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HomeMy WebLinkAbout98-06509 . ! I~ l .., i ~ I~ i '" I ., ~ ~ I (). ~ ~ ~ ~ ~ ~ ~ \~ I - . - .":) i ~ I I ~: , ~i , "j ,! Uoi ~l . ~ ~ :!. ~ .:.:. .:.:. -:.;. .:.:- .:.:- -:+;. .:.;. .:+;. ,:~;. .:+;. -:.:. -:C':. -:~;. .:.:- -:+:.' *-~~*~**~~'.~.~*.~.~~ ~,' -." ,.....-~_.~.~.,.-,-".~.,.. ~...~ ..~ ~ :t: :t: :,. . .'.... <.~. -:.;. ,:.:. ':+:. .;+;, .:+;. -:+;. -:.:. ':4 ~ '~ . , ~, IN THE COURT OF COMMON PLEAS ~ :t. . , *; OF CUMBERLAND COUNTY ~i ',') ~~. ;~~,'f;1i Xl~ '~. ~ !'-f.." 1 \. ....: ~.J';;':~t PENNA, ~I . : ~; STATE OF ~, ~~ CATHERINE A. PATCHEL ;\;1). 6509 I') 98 ~' Plaintiff ~ * ~ ~ ~ \'\.r,';ll'; HENRY C. BONISLAWSKI Defendant ~ ~ DECREE IN DIVORCE ..~a.~~. .!4J.....~., it is ordered and ~ ~ ~ ,. ~ AND NOW, decreed fhat ....... CATH~RINE, A:, PATCHEL , . . . . .. . . . . . . . . ., plointiff, and..... .. . . . . .. . . .. .. .1\ENR,Y .c'. .BONISLAWSKI. .. .. .... .. ... . . '. defendont, are divorced from the bonds of matrimony. ~ $ ~ ~ The court retains jurisdiction of the following claims which have been raised of r';\c~rd in this action for which a final order has not yet been entered; tJOl^-f2 ~ ~ ~ The terms of the Separation and Property Settlement Agreement between the parcies'daCed'DeCember'13;'1999'is'hereby'intotpotated'as' if' set. fbrth' at. length but. shall. not. merge in. the. fiunl. Div\lrce. Oenee. 1>eq"'een.)>l1e,P~F~~!'~', . . . . . . . Any existing spousal support order shall hereinafter be deemed an order for alimony e dente lite if any economic claims remain pe~d{ng/ n y The Co,, "\I ,( I ,j / -'LWu ~J( ~ ~ ~ ~ ... Prothonotary ~ ;0' ~ ~ ~ i. ~ II ~ :~;, .:.:.,.. !~ , . ;~ , ',', )~ I. ~.. I':' I 'a'! (. )'~ l~ l~ }'.' I,~ I':' )~ I.', 1~ I,;, \;"':; I~ )", I~ 11,_ J~ , \~ i: ," \~ !~ I~ II~ ~ 1* ~ ~ ~ ~ ~ ~ ~ ~ ~ J. * ~ . SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this _1.5 day of j)eC!....~~1999, by and between Catherine A. Patchel. hereinafter referred to as "Wife", and Herny C. Boruslawski. horeinafter referred to as "Husband", WITNESSETH: WHEREAS, Husband and Wife were lawfully married on November 28, 1992; and WHEREAS, no children were born of this marriage; and WHEREAS, certain differences have arisen between the parties as a result of which they separated on November 16,1998 and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which will distribute their marital property in a manner which is considered to be an equitable division of all joint property, and will provide for the mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, there has been a complete disclosure of the earnings and property of each party, and each understands his/her rights under the Divorce Code of the Commonwealth of Pennsylvania; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband by his attorney, Mark T. Silliker, Esquire and Wife by her attorney, John W. Purcell, Jr. have come to the agreement, which follows: wry j ~ t I '\ , \ . , ....;. ,~ -, . Separation and Property Settlement Agreement Page 2 NOW. THEREFORE. in consideration of tho above recitals and tho following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound, covenant, promise and 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 that he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness 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 urunanied. except as may be necessary to carry out the provisions of this Agreement, Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the otherto cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. Wife's Debts. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 4. Husband's Debts. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him, 6. Outstanding Joint Debts, The parties acknowledge and agree that they have no outstanding debts and obligations incurred prior to the signing of this Agreement, except as follows: (A) first mortgage with PNC (E) second mortgage/home equity loan with PSECU )reJi Se areUon and Pro ert SelUemenl A reemenl p~ e 3 (C) Visa The debt listed at (A) shall be tile full responsIbility of Husband, and shall be rofinanced in accordance With the provisions of paragraph 6B. heroundor. Tho debts listed at (B) and (C) shall be the sole responsibility of both Husband and Wife, and shall be paid out of the joint assets of the parties upon distribution of the same, in accordance with Paragraph 60. hereunder. In the event that either party contracted or incurred any debts since the date of separation, the party who incurred said debt shall be responsible for the payment thereof, regardless of the name in which the account may have been charged, and such party shall indemnify, defend and hold the other party harmless from any claim or demand made against that party by reason of such debt. 6. Equitable Distribution of Marital Property. