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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNSYLVANIA
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N ()......521.5 ........ ................. 1999
DECREE IN
DI V 0 R C E AND NOW, .... 7 . " G. ,..3, . , , . , , .. , , -)a d f , it is ordered and
decreed that ........ , ,James R. Tritt plaintiff,
and .................. Deanna J. Tritt
......................... 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. The parties have executed a Marriage
Settlement Agreement dated June 6, 2001, which Agreement has been
filed of record at the within term and number, and which Agreement
.............................
....,
.Js incorporated in this final Decree in Divorce but is not merged
gre;L;1................
.............................
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this v? day of_ ?n.L 2001, by
I' and between JAMES R. TRITT, of East Pennsboro Township, Cumberland County,
Pennsylvania, hereinafter referred to as "Husband", and DEANNA J. TRITT, of the
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j Borough of New Cumberland, Cumberland County, Pennsylvania, hereinafter referred to
I
as "Wife."
WITNESSETH:
WHEREAS, Husband and Wife were married on May 18, 1957, in Fairfax,
Minnesota, and separated from each other in or about April, 1991; and,
WHEREAS, differences have arisen between Husband and Wife in consequence
of which they are living separate and apart from each other; and
WHEREAS, Husband and Wife have made a full disclosure of their assets to each
other; and,
WHEREAS, Husband and Wife desire to settle and determine their rights and
obligations with respect to each other, including the disposition and distribution of property
rights and interests, as well as spousal support,
NOW, THEREFORE, the parties intending to be legally bound hereby, do
covenant and agree:
1. SEPARATION. It shall be lawful for each party at all times hereafter to
continue to live separate and apart from the other party at such places as he or she may
from time to time choose 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, nor in any way interfere with the peaceful
existence, separate and apart from the other.
3. WIFE'S DEBTS. Wife represents and warrants to Husband that since the
separation she has not and in the future she will not contract or incur any debt or liability
for which Husband or his estate might be responsible and shall indemnify and save
harmless Husband from any and all claims or demands made against him by reason of
debts and obligations incurred by the Wife prior to the date of the delivery of this
Agreement, and all further debts incurred by the Wife from and after the date of delivery
hereof, shall be the Wife's individual responsibility.
4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since
the separation he has not and in the future he will not contract or incur any debt or liability
for which Wife or her estate might be responsible and shall indemnify and save harmless
Husband from any and all claims or demands made against her by reason of debts and
2
obligations incurred by the Husband prior to the date of the delivery of this Agreement, and
all further debts incurred by the Husband from and after the date of delivery hereof, shall
be the Husband's individual responsibility.
5. JOINT DEBTS. The parties acknowledge and agree that they have no items
of joint indebtedness.
6. MUTUALRELEASE. Subject to the provisions of this Agreement, each party
has released and discharged, and by this Agreement does for himself or herself, and his
or her heirs, legal representatives, executors, administrators, and assigns, release and
discharge the other of and from all causes of action, claims, rights, or demands,
whatsoever in law or equity, which either of the parties ever had or now has against the
other, except any or all cause or causes of action for divorce and except for any or all
causes of action for breach of any provision of this Agreement.
7. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree
that they have made a full and complete disclosure to the other of all information pertaining
to the parties' separate and marital property owned, possessed and/or controlled by the
other at the time of the separation of the parties.
8. DIVISION OF PERSONAL PROPERTY. During the course of their
marriage, the parties have acquired certain memorabilia and antiques, as well as furniture
and other articles of household belongings which they had utilized in theirjoint occupancy
of their marital home. The parties agree to the division between themselves of the
aforementioned personal property, as follows:
3
A. Attached hereto, identified as Exhibit A, and incorporated herein by
reference, is a two-page listing of "Fire Memorabilia." Wife agrees that these
articles, heretofore removed from the marital home by Husband, shall be and
remain the sole and separate property of Husband.
