HomeMy WebLinkAbout06-5270
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - SJ..7D CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
NOTICE
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 in 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, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717.249-3166
1-800-990-9108
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.
,
JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - ~J. 70 CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301(C) AND illl OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Jevon T. Ford, by and through her attorneys, Irwin, &
McKnight, and files this Complaint in Divorce against the Defendant, Tara J. Tomlinson-Ford,
representing as follows:
I. The Plaintiff is Jevon T. Ford, an adult individual residing at 3 Sycamore Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is Tara J. Tomlinson-Ford, an adult individual currently residing at
2108 Cedar Run, Apartment 102, Camp Hill, Cumberland County, Pennsylvania 17011.
3. The Plaintiff and Defendant have been residents of the Commonwealth of
Pennsylvania at least six months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on May 26, 2001, in Lancaster
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
Respectfully submitted,
IRWIN & McKNIGHT
By:
Marcus . McKD t, III, Esquire
Supreme Court 1.0. No. 25476
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Date: September 7,2006
L__
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
Date: September 7, 2006
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
TARA J. TOMLINSON-FORD,
Defendant.
2006-~?O CIVILTERM
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: September 7, 2006
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - 5270 CIVIL TERM
TARAJ. TOMLINSON-FORD,
Defendant.
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(l)(i)
COMMONWEAL TH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant, Tara
J. Tomlinson-Ford, on September 9,2006, by certified, restricted delivery mail, addressed to her
at 2108 Cedar Run, Apartment 102, Camp Hill, Pennsylvania 17011, with Return Receipt
Number 70033110 0004 5768 1688.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and rrect. I understand that
false statements herein made are subject to the penaltie 18 Pa. . . Section 4904, relating to
unsworn falsification to authorities.
Date: September 12,2006
---
. bomptete Items 1. 2, and 3. Also complete
Item 4 If ~ed Delivery is desired.
. Print your name and eddress on the reverse
so that we can return the card to you.
. Attach this card to the back of the mallplece.
or on the front If space permits.
1. Article Addressed to:
:t
lIS TARA J 'l'OIILIBSOR-FORD }~;
2108 CEDAR RDIf APAR'DIERT 102;1(;
CAMP HILL PA 17011
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2. ArtIcle Number
~~~ 7003 3110 0004 57~a 1688
PS Form 3811. February 2004 00rnIIMk: Aeturri .--...'
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lllARRIAGE SETTLEMENT AGREE~MENT
THIS AGREEMENT made this ~y of September, 2006 by and between TARA J.
TOMLINSON-FORD, of 2108 Cedar Run, Apartment 102, Camp Hill, Cumberland County,
Pennsylvania, 17011 (hereinafter referred to as "WIFE") and JEVON T. FORD, of 3 Sycamore
Drive, Mechanicsburg, Cumberland County, Pennsylvania, (hereinafter referred to as
"HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on May 26, 2001, In
Lancaster, Pennsylvania, The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
a. has the right to be represent by legal counsel of his or her own choosing;
b, is fully and completely informed of the facts relating to the subject
matter of this Agreement and of the rights and liabilities of the parties;
c. enters into this Agreement v()luntarily after having the opportunity to seek the
advice of counsel;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully read each provision of this Agreement; and
f. fully and completely understands each provision of this Agreement,
both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5,
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage,
3
7.
REAL EST A TE: The parties own real estate located at 3 Sycamore Drive,
Mechanicsburg, Pennsylvania 17055. WIFE agrees to convey all right, title and interest in the
real estate to HUSBAND. HUSBAND agrees within one (1) year to refinance the real estate. If
he is unable to do so, he agrees to sell the real estate and payoff the mortgage.
8.
DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely
responsible for her debts. HUSBAND will indemnify and hold harmless WIFE from all
obligation related to his debts, WIFE will be solely responsible and will indemnify and hold
harmless HUSBAND from any claim made against him related to her debts.
