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HomeMy WebLinkAbout95-02071 .. I. . .. .. . EUGENE P. FARRELL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95 - 2071 CIVIL BONNIE L. FARRELL, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSEN~ 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on April 24, 1995. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a Final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. I have been advised of the availahility of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. llate: 8/7/ q6 I I . Pl:n 11I1 X Jeu ~'(.eil Bonnie L. Farrell Sworn subscribed hefore me day of ^ugust tlOTAI\IAl SEAl SEMIC, Notary Public Clll11fIlilll Bora. Cumbluli\l1\l Counly My Commission E.lplres May 6, 1996 # "b f"::! C) r.) A. ~ F~. l.;:J '-) "I., eo, :tJ... '- ~ ~ {'"//.' 'l'.. .::r-. ;. .:a: ~( ., CI~ ,_ - h -to, '() 'V' -. c.... ','S r.'. . :4,- C. IJ.. .-::'. ,. .:!JIt -,-hj! C\ fb , . ( . ~. ,,-( . . l.t; ('\ .:t! _.r:;~' Co ..l-) ::tj " CJi"/1 ". 'f ~ ,. ..... '0 ~(I -.; . . . . . rOST-NUPTIAL AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this J:1:!/t..day of 1)......- , 1995, by and between Eugene P. Farrell, hereinafter called "Husband", and Bonnie L. Farrell, hereinafter called "Wife". WHEREAS, Husband and Wife were lawfully married on October 17, 1987, in Dauphin County, pennsylvania. WHEREAS, dif ferences have ari.sen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each o~her including, without limitation by specification the settling of all matters between them relating to the ownership and equitable distinction of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife j and in general, the settling of any and all claims and possible 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, Wife and Husband each, intending to be legally bound hereby covenant and agree as follows: ~ SEPARATION AND NON INTERFERENCE It shall be lawful for each party at all times her.eafter to live separate and apart from each other at such place as he or she from time to time shall 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. Each party shall be free from interference, authority and control 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 molest or attempt to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. ~ SUBSEQUENT DIVORCE The parties hereby acknowledge that Husband has filed a Complaint in Divorce in Dauphin County, pennsylvania, to docket number 95-2071 claiming that the marriage is irretrievably brok~n under the no-fault mutual consent provision of Section 3301(c) of the pennsylvania Divorce Code. The parties hereby waive all rights to request Court-ordered counseling under the Divorce Code. The parties agree that they each shall execute Affidavits of Consent on or about July 24, 1995, which shall be filed to the hereinabove stated docket by counsel for Husband along with a praecipe to Transmit the Record in order that a Decree in Divorce incorporating the herein agreement, but not merged, may be issued in due course. Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, . 2 . l." ,'.J,..."..Jr'!I'\~.;"",!!.~r,W\""II:.'..~r.!4... . . 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, shall be incorporated by reference into any divorce, judgment or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. ENFORCEMENT Husband and Wife herecy acknowledge that the Dauphin County Court of Common Pleas currently has jurisdiction over the parties and authority to enforce this agreement pursuant to the Divorce Code of 1980 and Amendments thereto. ~ WAIVER OF SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE/ COUNSEL FEES, COSTS AND ~XPENSES Husband and Wife hereby acknowledge that they have been advised that each may have the right to assert a claim for spousal support, alimony, alimony pendent lite, counsel fees, costs and/or expenses. Further, Husband and Wife acknowledge that they understand that said rights are available in this action. Nevertheless, Husband and Wife hereby knowingly forever waive and relinquiSh any right they may each have to assert a claim now or in 1 I .. 3 '....