The URL can be used to link to this page

Home My WebLink About96-05321 .J ... ~ ~ ~ ~ t' .J S o .., ~ . C) ~ I , 1'-1 I 1,1,) , , , 1'1 " 1",/ , " ' I' , , , I' " , , " I'll ,,' , , " , , , )11, ," 'I , I Ii " " II " ,i 'I 'ii 1/ I , ,;'! ,d I' , ,;, , , I " I , " ,," ,', I, " ',I , fI' ii, , 1'- , " " " " " " ,', 'Ii 'J, ,I 'I , , 11 ,I ,ji I, r'r' I, I " : ~ I, III " I III I l,iI I J, "I i " 'I I ,I ", '1 i' " " , II , I' , i', iI 'J'I'I I , :11 'I " ,/ ,'ll, , ' 'I 'I " " " ,Ii, ,1 I J j -II I , " , , " 'I '" "t " " ''1 'I , , , , " , i,1 I 'I " , " " , " "11,1 " ," ;,1.1 I , " , ,I , 'I, 'I I '11,1 , , , , I I" ," ," " "~I I"i! 'il ' iii' , , , " " I It 'I " 'I , , I " , " , , " , , I" '1,1" t i, /, ,-I .I " " '" ',I " " I , , 11,Ii 1,'/' Iii /, " " " i " " , " " I, ,I, i,l, , I, " ,'I .,. ,"~" " , " ,/ " , " , II '(I ,', " Ii i " 'I,:h ,I ",1 Ii' I: ',) 'I, ',' " I, , 'I, ,I I It'! , II, , ,I ;/i ,1,1 , , " .,_,lil,I' J ! I') " , , .., 'Ii /'J' , , 'I 'I' 'I, ,iil J'II I , I , " I ~ " )'1), ,II il " " , , , i.i 'I I: /, !L " !li,'1 , I " J'; , Id 'q'l " " " i, , , ;" '11'1 ,,' ',,1 , " ,Ii " " -','I 'I I; , " ,I 'J , I 1\ \'1 I <r\IL/ ,j 1"'-, 1,1 ,'II " ~ " " " J' , " ,I , !, 'I', , ", IJ'I ;1 " " "ll" ,\ , , " II , ii' )'_, I '\ iih' " "I' J,-' ,'I'T I , t ~ 1- I ~ 'Iill 'i I';) ,/11 'I 'I 'i. 'j: " I, .-,' I. -f " :, d ji,.. ',1 -/ "I . ',I' ii', ':.', I , , I ~ I ,. ill. ", I' ,', ,/ , ,I " ! 'I , I ;1 '" 'r " " , , I;! " I " , 'II I, , / '1\ , " ilt , " " " I' \ I' J'I \ , , '" " ,I , , " , 'I , ,', 1/ /, iii , " ,/ " " " " r! II I I , " " "I " I, 'i' , " " "I '.. 0".' .,- I'": ,',:'-'; (a j'l: ". IIj " I" '-,.4 ',t '-'~ , " ,,- I , '-J ' ~:: ~, , .J) t,,: I,' '.';, '1'1 1'1' I I"~ I ' ..... ,ir~ 1"11 c..~' , I;"~ L' .1) ~.1 , I " i , I I . . " " ;11 ," , ' , . , . , LAW OHiC! Of THOMAS D, GOULD A"O'NIIl AI lAW IIMI MA'N mIll' 51i1"MA"ilOWN, PA 11011 11/0131,1161 " .' . . ~AGm SmTTLmMENT AGRmmMENT 'rHIS AGREEMENT mllde this 1-lli day of OC:\Oktth) , 1999, by and between Paul Edward Kr'.lsovic, <her.einafter. referred to as "Husband") and Lisa Marie Krasovic, (hereil1after referred to as "Wife") , WITNESSETH I WHEREAS, the Husband and Wife were lawfully married on August 11, 19841 and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each otherl and WHEREAS, there were two (2) children born of this marriage, Paul Eugene Krasovic, born May 16, 1967 and Kevin Andrew Krasovic, bcrn September 29, 19931 and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations 1 and NOW, THEREfORE, the parties intending to be legally bound horeby do covenant and agree as followsl 1, SIlPMA'rION tt shall be lawful for each party at all times hereafter to live separate and apart from the other party at auch place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be tak~n as an admissl.on by either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTZRnRlNCZ 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 maybe necessary to carry out the provisions of the 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, and each party hereto completely understand and agree that neither shall do or aay anything to the children of the parties at any time which might in any way influence the children adversely against the other party. . 