HomeMy WebLinkAbout99-04580
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNSYLVANIA
..JEFFREY...R..... BEYRENT .......................................
P aintiff
1 .................................... it CIVIL TERM
Versus
SHERI L. BEYRENT,
........ .... _ ........................Def.en.dant...............I ..
DECREE IN
DI V 0 R C E
19 99
AND NOW, ..........4!??? 19.99..., it is ordered and
..............
decreed that ... JEFFREY, R., ,BEYRENT ......................... plaintiff,
and ...... ,SHERI L. BEYRENT . . . . . ... . . . . . ... . ... . .... . . .. . . 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;
The provisions of the Marital Settlement Agreement entered int
Between the parties s hall .be incorporated into the decree in*aivorc
but..sha1Y],.: not .be..deemed . merged ........................................
By T e Cour
............ ...'..........._..... . ................... ........
Attest:
....... ....CCU
Prothonotary
4F 40. 4* .414 4p 40 . 4* 4tr..
4*1 4*
ii
i/ /5 99 Al
AGREEMENT
BETWEEN
JEFFREY R. BEYRENT
AND
SHERI L. BEYRENT
Cara A. Boyanowski, Esquire Sheri L. Beyrent, Wife
Counsel for Husband Pro Se
TABLE OF CONTENTS
SECTION I:
Introduction 3
SECTION II:
General Provisions 4
SECTION III:
Child Custody, Child Support, Tax Deductions, Alimony, and Alimony Pendente Lite
Provisions 10
SECTION IV:
Property Distribution Provisions I 1
SECTION V:
Closing Provisions and Execution 13
SECTION I
INTRODUCTION
THIS AGREEMENT made this q d l- day of OVP.fY1bPK 1999, by and
between JEFFREY IL BEYRENT ("Husband") and SHERI L, BEYRENT ("Wife").
WITNESSETH:
WHEREAS, Jeffrey R Beyrent, Social Security Number 206-54-2670, was born on March
22, 1961, and currently resides at 119 North 27th Street, Camp Hill, Cumberland County,
Pennsylvania 17011.
WHEREAS, Sheri L. Beyrent, Social Security Number 172-60-3190, was born on March
12, 1965, and currently resides at 2608 Chestnut Street, Camp Hill, Cumberland County,
Pennsylvania 17011.
WHEREAS, the parties hereto are Husband and Wife, having been married on January 20,
1989, in Carlisle, Cumberland County, Pennsylvania.
WHEREAS, the parties are the parents of two minor children, namely, Cameron Beyrent,
born July 12, 1989, and Taylor Beyrent, born October 10, 1991.
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, the settling
of all matters between them relating to the ownership of real and personal property, the equitable
distribution of such property; the settling of all matters between them relating to the past, present and
future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the
settling of any and all claims and possible claims by one against the other or against their respective
estates.
NOW, THEREFORE, in consideration of the mutual promises, set forth herein and for other
good and valuable considerations, Wife and Husband, each intending to be legally bound hereby agree
as follows:
SECTION II
GENERAL PROVISIONS
1. MUT U LOMUNT DIVORC
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of
Section 3301(c) of the Divorce Code of 1980, as amended and will execute the documents necessary
to effectuate a divorce under those provisions concurrently with the execution of this Agreement.
2. EFFECT nF WY CC nsC ..
The parties agree that unless otherwise specifically provided herein, this Agreement shall
continue in full force and effect after such time as a final decree in divorce may be entered with
respect to the parties.
3. A RF.F.MF.NT TO BE INCORPOIZA rFD B iT NOT b
IH R D IN n]VogCIF,
The provisions of this Agreement may be incorporated by reference but shall not be deemed
merged into any judgment or decree for divorce obtained by either party. This agreement shall
survive any such final decree of divorce, shall be entirely independent thereof, and the parties intend
that all obligations contained herein shall retain their contractual nature in any enforcement
proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement
action filed to the divorce complaint.
4. DATE OF EX ..UME
The "date of execution" or "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. ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to Husband
by his attorney, Cara A. Boyanowski, Esquire. Wife acknowledges that she has the right to legal
counsel but after acknowledgment of same has decided to sign this Agreement without the advice or
assistance of a lawyer. The parties acknowledge that they fully understand the facts and have been
fully informed as to their legal rights and obligations, and they acknowledge and accept that this
Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and
voluntarily and 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.
6. TAX PROVISIONS
The parties believe and agree, and have been so advised by their respective attorneys, that the
division of property heretofore made by this Agreement is a non-taxable division of property between
co-owners rather than a taxable sale or exchange of such property. Each party promises not to take
any position with respect to the adjusted basis of the property assigned to him or her or with respect
to any other issue which is inconsistent with the position set forth in the preceding sentence on his
or her federal or state 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.
7. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall
be free from any contact, restraint, interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or her may
seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the
respective families of each other nor compel or attempt to compel the other to cohabit or dwell by
any means whatsoever with him or her.
8. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
A. Each party hereby absolutely and unconditionally releases and forever discharges the
other and the estate of the other for all purposes from any and all rights and obligations which either
may have or at any time hereafter have for past, present or future support or maintenance, alimony
pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or
obligation, economic or otherwise, whether arising out of the marital relationship or otherwise,
including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and
amendments, as well as under any other law of any other jurisdiction, except and only except all
rights, agreements and obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the
other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges the
other and his or her heirs, executors, administrations, assigns, property and estate from any and all
rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the
parties or otherwise, whether now existing or hereafter arising. The above release shall be effective
regardless of whether such claims arise out of any former or future acts, contracts, engagements or
liabilities or the other or by way of dower, curtesy, widow's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to
treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state,
commonwealth or territory , or the United States, or any other country. It is expressly understood,
however, that neither the provisions of this release nor the subsequent entry of a divorce decree are
intended to defeat the right of either party to receive any insurance proceeds at the death of the other
of which she or he is the named beneficiary (whether the beneficiary designation was made prior or
subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest
or residuary portion of the others estate under his or her will, or to act as personal representative or
executor if so named by the will of the other, whether such will was executed prior or subsequent to
this Agreement.
C. Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations of the parties contained in this Agreement and such rights as are
expressly reserved herein, each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims, rights or demands
whatsoever, in law or in equity, which either party ever had or now has against the other.
9. FINANCIAL DISCLOSURE
The parties have disclosed to each other and they are each aware of the extent of each other's
income, assets, liabilities, holdings and estate. Each of the parties acknowledge that he or she is
aware of his or her right to seek discovery including, but not limited to, written interrogatories,
motions for production of documents, depositions and all other means of discovery permitted under
the Pennsylvania Rules of Civil Procedure. Each party is satisfied that no additional information is
necessary for the execution of this Agreement.
10. PRESERVATION OF RECORDS
Each party will keep and preserve for a period of four (4) years from the date of their divorce
decree all financial records relating to the marital estate, and each party will allow the other party
access to those records in the event of tax audits.
11. WAIVER OR MODIFICATION TO BE IN WR1TiNC
No modification or waiver of any of the terms hereof shall be valid unless in writing and
signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
M RE.MEDiE IN THE .VENT OF A BREACH
Any party breaching this Agreement shall be liable to the other party for all costs, including
reasonable counsel fees incurred by the non-breaching party to enforce his or her rights under the
provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of
whether litigation is instituted. In the event of default of any of the provisions of this Agreement by
one of the parties, the remedies available to the other are cumulative and include all remedies at law
and in equity, including those for breach of contract, under theories or equity, under the Domestic
Relations Code as amended, including Section 3105 of the Domestic Relations Code (which includes
contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies
specifically referred to in this Agreement.
13. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
14. AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors, and
assigns.
15. 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.
16. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will forthwith (within ten (10) days at most
after demand thereof) 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.
17. NO WAIVER OF D .FA .T
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 breach of any provision hereof be construed as a waiver
of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any
provision hereof be construed as a waiver of strict performance of any other obligations herein.
18. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be deemed
to be a separate and independent covenant and agreement. If any tens, condition, clause or provision
of this Agreement shall be detemuned 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 obligations under any one or more of the paragraphs herein,
with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the
remaining obligations of the parties.
19. MANNER OF GIVING NOTICE
Any notice required by this Agreement to be sent to Husband shall be sent by certified mail,
return receipt requested, to Jeffrey R. Beyrent, 119 North 27th Street, Camp Hill, Pennsylvania
17011, or counsel for Jeffrey R. Beyrent, or such other address as Husband from time to time may
designate in writing.
Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return
receipt requested, to Sheri L. Beyrent, 2608 Chestnut Street, Camp Hill, Pennsylvania 17011, or such
other address as Wife from time to time may designate in writing.
20. HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall
they affect its meaning, construction or effect.
SECTION III
CUSTODY, SUPPORT, ALIMONY,
AND INCOME TAX DEDUCTIONS
1. LEGAL CUSTODY
The parties agree that legal custody of their two children, Cameron Beyrent and Taylor
Beyrent, shall be shared equally between them to assure neither parent shall be foreclosed in
participating in all decisions affecting the maintenance, support, education, health, safety and welfare
of the children during their minority.
In addition to any provisions which may be contained herein regarding custody, both parties
shall have the following rights with respect to the children: reasonable telephone calling privileges;
access to report cards and other relevant information concerning the progress of the children in
school; approval of extraordinary medical and/or dental treatment provided that such approval shall
not be unreasonably withheld.
