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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF t_•• PENNA.
C M
Robert J Grohman
SS#180-54-2330
aintifT--
VERSUS
Tracy L Grohman
SS#164-60-9127
Defendant
No. 99-7318 Ci I TA?m
DECREE IN
DIVORCE
AND NOW, IT IS ORDERED AND
DECREED THAT Robert 7 Grohman PLAINTIFF,
AND Tracy i Grohman , 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 FINALORDER HAS NOT
YET BEEN ENTERED;
ONOTARY
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SEPERATION AGREEMENT
THIS AGREEMENT, made and entered into this 1st day of November, 1997,
by and between Robert J. Grohman, who resides at 828 Allenview Drive,
Mechanicsburg, Pennsylvania, 17055 herein referred to as Robert, and Tracy
L. Grohman, who resides at 1 Clemens Drive 418, Dillsburg, Pennsylvania,
17019, herein referred to as Tracy.
Underlying Facts and Intentions
1. The parties were legally married to each other in the Elkton,
Maryland, on the 21't day of January, 1989 and have been and are now Husband
and Wife
2. Robert and Tracy have 2 children born of this marriage,
Samantha Nicole Grohman, DOB 09/03/1990, and Nikolas Mikel Grohman, DOB
02/01/1993.
3. Due to unhappy and irreconcilable differences, the parties
separated on date of separation, and since said time have lived separate
and apart in separate residences without any cohabitation; and , intend to
live separate and apart for the rest of their natural lives and to seek a
divorce based upon irretrievable breakdown of the marriage.
4. WHEREAS, both parties have knowledge of the extent, value and
character of the properties owned by them separately or jointly and of
their respective means, obligations, and needs; and
5. WHEREAS, the parties intend, and it is the purpose of this
Agreement, to make a complete and final settlement of all claims that Tracy
may have against Robert for alimony, support and maintenance and that
Robert may have against Tracy for alimony, support and maintenance, and to
all other rights, claims, relationships or obligations between them arising
out of their marriage or otherwise, and to memorialize the separation of
the parties in their Agreement to remain permanently separate and apart.
For reasons set forth above, and in consideration of the mutual
promises of the parties made and of the acts to be performed by the
respective parties hereto, it is agreed as follows:
Section One: Living Separate
Robert and Tracy may, and shall hereafter, live separate and apart,
each free from all dominion, restraint and control of the other, whether
direct or indirect, as if unmarried. Each party may hereafter reside at
such place or places as he or she may elect, except insofar as such
residence affects the residence of the children as specified in SECTION
FOUR below.
Section Two: No Molestation or Interference
Neither party shall molest or interfere with the other or compel or
attempt to compel the other to cohabit or dwell with him or her by any
means whatsoever, by legal action or otherwise.
Section Three: Division of Property
All property, both real and personal, has been divided to the
satisfaction of the parties.
Section Four: Custody and Child Support
1. The Custody and Child Support has been entered as The Court of
Common Pleas of Cumberland County, Pennsylvania. Docket No. 97-05609 A copy
of which is attached and marked Exhibit A. This Order shall remain in
effect throughout the separation and divorce and shall remain a separate
issue from the divorce.
2. Extraordinary expenses shall also be shared equally by the
parties.
3. The child(ren) shall be named as equal sharing beneficiaries of
any life insurance policy which is now held or shall be purchased in the
future by either party on his or her life.
9. Robert shall have right to declare Nikolas as a dependent on all
of his Federal and State Income Tax Returns. Tracy shall declare Samantha
as a dependent on all of her Federal and State Income Tar. Returns.
5. Upon the death of the custodial parent, the non-custodial parent
shall have full and complete custody of the minor children.
' `i
Section Five: Alimony
Robert shall pay to Tracy as alimony the sum of $300.00 (Three
Hundred Dollars) per month in advance, commencing on November 1, 1997 and
continuing on the first day of each and every month thereafter. The said
payments shall terminate upon the death of the Robert, the death of
Tracy, or the remarriage of the Tracy, or on November 1,2000, whichever
event happens first.
Section Six: Separate property
Each party shall retain, have and enjoy independently of any claim,
right or demand of the other party, all property of every kind, nature and
description and wherever situated which is now owned or held or is
hereafter acquired by him or her or stands in his or her name.
Section Seven: Marital Property
Except for the right, which each of the parties respectively
reserves, to assert as a ground for divorce any cause or ground which
either of them might now or hereafter have against the other, and except
for the rights provided in this Agreement, the parties for themselves and
their respective heirs, personal representatives, successors and assigns,
do hereby mutually release, waive, surrender and assign unto the other, his
or her heirs, personal representatives, successors and assigns, all claims,
demands, accounts and causes of action which either of them may have
against the other or against his or her property, or rights, whether
arising out of the marriage.
Section Eight: Release of Estate Rights
Each party releases all right to share in the estate of the other or
to serve as executor or administrator of the estate of the other, except
only as provided by will or codicil to will executed subsequent to the date
of this Agreement.
