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IN THE COURT OF COMMON FLEAS
OF CUMBERLAND COUNTY
STATE OF r?`n PENNA.
DECREE IN
DIVORCE
19
AND NOW , . . . .. . . ? C IS M.2999• , it is ordered and
decreed that . . . . . .. .. . . . . . PATRICIA . WENTZ . . . . . . . . . .. . .... • . , • • , plaintiff,
.............
LARRY J. WENTZ . , defendant,
and ........................................................
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
The terms of the parties' Marital Settlement Agreement dated
...........................................................................
April 3, 2000, and attached hereto are incorporated herein but not merged
.........................................................................
By Th eo urt:
Attc t ^ J.
Prothonotary
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daf? 2000,byandbetween
'PI-IISAGREENIEN P, made this Yo
PATRICIA A. WENTZ of Enola, Pennsylvania, (hereinafter "WIFE") and LARRY J.
WENTZ of Enola, Pennsylvania, (hereinafter "HUSBAND");
WITNESSETH:
WHEREAS, the parties hereto were married on August 17, 1985 in Long Island, New
York;and
WHEREAS, a divorce action was filed by WIFE on or about December 20, 1999 in the
Cumberland County Court of Common Pleas at 99-7579 CIVIL ACTION-LAW; and
WHEREAS, there are three (3) children, namely; Bryan J. Wentz, date of birth August
25, 1986; Timothy M. Wentz, date of birth September 18, 1987; and Matthew S. Wentz, date
of birth April 3, 1991; and
WHEREAS, the parties separated on or about April, 1997; and
WHEREAS, difficulties have arisen between the parties and it is therefore their
intention to live separate and apart for the rest of their lives and the parties are desirous of
settling completely the economic and other rights and obligations between each other,
including, but not limited to: the equitable distribution of the marital property; past, present
and future support; alimony, alimony pendente lite; and, in general, any and all other claims
and possible claims by one against the other or against their respective estates; and
NOW THEREFORE, in consideration of the covenants and promises hereinafter to s
be kept and performed by each party and intending to be legally bound hereby, the parties do
hereby agree as follows:
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1. ADVICE OF COUNSEL.
The provisions of this agreement and their legal effect have been fully explained
to the parties by their respective counsel. WIFE is represented by Debra Denison Cantor,
Esquire. HUSBAND is unrepresented.
The parties further declare that each is executing the agreement freely and
voluntarily having either obtained sufficient knowledge and disclosure of their respective legal
rights and obligations. The parties each acknowledge that this Agreement is fair and
equitable and is not the result of any fraud, coercion, duress, undue influence or collusion.
2. DIVORCE ACTION.
The parties acknowledge that their marriage is irretrievably broken and that
they shall secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code.
The parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of
Intention to Request Entry of a Divorce Decree upon the expiration of the ninety (90) day
waiting period.
This Agreement shall remain in full force and effect after such time as a final
decree in divorce may be entered with respect to the parties. The parties agree that the terms
of this Agreement shall be incorporated into any Divorce Decree which may be entered with
respect to them and specifically referenced in the Divorce Decree. This Agreement shall not
merge with the divorce decree, but shall continue to have independent contractual
significance.
3. DATE OF EXECUTION.
The "date of execution" and "execution date" of this Agreement shall be defined
as the date upon which it is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement
shall be defined as the date of execution by the party last executing this Agreement.
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4. mum L RELEASES.
Each party absolutely and unconditionally release the other and the estate of
the other from any and all rights and obligations which either may have for past, present, or
future obligations, arising out of the marital relationship or otherwise, including all rights and
benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described
herein.
Each party absolutely and unconditionally releases the other and his or her
heirs, executors, and estate from any claims arising by virtue of the marital relationship of the
parties. The above release shall be effective whether such claims arise by way of widow's or
widower's rights, family exemption, or under the intestate laws, or the right to take against
the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or
all other rights of a surviving spouse to participate in a deceased spouse's estate, whether
arising under the laws of Pennsylvania, any state, Commonwealth, or territory of the United
States, or any other country.
Except for any cause of action for divorce which either party may have or claim
to have, each party gives to the other by the execution,of this Agreement an absolute and
unconditional release form all claims whatsoever, in law or in equity which either party now
has against the other.
5. FINANCIAL AND PROCEDURAL DISCLOSURE.
Each party understands that he/she had the right to obtain from the other party
a complete inventory or list of all property that either or both parties owned at the time of
separation or currently and that each party had the right to have all such property valued by
means of appraisals or otherwise. Both parties understand that they have right to have a
court hold hearings and make decisions on the matters covered by this Agreement. Both
parties hereby acknowledge that this Agreement is fair and equitable, and that the terms
adequately provide for his or her interests, and that this agreement is not a result of fraud,
duress or undue influence exercised by either party upon the other or by any person or persons
upon either party.
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0. SEPARATION - INTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and
apart. They shall be free from any interference, direct or indirect, by the other in all respects
as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or
her may seem advisable. WIPE and HUSBAND shall not harass, disturb, or malign each
other or the respective families of each other.
