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HomeMy WebLinkAbout03-4199Michael E. Frengel, 199-50-3838 PLAiNTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (iN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO: (~)'~ c{[~ ( ( ( NOTICE TO DEFEND AND CLAIM RIGHTS 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 THE DIVORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT S. HANOVER STREET, CARLISLE, PENNSYLVANIA, 17013. THE TELEPHONE NUMBER IS (717) 240-6200. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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. LAWYERS REFERRAL SERVICE S. Hanover St., 4th Floor Carlisle, PA 17013 Michael E. Frengel~Pr0~e 7 Independence Drive Shippensburg, PA 17257 ( ) Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Dr/ye Shippensburg, PA 17257 Toni M. Frengel 17%42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIVISION NO: 0'3' qlqfl AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) ) SS.' COUNTY OF CUMBERLAND ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, personally appeared Michael E. Frengel, who being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his knowledge, info.rmation, and belief, and that he is authorized to make this Affidavit.Michael ~f~, P~o~? ~~beforemethis~ Dayof('~q~d~ ,~. NOTARIAL SEAL TAMMY SUE HELMAN, Notary Public Obambersburg, Franklin County My Commission Expires Oct. 31, 2005 Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO: OqJ- q/9~ ( ( ( COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, Michael E. Frengel, by FILING PRO SE, who files this Complaint in Divorce a statement of which is as follows: 1. The Plaintiff is Michael E. Frengel, an adult individual currently residing at 7 Independence Drive, Shippensburg, County of Cumberland, Pennsylvania, 17257. 2. The Defendant is Toni M. Frengel, an adult individual currently residing at 204 Meals Drive, Carlisle, County of Cumberland, Pennsylvania, 17013. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of approximately forty-seven (47) years. 4. The Plaintiff and Defendant were married on November 27, 2000 in Hagerstown, Maryland. 5. No children were bom or adopted of this marriage, and Respondent is not now pregnant. 6. Neither party is a member of any branch of the military. 7. The marriage is irretrievably broken. The Plaintiff, Michael E. Frengel respectfully requests this Honorable Court to grant this divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code. Respectfully submitted: Michael E. Freng~, Pr~*Se' 7 Independence Drive Shippensburg, PA 17257 ( ) I verify that the statements made in the Complaint are tree and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to aul~horities. Date: ~1]-0~ ~Micha~l,~e~ Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( ( NO: ( ( ( AFFIDAVIT OF SERVICE PLAINTIFF, Michael E. Frengel, of the Commonwealth of Pennsylvania, hereby affirms the following statement under penalty of perjury: 1. I am the plaintiff in this action, I hereby certify that on caused a copy of the attached: Complaint in Divorce, Notice to Defend and Claim Rights, and Non-Military Affidavit to be served upon Defendant Toni M. Frengel 204 Meals Drive Carlisle, PA 17013 by depositing a true copy of the same enclosed in a post-paid addressed envelope, by certified mail, in a depository under the exclusive care and custody of the U.S. Postal Service within the Commonwealth of Pennsylvania. 2. I certify that the signature on the attached certified mail green receipt card, received back fi.om the United States Postal Service, is known to be the Defendant's, Toni M. Frengel. Date: · . g , ~ai~f~ >ro Se CUMBERLAND COUNTY COURT OF COMMON PLEAS INTAKE THIS FORM MUST BE FILLED OUT IF YOU ARE FILING A DIVORCE OR CUSTODY ACTION IN THE PROTHONOTARY'S OFFICE: TODAY'S DATE: CASE NUMBER: PLEASE CHECK ONE: [] DIVORCE FILING - NO CHILDREN: ~ DIVORCE FILING - W/CHILDREN UNDER 18: r~ CUSTODY FILING - W/CHILDREN UNDER 18: PLAINTIFF/PETITIONER NAME AND ADDRESS: Michael E. Frengel 7 Independence Drive Shippensburg, PA 17257 DEFENDANT/RESPONDENT NAME AND ADDRESS: Toni M. Frengel 204 Meals Drive Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL COVER SHEET Docket No. I. Plaintiff: Michael E. Frengel, Pro Se 7 Independence Drive Shippensburg, PA 17257 ii. MANDATORY ARBITRATION Does this fall under the mandatory arbitration requirements per Local Rule 1301 ? No IV. CAUSE OF ACTION Defendant: Toni M. Frengel, Pro Se 204 Meals Drive Carlisle, PA 17013 