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IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
STATE OF 4 PEN NA.
Thomas R. Bank, II
Plaintiff N O. 99-7268 Civil
VERSUS
Jean L. Wojnar
Defendant
DECREE I N
DIVORCE Leo. ?
AND NOW, ju'g? to ??7a IT IS ORDERED AND
DECREED THAT Thomas R. Bank, II PLAINTIFF,
AND Jean L. Wojnar 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 T C
AT J.
PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
THOMAS R. BANK, II.,
178-60-2149 No. 99-7268
Plaintiff
V.
CIVIL ACTION - LAW
JEAN L. WOJNAR,
195-64-6373
Defendant DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please transmit the record, together with the following information, to the Court for entry of a
divorce decree.
I. Ground for Divorce: Irretrievable breakdown under Section 330l(d) of the Divorce
Code.
2. Date and manner of service of the Complaint: Service upon Counsel. Acceptance of
Service dated December 17, 1999.
3. a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce
Code: by Plaintiff: March 27, 2000, by Defendant: 'fay; 17, 2000.
b) Date of execution of Plaintiffs Affidavit required by Section 3301(d) of the Divorce
Code: ala, and date of service of Plaintiffs Affidavit upon Defendant: n/a.
4. Related claims pending: there are no related claims pending as none were raised.
5. (a) Date and manner of Service of Notice of Intention to file Praecipe to Transmit record, a
copy of which is attached if the decree is to be entered under section 3301(d) of the Divorce Code: n/s.
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary:
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary:
Respectfully submitt
Keith S. DeArmoa Esq.
Attorney for Plaintiff
DeArmond & DeArmond
2800 Market Street
Camp Hill, PA 17011
717-730-9394
Supreme Ct. I.D. No. 58878
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
THOMAS R. BANK, II
Plaintiff
V.
JEAN L. WOJNAR,
Defendant
No. "/ `1 / , (0 b Ci zod,'
CIVIL ACTION - LAW
IN DIVORCE
SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
This Agreement made this F_ day of 1 ?rLZ 1999 by and
between Thomas R. Bank, II, 281 Walton Street, Lemoyne, Cumberland County,
Pennsylvania 17043, party of the first part, hereinafter referred to as "Husband" and Jean
L. Wojnar, 281 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043, party
of the second part, hereinafter referred to as "Wife".
WITNESSETH:
WHEREAS, Husband and Wife were married on August 28, 1993, in Greencastle,
Pennsylvania; and
WHEREAS, there are no minor children of this marriage; and
WHEREAS, Husband and Wife are residents of the Commonwealth of
Pennsylvania, and have been so for at least the past six months; and
WHEREAS, this Court has competent jurisdiction in the above-captioned divorce
action by virtue of the parties' domicile; and
WHEREAS, certain differences have arisen between the parties hereto and as a
consequence, they have lived separate and apart since August 1999; and
WHEREAS, Husband and Wife desire to settle and determine certain of their
marital rights and obligations, and make an equitable distribution of their marital property,
determine their rights to alimony, support and other matters which may be considered
under the Divorce Code; and
WHEREAS, it is the intention and purpose of this Agreement to set forth the
respective rights and duties of the parties while they continue to live apart from each other
and to settle all financial and property rights between them; and
WHEREAS, the parties have mutually entered into an agreement for the division
oftheirjointly owned assets, the provision for the liabilities they owe, and the provision
for the resolution of their mutual differences, after both have had full and ample
opportunity to consult with attorneys of their respective choice, the parties now wish to
have that agreement reduced to writing.
NOW THEREFORE, the parties hereto in consideration of the mutually made and
to be kept promises set forth hereinafter and for other good and valuable consideration,
and intending to be legally bound and to legally bind their heirs, successors, assigns and
personal representatives, do hereby covenant, promise and agree as follows:
ARTICLE I
SEPARATION
It shall be lawful for Husband and Wife at all times hereafter to live separate and
apart from each other and to reside from time to time at such place or places as they shall
respectively deem fit, free from control, restraint, or interference, direct or indirect, by
each other. Neither party shall molest the other or compel the other to cohabit or dwell
with him or her by any legal or other proceedings. The foregoing provisions shall not be
taken to be an admission on the part of either Husband or Wife of the lawfulness of the
causes leading to them living separate and apart.