7. REAL PROPERTY.
The parties are joint owners of areal property located at 1950 Wentz Lane,
Enola, Pennsylvania, 17025, which includes the marital home and adjacent apartment. The
home is encumbered by a mortgage with The Money Store. HUSBAND shall refinance the
property no later that 180 days from the date of the execution of this Agreement. Upon
receipt of a lump sum payment in the amount of Twenty-Five Thousand (S25,000) Dollars,
WIFE shall execute a deed transferring her interest in the home to HUSMAND.
In the event HUSBAND fails to refinance said property and pay WIFE Twenty-
Five Thousand ($25,000) Dollars within 180 days of the execution of this Agreement, the house
shall be placed up for sale with a mutually agreeable realtor. HUSBAND and WIFE agree to
cooperate with the listing of the home. The proceeds, after deduction of all reasonable costs
and expenses, shall be distributed as follows:
a. WIFE shall receive the lirst'rwenty-Five Thousand ($25,000) Dollars of
said proceeds; and
b. HUSBAND shall retain the remaining proceeds.
Upon execution of this Agreement. HUSBAND agrees to be solely responsible
for the payment of all costs associated with the home including, but not limited to: the
mortgage, taxes, insurance and utilities. RUSBAND agrees to indenutify and hold WIFE
harmless from said debt. I-IUSBAND shall assume all tax consequences of the sale.
HUS13AND shall specifically be responsible for the 1998 and 1999 unpaid property taxes on
the property.
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Both parties waive any right, title and interest in real property purchased after
the date of execution of this Agreement.
3. DEBTS.
'fhe parties have no joint debt. Any and all joint credit cards shall be closed
within seven (7) days of the execution of this Agreement.
HUSBAND represents and warrants to WIPE that since the separation he has
not, and in the future he will not, contract or incur any debt or liability for which WIPE or her
estate might be responsible, and he shall indemnify and save WIPE harmless from any and
all claims or demands made against her by reason ofsuch debts or obligations incurred by him
since the date of said separation, except as otherwise set forth herein.
WIFE represents and warrants to HUSBAND that since the separation she has
not, and in the future she will not, contract or incur any debt or liability for which HUSBAND
cr his estate might be responsible, and he shall indemnify and save HUSBAND harmless from
any and all claims or demands made against him by reason of such debts or obligations
incurred by her since the date of said separation, except as otherwise set forth herein.
9. BANK ACCOUNTS.
The parties acknowledge that they have divided the marital bank accounts to
their satisfaction. The bank accounts held solely in individual names shall become the sole and
separate property the patty in whose name it is registered. Each party does hereby
specifically waive and release his/her right, title and interest in the other party's respective
accounts. All joint accounts shall be closed within seven (7) clays of the execution of this
Agreement.
10. PERSONAL PROPERTY.
The parties hereto nnrtually agree I.hat they have divided all furniture,
hOLIS01101d furnishings and personal property between them in a 11[11111101• agreeable to both
parties. The parties mutually agrc0 that each party shall from and after the slate of this
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February N, 2000
Agreement be the sole and separate owner of all tangible personal property in his or her
possession. Notwithstanding the above, WI IF shall specifically retain all items in Exhibit "A".
11. VEHICLES.
The parties are joint owners of two (2) vehicles; a 1993 Caravan and a 1986 Ford
Taurus. HUSBAND shall retain the 1993 Caravan and WIFE hereby iSaives any right, title
and interest in said vehicle. WIFE shall retain the Ford Taurus and HUSBAND hereby
waives any right, title and interest in said vehicle.
12. INHERITANCE
HUSBAND and \VIFE waive any right, title and interest to any gifts or
inheritance the other may have received during the parties' marriage and any increase in
value thereof. The parties acknowledge that their minor children are the owners/beneficiaries
of trust accounts which are non•ntarital property and to which neither party makes a claim
against.
13. LIFE INSURANCE
HUSBAND agrees to maintain a term life insurance policy on his life in the face
amount of One Hundred Thousand ($100,000) Dollars. WIFE shall be named as the
irrevocable beneficiary on said life insurance policy until July 1, 2009. Thereafter, HUSBAND
may terminate said policy at any tine. NVIFE shall be provided proof of the existence and full
premium payutentof this policy each year. HUSBAND is solely responsible for the premiums
on said policy. If \VIFE determines that H US BAND is not paying such premiums, she may pay
the premiums on his behalf. HUSBAND shall indemnify WIFE for any payments made on his
behalf.
I.I. ALI.1-10NY SUPPORT. AND ALIMONY PENDENTE Ism
The parties hereby CNpressly waive, release, discharge and give up any and all
rights or claims which either nuw now or hereafter have for spousal support, alimony
pendente lite, alimony, or maintenance. The parties further release any rights that they may
have to seek nlotlification of the terms of this Agreement in a court of law or equity, with the
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understanding that this Agreement constitutes a final determination for all time of either
party's obligations to contribute to the support or maintenance of the other.