~'"';"...."t,,(l.w~.t':;: .. . . the future for spousal support, alimony, alimony pendente lite, counsel fees, costs and expenses. The parties agree that they are waiving any and all claims againsc the other under the Divorce Code of the Commonwealth of Pennsylvania including claims for alimony, alimony pendente lite, counsel fees, costs, and/or expenses. Each party further agrees that they waive against the other any claims relating to any pension or profit sharing plans through their respective employers. Each party agrees to sign, upon the execution of this Agreement, consents to divorce which will be promptly filed by Husband's attorney in the Court of Common Pleas, Dauphin County, Pennsylvania, docket number 95-2071 in order to secure the entry of a decree in divorce. ~ EOUITABLE DISTRIBUTION OF PROPERTY A. 1028 Hemlock Lane. Enola. Cumberland County. Pennsylvania The parties hereto mutually covenant and agree that the real estate they own jointly, as tenants by the entireties, and being known and numbered as 1028 Hemlock Lane, Enola, Cumberland County, Pennsylvania, was listed with Century 21, Piscioneri Realtor, Sue A. Redmond, Realtor. An Agreement for Sale and Purchase of said real estate was approved by the parties on May 4, 1995, in the amount of One Hundred Twenty One Thousand Six Hundred ($121,600.00) Dol.lars and zero cents; said purchasers being William J. and Lauri A. LaFoe. Settlement is scheduled to take place on June 30, 1995. The parties agree that the proceeds of the sale of said real estate, after the payment of the expenses associated Io!ith said 4 . . sale, to include a reasonable realtor's commission, shall be applied to pay the mortgage on the property and to pay any and all other liens or. encumbrances of record so as to give and deliver a good and marketable title at the time of settlement. At the time of settlement, the net proceeds payable to the parties shall be paid as follows: 1. Wife shall receive one check made payable to her in an amount equal to BO\ of the net proceeds; 2. Husband shall receive one check made payable to him in the amount of 20\ of the net proceeds; B. Payment from Husband to Wife In exchange for the parties mutual waivers and releases as defined within this agreement and the distribution of assets as defined herein, Husband shall issue to Wife at the time of settlement as described hereinabove (June 30, 1995) a check made payable to Wife in the amount of One Thousand Two Hundred ($1,200.00) Dollars and no cents. Husband and Wife hereby acknowledge that the wife had agreed to provide One Thousand ($1,000.00) Dollars and no cents towards Buyers' closing costs. This amount shall be considered and included as part of Husband's total cash payment to Wife. C. Understandinq It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as con~emplated 5 ,.lh:,;<l'.....t~~.....J,..:.I.',;-, , . by the Pennsylvania Divorce Code. ~ WAIVER OF MARITAL AND NON-MARITAL ASSETS Husband and Wife do hereby acknowledge that they have heretofore divided their respective non-marital assets and marital assets, including but without limitation, business interests, jewelry, clothes, brokerage accounts, stocks, hands, life insurance policies or other securities, Individual Retirement Accounts, checking and savings accounts, mutual funds, 401K plans, profit sharing plans and other assets whether real, personal or mixed, tangible or intangible. Husband and Wife further acknowledge and agree that the assets in the possession of the other spouse shall be that spouses sole and separate property, each party hereto specifically waiving, releasing, renouncing and forever abandoning whatever claim, if any, he or she may have with respect to any of the foregoing items which are the sole and separate property of the other. This Agreement is intended to distribute all property of the parties, whether real or personal, and whether determined to be separate or marital property. In the event that any property may be omitted from this Agreement, it is understood and agreed that the person having possession and/or title to such property following the execution of this Agreement shall be deemed the owner thereof and each of the parties will execute any and all legal documents without any charge therefor to evidence title to such property in the other party. ~ TRANSFER OF PERSONAL PROPERTY 6 '''': ,'.:,~itbii~~.,',..-_...-.. " , . Subject to those items which are listed hereinbelow in Appendix A, each party hereby assigns, conveys and transfers all of his or her right, title and interest in and to any and all furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art, and any other items of tangible personal property of whatever nature which are presently in the possession of the other. ~ AUTOMOBILES Husband hereby agrees to assign and convey to Wife any and all right, title and interest he may have to the 1993 Eagle Summit titled in Wife's name. Husband shall execute any and all documents necessary to transfer ownership of said vehicle to Wife. Wife agrees to be solely responsible for all loan payments to Loyola Federal, all