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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
PAM S. WENEUCK,
Plaintiff No.
VERSUS
JOSEPH R. WENERICK, JR.,
Defendant
DECREE IN
DIVORCE
AND NOW,_ A16 of, Lu 21 , 2000 , IT IS ORDERED AND
DECREED THAT PAM S. WENERICK
AND JOSEPH R. WE[Q MCK, JR.
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
, PLAINTIFF,
,DEFENDANT,
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;
BY THE COURT:
ATT T: J.
PR HONOTARY
NO. 1999-9516
"l'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Pam S. Wenerick,
Plaintiff
V.
Joseph R. Wenerick, Jr.,
Defendant
99-4516 CIVIL TERM
IN DIVORCE
SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
This Agreement made this f $6ay of r1fo v11, 6,,_„ , 2000 by and
between Pam S. Wenerick, .}« Siunel
Pennsylvania, party of the first part, hereinafter referred to as "Wife" and Joseph k-V 4,
Wenerick, 29 6teenulunt Drive, , Cumberland County, Pennsylvania, party of the
second part, hereinafter referred to as "Husband".
WITNESSETH: &dola- PA 170 2S10
WHEREAS, Husband and Wife were married on May 13, 1989 in Cumberland
County, Pennsylvania; and
WHEREAS, there is one minor child of this marriage, Kyle Wenerick, born
February 23, 1993; and
WHEREAS, Husband and Wife are residents of the Commonwealth of
Pennsylvania, and have been so for at least the past six months; and
WHEREAS, this Court has competent jurisdiction in the above-captioned divorce
action by virtue of the parties' domicile; and
WHEREAS, certain differences have arisen between the parties hereto and as a
consequence, they have lived separate and apart; and
WHEREAS, Husband and Wife desire to settle and determine certain of their
marital rights and obligations, and make an equitable distribution of their marital property,
determine their rights to alimony, support acid other matters which may be considered
under the Divorce Code; and
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WHEREAS, it is the intention and purpose of this Agreement to set forth the
respective rights and duties of the parties while they continue to live apart from each other
and to settle all financial and property rights between them; and
WHEREAS, the parties have mutually entered into an agreement for the division
of their jointly owned assets, the provision for the liabilities they owe, and the provision
for the resolution of their mutual differences, after both have had full and ample
opportunity to consult with attorneys of their respective choice, the parties now wish to
have that agreement reduced to writing.
NOW THEREFORE, the parties hereto in consideration of the mutually made and
to be kept promises set forth hereinafter and for other good and valuable consideration,
and intending to be legally bound and to legally bind their heirs, successors, assigns and
personal representatives, do hereby covenant, promise and agree as follows:
ARTICLE I
SEPARATION
It shall be lawful for Husband and Wife at all times hereafter to live separate and
apart from each other and to reside from time to time at such place or places as they shall
respectively deem fit, free from control, restraint, or interference, direct or indirect, by
each other. Neither party shall molest the other or compel the other to cohabit or dwell
with him or her by any legal or other proceedings. The foregoing provisions shall not be
taken to be an admission on the part of either Husband or Wife of the lawfulness of the
causes leading to them living separate and apart.
ARTICLE U
DIVORCE
2.1
This agreement is not predicated on divorce. It is specifically understood and
agreed by and between the parties hereto and each of the said parties does hereby warrant
and represent to the other that the execution and delivery of this Agreement is not
predicated upon nor made subject to any agreement for institution, prosecution, defense,
or for the non-prosecution or non-defense of any action for divorce, provided, however,
that nothing contained in this Agreement shall prevent or preclude either of the parties
hereto from commencing, instituting or prosecuting any action or actions for divorce,
whether absolute or otherwise, upon just, legal and property ground, nor to prevent either
party from defending such action which has been, may be or shall be instituted by the other
party, or from making any just or property defense thereto. It is warranted, covenanted,
and represented by Husband and Wife, each to the other that this Agreement is lawful and
enforceable and this warranty, covenant and representation is made for the specific
purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife
each knowingly and understandingly hereby waive any and all possible claims that this
Agreement is, for any reason, illegal or unenforceable in whole or in party. Husband and
Wife do each hereby warrant, covenant and agree that, in any possible event, he and she
are and shall forever be estopped from asserting any illegality or unenforceability as to all
or any part of this Agreement.
2.2
The parties acknowledge that a Divorce action has been filed in the Court of
Common Pleas of Cumberland County, Pennsylvania, at 99-4516 Civil Tenn.