15. TAX PROVISIONS.
The parties agree to file joint tax returns in 1999. The parties have previously
filed joint federal and state tax returns. Both parties agree that in the event any deficiency in
any federal, state or local income tax is proposed or any assessment of any such tax is made
against either of them, each will indemnify and hold the other harmless against loss or
liability for any such tax deficiency or assessment and any interest, penalty, and expense
incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely
and entirely by the individual who is determined to be the cause of the misrepresentation or
failure to disclose in the aforesaid returns.
All transfers contained are intended to be tax free transfers pursuant to Internal
Revenue Code.
16. BANKRUPTCY OR REORGANIZATION PROCEEDINGS.
In the event that either party becomes a debtor in any bankruptcy or financial
reorganization proceedings of any kind while any obligations remain to be performed by that
party for the benefit of the other pursuant to the provisions of this Agreement, the debtor
spouse hereby waives, releases and relinquishes any right to claim any exemption (whether
granted under State or Federal law) to any property remaining in the debtor as a defense to
any claim made pursuant hereto by the creditor-spouse as set forth herein, including all
attorney fees and costs incurred in the enforcement of this paragraph or any other provision
i
of this Agreement. No obligation created by this Agreement shall be discharged or
dischargeable, regardless of Federal or State law to the contrary, and each party waives any
r,
and all right to assert that obligation hereunder is discharged or dischargeable. '
The parties mutually agree that in the event of bankruptcy or financial
reorganization proceedings by either party in the future, any monies to be paid to the other
party, or to a third party, pursuant to the terms of this Agreement shall constitute support
and maintenance and shall not be discharged in bankruptcy.
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17. Arf,I'ORNEY FEES. COURT COSTS.
Each party hereby agrees to be solely responsible for his or her own counsel Ices,
costs and expenses. Neither shall seek any contribution thereto front die other except its
otherwise expressly provided herein.
18. ATTORNEYS' PEES FOR ENFORCEMENT.
In the event that either party branches any provision of this Agrcanont and the
other party retains counsel to assist in enforcing the terms thereof, the breaching piAy will
pay all reasonable attorneys' fees, court costs and expenses (including interest and travel
costs, Applicable) which are incurred by theothor party in enforcing the Agreement, whether
enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific
agreement and intent of the parties that a breaching or wrongdoing party shall bear the
obligation of any and all costs, expenses and reasonable counsel fees incurred by the
nonbreaching party in protecting and enforcing his or her rights under this Agreement.
19. WAIVER OF RIGHTS.
Both parties hereby waive the following procedural rights:
(a j The right to obtain an inventory and the it ppraisenentofall nuu•itaI and
non-marital property;
(b.) The right to obtain an hwomu and expense statement, of either party;
(o.) The right to have all property identified and 11111) I'll ised;
(dj The right to discovery as provided by the Pennsylvania Rules of Civil
Procedure; and
(a) The right to have the court, make all determinations regarding marital
;in([ non-marital properly, equitable distribution, spousal support,
aliniony pendente file, alimony, counsel fees and costs and expenses.
20. MUTUAL COOPERATION.
\1'll land IIUSBANDsholl mutuallycooper;uewith enchotherinordertoca•ry
through the terms ofthia Agmvnw"v includinp but not limited to, the signing oi'tloctiments.
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21. VOID CLAUSES.
Ifany term, condition, clause or provision of this Agreement shall be determined
or declared to be void or invalid in law or otherwise, then only that term; condition, clause or
provision shall be stricken from this Agreement, and in all other respects this Agreement shall
be valid and continue in full force, effect and operation.
22. APPLICABLE LANV.
This Agreement shall be construed Linder the laws of the Commonwealth of
Pennsylvania.
23. ENTIRE AGREEMENT.
'this Agreement contains the entire understanding of the parties, and there are
no representations, warranties, covenants or undertakings other than those expressly set forth
herein.
24. CONTRACT INTERPRETATION.
For purposes of contract interpretation and for the purpose in resolving any
ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties.
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IN WITNESSWHCREOF, the parties hereto have set I.heir hands anti seals of the day
first above written.
This Agreement is executed in duplicate, :1 lid in counterparts. WIf G and HUSBAND
aclcr;owledge the receipt of a duly executed copy "ereof.
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COMMONWEALTH Or PENNSYLVANIA
: SS.
COUNTY OF CUMBERLAND
On the ? clay of y -4--z .? 19000, before mc, a Notary Public
in and for the Commonwealth of Pennsylvania, the undesigned officer, personally appeared
PATRICIAA. `VENTZ, known to me (or satisfactory proven) to be on of the parties executing
the foregoing instrument, and she acknowledges the foregoing instrument to be her free act
and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
Notary Public
My Commi ion Ex
ftarnp': !
t.:y onenxr. - ..
COMMONWEALTH OF PENNSYLVANIA
COUNTY Or
: SS.
On the J 14C- davof C)e\ 9000, before me, a Notary Public
in and for the Commonwealth of Pennsylvania, the undesigned officer, personally appeared
LARRY J. WENTZ, known to me (or satisfactory proven) to be on of the parties executing the
foregoing instrument, and he acknowledges the foregoing instrument to be his free act and
deed.
