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MARITAL I'ROI'ERTY AND SE'ITLEMENT AGREEMENT
'I11is Agreement, made and enten.'lI into this /~ -14 day of #0 ,Il-fl< IS LtC-. 1998. between
PATRICIA A. ZAWATSKI of 533 First Strect, Carlisle, Cumberland County, Pennsylvania,
hereinafter referred to as ''Wife,'' and CHRISTOPHER ZAWATSKI., of 103 Oa'M1 Drive, Carlisle,
Cumberland County, Pennsylvania, hereinafter referred to as "Husband."
WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to
each other on August 16, 1984, in Virginia; and,
WHEREAS, Husband and Wife are the parents oflWo daughters, Janice R. Zawatski, 0,0.8,
January 3, 1985; and Diana F. Zawatski, 0,0.8, July 16,1986; and,
WHEREAS, certain differences have arisen by and between the parties as a result of which
they have now separated and the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligation as between each other including, without limitation by
specification: the settling of all matters between them relating to the o'M1ership and equitable
distnoution of real and personal property; the settling of all matters between them relating to the past,
present and future support and/or maintenance of the children; the settling of all matters between them
WHEREAS, both and each of the parties hereto have been advised of their legal rights and the
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relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of
Husband of Wife; and in genera~ the settling of any and all claims and pOSSlole claims by one against
the other or against their respective estates; and,
implications of this Agreement and the legal consequences that may and will ensue from the execution
hereof; and each has had the opportunity to consult with his or her 0'M1 coltlpetent legal counsel
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independent of each other; and,
WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has
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fully and completely disclosed all infonnation of a financial nature rcquestl.'ll by the other, and that no
infonnation of such nature has been subjcctto distortion or in any manner being misrepresented; and
WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of
her right of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or
inchoate, in and to the real and personal property of the Husband, now owned by him or \\<hich in the
future lt18y be owned by him, and all rights to counsel fees, or expenses and other than as set forth
herein, Husband likewise wishes to relinquish all his rights of curtesy, rights as heir or surviving spouse
or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife,
currently owned by her or \\<hich she lt18y own in the future;
NOW, THEREFORE, the parties hereto intending to be legally bound hereby do hereby
mutually agree as follows:
I. Advice of Counsel. Husband and Wife acknowledge that they have been given the
opportunity to obtain the advice of counsel regarding the provisions of this Agreement and their legal
effect in advance of the date set forth above to pennit such independent review. Each party
acknowledges that he or she has had the opportunity to receive independent legal advice from counsel
ofhis or her selection, and that each fully understands the facts and has been fully infonned as to his or
her legal rights and obligation, and each party acknowledges and accepts that this Agreement is, and
under the circumstances, fair and equitable, after baving the opportunity to receive such advice and
with such knowledge, and that execution of this Agreement is not the result of any improper or illegal
agreement or agreements. In addition, each party hereto acknowledges that he or she has had the
opportunity to be fully advised by his or her respective attorney of the impact of the Pennsylvania
Divorce Code, \\<hereby the court has the right and duty to detennine all marital rights of the parties
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including divorce, alimony, alimony pend~'l1te lite, equitahle distrihution of all marilal property or
property own~'<1 or posses.o;cd individually hy the other, counsel fees and costs of litigation and, fidly
knowing the some and having the opportunity 10 he fidly advised of his or her rights thereunder, each
party hel'l.10 still de~;res to exccute this Agl'I.'Cm~'l1t, acknowledging that the tenns and conditions set
forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to
have the Court of Common Picas of Cumberland County, or any other court of competent jurisdietion,
make any detennination or order effecting the respective parties' rights to a divorce, alimony, alimony
pendente lite, equitable distnbution of all marital property, counsel f~'Cs and costs of litigation,
2, Separation. Husband and Wife do hereby mutually agree and consent to live separate
and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to
live separate and apart from each other, and to reside, from time to time, at such place or places as they
respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each
other.
