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HomeMy WebLinkAbout04-5848 o JESSICA D FRANK, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. DONALD L FRANK, : No.04 - Sf"] Ciu,LC 1~ Defendant. : 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 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 is indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the Cumberland County Bar Association, 32 S. Bedford Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYERS' 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 OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 JESSICA D FRANK, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- SrP'IP (J~L'!-~ v. DONALD L FRANK, Defendant. CIVIL ACTION- DIVORCE COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I 1. Plaintiff is Jessica D. Frank, who currently resides at 4 Annandale Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Donald L. Frank, who currently resides at 265 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiffhas been a bona fide resident 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 July 17, 1999 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. 7. Neither Party is a member ofthe Armed Forces ofthe United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301(c) of the Divorce Code. COUNT II--CUSTODY 9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint for Divorce as fully set forth herein. 10. There was one (1) child born during this marriage, to wit: Erika N. Frank, born on March 22, 2001. 11. During the past five (5) years, the child has resided with the following persons and at the following addresses: Person(s) Mother Address 4 Annandale Drive, Mechanicsburg, P A Dates Birth to present 12. The Court of Common Pleas of Cumberland County, Pennsylvania, Family Division, has the sole and exclusive jurisdiction in this matter, pursuant to the Uniform Child Custody Jurisdiction Act, and the Commonwealth Child Custody Jurisdiction Act for the following reasons: a) Cumberland County, Pennsylvania, has been the child's home county within six (6) months before the commencement of the instant proceedings. b) It is in the best interest and welfare of the child that the Court of Common Pleas of Cumberland County, Pennsylvania, assume jurisdiction because the child has a significant connection with this jurisdiction, and there is available in this jurisdiction substantial evidence concerning the child's present or future care, protection, training and personal relationships. c) No other state has jurisdiction in this matter under the requirements ofthe Uniform Child Custody Jurisdiction Act and the Commonwealth Child Custody Jurisdiction Act. 13. The Plaintiffhas not participated in any capacity whatsoever in any other litigation concerning the custody of the minor child in this or any other state. 14. The Plaintiff does not know if any other person than the Defendant herein claims to have custody or partial custody rights with the minor child. 15. The Plaintiff submits that it is in the best interest and welfare of the child that the Plaintiff be granted custody of the child, and that the Plaintiff can best provide the minor child with a more stable, healthful, religious, and proper environment. WHEREFORE, Plaintiff prays that the Honorable Court grant custody of the minor child of the Parties to Plaintiff. Respectfully submitted, ROBINSON & GERALDO Date: , \ \ ,1 \ G~ ~~~ By: Gerald S. Robinson, Esquire Attorney LD. #27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the 18th day of October, 2004, I caused a true and correct copy of the Complaint to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Donald L. Frank 265 Woods Drive Mechanicsburg, P A 17050 Respectfully submitted, ROBINSON & GERALDO By: Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, P A 17110 (717) 232-8525 VERIFICATION I verify that the statements made in this 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. ~.E~ -il!., .' ~ ~ jl~ ~ ~ ~ 0 w p:! ~e ~"<,~ "- ~ {' - (f' ""lQ. --- ..c (19 . 8(3 l i' ',I I ........, (") ~-~.; --< ~~ 0 ~.~ ""..) C) -- --I -, f(-i ;:;Q -pin ~.T iSJ (_!(-) I..c' ?:. ?~~ . /Tl ~. ::., \.0 -r; 1') Ul r..; :l:: -<~ I " f ~ Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JESSICA D FRANK, v. NO. 04-5848 DONALD L FRANK, Defendant. CIVIL ACTION-LAW IN DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Divorce Complaint was served upon Donald L Frank on November 29,2004 at 265 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania. The signed acceptance of s{lrvice is attached hereto as Exhibit I. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subj{lct to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & Gl8:RALDO Dated: November 30, 2004 BY:~~~ Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff :II PS Form 3811. March 2001 00meIItic Return Receipt 102595-01~t.4I!. . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse 10 that we can return the card to you. . ~h this card to the back of the mailp~' or on the front if space permits. 1. Artk:le Addressed to: lJonoJd L. trtLnJ<>' ct2/.; S LJood5 ])rl ve -. M~ 'lSiw!j' PI+ /7tJ5'tJ o Express Mail ~ Recelp(for MerchandIiIe 2. 7001 1940 0004 16&6 7499 (") r,; ~~i~': ~ -) ~;C) p zO ">.;:'l-\ --S :'j -.... - , ... ,..........) ~:. ~) c::. ..l..