IN WITNESS WHEREOP, I have hereunto set my hand and notarial seal the clay and
year first above written.
No i ISe a, Public
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PATRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
V. Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7579
LARRY J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
Code. 1. Ground for Divorce: Irretrievable breakdown tinder §3301(c) of the Divorce
.
2. Date and manner of service of the Complaint: served by certified mail return
recei it re uested on December 24. 1999.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required by §3301(c) of the
Divorce Code: by Plaintiff April 9.2000; by Defendant April 12.2000.
(b)(1) Date of execution of the Affidavit required by §3301(d) of the Divorce
Code: N/A; (2) date of filing and service of the Plaintiffs Affidavit upon the Respondent: N/A.
4. Related claims pending: All matters have been resolved pursuant to a Marital
Settlement Agreement dated A ril 3.2000 and FvP ,,?oa .. ., _ __ .•
endin .
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: N/A
(b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was executed: April
9.2000; and filed with the Prothonotary: April 26, 2000.
Date Defendant's Waiver of Notice in §3301(c) Divorce was executed:
April 12.2000; and filed with the Prothonotary: Anri100
Date: May 24, 2000
De ra De ison Cantor, squire (counsel for Plaintiff)
Attorney I.D. No. 66378
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REAGER & ADL.ER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No.66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
PATRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLANDCOUNTY, PENNSYLVANIA
V.
LARRY J. WENTZ,
Defendant
NO. 9-7- 7S 9 9 Cu- a CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the 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 lost money or property or other
rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary, Room 101, Cumberland County
Courthouse, One Courthouse Square, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE, THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
F -___:
PATRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLANDCOUNTY, PENNSYLVANIA
V. NO.
LARRY J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
AVISO PARA DEFENDER Y RE CLAIMAR DERECHOS
USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las
quejas expuestas en ]as pgginas siguientes, debar tomar acei6n con prontitud. Se la
avisa que is no Se defienae, el caso t)urde proceder sin Listed y decreto de divorcio o
anulamiento puede ser emiiado en su contra per la Cort6. Una'dccisi6n pucdc tambidn
ser emitida en su contra per caulquier otra queja o compens„iction reclimados por el
demandante. Usted puede perder dincro, o sus propicdades o otros derechos
importantes para usted.
Cuando la base pars, el divorcio es indignadades o rompimiento irreparable del
matrimonio, usted uesde so'icitar consejo matrimonial. Una lista de consellieros
mattimonial is estg disponible en la oficina el Prothonota en'la, Room 101, Cumberland
County Courthouse, One Courthouse Square, Carlisle, PA 17013.
SI USTED NO RECLAMA PENSION ALIMIC4 NTACIA, PROPIE4 DAD
MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE
QUE4 EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA
EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR
CUALQUIERA DE ELLOS.
USTED DEBE I,I,EVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI
NO TIENE 0 NO IIUEDO PAGAR UN ABOGADO, VAYA 0 LLAME A LA
OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE
OBTENER ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No.66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
PATRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLANDCOUNTY, PENNSYLVANIA
V. NO. 9 9. 75 2 9 e ,?,( T.a-.
LARRY J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
UNDER $ 3301(C) OR (D) OF THE DIVORCE CODE
1. Plaintiff is Patricia Wentz, an adult individual who currently resides at 1950 Wentz
Lane, Enola, Cumberland County, Pennsylvania, 17025.
2. Defendant is Larry J. Wentz, an adult individual who currently resides at 1950
Wentz Lane, Enola, Cumberland County, Pennsylvania, 17025.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 17, 1985 in Long Island, New
York.
5. Plaintiff avers that the parties separated on or about April, 1998.
6. There have been no prior actions of divorce or for annulment between the parties.
3
7. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers & Sailors Civil Relief Act of
the Congress of 1940 and its amendments.
8. Plaintiff avers that there are three (3) children of this marriage, namely Bryan J.
Wentz, date of birth August 25, 1986; Timothy M. Wentz, date of birth, September
18, 1987; and Matthew S. Wentz, date of birth, April 3, 1991.
9. The marriage is irretrievably broken.
10. Plaintiff has been advised that counseling is available and that Defendant may have
the right to request that the court require the parties to participate in counseling.
Plaintiff declines counseling.
11. After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an affidavit.
12. In the alternative, Plaintiff will file an Affidavit of Consent and provide the
appropriate notices two (2) years from the date of separation.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce
pursuant to Section 3301(c) or (d) of the Divorce Code.
COUNTI
EQUITABLE DISTRIBUTION
13. Paragraphs one (1) through twelve (12) of this Complaint are incorporated herein by
reference.
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14. Plaintiff and Defendant have acquired property, both real and personal, during their
marriage.
15. The parties have acquired marital debt during the course of the marriage.
16. In the event the parties are unable to amicably resolve the property issues in this
matter, Plaintiff requests this Court equitably divide all marital property.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all
marital property and debt.
