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HomeMy WebLinkAbout05-3139IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. DT-3Q c? 01 0'NV2-""J V. TODD A. FREEMAN, Defendant CIVIL ACTION - LAW 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 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. tVS- 3139 V. CIVIL ACTION- LAW TODD A. FREEMAN, DIVORCE Defendant COMPLAINT Plaintiff, Kristen N. Freeman by her attorney, Diane G. Radcliff, Esquire, files this Complaint in Divorce of which the following is a statement: COUNTI DIVORCE 1. The Plaintiff is Kristen N. Freeman, an adult individual who currently resides at 221 West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania since June 1999. 2. The Defendant is Todd A. Freeman, an adult individual residing at 1203 Gross Drive, Mechanicsburg, Cumberland County, Pennsylvania since 2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 3, 1999 at Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 7. Defendant is not a member of the Armed Services of the United States or any of its Allies. -2- 8. Plaintiff avers that the grounds on which the action is based are: A. Section 3301(c) Mutual Consent No-Fault: The marriage is irretrievably broken; B. Section 3301(d) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, 3448 Tri le Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff -3- VERIFICATION KRISTEN N. FREEMAN verifies that the statements made in this Complaint are true and correct. KRISTEN N. FREEMAN understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. KRISTEN N. FREEMAN Date620s / w -4- 7J T:? Vi -41 rn ? 7?n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. D5-.3139 v. TODD A. FREEMAN, Defendant CIVIL ACTION - LAW DIVORCE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in October 2001 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 falsifica ions to authorities. Dater KRISTEN N. FREEMAN, Plaintiff CZ n= F uo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. nS'-3139 ac-? .1 V. TODD A. FREEMAN, Defendant Commonwealth of Pennsylvania County of Cumberland CIVIL ACTION - LAW DIVORCE Before me, the undersigned Notary Public, personally appeared KRISTEN N. FREEMAN, Plaintiff in the above entitled case, who being duly sworn or affirmed according to law, deposes and says that the Defendant or respondent above named is not in the military service of the United States of America, that she has personal knowledge that the said Defendant or respondent is now living at 1203 Gross Drive, Mechanicsburg, Cumberland County, Pennsylvania, and is a resident of Cumberland County, Pennsylvania and is employed at or by Herre Brothers, Enola, Pennsylvania. r ' DJ . KRISTEN N. FREEMAN Sworn to and subscribed before me this day 2005. NOTAR UBLIC H OF PENNSYLVANIA tarial Seal dcliff, Notary Public, Cumberland County n Expires Jan. 11, 2006 no ?....,:^?-iaUnn Of Notaries 5MR N} d ? r _ ?:J'? ?? J ?4 L Tt . __r. ? ,_.. n ' N =? ? ? ? --? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 CIVIL TERM V. TODD A. FREEMAN, Defendant CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE I hereby certify that on August 6, 2005, 1 served a true and correct copy of the Notice of Intention to Request Entry of 3301(d) Divorce Decree and Counter-Affidavit upon Todd A. Freeman, the Defendant, by Certified Mail addressed as follows: Todd A. Freeman 1203 Gross Drive Mechancisburg, PA 17055 The August 5, 2005 letter to Defendant, Notice of Intention, and Counter-Affidavit are attached as Exhibit "A" and made a part hereof. The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "B" and made a part hereof. , ESQUIRE Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff DIANE G. RADCLIFF, ES 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 E-mail: dianeradcliff@comcast.net August 5, 2005 Todd A. Freeman 1203 Gross Drive Mechanicsburg, PA 17055 IRE 1E Re: Kristen N. Freeman v. Todd A. Freeman Cumberland County Divorce No. Dear Mr. Freeman: Enclosed is a copy of the Plaintiff's Notice of Intention to Request Entry of Divorce Decree together with a 3301(d) Counter-Affidavit. Also enclosed is the revised Custody Stipulation and Proposed Order. This document is identical to the last one provided to you with the exception that the Christmas periods have been changed to alternate between the parties. If this document is acceptable to you, please sign the Stipulation as indicated and return it to my office. As per the enclosed letter, I am providing your attorney with a copy of this letter so that she is aware of this action being taken. I trust that you will consult with her regarding these matters. If and when she enters her appearance in this case, I will communicate with her directly regarding matters involving service of legal documents. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGR/dr Enclosure(s): 8.5.05 Notice of Intention with 3301(d) Counter-Affidavit 8.5.05 letter to Attorney Tanner cc: Tabetha Tanner, Esquire Kristen N. Freeman File 50-05-0 Transmitted by regular mail and certified mail #7004 0750 0004 1090 6421 KRISTEN N. FREEMAN, Plaintiff v TODD A. FREEMAN, Defendant 51 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3139 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 3301 (dl DIVORCE DECREE TO: TODD A. FREEMAN, DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 3301(d) affidavit. Therefore, on or after August 26, 2005, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone No. (717) 249-3166 Date: August 5, 2005 A G. RAD,CLIFF, ESQUIRE Camp Hill, PA 17011 Supreme Court ID # 32112 Attorney for Plaintiff KRISTEN N. FREEMAN, Plaintiff v TODD A. FREEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 05-3139 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): [ ] (a) I do not oppose the entry of a divorce decree. [ ] (b) I oppose the entry of a divorce decree because Check (i), (ii) or both: [ ] (i) The parties to this action have not lived separate and apart for a period of at least two years. [ ] (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): [ ] (a) I do not wish to make any claims for economic relief. 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. [ ] (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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: TODD A. FREEMAN, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ¦ Complate items 1, 2, and 3. Also complete item 4It Restricted Delivery Is deelred. ¦ 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 mailpksce or on the front If apace permits. 1. Article Addremed to. Todd A. F2EErmd 1203 GRzss U. MEC44 401CS SU4& P A. Agent of Dailvery D. b delivery Worms different from item 1? 0 Yee If YES, enter dewy address below. 0 No 3. 1yw t%loq FCWV W Mail 0 Egress Mall O Registered 0 Return Receipt for Merchandise 0 Insured MGM 0 C.O.D. 4. Restrialmo DBINeRR (Eft Fee) 0 Yes 2. Article Number (AansfarRomsambs 7004 0750 0004 1090 6421 PS Form 3811, February 2ou Domeem:Return Asoelpt 102se15-02-1*1540 EXHIBIT "B" CERTIFIED MAIL RETURN RECEIPT CARD L? -c,. .tea ?"') ?r co a CO { 05 SEPARATION AGREEMENT This Agreement, made and entered into this 71 day of_ 2005, between Kristen N. Freeman., residing at 221 West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17050, (hereinafter referred to as "Wife,", and collectively with "Husband" as "the parties") and Todd A. Freeman, residing at 1203 Gross Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, (hereinafter referred to as "Husband", and collectively with "Wife" as "the parties") WITNESSETH: WHEREAS, the parties were married on April 3, 1999, and remain married; and WHEREAS, presently irreconcilable differences having arisen between the parties, as a result of which they been living separate and apart for a period of at least two years; and WHEREAS, the parties have agreed to secure a 3301(d) no fault divorce; and WHEREAS, the parties have agreed that neither will raise any claims to prevent said divorce from being entered and a divorce decree from being issued; WHEREAS, in light of the parties' separation, they hereby desire to enter into an agreement to define their respective financial and property rights, together with all other rights, remedies, privileges and obligations which have arisen out of their marriage. The Page 1 of 7 parties agree that their future relations shall be governed and fully prescribed by the terms of this Agreement (hereinafter referred to as "the Agreement"); and WHEREAS, the parties have disclosed to the other's satisfaction the nature and value of all of their presently constituted assets, liabilities and income; and WHEREAS, Husband having been represented by the law firm of Tanner Law Offices, LLC with offices located in Lemoyne, Pennsylvania, and Wife having been represented by the law offices of Diane G. Radcliffe with offices located in Camp Hill, Pennsylvania; NOW THEREFORE, in consideration of the mutual promises, covenants, agreements and terms herein contained, the parties hereto intending to be legally bound hereby do mutually agree as follows: ARTICLE I SPOUSAL SUPPORT AND MAINTENANCE 1. Alimony. Each party hereby waives, now and forever, notwithstanding any possible foreseeable or unforeseeable changed circumstances, the right to receive alimony or any other form of spousal support from the other. 2. Insurance. Neither party shall have any obligation to provide or maintain any form of insurance for the other's benefit; such insurance to include, without limitation, Page 2 of 7 health, life, automobile, disability, homeowner's, etc., and neither shall have any obligation to pay any of the other's unreimbursed, uncovered health-related expenses. ARTICLE II EQUITABLE DISTRIBUTION 3. Marital Home. The parties acknowledge that during the marriage, they were vested with title, as tenants by the entirety, to premises located at 221 West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17050 (hereinafter refereed to as the "marital home"). On May 1, 2002, the parties entered into a Deed transferring title of the marital home to Wife. The parties also executed a Waiver of Marital Interest in regard to the marital home. Husband, in consideration of the covenants contained herein, hereby waives any and all interest he may have in 221 West Locust Street, Mechanicsburg, Pennsylvania. 