Loading...
HomeMy WebLinkAbout00-05073IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Tina Z. Trump, Plaintiff No. 2000-5073 Civil VERSUS Timothy L. Trump, DEGREE IN DIVORCE AND NOW, _?J e_ v?Znj, IT IS ORDERED AND DECREED THAT Tina M. T , PLAINTIFF, AND Timothy L. Trump DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE.FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD- IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The attached Property Settlement Agreement, dated July 12, 2001, ; hereby incorporated, but not merged, into the Divorce Decree. Y12r?7/ eLV AC'S PROPERTY SETTLEMENT (? THIS AGREEMENT, made this Ia day of D"?, 2001 by and between TINA M. TRUMP of Cumberland County, Pennsylvania (hereinafter referred to as WIFE), and TIMOTHY L. TRUMP of Cumberland County, Pennsylvania (hereinafter referred to as HUSBAND), WHEREAS, HUSBAND and WIFE were lawfully married on February 18, 1999 in Cumberland County, Pennsylvania; and WHEREAS, one (1) child was born of this marriage, namely: MELISSA TRUMP, born August 5, 1994; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them e relating to past, present and future support and alimony; and in general, the settling of any and all claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. Separation: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2, Interference: Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall 1 molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence of the other, while living separate and apart. 3. Subsequent Divorce: The parties acknowledge that WIFE has filed a Complaint in Divorce in Cumberland County, Pennsylvania, to docket number 2000-5073 Civil Term, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. HUSBAND hereby expresses his agreement that the marriage is irretrievably broken and expresses his intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court- ordered counseling under the Divorce Code. It is specifically understood and agreed by the parties that the provisions of this Agreement as to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. 2 Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is specifically agreed, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference, but not merged, into any divorce, judgment or decree. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. Date of Execution: The "date of execution" or "execution date" of this Agreement shall be defined as the day 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 3 execution by the party last executing this Agreement. 5. Distribution Date: The transfer of property, funds and/or documents provided for herein, shall only take place on the "distribution date" which shall be defined as specified herein. 6. Mutual Release: HUSBAND and WIFE each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a 4 surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any country, or any rights which either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relations or otherwise, except, all rights and obligation of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all right and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which 5 each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce code or the divorce laws of any other jurisdiction. 7. Advice of Counsel: The provisions of this Agreement and their legal effect have been fully explained to WIFE by MARYANN MURPHY, ESQUIRE, counsel for WIFE. HUSBAND has knowingly, willingly and voluntarily waived his right to counsel. HUSBAND understands that he has the right to have an attorney of his choice review this Agreement before it is executed. HUSBAND and WIFE acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 8. Warranty as to Existing obligations: Each party represents that he or she has not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the 6 other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligation arising out of this Agreement. 9. EXISTING DEBTS: HUSBAND and WIFE agree that there are no debts in joint names. HUSBAND agrees to be solely and exclusively responsible for any and all debts in his individual name and for those credit cards where he is the primary user. HUSBAND further agrees to indemnify WIFE and hold her harmless from any and all liability for same. WIFE agrees to be solely and exclusively responsible for any and all debts in her individual name and for those credit cards where she is the primary user. WIFE further agrees to indemnify HUSBAND and hold him harmless from any and all liability for same. 10. Warranty as to Future Obligations: HUSBAND and WIFE each covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall 7 hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 11. Personal Property: The parties agree they have divided all of their personal property between themselves. WIFE shall be the sole and exclusive owner of all personal property, including the computer, currently in her possession. HUSBAND shall be the sole and exclusive owner of all personal property, including the balance of the parties, joint savings account, currently in his possession. HUSBAND and WIFE agree that the above division of property is mutually acceptable to them. Neither party shall make any claim to any such item of marital property or of the separate personal property of either party, except as provided for in this Agreement, which will be in the possession and/or under the control of the other at the time of the execution of this Agreement. Should it 8 become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the execution of this Agreement; and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party at the time of the execution of this Agreement. 12. Motor Vehicles: The parties agree that they owned a 1985 Chevrolet Silverado truck with no outstanding loan. HUSBAND acknowledges that he sold this truck for one hundred ($100.00) dollars after the date of separation. WIFE waives her rights and interest in said truck and the proceeds therefrom. 13. Pension/Retirement Benefits: H U S B A N D a n d W I F E acknowledge that neither has accrued pension/retirement benefits 9 during the course of the marriage. 