Respectfully Submitted,
REAGER & ADLER, PC
Date: December 16, 1999 B
A PLKDWO-N CANTOR, ESQUIRE
Attorne o. 66378
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. [717] 763-1383
Attorneys for Plaintiff
5
VERIFICATION
I, PATRICIA WENTZ, verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
PATRICIA WENTZ
Data: W / O (-l
PATRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 - 7579
J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. AComplaintindivorce undersection3301(c)oftlieDivorceCodewasfiledonDecember
1999.
2. The marriage ofPlaintiff and Defendant is irretrievably broken and ninety (90) days have
from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to
entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that false
nts herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
authorities.
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PATRICIA WE Z
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TRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 - 7579
J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
I. AComplaint indivorce undersection 3301(c) ofthe Divorce Codewas filedon December
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
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
entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that false
:nts herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
authorities.
LARRY J. W
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PATRICIA WENTZ,
Plaintiff,
V.
LARRY J. WENTZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7579
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE. OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(C) OF THE. DIVORCE, CODE
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 ofproperty, lawyer's fees
or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
Dated: 41 g100
ATRICIA WENTZ 0
-0
_ _;
PATRICIA WENTZ,
Plaintiff,
V.
LARRY J. WENTZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7579
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301 (C) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division ofproperty, 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 Courtand
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
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LARRY J.J NTZ
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REAGER, ADLER & COGNETTI, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
PATRICIA WENTZ,
Plaintiff,
V.
LARRY J. WENTZ,
Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYLVANIA
NO. 99-7579
CIVIL ACTION - LAW
IN DIVORCE
Before me, the undersigned Notary Public, this day, personally appeared Debra Denison Cantor,
Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the
following:
I, Debra Denison Cantor, Esquire, being duly swom according to law, depose and state that
service of the Complaint in Divorce in the above-captioned matter was served by Certified
Mail, Return Receipt Requested, on Defendant, Larry J. Wentz, 1950 Wentz Lane, Enola,
Pennsylvania, 17025 on December 24, 1999. The Certified Receipt is attached hereto as
"Exhibit A."
REAGER & ADLER, P.C.
CANTOR, ESQUIRE
Subscribed and sworn to before me
this 15-th dayof Tnnt QCL 1999.
(Lt a• I/%C/lCi 1Gt
Notary Public
NOlaa2? SCaI
Lan A. Richartl, Public
Crimp ?!a 3oro. baaantl Caaruy
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71AG-r.- R -E:
DEBRA 8£NISON-CANTOR, ESQUTRF
REAGER B ADLER, PC
2331 MARKET STREET
CAMP HILL, PA 17011-4642
7. Dale of Delivery
4a. Article Number
P 902 067 506 'i
2. RESTRICTED 4b. Service Type
DELIVERY CERTIFIED
aluLV (OAddrossee or OAganl)
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P 902 067 506
S. Addressee's Addresapmr....av...o..ne...l
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9.rnq.ry AEdrm
I.ADi-l, Addressed lo:
LAK12Y J. WENTZ
1950 WENTZ LANE
ENOLA, PA 17025
................... ......... .............. _...................
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.....................P..............
abb II aoe.
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa. C.S.A. SECTION 4304.1(a)(3) ALL DIVORCES MUST
INCLUDE THE PARTIES' SOCIAL SECURITY NUMBER.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE.
DATE: 4/24/00
DOCKET NUMBER: 99-7579
PLAINTIFF/PETITIONER SS# 100-46-1288
NAME: Patricia A. Wentz
DEFENDANT/RESPONDENT SS # 186-38-3318
NAME: Larry I Wentz
Q )
'AUG 2 8 2001 "
r
PATRICIA WENTZ,
Plaintiff,
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 99 - 7579
LARRY J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
RULE TO SHOW CAUSE
AND NOW, this day of 2001, upon review of Plaintiff's -LQjjmAk Petition to Enforce Marital Settlement Agreement, a Rule to Show Cause is issued as to why
the relief requested should not be granted.
Rule returnable d-o days from date of service.
BY THE COURT:
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Itlr tifiiJnYYr°i^fr;f,Ow-,S:into&imitifi
and the tul of said S• ' 21 Gaelisi&, Pa.
rhl&-gaf -,day-of -,-&ai
Prothtinafary
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PATRICIA WENTZ,
Plaintiff,
V.
LARRY J. WENTZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 99 - 7579
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this day of 2001, upon review of the Plaintiff's
Petition for Enforcement of Marital Settlement Agreement and Defendant's response, if any,
thereto, the court hereby ORDERS as follows:
1. The real estate located at 1950 Wentz Lane, Enola, Pennsylvania shall be
immediately placed for sale.
2. Husband and Wife shall cooperate with the listing of the home and its ultimate
sale, including cooperation with showings and reduction in sales price if
recommended by realtor.
3. Pending the sale of the home, Defendant shall be solely responsible for all costs
and expenses associated with the home, including but not limited to mortgage,
taxes, insurance and utilities. Defendant's failure to pay any of the above
amounts will result in his removal from the home.