3. DIVISION or PI~SONAL paOPIRTY Husband will be providinq WHe with a liat of the personal property that he will be removinq from the marital home I Once that property has been removed from the marital home the partl.es will have equitably divided between them to their mutual satisfaction the personal affects, household furniture and furnishings and all other articles of personal ptoperty which heretofore have been used by them in common. Neither party will make any claim to any such items, except those on Husband/s list, which are now in the possession or under the control of the other, 4, AUTONOBILIlS The Husband is the owner of a 1991 ford Ranger and Wife is the owner of a 1992 Dodge Shadow. Neither vehicle is ~ncumbered, Husband shall nave all riqht and title to his vehicle, He shall maintain insurance on his vehicle and be responsible for any and all maintenance and other payments related thereto. Husband &shall indemnify and hold Wife harmless for all matters related to his vehicle. Wife shall have all right and title to her vehicle and shall maintain insurance on her vehicle and be responsible for any and all maintenance and other payments related thereto, Wife shall indemnify and hold Husband harmless for all matters related to her vehicle. 5. DXVISXON or Q.AL nOPZaTY The real estate owned by the parties as tenants by the entireties situated at 105 Maple Drive, Mechanicsburq, Cumberland County, ~ennsylvania shall be conveyed in fee simple to Wife. Wife shall assume full responsibility for the payment of the existing mortqage/ note and taxes. Wife shall indemnify and hold Husband harmless from any liability on the marital home's mortgaqe, note and taxe:s. Wife shall make reasonable efforts to refinance the mortqage/note on the marital home, Huaband agrees to cooperate with Wife and provide all required information and sign any documents necessary to assist Wife in refinancinq the mortgaqe and note solely into her name. If Wife is unsuccessful in her initial attempt to refinance the marital home, she shall, as a minimum, reapply yearly. Upon demand, Wife shall provide Husband with a copy of such denial. tf Wife, prior to the refinancing, falls more than 45 days late in making the mortgage payment/ Husband shall have the right to require the sale of the former marital residence. 2 . 6. HUSBAND'S IUSXNlS8 Ourinc;J the marriac;Je Husband established a sports memorabilia 4nd merchandise business, known as Paul's Sports Cards. The business ahall be Husband'o sole and separate propertYI Wife relinquishes any and all riQht and interest shll may ha\'1 11'1 Husband's business, This includlls, but is not limitlld to, Husband's bank account located a Fulton Bank in thll name of Paul's Sports Cards, 7. ~ITAL DilTS Wife shall be re~ponsible for all marital dllbts solely in her name and the mortgage on the marital home, Husband shall be responsible for all marital debts solely in his nome, Husband shall not be liable for any debts related to the marital home, Each party agrees to indemnify and hold the other harmless for any debt that they are responsible tor pursuant to this AQreement, Each party agrees that they will not attempt to discharQe any debt owed to the other pursuant to this AQreement in any bankruptcy proceeding, 8. PINSION AND RlTIRIMINT ACCOUNTS Husband and Wife shall maintain their separate pension and/or retirement accounts. Husband sh411 transfer to Wife, by tax exempt rollover, 11 interest in his IRA, 40t (k) or other pension/retirement account (s) derived from his employment with Kal.'n' s. Husband certifies that he has his entire Karn's pension/retirement funds located in account 11225-0401645 at Fulton Bank. The value of that account was $12,689,47 as of 07104/99. Husband relinquishes any and all right and interest he may have in Wife's pension or retirement accounts. 