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HomeMy WebLinkAbout96-02207 ., " \ I I ! '\ 'I I , , -' ,/ ,.-1' , , i I i " I I I j " 1 I j I I I ~ J t"- O '1 / ~ '" , ~I ./ ~! I ~" . \ " " " 'i. r 'J) 'I,'j " " " " ~<t:.1f. "~J co/'t ,,;:,kz.;;if "~h '6' (' /t :1t~ .c:-,'tr.:Jv-t- ~. oC 4 SITTLKMBNT AGRIIMlNT THIS AGRIKMBNT, made this ,'~ VII.. day of JltJ"" 1996, between Marilyn S. Galardini, hereinafter referred to as "WIFE" and Robert G. Galardini, hereinafter referred to as "HUSBAND" . WITNlSSBTH I WHIREAS, Husband and Wife were lawfully married on June 8, 1974 in Allegheny County, Pennsylvania; and WHIRIAS, two (2) children were born of this marriage: Nicholas C, Galardini born July 28, 1978 and Anthony G. Galardini born ~uly 28, 1978. WHIREAS, disputes and difficulties have arisen between the parties, and it is the present intention of Husband and Wife to live separate and apart, and the parties hereto are desirous of settling their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the past, present, and future support and/or maintenance of Wife by Husband or Husband by Wife; the settling of all matters between them relating to the equitable division of marital property; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates; and WHBRIAS, Husband and Wife declare that each has had a full and ) '\ " I, I .: " "I " , t fair opportunity to obtain independent legal advice of counsel of his or her selection; that Wife has been independently represented by counsel, Linda A. Clotfelter, Esquire, and that Husband has been ,. ~ '! Ii\ Ii', . '-~'........ I'. . .. ... informed that he has the right to seek independent legal counsel, but he has decided not to do so. The parties represent and warrant that they have fully disclosed to each other all assets of any nature owned by each, all debts or obligations for which the other party may be liable in whole or part, and all sources and amounts of income. The parties acknowledge that they fully understand the facts, and they acknowledge and accept that this Agreement is, in these circumstances, fair and equitable, and that it is being entered into freely and voluntarily, 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 improper or illegal agreement or agreements. 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, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. PERSONAL RIGHTS. It shall be lawful for each Husband and Wife at all times hereafter to live separate and apart from the other party at such place as hp. or she may from time to time choose or deem fit. The part.ies shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried, except .. may be necessary to carry out the provisions of this Agreemen,t. Each may, for his or her separate use or benef it, conduct, C.Tory on . :2 ,I " " 04 .. and engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wi fe shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means in any manner whatsoever with him or her, 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. 2. MUTUAl, RIlLIlASIl, Husband and wife each do hereby mutually remise, release, quitclaim and forever discharge the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (!.ncluding income and gains from property hereinafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former act, contracts, engagements or liabilities of such other or by way of dower or curtesy; or claims in the nature of dower or curtesy or widow's or widower's rights, family exception or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a survi ving spo'Jse to part icipate in a deceased spouse's estate, whether arising unde. the law of Pennsylvania, any state, commonwealth or territory of the United States, or any other 3 .. .. country, or the right to act as personal representativt: of the estate of the other; or any rights which any party may now have or any time hereafter have for past, present, future support, maintenance, alimony, Cllimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise; except all rights and agreements and obligations of whatsoever nature arising or which may aris,e under this Agreement or for breach of any provision hereof. It is the intention of Husband and Wife to give to each other, by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever' nature arising or which may arise under this Agreement or for the breach of any provision hereof. It is further specifically understood and agreed by and between the parties hereto that each accepts the provisions herein made by the other in lieu of and in full settlement and satisfaction of any and all of their rights against the other or any past, present and future claJ.ms on account of support and maintenance; that it is specifically understood and agreed that the payments, transfers and other considerations herein recited so comprehend and discharge any and all such claims by each other against the other, and are, inter alia, in full settlement and satisfaction and in lieu of their past, present and future claims against the other on account of maintenance and support, and also 4 .. 