2. PHYSICAL CUSTODY
A. MWority Physical Custody - The parties agree that Wife shall have majority physical
custody of the parties' two minor children.
B. Peal Phi sicat 9.Qdy - Husband shall have periods of liberal partial custody of the
parties' two minor children, as agreed between the parties.
3. CHILD SUPPORT
Husband agrees to pay to Wife the sum of Three Hundred Twenty-Five ($325.00) Dollars per
month as child support. This payment shall be made no later than the 15th of each month. Husband
agrees to be bound contractually to the child support payments due hereunder.
In addition to the basic duty of support as provided under the Pennsylvania Rules of Civil
Procedure, all reimbursed medical expenses shall be shared equally by the parents.
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4. INCOME TAX DEDUCTIONS (DEPENDENTS)
The parties agree that Wife shall be entitled to claim the parties' youngest child, Taylor
Beyrent, as a dependent on all of her future income tax returns. The parties agree that Husband shall
be entitled to claim the parties' oldest child, Cameron Beyrent, as a dependent on all of his future
income tax returns.
5. HEALTH INAN . .
The parties agree to provide health insurance for the children for so long as it is available to
them at no or minimal cost by each of their respective employers.
6. ALIMONY
The parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted
by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either
may now or hereafter have against the other for support, maintenance, alimony pendente lite or
alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to
seek from the other payment for support, maintenance, alimony pendente lite or alimony.
SECTION IV
PROPERTY DISTRIBUTION PROVISIONS
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs,
carpets, household equipment and appliances, pictures, books, works of art and other personal
property. Wife agrees that all of the property in the possession of Husband shall be the sole and
separate property of Husband; and Husband agrees that all of the property in the possession of Wife
shall be the sole and separate property of Wife. The parties do hereby specifically waive, release,
renounce and forever, abandon any claims which either may have with respect to the above items,
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which shall thereafter be the sole and exclusive property of the other.
2. BANK ACCOUNTS
Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that
these accounts shall be the sole and separate property of the person in whose name they are titled and
each party waives any right, title or interest they may have in the other parties' account.
3.
Husband and Wife are the owners of individual retirement/pension accounts through their
employers. Husband and Wife agree that these accounts shall be the sole and separate property of the
person in whose name they are titled and each party waives any right, title or interest they may have
in the other parties' account.
4. AUTOMOBILES
The parties are the owners of various automobiles including a 1990 Nissan Sentra and a 1985
Chevrolet Van. Husband and Wife agree that the 1990 Nissan Sentra shall be the sole and separate
property of Wife and Husband waives any right, title or interest he may have in this vehicle. Husband
and Wife agree that the 1985 Chevrolet Van shall be the sole and separate property of Husband, and
Wife waives any right, title or interest she may have in this vehicle.
The parties further agree to execute any and all documents necessary to effectuate the above
transfer of automobiles.
5. CURRENT LIABIIdTIES
Wife and Husband represent that they have taken all steps necessary to make sure that no
credit cards or similar accounts exist as of the date of execution of this Agreement which provide for
joint liability. From the date of execution of this Agreement, each party shall use only those credit
cards and accounts for which that party is individually liable.
Husband and Wife acknowledge that all joint debts have been satisfied in full. All liabilities
now existing shall be the sole responsibility of the party who incurred the liability.
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b. WAIVER OF PAYMENT OF LEGAL FEES
Each party hereby agrees to be responsible for any legal fees incurred on their behalf.
Each of the parties shall hereafter own and enjoy, independently of any claim or right of the
other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired
by him or her after execution of this Agreement, with full power in him or her to dispose of the same
as fully and effectively, in all respects and for all purposes, as through he or she were unmarried.
SECTION V
CLOSING PROVISIONS AND EXECUTION
Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals on the date indicated below.
less F Y .BEYRENT DATE
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W, SHERI L. BEYRE#T DATE
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JEFFREY R. BEYRENT,
Plaintiff
V.
SHERI L. BEYRENT,
Defendant
To the Prothonotary:
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
NO. 994580 CIVIL TERM
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: A copy of the Divorce Complaint was
served upon Defendant by certified mail, restricted delivery, return receipt requested
on August 5, 1999.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required by §3301(c) of
the Divorce Code: by Plaintiff: November 4, 1999; by Defendant: November 4,
1999.
(b)(1) Date of execution of the affidavit required by §3301(d) of the Divorce
Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the
respondent: N/A.
4. Related claims pending: None.
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: N/A.
(b) Da*.e Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: November 4, 1999.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with
the Prothonotary: November 4, 1999.
Respectfully submitted,
DALEY LAW OFFICES
Supreme Court I.D. No. 68736
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
Attorney for Plaintiff
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JEFFREY R. BEYRENT, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
V.