14. After Acquired Personal Property: Each of the parties shall hereafter own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, 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. 15. Applicability of Tax Law to Property Transfers: The parties hereby agree and express their intent that any transfers of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (herein the "Act"), specifically, the provisions of said Act pertaining to transfers of property between spouses or former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement, without recognition of gain on such transfer and subject to the carry-over basis provisions of said Act. 16. Waiver of Alimony: The parties herein acknowledge that, 10 by this Agreement, they have respectively secured and maintained an adequate fund with which to provide for themselves sufficient financial resources for their comfort, maintenance and support. HUSBAND and WIFE do hereby waive, release and give up any rights they may respectively have against the other for alimony, spousal support or maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 17. Waiver of Alimony Pendente Lite, Spousal Support and Counsel Fees: Each party hereby waives any rights to alimony pendents lite and spousal support. The parties agree to be responsible for their own attorney's fees. 18. Full Disclosure: HUSBAND and WIFE each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever and of every type whatsoever in which such party has an interest, and of all other facts relating to the subject matter of this 11 Agreement. 19. 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 the 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. Both parties waive the following procedural rights: a. The right to obtain an Inventory and Appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code; b. The right to obtain an Income and Expense Statement 12 of the other party as provided by the Pennsylvania Divorce Code; c. 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; d. The right to have the Court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including but not limited to, possible claims for divorce, spousal support, alimony, alimony pendente lite, counsel fees, costs and expenses. 20. Waiver of Modification to be in Writing: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 21. Mutual Cooperation: Each party shall, at any time and from time to time hereafter, take any and all steps and execute, 13 acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 22. Applicable Law: This Agreement shall be construed in accordance with the laws of the commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 23. Agreement Binding on Heirs: This Agreement shall be binding and shall inure to the benefits of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 24. Integration: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 25. Other Documentation: HUSBAND and WIFE covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other 14 writings as may be necessary or desirable for the proper effectuation of this Agreement. 26. No Waiver on Default: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provisions hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 27. Severability: if any 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. Likewise, the failure of any party to meet his or her obligation under any one or 15 17 more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 28. Breach: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her. The party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this agreement. 29. Headings Not Part of Agreement: Any heading 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. IN WITNESS WHEREOF, the parties hereto have set their 16 hands and seals this day and year first above written. 4 9 61 Q" "M /a.;, Late Witness TIMOTHY . T VMP / ? T S 1d1? bate Witness TIN ?tmrj {,L? ,?c?np 'I xzti?L- s/?yt7?e on/y Notarial Seat Helen D. Sneed, Notary @ubllo Middlesex 7wp., Cumberland Coyntyy Ay Commission Expires June 24, 2o®p M. TRUMP 17 c> "..: = ?.. -- - ? r- ?_ : _. ? ?: -, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff No. 2000-5073 Civil Term V. TIMOTHY L. TRUMP, : IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To The Prothonotary: 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: Sent to Defendant on July 20, 2001. by U.S. first class mail postage pre-paid Personal service accented by Defendant on July 21 2001. 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, July 12, 2001; by Defendant, April 19. 2001. (b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of filing and service of the Plaintiff s Affidavit upon Defendant: N/A. 4. Related claims pending: All claims have been resolved by the Property Settlement Agreement dated July 12, 2001. 5. Complete either paragraph (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 Plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 23.2001. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: A_pri124.2001. Plaintiffs Social Security Number: 173-60-3523 Defendant's Social Security Number: 105-54-3735 David Lopez, EWi MIDPENN LEGAL 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 -? ?_ -. r, ? - _. -:-, .. - ?? . l ;- -?' c, _? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff V. No. GG - SU73 Civil Term TIMOTHY L. TRUMP, : IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of 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, 1 Courthouse Square, 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, PA 17013 (717) 249-3166 Le han demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra soya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier que ja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA LISTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO ALA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff No. UU _ 30 7,3 Civil Term V. TIMOTHY L. TRUMP, : IN DIVORCE Defendant COUNTI COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW comes TINA M. TRUMP, by and through her attorney, Maryann Murphy, Esquire of Legal Services, Inc., who respectfully avers as follows: 1. Plaintiff is TINA M. TRUMP whose current address is 1501 Williams Grove Road, Lot #4, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is TIMOTHY L. TRUMP whose current address is 960 Lisburn Road, Wellsville, York County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 18, 1999 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. Plaintiff and Defendant are the owners of savings accounts and other personal property acquired during the marriage which is subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 13. Plaintiff requests this Court to equitably distribute the parties' marital property. