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HomeMy WebLinkAbout03-0524GOP/~S, PLAINTIFF Vo ROBERT D. GOR~%S, DEFENDANT IN THE COURT OF COCA'ON pT.~%S CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 -~ CIVIL TERM IN DIVORCE NOTICE TO DEFEND A19D CLAIM RIGHTS YOU HAH BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 BARBARA E. ~OP/~S, PLAINTIFF Vo ROBERT D. GOP~S, DEFENDANT IN THE COURT OF CO~ON PLEAS C~H~BERLAND COUNTY, PENNSI~LVANIA NO. 2003 -~ CIVIL TEP/~ IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Barbara E. Gormas who resides at 8416 Oxford Drive, Mechanicsburg, Cumberland County Pennsylvania 17055. 2. The Defendant is Robert D. Gormas who resides at 251 Oak Grove Court, Mechanicsburg, Cumberland County Pennsylvania 17055. 3. The Plaintiff and Defendant have been bonafide 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 February 4, 1973 in Orwigsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The 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. 10. hereto. 11. Plaintiff requests the court to enter a decree of divorce. CLAIM I Claim for Equitable Distribution of Marital Property Paragraphs 1-9 are incorporated herein by reference The Plaintiff and Defendant are owners of certain jointly owned property or other property which constitutes marital property. WHEREFORE, Barbara E. Gormas requests this Court to enter an Order equitably dividing or assigning the marital property between the parties. CLAIM II Claim for Alimony Alimony Penclente Lite, 12. hereto. 13. Paragraphs 1-11 are incorporated herein by reference Barbara E. Gormas is without sufficient income and/or assets to support herself or pay attorney fees and is unable to fully support herself through appropriate employment. 14. Barbara E. Gormas requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE Barbara E. Gormas requests this Honorable court to enter an award of reasonable temporary or permanent support, alimony, APL and additional sums as they may become necessary from time to time hereafter until final hearing and permanently thereafter. Respectfully submitted, Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint are true and correct. 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: Barbara E. Gormas BARBARA E. GORMAS, Plaintiff VS. ROBERT D. GORMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-524 CIVIL TERM CIVIL ACTION- LAW IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Max J. Smith, Jr., Esquire, as counsel for Robert D. Gormas, Defendant in the above-captioned matter. Date: July ~-~, 2003 Max~J~S~mith j~ '. ' , r., Es)~re~t~ I.D. No. 32114 Jarad W. Handelman, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this /'/"' day of /Y~/'i'/ ,2004, by and between BARBARA E. GORMAS (hereinafter called "Wife") and ROBERT D. GORMAS (hereinafter called "Husband"). WITNESSETH: WHEREAS, Husband and Wife were married on February 4, 1973; and WHEREAS, There have been three (3) children bom of this marriage, to wit: ROBERT D. GORMAS, JR., born September 1, 1973, BRANDY B. GORMAS, born June 11, 1977, and BRADLEY R. GORMAS, born December 16, 1981; and WHEREAS, the parties hereto desire to fix and determine by this Marital Settlement Agreement the rights and claims that have accrued to each of them in the estate and real and personal property of the other by reason of the marriage, and all economic rights of every kind and description arising from the marital relationship, including but not limited to present and future rights of inheritance, support, maintenance, alimony, payment of counsel fees and equitable distribution and to accept the provisions of this Agreement in lieu of and in full discharge, settlement and satisfaction of all such rights and claims. NOW, THEREFORE, in consideration of the premises and of the marriage, and in further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2, INTERFERENCE. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and umnarfied except as may be necessary to carry out the provisions of this Agreement. 3. WIFE'S DEBTS. Wife represents and warrants to Husband that as of the date of separation she has not incurred, and in the future she will not contract or incur, any debts or liability for which Husband or his estate might be responsible and shall inderm~ify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Any and all loans, and/or debts and charge accounts presently in Wife's name alone shall be Wife's sole and separate responsibility for payment thereof, and Wife agrees to indemnify and save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by Wife. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the date of the separation he has not incurred, and in the future he will not contract or incur, any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Any and all loans, and/or debts and charge accounts, presently in Husband's name alone shall be Husband's sole and separate responsibility for payment thereof, and Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. 5. EOUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for the equitable distribution of their property by any court of competent jurisdiction pursuant to Section 3502 of The Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 6. REAL ESTATE. The parties agree that Wife shall grant, transfer, relinquish and convey to Husband all of her right, title and interest in the marital residence located at 251 Oak Grove Court, Mechanicsburg, Cumberland County, Pennsylvania. Wife shall execute a deed so transferring her equitable interest in the said premises to Husband contemporaneously with the execution of this Agreement. As consideration for Wife transferring her interest in the marital home to Husband, Husband shall pay to Wife the sum of One Hundred Twenty-five Thousand and 00/100 ($125,000.00) Dollars. Said sum shall be payable as follows: (a) $15,040.00 shall be payable upon execution of this Agreement; (b) commencing April 1, 2004, and continuing on or before the first day of each month thereafter for a period of eleven (11) years, Husband shall pay to Wife monthly payments in the sum of $833.00 per month, or a total of $109,956 over said eleven (i 1 ) year period; and (c) said installment arrangement shall be secured by a note and mortgage listing Husband as mortgagor and Wife as mortgagee, which mortgage shall be recorded as a first lien against the 251 Oak Grove Court premises. Husband shall be responsible for payment of all real estate-related expenses and household expenses, including but not limited to taxes, insurance and utilities. Husband shall indemnify and save ham~less Wife from any loss she may sustain, including attorney fees, as a result of any default in payment of the aforesaid obligations by Husband. 7. DIVISION OF PERSONAL PROPERTY, ACCOUNTS AND VEHICLES. The parties have divided between them, to their mutual satisfaction, the personal effects, bank accounts, household furniture and furnishings and all other articles of personal property which have heretofore been used by them in common. The parties expressly agree that Wife shall be entitled to exclusive ownership of the 2003 Mitsubishi Spider currently in her possession, and that Husband shall relinquish any and all interest he may have in same. Wife agrees to be solely responsible for payment of any and ali encumbrances, and all other expenses affecting such vehicle. Wife agrees to indemnify aod save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by Wife. Husband shall be entitled to exclusive ownership of the 2002 Honda Odyssey currently in his possession, and that Wife shall relinquish any and all interest she may have in same. Husband agrees to be solely responsible for payment of any and all encumbrances, and all other expenses affecting such vehicle. Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. The parties further agree to execute any vehicle titles, Powers of Attorney or other documents necessary to give this Paragraph full force and effect, upon request. 8. PENSIONS AND EMPLOYMENT BENEFITS. Husband and Wife are the owners of certain pension plans and/or retirement plans and/or employee stock or savings plans, which they have accumulated during the course of their past and/or present employment. It is hereby specifically agreed that Husband and Wife each shall forever relinquish to the other his or her fight, title and interest in said pension plans and/or retirement plans and/or employee stock or savings plans, as well as all other employment benefits, of the other. Specifically, subject to the provisions of paragraph 9 herein, Wife shall relinquish to Husband any interest she may have in all benefits to which Husband is entitled through his employment with United Parcel Service (UPS), including but not limited to, his defined benefit plan, Teamsters-UPS National 401 (k) tax deferred savings plan and UPS stock. Husband shall relinquish any interest he may have in all benefits to which Wife is entitled through her employment with the Commonwealth of Pennsylvania. The parties agree to execute any and all documentation necessary to effectuate the terms herein contained. 4 9. ADDITIONAL PAYMENTS TO WIFE. The parties acknowledge herein that Husband has already paid to Wife the sum of $25,000 as an advance payment toward her portion of the equitable distribution of marital assets. In addition, and in satisfaction of Wife's remaining share of the division of marital assets, Husband shall tender the following additional payments to Wife, pa3;able upon execution of this Agreement: (a) $20,000.00 as Wife's share of the 401(k) plan referenced in paragraph 8 herein, payable to Wife from Husband in the principal sum of $600.00 per month, plus interest at 5% making the total payment $643.86 per month, for a period of thirty~six (36) months, commencing on or before the first day of each month following the issuance of a final Decree in Divorce, and continuing payments made on or before the first day of each month thereafter until paid in full. (b) $15,000.00 as Wife's share of the LIPS stock referenced in paragraph 8 herein. (c) $7,500.00 as Wife's share of the Merrill Lynch account