Section Nine: Subsequent Debts
1. Tracy warrants, represents, and agrees that she will not
hereafter contract or incur any debt, charge or liability whatsoever for
which Robert, his legal representatives, or his property or estate, will or
may become liable. Tracy further covenants at all times to hold Robert
free, harmless and indemnified from and against all debts, charges or
,
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liabilities hereafter contracted or incurred by her in breach of the
ions of this paragraph; and from any and all attorneys fees, costs
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prov
s
incurred by the Robert as a result of any such breach. With -
and expenses
the exception of the Bell Atlantic telephone and Pennsylvania Power and
Light and Suburban Cable company which remain in Tracy's name at 828
Allenview Drive
2. Robert warrants, represents, and agrees that he will not
hereafter contract or incur any debt, charge or liability whatsoever for
which Tracy, her legal representatives, or her property or estate, will or
become liable. Robert further covenants at all times to hold Tracy
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free, harmless and indemnified from and against all debts, charges or
liabilities hereafter contracted or incurred by him in breach of the
ions of this paragraph; and from any and all attorneys fees, costs
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prov
and expenses incurred by the Tracy as a result of any such breach. ,
Section Tan: Divorce
This Agreement is entered into as part of a pending divorce action in
the Court of Common Pleas of the STATE of Pennsylvania. Should a Judgment ;
of Divorce be entered in this Court, then this Agreement shall be f`
incorporated in, but not merged with, the Judgment, but shall survive and
remain as an independent contract.
Section Eleven: Mutual Release.
Except as otherwise provided herein, each party to this Agreement has k;
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 has against the other, except any or
all cause or causes of action for divorce.
Section Twelve: Modification and Binding Effects of this Agreement
The provisions of this Agreement shall not be modified or changed
except by mutual consent and Agreement of the parties, expressed in
writing, or by intervention of a court of competent jurisdiction.
This Agreement contains the entire undertaking of the parties, and
there are no representatives, warranties, covenants, or undertakings other
than those expressly set forth herein.
Section Thirteen: Governing Law
This Agreement shall be governed by and construed in accordance with '
the laws of the STATE of Pennsylvania.
In Witness Whereof, the parties hereto have signed, sealed, and
acknowledged this Agreement on this ?^day of
% zo
Witness Tracy L Grohman
Witness
ert Joseph Grohman
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND, SS:
I HEREBY CERTIFY that on this f December 1999, before
me, a Notary Public I and for the ST and county aforesaid, personally
appeared Tracy Lyn Grohman and made oath in due form of law that the
matters and facts contained in the foregoing Separation and Property
Settlement Agreement are true and correct to the best of her knowledge,
information and belief, and that she voluntarily executed the same for the
purposes therein contained.
Notary Public
My Commission Expires:
Natarlal Seal
WIIIiam H. Wessels, Notary public
carrou r York Coon
My CamYSSion Eicpires Aup. ?5, 2003
Membor, PemsyNanla Assodajlm of Nolarles
i
,,..,.
STATE OF PENNSYLVANIA
COUNTY OF COUNTY, SS:
of December, 1999, before
I HEREBY CERTIFY that on this ersonally
me, a Notary Public, I and for the ATE and county aforesaid, p
appeared Robert Joseph Grohman, and made oath in due form of law that the
matters and facts contained in the foregoing Separation and Property
Settlement Agreement are true and correct to the best of his knowledge,
information and belief, and that he voluntarily executed the same for the
purposes therein contained.
4rYPublic
My Commission Expires:
Notarial Seal
wmain H. Wessels, N ?nPPublic
My Cor=lsslon Exd r rea Aug.ls. 2009
Member, PervmM- Assoctabon of Notaries
l
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EXHIBIT A
Custody Agreement
1. Robert and Tracy will follow the attached Exhibit A
TRACY L. GROHMAN,
Plaintiff
Vs.
ROBERT J. GROHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-05604 CIVIL TERM
CUSTODY
CONSENT AGREEMENT I
This Agreement is entered on this day of / A
1997, by the plaintiff, Tracy L. Grohman, and the defendant,
Robert J. Grohman. The plaintiff is represented by Elizabeth B.
Stone, of STONE LaFAVER & STONE; the defendant is represented by
Joan Carey of LEGAL SERVICES, INC.
The defendant, Robert J. Grohman, hereinafter referred to as
the father, and the plaintiff, Tracy L. Grohman, hereinafter
referred to as the mother, agree to the entry of the following
order regarding custody of their children, Samantha Nicole
Grohman d.o.b. 9-3-90 and Nikolas Mikel Grohman 2-1-93.
1. The mother and the father shall have shared legal and
physical custody of the children.
2. Physical custody shall be shared on an alternating
weekly schedule as follows:
Week 1: The mother shall have Monday after school
until Tuesday morning, Wednesday after school until 7:30 p.m. and
Thursday after school until Sunday at 6:00 p.m.. The father shall
have all other times.
Week 2: The mother shall have Wednesday after school
until 7:30 p.m. and Thursday after school until Friday at 8:00
p.m. The father shall have all other times.
3. The father and mother shall alternate custody on the
following holidays: Thanksgiving, Christmas, and Easter with one
parent having the children from the day before the holiday until
the holiday at 2:00 p.m. and the other parent having the children
from the holiday at 2:00 p.m. until the day after the holiday.
