HomeMy WebLinkAbout99-07450
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i
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
JENNIFER JANE FARR-rnV
Plaintiff
N O. 99-7450 Civil
VERSUS
JEFFREY ABBOTT LOY,
DECREE IN
DIVORCE
AND NOW, 2004 IT IS ORDERED AND
DECREED THAT JE IFER JANE FARR-Lov , PLAINTIFF,
AND JEFFREY ABBOTT LOY
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
,DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; THE TERMS AND PROVISIONS OF THE MARITAL
SETTLEMENT AGREEMENT SIGNED BY BOTH PARTIES ON JUNE B, 2004
ARE HEREBY INCORPORATED BUT NOT MERGED IN THE DECREE IN DIVORCE
AND REMAIN BINDING UPON THE PARTIES.
BY THE COURT:
rROTHONOTARY
5::? -o? a-,4?
JENNIFER JANE FARR-LOY
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
* IN THE COURT OF COMMON PLEAS
* OF CUMBERLAND COUNTY
* PENNSYLVANIA
* No. 99-7450 Civil Term
* CIVIL ACTION - LAW IN DIVORCE
PRAECIPF, 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).
2. Date and manner of service of the Complaint: Served by a constable (personal
service) on December 18. 1999. A Return of Service was filed on .lanuaa 3 2000,
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of
the Divorce Code: By Plaintiff:.lune 8. 2004; By Defendant: June S. 2004,
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff s
Affidavit upon the Respondent:
4. Related claims pending:
None. All claims were resolved by a Marital Settlement Agreement dated June 8 2004,
Said Marital Settlement Agreement will he filed simultaneously with this Praecipe,
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached:
(b) Date Plaintiffs Waiver ot.Notice in Section 3301(c) Divorce was filed with the
Prothonotary: July 6.2004; Date Defendant's Waiver of Notice in Section 3301(c)
Divorce was filed with the Prothonotary:-July 6. 2004.
Date:
By:
r Spears, Esquire
jJenn'
Attorney for Plaintiff
JENNIFER JANE FARR-LOY,
Plaintiff
Vs.
JEFFREY ABBOTT LOY,
Defendant
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7450 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this day of
2004, the economic claims raised in the proceed ngs having been
resolved in accordance with a marital settlement agreement
dated June 8, 2004, the appointment of the Master is vacated
and counsel can file a praecipe transmitting the record to the
Court requesting a final decree in divorce.
BY THE COURT,
cc: Jennifer L. Spears
Attorney for Plaintiff
Charles E. Petrie
Attorney for Defendant
Geo ge P. .
C. "...
, n.
?v
?. N .•r 94.946b
MARITAL SETTLEMENT AGREEMENT
AGREEMENT made this day of JVje., 2004, by and between
JEFFREY A. LOY, hereinafter called "Husband," and JENNIFER J.
LOY, hereinafter called "Wife."
WHEREAS, in consequence of disputes and unhappy differences,
the parties are separated and living apart from each other; and
WHEREAS, the parties desire to confirm their separation and
make arrangement in connection therewith;
IT IS THEREFORE AGREED:
1. CONSIDERATION - The consideration for this Agreement is the
mutual promises, covenants and agreements herein contained.
2. SEPARATION - It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or places as he or
she may from time to time choose deem fit.
3. NO INTERFERENCE - Each party shall be free from interference,
authority and control, direct or indirect, by the other, as fully as if he or she
were single and unmarried.
4. COUNSEL FEES
A. Husband agrees to pay all counsel fees incurred by him since
the separation of Husband and Wife.
1
B. Wife agrees to pay all counsel fees incurred by her since the
separation of Husband and Wife.
5. DIVISION OF PERSONAL PROPERTY - Husband shall be the
sole owner of the items of personal property currently in his possession. Wife
shall be the sole owner of the items of personal property currently in her
possession, including the 1996 Ford. Except as outlined in this paragraph, the
parties have divided their personalty to their mutual satisfaction, and hereafter
each shall own and enjoy, independently of any claim or right of the other, all
items of personal property of every kind, which are now owned or held or which
may hereafter belong or come to him or her, with full power of disposition as if
he or she were unmarried.
Husband shall execute and deliver Wife's car title to Wife within five (5)
days of the execution of this Agreement.
6. AFTER-ACQUIRED PROPERTY - Each of the parties shall hereafter
own and enjoy, independently of any claim or right of the other, all property,
tangible or intangible, real, personal or mixed, acquired by him or her, whether
or not marital assets were utilized in the acquisition, since the date of the
parties' separation, or if not separated, the date of the execution of this
Agreement, with full power in him or her to dispose of the same as fully
and effectively, in all respects and for all purposes as though he or she were
unmarried; and each party hereby waives, releases, renounces and forever
2
Nr
abandons any right, title, interest and claim in and to said after-acquired
property of the other party pursuant to the terms of this paragraph.
7. NO-FAULT DIVORCE - The parties acknowledge that their marriage
is irretrievably broken and that they shall secure a mutual consent no-fault
divorce. The parties shall execute Affidavits of Consent and Waivers to permit
the entry of a Decree in Divorce simultaneously with the execution of this
Agreement.
8. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS - Each
party understands that he or she has the right to obtain from the other party a
complete inventory or list of all of the property that either or both parties own
at this time or owned as of the date of separation, and that each party has the
right to have all such property valued by means of appraisals or otherwise.
Both parties understand that they have the right to have a court hold hearings
and make decisions on the matters covered by this Agreement. Both parties
understand that a court decision concerning the parties' respective rights and
obligations might be different from the provisions of this Agreement.
Each party hereby acknowledges that this Agreement is fair and
equitable, that it adequately provides for his or her needs and is in this or her
best interests, and that the Agreement is not the result of any fraud, duress, or
undue influence exercised by either party upon the other or by any other
person or persons upon either party. Both parties hereby waive the following
procedural rights:
3
a. The right to obtain an inventory and appraisement of all marital
and non-marital property as defined by the Pennsylvania Divorce Code.
b. The right to obtain an income and expense statement of the
other party as provided by the Pennsylvania Divorce Code.
c. The right to have property identified and appraised.
d. The right to discovery as provided by the Pennsylvania Rules of
Civil Procedure.
e. The right to have the court determine which property is marital
and which is non-marital, and equitably distribute between the parties that
property which the court determines to be marital, and to set aside to either
party that property which the court determines to be the parties' non-marital
property.
f. The right to have the court decide any other rights, remedies,
privileges, or obligations covered by this Agreement and/or arising out of the
marital relationship, including but not limited to possible claims for divorce,
child or spousal support, alimony, alimony pendente lite (temporary
alimony), equitable distribution, debt allocation, and counsel fees, costs and
expenses.
9. WAIVER OF PENSION BENEFITS - Husband and Wife agree that
each shall execute any documents necessary to release and waive any right,
title or interest which either party may have in the other party's retirement
plan (which is defined to mean pension, profit-sharing, or any other plan or
4
account or retirement or deferred income). Each party agrees to execute
whatever documents are required to effectuate the purpose of this paragraph.
Each party appoints the other as attorney-in-fact for the purpose of consenting
to any election under any plan under section 417 of the Internal Revenue Code
or Section 205 of the Employee Income Security Act of 1974. It is specifically
agreed that each party's rights under their respective retirement plans
constitute their own separate property.
10. MARITAL. DEBTS - The parties acknowledge that they have
previously divided the obligations and payments required thereof of any debts
and obligations arising during the marriage and in accordance therewith any
obligation being paid by a party shall continue to be so paid and said party
shall indemnify, protect and save the other party harmless therefrom.
A liability not disclosed in this Agreement will be the sole responsibility of
the party who has incurred or may hereafter incur it, and each agrees to pay it
as the same shall become due, and to indemnify and hold the other party and
his or her property harmless from any and all such debts, obligations and
liabilities. From the date of execution of this Agreement, each party shall use
only those credit cards and accounts for which that party is individually liable
and the parties agree to cooperate in closing any remaining accounts which
provide for joint liability.
Specifically, Husband agrees to hold Wife harmless from liability from
any claim by the mortgagee arising out of Husband's failure to pay the
5
mortgage debt.
11. WIFE'S DEBTS - Wife represents and warrants to Husband that she
will not contract or incur any debts or liabilities for which Husband or his
estate may be responsible and she shall indemnify and save Husband harmless
from any and all claims or demands made against him by reason of debts or
obligations incurred by her since the date of the separation.
12. HUSBAND'S DEBTS - Husband represents and warrants to Wife that
he will not contract or incur any debts or liabilities for which Wife or her estate
may be responsible and he shall indemnify and save Wife harmless from any
and all claims or demands made against her by reason of debts or obligations
incurred by him since the date of the separation.