3, No MoIestJItion, lIarassment or Interference, Neither party shall molest, harass or
interfure with the other or compel or endeavor to compel the other to cohabit or dwell with him or her
by any means whatsoever.
4. Mutual Property and EstJIte Waiver. Except as otherwise expressly set forth herein,
in which event such express provision shall take precedence over this paragraph, the parties hereto
intend that from and after the date of this Agreement, neither shall have any spouse's rights in the
property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of
dower or cUrtesy, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or
allowance, to be vested with letters of administration or letters testamentary, or to take against any wiD
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ofllle other, and ellch IIgrees with the other if either sllould die inteslllte. Ilis or her sllllre sllall descend
to vest in Ilis or her hcirs at law, personal r~'/lrescntatives, and next of kin, excluding tIle other as
thongh he or slle had dk'<l a widow or widower. And each lillther agn.'Cs that should the other die
testate, his or her property sllall descend to and vest in those persons set forth in the other's Last Will
and Testament as though the spouse so designat~'<l as beneliciary Ilad predeeeased the testator, The
parties fUrther agree that they may and can herealler, as though unmanied, without any joinder by him
or her, sel~ convey, transfer or encumber any and all real estate and personal property which either of
them now or herealler OmJ or possess and further agree that the recording of this Agreement shall be
conclusive evidence to all of his or her right to do so, The said Husband and Wife do hereby
irrevocably grant, cach to the other, should the exercise of this power hereby given be necessary, the
right and the power to appoint one or more times any person or persons whom the Husband or Wife
shall designate to be the attomey-in-fact for the other, in their name and in their stead, to execute and
acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to
enable either party hereto to alienate his or her real or personal property, but without any power to
impose personal liability for breach of warranty or otllerwise. Each of the parties hereto further waives
any right of election contained in Chapter 22 of the PennSYlvania Probate Estates and Fiduciaries Code,
and any right to seek or have an equitable distnoution of married property ordered by the CoUrt
Pursuant to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither
shall herealler be under any legal obligations to support the other, pay any expenses for maintenances,
funera~ buria~ or otherwise for the other, and to that end each of the parties hereto does hereby waive
any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of
financial assistance whatsoever from the other, except as otherwise expressly provided for herein.
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of the other, and each agrecs with the other if either s1lould die intestate, his or ller share shall deseend
to vest in his or her heirs at Jaw, personal repreS<.'IItatives, and next of kin, excluding the other as
tllOugh he or she had died a widow or widower, And each further agrees that should the other die
testate, his or her property shall descend to and vest in those persons set forth in the others Last Will
and Testament as though the spouse so designated as beneficiary had predeceased the testator, The
Parties fiuther agree that they may and can herealler, as though unmamcd, without any joinder by him
or her, sel~ convey, transfer or encumber any and all real estate and personal property which either of
them now or herealler OMl or possess and fiuther agree that the recording of this Agreement shan be
conclusive evidence to aU of his or her right to do so. The said Husband and Wife do hereby
irrevoeably grant, each to the other, should the exercise of this power hereby given be necessary, the
right and the power to appoint one or more times any person or persons whom the Husband or Wife
shan designate to be the attomey-in-filct for the other, in their name and in their stead, to execute and
acknowledge any deed or deeds, releases, quit claims, or satis/i1ctions, under seal or otherwise, to
enable either party hereto to alienate his or her real or personal property, but without any power to
impose personal liability for breach of warranty or otherwise, Each of the paIties hereto fiuther waives
any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code,
and any right to seek or have an equitable distn'bution of mamed property ordered by the Court
P1U'Sllant to Section 3502 of the Divorce Code. Each of the paIties hereto fiuther agrees that neither
shan hereafter be under any legal obligations to support the other, pay any expenses for maintenances,
funeral, burial, or otherwise for the other, and to that end each of the paIties hereto does hereby waive
any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of
financial assistance whatsoever from the other, ~ as otherwise expressly provided for herein.
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5. Division of Personal Property.
