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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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MARY E. ZELADONIS,
PLAINTIFF
No. #2000-5767 CIVIL TERM
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VERSUS
THOMAS M. ZELADONIS,
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DEFENDANT
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DECREE IN
DIVORCE
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AND NOW,
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MARY E. ZELADONIA
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DECREED THAT
, PLAINTIFF,
THOMAS M. ZELADONIS
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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;
A PROPERTY SETTLEMENT AGREEMENT IS ATTACHED AND MADE A PART HEREOF FOR
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PURPOSES OF ENFORCEMENT.
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( PROTHONOTARY
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, dated the ~1.4 day of /~~~~~, 2000, by and
between Thomas M. Zeladonis, residing at 662 Hillcrest Drive, Carlisle,
Cumberland county, Pennsylvania, 17013, Social Security Number 210-36-5279,
hereinafter called the "Husband", and Mary Zeladonis, formerly Lichty of
wife, residing at 662 Hillcrest Drive, Carlisle, Cumberland County,
pennsylvania, 17013, Social Security Number 199-36-9873, hereinafter called
the "Wife", who agree as follows:
WIT N E SSE T H :
WHEREAS, the parties are Husband and Wife, having been married on
October 16, 1971, in Carlisle, CUmberland County, Pennsylvania. The
parties sepa~ated August 9, 2000. There are no minor children of this
marriage.
WHEREAS, diverse, unhappy, and irreconcilable differences, disputes,
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 parties hereto are desirous of settling fully and
finally their respective financial and property rights and obligations as
between each other including, without limitation by specification: the
settling of all matters between them relating to the ownership and
equitable distribution of real and personal property; the settling of all
matters between them relating to the past, present and future support,
alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in
general, the settling of any and all claims and possible claims by one
against the other or against their respective estates.
NOW THEREFORE, in consideration of the promises and of the mutual
promises, covenants and undertakings hereinafter set forth and for other
good and valuable consideration, receipt of which is hereby acknowledged by
each of the parties hereto, Wife and Husband, each intending to be legally
bound hereby, covenant and agree as follows:
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1. AGRE~NT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of
Wife or Husband to a limited or absolute divorce on lawful grounds if such
grounds nOW exist or shall hereafter exist or to such defense as may be
available to either party. This Agreement is not intended to condone and
shall not be deemed to be a condonation on the part of either party hereto
of any act or acts on the part of the other party which have occasioned the
disputes or unhappy differences which have occurred prior to or which may
occur subsequent to the date hereof. The parties intend to secure a mutual
consent, no-fault divorce pursuant to the terms of Section 3301(c) of the
Divorce Code of 1980 as amended by Act No. 1990, 206 effective 3-19-91.
2. ADVICE OF COUNSEL
Wife and Husband declare that each has had a full and fair opportunity
to obtain independent legal advice of counsel of her and his selection;
that Wife has been independently represented by counsel and that husband,
cognizant of his right to legal representation, declares that it is His
express, voluntary and knowing intention not to avail himself of his right
to counsel and chooses instead to represent himself with respect to the
preparation and execution of this Agreement.
3. EFFECT OF DECREE, NO MERGER
Neither party to any such action shall ask alimony or support contrary
to the provisions of this Agreement. It is further specifically
understood and agreed that the provisions of this Agreement relating to
the equitable distribution of property of the parties are accepted by each
party as a final settlement for all purposes whatsoever. Should either of
the parties obtain a decree, judgment, or order of separation or divorce in
any other state, country, or jurisdiction, each of the parties to this
Agreement hereby consents and agrees that this Agreement and all of its
covenants shall not be affected in any way by any such separation or
divorce; and that nothing in any such decree, judgment, order, or further
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modification or revision thereof shall alter, amend or vary any term of
this Agreement, whether or not either or both of the parties should
remarry, it being understood by and between the parties that this Agreement
shall survive and shall not be merged into any decree, judgment, or order
of divorce or separation.
It is further understood that Pennsylvania law provides that "a
provision of an Agreement regarding child support, visitation or custody
shall be subject to modification by the Court upon a showing of changed
circumstancesu.
It is specifically agreed, however, that a copy of this Agreement may
be inco~orated, by reference, into divorce judgment or decree. This
incorporation, however, shall not be regarded as a merger, it being the
intent of the parties to permit this Agreement to survive any such
judgment, unless otherwise specifically provided herein, and for this
Agreement to continue in full force and effect after such time as a final
decree in divorce may be entered with respect to the parties. The parties
agree that the terms of this Agreement may be incorporated into any divorce
decree which may be entered with respect to them for purposes of
enforcement only of any provisions therein, but shall survive such decree.