The mother shall have the period beginning the day before the
holidays in 1997, and odd numbered years thereafter.
4. The parent who has the children according to the
alternating weekly schedule in paragraph 2 will have custody on
the following holidays: Memorial Day, the Fourth of July and
Labor Day unless otherwise agreed by the parties.
5. The mother and the father shall alternate custody of the
children on their birthdays with the mother having them in 1998
and even number years thereafter.
6. The mother shall have the children on Mother's Day and
the father shall have the children on Father's Day.
7. During the summer months and when school is not in
session, the parties shall abide by the alternating weekly
schedule in paragraph 2 with custody being transferred at places
agreed upon by the parties.
8. The mother and the father shall have periods of vacation
with the children at mutually agreed upon times and with at least
two weeks notice to the other parent.
9. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the Order shall remain in
effect until further order of court.
10. The mother and father agree that each shall notify the
other of all medical care the children receive while in that
parent's care. Each parent shall notify the other immediately of
medical emergencies which arise while the children are in that
parent's care.
11. The mother and the father shall discuss the children's
extra curricular activities before the children are enrolled.
12. The mother and father shall discuss pertinent issues
regarding the children such as haircuts, braces etc. before
making a decision.
13. If either the mother or the father moves farther than 25
miles away from the other, the person who has moved will be
responsible for transportation of the children; neither party
shall move a distance which will make this order impractical
without modifying this order.
14. Neither the mother nor the father shall petition to
modify the custody order without first attempting to settle the
matter by agreement.
15. The parties realize that their children's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that neither party shall do anything which
may estrange the children from the other parent, or injure the
opinion of the children as to the other parent or which may
1Or
hamper the free and natural development of the children's love or
respect for the other parent.
WHEREFORE, the parties request that an Order of Court be
entered to roflect the above terms.
7
11.
Tracy L rohman, P a-intiff
v
? L(1-9kz? -
Robeiat Y. Grohman, Defendant
Elizabe B. Stone
Attorn y for P tiff
STONE,'ta er & STONE
414 Bridge Street P.O. Box E
New Cumberland, PA 17010
(717) 774-7435
Joan Carey
Attorney for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
TRACY L. GROHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 97-05604 CIVIL TERM
ROBERT J. GROHMAN, CUSTODY
Defendant
CUSTODY ORDER
AND NOW, this day of 1997+ upon
consideration of the parties' Consent Agreement, the following
Order is entered with regard to custody of the parties'
children, Samantha Nicole Grohman d.o.b. 9-3-90 and Nikolas Mikel
Grohman d.o.b. 2-1-93
The defendant, Robert J. Grohman, hereinafter referred to as
the father, and the plaintiff, Tracy L. Grohman, hereinafter
referred to as the mother, agree to the entry of the following
order regarding custody of their children, Samantha Nicola
Grohman d.o.b. 9-3-90 and Nikolas Mikel Grohman 2-1-93.
1. The mother and the father shall have shared legal and
physical custody of the children.
2. Physical custody shall be shared on an alternating
weekly schedule as follows:
Week 1: The mother shall have Monday after school
until Tuesday Morning and Wednesday after school until 7:30 p.m.
and Thursday after school until Sunday at 6:00 p.m.. The father
shall have all other times.
Week 2: The mother shall have Wednesday after school
until 7:30 p.m., Thursday after school until Friday at 8:00 p.m.
The father shall have all other times.
3. The father and mother shall alternate custody on the
following holidays: Thanksgiving, Christmas, and Easter with one
parent having the children from the day before the holiday until
the holiday at 2:00 P.M. and the other parent having the children
from the holiday at 2:00 P.M. until the day after the holiday.
The mother shall have the period beginning the day before the
holidays in 1997, and odd numbered years thereafter.
4. The parent who has the children according to the
alternating weekly schedule in paragraph 2 will have custody on
the following holidays: Memorial Day, the Fourth of July and
Labor Day unless otherwise agreed by the parties.
5. The mother and the father shall alternate custody of the
children on their birthdays with the mother having them in 1998
and even number years thereafter.
6. The mother shall have the children on Mother's Day and
the father shall have the children on Father's Day.
7. During the summer months and when school is not in
session, the parties shall abide by the alternating weekly
schedule in paragraph 2 with custody being transferred at places
agreed upon by the parties.
8. The mother and the father shall have periods of vacation
with the children at mutually agreed upon times and with at least
two weeks notice to the other parent.
9. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the order shall remain in
effect until further order of court.
10. The mother and father agree that each shall notify the
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other of all medical care the children receive while in that
parent's care. Each parent shall notify the other immediately of
medical emergencies which arise while the children are in that
parent's care.
11. The mother and the father shall discuss the children's
extra curricular activities before the children are enrolled.
12. The mother and father shall discuss pertinent issues
regarding the children such as haircuts, braces etc. before
making a decision.
13. If either the mother or the father moves farther than 25
miles away from the other, the person who has moved will be
responsible for transportation of the children; neither party
shall move a distance which will make this order impractical
without modifying this order.