The parties hereto mutually agree that they have effected a satisfactory division of the filmiture,
household furnishings, appliances and other household personal property bctwet:n them. and they
nmtually agree that each party shall from and aller the date hereofbe the sole and separate owner of all
such tangible personal property presently in his or her possession, whether said property Is hen.'tofhre
owned jointly or individually by the parties hereto, and this Agreement shall have the elli:d of an
assignment or bill of sale from each party to the other for such property as may be In the Individual
possessions of each of the parties hereto.
Further, the parties hereto have divided between themselves, to their rnlllual sallslnctlon, all
items of tangible and intangible marital property including band accounts and investIlK.'nts. Nehher
party shall make any claim to any such items of marital property, or of the Sl:parale persollal property
of either party, which are now in the possession and/or under the control of the otller.
From and after the date of the signing of this Agreement both parties shall have complcte
freedom of disposition as to their separate property which is in their possession or control pursuant to
this Agreement and may mortgage, sel~ grant, convey or otherwise encumber or dispose of such
property, whether real or persona~ whether such property was acquired before, during or after
marriage, and neither Husband nor Woe need join in, consent to, or acknowledge any d~'Cd, mortgage,
or other instrument of the other pertaining to such disposition of property,
MOBILE HOME: The parties acknowledge that they aTe the joint owners of a 11)l}5
Redman mobile home, The parties agree to offer for sale the mobile home and to divide the nL'!
proceeds equally from said sale. The parties further agree to sign w1l8t~"Ver docurn~'lIs are necessary 10
effectuate said sale. The parties agree to accept any offer sllmci~'1I 10 cover Ihe oulstandlnlllllan on
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the home. Pending sale of the mobile home, husband will continue to make the monthly mortgage
payment and he will be reimbursed from the sale proceeds, if any from the date that he has not
occupied the mobile home. In the event that an offer is received on the mobile home that is not
sufficient to cover the outstanding loan, it will be at husband discretion whether or not to accept the
offer and he will bear the responsibility of paying any and aU costs of sale, including the funds ncccssaJY
to payoff the mortgage,
AUfOMOBILES: The parties acknowledge that they are the joint oWllers of two
automobiles, a 1997 GMC Sonoma truck which is the primary mode of transportation of Husband and
a 1996 Dodge Stratus which is the primary mode of transportation ofWtfu, At the time of separation,
the parties have taken possession of their respective vehicles and have refinanced them to their mutual
satisfilction.
6, Debts. Husband agrees to assume the debt associated with the Visa credit card at
accaWlt No. 406095200291 6477 with an approximate balance of$2,000.00, The parties agree to be
responsible for their individual debts which are presently in their names. The parties agree to indemnify
the other for any outstanding marital debts in the event of demuh.
7. Future Debts. The parties further agree that neither will incur any more future debts
for which the other may be held liable, and if either party incurs a debt for which the other will be liable,
that party incurring such debt will indemnify and hold the other harmless from any and all liability
thereof
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Real Property. None.
9.
SuPPOrt. Alimony and Alimony Pendente Lite. Husband shall pay Wife, as
support, alimony pendente lite and alimony, the sum of Three hWldred sixty-two dollars ($362.00) per
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month, beginning on March I, 1998, payable on the first dllY ol'ellch lIIolllh Iilr II period lI1'sl,~ (6)
years.
Alimony payments made pursuant to this paragraph shall he pllld dh'ClIy 10 the DOlllestlc
Relations Office in accordance with a separate Order of Court Oil or he/ill'll Ihe first (I.) day of each
month. Alimony awarded pursuant to this paragraph sllall cease up un either IllIshand or Wife's dealh,
WIfe's remaniage or Wife's cohabitation. For purposes of this Agr~'CIII~'1ll, II Is Iile inl~'Iltloll ol'the
parties that Wife's continuous sharing ofa residence wit/I a ll1ember ol'the OPPIls/le HeX fllr a period in
excess of ninety (90) days shall constitute cohabiralion, 'I11e alimllllY awarded pursuanl III this
PIlrllgrJlph.shallbe taxable to Wife's income at the amount 111'$362.00 per month COll1l11t.'Ilcing March
], ]998, and dedueted from Husband's incoll1e at the amoUlI1 of $362,00 per month COll1mencing
March. 1,.1998.-in accordance with all tax laws and Internal Rcv~'Ilue Service Rules and Regulations.