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in !l3501 et. seq. of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that it is the first marriage for Husband and second marriage for Wife: the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties: the contribution of each party to the education. training or increased earning power of the other party; the Opportlmity of each party for future acquisitions of capital assets and income; the sources of income of both parties, inclUding but not limited to medical, retirement, insurance or other benefits; the contribution or diSSipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard ofliving of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division of being effected without the introduction of outside funds or other property not constituting marital property, The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties, Wr{{ Separation and Property SetUemellt Agreement Pallo 4 A. Distribution of Personal Proporty, The parties hereto mutually auroe that they have effectod a satisfactory division of the furniture, household fumislungs, appliances, and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently m his or her possession, except as set forth in Exhibit A attached hereto, which items shall be distributed in accordance with Exhibit A, and this Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto and as set forth in Exhibit A. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other, or which property will be distributed in accordance with Exhibit A attached hereto, Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph, Property shall be deemed to be in the possession or lUlder the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party, Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits, except as stated herein. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to their separate property and any property which is in their possession or control, pursuant to this Agreement, and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after maniage, and neither Husband nor Wife I~{ .' Separation and Property SeUlement Agreement ?age 5 need join in. consent to, or acknowledge any deed. mongage. or other instrument of the other penaining to such disposition of property. B, Distribution of Real Estate. Wife shall transfer to Husband concurrent with the execution of this Agreement, all of her interest in and title to their jointly owned real estate located at 1201 Scenery Drive, Mechanicsburg, Pennsylvania in exchange for which Husband agrees to refinance the existing mongage and assumes full responsibility for the same, as well as for the payment of all current and future taxes, insurance and utility bills relative to said real estate. Husband covenants and agrees to pay and discharge said obligations on said premises, and agrees to indemnify Wife from any loss by reason of his default in the payment thereof, and agrees to save Wife hannless from any future liability with regard thereto. including the cost of defense and actual counsel fees incurred to defend against an action brought against her by vinue of his default. C. Cash Distribution. In consideration for the transfer of the above referenced real estate. Husband shall pay to Wife the sum of $45.000,00. D. Liquid Accounts. The contents of the follOwing accounts shall be divided equally between the parties. 1. Putman Investor Services Account No. AOL-1-140-40-5909-BBB1 2. PBHG Funds Account No. 5322994 3. Oppenheimer Fund Services Account No. 700-7001071840 4, Northeast Investors Trust Account No. 59776 5. Aim Family of Funds Account No. 4031579586 6, Vanguard Health Care Fund Account No, 9914392232 7. Seligman Account No. 8695591442 8. Quick & Reilly Account No. 390-24170-17 9, Franklin Templeton Fund Account No, 104-7700885536 The following account shall remain the sole property of Wife 1. Quick & Reilly Account No. 390-23567-10 ~t Separation and Prop..ny SetUemenl Agreement flage t3 7. Vehicles. Notwithstandinu Parauraph 6 of thIS ^UlOfllllont, Husband shall retain possossion and ownership oftho 1997 Nlssan Pickup Plflsontly mills possession. Wife hereby transfers all of her right, title and interest in said vohiclo to Husband, In considoration thereof, Husband shall assume full responsibility for payment and ovontual satisfaction of any and all liens presently encwnbering the vehicle. and to indemnify, c1ofond and hold Wife hannless for the same. Wife hereby agrees to sign any title or other c10cuments necessary to transfer ownership of said vehicle at any time, upon demand, and funher shall indenutify Husband for any costs, including actual counsel fees. incurred by Husband to enforce this provision. Notwithstanding Paragraph 6 of this Agreement, Wife shall retain possession and ownership oCthe 1997 Suzuki Sidekick presently in her possession. Husband hereby transfers all of his right, title and interest in said vehicle to Wife. In consideration thereof. Wife shall assume full responsibility for payment and eventual satisfaction of any and all liens presently encumbering the vehicle. and to indenutify, defend and hold Husband hanniess for the same, Husband hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle at any time, upon demand, and further shall indenutify Wife for any costs, including actual counsel fees, incurred by Wife to enforce this provision, 8. Alimony. Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair. adequate and satisfactory to them. and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony, Husband and Wife funher, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indenutify. defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indemnity to include the actual counsel fees of the defendant in any such future action. 9. Alimony Pendente Lite, Counsel Fees and Expenses. Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties is fair, adequate and satisfactory to them, Both parties shall accept the provisions set forth in this Agreement in lieu of and in full and final J~A~ Separation and Property Seltlemenl Agreeme"l ?a.ae7 settlement and satisfaction of all claims and domands that eithor lllay now or hereafter have against the other for alimony pend onto lito, counsel fees or exponsos. or any other provision for their support and maintenance bllforo. during and after the conunencement of any proceedings for divorce or annulment between the parties. Each party shall be responsible for his or her own counsel fees, and each agrees to indemnify. defend and save the other hannless from any actionconunenced against the other for alimony pendente lite. counsel fees and/or expenses. 10. Divorce. A Complaint in Divorce has been filed to No. 98-6509 Civil in the Court of Conunon Pleas of Cwnberland County, Pennsylvania, and either party shall be free to proceed without further delay to secure the divorce, Both parties shall sign an Affidavit evidencing their consent to the divorce, pursuant to s3301(c) of the Divorce Code, In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indenmify, defend and hold the other hannless from any and all additional expenses, including actual counsel fees resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a Consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. 11. Time of Distribution. The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective parties immediately upon the execution of this Agreement, All spousal support and other such obligations, including alimony, shall inunediately terminate. The parties shall cooperate by executing whatever documents are necessary to effectuate a divorce under s3301(c) or s3301(d) of the Pennsylvania Divorce Code. and this Agreement to cooperate shall be enforceable by an assumpsit action for specific performance. However, upon refusal to consent, all distributed property shall be retumed to the party Originally in possession, until the time of final Decree. 12, Release. Subject to the provisions of this Agreement. each party has released and discharged, and by this Agreement does for himself or herself. and his or her heirs, legal representatives, executors. administrators and assigns. release. indemnify (including actual }V~6 Separation and Property Settlement Agreernenl ?it~'" a logal foes) and dischargo tho other of and from all causes of action, claims, rights, or demands, whatsoever m law or eqUIty, lllcludmg equitable distribution, spousal support, alimony, co\msol !'lOS, alimony pendente lite, and expenses which either of the parties against the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or IUlder any other statutory or common law, except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling, pursuant to !i3302 of the Divorce Code. 13, Waivers of Claims Against Estates. 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 have 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 in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and any right existing now or in the future under the Pennsylvania Divorce Code, as amended from time to time, 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 interests, rights and claims. 14. Rights on Execution. Immediately upon the execution of this Agreement, the rights of each party against the other, despite their continuing marital status, shall terminate and be as if they were never married. 15. Breach, In the event of breach of any of the terms of this Agreement, the nonbreaching party shall be paid, as part of any award or judgment against the breaChing party, all costs, including actual counsel fees paid to his or her attorney. 