ARTICLE H
DIVORCE
2.1
This agreement is not predicated on divorce. It is specifically understood and
agreed by and between the parties hereto and each of the said parties does hereby warrant
and represent to the other that the execution and delivery of this Agreement is not
predicated upon nor made subject to any agreement for institution, prosecution, defense,
or for the non-prosecution or non-defense of any action for divorce, provided, however,
that nothing contained in this Agreement shall prevent or preclude either of the parties
hereto from commencing, instituting or prosecuting any action or actions for divorce,
whether absolute or otherwise, upon just, legal and proper ground, nor to prevent either
party from defending such action which has been, may be or shall be instituted by the other
party, or from making anyjust or proper defense thereto. It is warranted, covenanted, and
represented by Husband and Wife, each to the other that this Agreement is lawful and
enforceable and this warranty, covenant and representation is made for the specific
purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife
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each knowingly and understandingly hereby waive any and all possible claims that this
Agreement is, for any reason, illegal or unenforceable in whole or in party. Husband and
Wife do each hereby warrant, covenant and agree that, in any possible event, he and she
are and shall forever be estopped from asserting any illegality or unenforceability as to all
or any part of this Agreement.
2.2
It is further specifically understood and agreed that the provisions of this
Agreement relating to the equitable distribution of property of the parties are accepted by
each party as a final settlement for all purposes whatsoever. Should either of the parties
obtain a decree, judgment or order of separation of divorce in any other state, county, or
jurisdiction, each of the parties to this Agreement hereby consents and agrees that this
Agreement and all its covenants shall not be affected in any way by any such separation
and divorce, and that nothing in any such decree, judgment, order, or further modification
or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not
either or both of the parties should remarry, it being understood by and between the
parties that this Agreement shall survive and shall not be merged into any decree,
judgment, or order of divorce or separation.
2.3
It is specifically agreed that a copy of this Agreement may be incorporated by
reference into any divorce, judgment or decree if or whenever sought by either of the
parties hereto, such incorporation, however, shall not be regarded as a merger, it being the
intent of the parties to permit this Agreement to survive any such judgment or decree.
ARTICLE III
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property in a manner that
conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code and
taking into account the following considerations: the length of the marriage, the prior
marriages of the parties, the age, health, station, amount and sources of income,
vocational skills, employability, estate, liabilities, and needs for each of the parties, the
contribution of one party to education, training, or increased earning power of the other
party, the opportunity of each party for future acquisition of capital assets and income, the
sources of income of both parties, including but not limited to medical, retirement,
insurance or other benefits, the contribution or dissipation of each party in the acquisition,
preservation, depreciation, or appreciation of marital property, including the contribution
of a party as a homemaker, the value of the property set apart to each party, the standard
of living of the parties established during their marriage, the economic circumstances of
each party, includin
of the g federal, state, and local tax ramifications, at the time of the division
property is to become effective.
3.2
The division of existing marital property is not intended by the parties to constitute
in any way a sale or exchange of assets. The division of property under this Agreement
shall be in full satisfaction of all rights of equitable distribution of the parties.
3.3
Real Estate. Wife agrees to transfer all right, title and interest in the marital home
located at 281 Walton Street, Lemoyne, Cumberland County, Pennsylvania. In
consideration, Husband agrees to refinance the mortgage in order to hold Wife harmless
from any and all liability for mortgage against said property. Said refinancing shall occur
no later December 14, 1999, and Husband shall bear the entire cost of the refinancing.
Husband agrees to pay unto Wife one-half of the equity in the marital home.
Parties agree that the equity is based on the appraised value of the marital home of one
hundred seven thousand dollars ($107,000.00) with an estimated mortgage payoff of
seventy two thousand five hundred dollars ($72,500.00). The parties agree that if the
mortgage payoff is less than the aforementioned estimated amount, the equity will be
equally divided.