13. REAL ESTATE - The parties acknowledge that they are the prior
owners of real estate known and numbered as 3924 Rauch Street, Lower
Paxton Township, Dauphin County, Pennsylvania. The parties acknowledge
that the real estate has been sold pursuant to a Sheriff's Sale as a result of a
mortgage foreclosure Complaint.
14. TAXES - Husband and Wife agree to indemnify and hold each other
harmless should either party have to pay any taxes, interest and/or penalties
assessed as a result of any error in the reporting of income and/or in the
preparation of any tax return by the other party during the years in which they
were married.
6
15. WAIVER OF WIFE'S CLAIMS AGAINST HUSBAND'S ESTATE - Wife
does hereby remise, release, quitclaim and forever discharge Husband and his
estate of and from any kind of every claim of any nature and kind whatsoever,
including but not limited to any claim arising out of the marital relationship,
whether arising out of any former contracts, engagements, or liabilities of
Husband, or by way of dower or claim in the nature of dower, widow's rights, or
under the intestate laws, or the right to elect against Husband's Will, or any
other claims of any nature whatsoever, except only the rights accruing to Wife
under this Agreement. Wife hereby waives and renounces any preference or
right to claim appointment or to qualify as the personal representative of
Husband, or to administer Husband's personal estate and effects in the event
that Wife survives Husband.
16. WAIVER OF HUSBAND'S CLAIM AGAINST WIFE'S ESTATE -
Husband does hereby remise, release, quitclaim and forever discharge Wife and
her estate of and from any and every claim of any nature and kind whatsoever,
including but not limited to any claim arising out of the marital relationship,
whether arising out of any former contracts, engagements or liabilities of Wife,
by way of curtesy, or claim in the nature of curtesy, widower's rights, or under
the intestate laws, or the right to elect against Wife's will or any other claims of
any nature whatsoever, except only the rights accruing to Husband under this
Agreement. Husband hereby waives and renounces any preference or right to
claim appointment or to qualify as the personal representative of Wife, or to
1
1_t
administer Wife's personal estate and effects in the event that Husband
survives Wife.
17. SUBSEQUENT DIVORCE - Nothing herein contained shall be
deemed to prevent either of the parties from maintaining suit for absolute
divorce against the other in any jurisdiction based upon any past or future
conduct of the other, nor to bar the other from defending any such suit. In the
event any such action is instituted, the parties shall be bound by all terms of
this Agreement and this Agreement shall be the sole remedy available to the
parties.
18. EQUITABLE DIVISION OF PROPERTY - By this Agreement, the
parties have intended to effect an equitable division of their marital property.
This division is not intended by the parties to constitute in any way a sale or
exchange of assets.
19. MUTUAL RELEASE - Subject to the provisions of this Agreement,
each party has released and discharged, and by this Agreement does for
himself or herself, or 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 in equity,
which either of the parties have, or have ever had, against the other including
any and all rights under the Pennsylvania Domestic Relations Code, including
spousal support, alimony, alimony pendente lite, equitable distribution of
property and counsel fees.
8
20. BREACH - If either party breaches any provision of this Agreement,
then he or she shall have the right to sue for damages for such breach, or seek
such other remedy or relief as may be available. Counsel fees and costs of the
prevailing party shall be paid by the defaulting party.
21. ADDITIONAL INSTRUMENTS - Each of the parties shall, from time
to time, at the request of the other, execute, acknowledge and deliver to the
other party within a reasonable time period (presumed to be thirty (30) days
after such request is made) any and all further instruments including deed(s)
or releases which may reasonably be required to give full force and effect to the
provisions of this Agreement.
22. VOLUNTARY EXECUTION - The provisions of this Agreement and
their legal effect have been fully explained to the parties and each party
acknowledges that the Agreement is fair and equitable, that it is being entered
into voluntarily, and that it is not the result of any duress or undue influence.
The parties acknowledge that full disclosure has been made and they have
been furnished with all information relating to the financial affairs of the other
which has been requested and that counsel for each of the parties have
reviewed the document, or, in the absence of counsel, the party has waives his
or her right to counsel.
23. ENTIRE AGREEMENT - This Agreement contains the entire
understanding of the parties, and there are no representations, waivers,
covenants or undertakings other than those expressly set forth herein.
9
24. MODIFICATION AND WAIVER - A modification or waiver of any of
the provisions of this Agreement shall be effective only if made in writing and
executed with the same formality as this Agreement. The failure of either party
to insist on strict performance of any of the provisions of this Agreement shall
not be construed as a waiver of any subsequent default for the same or similar
nature.
25. PARTIAL INVALIDITY - If any provision of this Agreement is held to
be invalid or unenforceable, all other provisions shall nevertheless continue in
full force and effect.
26. BINDING EFFECT - Except as otherwise stated within, all of the
provisions of this Agreement shall be binding upon the respective heirs, next of
kin, executors and administrators of the parties.
27. INTENT OF PARTIES - It is the intention of the parties hereto Lhat
this Agreement is a complete and final disposition of their property rights and
not a mere Separation Agreement.
28. INCORPORATION - The parties agree that the terms of this
Agreement shall be incorporated but not merged into tiny Decree of Divorce
which may be entered. The parties undersLcind and agree LhuL this Agreement
shall survive any such final Decree of Divorce and shall be independent
thereof. Said incorporation shall be for the sole purpose of obtaining additional
rights of enforcement and the parties understand lhaL the provisions of
this Agreement shall not be subject to ;my modification, unless specifically
10
provided for in the relevant paragraph.
29. ENFORCEMENT - The parties agree that any action necessary by
either party to enforce their rights under this agreement against the other shall
be filed before the Court of Common Pleas of Cumberland County,
Pennsylvania, and, regardless of where any divorce action between them is
concluded, both parties hereby stipulate to the jurisdiction and venue of the
Court of Common Pleas of Cumberland County, Pennsylvania, for purposes of
interpretation or enforcement of this agreement.
30. HEADINGS NOT PART OF AGREEMENT - Any headings preceding
the text of the several paragraphs and subparagraphs hereof, are inserted
solely for convenience of reference and shall not constitute a part of this
Agreement nor shall they affect its meaning, construction or effect.
11
BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES
HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH
PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT
SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY
THE COURT AFTER A FULL HEARING.
IN WITNESS WHEREOF, the parties have hereunto set their hands and
seals the day and year first above written.
NESS Y . LOY
WIT ESS J NIF J. LOY
12
all
MARITAL SETTLEMENT AGREEMENT
AGREEMENT made this day of3jvL 12004, by and between
JEFFREY A. LOY, hereinafter called "Husband," and JENNIFER J.
LOY, hereinafter called "Wife."
WITNESSETH•
WHEREAS, in consequence of disputes and unhappy differences,
the parties are separated and living apart from each other; and
WHEREAS, the parties desire to confirm their separation and
make arrangement in connection therewith;
IT IS THEREFORE AGREED:
1. CONSIDERATION - The consideration for this Agreement is the
mutual promises, covenants and agreements herein contained.
2. SEPARATION - It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or places as he or
she may from time to time choose deem fit.
3. NO INTERFERENCE - Each party shall be free from interference,
authority and control, direct or indirect, by the other, as fully as if he or she
were single and unmarried.
4. COUNSEL FEES
A. Husband agrees to pay all counsel fees incurred by him since
the separation of Husband and Wife.
1
B. Wife agrees to pay all counsel fees incurred by her since the
separation of Husband and Wife.
5. DIVISION OF PERSONAL PROPERTY - Husband shall be the
sole owner of the items of personal property currently in his possession. Wife
shall be the sole owner of the items of personal property currently in her
possession, including the 1996 Ford. Except as outlined in this paragraph, the
parties have divided their personalty to their mutual satisfaction, and hereafter
each shall own and enjoy, independently of any claim or right of the other, all
items of personal property of every kind, which are now owned or held or which
may hereafter belong or come to him or her, with full power of disposition as if
he or she were unmarried.
Husband shall execute and deliver Wife's car title to Wife within five (5)
days of the execution of this Agreement.
6. AFTER-ACQUIRED PROPERTY - Each of the parties shall hereafter
own and enjoy, independently of any claim or right of the other, all property,
tangible or intangible, real, personal or mixed, acquired by him or her, whether
or not marital assets were utilized in the acquisition, since the date of the
parties' separation, or if not separated, the date of the execution of this
Agreement, with full power in him or her to dispose of the same as fully
and effectively, in all respects and for all purposes as though he or she were
unmarried; and each party hereby waives, releases, renounces and forever
2
e:1!T!-M
abandons any right, title, interest and claim in and to said after-acquired
property of the other party pursuant to the terms of this paragraph.
7. NO-FAULT DIVORCE - The parties acknowledge that their marriage
is irretrievably broken and that they shall secure a mutual consent no-fault
clivorce. The parties shall execute Affidavits of Consent and Waivers to permit
the entry of a Decree in Divorce simultaneously with the execution of this
Agreement.
8. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS - Each
party understands that he or she has the right to obtain from the other party a
complete inventory or list of all of the property that either or both parties own
at this time or owned as of the date of separation, and that each party has the
right to have all such property valued by means of appraisals or otherwise.
Both parties understand that they have the right to have a court hold hearings
and make decisions on the matters covered by this Agreement. Both parties
understand that a court decision concerning the parties' respective rights and
obligations might be different from the provisions of this Agreement.
Each party hereby acknowledges that this Agreement is fair and
equitable, that it adequately provides for his or her needs and is in this or her
best interests, and that the Agreement is not the result of any fraud, duress, or
undue influence exercised by either party upon the other or by any other
person or persons upon either party. Both parties hereby waive the following
procedural rights:
3
a. The right to obtain an inventory and appraisement of all marital
and non-marital property as defined by the Pennsylvania Divorce Code.
b. The right to obtain an income and expense statement of the
other party as provided by the Pennsylvania Divorce Code.
c. The right to have property identified and appraised.
d. The right to discovery as provided by the Pennsylvania Rules of
Civil Procedure.
e. The right to have the court determine which property is marital
and which is non-marital, and equitably distribute between the parties that
property which the court determines to be marital, and to set aside to either
party that property which the court determines to be the parties' non-marital
property.
f. The right to have the court decide any other rights, remedies,
privileges, or obligations covered by this Agreement and/or arising out of the
marital relationship, including but not limited to possible claims for divorce,
child or spousal support, alimony, alimony pendente lite (temporary
alimony), equitable distribution, debt allocation, and counsel fees, costs and
expenses.
9. WAIVER OF PENSION BENEFITS - Husband and Wife agree that
each shall execute any documents necessary to release and waive any right,
title or interest which either party may have in the other party's retirement
plan (which is defined to mean pension, profit-sharing, or any other plan or
4
account or retirement or deferred income). Each party agrees to execute
whatever documents are required to effectuate the purpose of this paragraph.
Each party appoints the other as attorney-in-fact for the purpose of consenting
to any election under any plan under section 417 of the Internal Revenue Code
or Section 205 of the Employee Income Security Act of 1974. It is specifically
agreed that each party's rights under their respective retirement plans
constitute their own separate property.
10. MARITAL DEBTS - The parties acknowledge that they have
previously divided the obligations and payments required thereof of any debts
and obligations arising during the marriage and in accordance therewith any
obligation being paid by a party shall continue to be so paid and said party
shall indemnify, protect and save the other party harmless therefrom.
A liability not disclosed in this Agreement will be the sole responsibility of
the party who has incurred or may hereafter incur it, and each agrees to pay it
as the same shall become due, and to indemnify and hold the other party and
his or her property harmless from any and all such debts, obligations and
liabilities. From the date of execution of this Agreement, each party shall use
only those credit cards and accounts for which that party is individually liable
and the parties agree to cooperate in closing any remaining accounts which
provide for joint liability.
Specifically, Husband agrees to hold Wife harmless from liability from
any claim by the mortgagee arising out of Husband's failure to pay the
5
mortgage debt.
1 1. WIFE'S DEBTS - Wife represents and warrants to Husband that she
will not contract or incur any debts or liabilities for which Husband or his
estate may be responsible and she shall indemnify and save Husband harmless
from any and all claims or demands made against him by reason of debts or
obligations incurred by her since the date of the separation.
12. HUSBAND'S DEBTS - Husband represents and warrants to Wife that
he will not contract or incur any debts or liabilities for which Wife or her estate
may be responsible and he shall indemnify and save Wife harmless from any
and all claims or demands made against her by reason of debts or obligations
incurred by him since the date of the separation.
13. REAL ESTATE - The parties acknowledge that they are the prior
owners of real estate known and numbered as 3924 Rauch Street, Lower
Paxton Township, Dauphin County, Pennsylvania. The parties acknowledge
that the real estate has been sold pursuant to a Sheriff's Sale as a result of a
mortgage foreclosure Complaint.
14. TAXES - Husband and Wife agree to indemnify and hold each other
Iti
harmless should either party have to pay any taxes, interest and/or penalties
assessed as a result of any error in the reporting of income and/or in the
preparation of any tax return by the other party during the years in which they
were married.
6
15. WAIVER OF WIFE'S CLAIMS AGAINST HUSBAND'S ESTATE - Wife
does hereby remise, release, quitclaim and forever discharge Husband and his
estate of and from any kind of every claim of any nature and kind whatsoever,
including but not limited to any claim arising out of the marital relationship,
whether arising out of any former contracts, engagements, or liabilities of
Husband, or by way of dower or claim in the nature of dower, widow's rights, or
under the intestate laws, or the right to elect against Husband's Will, or any
other claims of any nature whatsoever, except only the rights accruing to Wife
under this Agreement. Wife hereby waives and renounces any preference or
right to claim appointment or to qualify as the personal representative of
Husband, or to administer Husband's personal estate and effects in the event
that Wife survives Husband.
16. WAIVER OF HUSBAND'S CLAIM AGAINST WIFE'S ESTATE -
Husband does hereby remise, release, quitclaim and forever discharge Wife and
her estate of and from any and every claim of any nature and kind whatsoever,
including but not limited to any claim arising out of the marital relationship,
whether arising out of any former contracts, engagements or liabilities of Wife,
by way of curtesy, or claim in the nature of curtesy, widower's rights, or under
the intestate laws, or the right to elect against Wife's will or any other claims of
any nature whatsoever, except only the rights accruing to Husband under this
Agreement. Husband hereby waives and renounces any preference or right to
claim appointment or to qualify as the personal representative of Wife, or to
7
administer Wife's personal estate and effects in the event that Husband
survives Wife.
17. SUBSEQUENT DIVORCE - Nothing herein contained shall be
deemed to prevent either of the parties from maintaining suit for absolute
divorce against the other in any jurisdiction based upon any past or future
conduct of the other, nor to bar the other from defending any such suit. In the
event any such action is instituted, the parties shall be bound by all terms of
this Agreement and this Agreement shall be the sole remedy available to the
parties.
18. EQUITABLE DIVISION OF PROPERTY - By this Agreement, the
parties have intended to effect an equitable division of their marital property.
This division is not intended by the parties to constitute in any way a sale or
exchange of assets.
19. MUTUAL RELEASE - Subject to the provisions of this Agreement,
each party has released and discharged, and by this Agreement does for
himself or herself, or 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 in equity,
which either of the parties have, or have ever had, against the other including
any and all rights under the Pennsylvania Domestic Relations Code, including
spousal support, alimony, alimony pendente lite, equitable distribution of
property and counsel fees.
8
20. BREACH - If either party breaches any provision of this Agreement,
then he or she shall have the right to sue for damages for such breach, or seek
such other remedy or relief as may be available. Counsel fees and costs of the
prevailing party shall be paid by the defaulting party.
21. ADDITIONAL INSTRUMENTS - Each of the parties shall, from time
to time, at the request of the other, execute, acknowledge and deliver to the
other party within a reasonable time period (presumed to be thirty (30) days
after such request is made) any and all further instruments including deed(s)
or releases which may reasonably be required to give full force and effect to the
provisions of this Agreement.
22. VOLUNTARY EXECUTION - The provisions of this Agreement and
their legal effect have been fully explained to the parties and each party
acknowledges that the Agreement is fair and equitable, that it is being entered
into voluntarily, and that it is not the result of any duress or undue influence.
The parties acknowledge that full disclosure has been made and they have
been furnished with all information relating to the financial affairs of the other
which has been requested and that counsel for each of the parties have
reviewed the document, or, in the absence of counsel, the party has waives his
or her right to counsel.
23. ENTIRE AGREEMENT - This Agreement contains the entire
understanding of the parties, and there are no representations, waivers,
covenants or undertakings other than those expressly set forth herein.
9
24. MODIFICATION AND WAIVER - A modification or waiver of any of
the provisions of this Agreement shall be effective only if made in writing and
executed with the same formality as this Agreement. The failure of either party
to insist on strict performance of any of the provisions of this Agreement shall
not be construed as a waiver of any subsequent default for the same or similar
nature.
25. PARTIAL INVALIDITY - If any provision of this Agreement is held to
be invalid or unenforceable, all other provisions shall nevertheless continue in
full force and effect.
26. BINDING EFFECT - Except as otherwise stated within, all of the
provisions of this Agreement shall be binding upon the respective heirs, next of
kin, executors and administrators of the parties.
27. INTENT OF PARTIES - It is the intention of the parties hereto that
this Agreement is a complete and final disposition of their property rights and
not a mere Separation Agreement.