HUSBAND agrees to pay Jackie Earl Ford the balance of two (2) loans owed by the
parties totaling the sum of $29,000.00. WIFE agrees to be solely obligated for any loan made by
h~r parents to the parties. This includes the loan of $10,000.00. WIFE agrees to hold
HUSBAND harmless from all obligations for said loan.
9.
SPOUSAL SUPPORT AND ALIMONY: Neither party will provide spousal support
and/or alimony to the other during the marriage or following the divorce.
10.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a, The personal property in his possession including all items
listed as his on Exhibit "A" attached hereto;
b. His bank accounts;
c. Any life insurance policy;
4
d. His employee benefits and/or any other retirement benefits; and
e. Any interest in the personal injury claim from the accident of
December 8,2005,
WIFE shall receive the following items:
a. The personal property in her possession including all items
listed as hers on Exhibit "A" attached hereto;
b. Her bank accounts;
c. Any life insurance policy; and
d. Her employee benefits and/or any other retirement benefits.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried. Each party agrees that neither will incur obligations, liens or liabilities on account of
the other and that from the date of this Agreement, neither party shall contract or Incur
obligations, liens or any liability whatsoever on account of the other.
11.
AUTOMOBILES:
a. HUSBAND agrees to waive any and all interest which he may
have in the 1999 Ford Explorer owned by WIFE.
b. WIFE agrees to waive any and all interest which she may have
in the 2002 Volkswagen Jetta of the HUSBAND.
5
The parties each waive any claim which they have in any automobile owned by the other.
HUSBAND agrees to be solely responsible for his car loan with Chase Automotive.
12.
INSURANCE. EMPLOYEE BENEFITS. AND HEALTH INSURANCE: The
parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other
employee benefits, including but not limited to retirement, profit sharing or medical benefits of
either party, shall be their own. HUSBAND agrees to maintain life insurance for the duration of
the term of alimony payments in an amount not less than the sum of the remaining alimony
payments with WIFE named as primary beneficiary. WIFE waives all right, title and claim to
HUSBAND'S employee benefits, and HUSBAND waives all right, title, and claim to any of
WIFE'S employee benefits,
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he may have in the savings or
checking or any other bank accounts of the WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
6
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
should 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, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party
acknowledges that the Agreement is fair and equitable, and that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence. The provisions of this
Agreement are fully understood by both parties and each party acknowledges that the Agreement
is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence.
18.
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.
7
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
WAIVER OF CLAIMS AGAINST ESTATES: 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 have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in tile property or the estate of the other as a result of the
marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and "each 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 relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
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Marriage Settlement for: Tara Jane Tomlinson-Ford and Jevon Thomas Ford
Compiled: August 15, 2006/ August 18, 2006/September 6, 2006
Tara Item Jevon
Dining Room
Table and Chairs X
Corner Cabinet X
Basket Print X
Invitation Frame X
Marriage Certificate X
X Cow Creamers
X G- Ma T Dish
X Aunt Jemima Cookie Jar
High Chair X
Wine Rack X
G- Ma Hicks China X
X Various Pitchers
X Crystal baskets
Living Room
X Grandfather Clock
3 Piece Leather Furniture X
3 Piece cast iron tables X
X Piano
X Carlson Painting
Mechanicsburg print X
X Girl with flowers print
Wedding album X
Civil war chess set X
X Fish tank
Table lamp X
X Floor lamp
Family Room
X Blue recliner couch
I Tan leather chair X
IX Travel trunk
X V./edding quilt
End table X
Table lamp X
Floor lamp X
Entertainment center X
Wedding picture X
EXHIBIT "A"
Civil war print X
X Reproduction chair
X Wall vases (2)
Office
Desk X
Dell Computer X
Rocking Chair X
Green Room
X Single bed
X Night stand