That is, this agreement and all warranties and representations
contained herein shall survive the Divorce Decree and shall continue to be
enforceable in accordance with its terms. Except with regard to child
support and child custody, no court may change the terms of this agreement,
and it @hall be binding and conclusive upon the parties. In the event of a
reconciliation, attempted reconciliation, or other cohabitation of the
parties hereto after the date of this agreement, this agreement shall
remain in full force and effect in the absence of a written agreement
signed vy both parties expressly stating that this agreement has been
revoked or modified.
4. DIST~IBUTION DATE
The transfer of property, funds and/or documents provided for herein
shall take place simultaneously with the execution of this Agreement.
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5. FINANCIAL DISCLOSURE
The parties confirm that each has relied on the substantial accuracy
of the financial disclosure of the other as an inducement to the execution
of this Agreement, and that Wife does not wish to exercise her right to
have appraisals by experts as to the value of the various interests of
Husband. She understands that such appraisals would be necessary to fix
the fair market value of these interests for purposes of equitable
distribution.
6. WARRANTY OF DISCLOSURE
The parties warrant and represent that they have made a full
disclosu,e of all assets and their valuation prior to the execution of this
Agreement. This disclosure was in the form of an information exchange of
information by the parties' attorneys and this Agreement between the
parties is based upon this disclosure.
7. OBTAINING INFORMATION ON FINANCES
Each party acknowledges that they have been informed they may have
the right, as provided by statute and Pennsylvania Rules of Civil
Procedure, to obtain information regarding the parties' finances. Such
information would include, without limitation, their present and past
income; and the identity and value of assets both presently owned and
transferred previously. Such information may be obtained by one or more of
several methods including depositions upon oral examination, written
interrogatories, production of documents or entry upon property for
inspection. The parties agree to waive any further discovery.
8. PERSONAL RIGHTS
wife and Husband may and shall, at all times hereafter, live separate
and aparC. They shall be free from any control, restraint, interference or
authority, direct or indirect, by the other in all respects as fully as if
they were unmarried. They may reside at such place or places as they may
select. Each may, for his or her separate use or benefit, conduct, carry
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on and engage in any business, occupation, profession or employment which
to him or her may seem advisable. However, each party shall make best
efforts to maintain employment with comparable benefits and salary as they
now hold or for which they are in training.
9. NO MOLESTATION
Husband and Wife shall not molest or interfere with each other, nor
shall either of them attempt to compel the other to cohabit or dwell with
her or him, by any means whatsoever. Neither party shall harass or be
verbally or physically abusive to the other.
10. MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim
and forever discharge the other and the estate of such other, for all time
to come, and for all purposes whatsoever, of and from any and all rights,
title and interest, or claims in or against the property (including income
and gain from property hereafter accruing) of the other or against the
estate of such other, of whatever nature and wheresoever situate, which he
or she now has or at any time hereafter may have against such other, the
estate of such other or any part thereof, whether arising out of any former
acts, contracts, engagements or liab'ilities of such 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 territory of the United States, or (c) any other country,
or any rights which either party may have or at any time hereafter have for
past, present or future support or maintenance, alimony, alimony pendente
lite, counsel fees, equitable distribution, costs or expenses, whether
arising as a result of the marital relation or otherwise, 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
thereof. It is the intention of Husband and Wife to give to each other by
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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
thereof.
11. EQUIT~LE DISTRIBUTION OF PROPERTY
It is specifically understood and agreed that this Agreement
constitutes an equitable distribution of property, both real and personal,
which was legally and beneficially acquired by Husband and Wife or either
of them during the marriage, as contemplated by The Act of April 2, 1980
(P.L. 63, No. 26) known as "The Divorce Code," 23 P.S. 3101 et. seq. of the
Commonwealth of Pennsylvania.
And further, that the parties have attempted to divide their marital
property in a manner which conforms to the criteria set forth in 3502 of
the Pennsylvania Divorce Code, and taking into account the following
considerations: the length of the marriage, the prior marriages of the
parties; the age, health, station, amount and sources of income, vocational
skills, employability, estate, liabilities and needs of each of the
parties; the contribution of one party to the education, training, or
increased earning power of the other party; the opportunity of each party
for future acquisition 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 marital
property, including the contribution of a party as a homemaker; the value
of the property set apart to each party; the standard of living 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.