: NO. 99 °ysd'd ?lvi? 'L?'l
SHERI L. BEYRENT,
Defendant 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, Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo a] partir de ]a fecha de la
demands y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado
y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que 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 es 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 INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA
EN PERSONA O 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, Pennsylvania 17013
(717) 249-3166
JEFFREY R. BEYRENT,
Plaintiff
V.
SHERI L. BEYRENT,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
NO.
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR SECTION 3301(d)
OF THE DIVORCE CODE
AND NOW comes the above Plaintiff, Jeffrey R. Beyrent, by his attorney, Cara A.
Boyanowski, 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 , Jeffrey R. Beyrent, is an adult individual who resides at 119 North 27th
Street, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. The Defendant, Sheri L. Beyrent, is an adult individual who resides at 2608 Chestnut
Street, Camp Hill, Cumberland County, Pennsylvania, 17011.
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3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
at least six (6) months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 19, 1989, in Carlisle,
Cumberland County, Pennsylvania.
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5. The Plaintiff and Defendant are both citizens of the United States of America.
6. There have been no prior actions in divorce between the parties.
7. The Plaintiff and Defendant are not members of the Armed Services of the United
States or any of its allies.
8. Plaintiff has been advised of the availability of counseling and that he may have the
right to request that the Court require the parties to participate in counseling.
9. The causes of action and sections of Divorce Code under which Plaintiff is rroceeding
are:
A. Section 3301(c). The marriage of the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an Affidavit.
B. Section 3301(d). The marriage of the parties is irretrievably broken.
The Plaintiff and Defendant separated on March 23, 1999.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from
the bonds of matrimony.
I verify that the statements made in this Complaint are true and correct. I understand that
Use statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn
falsification to authorities.
Date: 2G
By: *JeyReyrent, Plaintiff
B:
ara A. Boyanowski, squire
Attorney No. 68736
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Attorney for Plaintiff
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JEFFREY R. BEYRENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
NO. 99-4580 CIVIL TERM
SHERI L. BEYRENT,
Defendant IN DIVORCE
A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
July 29, 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.
I consent to the entry of a final decree of divorce after service of notice of intention
to request entry of the decree.
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.C.S.A. §4904 relating to unswom
falsification to authorities.
Date: 11-4-99 By IL4 Sheri L. Beyrent, Def ndant
SocialsecurityNo. / W - 66 - S/ 90.
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JEFFREY R. BEYRENT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
NO. 994580 CIVIL TERM
SHERI L. BEYRENT,
Defendant IN DIVORCE
A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
July 29, 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.
I consent to the entry of a final decree of divorce after service of notice of intention
to request entry of the decree.
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.C.S.A. §4904 relating to unworn
falsification to authorities.
Date: 11-4-99 By: ;,L e
AW3fBeyrent, Plaintiff
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JEFFREY R. BEYRENT,
Plaintiff
V.
SHERI L. BEYRENT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4580 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER §33010 OF THE DIVORCE CODE
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 herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom
falsification to authorities.
Date: 11-4-99 By. Id /-'r
J &4y R. Beyrent, Plaintiff
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JEFFREY R. BEYRENT,
Plaintiff
V.
SHERI L. BEYRENT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 994580 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301,(C) OF THE DIVORCE CODE
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 herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom
falsification to authorities.
Date: 11-4-99 By: & K6C
Sheri L. Beyrent, De endant
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JEFFREY R. BEYRENT, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
V.
NO. 99-4580 CIVIL TERM
SHERI L. BEYRENT,
Defendant IN DIVORCE
Cara A. Boyanowski, Esquire, being duly swom according to law, deposes and says that she
is an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on
the 5th day of August, 1999, she did serve upon Sheri L. Beyrent, the Defendant in the foregoing
case, a true and correct copy of the Complaint in Divorce by sending same to her, by certified mail,
restricted delivery, to her last known address of 2608 Chestnut Street, Camp Hill, Pennsylvania
17011. The receipt for said Complaint is attached.
Said copy of the Complaint was duly endorsed with notice to Defendant to appear and answer
or the matter would proceed without her.
Swom to an ubscribed before me this
day of
61A ? 1999
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Loww Paxbn Twp.. Dauphin Comity g M I/) ff? JA A I
NOTARIAL SEAL i
PATE" A. PATTON. Notary Puour.
Cw mission Ekpiros JuP ar 20., )
By
ara A. Boyanowski, q.
Attorney No. 68736
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
Attorney for Plaintiff
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7. Date of De .yam
5. Received By. (flint Noma) B. Addressee's Address's ( Hrequested ,
and fee is Ps/d)
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a ps Form 3817. Decem t984 mm -o"-0sse Domestic Retum Receiot