X Green chest
Wood table X
X Potty chair
Star frame X
X Star light print
Teddv bear hanger X
X Sewing machine
X 2 table lamps
Blue Room
X. Bedroom suite
Bed
Bureau
Night stand
Chest
X Wardrobe
X TV Stand with doors
TV X
Blanket chest X
Oil painting X
X VCR
Master Bedroom
Bedroom suite X
Same as before
X Jewelrv cabinet
Coat rack X
TV and dvdlvcr X
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Kitchen
X Coffee pot
X Expresso machine
Blender X
Mixer X
Microwave X
Toaster X
Breakfast nook X
X Mrs. T Glasses/cake plate
X Foreman Grill
X Foreman Roaster
Outside/Garaee
X Swing
Patio furniture X
X Fountain circle
Fountain square X
Grill X
X Treadmill
X Coke Machine
Lawn tractor X
Lawn mower X
Snow blower X
X Explorer
Jetta X
At Lar~e Items
3 Sycamore Drive - Home X
Jack Ford Loans - Jevon's student loan and other together loan X
X Any loan with Tomlinson's is eliminated or Tara's responsibility
Jetta Loan X
X Talbot Investments go back to each person by name on account - meaning X
Tara gets hers and Jevon gets his
EngagementJWedding Rings X
Scooter X
Ike/Mamie with periodic visitation for Tara - will work out mutually X
suitable schedule
X Fish - Jevon keeps shark and small tank, Tara gets rest offish X
COMMONWEAL TH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ~y Of#rIJ ~, 2006, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
TARA J. TOMLINSON-FORD, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEAl. TH OF PENNSYLVANIA
Nc8IIII 8M
Mar1ha L Noel, Nol8Iy PubIc
CarlIsle Boro, C4.1me.lIl1d Ccuoty
My Canml88lon ExpIres Sept. 18, 2007
Member. Pennsylvania Association Of Not.ri..
. COMMONWEALTH OF PENNSYLVANIA
SS:
subscribed to the within Marriage Settlement Agreement, and acknowledges that he executed the
same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - 5270 CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) and 3301(d) of the Divorce Code was filed on
September 8, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
Date: /:J- /:5 - 0 G
0iWJ-J{/tmlYnolYh - 4rn&~
TARA J OMLINSON-FORD
Defendant
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - 5270 CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2, I understand that I may lose rights concerning alimony, division 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: 1::2 - jj-D to
~ 1~ rh~iJ71 - ~'h~
TARA . OMLINSON-FORD
Defendant
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - 5270 CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) and 3301(d) of the Divorce Code was filed on
September 8, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
Date: J 2 -Cd -OIP
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
JEVON T. FORD,
Plaintiff,
2006 - 5270 CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: 12 - {p -Ow
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JEV T. FOR
Plaintiff
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JEVON T. FORD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION. LAW
2006 - 5270 CIVIL TERM
TARA J. TOMLINSON-FORD,
Defendant.
IN DIVORCE
I'
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) and or (d) of the Divorce Code,
2, Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Tara J. Tomlinson-Ford, on September 9,2006, by certified, restricted delivery mail, addressed to her at 2108
Cedar Run, Apartment 102, Camp Hill, Pennsylvania, 17011, with Return Receipt Number 7003310000045768 1688.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code:
by plaintiff: December 6,2006 by defendant: December 13,2006
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a)
of which is attached:
Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy
(b)
December 13,2006
Date plaintiffs Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary:
Date: December 13, 2006
with the Prothonotary:
December 13,2006
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNA.
STATE OF
JEVON T. FORD..
No. 2006-5270 CIVIL TERM
PLAINTIFF
VERSUS
TARA J. TOMLINSON-FORD,
DEFENDANT
DECREE IN
DIVORCE
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,;';yI. , IT IS ORDERED AND
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AND NOW,
, PLAI NTI FF,
JEVON T. FORD
DECREED THAT
TARA J. TOMLINSON-FORD
, DEFENDANT,
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The Marriage Settlement Agreement dated September 28, 2006, and signed by
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the parties is hereby ~nto this D.1orce Decree, but not merged.
J,
ATTESTa ~
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PROTHONOTARY
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