28. INCORPORATION - The parties agree that the terms of this
Agreement shall be incorporated but not merged into any Decree of Divorce
which may be entered. The parties understand and agree that this Agreement
shall survive any such final Decree of Divorce and shall be independent
thereof. Said incorporation shall be for the sole purpose of obtaining additional
rights of enforcement and the parties understand that the provisions of
this Agreement shall not be subject to any modification, unless specifically
10
provided for in the relevant paragraph.
29. ENFORCEMENT - The parties agree that any action necessary by
either party to enforce their rights under this agreement against the other shall
be filed before the Court of Common Pleas of Cumberland County,
Pennsylvania, and, regardless of where any divorce action between them is
concluded, both parties hereby stipulate to the jurisdiction and venue of the
Court of Common Pleas of Cumberland County, Pennsylvania, for purposes of
interpretation or enforcement of this agreement.
30. HEADINGS NOT PART OF AGREEMENT - Any headings preceding
the text of the several paragraphs and subparagraphs hereof, are inserted
solely for convenience of reference and shall not constitute a part of this
Agreement nor shall they affect its meaning, construction or effect.
11
BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES
HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH
PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT
SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY
THE COURT AFTER A FULL HEARING.
IN WITNESS WHEREOF, the parties have hereunto set their hands and
love written.
J REY A. LOY?
t
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JENNIFER JANE FARR-LOY
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.9q? LT -CIVIL TERM
: IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
its.
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99' 7`15-0 CIVIL TERM
IN DIVORCE
DIVORCE COMPLAINT
1. The Plaintiff is JENNIFER JANE FARR-LOY, Social Security number 202-60-
8869, who currently resides at 6116 Charing Cross, Mechancisburg, Cumberland County,
Pennsylvania.
2. The Defendant is JEFFREY ABBOTT LOY, Social Security number 187-50-
4026, who currently resides at 3944 Rauch Street, Harrisburg, Dauphin County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 19, 1991 at Snow Hill, Maryland.
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections
3301(c), in that:
a) The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
Respectfully submitted,
Date l qC 1(q' S
Austin F. Gr , E;
24 North 32 d Street
Camp Hill, PA 17019
(717) 737-1956
Attorney for Plaintiff
I. D. #59020
14 <r
.:
VERIFICATION
I, JENNIFER JANE FARR-LOY, verify that the statements made in the foregoing Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn
falsification to authorities.
Date Q0" ?. cm -
JE IFE JA FARR-LOY
HARRY N. LUKENS
PENNSYLVANIA STATE. CONSTABLE.
13 FERRY ST. WORMLEYSBURG, PA. 17043
OFF. 717-761-0583 PAGER 717-760-2136
FAX. 717-761-2233
RETURN OF SERVICE
ON DECEMBER 18. 1999 AT 10:10A.M. I. HARRY N. LUKENS. PENNSYLVANIA STATE CONSTABLE
SERVED: CIVIL PAPERS. DIVORCE CIVIL TERM NO.99-7450 CUMBERLAND COUNTY
SERVED ON: JEFFREY LOY
19 N. PROGRESS AVENUE
HARRISBURG. PA. 17109
1 VERIFY THAT THE STATEMENTS IN THIS RETURN OF SERVICE ARE TRUE AND CORRECT. I
UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF
18PAC.S.A.4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
SIGNATURE. `,
.. ----
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JENNIFER JANE FARR-LOY
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
* IN THE COURT OF COMMON PLEAS
* OF CUMBERLAND COUNTY
* PENNSYLVANIA
* No. 99-7450 Civil Term
* CIVIL ACTION - LAW IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on December
l3, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to
unswom falsification to authorities.
oq-
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Date Jen er Jane Farr-Loy
Plaintiff
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JENNIFER JANE FARR-LOY,
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
* IN THE COURT OF COMMON PLEAS
* OF CUMBERLAND COUNTY
* PENNSYLVANIA
*
* No. 99-7450 Civil Term
*
* CIVIL ACTION - LAW IN DIVORCE
WA IVE R OF NOTi (`F O F INT FNTLQN JO REQUEST
EN TRY OF A DIV OR DECgEE UNDER
SE CTIO N 3301 (8) O F TH . DIVORCE CODE
1. 1 consent to the entry ofa final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. 1 understand that false
statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom
falsification to authorities.
CA(S1)Dg
Date Jerti ifer Jane F. rr-Loy
Plaintiff
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JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
VS.
NUMBER: 99-7450
JEFFREY ABBOTT LOY,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A co plai t in divorce under Section 3301(c) of the Divorce Code
was filed on
2. The marriage of plaintiff and defendant is irretrievably broken and
ninety days have elapsed from the date of 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.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of
18 Pa.C.S. Section 4904 relating to unsworn falsification-torauthorities.
DATE: _ID_?J-O
LOY,
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JENNIFER JANE FARR-LOY,
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99-7450
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 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.
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: -,-2) OLI
FREY BBOTT LOY,
DEFENDANT
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JENNIFER JANE FARR-LOY
Plaintiff
VS.
JEFFREY A13BOTT LOY,
Defendant
* IN THE COURT OF COMMON PLEAS
* OF CUMBERLAND COUNTY
* PENNSYLVANIA
*
* No. 99-7450 Civil Term
*
* CIVIL ACTION - LAW IN DIVORCE
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1(x)(3) ALL DIVORCES MUST INCLUDE
THE PARTIES SOCIAL SECURITY NUMBER.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE.
DATE:
DOCKET NO.
PLAINTIFF SS NO.:
NAME:
DEFENDANT SS NO.:
NAME:
July 15, 2004
No. 99-7450 Civil Term
202-60-8869
Jennifer Janc Farr-Loy
187-50-4026
Jeffrey Abbott Loy
ir±-
JENNIFER JANE FARR-LOY
Plaintiff
VS.
JEFFREY ABBOTT LOY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99 - 7450
NO. CIVIL 19
IN DIVORCE
Defendant
STATUS SHEET
DATE: CTIVITIES:
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JENNIFER JANE FARR-LOY,
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
:IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7450 CIVIL
IN DIVORCE
TO: Austin F. Grogan Attorney for Plaintiff
Jeffrey Abbott Loy Defendant
DATE: Monday, June 17, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
. -40
JENNIFER JANE FARR-LOY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 7450 CIVIL
JEFFREY ABBOTT LOY,
Defendant IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Austin F. Grogan
Jennifer Jane Farr-Loy
Charles E. Petrie
Jeffrey Abbott Loy
Counsel for Plaintiff
Plaintiff
Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 8th day of May 2003, at 9:00 a.m., with
counsel and the parties to discuss the outstanding economic
issues to determine if there is a basis of settlement of
claims. If issues remain after the conference, a hearing
will be scheduled at another date.
Very truly yours,
Date of Notice: E. Robert Elicker, II
April 23, 2003 Divorce Master
)an M. Wiley
David 1• Lenox
Timothy J. Colgan
Christopher 1. Marzzacco
THE WILEY GROUP
Attnntcys at t r.v
Wiley, Lenox, Colgan & Marzzacco, RC.
July 1, 2004
Traci Colyer
Divorce Master's Office
9 North Hanover Street
Carlisle, PA 17013
Re: Jennifer J. Farr-Loy v. Jeffrey Abbott Loy
No. 1999-07450, In Divorce
Dear Ms. Colyer:
David E. Hershey
Diana Woodside
Bradley A. Winniek
Jennifer L. Frechette
Enclosed please find two copies of the Marital Settlement Agreement executed
in the above referenced case. Please prepare an Order to Vacate the Appointment of
the Master so that we may finalize the divorce.
If you have any questions, please feel free to call me. Thank you for your
assistance in this matter.
Sincerely,
Jennifer L. Spears
enclosures
cc Jennifer J. Farr
Charles Petrie, Esquire
130 W. Church Street, Suite 100 • Dillsburg, PA 17019 • Phone: (717) 432-9666 • (800) 682-4250 • Fax: (717) 432-0426
Offices in Harrisburg • York • Carbondale
www.wileygroupl,lkv.com
COYNE & COYNE
A PROFUSIONAL CORPORATION
ATTORNEYS AT LAW
Henry F. Coyne
Lisa Marie Coyne
Austin F. Grogan
3901 Market Street
Camp Hill, Pennsylvania
1701IA227
April 16, 2003
E. Robert Elicker, III, Esquire
Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Farr-Loy v. Loy
Dear Mr. Elicker:
717-737-0464
Pax: 717-737-5161
?IVh
This is a follow-up in the Loy Conference that was scheduled with the parties and counsel in
October of 2002. As you will remember, you directed the parties to exchange updated information
regarding the appraisal of the house and values of Mrs. Farr-Loy's car and pension paid. The
information has been exchanged between counsels so I ask some consideration for an expedited
Master's Hearing because at the same time Mr. Loy was retaining counsel and disputing Mrs. Farr-
Loy's interest in the marital property, he ceased payment of the mortgage which now is approximately
four months in arrears. Foreclosure action has now been commenced by the lender against both parties
indicating that Mr. Loy stopped payments beginning October 2002. I believe this is an attempt to
dissipate the marital state to my client's detriment. Accordingly, I ask for an expedited Master's
Hearing.
