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HomeMy WebLinkAbout98-01249 ,] ; ~j ~. ... u .'" ~l ~ \II '> ~I .... \II o . ~'f ~. ~ I , \ \ \ \ " , " y / I I: ... ~ ~I .'::) I "'1 ~I ~I ')o! ril ........ . b.,. (.)0-\ c;i ~ .:+:.- <+:.' -=+:.' .:+:. .:+:,'.:.:. .:+:.,-.:+:. .:+:. .:+:. .:+:. .:+:. .:+:. .:+> -:if!'< -:+:- <4..; ,~.> .:+> -:.~, :. -:+;<~-=+~<>=+:.:-:+>,.:.} ,~.:. .~+:' ':+:"":C:.-::'~~ ~ .~,.>_~~v,_~~~_.",_~___~.__.v,-_~_~>",_-, _,,_.. ".. .__~_ ...-, .."'.... ,.._.v'",,, .v...,.. .-__....._......~~,,_ ~ ~ f', ~ '.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY It, STATE OF 1~. PENNA, '" :, ~ 'i t, ~ w '.' ~I <;> ~ .:i " LORI KRAJCSIK, I' II II N (), ..,1.;::.<19".",..""".... t 9 'Mil Ii -" ~ '" ~ Plaintiff ~ ',' V(,I''':;U.~ ~ ~ ROBER1.' KRAJCSIK, i Ii q ;1 " ~ ... Defendant t, ~ ,i, t, ~ ~ DECREE IN DIVORCE ,', ~ ,', * M .. ,,- ,;, " AND NOW, ' , , . , , " , A1~dr , , ;1" , " " 199f.", it is ordered and decreed that ,Lor.i"~~~>csik""",,,,,,.,,,,,,,,,,,,,,,,,,,, plaintiff, and, , ,f\9~E)J;'t., ,~r:<;ljP,~~J:; . . . " , . . , , , , . .. , " , , , , , , , , , , , , , , , , , " defendant, (lre divorced from the bonds of matrimony, The Marital Settlement Agreement dated February II, 1999 is hereby incor~orated but uot,merq~d,herein " , me court retains IUI'IStllctlon 01 The followlrIg claims whIch have been raised of record in Ihis action for which a final order has not yet been entered; ~ ~ ,;, " " " ,;, ~ ,;, " ,;, !' ~ ~ ."""",.""".".""". """"""""""""", " r.~ .........".,..,..,.""..",.,....,......, , ~ ... ! "dhC:;,;i I: ~ Alle.t,/ <1~",i.J ,p X..,.~ A<'!,k~~ J, I~ 8 ;/r)' f((:L ;-' ,~f xJ.'J I::: " ,r r; I~ ~ PI'lIIhol101nry I ~ M~,,-_..-____"'_A_~____,..____'..n..' ".. ,.. i~ .~:. "', ->>:. .>>:. .:+:. .>>:. .:.:. .:c. .:+:. .:+:. .~~. .:.:. ,:+> .~+:. ,~.:' .:+:. .:+:. .:.:. .~+:. <+:' 0:.> -:.:- ':+;. ':6:- ':.:' .:.:. -:.:, .:+> .:.~, .:+:,' ~ ,~ ~ ',' ~ ~.~ ~ '.' .:; ~ ~ " l~ ~ ~ ',' ~ 'l ,'j ~ ~ ~ " r.'~ " ~ ,'~ ~ ~ ~ !,l i.=., ~ ~ I: ~ ~.. 'c, ~ ~ ~ ~ \,1 ,', ~ W ~.~ ~ ',' W 'i I ~ ... ~ " .. . . MARITAL SETTLEMENT AGREEMENT I'" I. AGREEMENT, made this 1L day of ft."" , 1999, by and between LORI A. KRA.JCSIK, hereinafter referred to as "Wife", and ROBERT A, KRAJCSIK, hereinafter referred to as "Husband". WITNESSETH: WHI~:REAS, the partics hercto are Husband and Wife, having been married on Septcmber 26, 1987, and therc are two children born of this marriage, Ashley N, Krajcsik, born November 21, 1989, and Andrew A Krajcsik, born July 16, 1992; WHEREAS, diverse unhappy differenccs, disputcs and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the patties hercto are dcsirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: thc settling of all matters between them relating to the ownership of real and personal propcrly, the equitable distribution of such property; the settling of all matters betwecn them relating to the past, present and future support and/or maintenancc of Wifc by Husband or of Husband by Wife; the settling of all matters between them relating to the parties' minor children including custody, visitation and support; and, in gcneral, thc settling of any and all claims and possible claims by one against the other or against their rcspcctive estates, NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter sct forth and for other good and valuable considerations, receipt of which is hereby acknowledged by each of thc parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: I. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS. This Agreement shall not be considered to affect or bar the right of Wife or Husband to a divorcc on lawful grounds if such grounds now exist or shall hereafter exist or to such defensc as may be available to eithcr party, This Agreement is not intended to condone and shall not be deemed a condonation on thc part of either party hereto of any act or acts on the part of the other party which have occurred prior to or which may occur subsequent to the datc hereof. 