3.4
Taneible Personal Property. Husband and wife acknowledge that they have agreed
upon the division of their personal property to their mutual satisfaction including all
furniture, jewelry, automobiles and other tangible property. Husband waives all right,
title, and interest in all personal property listed in Exhibit "A" herein with the exception set
forth in paragraph 3.5 of this Agreement.
Wife waives all right, title, and interest in all personal property listed in Exhibit
"B" with the exception set forth in paragraph 3.5 of this Agreement.
3.5
In consideration of one thousand dollars ($1,000.00) Wife agrees to transfer all
right, title and interest in the washer, dryer, gas stove, refrigerator and microwave
purchased by her at the time the marital home was purchased.
3.6
Pensio__ ri/genefits Husband and Wife hereby agree to forever waive any and all
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claims against the other for any interest in their life insurance policies, pensions, retirement
benefits, 401(k), disability benefits and/or vacation pay.
3.7
Bank Accounts. Husband hereby agrees to forever waive any and all right, title or
interest in any and all bank accounts in Wife's name.
Wife hereby agrees to forever waive any and all right, title or interest in any and all
bank accounts in Husband's name.
Husband and Wife further agree to equally divide any joint bank accounts as of the
date of the execution of this Agreement.
3.8
Taxes. Husband and Wife agree to cooperate in the selection of a CPA for
preparing state and federal tax returns for the 1999 tax year. Husband and Wife further
agree to cooperate in the preparation of said returns.
If any state or federal taxes are owed, Husband and Wife agree to equally divide
said tax liability. Should any complication arise as a result of either party's employment,
that spouse whose employment has created complication shall be responsible for any
additional tax or costs owing.
Husband and Wife agree to equally divide any state or federal tax refund.
ARTICLE IV
DEBTS OF THE PARTIES
4.1
Husband and Wife shall remove each other from any joint accounts which include,
but are not limited to, checking, savings, and retirement accounts, and each release the
other from any obligations or claims on said accounts with the following exceptions.
In consideration of Wife vacating the marital home on or before December 19,
1999, Husband agrees to be solely responsible for the mortgage, utility bills and telephone
bills associated with the property located at 281 Walton Street, Lemoyne, Pennsylvania,
commencing on the date of the execution of this Agreement.. Wife agrees to be solely
responsible for any itemized amounts, such as telephone long distance charges, incurred by
her on or after the date of the execution of this Agreement.
If Wife has not vacated the marital home on or before December 19, 1999, Wife
agrees to pay unto Husband the sum of two hundred dollars ($200.00) per month toward
living expenses plus one half of the utilities at 281 Walton Street, Lemoyne, Pennsylvania,
until Wife vacates the marital home.
ARTICLE V
ALIMONY AND SUPPORT
5.1
Husband and Wife hereby waive any and all right to receive payments on account
of spousal support, maintenance, Alimony Pendente Lite, Alimony, counsel fees or costs
or any other payments of a similar nature to which he or she, in the absence of this
Agreement, might be entitled by statute including rights arising pursuant to the Divorce
Code of 1980 as amended, or similar law of any jurisdiction which may be applicable now
or at any future time.
ARTICLE VI
MISCELLANEOUS PROVISIONS
6.1
Advice o- f Counsel. The provisions of this Agreement and their legal effect are
fully understood by the parties. The parties understand their legal rights and obligations.
Husband has been represented in this matter by Keith B. DeArmond, Esquire, of Camp
Hill, Pennsylvania. Wife has been represented in this matter Judith Calkin, Esquire, of
Harrisburg, Pennsylvania.
The parties acknowledge and accept that this Agreement is, in the circumstances,
fair and equitable, that it is being entered into freely and voluntarily, after having received
such advice and with such knowledge that the 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.
6.2
Counsel Fees. The parties agree that they will each be responsible for their
respective costs and attorney fees associated with this action.