2.3
It is further specifically understood and agreed that the provisions of this
Agreement relating to the equitable distribution of property of the parties are accepted by
each party as a final settlement for all purposes whatsoever. Should either of the parties
obtain a decree, judgment or order of separation of divorce in any other state, county, or
jurisdiction, each of the parties to this Agreement hereby consents and agrees that this
Agreement and all its covenants shall not be affected in any way by any such separation
and divorce, and that nothing in any such decree, judgment, order, or further modification
or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not
either or both of the parties should remarry, it being understood by and between the
parties that this Agreement shall survive and shall not be merged into any decree,
judgment, or order of divorce or separation.
2.4
It is specifically agreed that a copy of this Agreement may be incorporated by
reference into any divorce, judgment or decree if or whenever sought by either of the
parties hereto, such incorporation, however, shall not be regarded as a merger, it being the
intent of the parties to permit this Agreement to survive any such judgment or decree.
ARTICLE 111
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property in a manner that
conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code and
taking into account the following considerations: the length of the marriage, the prior
marriages of the parties, the age, health, station, amount and sources of income,
vocational skills, employability, estate, liabilities, and needs for each of the parties, the
contribution of one party to education, training, or increased earning power of the other
party, the opportunity of each party for future acquisition 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 marital property, including the contribution
of a party as a homemaker, the value of the property set apart to each party, the standard
of living of the parties established during their marriage, the economic circumstances of
each party, including federal, state, and local tax ramifications, at the time of the division
of the property is to become effective.
3.2
The division of existing marital property is not intended by the parties to constitute
in any way a sale or exchange of assets. The division of property under this Agreement
shall be in full satisfaction of all rights of equitable distribution of the parties.
3.4
Tangible Personal Property. Husband and Wife acknowledge that they have
divided their personal property to their mutual satisfaction including all furniture, jewelry,
automobiles, and other tangible property. Husband waives all right, title, and interest in all
personal property currently in the possession of Wife, and Wife waives all right, title, and
interest in all personal property currently in the possession of Husband.
3.5
Motor Vehicles. Husband agrees to transfer all right, title, and interest in the
parties' 1995 Chevrolet Metro unto Wife. Wife agrees shall to either have Mr.
Wenerick's name removed from the loan secured by said automobile, Members First,
account # 4, or obtain new financing and pay off said loan. The balance of said loan is
approximately $6,800.00. The transfer of the title into Mrs. Wenerick's name shall be
effectuated upon the satisfaction or refinancing of the loan.
Wife agrees to transfer all right, title and interest in the parties' 1998 Ford Taurus
unto Husband. This automobile is secured by a loan with Harris Savings Bank, account #
000008551002737, with a balance of approximately $11,021.31. This loan will remain in
both names until the above-referenced loan with Members First is satisfied or refinanced.
3.6
Pension/Benefits. Husband and Wife hereby agree to forever waive any and all
claims against the other for any interest in their life insurance policies, pensions, retirement
benefits, disability benefits and/or vacation pay.
ARTICLE IV
REALPROPERTY
The parties acknowledge that they were the owners of the real property located at
29 Greenmont Drive, Enola, Cumberland County, Pennsylvania. Said real property has
been sold and the mortgage, account # 0000093505285, with PNC Mortgage Company
has been satisfied. There were no material proceeds of said sale.
ARTICLE IV
DEBTS OF THE PARTIES
4.1
Husband and Wife shall remove each other from any joint accounts which include,
but are not limited to, checking, savings, and retirement accounts, and each release the
other from any obligations or claims on said accounts.
Husband agrees to be solely responsible for, and indemnify and hold Wife harmless
from the following joint debts:
Citibank Visa, # 4128-0023-2046-5136, approx. balance - $2,614.99
Citibank Mastercard, # 5424-1803-1543-8751, approx. bal. - $4,236.38
The aforementioned credit card account balances have been consolidated into one
account in Mr. Wenerick's name alone and the joint accounts have been closed. The new
credit card account, in Mr. Wenerick's name alone, is Citibank Mastercard #5141-1803-
1543-8751 with an approximate balance of $6,800.00.
Wife agrees to be solely responsible for, and indemnify and hold Husband harmless
from the following joint debts:
Discover, account # 6011-0024-2025-2520, approx, bal. $2,340.00
PNC Bank, account # approx. bal. $2,000.00
Members First Visa, account # 41214499-9117-4934, bal. $3,431.91
ARTICLE V
ALIMONY AND SUPPORT
5.1
Husband and Wife hereby waive any and all right to receive payments on account
of spousal support, maintenance, Alimony Pendente Lite, Alimony, counsel fees or costs
or any other payments of a similar nature to which he or she, in the absence of this
Agreement, might be entitled by statute including rights arising pursuant to the Divorce
Code of 1980 as amended, or similar law of any jurisdiction which may be applicable now
or at any future time.