12. Distribution of Personal PrODertv:
The parties hereto mutually agree that they have effected a
satisfactory division of the furniture, household furnishings, appliances,
and other household personal property between them as per Appendix "A"
attached hereto and made a part hereof, 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 in his or her possession,
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.
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. 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 under 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 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 his or her own individual pension or
other employee benefit plans or retirement benefits of any nature with the
exception of social security benefits 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.
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 marriage, and neither Husband nor wife
need join in, consent to, or acknowledge any deed, mortgage, or other
instrument of the other pertaining to such disposition of property.
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13. Real Property:
The parties recognize that they own as tenants by the entirety real
property known as 662 Hillcrest Drive, Carlisle, Cumberland County,
Pennsylvania, 17013. For the mutual promises and covenants contained in
this Agreement, Wife agrees to convey to Husband all right, title, claim,
or interest she may have by equitable distribution or otherwise in and to
this property. This conveyance shall take place within thirty (30) days of
the date of this Agreement. It is recognized that this conveyance is
subject to an existing second mortgage naming Members First bank as
mortgagee and having an approximate balance of $17,128.85 as of June 30,
2000. Husband agrees to indemnify Wife for any loss, including counsel
fees, that she might suffer as a result of default upon this mortgage.
Husband further agrees to refinance in his name the second mortgage within
thirty (30) days of the signing of this agreement.
14. FILING INVENTORIES AND APPRAISEMENT
The parties further acknowledge their understanding that they each
have the right to file Inventories and Appraisement with the Court and to
require the other party to do so. Such Inventories and Appraisement
require a party to indicate, under oath, information regarding all marital
property in which either party has an interest as of the date the action
was commenced. Fully knowing the same, each party nonetheless waives their
respective rights to request additional discovery be conducted, to file
Inventories and Appraisement with the Court, or to require the other party
to do so.
15. DEBTS:
Marital Debts: Husband and Wife agree that the debts incurred
by Husband and Wife during the marriage to various charge accounts
and other outstanding loans shall be assumed by Husband for the
existing balance at the time of separation, and Husband agrees to
hold Wife harmless of same.
Future Debts: Husband and Wife hereby mutually agree that
subsequent to the execution of this Agreement neither party shall incur any
debts which will obligate the other to make payment for same. Husband and
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wife hereby acknowledge that there are no outstanding bills or other
indebtedness which have been incurred by either for the liability of the
other, and both parties hereby covenant and agree that neither shall have
any financial obligation to pay any financial obligations which are solely
the financial obligation of the other and which have been contracted by
either party solely for their own benefit and without the knowledge or
consent of the other party. Husband and Wife further agree that they will
indemnify the other from any and all claims or demands made against the
other by reason of any debts or obligations contracted in violation of this
Agreement.
16. WARRANTY AS TO EXISTING OBLIGATIONS:
Each party represents that they have not heretofore incurred or
contracted for any debt or liability or obligation for which the estate of
the other party may be responsible or liable except as may be provided for
in this Agreement. Each party agrees to indemnify or hold the other party
harmless from and against any and all such debts, liabilities or
obligations of every kind which may have heretofore been incurred by them,
including those for necessities, except for the obligations arising out of
this Agreement.
17. WARRANTY AS TO FUTURE OBLIGATIONS.
Wife and Husband each covenant, warrant, represent and agree that
each will now and at all times hereafter save harmless and keep the other
indemnified from all debts, charges and liabilities incurred by the other
after the execution date of this Agreement, except as may be otherwise
specifically provided for by the terms of this Agreement and that neither
of them shall hereafter incur any liability whatsoever for which the estate
of the other may be liable.
18. PAYMENT OF SPECIFIED OBLIGATIONS:
A. During the course of the marriage, Wife and Husband have
incurred certain bills and obligations and have amassed a variety of
debts, and it is hereby agreed, without the necessity of ascertaining for
what purpose and to whose use each of the bills were incurred, that
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Husband shall be solely responsible for all bills, obligations and debts
as set forth below.
(1) 200 mortgage at Members First Federal Credit Union
B. Each party agrees to hold the other harmless from any and all
liability which may arise from the aforesaid bills and which, pursuant to
the terms herein, are not the responsibility of the other party.