0( alimony, alimony pendente lite, counsel fees, costs and expenses, as well as any and all claims to equitable distribut ion of property, both real and personal, and any other charge of any nature whatsoever pertaining to any divorce proceedings which may have been or may be instituted in any court in the Commonwealth of Pennsylvania or any other jurisdiction, including any other counsel , , I: r: r fees, costs and expenses incurred or to be charged by any counsel arising in any manner whatsoever, except as may be incurred in connection with a breach of the Agreement as set forth hereinafter in paragraph 23, 3. mBASI OF TISTAMBNTARY CLAIMi..,. Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by last will and testament or otherwise, and each of them agrees that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would have become entitled thereto as if the decedent had been the last to die. Except as set forth herein, this provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's estate whatsoever, and is intended to confer third-party beneficiary rights upon the other heirs and beneficiaries of each. Either party may, however, make such provision for the other as he or she may desire in an by his or her last will and testament; and each of the parties further covenants and agrees that he or she will permit any .....ill of the other to be probated aud allowed administration; and that neither Husband nor Wife will claim against or contest the 5 ~ ., will and estate of the other except as necessary to enforce any breach by the decedent of any provision of this Agreement, Each of the parties hereby releases, relinquishes and waives any and all rights to act as personal representative of the other party's estate. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, for the purpose of enforcing any of the rights relinquished under this Agreement. 4. rXNANCIAL DISCLOSURE. The parties waiva their rights to require the filing of financial statements by the other, although the parties have be~n advised by their respective attorneys that it is their legal right to have these disclosures made prior to entering into this Agreement and by entering into this Agreement without reliance upon financial disclosure, thO! parties are forever waiving their right to request or use that as a basis to overturn this Agreement or any part thereof. 5. INCOME TAX CONSIDERATIONS. The transfers of property pursuant to this Agreement are transfers between Husband and Wife incident to their divorce and as such are nontaxable, with no gain or loss recognized. The transferee's basis in the property shall be the adjusted basis of the transferor immediately before the transfer. The transfers herein are an equal division of marital property for full and adequate consideration and as such will not result in any gift tax liability. 6 .I 6. IQ..UITABLB DISTRIBUTION OF MARITAL PROPBRTY. The part.ies have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that it is the first marriage for Husband and Wife; the age, health. station, amount and sources of income, vocational skills, employability. estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for further acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation. depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established d1lring the marriage; and the economic circumstances of each party at the t.ime the division of the property is to become effective. 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 marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties, 7 .. ., 7. REAL ISTATB. The parties acknowledge that they are the joint owners of the marital residence situate at 209 Lamp Post Lane, Camp Hill, Pennsylvania. The parties agree that the marital residence shall be sold. The proceeds of the sale shall first be applied to discharge all existing liens on the property, with any remainder being divided as follows: Wife shall receive Seventy- Five percent (75\) and Husband shall receive Twenty-Five percent (25\). Said funds shall be paid to each party at the real estate settlement for the property by each party receiving an escrow check in his or her individual name. 8. PBNSION. PROFIT-SHARING. RETIRIMBNT. CREDIT UNION OR 2nlJ!lR BMPLOYMBNT-RIlLATED PLANEL.. The parties hereto expressly wai ve and relinquish any right, claim, title or interest in any pension, profit-sharing, retirement, credit union or other employment- related plans in which the other has any interest by virtue of his or her past or present employment, whether vested or unvested, matured or unmatured. 