, nor
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shall it be construed as a waiver of strict performance of any
other obligations herein.
30. SEVERABILITY: If any term, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law or otherwise, then only that term,
condition, clause or 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. Likewise, the
failure of any party to meet her or his obligation under any one or
more of the paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way avoid or
alter the remaining obligations of the parties.
31. BREACH: If either party breaches any provisions of
this Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach or seek such other
remedies or 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.
32. HEADINGS NOT PART OF AGREEMENT: Any heading
preceding the text of the several paragraphs and subparagraphs
hereof are inserted solely for convenience of reference and shall
not affect its meaning, construction or effect.
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WIFE'S PERSONAL PROPERTY
EXHIBIT "A"
1. All of her clothes and jewelry.
2. Kitchen hutch.
3. Various other items.
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IN WITNESS WHEREOF, the parties hereto have set their
hands and seals this day and year first above written.
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Franci L. Froment
Lori L. Froment
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FRANCIS L. FROMENT,
Plaintiff
Vs.
LORI E. FRONENT,
Defendant
To the Prothonotary:
IN THE COURT OF c6mmON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3996
CIVIL ACTION-IN DIVORCE
Transmit the record, together with the following information, to the Court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section (x ) 3301 C ( ) 3301 D of the
Divorce Code. ( Check applicable code )
2. Date and manner of service of the complaint
Certified-restricted delivery July 12, 1999
3. ( Complete either paragraph (A) or (B) .)
(A) Date of execution of the affidavit of consent required by Section 3301 (C) of the divorce code:
By plaintiff 10/13/99 ; by defendant 10/13/99
(B) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (D) of the
Divorce Code:
(2) Date of filing and service of the plaintiff s affidavit upon the respondent
4. Related claims pending:
5. (Complete either (a) or (b).)
(A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy
of which is attached:
(B) Date plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary:
10/13/99
Date defendant's Wavier of Notice in § 3301 (c) Divorce was filed with the Prothonotary:
10/13/99
Attorney for ( x) Plaintiff
( ) Defendant
Prothm 49
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FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVA?IA
„s. No. 92 - 399 IF"
LORI E. FROMENT, CIVIL ACTION-IN DIVORCE
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
take prompt action.
You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be
entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property
or other rights important to you, including custody or
visitation of your children.
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 Court Administrator's Office, Cumberland County
Courthouse, Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMFFT 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
TRUE COPY FROM RECORD
in Testimony whereof, I here unto set my hand
and the seal of said Co at Carlisle, Pa.
ay a 1
rothonotary
FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. n
No. rf. _Y996 d,1 i 7-z"-
LORI E. FROMENT, CIVIL ACTION-IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
3301(c)
1. Plaintiff is FRANCIS L. FROMENT, who resides at 5
Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is LORI E. FROMENT, who resides at
5 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident in the
Commonwealth for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on
November 22, 1980 in Cumberland, North Carolina.
5. There has been no prior action for divorce or
for annulment between the parties.
6. The Defendant is not a full time member of the Armed
Forces.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availability of
marriage counseling and that he may have the right to request
the Court to require the parties to participate in
such rounseling. , Being so advised, Plaintiff does not
request that the Court require the parties to participate in
counseling prior to a Divorce Decree being handed down by the
Court.
WHEREFORE, the plaintiff prays your Honorable Court to
enter a Decree in Divorce from the bonds of matrimony.
Respect
al/e-z? Ixe fully submitted:?,??
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j,dAith A. Calkin, Esquire
torney for Plaintiff
2201 North Second Street
Harrisburg, PA 17110
(717) 238-2312
Commonwealth of Pennsylvania:
ss.
County of Dauphin
I verify that the statements made in this 3301 (c)
Divorce Complaint are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
L.
Date:
rancis, roment
Sworn and Subscribed
before me this dl'?'day
of Q-V'4, 1999.
Notary Public
NOTARIAL SEAL
ELLEN ROSENBLOOM No
Oami4 lay Ex Da Mm 82003
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I, Judith A. Calkin, do hereby certify that a true and
correct copy of the within 3301 (c) Divorce Complaint was mailed
at Harrisburg, PA., certified-restricted delivery, postage pre-paid
to the following person:
CERTIFICATE OF SERVICE
Lori E. Froment
5 Woods Drive
Mechanicsburg, PA 17055
Date: 151z?
Jud' h A. Calkin, Esq.
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FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYr VANIA
VS. NO. 99-3996
LORI E. FROMENT CIVIL ACTION-LAW
Defendant IN DIVORCE i
AFFIDAVIT OF SERVICE
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I, Judith A. Calkin, Esquire, deposes and says:
1. That she is an adult individual residing in Dauphin
County, Pennsylvania.
2. That on June 30, 1999, she sent by certified-
restricted mail, return receipt requesting from Harrisburg,
Pennsylvania (No. 081 035 622) the Divorce Complaint in the above
captioned case to:
Lori Froment
5 Woods Drive
Mechanicsburg, PA 17055
3. That on July 12, 1999, Lori Froment signed the
receipt (No. 081 035 622) which is attached to this affida?v7it.
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torney for Plaintiff
2201 North Second Street
Harrisburg, PA
(717) 238-2312
1.
• I also vAsh to receive the
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delivered.
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and lee is paid!;
g 8. SlgMW ' (AddMSSG r gent)
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to^.595.97.8-0179 Domestic Retum Receipt
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FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-3996
LORI E. FROMENT, CIVIL ACTION-LAW
Defendant IN DIVORCE
, AFFmAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on June 30, 1999.
2. The marriage of Plaintiff anti naf=nA.nh
irretrievably broken and ninety (90) days have elapsed from the
date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree in Divorce
after service of notice of intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn.falsification to authorities
Date : 14/9/` )
grancis`L. Froment
S. S. No. 0 :;s -Yy-`1376
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FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-3996
LORI E. FROMENT, CIVIL ACTION-LAW
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (c) OF THE DIVORCE CODE
1. I consent to entry of a final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
3. I understand that I will not be divorced until a
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.
4. I verify that the statement made in this Waiver are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unswworn falsification to authorities. /
DATE:
F ancis L. Froment
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FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 99-3996
LORI E. FROMENT, CIVIL ACTION-LAW
Defendant IN DIVORCE
AFMAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on June 30, 1999.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree in Divorce
after service of notice of intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
9
Date:
Lori E. Froment
S.S. No., 4l . °_c/??y
1.
C.I
,j
FRANCIS L. FROMENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99-3996
LORI E. FROMENT, CIVIL ACTION-LAW
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (c) OF THE DIVORCE CODE
1. I consent to entry of a final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
3. I understand that I will not be divorced until a
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.
4. I verify that the statement made in this Waiver are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
DATE: rl " ( LC-rlu c J
on E. From nt
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