Please have your office coordinate with Attorney Petrie and me as to when we can have a
conference and potentially settle this case.
Very truly yours,
COYNE & COYNE, P.C.
AFG/amd
Cc: Jennifer Farr-Loy
Charles Petrie, Esq.
A
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JENNIFER JANE FARR-LOY,
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 7450 CIVIL
IN DIVORCE
PRE-HEARING CONFERENCE
TO: Austin F. Grogan
Jeffrey Abbott Loy
Counsel for Plaintiff
Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 7th day of October, 2002, at
9:30 a.m., at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 7/29/02
E. Robert Elicker, II
Divorce Master
Austin F. Grogan, Attorney for Plaintiff, filed a pre-trial
statement on July 17, 2002.
Jeffrey Abbott Loy, Defendant, has not filed a pre-trial
statement as of the date of this notice.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci Jo Colyer
Office Manager/Reporter July 2, 2002
West Shore
697.0371 Ext. 6535
Austin F. Grogan, Esquire Jeffrey Abbott Loy
24 North 32nd Street 3944 Rauch Street
Camp Hill, PA 17011 Harrisburg, PA 17109
RE: Jennifer Jane Farr-Loy vs. Jeffrey Abbott Loy
No. 99 - 7450 Civil
In Divorce
Dear Mr. Grogan and Mr. Loy:
I have received the certification from Mr. Grogan indicating that
discovery is complete. Therefore, we can move forward with pretrial
statements and conference.
A divorce complaint was filed on December 13, 1999, raising
grounds for divorce of irretrievable breakdown of the marriage. No
economic claims were raised in the complaint. An amended complaint
was filed on behalf of the Plaintiff on October 5, 2001, averring the
parties separated October 9, 1999. Another amended complaint was
filed on June 5, 2002, raising the economic claim of equitable
distribution. No claims have been raised for alimony or counsel fees and
expenses.
In accordance with P.R.C.P. 1920.33(b) I am directing Mr. Grogan
and Mr. Loy, if he remains unrepresented, to each file a pretrial
statement on or before Monday, July 22, 2002. Upon receipt of the
pretrial statements, I will immediately schedule a pre-hearing conference
with counsel or Mr. Loy, if he remains unrepresented, to discuss
Mr. Grogan and Mr. Loy
2 July 2002
Page 2
the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
JENNIFER JANE FARR-LOY,
Plaintiff
Vs.
JEFFREY ABBOTT LOY,
Defendant
TO: Austin F. Grogan
Jeffrey Abbott Loy
:IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7450 CIVIL
IN DIVORCE
Attorney for Plaintiff
Defendant
DATE: Monday, June 17, 2002
CERTIFICATION
" I 11"certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISQO`
(a) Outline what informa
complete in order to
and indicate whether
interrogatories or q
N,
IS NOT COMPLETE:
is required that is not
are the case for trial
e are any outstanding
ery motions.
i'-N
(b) Provide approximate date n discovery will be
complete and indicate w t action is being taken
to complete discovery
DATE COUNSEL FOR PLAIN F (?`)
COUNSEL FOR DEFEN T ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
JENNIFER JANE FARR-LOY
Plaintiff
v.
JEFFREY ABBOTT LOY,
Defendant
MOTION FOR APPOINTMENT OF MASTER
Jennifer Jane Farr-Loy, Plaintiff, moves the Court to appoint a Master with respect to the
following claims:
(X) Divorce (X) Distribution of Property
() Annulment () Support
() Alimony () Counsel Fees
() Alimony Pendente Lite () Cost and Expenses
and in support of the motion states:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
(1) Discovery is complete as to the claim(s) for which the appointment of a master is
requested.
(2) The defendant has not appeared in the action personally.
(3) The statutory ground(s) for divorce: 3301(d)
(4) Delete the inapplicable paragraph(s):
(a) The action is contested.
(b) The action is contested with respect to the following claims: equitable distribution.
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take 2 hours.
(7) Additional information, if any relevant to the motion: N/A
Date S/acl ?e ''? ??c
Austin F. Grogan, ire
Attorney for Plaint
c
ORDER APPOINTING MASTER
AND NOW, this day of C? 2002, Esquire, is
appointed master with respect to the following,' laims:
BY THE COU
Judge
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JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-7450 CIVIL TERM
JEFFREY ABBOTT LOY, IN DIVORCE
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
r .
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
AMENDED DIVORCE COMPLAINT
1• The Plaintiff is JENNIFER JANE FARR-LOY, Social Security number 202-60-
8869, who currently resides at 6116 Charing Cross, Mechanicsburg, Cumberland County,
Pennsylvania.
2. The Defendant is JEFFREY ABBOTT LOY
Social Security number 187-50- `
4026, who currently resides at 3944 Rauch Street, Harrisburg, Dauphin County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 19, 1991 at Snow Hill, Maryland.
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections +I
3301(c), 3301(d), in that:
a) The marriage is irretrievably broken.
b) Plaintiff and Defendant have lived separate and apart since October
9, 1999 and continue to do so.
8. The Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
Date _A- u //-c7/
Respectfully submitted,
? jlV:3?
Austin P. Grogan, Esquir
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
I.D. #59020
VERIFICATION
I, JENNIFER JANE FARR-LOY, verify that the statements made in the foregoing Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom
falsification to authorities.
Date
JEN IFER A ARR-LOY
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JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-7450 CIVIL TERM
JEFFREY ABBOTT LOY, IN DIVORCE
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
AMENDED DIVORCE COMPLAINT
I. The Plaintiff is JENNIFER JANE FARR-LOY, Social Security number 202-60-
8869, who currently resides at 6116 Charing Cross, Mechanicsburg, Cumberland County,
Pennsylvania.
2. The Defendant is JEFFREY ABBOTT LOY, Social Security number 187-50-
4026, who currently resides at 3944 Rauch Street, Harrisburg, Dauphin County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 19, 1991 at Snow Hill, Maryland.
COUNT I - DIVORCE
5. Paragraphs I through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections
3301(c), 3301(d), in that:
a) The marriage is irretrievably broken.
b) Plaintiff and Defendant have lived separate and apart since October
9, 1999 and continue to do so.
8. The Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
COUNT II - EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
11. Plaintiff and Defendant have acquired property, both real and personal, during
their marriage from August 19, 1991, until October 9, 1999, the date of their separation, which
property is "marital property".
12. Plaintiff and Defendant may have owned, prior to the marriage, property which
has increased in value during the marriage and/or which has been exchanged for other property,
which has increased in value during the marriage, all of which property is "marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property prior to the filing of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property.
Respectfully submitted,
Date G - `i (L4 (, ` J . /Jl e, t
Austin F. Grogan, Esquire' ll
24 North 32nd Street ?J
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
I.D. #59020
VERIFICATION
1, JENNIFER JANE FARR-LOY, verify that the statements made in the foregoing Amended
Divorce Coplaint are true and correct to the best of my knowledge, information, and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904,
relating to unworn falsification to authorities.
Date 5/36162- /(
JE IFER AN ARR-LOY
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JENNIFER JANE FARR-LOY
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
r-n
INVENTORY
OF
PLAINTIFF, JENNIFER J. FARR-LOY
(J
I, JENNIFER JANE FARR-LOY, Plaintiff, file the following Inventory of all property
owned or possessed by either party at the time this action was commenced and all property
transferred within the preceding three years.
I hereby verify that the statements made in this Inventory are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904
relating to unswom falsification to authorities.
DATE Z
JE IFER A FARR-LOY
Fri
ASSETS OF PARTIES
Plaintiff, JENNIFER JANE FARR-LOY, marks on the list below those items applicable
to the case at bar and itemizes the assets on the following pages.
(X) I. Real property
(X) 2. Motor vehicles
() 3. Stock, bonds, securities and options
O 4. Certificates of deposit
() 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
()
() 8.