-- t-, ;i:::! C"') :"i': ~.. 1 " '" _,"'f' " " ..~" ... "/ ~: . . ( ;, -,,(;", -", t:,) JESSICA D. FRANK, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. No. 04-5848 DONALD L. FRANK, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 3301(c) of the Divorce code was filed on December 3,2004, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 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 unsworn falsification to authorities. Date: L( - ( 'f - {)J- /' ("--PAA"hQ ti:0J, Jessica D. Frank I (~ ...', () c:'). , C) 'n ~n -~ :-;1 I N > 0.) ~. -( '" - JESSICA D. FRANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA: Plaintiff, v. No. 04-5848 DONALD L. FRANK Defendant. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 8 3301 (e) OF THE DIVORCE CODE I. 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! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the ! . prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. pate: 'j-I'I-J' ~eM-&-~ /J. -t~ JE SICA D. FRANK ~, c:;l G c::;. c..rl "" ~ ~ ::::~ -. I N -'('"\ i-.:~ ':".J .r. ...., JESSICA D. FRANK, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. No. 04-5848 DONALD L. FRANK, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 330I(c) of the Divorce code was filed on December 3,2004, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. '4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees lor expenses if I do not claim them before a divorce is granted. 15. I verify that the statements made in this affidavit are true and correct. I understand that ifalse statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn , ralsification to authorities. pate: J./ -,). / -oS ~-4I/~J Donald L. Frank ,.., C? ~ - <''''" ."'-,'~ ::.< I N .<. q, .-{ ,,,.4'"' (l'lf'-:' ; '-~ C") (-:.'7 .<C" C", - JESSICA D. FRANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA: Plaintiff, v. No. 04-5848 DONALD L. FRANK Defendant. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER Ii 3301 ee) OF THE DIVORCE CODE I. 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! 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. S4904 relating to unsworn , Ifalsification to authorities. pate: ..; -"I, I - (,5- ~//~~ DONALD L. FRANK ~1 0 = -OJ LJ'l ;: -.:-",. --<. . N " -"... ;" Sa.' - 0', JESSICA D. FRANK Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-5848 DONALD L. FRANK, CIVIL ACTION- LAW IN DIVORCE Defendant. MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this I r day of Ap,,~ I , 2005, by and between Jessica D. Frank, of Carlisle, CUMBERLAND County, Pennsylvania, hereinafter referred to as "Wife," and Donald L. Frank, of Mechanics burg, Cumberland County, Pennsylvania, hereinafter referred to as "Husband." WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 17, 1999; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of each other; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and detennine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them. 1 NOW, THEREFORE, in consideration 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, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. The Parties acknowledge that they have received or had the opportunity to receive independent legal advice from counsel of their selection and that they fully understand the facts and have been informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstance fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge 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. 2. SEP ARA nON. It shall be lawful for each Party at all times hereafter to continue to live separate and apart from the other Party. The foregoing provisions 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. 3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The Parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them at the request of either Party. The Parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania, shall retain continuing jurisdiction over the Parties and the Agreement for the purposes of enforcement of any of the provisions thereof. 2 The Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the Parties, although this Agreement shall be incorporated into said Decree, this Agreement shall not merge with, but shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the Parties and may be enforced in an action independent of the Divorce Decree. The Parties agree and it is the intent of each of them that even though this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent of the Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code, the provisions of this Agreement regarding the disposition of existing property rights and interests between the Parties, alimony, alimony pendente lite, counsel fees and expenses shall not be subject to modification by any Court. 4. SUBSEOUENT DIVORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section 330 I (c) of the Pennsylvania Divorce Code. 5. INTERFERENCE. Each Party shall be free from interference, authority, and contact by the other, as fully as ifhe or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither Party shall molest the other or attempt 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, separate and apart from the other. 