2, EFFECT OF DIVORCE DECREE, The parties agrcc that, unless otherwise specifically provided herein, this Agrecment shall continue in full forcc and effect after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the partics hereto that this Agreement shall create contractual rights and obligations entirely independent of any Court Order and that this Agreement may bc enforced by contract remedies in addition to any other remedics which may bc available pursuant to the tenus of this Agreement or otherwise undcr law or equity, 3, AGREEM~T TO BE INCORPORATED IN DIVORCE DECREE. The parties agree that the terms of this Agreement shall be incorporated, but not merged, into any divorce decrcc which may be cntered with rcspect to them. The parties further agree that the COllrt of Common Pleas which may enter such divorce decree shall retain continuing jurisdiction over the parties and the subject matter of the Agreement for the sole purposc of enforcement of any of the provisions thereof and not for modification of the Agreement. 2 4. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be dcfined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution dale" of this Agreement shall be defined as the date of execution by thc party last executing this Agreement. S, ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have becn fully cxpluined to Husband by his attorney, Diane S, Baker, Esquirc, and to Wife by hcr allomey, Catherine A, Boyle, Esquire, The parties acknowlcdgc that thcy fully understand thc facts and they acknowledgc and accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and voluntarily and that execution of this Agreement is not the result of any duress or undue influencc and that it is not the result of any collusion or improper or illegal agreement or agreements. The partics further acknowledge that they have each made to the other a full and complete disclosure of their respectivc assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purposes of this Agreement. Each party agrees that he and she shall not, at any future time, raise as a defense or otherwise thc lack of such disclosurc in any legal proceeding involving this Agreement, with the exception of disclosure that mny have been frnudulently withhcld, 6, PERSONAL RIGHTS. Wife and Husband, at all times hereafter, may and shall live separate and apart, They shall be free from any control, restraint, interference or authority, direct or indirect, by thc othcr in all respects as fully as if they were unmarried. They may reside, 3 .. " at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other or compel or attempt to compel the other to cohabit or dwell, by any means or in any manner whatsoever, with him or her. 7. SUBSEQUENT RECONCILIATION. The parties agree that the terms of this Agreement shall not be affected by their subsequent co-habitation or resumption of marital relations, unless the parties otherwise specifically agree in writing, 8. MUTUAL RELEASES.. Except as provided herein, Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of the other, for all time to come, and for all purposes whatsoever, of and trom any and all rights, title and interests, or claims in or against thc property (including income and gain from property hereafter aecming) of the other or against the estate of such other, of whatever nature or wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of the other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of the 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 exemption 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 surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territOlY of the United States, or (c) any other country, or any rights 4 which either party may have or at any time hereafler shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, 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 arise under this Agreement or for the breach of any provision thereof. 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 therC'of. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may havc against the other forequitablc division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the 'Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 9, RETIREMENT ACCOUNTS AND PENSION PLANs.. Both parties are employed and as a result of their respective employment may be entitled to certain pension and retirement benefits, a portion of which arc marital property. Wile hereby waives any rights which she may have to any employment related retirement accounts, pension plans or deferred compensation plans of Husband. Husband agrees that he hereby waives any rights which he may have to any employment related retirement accounts, pension plans or deferred compensation plans of Wife including her Individual Retirement Account with Dauphin Deposit Bank and 5 - Tmst, account number 616 707 7673. All such accounts and pension plans shall be the sole and separate property of the party in whose name the account or plan is titled. Each party shall execute all documents necessary to give effect to this paragraph. 10. PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have or will divide their tangible personal property, including, but without limitation, jewelry, clothes, fumiture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property in as equitable a manner as possible. The parties do hereby specifically waive, release, renounce and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. II. AEIE&ACQ.UlBED PERSONAL PRO.rE.RIY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in alll'espects and for all purposes, as though he or she were unman-ied, 12. AUTOMOBILES. The parties are the owners ofa 1995 Chevrolet Monte Carlo which shall become the sole and separate property of Husband who agrees that he will be solely responsible for the loan on said vehicle with Member's First Credit Union, account number 36246-03 and shall indemnify and hold Wife harmless therefrom, The parties are also owners of a 1996 Pontiac Orand Am which shall become the sole and separate property of Wife who agrees that she will be solely responsible for the loan on said vehicle with Member's First Credit Union, 6 account number 167 222 and shall indemnify and hold Husband harmless therefrom. Both parties agree to execute all documents nccessary to implement this paragraph upon request. 13. BANK ACCOUNIS. The parties acknowledge that they have previously divided their joint bank accounts and have no remaining joint bank accounts. Any individual accounts owned by the parties shall become the solc and separate property of the party in whose name the account is currently titled and both parties waive any rights they may have to the bank account(s) of the other. 14. ClJRRENT LIABILITIES. Except as may be set forth elsewhere in this Agreement, the parties agree that they have no joint liabilities, All remaining debts accumulated during the marriage are in the sole and separate name of the individual parties and shall become the sole and separate responsibility of the named party who shall indemnify and hold the other harmless therefrom, 15. WARRANTY AS TO EXISTING OBLIGATIONS. Each party represents that they have not heretofore incurred or contracted for any debt or liability 01' obligations for which the estatc of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmlcss for and against any and all such debts, liabilities or obligations of every kind which may have hcretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 16. WARRANTY AS TO FUTURE OBLIGATl!llis.. Wife and Husband each covenant, warrant, represent and agree that, with the exception of obligations set forth in this 7 Agreemcnt, neithcr of them shall hereafter incur any liability whatsoever for which the estate of the othcr may be liablc. Each pal1y shall indemni fy and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agrcement, cxcept as may be otherwise specifically provided for by the tenns of this Agreement. 17. REAL ESTATE. MARITAL RESIDENCE. The parties were previously the owners of a marital residence located at 37 Creek Road, Camp Hill, Pennsylvania which was sold in July of 1998 and the proceeds from the sale were divided to the satisfaction of both parties, The tax consequenees of the sale shall be divided equally between the parties. 