The parties agree to reduce this Agreement to an Order of court Upon the written r~'quest of either
pany.
The parties acknowledge that the alimony provisions herein have bC\.'Il negotiated to take into
account the parties overaJ/ economic circwnSlances and neirher will St.'Ck a 1II0dlfication hereof in any
court.
10.. Cbild SUPPOrt. The parties hereto acknowledge that Husband shall pay a basic child
support award in the amount 01'$543.60 per month comm~'Ilcing August 14, 1998, which amount may
be ,modified from time to time through application to the Domestic Relations Office. 'This agTeelJleot
sball be enforced by the Domestic Relations Office.
] L Custody. The parties agree that they slrall sllal'll legal custody of the two children and
that Wife shall have primary physical custody of the chiJdr~'Il, with Husband having periods of partial
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custody as the parties agree. Husband may take the children out of the jurisdiction but agrees to return
the children at Wife's request.
12. Military Pension. Husband recognizes that the pension that he earned while an active
member of the military is a property asset diviSIble as part of this property settlement agreement. The
parties were married on August 16, 1984 and were separated on February 13, 1998. Since the parties
have been married and lived as Husband and Wife for 162 months of the Husband's military service
. prior. to this agr"-"""""t, _ the parties agree that the pension sha1l be divided pursuant to a Qualified
Domestic Relations Order consistent with the tenns of this agreement. That portion of Husband's
military pension which was earned during the parties' marriBge sha1l be divided in such a manner that
fifty percent (50%) of the pension sbaD be paid directly to Wife and fifty percent (50%) to the Husband
ona.deferred distribution basis. In detennining.the marital portion of the pension, a fraction in which
the numerator representing the total months that the parties lived together as Husband and WJfu and a
denominator in which the Husband's total mnnth ofmilitary service sha1l be calculated and nw1tiplied
by fifty percent (50%) representing the Wife's interest and fifty percent (50%) representing the
Husband's interest. The parties sha1l execute. any and all documents necessary to effectuate this
distribution. WIfe sbaD be responSIble for preparation of the Qualified Domestic Relations Order.
Husband waives any right to Wife's pension. WJfu waives any right to Husband's swvivor
death benefit.
13. Health Insurance. Husband agrees to continue to provide health insurance for the
children at his expense until they reach the age of eightcen or graduate from high school or post-
5eCnnd.'Y school It is understood by the parties that Wife sha1l be covered by Husband's health
insurance untIl the entry of a divorce decree. Upon entry of a divorce decree, Wife acknowledges that
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she will be responsible for her own health insurance,
14. Counsel Fees and Court Costs. The parties agn..-c that thcy shall be responSlole for their
respective legal fees and court costs incurred in the process of any divorce action or separation
agreement.
IS. Life Insurance. Husband agrees to maintain a $200,000.00 life insurance policy naming
the children as beneficiaries until the children arc age 18 or out of high schoo~ whichever oceurs first.
Proof of said coverage shall be furnished at the time of the execution of this agreement and thereafter
at reasonable intervals.
16. Post-secondary Costs. Husband agrees to pay fifty percent (50%) of aD costs incurred
relative to the children attending a college or technical schoo~ including but not limited to tuition, room
and board, ,books costs for the chiWren after the children. apply for all available loans, grants, financial
aid and work study programs. Husband's college costs responSloility shaD not exceed the cost to him if
the children were to choose a state sponsored schooL This obligation shall continue for four (4) years
of post-secondary education so long as each child maintain full enrollment at the institution of her
choice.. The parties agree that the obligation for educational costs is not dischargeable through the
Bankruptcy Code.