19. ASSUMPTION OF LIABILITIES.
This provision sets forth the method for the payment and assumption
of the debts and liabilities of the parties. since the assumption is not
binding on the creditor, the party assuming the debt agrees to indemnify
the other party in the event the creditor seeks to hold such other party
liable. should the parties wish to bind the creditor and relieve the
original debts from all liability, a novation should be executed.
20. INCOME TAX PRIOR RETURNS
The parties have heretofore filed joint federal, state and local
income tax returns. Husband agrees that in the event any deficiency in
federal, state, or local income, real estate or personal tax is proposed,
or any assessment of any such tax is made against Wife by reason of Husband
having joined in the filing of said joint returns or by reason of Husband's
prior omission to file returns or pay such, Husband will indemnify and
hold Wife harmless from and against any loss or liability for any such tax
deficiency or assessment and any interest, penalty, and expense incurred in
connection therewith, and such tax, interest, penalty or expense shall be
paid solely and entirely by Husband, unless said tax, interest, penalty or
expense is finally determined to be attributable to Wife'S
misrepresentations or failures to disclose the nature and extent of Wife's
separate income on the aforesaid joint returns.
21. 2000 INCOME TAX RETURN
Husband and Wife agree that they shall file separately for Federal,
State and Local Income Tax Returns for the year 2000.
22. WAIVER OF SPOUSAL SUPPORT. ALIMONY PENDENTE LITE. AND ALIMONY
The parties herein acknowledge that by this Agreement they have each
respectively secured and maintained a substantial and adequate fund with
which to provide themselves sufficient financial resources to provide for
their comfort, maintenance and support, in the station of life in which
they are accustomed. Wife and Husband do hereby waive, release and give up
any rights they may respectively have against the other for alimony,
alimony pendente lite, support or maintenance. It shall be from the date
of this Agreement the sole responsibility of each of the respective parties
to sustain themselves without seeking any support from the other party.
23. L~FE INSURANCE
Both parties shall continue to maintain all current life insurance
policies on their lives even in the event their employment changes, naming
the Children solely as irrevocable beneficiaries of such policies. They
shall each provide a written list to the other setting forth the insurance
company(s), policy number(s), and principal amount(s) of such insurance as
provided above with proof of beneficiary. They also agree not to borrow
against or assign said policies without prior written consent of the other
party. Both Parties agree to make payment of premiums on the policies on
their individual lives so as to continue said coverage as long as each
Child is owed a duty of support.
24. DIVORCE
Husband and Wife agree that Wife shall file a Complaint in divorce
seeking a divorce on the basis of mutual consent. Husband and Wife both
agree that ninety (90) days following the filing of a Divorce Complaint by
Wife that both parties will execute the required Affidavits of Consent to
be filed with the Court to allow the Court to grant a divorce on the basis
of mutual consent. Wife agrees to pay all counsel fees, costs, and
expenses incident to obtaining the aforesaid divorce.
AND the parties hereto state and agree that this Agreement shall not
in any way be construed as a collusive agreement.
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25. WILLS
The parties hereby contract and agree to include in their Will a
provision whereby each will name the parties' Children if appropriate as
heirs to at least one-half of the testator's estate and that such interest
shall be held in trust for a child who is under the age of twenty-five
(25) .
26. RETIREMENT FUNDS
A. The Husband, who had been employed by Unisys, has accumulated
benefits in his retirement account. Husband also has an IRA account. It
is agreed by the parties that the Wife shall waive any interest she may
have in any of the benefits, including retirement, which the Husband may
have as a result of his employment.
B. The Wife, who is employed at Stoner and Associates, Carlisle,
Pennsylvania, also has retirement and other employee benefits. It is
agreed by the parties that the Husband shall waive any interest he may
have in any of the benefits, including retirement, which the Wife may have
as a result of her current or past employment.
27. ATTORNEY FEES. COSTS & EXPENSES
The parties agree to waive receipt of and to be responsible for their
own attorney fees, costs and expenses in connection with the negotiation
and preparation of this Agreement and the granting of a divorce decree.
28. BREACH OF 1l.GREEMENT
If either party fails in the due performance of obligations under this
Agreement at tbeir election, the non-breaching party shall have the right
to sue for damages for breach of this Agreement or to rescind same and seek
such legal remedies as may be available to them. The breaching party will
be responsible for actual legal fees and costs incurred by the
non-breaching party necessary to the enforcement of this Agreement.
29. LAW OF PENNSYLVANIA 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.
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30. 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.