6.3
Mutual Release. Husband and Wife each do hereby mutually remise, release,
quitclaim, and forever discharge the other and the estate of such other, for all times to
come and for all purposes whatsoever, of and from any and all rights, title, and interest, or
claims in or against the property (including income and gain from property hereafter
accruing) of the other or against the estate of such other, of whatever nature and
wheresoever situate, which he or she now has or has at any time hereafter, or any part
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thereof, whether arising out of any former acts, contracts, engagements, or liability of such
other as by way of dower or curtesy, or claims in the nature of dower or curtesy or
widow's or widower's rights, family exemption, or similar allowance, or under the
intestate laws, or the right to take against the spouse's estate, whether arising under the
laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or
(c) any country, or any rights which either party may have or at any time hereafter have
for past, present, or future support or maintenance, alimony, alimony pendente lite,
counsel fees, costs or expenses, whether arising as a result of the marital relation or
otherwise, except and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the breach of
any thereof. It is the intention of Husband and Wife to give each other by execution of
this Agreement a full, complete, and general release with respect to any and all property of
any kind or nature, real or personal, or mixed, which the other now owns or may hereafter
acquire, except and only except, all rights and agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or for the breach of any thereof.
6.4
Release of Testamentary Claims. Except as provided for in this Agreement, each
of the parties hereto shall have the rights to dispose of his or her property by Last Will and
Testament, or otherwise, and each of them agrees that the estate of the other, whether
real, personal or mixed, shall be and belong to the person or persons who would have
become entitled hereto as if the descendant had been the last to die. This provision is
intended to constitute a mutual waiver by the parties of any rights to take against each
other's last Will under the present or future laws of any jurisdiction whatsoever and is
intended to confer third party beneficiary rights upon the other heirs and beneficiaries of
each other party hereto. Either party, may, however, make such provisions for the other
as he or she may desire in and by his or her Last Will and Testament. Each of the parties
further covenants and agrees that he or she will permit any Will of the other to be
probated and allow administration upon his or her personal, real, or mixed estate and
effects to be taken out by the person or persons who would have been entitled to do so
had Husband or Wife died during the lifetime of the other and that neither Husband nor
Wife will claim against or contest the Will and the estate of the other. Each of the parties
hereby releases, relinquishes and waives any and all rights to act as executor or executrix
or administrator or administratix of the other party's estate. Each of the parties hereto
further covenants and agrees for himself and herself and his or her heirs, executors,
administrators and assigns, that he or she will never at any time hereafter sue the other
party or his or her heirs, executors, administrators, or assigns, for the purpose of enforcing
any of the rights relinquished under this Paragraph.
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6.5
Warranties. Each party represents that he or she has not heretofore incurred or
contracted for any debt or liability or obligations for which the estate of the other party
may be responsible or liable, except as may be provided for in this Agreement. Each party
agrees to indemnify or hold the other party harmless from and against any and all such
debts, liabilities, or obligations of each of them, including those for necessities, except for
the obligations arising out of this Agreement. Husband and Wife each warrants,
covenants, represents, and agrees that each will, now and at all times hereafter, save
harmless and keep the other indemnified from all debts, charges, and liabilities incurred by
the other party after the execution date of this Agreement, except as is otherwise
specifically provided for by the terms of this Agreement and that neither of them hereafter
incur any liability whatsoever for which the estate of the other may be liable.
6.6
No waiver or modification of any of the terms of this Agreement shall be valid
unless in writing and signed by both parties and no waiver of any breach hereof or default
hereunder shall be deemed a waiver of any subsequent default of the same nature.
6.7
Husband and Wife covenant and agree that they will forthwith execute any and all
written instruments, assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the property implementation of this
Agreement, and as their respective counsel shall mutually agree should be so executed in
order to carry fully and effectively the terms of this agreement.
6.8
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of the execution of this
Agreement.
6.9
This Agreement shall be binding and shall inure to the benefit of the parties hereto
and their respective heirs, executors, administrators, successors, and assigns.
6.10
This Agreement constitutes the entire understanding of the parties and supersedes
any and all prior agreements and negotiations between them. There are no representations
or warranties other than those expressly set forth herein.