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equitably distributing all property owned by the parties hereto; and c. for such further relief as the Court may determine to be equitable and just. Respectfully submitted, Maryam Murphy, Esqu're ` LEGAL SERVICES, INC. S Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff AFFIDAVIT I, TINA M. TRUMP, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date TINA M. TRUMP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff V. TIMOTHY L. TRUMP, Defendant No. Civil Term IN DIVORCE CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Divorce Complaint was mailed to the Defendant, TIMOTHY L. TRUMP, by first class U.S. mail, postage pre- paid, certified/restricted delivery, addressed as follows: Timothy L. Trump 960 Lisburn Road Wellsville, PA 17365 Respectfully submitted, L? Maryan Murphy, Esqui LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff C) !"7 ? } f ?l ri l:7; =? r -_ _- [r,.?" v? -s, --. - _ •• ' _ :{ f .. t9't = , :r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff NO. (xj - S'U23 Civil Term V. IN DIVORCE TIMOTHY L. TRUMP, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, TINA M. TRUMP, Plaintiff, to proceed in forma an u?eris. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. 4V C,1UsU??A Marya Murphy, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff V. NO. &v- 50,7-3 Civil Term IN DIVORCE TIMOTHY L. TRUMP, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I ant TINA M. TRUMP, Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: TINA M. TRUMP Address: 1501 Williams Grove Rd.. Lot #4, Mechanicsburg, PA 17055 (b) Social Security Number: 173-60-3523 If you are presently employed, state Employer: Scientific Games Address: 2850 Turnpike Ind Park Dr. Middletown, PA Salary or wages per month: $1,520.00 gross Type of work: Warehouse worker If you are presently unemployed, state N/A Date of last employment: Salary or wages per month: N/A Type of work: (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: Dividends: Pension and annuities: -0- Social Security benefits: Support payments: Order for $70.00 per month - not paid Disability payments: -0- Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support N/A (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: N/A Salary or wages per month: N/A Type of work: Contributions from children: -0- (e) Property owned Cash: Checking Account: Savings Account: -0- Certificates of Deposit: Real Estate (including home): N/A Motor vehicle: Make N/A Year N/A Cost N/A Amount owed N/A Stocks; bonds: -0- Other: (f) Debts and obligations Mortgage: N/A Rent: Loans: $16.00 Monthly Expenses: $1,400.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: MG,4+kPlA) Name: M e 19 S CL, Name: Name: Age: I Age: Age: Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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 unworn falsification to authorities. Date:/7-t/-04 A -MnC6 ? Wn D TINA M. TRUMP C c? -rf C^ -? 4 Uj i IJ -G C? _ Q.3 O4 V W v? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff V. TIMOTHY L. TRUMP, Defendant : No. 2000-5073 Civil Term IN DIVORCE AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on July 20, 2000, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number 7000 0600 0025 1595 3348, a 3301(c) Complaint in Divorce to the Defendant, TIMOTHY L. TRUMP, at the following address: Timothy L. Trump 960 Lisburn Road Wellsville, PA 17365 3. That on July 21, 2000, the Defendant was served with the Complaint in Divorce as evidenced by his signature on the green card, number 7000 0600 0025 1595 3348, which is I attached hereto. Maryann urphy, Esquire LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 I > ¦ Complete items 1, 2, and 3. Also complete item:4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on1he front if space permits. 1. Article Addressed to: Timo?? ?. rru.mP (,?,?lsu i 1 Ge, P i?t3b5 2. Article Nefnber (Copy from er(91 from1PS_Form 3811,..wiy 1999 h .. A T+noikt,cw?? I 7?l C. Signature X? ?Agi d. 0. Is delivery address different froem 1 e: If YES, enter delivery address below: ? No 3. Service ?erttf M? ' { ? Regiik[ ed h.4se- ? InsurbdiMail„ . 313 Domestic:Retufn Receipt 102595-99-M-1789 t a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff No. 2000-5073 Civil Term V. TIMOTHY L. TRUMP, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 19, 2000. 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. 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 to authorities. 7 ?tial Dad TINA M. TRUMP ?• &L ?+:-'JnK..,?.?-'.?e !+rG!-.f Y:v+R%AE25 3 riffa?Km'f.%fa-iiiti?'aa3ei'tl16tBeChltLiYB&&WNSYNfi'SWWHI' -•••••"•.•'•••". ••w.• . CJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff No. 2000-5073 Civil Term V. TIMOTHY L. TRUMP, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. I Date TINA M. TRUMP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff No. 2000-5073 Civil Term V. TIMOTHY L. TRUMP, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 19, 2000.. 2. The marriage ofPlaintiff 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 herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ,q-)q- 61 2r" ii? Date TIMOTHY L T UMP LMyMiddl es ez Twp NTember, Pennsylvania Association 01 N otanes Notarial Seal Helen D. Sneed, Notary Public ., Cumbedand County 2 Commission Expires June 24, 2002 ?' c3 ...? Q II .L7 .. .7; n ? F F 7 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TINA M. TRUMP, Plaintiff : No. 2000-5073 Civil Term V. TIMOTHY L. TRUMP, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date TIMOT L. TRUMP / co