B. Attached hereto and identified as Exhibit B is a two-page listing of
articles entitled "Collectibles, 509 9" Street, New Cumberland", some of which
articles are identified by a circle, and some of which are uncircled. Wife agrees that
the uncircled items, plus the circled item known as "Victorian Chair (Bobby
Kepford)", shall be the sole and separate property of Husband, and may be
removed by Husband from the marital home within thirty (30) days following the
date of the execution of this Agreement. Those items which are circled upon Exhibit
B shall remain in the marital home and shall be and become the sole and separate
property of Wife.
C. As to all of the items of tangible personal property identified upon
Exhibits A and B, whether the same be the sole and separate property of Husband
or the sole and separate property of Wife, shall be identified in a Last Will and
Testament which each of the parties shall draft and sign and which they shall
bequeath, as each sees fit, to one or more of their four children.
D. All other items of personal property, including furniture, which the
parties have acquired during the course of their marriage, Husband agrees shall be
4
from this day forward the sole and separate property of Wife, and shall be
unaffected by the provisions of sub-item C. of this paragraph.
9. BANK ACCOUNTS. The parties have heretofore closed theirjoint checking
accounts and savings accounts and each has established for himself or herself such
checking accounts and savings accounts as each desires to maintain. Such separate
savings accounts and checking accounts of each party shall be and remain the sole and
separate asset of the party in whose name such accounts are titled. Any sums remaining
in the joint banking accounts of the parties maintained at Allfirst Bank and Belco shall,
upon satisfaction by Husband of the immediate cash payments required under the terms
of this Agreement, be and become the sole and separate property of Husband.
10. AUTOMOBILES. Each party is the owner of an automobile and each
agrees that the owner and possessor of an automobile in his or her name shall be and
remain the sole and separate owner thereof.
11. REAL PROPERTY. The parties are the joint owners of real estate
known as 509 9th Street, New Cumberland, Cumberland County, Pennsylvania. The
parties agree that the aforementioned property shall become the sole and exclusive
property of Wife. Husband shall join with Wife in the execution of a special warranty deed
transferring sole and complete ownership of said real estate to Wife alone. Said deed shall
be executed concurrently with the execution of this Agreement. As he has heretofore
done, Husband shall pay all costs of utility services associated with the occupancy of 509
s
91h Street through the end of the month during which this Agreement has been executed
by the parties; such payment to include Husband having paid the calendar year (County
and Borough) real estate taxes upon the property, having paid the homeowner's insurance
premium through the end of the current renewal date, and Husband having paid any utility
charges associated with the real estate through at least the end of the month during which
the parties have executed this Agreement.
12. CASH PAYMENT. Husband agrees that upon the execution of this
Agreement, Husband will pay to Wife, as further equitable distribution, the cash sum of
Eight Thousand ($8,000.00) Dollars.
13. RETIREMENT ACCOUNTS. As a result of his years of employment as
an electrician, and his membership in various electrical workers' unions and for various
electrical contracting employers, Husband has become vested in several pension, annuity
or retirement accounts. Wife hereby waives any past, present or future interest in any of
said pension retirement accounts, specifically, the National Electrical Benefit Fund, the
International Brotherhood of Electrical Workers Pension, and the International Brotheihood
of Electrical Workers, Local No. 143 Pension Fund, and, agrees that, if such should be
deemed necessary by any of the sponsors of the aforementioned pension/retirement plans,
she shall execute any document appropriate to evidence her relinquishment of any interest
therein.
Notwithstanding the foregoing, Wife has already been designated by
Husband as being entitled to receive a monthly survivor benefit under the National
6
Electrical Benefit Fund and the International Brotherhood of Electrical Workers, Local No.
143 Pension Plan, and Husband agrees that Wife shall continue to be irrevocably
designated as being entitled to receive a joint survivor pension from both of such funds in
the event of his death prior to the death of Wife.
Nothing herein shall be construed to deprive Wife of any entitlement she may
have to the receipt of Social Security benefits arising by reason of her long-term marriage
to Husband.