14. Neither the mother nor the father shall petition to
modify the custody order without first attempting to settle the
matter by agreement.
15. The parties realize that their children's well being is
paramount to any differences they might have between themselves.
Therefore, they agree that neither party shall do anything which
may estrange the children from the other parent, or injure the
opinion of the children as to the other parent or which may
hamper the free and natural development of the children's love or
respect for the other parent.
By the Court,
J.
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
This ...... &... day of....`..... q, .., 19.17
.. »..? .... Prmho2?
IN THE COURT OF COMMON PLEAS
Robeet':J. Grohman
SS#180-54-2330
Tracy L. Grohman
SS#164-60-9127
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL DIVISION
NO. 99-7318 CIVILTERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
Ground for divorce:
Irretrievable breakdown under §3301(c)
44g-}u ff#zmarwubag.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: 12/06/99 Personal Service
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 PIarch 9. 2000 ; by defendant Narch 11.2000
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code:
4.
5.
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
Related claims pending:
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: _ ptarch 15 9000 Un;rad SrarAq MaiI
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 03/-31/200o
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 03/31/2000
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-anarAf " Plaintiff I V 106WAM
(Pro Se)
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ri y
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IN THE COURT OF COMMON PLEAS OF
FAMILY DIVISION
Robert J. Grohman
828 Allenview Drive
Mechanicsburg, PA 17055
SS#180-54-2330
Plaintiff
VS. No. 44- -72 1
Tracy L. Grohman
1 Clemens Drive # 18
Dillsburg, PA 17109
SS#164-60-9127
Defendant
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 Di-
vorce 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 Plaintiff. You
may lose money, property or other rights important to you,
including the right to demand marriage counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL
PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE
OF DIVORCE OR ANNULMENT IS ENTERED, 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:
York County Bar Association Lawyer Referral Service
cu"ffzi ??ew?lw
y Bar Association
1 3 = a M j _ ?--+^--- ee or 7401
X61
Z U P_7,e -1-7 AVk .
CAPu cr . PA 1-)013
In - 2`fC('31(0(p
COUNSELING NOTICE UNDER Pa.R.C.P.
RULE 1920.45(a)*(1)
The Divorce Code of Pennsylvania requires that you be
notified of the availability of counseling where a divorce
is sought under any of the following grounds:
Section 3301(a)(6)
Section 3301 (c)
Indignities
Irretrievable Breakdown
Mutual Consent
section 3301(d)
Irretrievable Breakdown
Two-Year Separation
where the court de-
termines that there
is a reasonable
prospect of recon-
ciliation.
A list of qualified professionals is available for inspec-
tion in the:
FAMILY DIVISION
Administrative Court
9th Floor, Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE COURT OF COMMON PLEAS OF C
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
Tracy L. Grohman DIVORCE
SS#164-60-9127
Defendant
COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. Plaintiff is Robert J. Grohman, who currently re-
sides at 828 Allenview Drive, Mechanicsburg, Pennsylvania
17055, at least since December 16, 1996.
2. Defendant is Tracy L. Grohman, who currently resides
at 1 Clemans Drive #18, Dillsburg, Pennsylvania 17019, at
least since November 1, 1997.
3. Robert J. Grohman has been a bona fide resident in
the Commonwealth for at least six months immediately previ-
ous to the filing of this Complaint.
4. The plaintiff and defendant were married on January
21, 1989, at Elkton, Maryland, County of Cecil.
5. Neither plaintiff nor defendant is in the military
or naval service of the United States or its allies within
the provisions of the Soldiers' and Sailors' Civil Relief
Act of the Congress of 1940 and its amendments.
6. There have been no prior actions of divorce or for
annulment instituted by either of the parties in this or any
other jurisdiction.
7. The plaintiff is aware of the availability of coun-
seling and of the right to request that the court require
the parties to participate in counseling.
8. The marriage is irretrievably broken.
9. An original copy of the marriage certificate is at-
tached.
10. After ninety (90) days have elapsed from the date
of filing of this Complaint, plaintiff intends to file an
affidavit consenting to a divorce. Plaintiff believes that
defendant will also file such an affidavit.
WHEREFORE, if both parties file affidavits consenting
to a divorce after ninety (90) days have elapsed from the
date of the filing of this Complaint, plaintiff respectfully
requests the Court to enter a decree of divorce pursuant to
§3301 (c) of the Divorce Code.
Pla t' f (Pro Se)
Date: IZ'-? 9g
j
1
COUNT II
REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT
PURSUANT TO SECTIONS 3104(A)(1) AND (3) and 3323(6) DIVORCE
CODE
1. Plaintiff and Defendant have reached an agreement on is-
sues including alimony, property division, child support
and child custody.
WHEREFORE, Plaintiff respectfully requests that this Court
approve and incorporate the agreement reached between Plain-
tiff and Defendant into the final divorce decree, pursuant
to Sections 3104(a) (1) and (3) and 3323(b) of the Divorce
Code.
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 unsworn falsification to authorities.