4. Automobiles. The parties agree that each shall retain ownership of the automobile presently in their possession. The parties understand and acknowledge that each shall continue to be responsible for any and all obligations with respect to their respective automobiles including, without limitation, costs of maintenance and repairs, license, registration, insurance and any miscellaneous charges in connection therewith. 5. Bank and Financial Accounts. The parties each hereby waive, release and relinquish any and all right, title and interest either may have in and to the other's Page 3 of 7 separately titled bank and financial accounts; including, without limitation, checking, savings, certificates of deposit, money markets and financial investment accounts of whatever kind and nature, and neither shall make any claim against the other's property now or in the future. 6. Retirement plans, 401(k)s, IRAs and Deferred Savings Plans. The parties each hereby waive, release and relinquish any and all right, title and interest either may have in and to the other's pension, annuity or profitsharing plan(s), IRA account(s), or any other such retirement benefit of like kind and character, and neither shall make any claim to the other's said property, now or in the future. The parties agree to retain possession and ownership of such properly as same is presently titled. 7. Stocks and Bonds. The parties agree to mutually waive, release and relinquish any and all right, title and interest either may have to any stocks, stock plans and bonds presently in either party's name. The parties agree to retain possession and ownership of such property as same is presently titled. 8. Personal Affects. The tangible personal effects acquired by the parties throughout the marriage have been distributed to the satisfaction of each party. Page 4 of 7 ARTICLE III INDEPENDENT LEGAL REPRESENTATION 9. Independent Legal Representation. The parties acknowledge that each has had the opportunity to be represented by independent counsel with respect to the negotiation, drafting and execution of this Agreement. Husband has been represented by Tanner Law Offices, LLC, with offices in Lemoyne, Pennsylvania and Wife has been represented by the law offices of Diane G. Radcliffe with offices in Camp Hill, Pennsylvania. The parties represent and acknowledge that each understands all of the legal and practical effects of this Agreement, and with this understanding, each signs voluntarily, of their own free will, and without any undue influence, fraud, coercion or duress of any kind whatsoever exercised upon either of them by any person. ARTICLE IV MISCELLANEOUS PROVISIONS 10. Entire Understanding. The parties acknowledge and agree that this Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. Page 5 of 7 11. Modification of this Agreement. 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. 12. Breach. In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of a breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 13. Applicable Law and Execution. The parties hereto agree that this Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. 14. Review of Agreement. The parties acknowledge that each has read and reviewed this Agreement in its entirety and has had the opportunity to obtain advice of separate legal counsel, prior to signing. Page 6 of 7 IN WITNESS WHEREOF, and intending to be legally bound, the parties have set their hands and seals the day and year written below their respective names. Kristen N. Freeman Todd A. Freeman Date: /. Aid lflw Signature of Witness 1/-0 , drah C• J/a4lev Printed Name of Witness Date: 7 le?5 Signature of Witness -7-adIAO A- -70nj-er Printed Name of Witness Page 7 of 7 ``?' ?--? ? :.. t_7 G7 -?? .? ? L" `3 _ y -,?1 .:. '-; c?F t , ?' - -ii :c' _- ,-? 1 ?.1 _ -'i ;?_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 V. CIVIL ACTION - LAW IN DIVORCE TODD A. FREEMAN, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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. Dated: ISTEN N. FREEMAN Y-3 f7l t ,r ti;a1 -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 V. CIVIL ACTION - LAW IN DIVORCE TODD A. FREEMAN, Defendant 1. I consent to the entry of a final decree in 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 Waiver 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. Dated: -?