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HomeMy WebLinkAbout03-3520FRANCIlffE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 35,~- CIVIL TERM CIVIL ACTION- LAW DIVORCE NOTICE 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FENAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE TFIE RIGHT TO CLAIM ANY OF T14EM. 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 WFIERE YOU CAN GET LEGAL HELP. Cumberland Coun~ Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 FRANC~ FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, pENNSYLVANIA NO. 03-_,~_ - CIVIL TERM CIVIL ACTION - LAW DIVORCE COMPLAINT AND NOW, this ]~/day of ~/c~/~ ,2003, comes the Plaintiff, Francine Foltz, by and through her attorney, Anthony N. Thomas, Esquire, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE The Plaintiff is Francine Foltz, an adult individual residing at 126 Valley View Drive, Mechanicsburg, Cumberland County, PA 17050. The Defendant is Simon Jones, an adult individual residing at 286 Ridge Hill Road Mechanicsburg, PA 17050. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. Plaintiff and Defendant were married on Februmy 12, 1989, at New Cumberland, Pennsylvania. There have been no prior actions of divorce or annulment between the parties. Plaintiff has been advised of the availability of counseling and the fight to request that the Court require the parties to participate in counseling. The Defendant is not a member of the Armed Services of the United States or any of its Allies. ThePlaimiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; or in the alternative, b. That the parties are now living separate and apart, and have been living separate and apart since September 27, 2001, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome, and that this action is not collusive. WHEREFORE, Plaintiffrequests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Date: 7//~/ Respectfully Submitted, THOMAS & ASSOCIATES sAnu;rhe°nmYe cN~Da~ 85150 3111 North From Street Harrisburg, PA 17110 (717) 541-9979 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Date: FRANCINE FOLTZ FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- - CIVIL TERM CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE I, Anthony N. Thomas, Esquire, counsel for Plaintiff, hereby certify that a tree and correct copy of the Divorce Complaint was served by Certified Mail, Restricted Delivery, postage pre-paid, First Class Mail on 7/24/03 as follows: William Foltz 268 Ridge Hill Road Mechanicsburg, PA 17050 I verify that the statements made in this Affidavit are tree and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, elating to unswom falsification to authorities. Date: ~uny~omas, Esquire THOMAS & ASSOCIATES 3111 N. Front Street Harrisburg, PA 17110 (717) 541-9979 Attorney for Plaintiff FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-,~q-20 -- CIVIL TERM CIVIL ACTION -. LAW DIVORCE NOTICE 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of mamage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE Tl-lE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TI-IE OFFICE SET FORTH BELOW TO FIND OUT WI4ERE YOU CAN GET LEGAL HELP. Cumberland Coun(v Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-,~ff'ZO - CIVIL TERM CIVIL ACTION -- LAW DIVORCE AMENDED COMPLAINT AND NOW, this 0~ day of~, 2003, comes the Plaintiff, Francine Foltz, by and through h~r attorney, Anthoffyt/N. Thomas, Esquire, and files this Amended Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE Road The Plaintiff is Francine Foltz, an adult individual residing at 126 Valley View Drive, Mechanicsburg, Cumberland County, PA 17050. The Defendant is William A. Foltz, an adult individual residing at 286 Ridge Hill Mechanicsburg, PA 17050. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. Plaintiff and Defendant were married on February 12, 1989, at New Cumberland, Pennsylvania. There have been no prior actions of divorce or annulment between the parties. Plaintiff has been advised of the availability of cotmseling and the right to request that the Court require the parties to participate in cotmseling. The Defendant is not a member of the Armed Services of the United States or any of its Allies. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; or in the alternative, b. That the parties are now living separate and apart, and have been living separate and apart since September 27, 2001, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome, and that this action is not collusive. WI~REFORE, Plaintiffrequests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully Submitted, THOMAS & ASSOCIATES Supreme Court ID # 85150 3111 North Front Street Harrisburg, PA 17110 (717) 541-9979 Date: Attorney for Plaintiff VERIFICATION I veri~ that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities~ Date: Anthony N. Thomas, Esquire FRANCINE FOLTZ, : Plaintiff : V. WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 3ff2-0 - CIVIL TERM CIVIL ACTION - LAW DIVORCE PRAECIPE TO AMEND COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY, Pursuant to Pa. I~C.P. 1033, please file the attached Amended Complaint in this matter. In Paragraph 2 of the original Complaint, Defendant's name was inadvertently stated incorrectly as Simon Jones. The correct name of the Defendant as indicated in the caption is William Foltz. 