Pla ti
Date: i Z-q-`j-9
«h;'I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
Tracy L. Grohman
SS#164-60-9127
Defendant
No.
VERIFICATION
I verify that the statements made in this complaint are
true and correct to the best of my knowledge, information
and belief. I understand that false statements made herein
are subject to the penalties of 18 PA. C.S., Subsection
4094, relating to unsworn falsification to authorities.
Plai ti
t,
?s
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DATE: Z'? '99
3
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CLERK'S CERTIFICATE
STATE OF MARYLAND
CECIL COUNTY, TO WIT:
I, WILLIAM L. BRUECKMAN, Clerk of the Circuit Court for Cecil
County, do HEREBY CERTIFY that the aforegoing is a TRUE COPY of the marriage
license number 82259 dated JANUARY 17TH.__U_Py , issued to:
ROBERT J. GROHMAN AND TRACY L. WILEY
IN TESTIMONY WHEREOF, I hereunto set my
hand and affix the Seal of the Circuit Court for Cecil
County, this 1ST day of NOVEMBER
In the Year Nineteen Hundred and NINETY NINE
Clerk of the Circuit Court for Cecil County.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-59-2330
Plaintiff
VS.
Tracy L. Grohman
SS#164-60-9127
Defendant
NO.99-7318 Civil
ACCEPTANCE OF SERVICE
I, Tracy L. Grohman, hereby state that I have accepted
service of a true correct copy of the Complaint in Divorce
in the above captioned matter at 6 , UO on /°I • (0 -q9 by
personal service. The server was Kel/y S?hmr , whose age
is 41 and whose address is
J?3 cuw-nvac c-r /3?.
MeeehcuLLUJ?LAS? jofl )-70 1 C
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS. N0.99-7318 Civil
Tracy L. Grohman DIVORCE
SS#164-60-9127
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on 12/6/99.
2. The marriage of Plaintiff and Defendant is irre-
trievably broken and ninety days have elapsed from the date
of filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce.
4. I understand that I may lose rights concerning ali-
mony, division of property, lawyer's fees or expenses if I
do not claim them before a divorce is granted.
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I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein made
are subject to the penalties of 18 PA C.S. Sec 4904 relating
I'
to unsworn falsification to authorities.
Pl i f
Dated: ? -J -OD
SWORN TO AND SUBSCRIBED
BEFORE ME THIS (I" DAY
OF,M" _, a I
NOTARIAL SEAL
lAtr'A A. tAc 3 RY, tJOt=r? Pu I`,a
Camp H II Soto, Cumbcrl5. d Coan'l
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#160-54-2330
Plaintiff
Tracy Lyn Grohman DIVORCE
SS#164-60-9127
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. 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 unsworn falsification to authorities.
Date: 3 -10 , oo
laintiff
vs.
No.99-7318 Civil
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
Tracy L. Grohman
SS#164-60-9127
Defendant
No.99-7318 Civil
DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on December 6, 1999.
2. The marriage of Plaintiff and Defendant is irre-
trievably broken and ninety days have elapsed from the date
of filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce.
4. I understand that I may lose rights concerning ali-
mony, division of property, lawyer's fees or expenses if I
do not claim them before a divorce is granted.
A
I verify that the statements made in this Affidavit are
true and correct. I understand that false statements herein
made are subject to the penalties of 18 PA C.S. Sec 4904 re-
lating to unsworn falsification to authori ies.
Defendant
Dated: 3 _g -Q:)
SWORN TO AND SUBSCRIBED
BEFORE ME THIS // DAY
Wills, Nosy p?MYork ty
OF *PenVania l Seal
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SEPERATION AGREEMENT
THIS AGREEMENT, made and entered into this 1st day of November, 1997,
by and between Robert J. Grohman, who resides at 829 Allenview Drive,
Mechanicsburg, Pennsylvania, 17055 herein referred to as Robert, and Tracy
L. Grohman, who resides at 1 Clemens Drive #18, Dillsburg, Pennsylvania,
17019, herein referred to as Tracy.
Underlying Facts and Intentions
1. The parties were legally married to each other in the Elkton,
Maryland, on the 21" day of January, 1989 and have been and are now Husband
and Wife
2. Robert and Tracy have 2 children born of this marriage,
Samantha Nicole Grohman, DOB 09/03/1990, and Nikolas Mikel Grohman, DOB
02/01/1993.
3. Due to unhappy and irreconcilable differences, the parties
separated on date of separation, and since said time have lived separate
and apart in separate residences without any cohabitation; and , intend to
live separate and apart for the rest of their natural lives and to seek a
divorce based upon irretrievable breakdown of the marriage.
4. WHEREAS, both parties have knowledge of to extent, value and
character of the properties owned by them separately or jointly a:,d of
their respective means, obligations, and needs; and
5. WHEREAS, the parties intend, and it is the purpose of this
Agreement, to make a complete and final settlement of all claims that Tracy
may have against Robert `or alimony, support and maintenance and that
Robert may have against Tracy for alimony, support and =aintenance, and to
all other rights, claims, relationships or obligations b=etween them arising
out of their marriage or otherwise, and to memorialize the separation of
the parties in their Agreement to remain permanently separate and apart.