18. PAST DUE TAXES, The parties have heretofore filed joint Federal and state tax retums. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely hy the individual who is finally determined to be the eause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 19. 1998 INCOME TAXES. The parties agree that they shall file joint federal, state and local income taxes for the 1998 tax year, In the event that the parties arc entitled to a refund or owe taxes they agree to be equally responsible for the debt or divide the refund. 20. TAX DEDUCTION FOR CHILD, 8 The parties acknowledge that the pal1y having primary physical custody of the minor children shall be cntitled to claim the child dependency tax exemption, deduction or credit for federal, state and local tax purposes. 21. BANKRUPTCY, It is hereby understood and agreed by and between the parties that their obligations pursuant to this Agreement shall not be affected by any bankruptcy proceeding and shall not be deemed to constitute or be a dischargeable debt of a bankruptcy. Both parties warrant that he/she has not heretofore instituted any proceedings pursuant to the bankruptcy laws nor are there any such proceedings pending with respect to him/her which have been initiated by others, 22. WAIVER OF PAYMJrnI. OF' LEGAL FEES. Wife shall be responsible for payment of her legal fees. Husband shall be responsible for payment of his legal fees, 23. i\LIMONY. ALIMONY PENDENTE LITE AND SeOUSAL SUPPQRL Wife and Husband do hereby waive, release and give up any other rights they may respectfully have against the other for any alimony, support or maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any additional support from the other party, except as provided herein. 24. CUSTODY, Husband and Wife shall share legal custody of their minor children Ashley and Andrew and shall cooperat.e and consult with each other concerning major issues such as edueation, religion and medical decisions. Wife shall have primary physical custody and Husband shall have partial physical custody as agreed upon by the parties. The parties agree that this is a tentative schedule and they shall work together to modify the schedule as necessary to serve the bcst interests of their children. In addition to the aforementioned schedule the parties 9 shall share or alternate major holidnys and the children's birthdays. Both pal1ies shall be cntitled to a minimum of thrce weeks eithcr consecutivc or non-consecutive vacation time with the children provided they give the other party thirty (30) days written notice of the intended vacation schcdulc, 25. SUPPORT, Husband shall pay support to Wife for the children in the amount of $215 per week which includes one-half of the day care expcnses. This amount may be modified by either party in accordancc with the Supreme Court Support Guidelines, Both parties agree to notify one another of any increases in income from any source within ten (10) days of being notified of said increasc. 26. HEALTHCARE COVERAGE, Wife shall provide medical coverage for the minor children so long as it remains available to her at a reasonable cost through hcr employment. Husband shall provide dental coverage for the children so long as it remains available to him at a reasonable cost through his employment. Unreimbursed medicals including co-pays, deductibles, dental and orthodontia expenses shall be shared by the parties in proportion to their net monthly income as expressed as a percentage of the combincd monthly income. Wife shall continue to provide medical coverage for Husband until such time as a final decree in divorcc is entered. Husband shall continue to provide dental coverage for Wife as available to him through his employer until such time as a final decree in divorce is entered. In the event that Husband is unable to provide dental coverage for Wife as set forth above, he shall reimburse her directly that portion of any dental bill incurred that would have been covered by dental insurance. 