insurance(s), taxes and registration fees on said vehicle. Wife further agrees to indemnify and hold Husband harmless with respect to all items as herein stated related to said vehicle from the date of separation. Wife hereby agrees to assign and convey to Husband any and all right, title and interest she may have to Husband's 1995 Chevrolet Tahoe. Wife shall execute any and all documents necessary to transfer ownership of said vehicle to Husband. Husband agrees to be solely responsible for all payments to GMAC, insurance (s), taxes and registration fees on said vehicle. Husband further agrees to indemnify and hold Wife harmless with respect to all items as herein stated related to said vehicle from the date of separation. 7 i,\~'>>'~l\:).'.'-' . ' wife hereby agrees to assign and convey to Husband any and all right, tiLle and interest she may have to the parties' 1993 Terry Resort, serial number 1EB1Y3224P1457541. Wife shall execute any and all documents necessary to transfer ownership of said vehicle to lIusband. Husband agrees to be solely responsible for all payments to Fleetwood Credit Corp., Account Number 02608501409, insurance(s), taxes and registration fees on said vehicle. Husband further agrees to indemnify and hold Wife harmless with respect to all items as herein stated related to said vehicle from the date of separation. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the date of execution of this Agreement and said executed titles shall be delivered to the proper party on the distribution date provided for in this Agreement. In the event that either or all of the documents of title to the said vehicles shall be in the hands of a bank or other holder of a lien or encumbrance upon said vehicle, the parties agree to advise such bank or holder as to the transfer of title set forth herein and they further agree to execute whatever documents may be required to transfer title where said document(s) of title are in the hands of such bank or holder. ~ PENSION BENEFITS (1) The \~ife waives any and all rights which she may have to any of the Husband's vested or non-vested interest which he may have in pension plans including, but not limited to, defined benefit plans, defined contribution plans, 401K plans, and deferred B . ;1 ,-.',~I.(.~.H\t'f^~' ~-... ,~. . .' compensation plans. The Wife agrees to execute any documents necessary to effectuate the aforementioned waiver. (2) The Husband waives any and all rights which he may have to any of the Wife's vested or non-vested interest which she may have in pension plans including, but not limited to, defined benefit plans, defined contribution plans, 401K plans, and deferred compensation plans. The Husband agrees to execute any documents necessary to effectuate the aforementioned waiver. 2... DEBTS Vehicles Husband and Wife hereby acknowledge and agree that Husband reaffirms that he shall be solely responsible for the debts presently due and owing as defined hereinabove in Clause seven (7) indemnifying and holding Wife harmless thereon. Husband and Wife hereby acknowledge and agree that Wife reaffirms that she shall be solely responsible for the debts presently due and owing as defined hereinabove in Clause seven (7) indemnifying and holding Husband harmless thereon. Wife's Debts Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and 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. Further, Wife hereby agrees to be solely responsible for all debt associated with her ~evolving 9 . ..'1.,', J~I"".'~...,;.)f.i~A-.,. . ., credit with Visa, Boscov's, and any other such credit, indemnifying and holding Husband harmless thereon. Husband's Debts Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and 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. Further, Husband hereby agrees to be solely responsible (or all debt associated with his credit card accounts, and any other such credit, indenmifying and holding Wife harmless thereon. All debts, contracts, obligations or liabilities incurred at any time in the past or future by either of the parties will be paid promptly by said party, unless and except as otherwise specifically set forth in this Agreement; and each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified and saved harmless from all debts or liabilities incurred by him or her, as the case may be, and from all actions, claims and demands whatsoever with respect thereto and from all costs, legal or otherwise, and counsel fees whatsoever appertaining to such actions, claims and demands. Neither party shall, after the date of this Agreement, contract or incur any debt or liability for which the other or his or her property might be responsible and shall indemnify and save harmless the other from 10 ,. ,~.1,~~~"'_~'st;.tAi.