3111 N. Front Street Harrisburg, PA 17110 (717) 541-9979 Attorney for Plaintiff FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3520 - CIVIL TERM CIVIL ACTION - LAW DIVORCE o bl} q AND NOW, this ~ ~ of I, upon consideration of Parties Stipulated ~Pat~[n and Property Settlement Agreement, it is hereby ORDERED and DECREED that the visitation with the Minor Children and distribution of marital property shall be as follows: 1. Father agrees to re-mortgage the marital home located at Y .}~tl/tg~Jrd~ ~ Meehanicsburg, pA~ 17050. 2. Father agrees to pay Mother the sum of $4,000.00, cash. 3. Father agrees to make a $1,000.00 payment on the Lowe's credit card. 4. Father agrees to pay all attorney's fees associated with the preparation and fihng of the Divorce action, Stipulated Custody and Visitation Agreement and Stipulated Property Settlement Agreement. 5. Father agrees to make a $23,000.000 payment on the Chase Manhattan credit card. ' 6. Upon satisfactory production of evidence of the above delineated payments, Mother Agrees to surrender all rights and interests in the marital home. 7. The Parties agree that all items of personal property obtained during the marriage have :been divided amongst the Parties to their mutual satisfaction. 8. In the event that any provision of this Agreement is deemed to be void, invalid or unenforceable, that provision shall be severed from the remainder of this Agreement so as not to cause the invalidity or the unenforceability of the remainder of this Agreement. Any of the remaining provisions of this Agreement shall then continue in full force and effect. 9. The Parties acknowledge and agree that this Property Settlement Agreement contains the entire Understanding of the Parties and supersedes any prior agreement between them. There are no other representations, warr~anties, promises, covenants or understandings between the parties other than those expressly set forth within. 10. The Parties hereto agree that this Property Settlement Agreement shall be construed under the laws of the Commonwealth of Pannsylvania and shall bind the Parties hereto and their respective heirs, ,executors and assigns. 11. In the event that either Party at any time hereafter obtain a divorce in the action for divorce presently pending between them, or otherwise, this Agreement and all of its provisions shall be incorporated into, but shall not merge with, any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this Property Settlement Agreement. 12. Father acknowledges he has the right to have this agreement reviewed by an attorney. Upon signing this agreement Father has either had the agreement reviewed by an attorney or has acknowledged this right and waived it. Distribution: BY THE COURT: FRANC[NE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI) NO. 03-3520 - CIVIL TERM CIVIL ACTION - LAW DIVORCE AND NOW, this ~ day of~03, upon consideration of?attics Stipulated Visitation an~ ~ro,p~ly S~tl~mea,t Agroement, it is hereby ORi)EREI) and DECREED that the visitation wi.th the Minor Children and distribution of marital property shall be as follows: 1. The Parties shall have Joint Legal Custody of the Minor Children. 2. Mother shall 'have Primary Physical Custody of the Minor Children. 3. Mother shall provide a copy of, or information regarding, the Minor Children's school schedules to Father in every year, within a reasonable time, as soon as it is available. 4. Father will provide health insurance for the Minor Children until they graduate from college or turn 22 years of age. Ifa child does not attend college, then Father will provide insurance coverage until the child is 18 years of age. 5. Father agrees to pay for any and all medical and dental expenses, over and above the insurance cost, for Megan Foltz. 6. Mother agrees to pay for any and all medical and dental expenses, over and above the insurance cost, for Valerie L. Foltz. Father agrees to pay the sum of $425.00 bi-weekly for support of the two Minor Children until the oldest child graduates from college or turns 22 years of age whichever is first. 8. Upon the graduation or the turning 22 years of age by the oldest child, Father then will pay the sum of $225.00 bi-weekly as until the younger child graduates fi.om college or turns 22 years of age, whichever is first. 9. After both Minor Children have either graduated or turned 22 years of age, Father's support obligation will termin~ate.. If one of the Minor Children do not attend college and is beyond age 18, Father will pay only the reduced support amount of $225.00. 10. If both Minor Children reach the age of 18 and do not attend college, then Father's support requirement will be terminated: 11. Father shall have visitation with the Minor Children every Wednesday. 12. Father shall have visitation with the Minor Children every other weekend beginning 13. Holiday visitation shall be divided by agreement by the parties. 14. The Parties agree that no visitation shall interfere with the Minor Children's attending school. 