For reasons set forth above, and in consideration of the mutual
promises o` the parties made and of the acts to be performed by the
respective parties hereto, it is agreed as follows: ,
Section One: Living Separate
Robert and Tracy may, and shall hereafter, live separate and apart,
each free from all dominion, restraint and control of the other, whether
direct or indirect, as if unmarried. Each party may hereafter reside at
such place or places as he or she may elect, except insofar as such
residence affects the residence of the children as specified in SECTION
FOUR below.
Section Two: No Molestation or Interference
Neither party shall molest or interfere with = :e other or ccmpel or
attempt to compel the other to cohabit or dwell wit. him or her by any
means whatsoever, by legal action or otherwise.
Section Three: Division of Property
All property, both real and personal, has been divided to the
satisfaction of the parties.
Section Four: Custody and Child Support
1. The Custody and Child Support has been entered as The Court of
Common Pleas of Cumberland County, Pennsylvania. Docket No. 97-05604 A copy
of which is attached and marked Exhibit A. This Order shall remain in
effect throughout the separation and divorce and sha'-1 remain a separate
issue from the divorce.
2. Extraordinary expenses shall also be shared equally by the
parties.
3. The child(ren) shall be named as equal sharing beneficiaries of
any life insurance policy which is now held or shall be purchased in the
future by either party on his or her life.
4. Robert shall have right to declare Nikolas as a dependent on all
of his Federal and State Income Tax Returns. Tracy shall declare Samantha
as a dependent on all of her Federal and State Income Tax Returns.
5. Unon the death of the custodial parent, the non-custodial parent
shall have full and complete custody of the minor chi l dr=-n.
Section Five: Alimony
Robert shall pay to Tracy as alimony the sum of $300.00 (Three
Hundred Dollars) per month in advance, commencing on November 1, 1997 and
continuing on the first day of each and every month thereafter. The said
payments shall terminate upon the death of.the Robert, the death of
Tracy, or the remarriage of the Tracy, or on November 1,2000, whichever
event happens first.
Section Six: Separate property
Each party shall retain, have and enjoy independently of any claim,
right or demand of the other party, all property of every kind, nature and
description and wherever situated which is now owned or held or is
hereafter acquired by him or her or stands in his or her name.
Section Seven: Marital Property
Except for the right, which each of the parties respectively
reserves, to assert as a ground for divorce any cause or ground which
either of them might now or hereafter have against the other, and except
for the rights provided in this Agreement, the parties for themselves and
their respective heirs, personal representatives, successors and assigns,
do hereby mutually release, waive, surrender and assign unto the other, his
or her heirs, personal representatives, successors and assigns, all claims,
demands, accounts and causes of action which either of them may have
against the other or against his or her property, or rights, whether
arising out of the marriage.
Section Eight: Release of Estate Rights
Each party releases all right to share in the estate of the other or
to serve as executor or administrator of the estate of the other, except
only as provided by will or codicil to will executed subsequent to the date
of this Agreement.
Section Nine: Subsequent Debts
1. Tracy warrants, represents, and agrees that she will not
hereafter contract or incur any debt, charge or liability whatsoever for
which Robert, his legal representatives, or his property or estate, will or
may become liable. Tracy further covenants at all times to hold Robert
free, harmless and indemnified from and against all debts, charges or
liabilities hereafter contracted or incurred by her in breach of the
provisions of this paragraph; and from any and all attorneys fees, costs
and expenses incurred by the Robert as a result of any such breach. With
the exception of the Bell Atlantic telephone and Pennsylvania Power and
Light and Suburban Cable company which remain in Tracy's name at 828
Allenvie,K Drive
2. Robert warrants, represents, and agrees that he will not
hereafter contract or incur any debt, charge or liability whatsoever for
which Tracy, her legal representatives, or her property or estate, will or
may bete=e liable. Robert further covenants at all times to hold Tracy
free, *,armless and indemnified from and against all debts, charges or
liabilities hereafter contracted or incurred by him in breach of the
provisions of this paragraph; and from any and all attorneys fees, costs
and excesses incurred by the Tracy as a result of any such breach.
Section Ten: Divorce
Tbis Agreement is entered into as part of a pending divorce action in
the Court of Common Pleas of the STATE of Pennsylvania. Should a Judgment
of Divorce be entered in this Court, then this Agreement shall be
incorporated in, but not merged with, the Judgment, but shall survive and
remain as an independent contract.
Section Eleven: Mutual Release.
Except as otherwise provided herein, each party to this Agreement 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 has against the other, except any or
all cause or causes of action for divorce.
Section Twelve: Modification and Binding Effects of this Agreement
The provisions of this Agreement shall not be modified or changed
except by mutual consent and Agreement of the parties, expressed in
writing, or by intervention of a court of competent jurisdiction.
This Agreement contains the entire undertaking of the parties, and
there are no representatives, warranties, covenants, or undertakings other
than those expressly set forth herein.
Section Thirteen: Governing Law
T`--'s Agreement shall be governed by and construed in accordance with
the laws of the STATE of Pennsylvania.