(;.'!.'.,' I" (, ' r' t,' . b t, I' ('.' I. '. . ,: I ;'IJ :" ,',', 1 I' : ,{, ! : ~ h, i,' ~ ! , I . " 1'1 ;,'j I,;,' ' ,. , ji'j ",'l i': t~I' I' : , I; I , :,i I '\ , ., any and all claims or demands made against her or him by reason of debts or obligations incurred by her or him and from all costs, legal costs and counsel fees unless provided to the contrary herein. ~ TAX ON PROPERTY DIVISION Husband hereby agrees to pay all income taxes assessed against him, if any, as a result of the division of the property of the parties hereunder. \1ife hereby agrees to pay all income taxes assessed against her, if any, as a result of the division of the property of the parties hereunder. The parties hereby acknowledge and agree that in accordance with the division of the net proceeds from the sale of 102B Hemlock Lane, Enola, Pennsylvania, as hereinabove defined under Clause four (4), Equitable Distribution, Wife shall be responsible for and declare for tax reporting purposes eighty (BO%) percent of the capital gains on said sale while Husband shall be responsible for and declare for tax reporting purposes twenty (20%) percent of said gain. By this agreement, the parties have intended to effectuate and, by this Agreement, have equally divided their marital property. The parties have determined that such equal division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property has not, except as may be otherwise expressly provided herein, been intended by the parties to constitute in any way a sale or exchange of assets and the division is being effected without the intrpduction 11 .;14'-h!lr>\o,'.i.'~~.::ft"-,,,,: . '. , " of outside funds or other property not constituting a part of the marital estate. As part of the equal division of the marital properties and the marital settlement herein contained, the parties hereby agree to save and hold each other harmless from all income taxes assessed against the other resulting from the division of the property as herein provided. Husband and Wife do hereby specifically agree and elect to apply the provisions of the 1984 Domestic Relations Tax Reform Act, as amended, with respect to the creation of a taxable event. Husband and Wife specifically ugree that none of the provisions of the within Agreement shall constitute a taxable event as set forth in the 1984 Domestic Relations Tax Reform Act, and amendments thereto. The parties hereto have filed Joint Federal, State and Local income tax returns for tax year 1994, and agree to file separate tax returns for tax year 1995 and every year thereafter. 11. FULL DISCLOSURE The parties acknowledge that they have been fUlly advised and informed of the property and the estate of the other and the value thereof, or has knowingly waived such advice and/or information, and the parties hereto have been fully advised and informed of all rights and interests which, except for the execution and delivery hereof, have been conferred upon or vested in each of them by law with respect to the property or estate of the other by reason of their marital status, or has knowingly refused or waived such advice or information. 12 .. '" :; . ;1 ~.- , " , " ':J,..,,,:'t~4~;~~"'d;, i . ., . . . . . '. . ~ RECONCILIATION This Agreement shall not be deemed to have been waived, extinguished, discharged, terminated, invalidated or otherwise affected by a reconcil iation between the parties hereto, cohabitation between the parties, a living-together or resumption I of marital relations between them. They shall not be deemed to have reconciled with the intention of vitiating or terminating this Agreement unless they make such actions through a written instrument. executed and acknowledged in the same manner as this ,.. I'. t: Agreement. h.L. 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. The party breaching this contract shall be responsible for the payment of legal fees an costs incurred by the other in enforcing his or her rights under this Agreement. or seeking such other remedy or relief as may be available to him or her. ~ ADDITIONAL INSTRUMENT Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignment. consents to change of beneficiary on insurance policies, tax returns, consents to a divorce under section 3301 (c) of the Divorce Code and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. If either party fails on demand to co~ply with 13 _"i-.'=-t..:d~.