ARTICLE VI
CHILD CUSTODY AND SUPPORT
The parties shall share physical and legal custody of their minor child: Kyle
Wenerick.
The subject minor child shall primarily reside with Husband but Wife shall have
unlimited visitation rights. The parties have deiced upon this arrangement based on
Husband's assertion that he shall continue to reside in the same school district where the
parties currently reside.
The parties agree to evenly divide all expenses for Kyle including but not limited to
medical, vision, dental, clothing, school activities, school supplies, and also any future
college expenses including loans, books, supplies and tuition.
Neither party shall seek child support from the other.
Both parties agree to cover Kyle Wenerick on their respective medical, dental and
vision insurance plans. The parties shall divide equally any uncovered medical, dental or
vision expenses for the subject minor child.
ARTICLE VII
MISCELLANEOUS PROVISIONS
7.1
Advice of Counsel. The provisions of this Agreement and their legal effect are
fully understood by the parties. The parties understand their legal rights and obligations.
Husband has been represented in this matter by Keith B. DeArmond, Esq., of Camp Hill,
Pennsylvania. Wife has been represented in this matter and by Mindy S. Goodman, Esq.
of Harrisburg, Pennsylvania.
The parties acknowledge and accept that this Agreement is, in the circumstances,
fair and equitable, that it is being entered into freely and voluntarily, after having received
such advice and with such knowledge that execution of this Agreement is not 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.
7.2
Counsel Fees. The parties agree that they will each be responsible for their
respective costs and attorney fees associated with this action.
7.3
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 times to
come and for all purposes whatsoever, of and from any and all rights, title, and interest, 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, or whatever nature and
wheresoever situate, which he or she now has or at any time hereafter against such other,
the estate of such other, or any part thereof, whether arising out of any former acts,
contracts, engagements, or liability of such other as 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
estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or
territory of the United States, or (c) any country, or any rights which either party may
have or at any time hereafter have for past, present, or future support or maintenance,
alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result
of the marital relation or otherwise, except and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for
the breach of any thereof. It is the intention of Husband and Wife to give each other by
execution of this Agreement a full, complete, and general release with respect to any and
all property of any kind or nature, real or 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 thereof.
7.4
Release of Testamentary Claims. Except as provided for in this Agreement, each
of the parties hereto shall have the rights to dispose of his or her property by Last Will and
Testament, or otherwise, and each of them agrees that the estate of the other, whether
real, personal or mixed, shall be and belong to the person or persons who would have
become entitled hereto as if the descendant had been the last to die. This provision is
intended to constitute a mutual waiver by the parties of any rights to take against each
other's last Will under the present or future laws of any jurisdiction whatsoever and is
intended to confer third party beneficiary rights upon the other heirs and beneficiaries of
each other party hereto. Either party, may, however, make such provisions for the other
as he or she may desire in and by his or her Last Will and Testament. Each of the parties
further covenants and agrees that he or she will permit any Will of the other to be
probated and allow administration upon his or her personal, real, or mixed estate and
effects to be taken out by the person or persons who would have been entitled to do so
had Husband or Wife died during the lifetime of the other and that neither Husband nor
Wife will claim against or contest the Will and the estate oaf the other. Each of the parties
hereby releases, relinquishes and waives any and all rights to act as executor or executrix
or administrator or administratix of the other party's estate. Each of the parties hereto
further covenants and agrees for himself and herself and his or her heirs, executors,
administrators and assigns, that he or she will never at any time hereafter sue the other
party or his or her heirs, executors, administrators, or assigns, for the purpose of enforcing
any of the rights relinquished under this Paragraph.
7.5
Warranties. Each party represents that he or she has not heretofore incurred or
contracted for any debt or liability or obligations for which the estate of the other party
may be responsible or liable, except as may be provided for in this Agreement. Each party
agrees to indemnify or hold the other party harmless from and against any and all such
debts, liabilities, or obligations of each of them, including those for necessities, except for
the obligations arising out of this Agreement. Husband and Wife each warrants,
covenants, represents, and agrees that each will, now and at all times hereafter, save
harmless and keep the other indemnified from all debts, charges, and liabilities incurred by
the other party after the execution date of this Agreement, except as is otherwise
specifically provided for by the terms of this Agreement and that neither of them hereafter
incur any liability whatsoever for which the estate of the other may be liable.
7.6
No waiver or modification of any of the terms of this Agreement 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 nature.