11.., Divorce. The parties acknowledge their intention and ~t to proceed in an
action in divorce to obtain a final decree in divorce by mutual consent on the grounds that their
"",rriAge is irretrievably broken, and to settle amicably and fully hereby aD claims raised by either party
in any divorce action. The parties agree to execute any and all docwnents neceSSSJy for the entry of a
final divorce decree.
18. Breach. In the event that either party breaches any provision of this Marital Property
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ond Settlement Agreement, he or she sholl he responsihle lilr ony IInd 1111 cosls Incurred to L'Illilrce the
teons hereof, including. but not limited to, court costs and reasonable coun!ic:llt'Cs of the other party,
In the cvent ofbrcach, the other party shall have the right, ot his or her c1~'Ction, to sue for dall1Rges for
such breach or to seck. such other and additional remedies as may be available to him or her,
19. Enforcement, The parties agree that this Il1Rrital settlement agreement or any part or
parts hereof may be enforced in any court of competent jurisdiction,
20, Applicable Law and Execution, The parties hereto agree that this Il1Rrital settlement
asreemem shaI1 be construed under the laws of the Commonwealth of Pennsylvania and shaD bind the
parties hereto and their respective heirs, executors and assigns. This document shall be executed as
~aI and multiple copies.
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21... The Entire Agreement The parties acknowledge and agree that this marital
settlement agreement contains the entire understanding of the parties and supersedes any prior
agreemem between them. There. are no other representations, wammties, promises, COvenants or
understandings between the parties other than those expressly set forth herein.
22.. Incorporation and Judgment for Divorce. In the cvent that either Husband or Wife
at any time hereafter obtain a divorce in the action for divorce presently pending between them, or
otherwise,.this agreement and an ofits provisions shaI1 be. incorporated but not merged into any such
judgment for divorce, either directly or by reference. The Court, on entry of jUdgment for divorce,
shaI1 retain continuingjurisdiction over the parties and the subject matter of the agreement for the sole
purpose of enforcement of any of the provisions thereofl\l1d not for modification of this agreement.
23.. AdditionaI Instruments. Each of the parties shaI1 on demand or within a reasonable
period thereafter, execute and deliver any and all other documents and do or cause to be done any
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other act or thing that may be necessary or desirable to effectuate the provisions and pUl]loses of this
Agreement. If either party fails on demand to comply with this provision, that party shall pay to the
other all atlomcy's fees, costs, and other expenses reasonably incurred as a result of such failure.
IN WITNESS WHEREOF, the parties have Set their hands and seals the day and year first
written above.
WITNESS:
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6, As and for her property interest in Member's military retired pay, Former Spouse
Is awarded flAy pereent (50%) of that portion of the monthly disposable retirement
annuity which is calculated by multiplying the monthly disposable retirement annuity by
a fraction, the numerator of which is 162 months and the denominator of which is the
number of months creditable to Member for retirement. Said amount so calculated shall
be a fixed amount and will be Former Spouse's entitlement even though Member may
increase that amount of retired pay waived in order to obtain disability compensation
from the Department of Veterans' Affairs. Furthermore, the said amount shall not be
reduced even ifit exceeds one hundred percent (100%) of Member's disposable retired
pay as defined in the Uniformed Services Former Spouses' Protection Act.
7. Former Spouse's interest shall terminate only upon the death of either party and
shall not terminate upon the remarriage of Former Spouse,
8. The Act authorizes a former spouse of a retired military member to obtain court
awarded payments from a member's retired pay directly from the member's service
finance center.