6.11
Severability. If any term, condition, clause, section, or provision of this
Agreement shall be determined or declared to be void or invalid in law or otherwise, then
only that term, condition, clause, section, or provision shall be stricken from this
Agreement, and in all other respects, this Agreement shall be valid and continue in full
force, effect, and operation. Likewise, the failure of any party to meet his or her
obligation under any or more of the articles and section shall in no way void or alter the
remaining obligations of the parties.
6.12
It is specifically understood and agreed that this Agreement constitutes an
equitable distribution of property, both real and personal, which was legally and
beneficially acquired by Husband and Wife, or either of them during the marriage as
contemplated by the Divorce Code of the Commonwealth of Pennsylvarda.
6.13
Disclosure. The parties warrant and represent that they have made a full
disclosure of all assets prior to the execution of this Agreement.
6.14
Enforceability and Consideration. This Agreement shall survive any action for
divorce and decree of divorce and shall forever be binding and conclusive on the parties,
and any independent action may be brought, either at law or in equity, to enforce the terms
of the Agreement by either Husband or Wife until it shall have been fully satisfied and
performed. The consideration for this contract and agreement is the mutual benefits to be
obtained by both of the parties hereto and the covenants and agreements of each of the
parties of the other. The adequacy of the consideration for all agreements herein
contained and stipulated is confessed and admitted by the parties, and the parties intend to
be legally bound hereby. In the event either party breaches the aforesaid Agreement and it
is determined through appropriate legal action that the alleged party has so breached the
agreement the breaching party shall be responsible for any and all attorneys' fees as well as
9
costs and expenses associated with litigation incurred by the non-breaching party to
enforce this Agreement against the breaching party.
Thomas R. Bank, 11 Jean L. Wojnar10
EXHIBIT "A°
Front Bedroom Furniture
Green and Wood Table
Entertainment Center
Bookshelf
Cookbook Bookshelf
Television
VCR
Antennae
Vacuum Cleaner (Riccar)
Color Enlarger
Clawfoot Bathtub
Rocking Chair
Coffee Table
All End Tables
Dog Crate
Large Cat Carrier
Green Oriental Rug
Tent
Kitchen-Aid Mixer
All-Clad Pan
Muffin Pans
Decorative Baking Pans
Canisters
Stock Pot
Snow Shovel
(2) Sets of Flannel Sheets
Baby Gate
Cookbooks
1/2 of Garden Tools
(1) Hose
(1) Set of Towels
Good Wine Glasses
Point and Shoot Camera
Knife Set
Pfaltzcraft Plates
Ladder-Aluminum Step and Wooden Kitchen
1/2 of Christmas Decorations
1/2 of Silverware
Heat Gun
Safety Deposit Box
Ziggy
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EXHIBIT "B"
Lazlo
Chessie
Dining Room Table
Couch
Dining Room Chest
Lawn Mower
Weed Wacker
Rugs
Desk in Lazlo's Room
2 Night Stands
Coat Rack
Filing Cabinet
Dehumidifier
Cuisinart
Bread Maker
Crockpot
Skillet
Pots and Pans
Loaf Pans
Cookie Sheets
Kitchen Telephone
Answering Machine
Small Cat Carrier
(1) Hose
Heat Plate
(1) Set of Flannel Sheets
Towels
Ladders (Extension and Wood)
1/2 of Garden Tools
1/2 of Silverware
1/2 of Christmas Decorations
Plant Stand
12
15 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS R. BANK, 11.
Plaintiff No. ?? - ] 1 /_ ¢ n/ ,ta
v.
CML ACTION - LAW
JEAN L. WOJNAR.
Defendant IN 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 against you by the court. Ajudgment 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 at the Cumberland County Courthouse, One Courthouse
Square, Carlisle, Pennsylvania 17013.
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
^_ Libcrty Avenue
Carlisle, PA 17013
717-249-3166
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THOMAS R. BANK, 11,
Plaintiff
V.
JEAN L. WOJNAR.
Defendant
CIVIL ACTION - LAW
IN DIVORCE
C0M1iPLAINT IN DIVORCE
1. The Pfaintiff, Thomas R. Bank. If. is an adult individual whose current address is 2S l
Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043.