14. SPOUSAL SUPPORT ALIMONY PENDENTELITE COUNSEL FEES AND
EXPENSES. Both parties hereby waive and relinquish any right which each or either of
them may have to seek or to receive from the other party the payment of any sums of
money as spousal support, alimony pendente lite, or provision for the payment of any
counsel fees and expenses associated with any action in divorce, except such payments
as Husband may otherwise be required to make pursuant to paragraph 11 of this
Agreement. Husband acknowledges that he has caused to be instituted the presently-
pending action in divorce in the Court of Common Pleas of Cumberland County at Civil
Action No, 99-5215, and agrees that he, alone, shall be responsible for payment of his
attorneys' fees and all Court costs associated with said divorce action.
15. PERMANENT ALIMONY. Husband shall pay to Wife, commencing on the
first day of the first month following the issuance of a Decree in Divorce by the Court of
7
Common Pleas of Cumberland County, the cash sum of Eight Hundred ($800.00) Dollars
per month, as permanent alimony. Said alimony payments shall not be modifiable but shall
terminate upon the death of either Husband or Wife.
16. IMPLEMENTATION OF AGREEMENT. Except for those items herein
provided to be accomplished contemporaneous with the execution of this Agreement, the
parties agree that all other provisions contained in this Agreement shall be accomplished
no later than thirty (30) days following the execution of this Agreement and each of them
agrees to sign all documents contemplated by the terms of this Agreement, and will
perform all acts otherwise contemplated by the terms of this Agreement, which are
necessary to provide for the transfer, distribution or utilization of any asset intended to be
utilized for the purposes herein contained, or to be transferred to one or the other of the
parties under the terms of this Agreement.
17. BREACH. If either party breaches any provision of this Agreement, the other
party shall have the right, at his or her election, to sue for damages for such breach, and
the party breaching this contract should be responsible for payment of legal fees and costs
incurred by the other in enforcing their rights under this Agreement, or seek such other
remedies or relief as may be available to him or her.
18. ENTIRE AGREEMENT. This Agreement contains the entire understanding
of the parties and there are no representations, warranties, covenants or undertakings
other than those expressly set forth herein.
8
19. MODIFICATION AND WAIVER. The modification or waiver of any of the
provisions of this Agreement shall be effective only if made in writing and executed with the
same formality as this Agreement. The failure of either party to insist upon strict
performance of anyof the provisions of this Agreement shall not be construed as a waiver
of any subsequent default of the same or similar nature.
20. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or
obligations of the parties.
21. INDEPENDENT SEPARATE COVENANT. It is specifically understood and
agreed by and between the parties hereto that each paragraph hereof shall be deemed to
be a separate and independent covenant and agreement.
22. APPLICABLE LAW. This Agreement shall be construed under the laws of
the Commonwealth of Pennsylvania.
23. VOIDCLAUSE. If any term, condition, clause, or provision of this Agreement
shall be determined or declared to be void or invalid in law or otherwise, then only that
term, condition, clause or provision shall be stricken from this Agreement, and in all other
respects this Agreement shall be valid and continue in full force, effect and operation.
24. ENTRY AS PART OF THE DECREE. Husband has initiated an action in
divorce under Section 3301(c) or 3301(d) of the Pennsylvania Domestic Relations Code,
filed in Cumberland County at Civil Action No. 99-5215. It is the intention of the parties that
9
the within Agreement shall survive the aforementioned action for divorce, and that no
i
order, judgment or decree, temporary or interlocutory, final or permanent, shall affect or
modify the financial terms of this Agreement. Both parties agree to execute Affidavits of
Consent for the purpose of entry of a Divorce Decree under Section 3301(c) of the
Pennsylvania Domestic Relations Code. This Agreement shall be made part of any such
judgment or decree of final divorce, but shall not be merged therein. Husband agrees to
provide to Wife, at his expense, a certified copy of the final Decree in Divorce.