7.7
Husband and Wife 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 property implementation of this
Agreement, and as their respective counsel shall mutually agree should be so executed in
order to carry fully and effectively the terms of this agreement.
7.8
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of the execution of this
Agreement.
7.9
This Agreement shall be binding and shall inure to the benefit of the parties hereto
and their respective heirs, executors, administrators, successors, and assigns.
7.10
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.
7.11
Severabili . If any term, condition, clause, section, 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, section, 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 his or her
obligation under any or more of the articles and section shall in no way void or alter the
remaining obligations of the parties.
7.12
It is specifically understood and agreed that this Agreement constitutes an
equitable distribution of property, both real and personal, which was legally and
beneficially acquired by Husband and Wife, or either of them during the marriage as
contemplated by the Divorce Code of the Commonwealth of Pennsylvania.
7.13
Disclosure. The parties warrant and represent that they have made a full
disclosure of all assets prior to the execution of this Agreement.
7.14
Enforceability and Consideration. This Agreement shall survive any action for
divorce and decree of divorce and shall forever be binding and conclusive on the parties,
and any independent action may be brought, either at law or in equity, to enforce the terms
of the Agreement by either Husband or Wife until it shall have been fully satisfied and
performed. The consideration for this contract and agreement is the mutual benefits to be
obtained by both of the parties hereto and the covenants and agreements of each of the
parties of the other. The adequacy of the consideration for all agreements herein
contained and stipulated is confessed and admitted by the parties, and the parties intend to
be legally bound hereby. In the event either party breaches the aforesaid Agreement and it
is determined through appropriate legal action that the alleged parry has so breached the
agreement the breaching party shall be responsible for any and all attorneys' fees as well as
costs and expenses associated with litigation incurred by the non-breaching parry to
enforce this Agreement against the breaching party.
seph enerick Pam S. Wenerick
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PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-4516
CIVIL ACTION - LAW
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 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Certified Mail, Restricted
Delivery, Return Receipt Requested, received by Defendant on July 31, 1999, and
attached hereto as part of the record.
3. Date of execution of the affidavit of consent required by 3301(c) of the
Divorce Code: by Plaintiff _I I-I8-00 ; by Defendant I I-19-00
4. Related claims pending: NONE
5. Date Plaintiff's Waiver of Notice in 3301(c) Divorce was f i led with the
Prothonotary: _ 1L 18-00
Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary: 11-19-00
Respectfully submitted,
Date: 11 - 71 - ? & S C oo
Mindy S. Goodman, Esquire
I.D. No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
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PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q9
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may proceed without you and a decree
of divorce or annulment may be entered against you by the court. A 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 Office of the Prothonotary, Dauphin County
Courthouse, Front and Market Streets, Harrisburg, PA 17101.
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PAM S. WENERICK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
JOSEPH R. WENERICK, JR., : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICIA
Le han Demando a usted an la corte. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de
plazo al partir de la fecha de la demanda y la notfcacion. Usted deve presenter
una apariencia excrita o en persona o por abogado y archivar an to corte en
forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado qua si usted no se defiende, la corte tomara medidas y
puede entrar una Orden contra usted sin previo aviso o notificacion y por
cualquier queja o alivio que as pedido en la peticion do demanda. Usted puede
perder dinero o sus propiedades o otros derechos importanates para usted
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, PAM S. WENERICK, by her attorney,
Mindy S. Goodman, Attorney at Law, and seeks to obtain a decree in divorce
from the above-named Defendant, upon the grounds hereinafter set forth:
1. The Plaintiff, PAM S. WENERICK, is an adult individual who
currently resides at 29 Greenmont Drive, Enola, Cumberland County,
Pennsylvania, 17025.
2. The Defendant, JOSEPH R. WENERICK, JR., is an adult individual
who currently resides at 29 Greenmont Drive, Enola, Cumberland County,
Pennsylvania, 17025.
3. The Plaintiff and Defendant are sui juris, and both have been bona
fide residents of the Commonwealth of Pennsylvania for a period of more than
six months immediately preceding the filing of this Complaint.
4. The Plaintiff and Defendant were married May 13, 1989, in
Cumberland County, Pennsylvania.
5. The Plaintiff avers that there is one child born of the parties under
the age of 18, and his name and date of birth are as follows:
KYLE JOSEPH WENERICK Born February 23, 1993
6. The parties believe they will agree on a mutually acceptable
custody arrangement as well as an equitable division of marital assets and
Plaintiff anticipates no outstanding issues regarding these or other matters.
7. Neither Plaintiff nor Defendant is in the military or naval service of
the United States or its allies within the provisions of the Soldiers' and Sailors'
Civil Relief Act of the Congress of 1940 and its Amendments.