31. SEVERABILITY
If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only
that term, condition, clause or provision shall be stricken from this
Agreement and in all other respects this Agreement shall be valid and
continue in full force, effect and operation. Likewise, the failure of any
party to meet her or his obligations under anyone or more of the
paragraphs herein, with the exception of the satisfaction of the conditions
precedent, shall in no way avoid or alter the remaining obligations of the
parties.
32. INTEGRATION
This Agreement constitutes the entire understanding of the parties and
supersedes any and all prior agreements and negotiations between them.
There are no representations or warranties other than those expressly set
forth herein.
33. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until
terminated under and pursuant to the terms of this Agreement. 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 same, nor shall the waiver of any breach of any provision
hereof be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of any subsequent
default of the same or similar nature, nor shall it be construed as a
waiver of strict performance of any other obligations herein.
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34. WAIVER OR MODIFICATION 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.
35. SUBSEQUENT DIVORCE
It is contemplated that Wife will proceed with a Complaint in Divorce
against Husband in the near future. Husband and Wife each agree to sign an
Affidavit of Consent and an Affidavit waiving counseling to be filed in
said divorce action. In the event such divorce action is concluded,
Husband shal1 be entitled to receive a copy of the Decree in Divorce for
the normal fee charged by the Prothonotary and shall not be assessed any
costs of the proceeding, except as previously agreed to herein in Paragraph
twenty four (24). In the event such divorce action is concluded, the
parties shall be bound by all the terms of this Agreement, which shall not
be incorporated by reference into the Divorce Decree, and this Agreement
shall not be merged in such Decree, but shall in all respects survive the
same and be forever binding and conclusive upon the parties.
36. MUTUAL COOPERATION
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.
37. 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.
38. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will forthwith (and
within at least ten (10) days after demand therefore) execute any and all
written instruments, assignments, releases, satisfactions, deeds, notes, or
such other writings as may be necessary or desirable for the proper
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effectuation of this Agreement, and as their respective counsel shall
mutually agree should be so executed in order to carry out fully and
effectively the terms of this Agreement.
39. BANKRUPTCY
In the event that either party becomes a debtor in any bankruptcy or
financial reorganization proceedings of any kind while any obligations
remain to be performed by that party for the benefit of the other party
pursuant to the provisions of this Agreement, the debtor spouse hereby
waives, releases and relinquishes any right to claim any exemption (whether
granted under state or federal law) to any property remaining in the debtor
as a defense to any claim made pursuant hereto by the creditor-spouse, and
the debtor-spouse hereby assigns, transfers, and conveys to the creditor-
spouse an interest in all of the debtor's exempt property sufficient to
meet all obligations to the creditor-spouse as set forth herein, including
all attorneys' fees and costs incurred in the enforcement of this Paragraph
or any other provision of this Agreement.
No obligation created by this Agreement shall be discharged or
dischargeable, regardless of federal or state law to the contrary, and each
party waives any and all right to assert that any obligation hereunder is
discharged or dischargeable.
40. HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and
subparagraphs hereof are inserted solely for convenience of reference and
shall not constitute a part of this Agreement nor shall they affect its
meaning, construction or effect.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals
first above written.
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" Thomas 111. Ze aaonis
0YlCM- E~D l~L
Mary E. Zel~o 1
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COMMONWEALTH OF PENNSYLVANIA
:aa
COUNTY OF CUMBERLAND
On this, the ~day of ~o~
, 2000, before me, a Notary
Public, the undersigned officer, personally appeared Thomas M. Zeladonis,
known to me to be the person whose name is subscribed to the within
Property Settlement Agreement, and acknowledged that he executed the same
erein contained.
NOTARIAL SEAL
Michelle L. Sollenberger, Notary Public
Fayetteville, Franklin County
My Commission Expires Oct. 5, 2002
COMMONWEALTH OF PENNSYLVANIA
:ss
COUNTY OF CUMBERLAND
On this, the ~ day of
~
, 2000, before me, a
Notary Public, the undersigned officer, personally appeared Mary E.
Zeladonis, known to me to be the person whose name is subscribed to the
within Property settlement Agreement, and acknowledged that she executed
the same for the purposes therein contained.
NOTARIAL SEAL
Michelle L. Sollenberger, Notary Public
Fayetteville, Franklin County
,ny Commission Expires Oct. 5, 2002
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Mary Zeladonis
SummarY of Present Values
- .