9. MOTOR VEHICLES. The parties agree that the 1990 Chrysler Lebaron Convertible shall be sold, and Wife shall become full and sole owner of the 1989 Chrysler New Yorker. The parties further agree that they shall execute in a timely manner, the titlea to said vehicles, if appropriate. .10 . DISTRIBUTION OF HOUSEHOLD and PBRSONAL PROPBRTY. The parties hereto mutually agree that they have effected a satisfactory divi!1ion of the furniture. household furnishings, appliances, and other household personal property bet.ween them, and 8 -. . they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession, and this Agreement shall have the effect of an assigned or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of each party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the par.ty at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party, From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to their separate property and any property which is in their p088e8~ion or, control, pursuant to this Agreement, and may mortgage, 8ell, grant, convey, or otherwise encumber or dispose of such property, 9 . real or personal, whether such property was acquired before, during, or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgager or other instrument of the other pertaining to such disposition of property. 11 . DBSTS. 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 he shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of such debtor obligation incurred by him since the date of said separation, except as otherwise set forth herein. wife represents and warrants to Husband t.hat 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 she shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as other wise set forth herein. Husband hereby assumes and shall be solely responsible and liable for the payment of the following obligations: a. Visa (2) b. Chevy Chase c, Mellon Bank d. Sears e. Discover f. Boscovs g, PNC Loan h. JCPenney Husband shall immediately upon execution of t.his Agreement take such steps as are necessary to transfer ownership of the said accounts and obligation to his name solely, obtaining a full, complete and general release of Wife from the said creditors, In 10 , the event that the creditors refuse for any reason to transfer the charge accounts to Husband's name absolutely and to release Wife from any liability thereon, such accounts shall be immediately closed, Wife hereby assumes and shall be solely responsible and liable for the payment of the following obligations: a. Bon Ton b, Hecht's c, Kaufmann's d. Washer loan e. Cellular telephone bills (2) Wife shall immediately upon execution of this Agreement take such steps as are necessary to transfer ownership of the said accounts and obligations to her name solely, obtaining a full, complete and general relp.ase of Husband from the said creditors. In the event that the creditors refuse for any reason to transfer the charge accounts to Wife's name absolutely and to release Husband from any liability thereon, such accounts shall be immediately closed, 12. COLLEGI EXPENSES. The parties each shall contribute to the expenses associated with the college or other post-high school education for the children of the parties, subject to the provisions hereinafter set forth. Such expenses shall include, without limi tat ion , tuition, room and board, lab fees, miscellaneous student fees, books, and student supplies, transportation expenses for summers and other school breaks, clothing, miscellaneous spending money, and summer living expenses. Each party shall make payment of his or. her share of such expenses on or before the due date for such payments or wi thin ten (10) days 11 . -.......... , " of receiving the notice fr0m the other party of the amount of such expenses. Both parents shall be involved in and have input into the choice of academic institutions selected by the children. Further, the children will be required to apply for and to use all possible grants, scholarships and work-study programs and any of their own income or assets before the parties are responsible to contribute to their college expenses For such period of time as the children reside with Wife, she shall be entitled to cl.aim any appropriate dependency exemptions for tax purposes. 