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HomeMy WebLinkAbout02-4767JACQUELYN L. TAYLOR, : Plaintiff, : V. : DAVID H. TAYLOR, : Defendant. : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 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 annulmen; 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, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 JACQUELYN L. TAYLOR, : Plaintiff, : V. : : DAVID H. TAYLOR, : Defendant. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notifcacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o propiedad u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 JACQUELYN L. TAYLOR, Plaintiff, V. DAVID H. TAYLOR, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Jacquelyn L. Taylor, by and through her counsel, Killian & Gephart, who represents as follows: 1. Plaintiff, JACQUELYN L. TAYLOR, is an adult individual, who currently resides in Cumberland County, Pennsylvania, and is receiving mail at P. O. Box 515, Harrisburg, PA 17108-0515. Her date ofbirthis August 12, 1954; and her Social Security Number is 182-46-4576. 2. Defendant, DAVID H. TAYLOR, is an adult individual who currently resides at 333 North 29th Street, Camp Hill, Cumberland County, Pennsylvania 17011. His date of birth is September 2, 1954; and his Social Security Number is 174-46-6102. 3. Plaintiff avers that she has been a bonafide resident in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 15, 1999, in Mechanicsburg, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of 18. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There have been no other prior actions of divorce or annulment filed by either of the parties hereto. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 9. The marriage is irretrievably broken. COUNT ONE--CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY I0. The averments of Paragraphs 1 through 9 are hereby incorporated by reference thereto. 11. The Plaintiffand Defendant are the owners of various items of property acquired during their marriage which are subject to equitable distribution by this Court. 2 Dated: hereto; and C. and just. WHEREFORE, the Plaintiff requests the Court enter a Decree: Dissolving the marriage between Plaintiff and Defendant; Equitably distributing all marital property owned by the parties September 27, 2002 Granting such further relief as the Court may determine equitable Respectfully submitted, KILLIAN & GEPHART P.O. Box 886 Harrisburg, PA 17108 (717) 232-1851 Attorney I.D. #53148 Attorneys for Plaintiff 3 VERIFICATION I hereby verify that the statements of fact made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S.A. §4904, relating to unswom falsification to authorities. Dated: 09/27/02 JACQUELYN L. TAYLOR, Plaintiff, DAVID H. TAYLOR, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4767 Civil CIVIL ACTION - LAW IN DIVORCE PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT made this ] rl q Jo day of ~ .2003, by and between DAVID H. TAYLOR, of 333 North 29th Street, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Husband"), and JACQUELYN L. TAYLOR, who currently resides in Cumberland County~, Pennsylvania, and is receiving mail at P. O. Box 515, Harrisburg, PA 17108-0515 (hereinafter referred to as "Wife"), WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 15, 1999; and WHEREAS, no children have been conceived of this marriage; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they have been separate and apart from each other; and NOW THEREFORE, the parties intending to be legally bound hereby covenant and agree: DATE: 06/10/03 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing 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. 2. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date of separation of May 1, 2002, 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 incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the date of separation of May 1, 2002, 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 DATE: 06/I0/03 2 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. 5. OUTSTANDING JOINT DEBTS: All other debts, contracts, obligations or liabilities incurred at any time in the past 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 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. 6. 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, DATE: 06/10/03 3 whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for termination of the marriage by divorce or annulment and except for all causes of action for breach of any provisions of this Agreement. Husband and Wife specifically release and waive any and all rights he or she might have to raise claims under the Divorce Code and any amendments thereto including, but not limited to claims for equitable distribution of marital property, support, alimony, alimony pendente lite, counsel fees or expenses. The parties agree that the moving party in any divorce action which has been or which will be commenced shall request the Court to incorporate, but not merge, this Agreement into any divorce decree. If this Agreement is incorporated into a divorce decree, the parties shall have the right to enforce this Agreement under the Divorce Code and any amendments thereto in addition to any remedies in law or equity and these enforcement rights are not waived or released by any of the provisions of this Agreement. The fact that a party brings an action to enforce the property agreement as incorporated in the divorce decree does not give either party the right to raise other claims under the Divorce Code specifically waived and released by this paragraph, and all rights and obligations of the parties arising out of the marriage shall be determined by this Agreement. 7. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and DATE: 06/10/03 4 furnishings, and all other articles of personal property which have theretofore been used by them in common, and neither party will make any claim to any such items which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. 8. EACH PARTY RETAINS OWN PENSION PLANS: Each of the parties does specifically waive, release, renounce and forever abandon all of his or her right, title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee benefit plan of the other party, whether acquired through said party's employment or otherwise, and hereafter said Pension Plan, Retirement Plan, Savings Plan, Tax Deferred Savings Plan and/or any employee benefit plan shall become the sole and separate property of the party in whose name or through whose employment said plan is carried. 9. LUMP SUM PAYMENT TO WIFE: Husband agrees that he shall, within sixty (60) days of the signing of this Agreement, pay Wife a lump sum in the amount of TWO THOUSAND TWO HUNDRED FORTY ($2,240.00) DOLLARS. 10. SPOUSAL SUPPORT: Wife agrees that Husband's obligation to pay spousal support shall terminate as of the date that both parties have signed and notarized DATE: 06/10/03 5 this Agreement. Wife agrees that she shall direct her counsel to forward a copy of this Agreement to the Domestic Relations Office promptly upon receipt of an executed Agreement, with instructions to terminate Husband's support obligation towards Wife. 11. 