27. UFE INSU~ Any life insurance policies owned by the parties 10 shall become the sole and separatc property of the party in whose name thc policy is in. Both parties specifically waive any rights which they may have to said policies by virtue of having been a namcd bcncficiary thercon, The parties do however acknowledge that they may voluntarily designate the other as their bcneficiary and it is therefore agreed that failure by either party to remove the other as their stated beneficiary shall be interpreted as all intentional act designating the other as thc intended beneficiary, 28. APJ>LICABILlTY Oil TAX LAW TO PROPERTY TRANSFERS. Thc parties hereby agree and express their intent that any transfer of property pursuant to this Agreemcnt shall be within the scope and applicability of the Deficit Reductioll Act of 1984 hereinafter thc "Act"), specifically, the provisions of said Act pcrtaining to the transfers of propcrty between spouscs and former spouses. The parties agree to sign and causc to be filed any clections or other documents required by the Internal Revenuc Service to rendcr thc Act applicable to the transfers sct forth in this Agrecmcnt without rccognition of gain on such transfcrs and subject to the carry-over basis provisions of the said Act. 29. DlS!;LOSURE. The parties acknowledge that there has bcen full and fair disclosure to the other of his or hcr respective incomc, assets and liabilities, whether they are held jointly or in thc namc of one party alone. Any and all other accounts, investments, property lights, contract rights, business interests, retirement accounts and other retirement vehicles and insurances, not specifically mentioned herein, and of whatsoever nature of either of the parties is subject to the Divorce Code of Pennsylvania. 30. MUTUAL CONSENT DIVORCE. The parties agree and acknowledge that II their marriage is inetrievably broken, that they do not dcsire marital counseling, and that they hoth consent to the entry of a decree in divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (herein referred to as the Code). Accordingly, both parties agree to execute such consents, affidavits, or other documents and to direct their respective attorneys to file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301(c) of The Code. Upon request, to the extent pcrmitted by the law and the applicable Rules of Civil Procedure, the named defendant in such divorcc action shall execute any waivers of notice or other waivers necessary to expedite such divorce, 31. WAlYE.R..!lltMODIFICATlON TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent. default of the same or similar nature, 32. MUTUAl. COOPERA'1lillS, Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 33. LAWS OF P.EMSSYL V ANlA....APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 34. AGREEMENT BINDING.1JEIRS, This Agrcement shall be binding and shall 12 inure to the benefit of thc parties hcreto and their respcctivc heirs, executors, administrators, sucoessors and assigns. 35. OTHER DOCUMENTATIOl't Wifc and Husband covcnant and agree that they will forthwith (and within at least ten (10) days aftcr demand therefor) executc any and all writtcn instrumcnts, assignments, releases, satisfactions, deeds, notes or such other writings as may be ncccssary or desirable for the proper effectuation of this Agreemcnt. 36. NQ..W AlVEI! OF DEIIAUI:r. This Agrecment shall remain in full forcc and effect unlcss and until tenninated under and pursuant to the terms of this Agrcement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the samc, nor shalllhe waiver of any default 01' breach of any provision hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be eonstrued as a waiver of strict performance of any other obligations herein, 37. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, wananties, covenants or undertakings other that those expressly set fotth herein. The parties further acknOWledge that any previous agreements between them are incorporated herein. 38, EM'QRCEMENT OF.....AGREEMENr. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her selection, to sue for damages for such breach or to require specific performance. Thc party breaching this Agreement shall be responsible for paymcnt of legal fees and costs incurred by the other party in enforcing their 13 >. CO '.. n; C'; r.: ~, , ~-;: .. ) \U\~l f::J J ~td t'- :'(: ) "., It.._, (t. ~;~~.i ~4 )I.. 1 ~ ~-J (i) ft~: I N ! itl' en il:JiJ./ '.i LtJ !LL ,. 1.1.. ,; en :3 C) Q\ U ~ .' "- en (; 4; ('<'. ~:: <'~. .. :.~) ."r U-lr;,? - r:)tj) ~j(; "1'~ \...J ;~ "" t ...s.: t..'l ~~: I (" Cf.) ,'-, (/; [' .) ~.~ }" L !,c;g Ei.:i;, en i!,.!&, kl 1-'.) [.. u... ....;c. , 1.1- m ::J 0 c:r, u >- C1\ is. cr; (<', .,t "- I.~ .. h-? ~~t; LJ~q -. (,,}.;? (~- t ,; :C~ (.,1;/ t"" .,;C -;::':-1 ~v, ..'.').. 0':1 ,'-r'l/J Ie :' l~! :~~: L .:....:IU t.n UJlU rL" L<.J {"~ILl... I," u.. ':~i; b en ~:3 rn (.) , I . , ~ LORI KRAJCSIK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-1249 ROBER'f KRAJCSIK, Defendant CIVIL ACTION .. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301lCl OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2.. I understand that 1: may lose rights concerning alitnony, 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 decre will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are tru and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unswor falsification to authorities. ~ ~. Date f€6 1/, /fl1 ~- . 4_.-2. .. I' 1_ ROB, K J SIK. ___ Mf.VSRS, DESPOR, SALTZQIVER & BOVLE 0110 NORTH SECOND STREET . PO. BOX 1062 . HARRISBURO, PA 1'/108 (117) 2~HH~,120 . fAX (717) 2:W.2flI7 > 0' ~ r;; C'r-: j';~ .. ,:'J~ ~t1Cl ..-~ 0,,,, - .:T-N"; Jr" . r~ ..(;.. .. ,--. ';:-1, 1"'[ If:r r.)~j ,c"( (i't, 0::) ,',:1' {n 6 (, ,_J ;!i'; .:fLc _-II'! ,...'~ [neT; [j" "'--, " :c l,J ~_flr.l.. t lL. ~3 l.,l.. m 0 0"> (J . . ",:,.,;.;t",,,,Ii' -.,.~'- ,,, ., '.";." , . LORI KRAJCSIK, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-1249 CIVIL ACTION - LAW IN DJ;VORCE VB. ROBERT KRAJC8IK, Defendant CERTIFIED MAIL SERVICE CARD I also wish to lseelve the following s.rvlces (fol .n .ldr.I..): 1. 0 Addr......s Addr... 2)lit::'R.stl1c1.d O.lIvsry tf'M CompIttltt;'" 1 and'Of 2 tor addltlonalllMcll. COmptellltemt 3. 4'1 and 4b. I Pit"" yet' NOli and ,dd,"' on the revt.... 01 thl, foon 10 thai WI f.an rllum lhl, ~~~ I -Attach thII form to lhl front of Iht mallpltot:, or QO the bIdllf ap.ICie dol, not i _e:~R.,um Rec>>ipt RfqUOft~' 00 IhI mallpltee below the lf1lCle nu.-1lbIr. $I _The Rltum Rtc8lP' wiN show to wnom thllltldl WI' deIlYlted If\d lhe dlle 8 ~~. Cons~tmllstol fOI I... I ty;::a;sed~~I'~~I.--~ 4..A ~.7~.'6~/ ~3~ 'RiP,&::, I'-~~ 4b.SSMCO vp. ~ f't,/3tJ ':JJk'/;:'7iVtJtJ{) J)k'It/G 0 R.glstered ..s(eertlfted I /1 0 Express Mall 0 Insured .~ /!lItfl:/..-5',8t/A?6t ,/7 /7/// 0 RetumReoslpllorMerchan<llS 0 COD 'I 1.Datsof~~~\ _q~ t 8, Address..'s Addr.ss(Only" f8<'!lHISled 'I end '..Is psld) ~ 5. Received By: (Print Niiiii)- 1 1 \i 1\ " , [' 11 Ii ]I '\ MEVERS. DESFOR. SALTZGIVER . BOVLE "'0 NORTH seCOND STAen . P.0.1I0X 1062 . HAAAISBlJAG, PA 1710B urn ?~\tH)"28 . FAX (711) 230.2(117 L LAW OFFICE EDWARD J. WEINTRAUB 26!iO NORTtt':WIRIl.HREET HARIUSFllIRG, PENNSYLVANIA 17110 (71712:lH.2200 FAX (71712JH.9280 "..~~......A -~....,--~.-- -'-""'''''''''''''~~l'~\il!l4~~~i\=--,;",~_"";j""..",,,,;_..-.,~_,,_" .,,,,.,,, - ."".,",.-,~ ",,~~,~,.~ ~"~-'''''''O'''~''''_'''*''"''>"''''''''<-~~u, ,,"_,_..~.~+,,~. LORI A, KRAJCSIK Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLANI> COUNTY, PA * VS. * No, 98-1249 CIVIL * ROBERT A, KRAJCSIK Defendant * CIVIL ACTION - LAW * IN DIVORCE ffiAECIPEFOR WIIHDHAW_OEAPPEAMNCE Please withdraw my appearance on behalf of Plaintiff, Lori A. Krajcsik, In the above captioned matter without prejudice. Oa..:~DI _~yr;~' Edward J. Weintraub, Esquire PHAEC1PE_TO..ENTERAPPEARANCE Please enter my appearance on behalf of Plaintiff, Lori A. Krajcslk, in the above captioned matter. Date: biLl; (.alba" sumPI..sum,,;' Esqulra ,- ID G r.f;: LO f:"-' "'?': i,l I ,';, :") d' () ,oJ , .- !':) ':--.1 C1..,.. ~.1. u ; J :::.i , ! >..;. :_1' -~;;:Q , ....i' :r': lJlttl ::'.i ~q~ ---'j ..~- I I ::.:> C' f~ () - . ----~---- \,? ~j '-~~ .....,.~