13. MEDICAL INSURANCE. The parties agree to maintain their medical insurance as it is at the time of the execution of this Agrep.ment until the time that a divorce decree is issued, Husband shall provide medical insurance for the children of the parties until such time as each child had graduated from college or has earlier terminated his education. The parties shall equally share all medical, dental, prescription, eyecare, orthodontic and counseling expenses for the children which are not otherwise paid by medical insurance until each child has graduated form college or has earlier terminated his education, Husband shall reimburse wife within fifteen (15) days for any unreimbursed expenses she incurs for the children. 14. LIPI INSURANCI. The parties acknowledge their intent and desire that Husband shall provide f.or a fund tQ pay alimony, the balances due on any debts and obligations he assumes pursuant to 12 the terms of this Agreement, and for the care, support, education and maintenance of their children (including college expenses) in the event of Husband's death. In furtherance of this covenant, I I I, " 1 I I Husband agrees that he shall obtain and maintain at all times hereafter a policy of life insurance coverage on himself in the minimum amount of $100,000.00; coverage insuring his life in sufficient amounts to pay in full all balances due on the said debts and obligations, including all alimony obligations owed to Wife, as set forth hereinafter. Within thirty (30) days following the date of execution of this Agreement, Husband shall provide to Wife or to her attorney satisfactory proof of the existing balances due on each such debt and of the insurance coverage obtained to secure their payment. Husband shall annually provide to Wife or to her attorney documented proof of the existing balances then due in each such debt and of the insurance coverage in place to secure payment of such balances in the event of his death. Husband shall be prohibited from borrowing against, assigning, pledging or othenlise encumbering the said .insurance policy, Wife shall be named as the irrevocable beneficiary of the said policy until such time as all alimony, support, debts and obligations hereunder have been paid in full, and she shall be responsible for making payment of the said debts from the insurance proceeds received in the event of Husband's death. Wife shall maintain the current life insurance coverage for herself as provided by her employer, Pennsylvania Blue Shield, under the same terms and conditions, Ownership of the said 13 -, . insurance policies by each party shall be subject to the following conditions: a, Each party shall maintain the respective insurance in full force and effect at all times, paying all premiums thereon as due, and shall not borrow against, assign, pledge or otherwise encumber . , ' the insurance, nor surrender it to obtain its cash value. b. Wife shall immediately designate the part ies' children, as irrevocable benef iciaries of her li fe insurance policy and Husband shall designate the parties' children as irrevocable beneficiaries of his life insurance policy upon complete satisfaction in full of all obliga,tions of alimony or support of any nature required I I 1 hereunder and upon payment in full of all debts assumed by Husband hereunder. , I, I ,. I c, Within thirty (30) days after the execution of this Agreement. each party shall deliver to the other or to his or her , , I attorney satisfactory proof that the minim'Jm required insurance Ii \ Ii , I, coverage has been obtained and that the beneficiary designation has been properly endorsed on each policy. Each party shall request that premium statements and receipts be mailed ~' . duplicate perJ,adically by the insurer to the other party. 15. ALIMONY. In order to permit Wife and the children of the part ies enjoy a lifestyle substantially similar to that enjoyed during the marriage, Husband shall pay to Wife non-modifiable alimony in the amount of $1,500.00 per month following the. date of execution of this Agreement. The said alimony payments shall not , ... . , :, \ 1, " ~l 1 1..\ It ! \ be subject to modification for any reason, and they shall terminate 14 upon only upon Wife's death or remarriage. Said alimony payments shall not terminate upon Wife's cohabitation, and such paymento shall be taxable as income to Wife and deductible by Husband for federal income tax purposes. Suc:h payments shall be made prospectively on or before the first of each month, commencing with the first day of August, 1996, The parties shall cooperate in the entry of an Order of Court directing such payments to be made through the Domestic Relations Section of cumberland County. 