~I.:~fu... ' . " , '. . , .. . this provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonable incurred as a result of such failure. ~ WAIVERS 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 the property or the estate of the other as a result of the mari tal relationship, including wi thout I imi tation, dower, curtesy, 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, to 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. ~ REPRESENTATION It is recognized by the parties hereto that Husband is represented by James A. Miller, Esquire and Wife is represented by Linda A. Clotfelter, Esquire. It is fully understood and agreed that the parties have the right to have advice of counsel prior to the signing of this Agreement. By the signing of this Agreement, the parties recognize that he/she fully understands the legal impact of this Agreement and waives his/her right to have the Agreement reviewed by an attorney of his/her choosing, an4 further 14 . '-'.i:.'M\",~ :"~1f'~Jr,~I'J;,~...I".;'-I" . . .' . . . . ' . ... . intends to be legally bound by the terms of this Agreement. ~ VOLUNTARY EXECUTION The provisions of this Agreement are f~lly understood by both parties and each party acknowledges that this 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. ~ 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. ~ PRIOR AGREEMENT 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. ~ MODIFICATION AND WAIVER Any modification or waiver of any provision 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. ~ GOVERNING LAW This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of pennsylvania. ~ INDEPENDENT SEPARATE COVENANTS It is specifically understood and agreed by and between the . 15 .. . . . .' .. . ~ ... ' parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or ,. I ! , I. ~ VOID CLAUSES 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. ~ DISTRIBUTION DATE The parties hereto acknowledge and agree that for purposes of distribution of property as provided for in this agreement, the date of execution of this agreement shall be known as the Distribution Date. ~ DATE OF EXECUTION The parties hereto acknowledge and agree that the date of execution referred to herein shall be known as the last date upon which either party executes this agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. ~NESS: ~ /'/ ?'~l~ C~ .! -~__ ( 'fl~{V O. U#:fr~Ut~ EU~.~~~l ~f}I/ ~ ~Ott))}zPO€.. onnie L -: arrell 16 ".\.~~;.~',i".'''~,~, BUGBNB P. FARRELL, . IN THB COURT OF COMMON PLEAS . Plaintiff CUMBBRLAND COUNTY, PENNSYLVANIA . . v. . NO. 95 - 2071 CIVIL . BONNIB L. FARRELL, . CIVIL ACTION - LAW . Defendant . IN DIVORCE . 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 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: a CERTIFIED COpy OF THE COMPLAINT IN DIVORCE dated April 24, 1995, was served on Defendant's Counsel on May 1, 1995, by United States First Class mail. 3. Section by by Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: Plaintiff: August 5, 1995 Defendant: August 7, 1995 4. Related claims pending: pending. There are no related claims Respectfully SUbmitted, , \ C "--____.. I -'I~' /// By: ....i- \ . James A. Miller, Esquire Attorney for Plaintiff 122 Locust Street Suite 100 Harrisburg, PA 17101 (717) 236-5161 EUGBNE P. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . ( lit/'\J{I..-/./ . v. NO. ~)!,'- ,,:lei 71 : BONNIE L. FARRELL, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims Bet forth in the following papers, 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 the 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 Court House, North Hanover Street, 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 Lawyer Referral Service Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17101 Phone: (717) 697-0371 //rAL-1. fk- /Jam~~n:,;/ Miller, Esquire (. A:~/ for Plaintiff . . " . EUGENE P. FARRELL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. BONNIE L. FARRELL, Defendant CIVIL ACTION - LAW IN DIVORCE COUNT I COMPLAINT UNDER SECTION 330llcl OF THE DIVORCE CODE 1. Plaintiff is Eugene P. Farrell, who currently resides at 1028 Hemlock La~e, Enola, Cumberland County, Pennsylvania. 2. Defendant is Bonnie L. Farrell, who currently resides at 1028 Hemlock Lane, Enola, Cumberland 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 October 17, 1987, in Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United states of America. 7. The Defendant is not member of the Armed Services of the United States of America. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. .- ~ (;) ~ tli\ "" :: ... -, l~ :-., "" ~ 0, ~\J::J (-.'.1 r:5 -1 - .' 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