Prepared August 9, 2000
Property Division
Marital ProDertv Value Date Value Husband Wife
Charles Schwab #9737-1425 Joint 6/30/00 1,268.55 1,268.55
Member's First Savings -# 24438 Wife 6/30/00 755.20 755.20
Member's First Checking - #24438 Wife 6/30/00 998.63 998.63
Delaware Investments (403b) #5183012843 Wife 6/30/00 4,061.26 4,061.26
Delaware Investments (403b) #5164074954 Wife 6/30/00 3,497.51 3,497.51
Delaware Investments (403b) #5157000416 Wife 6/30/00 1,645.50 , , 1,645.50
Sevem Trent Profit Sharing & 401(k) #199-36-9873 Wife 6/30/00 89,812.68 . . . 89,812.68
Transamerica Tax Sheltered Annuity Cert#0059899416 .
Grp#14623010 Wife 12/31/99 3,219.95. 3,219.95
Member's First Savings -# 67686 Husband 6/30/00 839.27 839.27
Member's First Checking. #67686 Husband 6/30/00 1,128.62 1,128.62
Member's First IRA - #12181 Joint 6/30/00 11,544.67 11,544.87 . .
State Farm Insurance #1044-3629 Wife 2/29/00 1,669.53 1,669.53
State Farm Insurance #0266-6775 Wife
State Farm Insurance #0832-5636 Husband 2/29/00 3,669.27 . 3,669.27
State Farm Insurance #LF-1761-566 Husband .'
UNISYS Pension Plan
Dining Room set 8/11/99 135.00 135.00
Organ 8/11/99 65.00 65.00
Ceda-r Chest 6/11/99 115.00 115.00
Oriental Rug 8/11/99 600.00 600.00
Windy Meadow Pottery (eight pieces) 8/11/99 1,600.00 1,600.00
Music Center w/ TV, VCR, Stereo 8/11/99 300.00 300.00
Rocker, Twig 8/11/99 65.00 65.00
Print, G Putt 6/11/99 125.00 125.00
Bedroom Set, Master 8/11/99 350.00 350.00
Desk, Maple 6/11/99 . 95.00 95.00
Linen Closet 8/11/99 75.00. 75.00
Computer, Hewlett Packard 8/11/99 1 ,000.00 1,000.00
TV & VCR, upstairs 8/11/99 55.00 55.00
Sofas (2) & Recliner 8/11/99 75.00 75.00
Washer & Dryer 8/11/99 75.00 75.00
Saw, radial arm Sears 8/11/99 125.00 125.00
Drill Press, Dul'llcraft 8/11/99 185.00 185.00
Sander, belt Enco 6/11/99 135.00 135.00
Saw, band Craftsman 8/11/99 150.00 150.00
Grinder, bench Craftsman 8/11/99 75.00 75.00
Compres$or air, Campbell Hausfield 8/11/99 275.00 275.00
Chain saw. Stihl 8/11/99 100.00 100.00
. SaW;"bill'ld,Central'Machinery ".~'_'. ---. . 1--- -. -. - .... 8/11/99 240.00. -. .._.240.00 ----
- ---_.-. .. "-'~'
Air-Condilloner; wind.owmount . . 8/11/99 200.00 - .. 200.00
Hllry~-WrE!nches, s~~kets, power hand tooilf - . 8/11/99 - 200.00 200.00 - ..-
Swing, outdoor .- .'. -- .. 8/11/99 - 55.00 . .- .- .55.00
Saw LSell~' chop type 8/11/99 .. 100.00 100.00. .
- Aulotnoblle;-PeUgeot 196!)""- ~._. .. -- .- '-'--'. 6/11/99 500.00 -50Ma' ..
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Mary Zeladonis
Summary of Present Values
Prepared August 9, 2000
Caravan, Dodge Grand 1996 8/11/99 12,900.00 12,900.00
Truck, Nissan 1986 8/11/99 1,000.00 1,000.00
Bayliner, 19', 1987 (Paid $3,OOO/owns 50%) Receipt 1,500.00 1,500.00
Residence - 662 Hillcrest Drive, Carlisle Joint 8/5/99 115,000.00 115,000.00
Marital Llabilitv
Membe~s First - #24438 Second Mortgage 6/30/00 (17,128.85) (17,128.85)
244,491.99
122,261.73
122,230.26
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Ml\.RY E. ZELADONIS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
TllOMAS M. ZELADONIS,
Defendant
#2000-5767
CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a divorce
decree:
1. Ground for divorce: irretrievable breakdown under Section (3301(c))
2. Date and manner of service of the complaint: Certified mail. restricted de1iverv number
7033000452153033 sent August 21. 2000 and acceoted August 25. 2000.