16. Incorporation in Final Divorce, The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties, This Agreement shall survive in its entirety resolving the spousal support, alimony, property and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania. This Agreement may be enforced independently of any IvJ"~ 5e aration and Pro e SetUement A reemont ?'" e 9 support order, divorco decree or judgmont and its tenns shall take precedence over same, remaining the primary obligation of eacli polIty, ThIS Aureoment shall remain III full force and effect regardless of any change in tlio mantal statlls of the parties. It is warranted, covenanted and reprosontod by Husband and Wife, each to the otlll1r, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement, 17. 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 that may be reasonably required to give full force and effect to the provisions of this Agreement, 18, Separability. In case any provision of this Agreement should be held to be contrary to, or invalid under, the law of any COlffitry, state or other jurisdiction, such illegality and invalidity shall not in any way affect the other provisions hereof, all of which shall continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate and illldisputed covenant and agreement, 19. Entire Agreement. This Agreement contains the entire illlderstanding of the parties and there are no representations, warranties, covenants and illldertakings other than those expressly set forth herein. 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 the 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 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 each voluntarily and intelligently waive and relinquish any right to seek a Court ordered detennination 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. l~{ Se aration and Pro e Settlement A r..ment r,i....., 10 20. Modification and Waiver. ^ modification or waiver of ilny of the provisions of this Agreement shall be effectIve only If made III writing and executod with the same formality as this Agreement. The failuro of eltllOl party to insist upon stnct performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 21. Intent. It is the intent of the parties by this Agreement to fully and finally foreclose any resort to the Courts for relief on the basis of any statute or case law presently existing or which may exist at some time in the future within the COIIUllonwealth of Pennsylvania, including but not limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended, This Agreement has been drafted and accepted on the basis that such resort would constitute a breach under this Agreement, entitling the nonbreaching party to reimbursement for actual counsel fees. Other than as provided by the terms of this instrument, it is intended that the Court shall treat the parties as if they had never entered into a marital relationship. This Agreement shall be interpreted and governed by the laws of the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms of this instrument shall govern. 22. Voluntary Execution, The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been funtished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 23. 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, 24. Agreement Binding on Heirs, This Agreement shall be binding and shall inure to the benefit of the parties hereto, and their respective heirs, executors, administrators, successors and assigns. ~~ .,. r- >- if. <': I- ~ .. >, (~10 lJ.I( : ();. . :'C r!'- 0- ~i: r '.J ,L: >- ~ ~; ';'! UJIl fl~~; . ;1; .- L: ;;":.U .- ..1....... j" - 1.1- 0 "j (J 0 u CATIIERINE A I'ATC'lIEI., I'laintill' . IN TilE ('OURT OF ('O:\I:\ION I'I.Et\S . ('\i:\IBEIlI.ANI> COUNTY. I'I:NNSYL VANIA \'S NO 'IX-h,fII) ('IVII. IIENRY C 1I0NISI.AWSKI. Dcfcndant . IN III VORCE I'/{AF:CII'E TO TI(Al'iSMIT IU:COIU> TIlE I'ROTlIONOTAR Y Transmit thc rccord, togethcr with thc f(lllowing inlllfll1ation. 10 the Court f(lr entry ofa Divorce Decree: I, Ground lor divorce. Irretricvllble brellkdownundcr Scction (X) 330 I (c) of the Divorce Code. 2, Dllte llnd l1111nner of servicc of the Complaint. 12128/98 h)' certified JIIail 3, (:1) Dllte ofexeculion ofthc Aflidllvit ofConscnt required by Section.1301(c) of the Divorce Code: by Plaintill.: December 21, 1999 by Defendllnt: ,'annary 3, 2000 (b) (I) Dllle of execution of the Plllintin's Allidavil requircd by Section 330 I (d) of the Divorce Code: (2) Dllte of service of the Plllintifl's Aflidavil upon the Delendllnt: 4, Relllted c111ims pending: No economic c1llims hll\'e heen raised. 