16. COUNSEL PIES AND COSTS. Husband and Wife each agree to pay and be responsible for their own attorney's fees and costs incurred with respect to the negotiation of this property set t lement Agreement and the divorce proceedings related thereto. . 17. l21VORCE. A Complaint in Divorce has been field to No. 96-2207 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania, and either party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an affidavit evidencing their consent to the divorce, pursuant to Section 3301 (c) of the Divorce Code not later than seven (7) days following July 23, 1996 (the 90th day), or the signing of this Agreement, whichever is later. In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees, resulting from any action brought to , ~ J " compel the refusing party to consent. Each party hereby agrees ;j1 . " ':, · ,'f that a legal or equitable action may be brought to compel him or 15 her to execute a consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. 18. RICONCILIATION. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. . , i'l i, , " 19. INCORPORATION IN FINAL DIVORCE DECREE. The terms of this Agreement shall be incorporated but shall not merge in the final di vorce decree between the parties. Any Court having jurisdict ion shall enforce the provisions of this Agreement as if it were a Court Order. This Agreement shall survive in its entirety, jl I Ii I- '/ resolving the spousal support, alimony, equitable distribution and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania, and no court asked to enforce or interpret this Agreement shall in any way change the terms of this Agreement. This Agreement may be enforced independently of any support order, divorce decree or judgment and its terms shall take precedence over same, remaining the primary obligation of each party. This Agreement shall remain in full force and effect regardless of any change in the marital status of the part ies. It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable, and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement, 16 _. 20. DATJ: O~ J:XICUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the part ies if they have each executed the Agreement I, , on the Bame date. Otherwise, the "date of execution" or "execution I. , I I I date" of this Agreement shall be defined as the date of execution by the party last executing the Agreement. 21. P~LL DISCLOSURI. Each party asserts that he or she has made or shall make a full and complete disclosure of all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, and of all sources and amounts of income received or receivable by each party. 22. &HIIRI AGRIEMINT. 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. 23. BREACH. If either party breaches any provision of this Agreement, the other party shall have the r'ight, at his or her election, either to sue for specific performance or for damages for such breach or to pursue the remedies available in enforcing this Agreement as an Order of Court, and the party breaching this Agreement shall be responsible for legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 24. WAIVJ:R 9R MODIFICATION TO BI IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless made in writing and signed by both of the parties. 17 25. ADDITIONAL INSTRUMBNTS. 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, including Deeds and other real est.ate-related documents, titles, or other documents that may be reasonably required to give full force and effect to the provisions of this Agreement. . 26. SBVBRABILITY. If any term, condition, clause or ;1 " provision of this ~greement 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. 27. WARRANTY. Husband and Wife again acknowledge that they have each read and understand this Agreement, and each warrants and represents that it is fair and equitable to each of them. 28 . DISCRIPTIVI HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in deter.mining the rights or obligations of the parties, 29 . LAW GOVBRNING AGRZEMIlNT . This Agreement shall be governed by, and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 18 IN WITNBSS WHBRIOr, and intending to be legally bound hereby, I I , t I' i ,I ~ the part ies hereto have hereunto set their hands and seals the day and year first above written. This agreement is executed in duplicate, and each party hereto acknowledges receipt of a duly executed copy thereof. WITNBSSBSI 4~/V1#~' ROBERT G. GXLARDINI . ~ Ii ~ /' " {t :1 r i' ," , ' 19 '.. If) (I' ...... , " , " , tI,\ ..../ . ( 1 f" " " I'll '"j \. , I f' ,) (. . , 1';.: , , 'i,j , , I i._ I.' . ) "-.; \.1 :i! 8 ~ wHSl 6 ~ ~ ~ .c ~ ffi "'" "i~;::~ ~~~-~ "" '" o E en " _ x W i<<; ~ o :l ~ ~ lE~~~ o z g ,.. ~h~ ..... .,., "'"':'0" MARILYN S. GALARDINI, PldntUf IN THE COURT 0' COMMON PLBAS or CUMBERLAND COUNTY, PENNSYLVANIA V8, I C NO. 96-2207 civil Term c c CIVIL ACTION - LAW c IN DIVORCE ROBERT G. GALARDINI, Defendant iRAlCIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry ot a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Di.vorce Code. 2. The Complaint WaY filed on April 24, 1996. 