9. In order to effect service on the service finance center so that direct payments can
be sent to Former Spouse, certain information must be provided to the finance center. In
order to initiate such payments, Former Spouse shall process an application that is in
conformity with the Act, as follows:
The following information shall be sent to DFAS-CUL, Cleveland, Ohio, by personal
service, or certified or registered mail return receipt requested:
a. A certified copy of all orders of this Court relating to these parties that has been
certified within ninety (90) days of the date the Center receipts for the application;
b, A statement signed by Former Spouse requesting direct payment that includes the
following language:
"I request direct payment from the retired pay of Christopher Zawatski, whose
social security account number is , in accordance with the
enclosed court order, I certifY that the court order is a final decree and has not
been amended, superseded or set aside. As a condition precedent to payment, I
agree that any overpayments are recoverable and subject to involuntary collection
from me or my estate, and that I will notifY the Uniformed Service if the operative
court order, upon which payment is based, is vacated, modified or set aside, I
also agree to notifY the Uniformed Service of a change of eligibility for payments,
This includes notice of my remarriage, ifunder the tenus of the court order or
laws of the jurisdiction where it was issued, remarriage eligibility for child
support payments by reason 'lfthe death, emancipation, adoption or attainment of
majority of a child whose support is provided through direct payments from
retired pay. ..
c. The address, or account and bank routing information, to which the payments are
to be made.
10. Member is appointed as trustee for the benefit of Fonner Spouse to the extent of
her award of a portion of his military retired pay. Member will pay to Fonner Spouse her
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said share no later than five (5) days after he receives a payment from the Finance Center.
This paragraph shall be applicable until a direct payment takes effect so that Fonner
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Spouse will receive her payment directly from the Finance Center and shall be effective
for any month for which Fonner Spouse does not receive full direct payments from said
Center.
11. Member will pay Fonner Spouse her interest in his retired pay as herein provided.
Member is not relieved of this obligation except to the extent that he is notified that the
interest of Fonner Spouse has been paid directly to her by the servicing Finance Center.
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I'ATRICIA A.1.AWATSKI.
l'Ialntlrr
IN 'I'm: COLJRT m" COMMON PU:AS OF
c:llI\lIJt:RLAND C;OlINTY.I'ENNSYIN ANIA
CIVIL ACTION - LAW
NO. 98-1128
V.
CIIRISTopm:R l.AWATSKI.
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:
I. Grounds for divorce: irretrievable breakdown under Section 3301 (c), 3391 (.1)( I) of
the Divorce Code. (Strike out inapplicable section).
2, Date and manner of service of the Complaint: AcceDtance of Service bv counsel of
record dated March 9. 1998.
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3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by sec. 3301 (c) of the
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Divorce Code: by plaintiff October 19. 1998; by defendant October 18. 1998.
(b) (I) Date of execution of the affidavit required by sec. 3301 (d) of the Divorce
Code:
; (2) Date of filing and service of the
plaintilP s affidavit upon the defendant
4, Related claims pending: None
5. Complete either (a) or (b). _
(a) Date and manner of service of the Notice of Intention to file Praecipe to transmit
:,
)
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record, a copy of which is attached
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(!!) Dalc plainlitrs Waivcr ofNolicc in scc, 330/ (c) Divorcc was li/cd with thc
I)rothonotary: Novcmbcr 30. 1998,
Datc dcfcndant's Waivcr ofNolicc in scc. 3301 (c) Divorcc was li/cd with IItc
Prothonotary: Novcmbcr 30. 1998,
Date: 11/30/91
~~hi~c;A.~
Ito y for Plaintiff -J'
Jacquclinc M, Vcrney, Esquire
44 South Hanovcr StrcCl
Carlislc, PA 17013
(717) 243-9190
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PATRICIA A. ZAWATSKI,
l'lainliff
vs,
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 98- /0';' CIVIL TERM
CIIRISTOPIIER ZAWATSKI,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGIITS
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
will proceed without you and a decree in divorce or annulment may 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 or 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 First Floor, Cumberland County Courthouse, South Hanover Street,
Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED,
YOU MAY LOSE THE RlGl-IT 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.
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Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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PATRICIA A. ZAWATSKI.
Plaintiff
IN TIlE COURT or COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO. 98- /1.1 P'CIVIL
CIIRISTOPIIER ZAWATSKI.
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF TilE
DIVORCE CODE
Carlisle, Cumberland County, Pennsylvania 17013.