9. CUSTODY The parties agree that they shall share Leqal Custody with Wife having Primary Physical Custody of the children subject to Husband's periods of Partial Custody as mutually aqreed. Each party aqrees to inform the other at the major parentinq decisions affectinq the children's health, education and welfare. Each party shall have the riqht to access the children's medical, educational and other records. The parties aqree that the above custody arrangement may be changed by the mu1ual aqreement of the parties or, if the parties are unable to aqrae, by a Court of competent jurisdiction. 3 , LO. IUP'ORT/ALIHONf/ALIHONf 'INPINTI LITI The parties hereby waive, release, discharge and give up any rl.ghts either may have against the other to receive spousal su~port, alimony pendente lita or a~imony. Husband shall pay Wife $700.00 per month for child support. A $350.00 payment shall be paid on the 1st and 15th of each and every month. tf Husband is late in his payment WUe shall have the riqht to file a leqal action for breach of this MSA, seek a Support Order and wage llttachment, The Bupport amount may be modified with a material change in circumstances as agreed to by the pal:ties, tf the parties are unable to agree, either party may seek a modification by the Dome/ltic Relations Office (DRO) or court of competent jurisdiction, 11, rILING or IRS RlTURN Husband and Wife agree to file a separate tax return for taX year 1999 and all subsequent years, Wife shall be allowed to claim the interest payments on the current marital home mortgage. 12, DIVORCI Wife filed a Complaint in Divorce o~ September 25, 1996 in Cumberland County. The parties aqree to cooperate with each other in obtaining a final divorce of the marriage. It is aqreed that the parties shall execute and IIllow to be filed the documents necessary to obtain a divorce. Each party shall be responsible for their respective attorney fees and costs, 13. INCORPORATION This agreement is to be incorporated into any subsequent Decree in Divorce, 14. CONTINUED COOPIlRATION The parties IIgree that they will within fifteen days after the execution of this agreement execute any and all written instruments assignments, releases, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this agreement. 4 I, " I .:,>> -.. , ',- fl. I~.. I I' ':'1 , i " HI , , J " , ~ ,\ ,I, \ ; :!~ 1(.1 '.II I I, .. I I.l} . I\\;' , . ,j " ,...." ,I 'i 1_,1 dl ,J " , I .' , , " " ;; i' ~ :',1 \ :,,"; (", !i 'Ii'!;' " , , I "', \,' 1;1 I' ,I' " ~, 1. ,,:.q Y' ," " i,'" I 1" , , "I ., " , I"J , ' !, " "tJ { ,1-, ~,R' '~ :t.O ~ ci C" 00 - 'I ,,' , " " ,<I " '1'.1 " :1, 'I I d ,,1 , " , 1,'., , " "/ , \/1 I I' " , , I), " , 'J J , I -", ),'\11_ t Ii 1 '~~~~i~i;:\r\l'illl' tl, ,. ~~! ,~~(~{'I~J,j,P' , " , ~~!~~f::Al~.m~ff,lf: '"I: ,:" ~'; ,/-,.,' ",.' i" " il , ! " , , , !' ,j,' , , '1\ , I " " " \j , 9/wnuw q;, ~t)ouU- "TTORNtv,o,n"W il E "''',N STREET SHIRE","NSTOWN, p;.. 17011 7'7-731-10401 h '.;).' II r1: . ;"', '1 ! ~'~ 'ji " ,,'il' '1:.), ~I' ,J "I '-..II,'.,' IJt I.., " 'I 'I] " I, 'I ,I , J" , " ," , , '1' , " " " " , , " ,. " " 'I" ,;1 , , '/1 " 1,,' , " 'I. I,' Ii! In , " , ,. , , "" , .' ',' . {'; " \\,1 ji I , " ,,-I 1'-." '1'\" , , ',1' '~.. ,~" 'I, i',! I' '. , , . , 'II " J I" 'i' I', ,i ! " , d" 1'\' 'I " II"i 'I: " .' !; t" ~;, J /1'.