In witness Whereof,
acknowledged this Agreement
the parties hereto have signed, sealed, and
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on this -day of //CCLM ? 19?.
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Witness Tracy LI Grohman
/ "2.
Witness
STATE OF PENNSYLVANIA.
COUNTY OF CUMBERLAND, SS:
'_.,er? Joseoh Grohman
I HEREBY CERTIBY .::at on this December 1999, ?e'ore
me, a Notary Public I and for the ST .. and county aforesaid, personally
appeared Tracy LynGrohman and made oath in due form of law that tn_
matters and facts contained in the foregoing Separation and Property
Settlement Agreement are true and correct tc the best of her knowledge,
information and belie:, and that she voluntarily executed the same for the
purposes therein contained.
Notary =.rblic
My Commission Expires:
Nptartal Seal
William H. Wessels, Notary Pubfk:
Carroll Twp York County
My Comm7ssion Eirpires Aug.75. 2063
Mermrer, Pemsylvanla Assoclallon of Notaries
STATE OF PENNSYLVANIA
COUNTY OF COUNTY, SS:
I HEREBY CERTIFY that on this of December, 1999, before
me, a Notary Public, I and for the P.T_= and county aforesaid, personally
appeared Robert Joseph Grohman, and made oath in due form of law that the
matters and facts contained in the foregoing Separation and Property
Settlement Agreement are true and correct to the best of his knowledge,
infcrmation and belief, and that he voluntarily executed the same for the
purposes therein contained. ,(,
Nbfry Public
My Commission Expires:
Notarial Seal
William H. Wessels, Notary Pubik:
CarmUT YyorkCounty
.. MY Coamissbn r:xpires Aug.
15. 2003
Member, PemsyNaraa AssodaUm of Nolarles
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EXHIBIT A
custody Agreement
1. Robert and Tracy will follow the attached Exhibit A
TRACY L
GROHMAN,
Plaintiff
VS.
ROBERT J. GROHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-05604 CIVIL TERM
CUSTODY
CONSENT AGREEMENT (f u /' ,
entered on this ? y day of1iC'/2A
This Agreement is
1997, by the plaintiff, Tracy L. Grohman, and the defendant,
Robert J. Grohman. The plaintiff is represented by Elizabeth B.
Stone, of STONE LaFAVER & STONE; the defendant is represented by
Joan Carey of LEGAL SERVICES, INC.
The defendant, Robert J. Grohman, hereinafter referred to as
the father, and the plaintiff, Tracy L. Grohman, hereinafter
referred to as the mother, agree to the entry of the following
order regarding custody of their children, Samantha Nicole
Grohman d.o.b. 9-3-90 and Nikolas Mikel Grohman 2-1-93.
1. The mother and the father shall have shared legal and
physical custody of the children.
2. Physical custody shall be shared on an alternating
weekly schedule as follows:
Week 1: The mother shall have Monday after school
until Tuesday morning, Wednesday after school until 7:30 p.m. and
Thursday after school until Sunday at 6:00 p.m.. The father shall
have all other times.
Week 2: The mother shall have Wednesday after school
hamper the free and natural development of the children's love or
respect for the other parent.
WHEREFORE, the parties request that an order of Court be
entered to- reflect the above terms.
?rn
Tracy .I rohman, PI-aintiff
El izabe B. Stone
Attorn y for P tiff
STONE, Z-crF er 8 STONE
414 Bridge Street P.O. Box E
New Cumberland. PA 170'10
(717) 774-7435
Ro-be-MC Y. Grohman, Defendant
Joan Carey
Attorney for Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
4
TRACY L. GROHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 97-05604 CIVIL TERM
ROBERT J. GROHMAN, CUSTODY
Defendant
CUSTODY ORDER
AND NOW, this ?7 .t day of `::71- mr • 1997, upon
consideration of the parties' Consent Agreement, the following
order is entered with regard to custody of the parties'
children, Samantha Nicole Grohman d.o.b. 9-3-90 and Nikolas Mikel
Grohman d.o.b. 2-1-93
The defendant, Robert J. Grchman, hereinafter referred to as
the father, and the plaintiff, Tracy L. Grohman, hereinafter
referred to as the mother, agree to the entry of the following
Order regarding custody of their children, Samantha Nicole
Grohman d.o.b. 9-3-90 and Nikolas Mikel Grohman 2-1-93.
1. The mother and the father shall have shared legal and
physical custody of the children.
2. Physical custody shall be shared on an alternating
weekly schedule as follows:
Week 1: The mother shall have Monday after school
until Tuesday Morning and Wednesday after school until 7:30 P.M.
and Thursday after school until Sunday at 6:00 p.m.. The father
shall have all other times.
Week 2: The mother shall have Wednesday after school
until 7:30 p.m., Thursday after school until Friday at 8:00 p.m.
The father shall have all other times.
3. The father and mother shall alternate custody on the
following holidays: Thanksgiving, Christmas, and Easter with one
parent having the children from the day before the holiday until
the holiday at 2:00 p.m. and the other parent having the children
from the holiday at 2:00 p.m. until the day after the holiday.