2. The Defendant, Jean L. Wojnar, is an adult individual who currently resides at 281
Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043
3. Plaintifl'and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on August 28,
.
Pennsylvania. 1993, in Greencastle.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
5. The parties separated on or about August 1999.
6. Neither party has instituted any prior action of divorce or annulment with regard to this
marriage in this or any otherjurisdiction.
7. Plaintiff has been advised of the availability of counseling and understands that he may
have the right to request that the Court require the parties to participate in counseling.
8. There are no minor children by this marriage.
9• Neither party is a member of the Armed Forces of the United States of America.
10. The marriage is irretrievably broken.
WHEREFORE. the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this
matter pursuant to 3301(c) or 3301(d) of the Divorce Code.
Respectfully submitted,
Keith B. DeAnnond, Esq.
Atlomev for Plaintiff
DeAnnond & DeAnnond
2800 Market Street
Camp Hill, PA 17011
717-730-9394
Supreme Ct. I.D. No. 58878
No. y q- 9.2 ( T.c.....
VERIFICATION
I, the undersigned, do hereby verify that the statements made in the foregoing
document are correct to the best of my knowledge, information and belief. I understand
that statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Date: F( I?oyF MIL ?9 `j y?
Thomas R. Bank, II
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
THOMAS R. BANK, II No. 99-7268 CIVIL
Plaintiff
V. CIVIL ACTION - LAW
JEAN JL. WOINAR,
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Judith Catkin, Esquire, as attorney for the Defendant, hereby acknowledge that
on 1/1999, I accepted service of a Complaint in Divorce in the above-
captio ed matter.
Date: ?a 7 l r/1 L.
J ith Catkin, Esquire /
._:
IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY, PENNSYLVANIA
THOMAS R. BANK, II No. 99-7268 CIVIL
Plaintiff
V.
CIVIL ACTION - LAW
JEAN L. WOJNAR,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
December 2, 1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final Decree of Divorce after service of Notice of
Intention to request entry of the decree.
4. 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.
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 unworn falsification to authorities.
Date: Z? M4 2e.N zX0 -=??
Thomas R. Bank, 11
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
THOMAS R. BANK, 11,
Plaintiff
V.
JEAN L. WOJNAR,
No. 99-7268 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 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. §4904
relating to uns/wom falsification to authorities.
Date: ?? IVlfFfs? z?
E?;X2
Tho as R. Bank, 11
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THOMAS R. BANK, II.,
Plaintiff
VS.
JEAN L. WOJNAR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7268 CIVIL
CIVIL ACTION-IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on December 2, 1999.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree in Divorce
after service of notice of intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Date: 517&Ooo i //Or
EAN L. WOJNAR
S.S. No. 195-(aN-0
73
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THOMAS R. BANK, II.
Plaintiff
VS.
JEAN L. WOJNAR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7268 CIVIL
CIVIL ACTION-IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (c) OF THE DIVORCE CODE
1. I consent to entry of a final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
3. i understand that I will not be divorced until a
Decree is entered by the Court and that a copy of the Decree will
be sent to me immediately after it is filed with the Prothonotary.
4. I verify that the statement made in this Waiver are .
true and correct.. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
DATE: /
0`II?r7?2DD0 Z4ea L. Wojnar
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF3 Y PEN NA.
Thomas R. Bank, II
Plaintiff N O. 99-7268 Civil
VERSUS
Jean T.- Woj nar
Defendant
DECREE IN
AND NOW,
DECREED THAT
DIVORCE
Thomas R. Bank, II
IT IS ORDERED AND
, PLAINTIFF,
AND Jean L. Wojnar 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 THE COURT:
ATTEST: J.
PROTHONOTARY
IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
PENNA.
STATE OF tom" ?4,`
7"
Thomas R. Bank, II
Plaintiff N O. 99-7268 Civil
VERSUS
Jean L. Wojnar
Defendant
DECREE IN
DIVORCE
AND NOW,
IT IS ORDERED AND
DECREED THAT Thomas R. Bank, II , PLAINTIFF,
AND Jean L. Wo'nar ,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 THE COURT:
ATTEST: J
PROTHONOTARY