4. Upon the sale of the home, Wife shall be entitled to the first $25,000.00 in
proceeds. Defendant shall be solely responsible for all outstanding mortgages,
taxes, insurance and utilities at the time of sale. Failure to comply with this
Order will result in the finding of contempt.
5. Plaintiff is awarded counsel fees and costs in the amount of $500.00.
BY THE COURT:
J.
C002 EMU V ti39VHH 99C4 OCL LTL Svd tO:ZT TOOMT/TT
If-
PATRICIA WENTZ, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND CO., PENNSYLVANIA
n
NO. 99 - 7579 C- T
Lei r-' n , .
LARRY J. WENTZ, CIVIL ACTION -LAW cry;,: ti
Defendant IN DIVORCE c`c:
SO r Jni
PETITION TO ENFORCE MARITAL SETTLEMENT AGREE*N;) 28
AND NOW, comes Plaintiff, Patricia Wentz, by and through her counsel, Reager &
Adler, PC, and seeks enforcement of the Marital Settlement Agreement as follows:
1. Plaintiff is Patricia A. Wentz, an adult individual residing at 2205 Gleim Court,
Enola, Pennsylvania 17025.
2. Defendant is Larry J. Wentz, an adult individual residing at 1950 Wentz Lane, Enola,
Pennsylvania 17025.
3. The parties were husband and wife, having been married on August 17,1985.
4. The parties separated on or about April, 1997 and executed an Marital Settlement
Agreement dated April 3, 2000. Said Marital Settlement Agreement is attached hereto as
Exhibit "A".
5. A Final Decree in Divorce was entered on June 15, 2000 and the terms of the parties'
Marital Settlement Agreement were incorporated but not merged therein.
6. Pursuant to the terms of the Marital Settlement Agreement, Husband remained in
the marital home. Husband was to refinance the property no later than 180 days from the date
of execution of the Agreement or no later than October 3, 2000.
too(pJ ?I3'Iav Is N39Y3ti 99CL OCL LTL XV.4 to:ZT TOOZ/CT/TT
V
7. Upon refinance, Wife was to receive a lump stun payment in the amount of $25,000.00
in exchange for her waiver to her right, title and interest in the property.
8. Pursuant to the terms of the Agreement, if Husband failed to refinance the property
and pay Wife $25,000.00, the home was to be placed up for sale by a mutually agreeable realtor.
9. The terms of the Agreement specifically require Husband and Wife to cooperate with
the listing and sale of the home.
10. To date, Husband has failed to refinance the property. In addition, Husband has
failed to agree to list the home for sale with a mutually agreeable realtor.
11. Furthermore, pursuant to the terms of the Agreement, Husband was to be solely
responsible for the payment of all costs associated with the home, including but not limited to
the mortgage, taxes, insurance and utilities. Specifically, Husband was to asstune all
responsibility for unpaid taxes for 1998 and 1999.
12. Wife was notified that the parties' home was placed up for Sheriff's sale due to
unpaid taxes. To date, $1,744.90 of 2000 property taxes remain unpaid. In addition, no
payments have been paid on the 2001 taxes.
13. Pursuant to the terms of the Marital Settlement Agreement, Wife is entitled to
receipt of all reasonable attorney's fees, court costs and expenses which are incurred in
enforcing the Agreement. To date, Wife has incurred $500.00 in fees and expenses in the
preparation of this Petition. Wife reserves the right to submit a final invoice for costs and
expenses upon the completion of this matter.
WHEREFORE, Plaintiff requests this Honorable Court to enter an Order enforcing the
terms of the Marital Settlement Agreement and awarding Plaintiff attorney's fees and costs in
the amount of $500.00.
S00(n
N371V 18 N39v3H 99CL OCL LTL TV3 SO:ZT TOOZ/CT/TT
Respectfully submitted,
REAGER & ADLER, PC
Date: _424U'
, Esquire
T #6 8
2331 Market Street
Camp Hill, PA 17011
717-763-1353
Attorneys for Plaintiff
900 In
unav v u!)YaH 99CL OCL LTL IVA 90:ZT TOWCT/TT''.:"
,
CERTIFICATE OF SERVICE
I, Debra Denison Cantor, Esquire, do hereby certify that on this date I served the
foregoing Petition to Enforce Marital Settlement Agreement by depositing a true and exact
copy thereof in the United States mail, first class, postage prepaid, addressed as follows:
Larry J. Wentz
1950 Wentz Lane
Enola, PA 17025
Date.-
Loop
EMU V aama 99CL OU LTL TV3 90:ZT TOOZ/CT/TT
REAGER & ADLER, PC
NOV 0 8 2001f?
PATRICIA WENTZ, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND CO., PENNSYLVANIA
V. NO. 99 - 7579
LARRY J. WENTZ, CIVIL ACTION - LAW
Defendant IN DIVORCE
ORDER
AND NOW, this ,,,?Aday of o ? /" Lel 2001, upon review of Plaintiff's
Petition of Enforcement of the Marital Settlement Agreement, and the Motion to Make Rule
Absolute, the Court hereby ORDERS as follows:
1. The real estate located at 1950 Wentz Lane, Enola, Pennsylvania shall be
immediately placed for sale.