-1', "1'," " .:/, i\ p. LIlA MARII KftAlOVIO, PLAINT IF' v. , , , , , , I IN THI COURT 0' COMMON PLIAS CIUMIJIIWUtD COUNTY, P.NNIVJ.,vIUUA NO. 116 - '. ',.J I CIVIL TIRN PAUL IDWARD KRABOVIC, DU.lfDIUfT IN DIVORCI COMPLAINT UlfDIR BICTION 3301(0) OR 3301(d) or THI DIVORCI CODI IN DIVORCI 1. The Plaintiff is LiBa Mllrie Krasovic who resides at 105 Maple Drive, Meohaniosbur9, Cumberlllnd County, Pennsylvania 17055. 2. The Defendant ia Paul Edwllrd Krasovio who ~esides at 105 Maple Ovive, Meohanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Ollfendant have been bona fide residents of the commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 11, 1984, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divoroe or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant iB not a member of the Armed Bervioes of the United Btates or any of its Allies. 8. ThEl plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. -, ' " LIlA ~I. ~OYIC, PU;r;"TXrr Y. I" Till COUP.T or CotINO" PLMB c:uNISIlU..NfP COUJrJ.'lt, 'amrSltLVMIA "0. 98 ~ 5321 C;r;YIL TIRN PAUL IDNW IaWIOYIC, PlratmANT I" p;r;YOP.C1 AI'.IPAVIT O. CONSINT 1. A Complaint in Divorce under Section 3301(c) of the Di vorce Code WaB f ilad on September 25, 1996. 2, The ma rria\le of Plail1t1f.f IInd Defendant is irretrievebly broken and ninety (90) days hllve elapsed from the date of the filing and service of the Complaint, 3. r consent to the entry of II Final Decree of Divorce after service of notice of intention to request entry of the decree. r acknowledge that purauant to Rule 1920,42 Ie) r have wsived the requirement that r receive notice of intention to request entry of the decree. 4. r underBtand that r mllY lose rights concerning alimony, division of property, lawyer's fees or expenses, if I do not claim them before a divorce is grllnted. r verify thllt the statements made in this Affidavit are true and correct. I understand that falBe statements herein are subject to the penalties of 16 Pa, C.S, Section 4904 relating to unsworn falsification to authorities. DATEDt /2.Jh I -I '/ , ~,j,( .,;}')(1.'): d .j/l....,JO.r..IIC_ LIlA ~I. KRABOYIC , I I I ')' " I" I -.. ,... ': . .:.:: r.t " , ~'~l .':\' II' ',.):fi I, " . I ,I 'J ' ~ I,Y , )".J If'.) . ii'l] , , I , ';~ 1'1 1-' '!IV , II. I U , '1" .j't '., .1> .1 II , ' I, ,I '. " i' I I I I' " , , , , IN TilE COUR1' OF COMMON PLEAS OF CUMnERLANI) COUNTY. PENNSYLVANIA LISA MARIE FREBERcl. rtkI. LISA MARIV, KRA!tOVIC, 1)lolnIIO' CIVIL ACTION .I.AW I)uckel No, \996.5321 PAUL EI)WARD KRASOVIC, OefendwlI (hI Dlvlll'ce) ~M TO ocrOl..;n 7. 1999 ~MRR'~(,t; tjETIl,EMENT ACJ"D.M.mI nlls AClItEEMENT mode Ihls j1z.tl.,doy of ..Jyjl~. 2005. by wId belween PlmnlltT. UIlI1 Marie Freberg. Ilc/ko UIiB Marie Krnllovlc. of JOS Maple Drive, Mechanlcaburg. Cumberland Counly. I)ennllylvanla, herelnaller referred 10 os "Wile" A N D Paul Edward Krosovlc. of 411 River Rood, Dauphln, Dauphin Counl)'. Pennsylvanlo, hereinafter referred \0 as "Husband", RECll&It'i R, I: The portles herelO were lIusbond and Wife, having been joined In monill8e on Augullt II. 1984. and LMFN poge 1 01'5 PEKU ... It,2t Thill'll Will'll two (2) chlldl'llll born of this mWTlpill, IIUlllllly, I'uul EUicne KrII/IOvh:, whose: dutll of birth Is May 18. 