25. VOLUNTARY EXECUTION. Husband acknowledges that Carl G. Wass, I,
Esquire, has served as legal counsel to him in connection with the pending divorce action
and in the preparation of this Marriage Settlement Agreement. Wife acknowledges that
Timothy J. Colgan, Esquire, has served as legal counsel to her in connection with the
pending divorce action and in the preparation of this Marriage Settlement Agreement. Prior
to the execution of this Agreement, copies thereof have been provided to both parties, and
each party has consulted with his or her respective attorney with regard to each and every
term contained herein, and has benefitted from the advice and counsel of their respective
attorneys. Both parties acknowledge and declare that each does understand the full legal
effect of this Agreement, especially with regard to the fairness and equitable nature of the
distribution of marital property between them and the waiver by each of them of any
spousal support, alimony, alimony pendente lite, and/or the payment of counsel fees and
10
Court costs. Both parties acknowledge that their execution of this Agreement has been
done voluntarily and knowingly and that their execution is not the result of any duress or
undue influence.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the
day and year first above written.
WITNESS:
23989
Ja sI ?R.<Tritt
Vl? 2
Deanna J. Tritt
11
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF SS:
On this, the. 6 AA day of J-4)nIG , 2001, before me,
a Notary Public, the undersigned officer, personally appeared JAMES R. TRITT, known to
me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary f?jibliC
NOTARIAL SEAL
NANCY L BMW, Nowy Pubk
Flenleburg, Nuphht Cft*
IMY Commioebn hea Mmdt 18, 2004
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF SS:
On this, the day of 2001, before me,
a Notary Public, the undersigned officer, personally appeared DEANNA J. TRITT, known
to me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
23989
Notarial," S. Dawn Gla"alter, Dillaburg earo, YMy Commission EpirMember, PennsylvaniaAssoriationotNoWies
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Exhibit A
Oct' V9
FIRE MEMORABILIA
NUMBER ITEM
1 Wooden Fire Truck Wall Clock
1 Tonka Metal Fire Truck -1970s
1 Metal Fire Bucket
3 Boxes Magazines
1 Nylint Fire Truck 70s
1 Tonka %snorkel Fire Truck 70s
3 Boxes Bottles
1 MSA NCFD Helmet Skullguard 70s
1 Cairns Model 770nHelmet - Yellow
1 Calms Model 900 Helmet - Yellow
1 Mirror Lounge Plastic Helmet Small
1 Critter Bank - Hand Painted Porcelain Dalmatian
1 Cap Tins 3" England
1 Wormleysburg Helmet MSA Plastic Black
1 Black Bunker Coat "Globe"
1 Miniature Revolving Red Light
1 Calms Model 900 Junior
2 8" Straight Tip Nozzles
1 Dow Hatan 1 % Nozzle Tip
1 Brass Fire Extinguisher
1 Copper Fire Extinguisher
1 Fire Extinguisher Musical Bottle
1 Fire Engine B.O. with Climbing Fireman
1 Hubley #402 Fire Engine
1 Hubley #468 Fire Engine (Missing Ladder & Dash Board)
1 Tonka Ladder 23 small
1 Tootsie Toy Fire Truck, Metal & Plastic 70s
1 Bump & Go Fire engine B/O
1 Buddy L Rescue Fire & Lights
1 6 Citgo Fire Pieces Prints
1 Fire Alarm Bell 8"
1 Fire Alarm Pull Station
6 Glasses International Association of Fire Chiefs 50"'
1 Tin Plate
1 Enesco Musical Mickey Mouse Fire Truck
1 Belt - Cumberland Fire Co - Carlisle
1 Ashtray - C H Dennis, Harrisburg Fire Truck
1 Plastic Fire hydrant 6 %_" high
1 Windup Fire Chief Car - Small 4" Long
vLr f/ .