The mother shall have the period beginning the day before the
holidays in 1997, and odd numbered years thereafter.
4. The parent whu has the chi ldren.according to the
alternating weekly schedule in paragraph 2 will have custody on
the following holidays: Memorial Day, the Fourth of July and
Labor Day unless otherwise agreed by the parties.
5. The mother and the father shall alternate custody of the
children on their birthdays with the mother having them in 1998
and even number years thereafter.
6. The mother shall have the children on Mother's Day and
the father shall have the children on Father's Day.
7. During the summer months and when school is not in
session, the parties shall abide by the alternating weekly
schedule in paragraph 2 with custody being transferred at places
agreed upon by the parties.
8. The mother and the father shall have periods of vacation
with the children at mutually agreed upon times and with at least
two weeks notice to the other parent.
9. The mother and father, by mutual agreement, may vary
from this schedule at any time, but the Order shall remain in
effect until further order of court.
10. The mother and father agree that each shall notify the
opinion of the children as to the other parent or which may
hamper the free and natural development of the children's love or
respect for the other parent.
By the Court,
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
~zC
This ...... .j......... day of .... A:^, 19.'?
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IN THE COURT OF COMMON PLEAS OF
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
Tracy L. Grohman
SS#164-60-9127
Defendant
D
No. QQ+ 'n L? a
DIVORCE
AFFIDAVIT OF NON-MILITARY SERVICE
Personally appeared before me the undersigned, a Notary
Public in and for said County and State, Pennsylvania, for
the Plaintiff and duly authorized to execute this Affidavit,
and states that the Affiant knows of his own knowledge that
the Defendant Tracy Lyn Grohman herein is not in the mili-
tary service as defined in the Solders' and Sailors' Relief
Act of 1940 and its Amendments thereto, for the following
reasons: She lives in Dillsburg and works for a collection
company.
Affiant further says that the obligation sought to be
enforced in this suit is not an obligation against a surety
guarantor, endorser, or other person liable, primarily or
secondarily, for a party in the military service.
Signore" of Plaintiff
1.
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IN WITNESS THEREOF, I have hereunto set my hand and seal.
Dated: Noterl=N
William H. WessePublic
Carroll Twp?? MY Cortwnlsskm Ex
liefT ARY PUBLIC ennsyNanW ASaodalron of NOta les
11 .? ti
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
No.99-7318 Civil
Tracy Lyn Grohman
SS#164-60-9127
Defendant
DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. 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 unsworn falsification to authorities.
Date: 3 - 0- 00 Defendant
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Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
Tracy Lyn Grohman
SS#164-60-9127
Defendant
'LEAS OF CUMBERLAND COUNTY
FAMILY DIVISION
YL
N0.99-7318 Civil
DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(c) DIVORCE DECREE
To: Tracy Lyn Grohman, Defendant
You have signed a section 3301(c) affidavit consenting the entry
of a divorce decree. Therefore on or after 3/28/2000, the other party
can request the Court to enter a final decree in divorce.
Unless you have already filed with the Court a written claim for
economic relief, you must do so by the day in the paragraph above, or
the Court may grant the divorce and you will lose forever the right to
ask for economic relief. The filing of the form counter-affidavit
alone does not protect your economic claims.
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.
Court Administrator
Cumberland County Courthouse, 4th Floor
Carlisle, PA 17013
TELEPHONE: (717) 240-6200
'46i qz
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IN THE COURT
SS#
Plaintiff
VS.
E
IA
ON
No.
DIVORCE
SS#
Defendant
COUNTER-AFFIDAVIT UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I wish to claim economic relief which may include alimony,
division of property, lawyer's fees or expenses or other important
rights.
I understand that I must file my economic claims with the Clerk
of the Family Court in writing and serve them on the other party. If I
fail to do so before the date set forth on the Notice of Intention to
Request Divorce Decree, the divorce decree may be entered without
further notice to me, and I shall be unable to file any economic
claims.
I verify that the statements made in this counter-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.
?I
f?
Date
Defendant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FAMILY DIVISION
Robert J. Grohman
SS#180-54-2330
Plaintiff
VS.
Tracy L. Grohman
SS#164-60-9127
Defendant
No.99-7318 Civil
DIVORCE
NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT THE RECORD
TO: Tracy L. Grohman (Opposing Party)
Pursuant to Local Rules of Cumberland County please be
advised that I plan to file with the Office of the Prothono-
tary a Praecipe to Transmit the Record with attended docu-
ments on _312$2&i2o
Exact copies of the Praecipe and the proposed Final De-
cree are enclosed herewith.
After the Praecipe and proposed Final Decree are filed,
you will have a period of ten (10) days during which you may
file objections to the entry of the Final Decree based upon
this Praecipe. If you dispute any of the information on the
Praecipe or the Final Decree, you must act within that ten-
day period. Any objections must be filed in writing with the
Office of the Prothonotary. If no objections are filed be-
fore the expiration of the ten-day period, this case will be
submitted to the Court for entry of the Final Decree.
-311 S 2C2?;O ' ,
Date of Mailing Pla tiff