9. Trusts
Life Insurance policies (indicate face value, cash surrender value and current
beneficiaries)
O 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Businesses (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
(} 16. Employment termination benefits - severance pay, workman's compensation
claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, individual retirement accounts
() 20. Disability payments
() 21. Litigation claims (matured and unmatured)
() 22. Military/VA benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
(X) 25. Household fumishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute)
() 26. Other
MARITAL PROPERTY
i
Plaintiff, JENNIFER JANE FARR-LOY, lists all marital property in which either or both
spouses have a legal or equitable interest individually or with any other person as of the date this
action was commenced:
Item Description of Property Names of All Owners
Number
1 3944 Rauch St. Harrisburg, PA Jeffrey & Jennifer Loy
2 1996 Ford Thunderbird Jeffrey & Jennifer Loy
25 Household Goods Jeffrey & Jennifer Loy
19 IRA Jennifer Farr-Loy
NON-MARITAL PROPERTY
Plaintiff, JENNIFER JANE FARR-LOY, lists all property in which a spouse has a legal
or equitable interest, which is claimed to be excluded from marital property:
Item Description of Property Reason for Exclusion
Number
PROPERTY TRANSFERRED
Item Description of Date of Consideration Person to
No. Property Transfer Whom
Transferred
LIABILITIES
Item Names of All Names of All
Number Description of Property Creditors Debtors
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that on IV eA -- 2002,1
served a copy of the Plaintiff s Inventory by first class mail, postage prepaid addressed as follows:
Jeffrey A. Loy
3944 Rauch Street
Harrisburg, PA 17109-2226
Dated../ 4 . v z
Austin F. Grogan, Es uire
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
/
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
INCOME AND EXPENSE STATEMENT
OF
PLAINTIFF JENNIFER J. FARR-LOY
The undersigned files the following Income and Expense Statement.
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 S/
JEN IFER Y. F -LOY
C7 iJrl
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rntrnME AND EXPENSE STATEMENT
INCOME:
Employer: Self
Address: 6116 Charin Cross
Mechanicsburg, PA 17050
Type of Work: Professional Personal Chef
Payroll Number:
Pa Period: Weekly
Gross Pa per Pa Period:
Itemized Payroll Deductions:
Federal Withholding
Social Security
Local Income Tax
State Income Tax
Retirement
Savings Bonds
Credit Union
Life Insurance
Health Insurance
Other (Specify)
Net Pa per Pa Period: $0.00
(Fill in appropriate column)
OTHER INCOME: Weekly Monthly Yearly
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Com2ensation
Workmen's Compensation
Other (Specify):
Total $0.00 $0.00 $0.00
EXPENSES: Weekly Monthly Yearly
HOME
INCOME AND EXPENSE STATEMENT
Mortgage/Rent
Maintenance
Utilities
Electric
Gas
O
il
T
ele hone $33.44
Water
Sewer
Trash
EMPLOYMENT
Public Transportation
Lunch
TAXES
Real Estate
Personal
Property (land)
Income (school)
INSURANCE
Homeowners
Automobile $45.00
Life
Accident
Health $215.00
Other (Specify):
AUTOMOBILE
Payments W
Fuel
Repairs
MEDICAL
Doctor
Dentist
Orthodontist
Hospital (lab)
Medicine
Special Needs (glasses, braces...)
EXPENSES CONTINUED
EDUCATION Weekly Monthly Yearly
Private School
Parochial $2,995.00
tNr.nMF AND EXPENSE STATEMENT
College (ICS)
Religious
PERSONAL
Clothing
Food
Barber/Hairdresser
Credit Payments
Charge Accounts
Memberships: BJ's $40.00
LOANS
Credit Union
Other (specify):
MISCELLANEOUS
Household Help
Child Care
Papers, Books, Magazines
ENTERTAINMENT
Cable TV $36.93
Vacation
Gifts
OTHER
Legal Fees. $2,500.00
Charitable Contributions
Other Child Support
Alimony Payments
Other (specify): Water Cooler Service $247.31
TOTAL EXPENSES $15.00 $330.37 $5,782.31
PROPERTY OWNED Description Value H W J C
Checking Accounts x
Savings Accounts Savings/Christmas x
Credit Union
Stocks/Bonds
IRA Photocopies attached x
Real Estate
Other:
TOTAL $0.00
INSURANCE Company Policy Number H W J C
Hospital
Blue Cross
Other
Medical
Blue Shield
Other
Health/Accident
Disability
Dental
Prescription
Other:
*H=Husband; W=Wife; J=Joint; C=Child
JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-7450 CIVIL TERM
JEFFREY ABBOTT LOY, IN DIVORCE
Defendant
PROOF OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that on the Ix? day of Q?
2002 I served a copy of the Plaintiff's Income and Expense Statement by first class mail, postage
prepaid addressed as follows:
Date I- I to • 02
C U ? "
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
ClMMC?C° 'l.4'K/HA=?LSUU4G. N.A. COT= _11'21.2
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ACCOUNT NUM9E° ..•."J":.'.,1
TOTAL VALU•_ JANUA-Y 1, 21
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JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
The Plaintiff, JENNIFER J. FARR-LOY, files the following Pre-Trial Statement.
LIST OF ASSETS - MARITAL AND NON-MARITAL
Plaintiff, JENNIFER J. FARR-LOY, requests a stipulation that the date of final
separation was October 9, 1999. The inventory is supplemented with the values of the marital
and non-marital property on the attached charts:
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CAM46z' W_ XOrUJI
ATTORNEY AT LAW
24 North 32nd Street
Camp Hill, PA 17011
Telephone (717) 737-1956
Fax (717) 761-5319
July 25, 2002
E. Robert Elicker, III
Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re. Farr-Loy v. Loy
Dear Mr. Elicker:
This is a follow up to the Pretrial Statements submitted to your office on July
17, 2002 in the above referenced case. It has come to my attention that there is
typographical error in the Pretrial Statement under Marital Debts wherein the mortgage
is listed with a payoff of approximately $5,500.00. That actual debt remaining on the
mortgage should be approximately $55,000.00.
If you have any questions or require further information, please contact nie at
your convenience.
Sincerely,
Austin F. Grogan, Esq.
AFG/rr
Cc: Jennifer Farr-Loy
Jeffrey A. Loy
EXPERT WITNESSES: Plaintiff does not intend on calling expert witnesses. Plaintiff reserves
the right to call expert witnesses.
OTHER WITNESSES: Plaintiff reserves the right to modify witness list.
EXHIBITS: Plaintiff intends on submitting tax documents for home appraisal or requests that the
home be appraised by an expert.
PLAINTIFF'S GROSS INCOME: $0.00
PENSION AND RETIREMENT: Plaintiffs IRA $6,405.00
COUNSEL FEES: $5,000.00
PERSONAL PROPERTY: See attached documents.
MARITAL DEBTS: Mortgage approximately $5,500.00 and bottled water bill of $247.31.
PROPOSED RESOLUTION OF ECONOMIC ISSUES: Wife retains IRA; husband keeps home
and pays wife half of the equity; property in home is awarded to husband.
Respectfully submitted,
Date ??" 0 2 ??n O J cL?` -'
Austin F. Grogan, squire
24 North 32nd Street, C Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
VERIFICATION
I, JENNIFER JANE FARR-LOY, verify that the statements made in the foregoing Pre-
Trial Statement are true and correct to the best of my knowledge, information and belief, 1
understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. §
4904, relating to unsworn falsification to authorities.
lc?
DATE J [3010 Z
7
JQ4NIFE lA i FAl
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450
CIVIL TERM
IN DIVORCE
PROOF OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that on
Z- 2002, I
served a copy of the Plaintiff's Pre-Trial Statement by first class mail, postage prepaid addressed
as follows:
Jeffrey A. Loy
3944 Rauch Street
Harrisburg, PA 17109-2226
Date 14 ?-0?
Austin F. Grogan, Esquir
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
NUMBER: 99-7450 CIVIL TERM r?
JEFFREY ABBOTT LOY,
Defendant IN DIVORCE
INVENTORY -
OF
JEFFREY ABBOTT LOY, DEFENDANT
cr'? '
Plaintiff files the following inventory of all property owned or possessed
by either party at the time this action was commenced and all property
transferred within the preceding three years.
Plaintiff verifies that the statements in this inventory are true and
correct. Plaintiff understands that false statements herein are made subject to
the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
DEFENDANT
ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the case at
bar and itemize the assets on the following pages.
(X) 1. Real property
(X) 2. Motor vehicles
() 3. Stocks, bonds, securities and options
O 4. Certificates of deposit
r.
i
-i I
() 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
1
() 8. Trusts S
() 9. Life insurance policies (indicate face value, cash surrender value and
current beneficiaries)
() 10. Annuities '
O 11. Gifts ;
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties I't
It
() 14. Personal property outside the home
O 15. Business (list all owners, including percentage of ownership, and a
h
officer/ director positions held by a party with company)
() 16. Employment termination benefits-severance pay, worker's Ir
'•
compensation claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
() 20. Disability payments
() 21. Litigation claims (matured and unmatured)
() 22. Military/VA benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held -
() 25. Household furnishings and personalty (include as a total category and
attach itemized list if distribution of such assets is in dispute)
( ) 26. Other
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a
legal or equitable interest individually or with any other persona as of the date
this action was commenced:
Item Description
Number of Property
1.
2.
25.
19.