1987 (hen:lnaller I'lllill1'1:d 10 llll"I'pul"). wId Kllvln Andrew Kl'IIJIOvh:. whorse date of birth Is Seplllmber 29, 1993 (hcl'lllnul\.er relereed 10 Illl "Kevln"). hllrelnaller collectively rnferred III WI tlu: "Children"; and JU: The l'OI1les cxecuted u MWTlage Seulement Agn.'Cmcnt on OelOber 7, I')t)l). thll purpoSIl of which WWl \1) slIlIle and delemllnll certain of Ihelr mnrllul rlghls and obllpUons, and make 011 elJUlloble dlsuibutJon of Ihelr morllol property, delllnnJne their rlghll 10 alimony. SUppc.lrt and other mailers which may be conslderell under Ihe Divorce Cooe, and R.4: Wile llIed a Dlvoree Complalnl WWI mild 10 Ihe abow-referenccd lenn WId nUlllber; and R,S: The Parties' OClober 7, 1999 Morrlnge Seulemcnt Agrecment WWl entc:red Into record on or nboul the dwe onhe Dlvoree Decree; and R.6: The Parties' son. I'aul, turned Ell&hteen (18) years old on May 18. 200S, olld R.7: ThcPartles' son, 1'11U1. will will gruduole from high school on or about June 9.200S,and R,8: Thc POI1les now wish 10 modify spec,"c clllld portlollll of thc pfon:mcnlloned OClObcr 7, 1999. Marriage Settlemenl Agreement, hllrelnal\er referred to WI the "Agreement". LMFN Palle20fS PEK~ NOW TlIEIU!FOIW, with Ihlllllilnlllol"ll Nllltlll~ bIlhlK hllnllllllllllr hlllul'JXll'llled by n1rlll'lmcc wId dUllmlld WI U5KCllllul PUI1 hll~'()f un~ III IlllllsldurUlhlll lIf Ihu IlllVIlIIUIIIII lInd promlllllll hll/'lllllllllur 10 bIlmululIlly kllpl and flIlr'ilml~'Il by ellllh l'ul1y, IIlI well IIlI lilr lIlhllr Kood und vlIluublllllollllldurutlllll, Ncclplllf which Is hlln:by acknllwledHed, lIlIlllhcl'artlcs, Inlendlnlllo bIlluWllly boUlld, hUnlhy lI~nlllllll /illlowlI: (I) The l'ul1lcs henllO aHrue 10 modiI')' l'aruHruph 10 Ill' Ihe A~l'I:emenl, whlr.:h flIlrtlllnll 10 Ilhlld IIUpptlrt, lindeI' Ihe origlnul ^It~'\!melll, lIushwld WUll 10 "pay Wife $700,00 per mOlllh till' cblld KUpport," Thcse puymenla WllrClO hi: mude Iwlcc a 1ll01llh - "a 5350.00 paymenl shall bIl puld Iln Ibe I" WId I sih of ellllh und evcry 1II01l1h," Slncc Ihc 1'lIJ1.les' oldcsI ehlld.l'aul.IK IIIlW elllwlelpull~d, Ihe l'nrtlcK hllve ul!nlcd IhullluKbund's child KUpport obllWllllln shall be reduccd 10 $350,00 per 1II0nlh, 'J1lcllll $350,00 munlhly paymenls lor IIWlbwld's support of Kllvll1 shull ulso be lIIudc IWlcc a Illonlh . u $175,00 pByment shllll bIl mudc 10 Wll'c on Ihe \" wId I SUI or caeh alld every monlh. The I'nrtles further a~ree Ihul UpOIl Kevin's I gill blrthduy Ill' upon hili graduollon rrom hlHh school. whlehevc:r OCCW'llIOlllr, IIWlbwld's child support obHHallon will ellllllll Iotlllly, In 011 olber respee\ll. IncludlnH an)' and ull additional provisions Inl'urngruph 10. the I'artles' OClobcr 7. 1999 AW'Cemenl sholl rellluln In full forer. BIId etfecl. (2) Thc purtleK hllrelo ncknowledHc und dcelal'l: Ihat each hllll had a full WId fall' opportunity 10 oblnln Independenl ICHal advlcc of counlllll of Ibelr IlIllccllon; Ibal Husbund hOll hl:en independcnlly represenled by Lindsay OhlHrleh Mucloy, Esquire. or Daley. Zuckur &. Olnwlch, LLC, 11111.1 rhal Wire. cognl7J1/11 of hcr riHhllo counsel, choolllls 10 I'I:presenl herself wllh rellurd 10 Ihe preparallon, undcrstandlng und execullon OflhlK AddcndulII, LMF fnt) l'OIlU 3 of 5 J>EK& " , f';; C) ~~ ~. ~.., ., ~ n1\;! iE " I{J \It~ , '.I~ @<1 en ' " a: N ,,.'111 ' ' "J "J lt~ ~ ~m ~ ~ " " , , ! , I '11 " d I, , , I 'I; , " I,) " , " , ',I .1 " .,