3 . (a) Date of execution ofthe affidavit of consent required by Section 3301 (c) ofthe Divorce
Code: by the plaintiff December 6. 2001 ; by the defendant December 6. 2001.
(b) Date plaintiffs Waiver of Notice in ~ 3301 (c) Divorce was filed with the prothonotary:
December 6. 2001.
Date defendant's Waiver of Notice in ~ 3301 (c) Divorce was filed with the prothonotary:
December 6. 2001
Date: December 6, 2001
RUb~~
Attorney for Plaintiff
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MARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
~-S7c'.1 CIVIL TERM
NOTICE TO DEFEND AND CLAIM RIGHTS
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 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 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 Cumberland
County Court House, Carlisle, Pennsylvania, 17013.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
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NARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
II
CIVIL TERM
AFFIDAVIT OF MARRIAGE COUNSELING
I, Mary E. Zeladonis, being duly sworn according to law, depose and say:
1. 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.
2. I understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse
and I participate in counseling prior to a divorce decree being handed
down by the Court.
I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities.
Dated:~
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is,
Plaintiff
sworn and sUbscribe~to
befIT me this _8J~ day
of )Q.f ,.() ~ , 20.00.
()
tlOfAIIIAL SIAl
CAllOI. A. MCllIIlOW:C=
CarlIsle IIato. eu..
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Notary Public
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MARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS.
Defendant
#
CIVIL TERM
COMPLAINT IN DIVORCE
TO THE HONORABLE. THE JUDGES OF SAID COURT:
AND NOW COMES, Mary E. Zeladonis, Plaintiff, by her attorney, Ruby D.
Weeks, Esquire, who avers as follows:
1. Plaintiff, an adult sui juris, is Mary E. Zeladonis, a U. S. citizen, who
currently resides at 662 Hillcrest Drive, Carlisle, Cumberland County,
Pennsylvania 17013, since 1975.
2. Defendant, an adult sui juris, is Thomas M. Zeladonis, a U. S. citizen,
who currently resides at 662 Hillcrest Drive, Carlisle, Cumberland County,
Pennsylvania 17013, since 1975.
3. Plaintiff and Defendant have been a bona fide resident(s) in the
Commonwealth of Pennsylvania for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 16, 1971, at Carlisle,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties in this or any other jurisdiction.
6. Neither party is a member of the Armed Forces of the United States.
7. The marriage is irretrievably broken.
8. Plaintiff and Defendant are not living apart as of yet.
9. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the Court require the parties to
participate in counseling.
-
10. Plaintiff requests the Court to enter a decree of divorce.
COUNT I (Al- INDIGNITIES
3301 (al (6l of the Divorce Code
11. Paragraphs 1 through 10 are hereby incorporated by reference and made a
part hereof.
12. The averments under this Count are not collusive.
13. Defendant has offered such indignities to Plaintiff, the innocent and
injured spouse, as to render her condition intolerable and life
burdensome.
COUNT II - IRRETRIEVABLE BREAKDOWN
3301 (cl of the Divorce Code
14. Paragraphs 1 through 13 are hereby incorporated by reference and made a
part hereof.
15. The marriage is irretrievably broken.
16. Plaintiff has been advised as to the availability of counseling and that
she may have the right to request that the Court require the parties to
participate in counseling.
17. Plaintiff requests the Court to enter a decree of divorce.
COUNT III - REOUEST FOR DIVISION OF PROPERTY
UNDER SECTION 53502 OF THE DIVORCE CODE
18. Paragraphs 1 through 17 are hereby incorporated by reference and made a
part hereof.
19. The partie@ purchased or otherwise obtained during the course of their
marriage property which is considered llmarital property".
20. Upon entry of a divorce decree, such property should be divided equitably
as is just and proper.
WHEREFORE, plaintiff prays that a decree in divorce be entered divorcing
plaintiff from the bonds of matrimony between the said plaintiff and defendant.
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20. Upon entry of a divorce decree, such property should be divided equitably
as is just and proper.
WHEREFORE, plaintiff prays that a decree in divorce be entered divorcing
plaintiff from the bonds of matrimony between the said plaintiff and defendant.
A. As to Count I, that a decree in divorce be entered divorcing
Plaintiff from the bonds of matrimony between the said Plaintiff and
Defendant.