Names of
All Owners
3944 Rauch Street, Harrisburg, PA Jeffrey & Jennifer Loy
1996 Ford Thunderbird
Household Goods
IRA
Jeffrey & Jennifer Loy
Jeffrey & Jennifer Loy
Jennifer Farr-Loy
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable
interest which is claimed to be excluded from marital property:
Item Description Reason for
Number of Property Exclusion
25. All personal property purchased
by Defendant since October, 1999
PROPERTY TRANSFERRED
Item
Number
None
Consid-
eration
LIABILITIES
Names of
All Creditors
Citibank
Description Date of
of Property Transfer
Item Description
Number of Property
1. Credit card debt
2. Credit card debts to be provided
Person
to Whom
Transferred
Names of
All Debtors
Jeffrey Loy
to be provided
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements in the foregoing Pre-Trial Statement 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.
o 4 ho o -L-
DAT REY A BOTT LOY
JENNIFER JANE FARR-LOY
Plaintiff
VS.
JEFFREY ABBOTT LOY,
Defendant
* IN THE COURT OF COMMON PLEAS
* OF CUMBERLAND COUNTY
* PENNSYLVANIA
* No. 99-7450 Civil Term
* CIVIL ACTION - LAW IN DIVORCE
PRAECIPE TO DISCONTINUE AMENDED DIVORCE COMPLAINTS
AND RELATED CLAIMS THEREIN
To the Prothonotary:
Please discontinue the Amended Divorce Complaints filed in the above-
referenced action on October 5, 2001, June 5, 2002 and November 27, 2002 and the
additional claims raised therein, as Plaintiff wishes to withdraw them. The original
Divorce Complaint will be left as is.
Je PeyLenox Spears, Esquire
Marzzacco, PC
W, Colga n &
130 W. Church Street
Dillsburg, PA 17019
ID # 87445
ATTORNEY FOR PLAINTIFF
Dated: July 1, 2004
u?r cV ?Q
i
w
LL o
N U
JENNIFER JANE FARR-LOY
Plaintiff
Vs.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
• CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450
` CIVIL ACTION - LAW
` IN DIVORCE
PRAECIPE FOR WITHDRAW OF APPEARANCE
Please withdraw my appearance on behalf of Plaintiff, Jennifer Jane Farr-Loy, in the
above captioned matter without prejudice.
Date: +a U3 at.'Iv t? ?A?
Austin F. Grogan, Esq . e
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Plaintiff, Jennifer Jane Farr-Loy, in the
above captioned matter.
Dater I ?1 I v ' a:q (?ktb
Jennifer L. Frechette, Esquire
Wiley, Lenox, Colgan & Marzzacco, PC
One South Baltimore Street
Dillsburg, PA 17019
I D # 87445
+ -7 L
C- 7
L Ll
C l
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
The Plaintiff, JENNIFER J. FARR-LOY, files the following Pre-Trial Statement.
LIST OF ASSETS - MARITAL AND NON-MARITAL
Plaintiff, JENNIFER J. FARR-LOY, requests a stipulation that the date of final
separation was October 9, 1999. The inventory is supplemented with the values of the marital
and non-marital property on the attached charts:
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EXPERT WITNESSES: Plaintiff does not intend on calling expert witnesses. Plaintiff reserves
the right to call expert witnesses.
OTHER WITNESSES: Plaintiff reserves the right to modify witness list.
_ EXHIBITS: Plaintiff intends on submitting tax documents for home appraisal or requests that the
home be appraised by an expert.
PLAINTIFF'S GROSS INCOME. $0.00
PENSION AND RETIREMENT: Plaintiffs IRA $6,405.00
COUNSEL $5,000.00
PERSONAL PROPERTY: See attached documents.
MARITAL DEBTS: Mortgage
approximately $5,500.00 and bottled water bill of $247.31.
PROPOSED RESOLUTION OF ECONOMIC ISSUES, Wife retains IRA; husband keeps home
and pays wife half of the equity; property in home is awarded to husband.
Respectfully submitted,
Date ?(, , d 2
Austin F. Grogan,, squire
24 North 32nd Street, C i
(717) 737-1956 am Hill, PA 17011
Attorney for Plaintiff
ID #59020
i^
AWN
VERIFICATION
I, JENNIFER JANE FARR-LOY, verify that the statements made in the foregoing Pre-
Trial Statement are true and correct to the best of my knowledge, information and belief. I
understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. §
4914, relating to unsworn falsification to authorities.
DATE 7
J NIFE JA FARR-LOY
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
PROOF OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that on
a 12002, I
served a copy of the Plaintiff's Pre-Trial Statement by first class mail, postage prepaid addressed
as follows:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450
CIVIL TERM
IN DIVORCE
Jeffrey A. Loy
3944 Rauch Street
Harrisburg, PA 17109-2226
Date ?/
Austin F. Grogan, Esquir
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
IL r.
LUG? --J _ r
ii
% . r0,
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
INCOME AND EXPENSE STATEMENT
OF
PLAINTIFF, JENNIFER J. FARR-LOY
The undersigned files the following Income and Expense Statement.
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
'5imlo Z- " 9
JEN' IFER Y. F R-LOY
INCOME AND EXPENSE STATEMENT
INCOME:
Employer: Self
Address: 6116 Charing Cross
Mechanicsburg, PA 17050
Type of Work: Professional Personal Chef
Payroll Number:
Pa Period: Weekly
Gross Pa per Pa Period:
Itemized Payroll Deductions:
Federal Withholding
Social Security
Local Income Tax
State Income Tax
Retirement
Savings Bonds
Credit Union
Life Insurance
Health Insurance
Other (Specify)
Net Pa per Pa Period: $0.00
(Fill in a ro riate column)
OTHER INCOME: Weekly Monthly Yearly
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Compensation
Workmen's Compensation
Other (Specify):
Total $0.00 $0.00 $0.00
EXPENSES: Weekly Monthly Yearly
HOME
n
P'1
INCOME AND EXPENSE STATEMENT
Mortgage/Rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone $33.4 4
Water
Sewer
Trash
EMPLOYMENT
Public Transportation
Lunch
TAXES
Real Estate
Personal
Property (land)
Income (school)
INSURANCE
Homeowners
Automobile $45.00
Life
Accident
Health
$215.00
Other (Specify):
AUTOMOBILE
Payments
Fuel $15.00
Re airs
MEDICAL
Doctor
Dentist
Orthodontist
Hospital (lab)
Medicine
Special Needs (glasses, braces...)
EXPENSES CONTINUED
EDUCATION Weekly Monthl Yearl
Private School
Parochial $2,995.00
r
INCOME AND EXPENSE STATEMENT
College (ICS)
Religious
PERSONAL
Clothing
Food
Barber/Hairdresser
Credit Payments
Charge Accounts
Memberships: BJ's $40.00
LOANS
Credit Union
Other (specify):
MISCELLANEOUS
Household Help
Child Care
Papers, Books, Magazines
ENTERTAINMENT
Cable TV $36.93
Vacation
Gifts
OTHER
Legal Fees $2,500.00
Charitable Contributions
Other Child Support
Alimony Payments
Other (specify): Water Cooler Service $247.31
TOTAL EXPENSES $15.00 $330.37 $5,782.31
/'\
PROPERTY OWNED Description Value H W J C
Checkin Accounts x
Savings Accounts
Credit Union Savings/Christmas x
Stocks/Bonds
IRA Photocopies attached x
Real Estate
Other:
TOTAL $0.00
INSURANCE Company Policy Number H W J C
Hospital
Blue Cross
Other
Medical
Blue Shield
Other
Health/Accident
Disabilit
Dental
Prescription
Other:
*H=Husband; W=Wife; J=Joint; C=Child
JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-7450 CIVIL TERM
JEFFREY ABBOTT LOY, IN DIVORCE
Defendant
PROOF OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that on the f r?J day of
2002 I served a copy of the Plaintiff's Income and Expense Statement by first class mail, postage
prepaid addressed as follows:
Date 7- I to -
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
(717)737-1956
Attorney for Plaintiff
ID #59020
C•7te Me_ •F g:, `Ih./Ha-•?LSi1UIG. N.A. Ca TE _t/'L/_'
CV-W HILL.
.*k i=;. STAT_M-VT JF ,CrtLUNT F.D TAX YcAR 2'_l kA.
ia% f0 NU'?J?r _-c`-9afi •7 ;! GULAG IJJA
J.V7JIF:..i J FA-TP
:!IG CHASING CROSS
IJ_CHiNICSJURG PA 17•.3'
ACCOUNT NU49E? „"'J-1711
TOTAL V•ALUc JANUA?Y !. 2':. '
PLUS
o°CIIL A.i DAYM NITS
"fr'LL/O.:CrWtAOT=?;L:O PAYMF hlr3 6 ?72'1 •44
T =AhISF'_- PAYN°,VTS
PAY..MI NTS IN 2".! FO= °__ '
v=:.?-TO-.iAic EA°NlNrS o''•!?