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 marital relationship, including without limitation, 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, 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. 12. SUBSEQUENT DIVORCE: Both parties agree to execute Affidavits of Consent to Divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree pursuant to Section 3301(c) of the Divorce Code contemporaneous with the signing of this Agreement and shall direct their respective counsel to immediately file with the Court said documents. Wife agrees that she shall direct her counsel to DATE: 06/10/03 6 immediately file with the Court a Decree in Divorce from the bonds of matrimony under Section 3301(c) of the Divorce Code. 13. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 14. 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. 15. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Wife has employed and had the benefit of counsel of J. Paul Helvy, Esquire, as her attorney. The Husband has employed and had the benefit of counsel of G. Patrick O'Connor, Esquire, as his attorney. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection and that each fully understands the facts and has been fully informed as to his or her legal fights and obligations, and each party acknowledges and accepts that this Agreement is, under the DATE: 06/10/03 7 circumstances, 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. Also, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the Court has the right and duty to determine all marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and being fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties and waives their respective right to have the Court of Common Pleas of Cumberland County or any other Court of competent jurisdiction to make any determination or order affecting the respective parties' right to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 16. ENTIREAGREEMENT: 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. 8 DATE: 06/10/03 17. MODIFICATION AND WAIVER: A 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. 18. INDEPENDENT SEPARATE COVENANTS: 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. 19. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Permsylvania. 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 21. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 9 DATE: 06/10/03 IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. WITNE S S: DAVID H. TAYLOR EL~N L. ~FAYL~R 10 DATE: 06/10/03 COMMONWEALTH OF PENNSYLVANIA ) ) SS.: COUNTY OF ~,F/'v'/Xg~/''O~v'~ ) On this the /~ r~day of ~_~,.a._.. ,2003, before me, the undersigned officer, personally appeared DAVID H. TAYLOR, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarj, al seal. My Commission Expires: COMMONWEALTH OF pENNSYLVANIA ) ) SS.: COUNTY OF D o, 0 ~h; ~ ) J' ' NOTARIAL SEAL WILLIAM L. GRUBEI, Nola~ Pul~ Lower Allen Twp., Curceerland County My Commission E~ Aug. 13, 2005 On this the r/~ch day of ~~ ,2003, before me, the undersigned officer, personally appeared JACQUELYN L. TAYLOR, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. 1N WITNESS WHEREOF, I have hereunto set my hand and notarial seal. My Commission Expires: DATE: 06/10/03 11 Notarial Seat Patflcia L. Eismann, Notary Public Harrisburg, Dauphin County My Commission Expires Nov. 8, 2003 JACQUELYN L. TAYLOR, Plaintiff, V. DAVID H. TAYLOR, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 024767 Civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, DAVID H. TAYLOR, Defendant herein, do hereby swear and affirm that I accepted service of a tree and correct copy of the Complaint in Divorce on '~'~ ~_~_ ~ ,2002. David H. Taylor/ JACQUELYN L. TAYLOR, : Plaintiff, : .. V. : : DAVID H. TAYLOR, : Defendant. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4767 Civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 09/30/02. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Com- plaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: 06/17/03 JACQUELYN L. TAYLOR, : Plaintiff, : : V. : : DAVID H. TAYLOR, : Defendant. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4767 Civil CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(c~ OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. o 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.A. Section 4904 relating to unsworn falsification to authorities. Dated: 06/17/03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JACQUELYN L. TAYLOR, Plaintiff VS. DAVID H. TAYLOR, Defendant NO. 02-4767 Civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 30, 2002. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JACQUELYN L. TAYLOR, Plaintiff VS. DAVID H. TAYLOR, Defendant NO. 02-4767 Civil CIVIL ACTION - LAW 1N 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 ifI 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 the foregoing are tree 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.~ / 3/,.10,~$ DAVID H. TAYLORffDefendant JACQUELYN L. TAYLOR, Plaintiff, Vo DAVID H. TAYLOR, : Defendant. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4767 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date of service of the Complaint: October 5, 2002, as evidenced by the Affidavit of Acceptance of Service, which is being filed contemporaneously herewith. 3. Date of execution of the Affidavits of Consent required by Section 3301(c) of the Divorce Code: by Jacquelyn L. Taylor, Plaintiff, on June 17, 2003; by David H. Taylor, Defendant, on June 13, 2003; which are being filed contemporaneously herewith. Related claims pending: The attached Property Settlement Agreement is incorporated but not merged to the Decree in Divorce. Date of execution of Waivers of Notice of Intention to Request Entry of a Divorce Decree: by Plaintiff on June 17, 2003; by Defendant on June 13, 2003. Said Waivers are being filed contemporaneously herewith. Dated: June 18, 2003 Respectfully submitted, Harrisburg, PA 17108 (717) 232-1851 Attorney I. D. #53148 Attorneys for Plaintiff CERTIFICATE OF SERVICE I do certify that I served a true and correct copy of the within Praecipe to Transmit Record and related documents upon the following by depositing a copy of same in the United States mail, postage prepaid, addressed as follows: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 Dated: June 18, 2003 Peggy Hile, Secretary to J. PAUL HELVY, ESQUIRE Killian & Gephart, LLP 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY  PENNA. STATE OF ~ JACQUELYN L. TAYLOR Plaintiff VERSUS DAVID H. TAYLOR Defendant NO. 02-4767 CIVIL DECREE IN DIVORCE DECReed ThAT JACQUELYN L. TAYLOR 2003 , IT IS ORDERED AND , PLAINTIFF, AND DAVID H. TAYLOR , DEFENDaNt, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HaVE BEEN RAISED Of RECORD IN ThIS ACTION FOR WHICH A FINAL ORDER HAS NOT YeT been ENTEreD; The attached Property Settlement Agreement is incorporated but not merged to the Decree in Divorce. BY THE I ATTEST:~ PROTHONOTARY