IlL ALTERNATE DISPUTE RESOLUTION REQUESTED Sunmmary Jury Trial Other: See "Guide to Alternate Dispute Resolution Programs" Published by the Columbia County Bar Association. Divorce under Section 3301(c) of the Divorce Codlg V. GENERAL NATURE OF SUIT CONTRACT Insurance PA Bond Collection Suits Construction Other-List in IV above REAL PROPERTY Condemnation Foreclosure Landlord & Tenant Partition Mechanics' Lien Environment Other - List in IV above Address of Property (a) Is this an equity case? No VI. ORIGIN (Mark only 1) PERSONAL INJURY __ Motor Vehicle __ Product Liability __ Medical Malpractice __ Other Prof. Liability __ Intentional __ Premises __ Other-List in IV above pRISONER PETITIONS __ Habeas Corpus __ Mandamus __ Other - list in IV above LABOR DOMESTIC RELATIONS X Divorce __ Protection bom Abuse Custody/Visitation Other - List in IV above Support OTHER STATUTES Zoning Appeal School Board Appeal License Suspension Appeal Assessment Appeal Other- List in IV above TAX LIEN & TAX MATTERS OTHER List in IV above (b) Does it involve a governmental body?. No X__I Original __2 Removed from __3 Confessed __ 4 Transferred __ 5 Appeal __ 6 Appeal to __ 7 Foreign Complaint Federal Court Judgments From Another From Court from Judgment of Writ by Complaint District or Govt. District or Pmecipe VII. REOUESTED IN COMPLAINT (a) Is this a CLASS ACTION NO (c) Amount demanded in complaint VIH. RELATED CASE(S) IF ANY JUDGE County Agency Justice Judgement (b) Circle YES only if jury demanded in complaint: JURY DEMAND: [] YES or NO [] Will you accept 6 jurors? YES or NO DOCKET NUMBER Date: Case Caption SIGNATURE OF FILINC[/PA~Y OR ATTORNEY OF RECORD Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO: ( ( ( ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I, Toni M. Frengel, Defendant in the above-captioned matter, hereby acknowledge receipt of the Complaint in Divorce and Notice to Defend and Claim Rights in the matter of Michael E. Frengel v. Toni M. Frengel, Civil Division No: , and I hereby waive formalities of service and any objections to defects thereto. 204 Meals Drive Carlisle, PA 17013 ( ) I, Toni M. Frengel, certify that a copy of the foregoing Acceptance of Service has been fonvarded on this date by US Mail, postage prepaid, to the Plaintiff, Michael E. Date:Frengel, at his address of record. ~'~ {7~'~ "-'f'--[~& Toni M. Frengel, Defendant Michael E. Frengel, 199-50-3838 PLAiNTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (iN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO: ( ( ( NON-MILITARY AFFIDAVIT I, Michael E. Frengel, do hereby CL~(lfy that: 1. I am the Plaintiffin the above entitled civil action. 2. I am personally acquainted with Toni M. Frengel, Defendant herein, and I know that she resides at 204 Meals Drive, Carlisle, Pennsylvania, 17013. I have seen the Defendant on an average of (~ during the pendency of this action. 3. The Defendant is not in the Military Service of the United States. 4. I certify that the statements made by me in the foregoing Certification are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Date: Michael E. Frengel,'Pla'fhtiff, Pro Se I, Michael E. Frengel, certify that a copy of the foregoing Non-Military Affidavit has been forwarded on this date by US Mail, postage prepaid, to the Defendant, Toni M. Date:Frengel' at her address of record. }( ~ ~ ~ //~ ~.~ Michael E. Frengel Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( ( ( MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this __ day of ., 200~, between PLAINTIFF, Michael E. Frengel (Husband), residing at 7 Independence Drive, Shippensburg, PA 17257, and DEFENDANT, Toni M. Frengel (Wife), residing at 204 Meals Drive, Carlisle, PA 17013. WITNESSETH 1. The parties were married on November 27, 2000; 2. The parties filed for 3301(c) Divorce on: l~l,~OtX_q~_ 3. The parties hereto desire to settle their property rights; ,2003; 4. Both parties agree to relinquish any and ail claims which either may have against any property now owned or belonging to the other or which may hereinafter be acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, and agreements contained herein; and 5. Both parties have had an opportunity to seek the benefit of competent and independent legal and financial advice by separate counsel. THEREFORE, the parties, agree and stipulate at follows: 1. INCORPORATION OF RECITALS The recitals set forth above are incorporated herein as if set forth in full. 2. SEVERABILITY Each paragraph contained herein shall be determined to be a separate and independent agreement. In the event that any portion of this agreement is deemed to be illegal or unenforceable, said determination shall not affect the enforceability of any other paragraph. 