15. In the event that any provision of this Agreement is deemed to be void, invalid or unenforceable, that provision shall be severed fi.om the remainder of this Agreement so as not to cause the invalidity or the unenforceability of the remainder of this Agreement. Any of the remaining provisions of this Agreement shall then continue in full force and effect. 16. The Parties acknowledge and agree that this Custody and Visitation Agreement contains the entire understanding of the Parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth within~ 17. The Parties hereto agree that this Custody and Visitation Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the Parties hereto arid their respective heirs, executors and assigns. 18. In the event that either Party at any time hereafter obtain a divorce in the action for divorce presently pending bet, ween them, or otherwise, this Agreement and all of its provisions shall be incorporated into, but shall not merge with, any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this Custody and Visitation Agreement. 19. Father acknowledges he has the right to have this agreement reviewed by an attorney. Upon signing this agreement Father has either has had the agreement reviewed by an attorney or has acknowledged tNs right and waived it. Distribution: BY THE COURT: rdmcm%o: ¥. CI'~IL AcTIO~ ~ LAW D, NoKCE ~is ~ee~e~t is ~ade and ~tered into as ,,Mo~e~", ~d ~iBiam A. ~oltz, be~een Frandtne Foltz, hereina~er refe~ed to "the p~ies" · 2003, . ,,~ ~ ,,gather" t°g~her refe~O~ to as ~ie~ Dd~e hereina~e~ rete~ea *~ ~ ~- ' iadivid~l re~tdiag at ' is a~ ~ult ~AS, Mother MechaKtcsb~g' Cu~bed~d County, PA 1~050. is an adult individual residing at ~BE~AS, Father 286 ~dge HiB Koad Mechafftcsb~g' P ~ 1~.050- lg, 1989, at Ne~berl~d' ~¢E~AS, Ce pa~ies were ~med on Febm~ 2/26/88 and pe~sYl~a ~fi Mo~er subsequ~tly filed a Divorce Complaint. ~E~AS, to the p~es me~e bom ~o children as "the Minor Child . ~ s/4/90, her~ma~er refe~ed to . . . ~ule for the Minor Megan E. Foltz, u~ ~BE~AS' Mother and Father agree to the CBowmg ~sttat~ of prope~ pursaant to the following Children aad DiVision : The p a¢ies shall have l oint Legal Custody of the Min°~n' 'ma~ physical Custody of the 1. Mother shall have Prt 2. 3. Mother shall provide a copy of, or information regarding, the Minor Children's school schedules to Father in every year, within a reasonable time, as soon as it is available. 4. Father will provide health insurance for the Minor Children until they graduate from college or turn 22 years of age. Ifa child does not attend college, then Father will provide insurance coverage until the c,hild is 18 years of age. 5. Father agrees to pay for any and all medical and dental expenses, over and above the insurance cost, for Megan Foltz. 6. Mother agrees to pay for any and all medical and dental expenses, over and above the insurance cost, for Valerie L. Foltz. 7. Father agrees to pay the sum of $425.00 bi-weekly for support of the two Minor Children until the oldest child 'graduates from college or turns 22 years of age whichever is first. 8. Upon the graduation or turning 22 years of age by the oldest child, Father then will pay the sum of $225.00 bi-weekly as until the younger child graduates from college or turns 22 years of age, whichever is first. 9. After both Minor Children have either graduated or turned 22 years of age, Father's support obligation will terminate. If one of the Minor Children do not attend college and is beyond age 18, Father will pay only the reduced support amount of $225.00. 10. if both Minor Children reach the age of 18 and do not attend college, then Father's support requirement will be terminated. 11. Father shall have visitation with the Minor Children every Wednesday. ~12. Father shall have visitation with the Minor Children every other weekend beginning t. 13. Holiday visitation shall be divided by agreement by the parties. 14. The Parties agree that no visitation shall interfere with the Minor Children's attending school. 15. In the event that any provision of this Agreement is deemed to be void, invalid or unenforceable, that provision shall be severed from the remainder of this Agreement so as not to cause the invalidity or the un?forceability of the remainder of this Agreement. Any of the remaining provisions of this Agreement shall then continue in full force and effect. 16. The Parties acknowledge and agree that this Custody and Visitation Agreement contains the entire understanding of the Parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth within. 17. The Parties hereto agree that this Custody and Visitation Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the Parties hereto and their respective heirs, executors and assigns. 18. In the event that either Party at any time hereafter obtain a divorce in the action for divorce presently pending between them, or otherwise, this Agreement and all of its provisions shall be incorporated into, but shall not merge with, any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this Custody and Visitation Agreement. 