5. (ll) Date and manner of service oflhe notice of intention 10 file Pmecipe 10 tmnsmit record, II copy of which is llttllched: (b) Date of Plaintin's Waiver of Notice in 330 I(c) Divorce WllS filed with Prothonotary: Filed contemporaneously herewith Dllte of Defendant's Wlliver of Notice in J30 I (c) Divorce WllS filed with the Prothonotllry: Filed contemporaneonsly herewith r'~ ?' CATHERINE A. PATCHEL, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, '7:. ~. ~[!'f ((I" i y;,,-- HENRY C, BONISLAWSKI, Dllfendant CIVIL ACTION. LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice, Failure to do so will constitute a waiver of your right to request counseling. Prothonotary -J ., ->l V> x. ", '\ -- '-'J '-.l "> <j ^0 '-> \3"- '" , . - '- "- ~ .~ ' "-' ~ ~ .. ~ ') -+ \.r> ~ , ...j . -..J _J \n Vl '-- r') '--' "- '-., . r-- f'-. --- ~ 0,/:> (\"- -~ I' ''<- - c)'~ I I I t i I I I I i I ! ! Jot 101111 "IV'.O COMMONWEALTH 0' "'(NNS"L..."NI'" OC~A'HM[lIlT OF Mf......TH VITAL RECORDS DIVORCE RECORD OF OR ANNULMENT (CHECK ONEI 0 S .HI "I.e "'UMBeR STATI FILE OATE (rUNTY I J/llv,rrUII-.D [gJ 1. '\lAME IF"ul 1I U~;/~ V 2. RUIDENCE Sr,.,n or ff.O. /),() / ,')(1 i ) HUSBAND ) . .~LllrI " hIIL1')/. 10 A,I "my I.t. -, U, ;;). )EI'..SE'/ m" ., 2. ~ATe. oP t,}, - ) 4g ., '\lUMBER Oil THI' ....."UHAD !IIATH 4 Pl.ACE 0' Ii -, , alATM -..It_LV 7 USUAL OCCUPATIO,,", (! Out, Ct!... ,t.tH O"1flII urruy WIFE ., 01TcniE L =-e.SIO!NCe :') Monrhl a.yl 6'1-{;5- ,., 9. DATE 0' BIRTH 11 Pl..ACE 0' BIRTH C UP. I !II /)/"5(1 reliC 'lUMBER OF THIS ....ARRIA IS. 'I.ACl! 0," OF THIS "'''''''''ADE 17.... 'lUMBeR OF CHIL- DREN THIS 0 \lARRIAGE 2Q. 'l/VMBER OF HUSBAND ~HII.OREN TO 0 CtJSTOOV OF 22, :3ATE OF OECREE (Month} OATEOF ,Month} O.yJ Y_n THIS / J . .!)S -'} do 'IotARRIAOe HUSBANO oNIFE OTHER fSIMC,lyl 0 El 0 /D.yl j; /Y. ., ,... SIONATURE OF .RANSCRIB1NO Cl.ERIC ., CATHERINE A. PATCHEL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. HENRY C. BONISLAWSKI, Defendant : NO. 98-6509 CIVIL : CIVIL ACTION.LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (e) Dr 1110 divorco Code was filed on November 16, 1998. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301 (c) OF THE DIVORCE CODE 2. The marriage of Plaintiff and Defendant is irrotrillvllhly hrokoll alld ninety days have elapsed from the date of filing and servico of 1110 COlllfllllilll. 3. I consent to the entry of a final decrHo of rlivoreo altor sorvicll 01 notice of intention to request entry of the decree 1, 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 II divorco 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 senl to me immediately after it is filed with the prothonotary. I verify that the statements made in this Affidavit are Irue ond correct. I understand that false statements herein are made subject to the pellllltles of 18 Po. Date: '&'/AnN/.I ,..;1/, /99f .d1j;~l1Ii--c:Ldd!.1~ Call1orino A, Plltr:1101 i1 ! C.S. ~ 4904 relating to unsworn falsification to authorities. ~ : CUMBERLAND COUNTY, PENNSYLVANIA vs. HENRY C. BONISLAWSKI, Defendant : NO, 98650~ CIVIL : CIVIL ACTION LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorcn lJndor Suclion 3301 lei of tlm divorce Code was filed on November 16, 1998. 2. The marriage of Plaintiff and Dufundant is irrotrillvably broken and ninety days have elapsed from the date of filinn and snrvico of tho Complaint. 3. I consent to the entry of a final docrl!e of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final dncree of divorce without notice, 2. I understand that I may lose rights concernin(J alimony, division of property, lawyer's fees or expenses if I do not claim Ihem 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 Df 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. ~ 4904 relating to unsworn falsification to authorities. 0,,01/ D3 /00 fJ'? !Jrrz/J,j {tic iJ, I-; / Henry C, Bonislawski ii; ,.... ~ ~ c": ,- ?~ <~ 0,: I.:' :.~ o~ ;..~ ~~'. :5: ; ~~ " 0- 02 ("i~ ~:'. 7c:~ (..) ~~:. - X '2':.::[_ - 1n ~- Co cPo- -, 3 ". C> (.,) c::> CATHERINE A. PATCHEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 9B.6509 HENRY C. BONISLAWSKI, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this ILL- day of \/~U~ );~i l; .\ .' , 1998. personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce was served on the Defendant, Henry C, Bonislawski. on December 3, 1998 by certified mail number P 397 739 948, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. .~ '. Sworn to and subscribed before me this Yi -J- J, d f l A, , ^ \ ~)' I' Ie' h ) 1998 ay 0 ..!\\1i(lli il '- 1'f ,l ,; I . , " lJ';,J, , ,.iJJ !) ']) . ~-?'fL~~)t-' C!Notary Public' I" NOTARIAL SEAL J::AN L. KOSIER. NOh~ry Public elr)' of H(lr~I~~ur<). O,lllphin Cf)unt/ ) ~1Lq~r:::'1~t':~'('r: r: qg. LtN, 211, E.qg ~ \f) ~ .Z .;l r f:i1 ?ef. fA 0"" ).0;.. ~ ()*. ~,! c- ~:1~ ")F"l - .'. if) \.-iJ?;"o "j% '.. 7- D:~; ~ ;c,uJ ::.:> il \0.. ,- -. ~.-::. .- ". 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