3. Date and manner of Service of the Complaint: April 30, 1996 by Acceptance of Service of Defendant Robert G. Galardini. 4. The Plaintiff's Affidavit Plaintiff on J...I'I 3V , 1996, 1996. The Defendant's Affidavit J,uo..j 00 , 1996, and filed on of Consent was executed by the and filed on J.d..,..3/ of Consent was executed on J...."i J J , 1996. 5. plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on J....I'j 30 , 1996, and said waiver was filed on J>l.I'1 ..31 , 1996. De::endant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (cl of the Divorce Code on J.dLI dLl 1996, and said waiver was filed on J~d'1 -31 ,1996. 6. There are no related claims pending. The parties have resolved economic issues by agreement. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL 1/'I/{lli Dated: ;>_ .-- lvL , Esquire 69 '- Attorney for Plaintiff ~-,''l''''''''~'"'M'"''~r.''!.-'' .1' I: 'ej..,..:" ",...., i\'HI:""'-';''''l,,'tr't,J' 'j r 'jl.', "i'f{(t("'i" '.: - \j~;" ,'11)'.'1<1 (_.n'..,.;,' 1-'\' (~..t_d> It"'It .J-;'hl~:", '.'Wf"'.zr?1, , .. ,J_S~;H;.;fl{t\ .'",;_"-:-,, ,':.,',:', ',.,', ;',;'i,l:',. ,I,': ,';,'-';~\';-:i)i~~?A'\}'I,~;1;;~8l![:~ ",t!i:,t;\~,{_'" ," .. , 1~; ,'; ',{ '\" ),\\. ".." "-:""" _" \!; ""I,ll, 'i '-h~T~' I" \ .d-I.!i'tll; II '{'i;] I;; \1, l,;,,;\,!.li'{~I'i -j' '_,,'11, ;'_'l!H:'[);;-:i\,I'I,;h--'_;-iJ::;'I,',i,L'~J);\';:h_'~'_'~ ,. " J".-,,', '-.: , ",,' ~ ,'_ ,!'," J I ,. -,',' .., ',.' '''' " . " j' -"" '_ _ ' ,>"..; 1J: " _ ,; _ll:~[~~.'::!;\:l.~,~\L<\:Wjt~~Jil i..,.wIlu~h;;-':I'~::;H :h,: ~-r;\\I~,;tfI;t:lr.({~tl~11'~ . 1 \ . .I!. ,,," \ ., I~ I, .. P .) .j " ,:; ^ , 'f' 'i' ,. r- '. - ' - . " If '" I ,j , ...-.j '-, ~ I~!m iP~! ~ I !> a~~~~ !jg! ~1~5 . MARILYN S. OALARDINI, I IN THIl COURT OF COMMON PLUS OF Plaintiff I CUMBIRLAND COUNTY, PBNNSYLVANIA I 'II. ,J;JrJ 7 G~.J'r.J..4.'- ve. I NO. I ROBIRT G. OALARDINI, I CIVIL ACTION - LAW Defendant I IN DIVORCI 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 action, You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment be entered against you by the Court. A judgment may also be entered against you for any other claim or relief re.quested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you,", 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, One Courthouse Square, Carlisle, PA 17013, IF YOU DO NOT PILI A CLAIM FOR ALIMONY, DIVISION OF PROPBRTY, LAWYIR'S PIES OR EXPENSES BEFORE A DIVORCI OR ANNULMENT IS GRANTID, YOU MAY LOSE THE Rl:GHT TO CLAIM ANY 01' THIM. YOU SHOULD TAXE THIS PAPER TO YOUR LAWYBR AT ONCIl. II' YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONl!, GO TO OR TILBPHon THB OPFICE SilT FORTH BELOW TO I'IND OUT WHBRE YOU CAN GilT LBOAL HIlLP. Cllr-IBERLAND COUNTY COURT ADMINISTRATOR Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 249-1133 or (717) 697-0371 MARILYN S. GALARDXNI, I IN THII COURT 0.. COMMON PloDS 0.. Plaintiff I CUMBIIRLAND COUNTY, PIINNSYLVANIA I v.. I NO. I ROBIIRT Q. GALARDINI, I CIVIL ACTION - LAW De f endan t I IN DIVORCB VBRIFICATION X, MARILYN S. GALARDINIr verify that the statements made in the foregoing DIVORCE COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S. 4904, relating to unsworn falsification to authorities. Date: !lfu.( .~, /N~ \/Jrla~ / )J~~w- Marilyn S.~Galardini i'" , ' ;1' " -' MARILYN S. GALARDINI. I IN THI COURT OF COMMON PLUS or Plaintiff I CUMBIRLAND COUNTY, PINNSYLVANIA I v.. I NO. 96-2207 Civil Term I ROBIRT G. GALARDINI, I CIVIL ACTION - LAW Defendant I IN DIVORCI AFFIDAVIT OF CONSINT 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 24, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I conaent to the entry of a final decree of divorce after service of notice of intention to request entry of the decr~e, 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and 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: ?L'() / 'l~) , r77a;ll,~tLC~ MARILYN S ' G DINI, PlaintiU i 1(1 1._ , - Ill', , , " (' " 'I ( . , 'I f ;, (' ;,; I' , .J I, ,,- , , . ; I , , , I .l ~ S ~ ~ ~ C ~ ~ ~ g ; ~ E ~ ... ~ ~ r::. III ~:: ~ (J ~ M ~ - q; ~ f ~ ~ ~ ~ ~ ~ ~ & ~ , '. , . . . . . . . , , " , .., f") I,l;) !..) C~: l'J) ~ - . " en,' . '- :;J , j-.<-- , ,";':f: I:tg tr':.;, " Co.> 'I '9 t' .'/~ - ....; . 'l~ r.~i ""-:-;r ", ..y __n.- . :'& i,.-!'\' '.(, ,):'0, L,- . (:)11'1 , .. .;j , , ,.., (J'( ~rl .....