3. APPLICABLE LAW Agreement shall be construed under the laws Pennsylvania. of the Commonweflth of 4. PROPERTY DIVISION A. Property to be awarded to Wife: Wife shall retain any and all property in her possession free and clear of any right, title or interest of Husband. This award shall include, without limitation, her personal clothing and effects, her furniture and furnishings, and such other property she may hold as of the date of this agreement. B. Property to be awarded to Husband: Husband shall retain any and all property in his possession free and clear of any right, title or interest of Wife. This award shall include, without limitation, his personal clothing and effects, his furniture and furnishings, and such other property he may hold as of the date of this agreement. 5. DISTRIBUTION OF DEBT. A. The Wife shall be responsible for any and all debt standing in her respective name, and shall hold the Husband harmless thereon. B. The Husband shall be responsible for any and all debt standing in his respective name, and shall hold the Wife harmless thereon. 6. REAL ESTATE There is no real property of the marriage. 7. ALIMONY, SPOUSAL SUPPORT, AND SEPARATE EXPENSES. Each party hereto waives any present claim to alimony, temporary alimony, and spousal support. 8. JOINT DEBTS Husband and Wife each ccTtify that there are no joint marital obligations or individual debt, other than those listed herein. 9. DIVORCE Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce under 23 Pa. C.A. Section 3301(c). 10. LEGAL ADVICE Husband and Wife declare that each has had the opportunity to obtain independent legal advice by counsel of his or her own selection and to obtain financial advice, and that any failure of either party to obtain independent legal or financial advice has been of his or her own choosing and not based on any representation or suggestion to the contrary, and that each has read the stipulation and believes it to be fair, just and equitable, and that each signs the stipulation freely and voluntarily. 1N WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. ~~f~_ ) Witness Plaintiff,'Michael ~.. Fl rd Se Witness Defendant, Toni M. Fri ,el, Pro Se ~] COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND ) On this ~_ day of ]~D~/ , 2007__, betbre me, a Notary Public, the undersigned officer, personally appeared Michael E. Frengel, known to me to be the person whose name is subscribed to the written instrument, and acknowledges that he executed the same for the purposes therein contained. set my han and official seal .~ IN WITNESS WHEREOF, I hereunto NOTARIAL SEAL~-~'-----~ DAWN M. SHUGHA[~T, Notary Public I Carlisle, Cumberland County COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND ) On this ~L day of/~/ _, 200~,__ before me, a Notary Public, the undersigned officer, personally appeared Toni M. Frengel, known to me to be the person whose name is subscribed to the written instrument, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my h~ and official se~l./ / I DA NOTARIAL'~EA~ ~ J WN M. SHUGHART, Notary Public I Notary Public J Carlisle, Cumberland County/ ~ Commission Explros N~Ov,, 28, 20061 Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, IN THE COURT OF COMMON PLEAS OF 'CUMBERLAND COUNTY, PENNSYLVANIA 'CIVIL DIVISION ACKNOWLEDGMENT A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on /~ctq~xs~ 2{o , 200 3. I agree that the marriage of the Plaintiff and Defendant is irreti-ievably broken md ninety days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions set forth within the said Marital Property Settlement Agreement documentation. 2003_. IN WITNESS WHEREOF, I set my hand and~~seal th' ~" ~.,l~Y°f~ Plaintiff, Michael~E. e~--'lSro Se On this ~F day, of /~x~/ , 201~k, before me, aL/Notary Public, the undersigned officer, personally appeared Michael E. Frengel, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he executed the same for the purposes therein contained. !otarlyT~iSc WHE F, I hereunto (~f~~ set my hand and official seal. Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( ( NO: ( ( ( ACKNOWLEDGMENT A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ~txOt,l£~c gO , 20(Lq_. I agree that the marriage of the Plaintiff and Defendant is irretltievably broken and ninety days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions set forth within the said Marital Property Settlement Agreement documentation. IN WITNESS WHEREOF, I set my hand and seal thisc-'~ ~""day of ,/j 200~. Defendant, Toni M. Frengel, Pro SO , 2003~, before me, a Notary Public, the On this~:,'-Q~/ day, of A_)oV undersigned officer, personally appeared Toni M. Frengel, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. S;HE~ereunto set my hand and official seal. Notary Public ~ ~ NOTARIAL SEAL DAWN M, SHUGHART, Notary Public Carlisle, Cumberland County My Commission Expires Nov. 28, 2006 Michael E. Frengel, 199-50-3838 PLAINTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 DEFENDANT, 204 Meals Drive Carlisle, PA 17013 (IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( ( ( o AFFIDAVIT OF CONSENT A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ,2003_. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and Complaint. I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the decree. 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 fights 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 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. Section 4904 relating to unsworn falsification t° auth°rities' n?:el, p/. p~roro o~ Date: Defendant, T~ni M. Fre g , ~ I, Toni M. Frengel, certify that a copy of the foregoing Affidavit of Consent was forwarded by US Mail, postage prepaid, on this date, to the Plaintiff, Michael E. Frengel at his address of record. Date: ~~ Michael E. Frengel, 199-50-3838 PLAiNTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (iN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( ( ( AFFIDAVIT OF CONSENT A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ,200D_. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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. 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 ifI do not claim them before a Divorce is granted. I understand that I will not be divorced until a Divorce decree is entered by the Court and 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 t9 the penalties of 18 Pa. C.S. Date:[[/~/~YOo,~Secti°n 4904 relating to unswom falsification to ~/~//~/r~/d~ fauth°ritiTt"/~ /// II Plaintiff, Michael E. Frenge~16~// I, Michael E. Frengel, certify that a copy of the foregoing Affidavit o .was fo,r~.alded .by US Mail, postage prepaid, on this date, to the Defendant,fTCo~.s~v~l vrenge~ at ner address of record. Date: Michael E. Frengel, 199-50-3838 PLAiNTIFF, 7 Independence Drive Shippensburg, PA 17257 Toni M. Frengel 177-42-1502 204 Meals Drive Carlisle, PA 17013 DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO:)003- Oql~Cl ( ( ( PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: on or about 200~L via FI Personal Service FICertified Mail. 3. Date of execution of the Affidavit of Consent/Consent Waiver required by Section 33.0J(c) of the Divorce Code: by Plaintiff ~0v~ntJgt~r ~ 20037; by Defendant ~6i/~ Ag, 200..fit_. 4. Related claims pending: None 5. Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if Decree is to be entered under Section 3301(d) of the Divorce Code. NotApplieable. ~d~ Michael E. Fr[n~, ~{~ Se 7 Independence Dri~ Shippensburg, PA 17257 ( ) I, Michael E. Frengel, certify that a copy of the foregoing document has been forwarded by US Mail, postage prepaid, on this date to the Defendant, Toni M. Frengel, at her address of record. Date:/o-i 11 0o5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF VERSUS PENNA. No. ~005- 0¥/99 DECREE IN AND NOW ~ ~'~ ~ f , , IT IS ORDERED AND DECREED THAT~.l(~tlA61 E, ~6~d~6~_ PLAINTIFF, j ' ARE DIVORCED PROM THE BONDS OP MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW '-' -~aintiff : VS. : IN DIVORCE fendant : 20 NOTICE TO RESUME PRIOR SUPd~AME Notice is hereby gi{~en that the Plaintiff/Defendant in the above matter, having been granted a Final Decree' in DivOrce on th~___l_~, day of~..~ hereby elects to resume the prior surname of '-T'-~V) \ ?'~ ~S{/-'xO,~-_~f- , and gives this written notice pursuant to the provisions of 54 P.S. 704. Signature ~ t Sigrtat~re of re, me bein~ resumed 0 COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : On the c~r/[22~ day of , 20~r~, before me, a 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 h~eunto set my hand and official seal. NOTARIAL SEAL JODY S SMITH, NOTARY PUBLIC Carlisle Boro, Cumberland County My Commission Expires April 4, 2005 Notary Public