19. Father acknowledges he has the right to have this agreement reviewed by an attorney. Upon signing this agreement Father has either had the agreement reviewed by an attorney or has hcknowledged this right and waived it. IN WITNESS WI]~EREOF, the Parties have set their hands and seals the day, and year first written above. WITNESS: FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANi,a NO. 03~3520 - CIVIL TERM CIVIL ACTION - LAW DIVORCE -,STII~ULATED PROPERTY SETTLEMENT AGREEMENT This Agreement is made and entered into this ~ 04t~ day of ~Deo,,~tol~, 2003, between Francine Foltz, hereinafter referred to as "Mother", and William A. Foltz, hereinafter referred to as "Father", together referred to as "the Parties". WHEREAS, Mother is an adult individual residing at 126 Valley View Drive, Mechanicsburg, Cumberland County, PA 17050. WHEREAS, Father is an adult individual residing at 286 Ridge Hill Road Mechanicsburg, PA 17050. WHEREAS, the Parties were married on February 12, 1989, at New Cumberland, Pennsylvania and Mother subsequently filed a Divorce Complaint. WHEREAS, to the Parties were born two children Valerie L. Foltz, born 2/26/88 and Megan E. Foltz, born 5/4/90, hereinafter referred to as "the Minor Children". WltEREAS, Mother and Father agree to the following Division of Property pursuant to the following terms: AGREEMENT 1. Father agrees to re-mortgage the marital home located at Mechanicsburg, PA 17050. 2. Father agrees to pay Mother the sum of $4,000.00, cash. 3. Father agrees to make a $1,000.00 payment on the Lowe's credit card. 4. Father agrees to pay all attorney's fees associated with the preparation and filing bfthe Divorce action, Stipulated Custody and Visitation Agreement and Stipulated Property Settlement Agreement. 5. Father agrees to mak~ a $23,000.000 payment on the Chase Manhattan credit card. 6. Up°n satisfactory production of evidence of the above delineated payments, Mother Agrees to surrender all rights and interests in the marital home. 7. The Parties agree that all items of personal property, obtained during the marriage have been divided amongst the Parties to their mutual satisfaction. 8. In the event that any provision of this Agreement is deemed to be void, invalid or unenforceable, that 'provision shall be severed from the remainder of this Agreement so as not to cause the invalidity or the unenforceability of the remainder of this Agreement. Any of the remaining provisions of this Agreement shall then continue in full force and effect. 9. The Parties acknowledge and agree that this Property Settlement Agreement contains the entire understanding of the Parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth within. 10. The Parties hereto agree that this Property Settlement Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the Parties hereto and their respective heirs, executors and assigns. '11. In the event that either Party at any time hereafter obtain a divorce in the action for divorce presently pending between them, or otherwise, this Agreement and all of its provisions shall be incorporated into, but shall not merge with, any such judgment for divome, either directly or by reference. The Court, on entry of judgment for divorce, shall r~ain the right to enforce the provisions and terms of this Property Settlement Agreement. 12. Father acknowledges he has the right to have this agreement reviewed by an attorney. Upon signing this agreement Father has either had the agreement reviewed by an attorney or has acknowledge~ this fight and waived it. IN WITNESS WHEREOF, the Parties have set their hands and seals the day and year first written above. WITNESS: IN THE COURT OF CC~ON PLEAS OF NO. ~3 ' 3~2~ CIVIL 19 vs. 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: ~/' q/o3 - ~_3~j ~ 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 the plaintiff //~/0~ by the defendant //~/0 ~ B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code Attorney for ~aint if f/De fendant IN THE COURT Of COMMON Francine Foltz OFCUMBERLANDCOUNTY STATE OF ~~ PENNA. "tiff VERSUS D~f~nd~qt NO. __03-3520 PLEAS DECREE IN DIVORCE AND NOW~~ DECREED THAT , _ , IT IS ORDERED AND , PLAINTIFF, AND , 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; BY TH OURT: ,~,...---- ~, ~,/]1~ ROT H O N OTA Ry FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, ENNSYLVANIA : NO. 2003-CV-3520-DV : : CIVIL ACTION - LAW : DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Francine Foltz, Plaintiff, in the above captioned case. Date: January 28, 2004 Jeffr~ ~/Wo~d, Esquire THOMAS & ASSOCIATES Attorneys At Law 3111 North Front Street Harrisburg, PA 17110 Attorney I. D. No. 38579 Tele: 717-541-9979 FRANCINE FOLTZ, Plaintiff WILLIAM A. FOLTZ, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ENNSYLVANIA NO. 2003-CV-3520-DV CIVIL ACTION - LAW DIVORCE CERTIFIATION OF SERVICE I, Jeffrey J. Wood, of THOMAS & ASSOICATES, hereby certify that on this 28th day of January 2004, I served a copy the attached Praecipe For Entry of Appearance in the above- captioned matter to the following person, via first class mail, postage prepaid, at the following address: Mr. William A. Foltz 286 Ridge Hill Road Mechanicsburg, PA 17050 Date: January 28, 2004 By: J~fr~ J. Hood, Esquire THOMAS & ASSOCIATES Attorneys At Law 3111 North Front Street Harrisburg, PA 17110 Attorney I. D. No. 38579 Tele: 717-541-9979