3 6. WIFE'S DEBTS. Wife represents and warrants to Husband that she will not contract or incur any debt or liability for which Husband or his estate might be responsible and she shall indemnifY and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that he will not contract or incur any debts or liability for which Wife or her estate might be responsible, and he shall indemnifY and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party has released and discharged, and by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the Parties had or now has against the other, except for any and all causes of action for divorce and except for any and all causes of action for breach of any provisions of this Agreement. 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the Parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the Parties and, further, that the Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to receive an Inventory and Appraisement of all 4 property owned or possessed by them, either jointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. 10. CUSTODY. Husband and Wife shall have shared legal custody of Erika Nicole Frank, born March 22, 2001. Wife shall retain primary physical custody of said minor child. Husband shall have periods of partial custody as the parties mutually agree. II. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise provided, each Party may dispose of his or her property in any way, and each Party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy, right to take against the will of the other's estate, and who will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquislunent of all such interests, rights and claims. 12. 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 advisable to him or her, and the Party breaching this Contract shall be responsible for payment oflegal fees and costs incurred by the other in enforcing their rights under this Agreement. 5 13. 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. 14. MODIFICATION AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either Party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 15. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations ofthe Parties. 16. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 17. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 18. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both Parties and 6 . each Party acknowledges that this Agreement is in all respects fair and equitable, that it is being entered into voluntarily and knowingly, and that it is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF, the Parties have hereunto set their hands and seals the day and year first above written. ~ n~ it~ (SEAL) J ssica D. Frank, Plaintiff ~~ ~~'::;;:-.-J (SEAL) Witness Donald L. Frank, Defendant /' Witness 7 ~, ""'~:J r' , , , , 1 ::-J . -'-~ 1 C:'j. .1 .< ~ ... Jessica D Frank, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, v. : NO. 04-5848 Donald L Frank, Defendant. CIVIL ACTION--LA W IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under section 330 I ( c) of the Divorce code. 2. Date and Manner of service of the Complaint: served upon Defendant Donald Frank, by Certified Mail, Restricted Delivery, on or about November 29, 2004. A copy of the signed Return Receipt is attached hereto as Exhibit I. 3. Date of execution of the affidavit required by section 3301(c) of the Divorce Code: by Plaintiff on April 19, 2005 and by Defendant on April 21, 2005. 4. Related claims pending. The economic claims have been settled by agreement. - . 5. Date the Plaintiff's waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: is May 2, 2005. 6. Date the Defendant's Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: May 2,2005. Respectfully submitted, ROBINSON & GERALDO Slu~ By Gerald S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff. ~ . . 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.:~/' .. ':r, . Attach this card to the back of the mail piece, t~, or on the front if space pennits.\;,!j-~,:. 1. Article Addressed to: fi\i:).:,i JJ6no...ld. L. trCLnJ("i,;. cQl./S cJood5 ])/1 ve ~;:' M t"c.hM1 tlS -fw!j I Pit /7050 3. Se<vlce (j El~ an:erofied Mail 0 Express Mail o Registered ~eturn Receip(for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) es 2. 7001 1940 0004 1686 7499 PS Form 3811 , March 2001 Domestic Return Receipt 102595-01-M"1424 EXHIBIT j , r<: _I C", ... -~ i "-',; ;+:;+:;+:;+:;+: + + Of,+, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~+;+:+~+;+:;+:++~;+:+++++++++~;+:++;+:;+:+++++? 'f.'f.:f.;+::+: + + ~;+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;+::f.:+::f.;ti;+:;ti;+::+:;ti;+::+:~~;+: ;+::+:++;+::+:++:+::+:+;+::+::+::+::+:;+::+::+::+::+::+:;ti;+::+::+: ;+::+::+::+::+: +:+::+::+:;+::+::+::+: Of. +;+: + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Jp-ssica D. Frank VERSUS Dnnrl' n T. Frrlnk PENNA. No. 04 'iA4A DECREE IN DIVORCE AND NOW, 'J~( ..a- ! .08' f./I11 /)065, IT IS ORDERED AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE DECREED THAT Jessica D. AND Donald L. Frank Frank , PLAINTIFF, , DEFENDANT, YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT Marriage Settlement Aareement dated April 15. 2005 is into this Order. By TH ATTEST: . PROTHONOTARY +:+:+~++++~+++ J. - ;/t;o" ~- ~u; 50. ~- 9 ~ ~ ~ ~,;,~ n 50- ~.~ . - I '. '.,;' . .'\..'!:.. ~: --". ; ], '.. ~ .