2. Husband and wife shall cooperate with the listing of the home and its ultimate
sale, including cooperation with showings and reduction in sales price if recommended by a
realtor.
3. Defendant shall be solely responsible for all costs and expenses associated
the home including, but not limited to, the payment of their mortgage,
utilities. Defendant's failure to pay any of the above amounts will result
removal from the home. /U
4 Upon the sale of the home, wife shall be entitled to the first 525,00 0 inceeds.
A,
Defendantshall be responsible foroutstanding mortgages, taxes, insurance and utilities at the
time of the sale.
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5. Defendant is ordered to pay Plaintiff the amount of $750.00 for counsel fees and
costs.
6. Failure to comply with the terms of this Order will result in the finding of a
contempt.
69 6
C ,\\
BY THE COURT:
PATRICIA WENTZ,
Plaintiff,
V.
LARRY J. WENTZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 99 - 7579
CIVIL ACTION- LAW
IN DIVORCE
MOTION TO MAKE RULE ABSOLUTE
AND NOW, comes Plaintiff, Patricia Wentz, by and through her counsel, Reager &
Adler, PC, and moves this Court to make the Rule dated August 30, 2001 absolute:
1. Plaintiff is Patricia A. Wentz, an adult individual residing at 2205 Gleim Court,
Enola, Pennsylvania 17025.
2. Defendant is Larry J. Wentz, an adult individual residing at 1950 Wentz Lane,
Enola, Pennsylvania 17025.
3. On August 27, 2001, Plaintiff filed a Petition to Enforce the Terms of the Marital
Settlement Agreement dated April 3, 2000.
4. Pursuant to the terms of the Marital Settlement Agreement, husband was to
refinance the property within 180 days of the execution of the Agreement.
5. In the event that the home was not refinanced, the house was to be placed up
immediately for sale.
6. To date, husband has failed to do so.
7. A Rule to Show Cause was issued by this Court on August 30, 2001. The Rule
was returnable in 20 days.
a
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8. By correspondence dated September 5, 2001, Defendant was served with the
Rule to Show Cause and was advised to respond (see correspondence attached hereto as
Exhibit A).
9. To date, Defendant has failed to reply to the Petition.
10. Pursuant to the terms of the Marital Settlement Agreement, Defendant should
also be responsible for outstanding payment of expenses and costs incurred by Plaintiff in
seeking to make this rule absolute.
11. Plaintiff has incurred an additional fee of $250.00.
WHEREFORE, Plaintiff requests this Honorable Court to enter an Order making the
rule absolute, order the sale of the real estate located at 1950 Wentz Lane, Enola, Pennsylvania,
order husband and wife to cooperate with the listing and sale of the property. Defendant to
be solely responsible for all costs and expenses associated with the home, including the
mortgage, taxes, insurance and utilities and upon the sale of the home, paying to wife the first
$25,000.00, and awarding counsel fees and costs to Plaintiff in the amount of $750.00.
Respectfully submitted,
REAGER & ADLER, PC
Date: By..-
ebr eniso Canto ,Esquire
ID #66378
2331 Market Street
Camp Hill, PA 17011
717-763-1383
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I, Debra Denison Cantor, Esquire, do hereby certify that on this date I served the
foregoing Motion to Make Rule Absolute by depositing a true and exact copy thereof in the
United States mail, first class, postage prepaid, addressed as follows:
Larry J. Wentz
1950 Wentz Lane
Enola, PA 17025
REAGER & ADLER, PC
Date: S U ?
D b D? ' on ntor, Esquire
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PATRICIA WENTZ,
Plaintiff
Vs.
LARRY J. WENTZ,
Defendant
AND THIS ? ` day of
as Exhibit "A" is an Order of Court.
REAGER & ADLER, PC.
ATTORNEYS AT LAW
2331 MARKET STREET
CAMP HILL, PA 17011.4642
(71'1) 763-13,33
,JUL 11 "04-
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99-7579
CIVIL ACTION-IN CUSTODY
ORDER
3') l I , 2002 the parties Stipulation attached hereto
9Y
PATRICIA WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99-7579
LARRY J. WENTZ, : CIVIL ACTION-IN CUSTODY
Defendant
STIPULATION
AND NOW this /o day of L? 2002, the parties are separated and
divorced and files the following Stipulation regarding custody, after due consideration of the best
interest of their children: namely, Bryan J. Wentz, Timothy M. Wentz and Matthew Wentz,
hereinafter; and,
WHEREAS, the parties wish to enter into an agreement relative to custody of the
children; and
WHEREAS, both parties have been provided an opportunity to review the Agreement
with the counsel of their choice prior to signing; and
THEREFORE, in consideration of the mutual covenants, promises, and agreements as
hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows:
1. Lgg I Custody-
The parties agree to shared legal custody of the minor children. The
parties agree that major decisions concerning the children, including, but not necessarily limited
to, the children's health, welfare, education, religious training and upbringing shall be made by
them jointly, after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the children's best interest. Each party agrees not to impair the
other party's rights to shared legal custody of the children. Each party agrees not to attempt to
alienate the affections of the children from the other party. Each party shall notify the other of
any activity or circumstance concerning their children that could reasonably be expected to be of
concern to the other. Day to day decisions shall be the responsibility of the parent then having
physical custody. With regard to any emergency decisions which must be made, the parent
having physical custody of the children at the time of the emergency shall be permitted to make
any immediate decisions necessitated thereby. However, that parent shall inform the other of the
emergency and consult with him or her as soon as possible. Each party shall be entitled to
complete and full information from any doctor, dentist, teacher, professional or authority and to
have copies of any report given to either party as a parent.