AND NOW comes Patricia A. Zawatski, plaintiff herein, by and through her attorney, Jacqueline
M, Verney, Esquire, and represents the following:
1. Plaintiff is Patricia A. Zawatski, an adult individual, currently residing at 103 Dawn Drive,
2. Defendant is Christopher Zawatski, an adult individual, currently residing at 103 Dawn Drive,
Carlisle, Cumberland County, Pennsylvania 17013.
3. Plaintiff and Defendant are bona fide residents oftbe Commonwealth of Pennsylvania and
have been so for at least six months immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on August 16, 1984 in the state of Virginia.
S. There have been no prior actions for divorce or annulment hetween the parties.
6, Defendant is presently enlisted in the United States Marine Corps.
7. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiffmay
have the right to request that the Court require the parties to participate in counseling,
Having been so advised Plaintiff does not desire the Court to order counseling.
8, This marriage is irretrievably broken.
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WHEREFORE, Plaintlffprays Your Honorable Court enter a decree in divorce,
Respectfully submitted,
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,Ucq line M. Verney, Esquire 2J
Supreme Ct. 10. 23167
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
Attorney for Plaintiff
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VER.....CATlON
I verify that the b1atemcnts made in the foregoing divorce complaint are true and correct.
· understand that false statements herein made are subject to the penalties of I 8 Pa,C,S, Section
4904 relating to unsworn falsification to authorities,
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, . lAW O[fICE OF .
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Jacqueline M. Verney
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,',441, HANOVlAST, . CAAUllE, PA 17011 . (717) 243-9190 . fAX (717) 24].]518
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PATRICIA A. ZAWATSKI,
P1nintiff
IN TilE COllRT 0..' COMMON PLEAS 0..'
CUI\Un;RLAND COUNTV,PENNSVLV ANIA
v.
CIVIL ACTION - I,A W
CIIRISTOPIIER ZA W ATSI,
Defendnnt
: NO. 98-1128 CIVIL TERM
IN DIVORC..:
AFFIDA VIT OF CONSENT
I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on March 2, 1998 and service of the complaint was accepted by counsel of record
on March 9, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry ofa 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,
section 4904, relating to unsworn falsification to authorities.
Date: cd- / 1, /99 r
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LAW OIf1CE OF .
~queline M. Verney
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~41. HANOV1UT. . CAAUIll. PA 17011 . (717) 24109190 . fAX (717) 24].]518
CIIRISTOPIlt:R ZA W ATSKI,
Defendant
IN DIVORCE
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IN TilE COURT 0... COMMON PLEAS OI~
CUMBERLAND C0I1NTV ,PENNSVIN ANIA
CIVIL ACI'ION - LAW
NO. 98-1128 CIVIL TERM
PATRICIA A. ZAWATSKI,
Plaintiff
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRV OF A DIVORCE
DECREE UNDER SECfION 3301 (C) OF THE DIVORCE CODE
I, I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verifY that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904
relating to unsworn falsification to authorities.
Date: (Jd
/1, /9fY
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LAW OFIICE OF .
. Jasquellne M. Verney
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(44S,HANOVUST. .wusu,rA17013. (711)241.9190. fAX (717) 241,lllB
.
PATRICIA A. ZAWATSKI,
PIointiff
IN TilE COURT 0.' (;OMMON PU:AS 0.'
ClIMOt:RI,ANI) COUNTY ,Pt:NNSYIN ~I~J
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CIVIl, ACTION -I,AW
NO. 98-1128 CIVIl, n:Rl\1
CIIRISTOPIIER ZAWATSKI,
Derendont
IN DIVORCE
WAIVER OF NOTICE OF INTENTION 1'0 REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301 (C) m'TIIE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice,
2, I understand that I moy lose rights concerning olimony, division of property, lawyer's
fees or expenses if! do not c10im them before 0 divorce is gronted.
3. I understand thot I will not be divorced until 0 divorce decree is entered by the Court
ond thot 0 copy of the decree will be sent to me immediately ofter it is filed with the
prothonotory.
I verify thot the statements mode in this affidovit ore true ond correct. I understond
that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904
relating to unsworn falsification to authorities.
Date:
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