° IST N. FREEMAN CO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 V. CIVIL ACTION - LAW IN DIVORCE TODD A. FREEMAN, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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. Dated / z1 aS TODD A. FREEMAN r--:? C) C R? r1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 V. TODD A. FREEMAN, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 1. I consent to the entry of a final decree in 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 Waiver 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. Dated: TOD A. FREEMAN c> 45 '; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff . NO. 05-3139 CIVIL TERM V. : CIVIL ACTION - LAW TODD A. FREEMAN, DIVORCE Defendant PRAECIPE OF 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 OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: June 17, 2005 b. Manner of Service of Complaint: Certified Mail/Restricted Delivery C. Date of Service of Complaint: June 24, 2005 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: September 21, 2005 b. Defendant: September 27, 2005 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: N/A b. Date of Filing: N/A C. Date of Service: N/A 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Marital Agreement dated September 27, 2005, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(D)(1)(1) OF THE DIVORCE CODE: a. Date of Service: N/A b. Manner of Service: N/A OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: October 5, 2005 b. Defendant's Waiver: October 5, 2005 r? MdtE-e': RAD FF, ESQUIRE 3448 Trindle Roa ' 011 Supreme Court ID # 32112 Phone: (717) 737-0100 _ 'r KRISTEN N. FREEMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TODD A. FREEMAN : NO. 2005 - 3139 CIVIL TERM ORDER OF COURT AND NOW, this 12TH day of OCTOBER, 2005, it appearing to the Court that the Plaintiff's Affidavit of Consent was executed on the 891h day after the service of the complaint, the request for the entry of a final divorce decree is DENIED without prejudice. Edward E. Uuldo, J. /lane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, Pa. 17011 /odd A. Freeman 1203 Gross Drive Mechanicsburg, Pa. 17055 :sld D`5? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 V. CIVIL ACTION - LAW IN DIVORCE TODD A. FREEMAN, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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. d 0 f I Dated: rXICk. ? , l? CY 1{RI EN N. FRE MM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff NO. 05-3139 V. TODD A. FREEMAN, Defendant CIVIL ACTION - LAW IN DIVORCE 1. I consent to the entry of a final decree in di, notice. 2. I understand that I may lose rights concerning of property, lawyer's fees or expenses if I do before a divorce is granted. 3. I understand that I will not be divorced until is entered by the Court and that a copy of the 7orce without alimony, division not claim them a divorce decree decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver 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. Dated: Zti I -- KRISTEN N. FREEMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff : NO. 05-3139 CIVIL TERM V. : CIVIL ACTION - LAW TODD A. FREEMAN, DIVORCE Defendant PRAECIPE OF TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: June 17, 2005 b. Manner of Service of Complaint: Certified Mail/Restricted Delivery C. Date of Service of Complaint: June 24, 2005 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: October 25, 2005 b. Defendant: September 27, 2005 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: N/A b. Date of Filing: N/A C. Date of Service: N/A 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Marital Agreement dated September 27, 2005, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(D)(1)(I) OF THE DIVORCE CODE: a. Date of Service: N/A b. Manner of Service: N/A OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: October 31, 2005 b. Defendant's Waiver: October 5, 2005 DCLIFF, ESQUI 344?Tri,* Road --f , A 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KRISTEN N. FREEMAN Plaintiff No. 05-3139 CIVIL TERM VERSUS TODD A. FREEMAN, Defendant DECREE IN DIVORCE AND NOW, 2005 T IS ORDERED AND DECREED THAT KRISTEN N. FREEMAN AND TODD A. FREEMAN ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No issues are outstanding. All issues have been resolved and settled by the Parties' Marital Agreement dated September 27, 2005, filed of record and incorporated into, but not me _ with, this Decree. BY THE ATTEST: PROTHONOTARY /Xw 1 ?? _s? p Il 1 iLCLI-Ji' Ili 1 111! IA?1 1 IQ ¦1 Praecipe to Withdraw Appearance 2010 FEB 16 PK 3: 13 Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 CI:Pv? -t t_ IN,y Supreme Court ID # 32112 Phone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff @comcast.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN N. FREEMAN, Plaintiff V. TODD A. FREEMAN, Defendant : NO. 2005-3139 CIVIL TERM : CIVIL ACTION - LAW . IN CUSTODY PRAECIPE TO WITHDRAW APPEARANCE OF LEGAL COUNSEL To the Prothonotary: Please withdraw the appearance of Diane G. Radcliff, Esquire, as legal counsel for Plaintiff, Kristen N. Freeman, there being no matters pending in this case, and Plaintiff now being represented by Gregory Hazlett, Esquire, as appearing on the February 3, 2010 Custody Stipulation Agreement filed on record in this case. DIANE-G. DCLIFF, ESQUIRES 3 e Road Camp Hill, PA 17011 Phone: 717-737-0100 Supreme Court ID # 32112 Date: February 12, 2010