of the parties. Thus, upon execution of this agreement, Wife shall receive from Husband the net sum of $12,540, representing the $15,040 payment referenced in paragraph 6 herein, plus all payments referenced above in 9(a), (b) and (c), less credit to Husband of the $25,000 advance payment also referenced herein. Further, Husband shall pay Wife an additional sum of $60,000, representing Wife's interest in the defined benefit plan referenced in paragraph 8 herein, payable upon sale of the marital residence or upon Husband attaining age 62, whichever is sooner. Said $60,000 payment shall be secured by a second mortgage and note listing Husband as mortgagor and Wife as mortgagee, which mortgage shall be recorded as a second lien against the 251 Oak Grove premises. 10. ALIMONY. Both parties agree to make no claim for alimony or alimony pendente lite now or at any future time, or in connection with the pending divorce action between the parties. 5 11. COUNSEL FEES. Husband and Wife agree to be solely responsible for payment of his or her attorney fees in connection with this Agreement and the pending divome action between the parties. 12. LIFE INSURANCE. Husband agrees to maintain life insurance on his life naming Wife as irrevocable be~aeficiary until Husband's obligations to Wife under paragraph 5 of this Agreement have been satisfied in full. The death benefit shall be in at least the minimum sum that remains outstanding to Wife by Husband in paragraphs 6 and 9 herein, except the payments which are secured by mortgages. Proof of beneficiary designation and payment of premiums shall be furnished annually upon request. 13. FiNANCIAL DISCLOSURE. The parties have disclosed to each other and they are aware of the extent of each other's income, assets, liabilities, holdings and estates. Husband and Wife confirm that by executing this Agreement each forever waives any future right to set aside said Agreement, or to defend against its enforcement or any portion thereof based upon the absence of such a disclosure by the other party, or based upon any claim that it is inequitable, unconscionable or does not make a reasonable provision for one or the other of them. 14. NO-FAULT DIVORCE. Both parties agree to execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry ora Divorce Decree to facilitate entry ora divorce decree pursuant to Section 3301 (c) of the Divorce Code contemporaneously with execution of this Agreement. 15. BREACH. If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages, including attorney fees, for such breach, or seek such remedies or relief as may be available to him or her respectively, 16. ADDITIONAL iNSTRUMENTS. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments, including Deeds and other real estate-related documents, titles, pension documents, 6 or other documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal effect have been fully explained to the parties by Max J. Smith, Jr., Esquire, attorney for Husband and Thomas D. Gould, Esquire, attorney for Wife, and each party acknowledges that the Agreement is fair and equitable, that lull disclosure has been made by each respective pm-ty to the other, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Wife and Husband acknowledge that they have been furnished with all information relating to the financial affairs of the other, which has been requested by them respectively. 18. WAIVER OF CLAIMS AGAiNST ESTATE. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take property against the Will of the other, and the right to act as administrator or executor of the other's estate, and each will~ at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights and claims. 19. iNCORPORATION OF AGREEMENT FOR ENFORCEMENT. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives and assigns. This Agreement shall survive a decree of divorce between the parties in any jurisdiction and any other order which may be entered in accordance with this Agreement. In the event that a Decree of Divorce is entered in the Court of Common Pleas of Cumberland County, Pennsylvania or in the event that a Decree in Divorce is entered in any other jurisdiction, the parties agree to incorporate this Agreement in the Divorce Decree for purposes of enforcement. It is the specific intent of the parties to be bound by the provisions 7 hereof in lieu of any other claim or order of support, maintenance, alimony, equitable distribution, counsel fees, costs, maintenance of insurance, equitable relief or property settlement or with regard to any other provision hereo£ In the event that any final order of court is entered in any jurisdiction with respect to the parties hereto which is contrary to the provisions hereof, then the rights and responsibilities of each of the parties hereto shall be relieved or adjusted to the extent necessary to conform to this Agreement. 20. ENT1RE AGREEMENT. This Agreement contains the entire understanding of the panics, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 21. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement, shall not be construed as a waiver or any subsequent default of the same or similar nature. 22. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 23. IRREVOCABILITY. It is understood and agTeed to by and between the respective parties hereto that the property division-distribution effected by the herein Agreement is IRREVOCABLE and that such division-distribution shall not be affected by any future change in cimumstances of the respective parties OR by other statutory or judicial alternatives which may be available to the respective parties under prior, current or future laws of the Commonwealth of Pennsylvania or any other jurisdiction. Except as provided herein, the parties hereby waive any respective rights to financial support and/or alimony and/or pension or future expectancies each may respectively have under prior, current or future laws or case decisions. 8 1N WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS BARBARA E. GORMAS ROBERT D. GORMAS 9 BARBARA E.~RMAS, P~INTIFF ROBERT D · GORMAS, DEFENDANT IN THE COURT OF COb~4ON PLEAS CUMBE~ COUNTY, PENNSYLVANIA NO. 2003 - 0524 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT Divorce Code was 2. A Complaint in Divorce under Section 3301(c) of the filed on February 3, 2003. The marriage of Plaintiff and Defendant is irretrievably from the date of the Section 4904 relating to unsworn BARBARA E. GORMAS to the penalties of 18 Pa. C.S. falsification to authorities. broken and ninety (90) days have elapsed filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject BARBARA E. GORMAS, Plaintiff VS. ROBERT D. GORMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- 524 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELiNG 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 3, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. 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: ROBERT D. GORMAS BARBARA E. GORMAS, PLAINTIFF ROBERT D. GORMAS, DEFENDANT IN THE COURT OF CO~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 0524 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: BARBARA E. GORMAS, Plaintiff VS. ROBERT D. GORMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- 524 CWIL TERM CWIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO KEOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without further notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in 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: BARBARA E. GORMAS, PLAINTIFF ROBERT D. GORMAS, DEFENDANT IN THE COURT OF CO~4ON PLEAS CUMBERI~a_ND COUNTY, PENNSYLVANIA NO. 2003 - 0524 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail on February 3, 2003 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the signed Acceptance of Service attached hereto, the Complaint was received by the Defendant on March 2, 2003. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA (717) 731-1461 17011 BARBARA E. GORMAS, PLAINTIFF ROBERT D. GORMAS, DE F~NDANT IN THE COURT OF CO~94ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 0524 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, Robert D. Gormas, accept service of the Complaint In Divorce in the above captioned matter. Dated: ~3- o$- o3 251 Oak Grove Court Mechanicsburg, PA 17055 DEFENDANT BARBARA E. GORMAS, PLAINTIFF ROBERT D. GORMAS, DEFENDANT IN THE COURT OF CO~R4ON PLEAS CUMBERLA~q~ COUNTY, PENNSYLVANIA NO. 2003 - 0524 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On March 2, 2003 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, April 14, 2004, 2003; By Defendant, April 2, 2004. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on April 23, 2004. Date Defendant's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary on April 23, 2004. Thomas D. Gould, Esquire Attorney For Plaintiff IN THE COURT OF COMMON PLEAS BARBARA E. OF CUMBERLAND COUNTY STATE OF PENNA. GORMAS, PLAINTIFF NO. 2003 - 0524 CIVIL VERSUS ROBERT D. GORMAS, DEFENDANT DECREE IN DIVORCE AND NOW, /~¢%( '~"'(~ 2004, IT IS ORDERED AND DECREED THAT BARBARA E. GORMAS , PLAINTIFF, AND ROBERT D. GORMAS ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; THE MARITAL SETTLEMENT AGREEMENT DATED APRIL 14, 2004 IS HEREBY INCORPORATED INTO THIS DECREE IN DIVORCE. BY THE PROTHONOTARY DANNY P. ANDERSON, Plaintiff VS. JENNIFER L. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 524 C![vil Term CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this oq l~: day of ~/t'l~_ ,2004, upon request of the attorney for the Plaintiff, Danny P. Anderson, and without objection by the attorney for the Defendant, Jennifer L. Anderson, it is hereby ORDERED that the Hearing scheduled for June 2, 2004, is continued and shall be heard on ,ff'~j~/aa,, the /o~-b{ day of L/~Jd ~a~; ,2004, at 9;~0 cl..m, in Courtroom //4 of the Cumberland County VCourthouse, Carlisle, Pennsylvania, which time all parties shall appear and be heard. BY THE COURT: The HT?able Kevin A. Hess, Judge Distribution: ,/Diane M. Dils, Esquire, 1017 North Front Street, Harrisburg, PA 17102 ~X4aryann Murphy, Esquire, PMB 246, 4902 Carlisle Pike, Mechanicsburg, PA 17050