2. Physical Custody:
The mother shall maintain primary physical custody of the minor children. Father
shall have partial custody as follows:
a. Every other weekend from Friday evening through Sunday evening.
Father specifically agrees to take the kids to church and Sunday school on his weekends.
b. One (1) evening per week which shall be a fixed day to be determined
by father.
c. Four (4) non-consecutive weeks of custodial time in the summer.
3.Holidays:
Fl
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The parties shall alternate or share the holidays by agreement.
ire that this stipulation as an Order of Court.
Patricia Wentz
O 2-
Larry,f W ntz
.!t !Iltia
_
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REAGER & ADLER. P.C.
ATTORNEYS AT LAW
2331 MARKET STREET
CAMP HILL, PA 17011.4842
17171783-1383'
JUL .t 7 ZOOZ 1'
PATRICIA A. WENTZ, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-7579
LARRY J. WENTZ, : CIVIL-ACTION - LAW
Defendant : IN CUSTODY
ORDER OF COURT
AND NOk upon consideration of the attached Complaint, it is hereby
that the parties and thl''r respective counsel appear before
Esquire, Conciliator, at
1996, at
.m., for
an effort will be made to resolve th t
to define and narrow the issues to be Order. Either party may bring the child
conference, but the children's attendan
conference may provide grounds f the
DATED:
a, on the y of
ng Custody C ference. At such conference,
in dispu , or, if this cannot be accomplished,
by JWe Court, and to enter into a temporary
the subject of this custody action to the
is
entry
FOR
BY:
Custody Conc
Failure to appear at the
or permanent Order.
YOU SHOULD'it/AKE THIS PAPER TO YOUR LAWYERN?T ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD O , GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
PATRICIA A. WENTZ : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.
LARRY J. WENTZ, : CIVIL ACTION - LAW
Defendant . IN CUSTODY
COMPI HINT FOR C(TST DY
1. Plaintiff is Patricia A. Wentz, residing at 2205 Gleim Court, Enola,
Cumberland County, Pennsylvania.
2. Defendant is Larry J. Wentz, residing at 1950 Wentz Lane, Enola,
Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following children:
N rn Present Address
Bryan J. Wentz
Timothy Wentz
Matthew Wentz
2205 Gleim Court
Enola, PA
2205 Gleim Court
Enola, PA
2205 Gleim Court
Enola, PA
4. The children were not born out of wedlock. The children are Presently in the
custody of mother, Patricia A. Wentz who resides at 2205 Gleim Court, Enola,
Cumberland County, Pennsylvania. She is single. '
i
5. The relationship of Defendant to the children is that of father. Defendant
currently resides with the following persons:
Name
Relationship
Unknown.
6. Plaintiff has not participated as a party or a witness, or in any other
capacity in other litigation concerning the custody of the children in this or any other
Court.
7. Plaintiff has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth.
8. Plaintiff does not know of a person not a party to the proceedings who
has physical custody of the children or claims to have custody or visitation rights with
respect to the children.
9. The best interest and permanent welfare of the children will be served by
granting the relief requested to mother having shared legal custody of the minor children..
10. Each parent whose parental rights to the children have not been
terminated and the person who has physical custody of the children have been named as
parties to this action.
11. The parties have entered into a Stipulation and entered into an Order. The
Stipulation is marked Exhibit "A"
WHEREFORE, Plaintiff requests the Court to grant Mother primary physical custody
of the minor children and Father partial custody of the minor children.
Respectfully Submitted,
Dated: July 12, 2002 1
LDatra Dens n Cantor, Esquire
Attorney for Plaintiff
Sup. Ct. I.D. #36461
2331 Market Street
Camp Hill, PA 17011
(717) 763-1383
VERIFICATION
I, Patricia A. Wentz, verify that the statements made in the foregoing document 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.
Section 4904, relating to unswom falsification to authorities.
Date: l (7C?CAn' t tc
Patricia A. Wentz
C ERTH,ICAn OF SERVICE.
I hereby certify that on the date set forth below a true and correct copy of the foregoing
Custody Complaint and Stipulation was served on the following individual via United States
First Class Mail, postage prepaid as follows:
Larry J. Wentz
1950 Wentz Lane
Enola, Pennsylvania 17025
Dated: 7/1 Z/0 2,-
e e tson C tor, Esquire
2331 Market Street
Camp Hill, PA 17011
(717)730-7366
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