L-GS
0AYMENT '41TH7RAmALS
--JLV .JtfHDRAWaLS - NO -ACdPTIO'IS
NOAYAL 015 TG I RUT IONS IN d^.1
a RLY 4!THDRAWALS - EXC-PTIONS
T -%NSFL'J WITHDPA',J •1L5
S-RVICL ChIA4G= FtES •?
y'!LV rYITHiJ0A'A-L o_NALTlCS
TOTAL VALU? 5.7d-•"
111TFR- T a;:CaU_O I1.
Fa:= MA-?K°T VALUZ -IF •ACCOU VT A+A 5.4 V5.'6
UTSTi:IrlUTTJ'IS dITHHFLC`.
.kk THlS I.v°Ja,IATIJN IS zi=1%IG FU%rhl:SHcU T^ THE TNTt=hIIL k VENUc SFPV1Ct
nl
LIJ rI ( ?
p )
?) U
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
INVENTORY
OF
PLAINTIFF, JENNIFER J. FARR-LOY
I, JENNIFER JANE FARR-LOY, Plaintiff, file the following Inventory of all property
owned or possessed by either party at the time this action was commenced and all property
transferred within the preceding three years.
I hereby verify that the statements made in this Inventory are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904
relating to unworn falsification to authorities.
DATE `) Z
JE IFER A FARR-LOY
ASSETS OF PARTIES
Plaintiff, JENNIFER JANE FARR-LOY, marks on the list below those items applicable
to the case at bar and itemizes the assets on the following pages.
(X) 1. Real property
(X) 2. Motor vehicles
() 3. Stock, bonds, securities and options
() 4. Certificates of deposit
O 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
() 9. Life Insurance policies (indicate face value, cash surrender value and current
beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Businesses (list all owners, including percentage of ownership, and
officer/director positions held by a parry with company)
() 16. Employment termination benefits - severance pay, workman's compensation
claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, individual retirement accounts
() 20. Disability payments
() 21. Litigation claims (matured and unmatured)
() 22. MilitaryNA benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute)
() 26. Other
1J :N
MARITAL PROPERTY
Plaintiff, JENNIFER JANE FARR-LOY, lists all marital property in which either or both
spouses have a legal or equitable interest individually or with any other person as of the date this
action was commenced:
Item I Description of Property
Number Names of All Owners
1 3944 Rauch St. Harrisburg, PA
Jeffrey & Jennifer Loy
2 1996 Ford Thunderbird
Jeffrey & Jennifer Loy
25 Household Goods
Jeffrey & Jennifer Loy
19 IRA
Jennifer Farr-Loy
NON-MARITAL PROPERTY
Plaintiff, JENNIFER JANE FARR-LOY, lists all property in which a spouse has a legal
or equitable interest, which is claimed to be excluded from marital property:
Item Description of Property I Reason for Exclusion
Number
fr
PROPERTY TRANSFERRED
Item Description of Date of Consideration Person to
No. Property Transfer Whom
Transferred
LIABILITIES
Item Names of All Names of All
Number Description of Property Creditors Debtors
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that on 1 2002,1
served a copy of the Plaintiff's Inventory by first class mail, postage prepaid addressed as follows:
Jeffrey A. Loy
3944 Rauch Street
Harrisburg, PA 1 71 09-2 22 6
Date'/ 4, v Z
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
?-
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JENNIFER JANE FARR-LOY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
VS.
NUMBER: 99-7450 CIVIL TERM
JEFFREY ABBOTT LOY,
Defendant IN DIVORCE
INVENTORY
or
JEFFREY ABBOTT LOY, DEFENDANT
Plaintiff files the following inventory of all property owned or possessed
by either party at the time this action was commenced and all property
transferred within the preceding three years.
Plaintiff verifies that the statements in this inventory are true and
correct. Plaintiff understands that false statements herein are made subject to
the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
DEFENDANT
ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the case at
bar and itemize the assets on the following pages.
(X) 1. Real property
(X) 2. Motor vehicles
() 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
O 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
() 9. Life insurance policies (indicate face value, cash surrender value and
current beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Business (list all owners, including percentage of ownership, and
officer/ director positions held by a party with company)
( ) 16. Employment termination benefits-severance pay, worker's
compensation claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and un
( ) 22. Military/VA benefits
O 23. Education benefits
O 24. Debts due, including loans, mortgages held -
() 25. Household furnishings and personalty (include as a total category and
attach itemized list if distribution of such assets is in dispute)
( ) 26. Other
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a
legal or equitable interest individually or with any other persona as of the date
this action was commenced:
Item Description
Number of Property
1.
2.
25.
19.
Names of
All Owners
3944 Rauch Street, Harrisburg, PA Jeffrey & Jennifer Loy
1996 Ford Thunderbird
Household Goods
IRA
Jeffrey & Jennifer Loy
Jeffrey & Jennifer Loy
Jennifer Farr-Loy
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable
interest which is claimed to be excluded from marital property:
Item Description Reason for
Number of Property Exclusion
25. All personal property purchased
by Defendant since October, 1999
PROPERTY TRANSFERRED
Item
Number
None
Description Date of Consid-
of Property Transfer eration
LIABILITIES
Names of
All Creditors
Citibank
Item Description
Number of Property
1. Credit card debt
2.
Credit card debts to be provided
Person
to Whom
Transferred
Names of
All Debtors
Jeffrey Loy
to be provided
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements in the foregoing Pre-Trial Statement 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.
Q ().L-
DAT
REY A BOTT LOY
Di
1 G
L
? C"i 'j
' O U
JENNIFER JANE FARR-LOY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-7450 CIVIL TERM
JEFFREY ABBOTT LOY, IN DIVORCE
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
JENNIFER JANE FARR-LOY,
Plaintiff
V.
JEFFREY ABBOTT LOY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7450 CIVIL TERM
IN DIVORCE
AMENDED DIVORCE COMPLAINT
1. The Plaintiff is JENNIFER JANE FARR-LOY, Social Security number 202-60-
8869, who currently resides at 6116 Charing Cross, Mechanicsburg, Cumberland County,
Pennsylvania.
2. The Defendant is JEFFREY ABBOTT LOY, Social Security number 187-50-
4026, who currently resides at 3944 Rauch Street, Harrisburg, Dauphin County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 19, 1991 at Snow Hill, Maryland.
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections
3301(c), 3301(d), in that:
a) The marriage is irretrievably broken.
b) Plaintiff and Defendant have lived separate and apart since October
9, 1999 and continue to do so.
8. The Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
COUNT II - EQUITABLE DISTRIBUTION
10. Paragraphs I through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
11. Plaintiff and Defendant have acquired property, both real and personal, during
their marriage from August 19, 1991, until October 9, 1999, the date of their separation, which
property is "marital property".
12. Plaintiff and Defendant may have owned, prior to the marriage, property which
has increased in value during the marriage and/or which has been exchanged for other property,
which has increased in value during the marriage, all of which property is "marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property prior to the filing of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property.
COUNT III - COUNSEL FEES AND COSTS
14. Paragraphs 1 through 13 of this Complaint are incorporated herein by reference as
though set forth in full.
15. Plaintiff has retained the Law Offices of Austin F. Grogan but she is unable to pay
the necessary and reasonable attorneys' fees for said counsel.
16. Plaintiff may need to hire experts to appraise the marital property but she lacks
funds to pay the necessary and reasonable fees.
WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim
counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed
necessary and appropriate, and at final hearing to award such additional counsel fees, costs and
expenses as are deemed necessary and appropriate.
Respectfully submitted,
Date vV UV ((
Austin F. Groga, Fsgtiire
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
I.D. #59020
VERIFY
I, JENNIFER JANE FARR-LOY, verify that the statements made in the foregoing Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn
falsification to authorities.
Date JENN ER J NE ARR-LOY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
JCu?n; kr.l?ne ?r? Loy
Plaintif l l _7-7 SQ ci ?r I
Vs File No.
IN DIVORCE
?-fT Ir(,ct OT7 (.O
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/ defendant in the above matter,
[select one by marking "x"]
- prior to the entry of a Final Decree in Divorce,
or x after the entry of a Final Decree in Divorce dated OIL ?/v
hereby elects to resume the prior surname of r?'rr , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704.
Date: 2 b
Signature
Y HMI g . ?-a,,
Signa ure of name being resumed
COMMONWEALTH OFF PE?NNSYI,VANIA )
COUNTY OF ('/ Q - . c
On the ZJ day ofJ lP Lfl- , 200 , before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
INOTAfiiAl- SEAL
C:AUCIAA. bP.FWBAM.ER, NO TARYPUBLIC
Carl::de Boro. Camberlano County
N: rur,r,+ssion irpues April?, 2005
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