Decanters
Little Tower
Lionstone 1974 Fireman/Child
Lionstone IAF - AFL/CIO 1977
Jim Beam 1930 Model A Ford
Jim Beam Emergency Ambulance
Hoffman Mr. Lucky Series - Mr. Fireman 1976
Snorkel Fire Engine B/O
Remco Fire Department Set - 5 Piece -1990
Fire Rescue (Road Tough) 10-1/64"' Scale
Exhibit 8
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COLLECTIBLES
509 9s' St, New Cumberland
Glass Duds
Brass Kerosene Lamp (Table)
Cranberry & Clear blown decanter w/ stopper- painted flowers
Plate - 2 Bobwhites - Middleburg Bakery, G.C. Peters Prop., Middleburg, PA
Awn Plate - 2 Sandpipers - S. G. Kerstetter, Meiserville, PA
Plate - 2 Redbreasted Merganser -1918 Atlas China, NY - John James Audobon
1 Plate - 4 Mallard Ducks -1918 Atlas China, NY - John James Audobon
Blue Blown Vases - Painted White Angels - Mary Gregor type
' Blue Blown Vase - Ir high - 4 wh.,Alyellow daisies - Fluted top
Green etched glass Vase -10' high
Table Lamp - Tftr y type - White metal - made by Larkin
Square Oak 2 door"China Closet - 4 shelves
' Walnut Grandmothers Clack (not old)
Blue painted Desk - French style
Oak Washstand - 2 doors, 2 drawers complete
Oak Table -1 or 2 drawer night stand type
Victorian Marble Table - marble in 2 pieces
1 Drawer Table - 30' H x 20' W x 14'D - Turned legs
Ruby Flashed Glass marked Katheryn
Blue and White Plate -10" - Castle & Boat - Warwick
Medium Table Kerosene Lamp
Milk Mite Kerosene table lamp
Frosted Bitters Bottle - 4' high
Clear glass Chicken on the Nest (1 piece)
White glass chicken on the Nest
Fish Plate
Set Sugar & Creamer - Gold trim - Pressed glass
Shawnee #80 Pitcher - Grapes, peaches, cherries - Ivory, blue, pink/red
Sleepy Eye Vases (1 w/haidine)
#2 Sleepy Eye Pitcher
CIicEN CAm#VAL /j7oWd- (12o5,6)
3 Soda/Acid Fire Extinguishers
2 C02 Fire Extinguishers
3 Fireman's Decanters
2 Glass Fire Trucks
24 Glass & Pottery Fire Mugs & Glasses
1 Fire Hydrant Clock
1 Ceramic Fire Stein - Gray & White
1 ALF Model Plaster Fire Truck
Numerous Sprinkler Heads
1 Indian Tank - no hose
5 Boxes of Fire Magazines/books/catalogs/ephemera
10 Boxes of Records - 78's, 33-1/3s, 45s
's 1?.
I Box 8-Track Tapes
1 Box of Fire Calendars & ephemera
1 Fire Bunker Coat
100' IN Thinwell Conduit
40' '/.' Thinwell Conduit
10' 1 W Unistrut
10' '/: aluminum Conduit
10' 'Y.' Unistrut plus pieces
1 41 IN L x 8' W x 7/8' piece of Marble
1 Propane Burning Kit
1 Pabst beer advertising tight without light
Pabst & Schlitz signs
1 Miller beer Clock
1 Snap-On Clock
Schlitz Calendar
Wooden Rolling Pin.
Hand 8eatem -
Suck Saw
Victorian Chair (Bobby Kepford)
Oak Clothes Tree
Metal Porch Chair -Green
Boxes Royal Ruby Glass - Dinner plates, water glasses coffee cups, wine goblets,
bowls, dishes, punch bowl & cups & dipper
uby Flashed Glass - various souvenirs
Blue glassware -different size glasses p- • '
ichter Jugs - various sizes
5 Boxes Beer Can collection - Shells Beer
Black porcelain top Ice Cream Table
Oak Library Table
Oak Washstand (needs one door)
Trunk (pink)
Rye Woven Basket - medium
Display Case - 2 glass shelves - 61 x TH
Fire Hydrant - Red ceramic -14' H
Wall Covering - Company #10 - Framed - 2'x 2'_
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JAMES R. TRITT,
Plaintiff
vs.
DEANNA J. TRITT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5215
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry
of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) 330+(d"
of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the Complaint: September 9, 1998, by
acceptance of service by the Defendant.
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, June 22, 2001; by Defendant, June 18, 2001.
(b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d)
of the Divorce Code:
(2) Date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached:
(check one)
(a) Decree to be entered under 3301(d)(1)(i) of the
Divorce Code;
(b) Decree to be entered under 3301(c) of the Divorce
Code;
X (c) Not applicable. See Waiver filed.