8. The cause of action and section of the Divorce Code under which
the Plaintiff is proceeding is:
23 Pa. Cons. Stat. § 3301(c) or, in the alternative, 23 Pa. Cons.
Stat. § 3301(d). The marriage of the parties is irretrievably broken.
9. There have been no prior actions of divorce or annulment between
the parties in this or any other jurisdiction.
10. Plaintiff has been advised of the availability of counseling and that
Plaintiff may have the right to request the parties to participate in counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree
in Divorce, divorcing Plaintiff and Defendant.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
Attorney I.D. No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in this Complaint in Divorce are true and
correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. Cons. Stat. § 4904, relating to unsworn falsification to
authorities.
DATE: Cw c
Pam S. Wenerick
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CERTIFICATE OF SERVICE
1, MINDY S. GOODMAN, Esquire, do hereby certify that on the 28th day of
July, 1999, I served a true and correct copy of a Complaint in Divorce upon the
Defendant, JOSEPH R. WENERICK, JR., by Certified Mail, Restricted Delivery,
Return Receipt Requested, and by depositing same in the United States First Class Mail,
postage prepaid, addressed as follows:
Mr. Joseph R. Wenerick, Jr.
29 Greenmont Drive
Enola, PA 17025
Said Complaint in Divorce was received by the Respondent on July 31, 1999.
BY:
Mindy S. Goodman, Esquire
Attorney No.: 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
ENDER:
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PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYLVANIA
NO. 1999-4516
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 33111(5) OF THE DIVORCE CODE
1. A Complaint in divorce under § 3301 (c) of the Divorce Code was filed on
July 26, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of the
Complaint.
3. 1 consent to the entry of a final decree of divorce without formal notice of
the intention to request entry of a divorce decree.
4. 1 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.
5. 1 understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the Decree will be sent to me immediately
after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties
of 18 Pa. Cons. Stat. § 4904, relating to unsworn falsification to
authorities.
Date: /1-19 `J, S k ,l D J OJ` A Il
Pam S. Wenerick
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PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYLVANIA
NO. 1999-4516
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(c OF THE DIVORCE COD
A Complaint in divorce under § 3301 (c) of the Divorce Code was filed on
July 26, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of the
Complaint.
3. 1 consent to the entry of a final decree of divorce without formal notice of
the intention to request entry of a divorce decree.
4. 1 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.
5. 1 understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the Decree will be sent to me immediately
after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties
of 18 Pa. Cons. Stat. § 4904, relating to unsworn falsification to
authorities.
Date: C1//Z ? lw;P41
eph R. enerick, Jr.
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PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-4516
CIVIL ACTION - LAW
IN DIVORCE
Plaintiff provides the Court with the following information in accordance
with the laws of the Commonwealth of Pennsylvania:
Plaintiffs Social Security Number is 189-62-4453.
Defendant's Social Security Number is 204-48-3580.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PF.NNSYI.VANIA
Pam S. Wenerick, No. 994516 Civil
Plaintiff
V.
CIVIL ACTION - LAW
Joseph R. Wenerick, Jr.
Defendant IN DIVORCE
PRAEC.IPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY-
Kindly enter the appearance of Keith B. DeArmond, Esq. as counsel for Defendant
in the above captioned matter.
Respectfully submitted,
Keith B. DeArmond, Esq
Attorney for Plaintiff
DeArmond k DeArmond
2800 Market Street
Camp Hill, PA 17011
717-730-9394
Supreme Ct. I.D. No. 58878
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PAM S. WENERICK,
Plaintiff
V.
JOSEPH R. WENERICK, JR.
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-4516
CIVIL ACTION - LAW
IN DIVORCE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
PAM S. WENERICK, being duly sworn according to law, deposes and
says that she is the Defendant in the above-captioned divorce action in which a
final decree from the bonds of matrimony was entered and she hereby elects to
resume her prior surname of PAM S. RUDY and, therefore, gives this written
notice avowing said intention, in accordance with #704 of the Act of November
15, 1972, P.L. 1063, 54 PA. C.S.A. 704.
Vham2a ) \?S. Wenerick
To be known as
PaY~, RA4
Pam S. Rudy
Sworn and subscribed to
Before me this 514-L day of
`D? =- , 2000
Notary Public
WARIAL SEAL
MAVO'r1 GOODMAN, NOTARY PURI.N;
HARRISBURG DAUPHIN COUNTY, PA.
MYCULIM11ISSION E%PIRES MAY 21, 2001
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