B. As to Count II, in the alternative, should Defendant execute an
Affidavit consenting to a divorce because the marriage is
irretrievably broken, that a decree in divorce be entered divorcing
Plaintiff from the bonds of matrimony between the said Plaintiff and
Defendant.
C. As to Count III, that this Court determine marital property and
order an equitable distribution thereof.
D. Such other additional relief as the Court deems necessary and
appropriate.
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:
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Rub~~
Attorney for Plaintiff
10 West High Street
Carlisle, PA 17013
(717) 243-1294
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
The above named, Mary E. Zeladonis, being duly sworn according to law,
deposes and says that the facts contained in the foregoing Complaint are true and
correct, and the Complaint is not made out of levity or by collusion between her
and the said Defendant for the mere purpose of being freed and separated from
each other, but that it is brought in sincerity and in truth for the cause
mentioned in the said Complaint.
CY\;1
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Mary E.
Sworn and subsc~~~ to
bef~ me this aI.t:- day
of 6.(.<AJ.J , 20QQ.
O(l))~~, ~J)(JJf)
Notary Public
HOrAlllAl SIAl.
CUIClI. A. MOfIIOW. NoIaty PublIc
CartIsIe lien>, Cumberland CounIy
Nit Commiltlon ExpIres Jun* 2g, ~,o,c~
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MARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
#2000-5767
CIVIL TERM
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO PA R.C.P. 1920.4 (al (ll (ii)
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
I, RUBY D. WEEKS, ESQUIRE, Attorney for Mary E. Zeladonis, being duly
sworn according to law, depose and say that a true and correct copy of the
Divorce Complaint, was served on Thomas M. Zeladonis, at 662 Hillcrest Drive,
Carlisle, Cumberland County, Pennsylvania, 17013, by mailing the same to him
by certified mail, restricted delivery, No. 7099 3400 0004 5215 3033, on
August 21, 2000 Service was accepted on August 25, 2000.
RUb~
Sworn and S~SC~i~d to
befo}1 me th1s' day
of ~ .",.j , 20QQ...
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CARLISl.E PA 17lil13
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08-21-lil0 15:11:51
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:t";JniIil!t your name and address on the reverse
4\Ol.1hat we can relurn the card to you.
. .ch this card to the back of the mallpiece,
0t en the front if space permits.
t. Afllele Addressed to:
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D. Is delivery address different from item 1?
If YES, enter delivery address beiow:
3. Service Type
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4, Restricted Delivery? (Extra Fee) Yes
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MARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
#2000-5767
CIVIL TERM
PRAECIPE TO WITHDRAW COUNTS IN DIVORCE
TO THE OFFICE OF THE PROTHONOTARY:
Please withdraw the previous requests for Division of Property Under
Section 53502 of the Divorce Code in the above captioned divorce action since
these matters have been satisfactorily resolved between the parties through a
Property Settlement Agreement entered into September 6, 2000.
Dated: December 6. 2001
ub~'
R Y D. Wee s, squ~re
Attorney for Plaintiff
cc: Ruby D. Weeks, Esquire
Thomas M. Zeladonis, Pro Se
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MARY E. ZELAVONI~,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,I PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZE~ADONIS,
Defendant
#2000-5767
CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on August 21, 2000.
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 of a final decree of divorce after service of
notice of intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of
property, lawyer I s fees or expenses if I do not claim them before a
divorce is granted.
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. 54904 relating to unsworn falsification to authorities.
Dated:~
0Yl
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Plaintiff
Sworn and subscrjl<ed to
bef~ me th~ ~ day
of .\'..Q"m 0 \1 , 20D./.
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MARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
#2000-5767
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER S 3301 (c) OF THE DIVORCE CODE
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 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. ~ 4904 relating to unsworn falsification to authorities.
Date:
'. 'L/ G I () I
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
#2000-5767
CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on August 21, 2000.
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 of a final decree of divorce after service of
notice of intention to request entry of the decree.
4. 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.
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.
Dated:
IL1v\DI
~-;:?p~,
Thomas M. Zeladonis, Defendant
Sworn and
before me
of
subscribed to
this day
20_
Notary Public
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MARY E. ZELADONIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
THOMAS M. ZELADONIS,
Defendant
#2000-5767
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER ~ 3301 (c) OF THE DIVORCE CODE
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 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. ~ 4904 relating to unsworn falsification to authorities.
Date:
IL\(P)DI
~~~~...:
Thomas M. Zeladonis, Defendant
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