6. Plaintiffs Social Security number: 210-26-7340
Defendant's Social Security number: 474-38-1972
7. The parties have executed a Marriage Settlement Agreement, dated June 6,
2001, which Agreement has been filed of record at the within term and number, and which
Agreement is requested to be incorporated in the final Decree in Divorce, but not merged
therein,
Date: ? Z 5 2 "
Attorney for (X) PI tiff
( ) Defendant
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JAMES R. TRITT,
Plaintiff
vs.
DEANNA J. TRITT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. (--C - Sa o
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 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, Room 101, Dauphin County Court House, Front and
Market Streets, Harrisburg, 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, PA 17013
(717) 249-3166
1503-1
JAMES R. TRITT,
Plaintiff
vs.
DEANNA J. TRITT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99. SLl?d Tzc
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR 3301(d)
OF THE DOMESTIC RELATIONS CODE
1. Plaintiff is James R. Tritt„ an adult individual who resides at 611 High Street,
East Pennsboro Township, Cumberland County, Pennsylvania, (Enola, Pennsylvania
17025).
2. Defendant is Deanna J. Trill, an adult individual who resides at 509 9ht Street,
New Cumberland, Cumberland County, Pennsylvania, 17070.
3. Both the Plaintiff and the Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendantwere married on May 18, 1957 in Fairfax, Minnesota.
5. There have been no prior actions in divorce or annulment between the parties
6. The Defendant is not a member of the armed forces of the United States or any
'
of its allies. ,
7. The Plaintiff avers that the marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the Court require the parties to participate in counseling. The
Plaintiff does not desire counseling.
9. Plaintiff avers that there are no children of the parties under the age of 18.
10. Plaintiff requests the Court to enter a Decree of Divorce.
CALDWELL & KEARNS
Date: 23 t ctBy:
Carl G. Was , Esquire
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
I. D. #07268
Attorney for Plaintiff
1492
VERIFICATION
I, JAMES R. TRITT, verify that the averments made in this Complaint are true and
correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to
unsworn falsification to authorities.
Date: Lac t?z /? /???
1
// James R. Tritt
1504-1
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JAMES R. TRITT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. No. 99-5215 CIVIL
DEANNA J. TRITT, CIVIL ACTION - LAW
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I do hereby accept service of and acknowledge receipt of a certified copy of the
Divorce Complaint in the above case.
Date:
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Deanna J. Tritt
1880-1
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JAMES R. TRITT,
Plaintiff
vs.
DEANNA J. TRITT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5215
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE UNDER
SECTION 33011c) OF THE DIVORCE CODE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on August 25, 1999.
2. Plaintiff acknowledges that a copy of the Complaint was served on Defendant
by means of Acceptance of Service on September 9, 1999.
3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed, both from the date of the filing of the Complaint, and from the
service of the Complaint.
4. 1 consent to the entry of a final Decree of Divorce without notice.
5. 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.
6. 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.
7. 1 have been advised of the availability of marriage counseling and understand
that I may request that the Court require counseling. I do not request that the Court
require counseling.
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. Section 4904 relating to unsworn falsification to authorities.
Dated: Juno Z.2 , Z o o
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Jam R. Tritt, Plaintiff
t?x
SS# 210-26-7340
99-439/25407
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JAMES R. TRITT,
Plaintiff
vs.
DEANNA J. TRITT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5215
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on August 25, 1999.
2. Defendant acknowledges that a copy of the Complaint was served by means
of Acceptance of Service on September 9, 1999.
3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed, both from the date of the filing of the Complaint, and from the
service of the Complaint.
4. 1 consent to the entry of a final Decree of Divorce without notice.
5. 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.
6. 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.
7. 1 have been advised of the availability of marriage counseling and understand
that I may request that the Court require counseling. I do not request that the Court
require counseling.
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. Section 4904 relating to unsworn falsification to authorities.
Dated: 6 ?8 0/
Deanna J. Tritt, D fendant
SS# 474-38-1972
99-439/25407
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