HomeMy WebLinkAbout00-06250
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE ~
.
BEEN RAISED OF RECOR!lI~ THIS ACTION FOR WHICH A FINAL ORDER HAS NOT .
YET BEEN ENTERED; W~ ~
IT IS FURTHER ORDERED AND DECREED that the Marriage Settlement Agreement .
executed by and between the parties, dated December 27, 2001, is incorporated .
by reference into this Decree for the purposes of enforcement, but shall
not be deemed to have been merged with this Decree.
I"
, ,
"-~' ~ -
.
, .
,
. .
.
. .
~ ~ ~ ~ ~ ~~ ~~~~ ~~~~
...
...
"',., ;!;iF. "':Ii Of.
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
.
.
.
.
PENNA.
STATE OF
.
.
IJlIXJRA M. PASTUCKA
No. 00
6250
.
PI JI TNTTFF
.
.
VERSUS
MARTIN J. PASTUCKA
.
.
.
.
DEFENDANT
.
.
DECREE IN
DIVORCE
.
.
.--
~
, IT IS ORDERED AND
tl
~,
,
AND NOW,
DECREED THAT
LAOORA M. PASTlilCKA
, PLAINTIFF,
.
MARTIN J. PASTUCKA
, DEFENDANT.
AND
.
.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
AmC!~
PROTHONOTARY
.
.
.
.
.
"n" "'Of. "';to
,In!:",:+::f. '" '" :f.
..
=~" . ~",.;;.t@.
;ti"'if.;F.ff.~1.f.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
,
,
,
,
.
.
.
,
,
,
.
.
,
.
.
.
.
.
,
,
.
,
.
.
,
,
,
.
.
.
J.
,
,
,
,
,
.
.
,
Of.:f. "';+;
~ =~ -~ -~--"<
ill
"_". A">> -."~-~.,. "'i.p,,
,
.
,,' ~-,_, ''.- -.V'
);l :31-01
kJ :3/-0/
~ .. ~'..." ......"d""l'.%C'~ '..", ,. .".,.~.. I!lfr~1Il1TITT1! i"
" '~,"'~
~-4 . - ~
M~~.M~.~ 4~
lj(~ ~ -?4"~
,
~~
_ r I'lt I!__ , <,,,"",,cI'l!8 _ ,~ " '!""'_
- ~,~ _" ";_~, C,'__
"
JI"
:2[,f.Li '~wii%'~"
..
,
,
MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this ;[7 dayof t>eceM bel
, 20QL, by and
between Ladora M. Pastucka ("Wife") - AND - Martin J. Pastucka, D.D.S. ("Husband"), at Harrisburg,
Pennsylvania.
WHEREAS, the parties hereto are husband and wife having been married on March 28, 1980, at
York, Pennsylvania.
WHEREAS, two (2) children were born ofthis marriage; said children being: Erin Michelle
Pastucka and Brandon Lloyd Pastucka. Both children are over the age of eighteen.
WHEREAS, diverse unhappy 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 desire to settle fully and finally their respective fmancial and property rights and
obligations as between each other including, without limitation by specification: settling of all matters
between them relating to the ownership and equitable distribution of real and personal property; 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 foregoing premises 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, Wife and Husband, each intending to be legally
bound hereby, covenant and agree as follows:
.-, ..
,.
',-c.
",' ",1,,,,-.,, .,(. <. .1-,
,"e';.
. ,-- ~'-"-->-. .
.:
1. Divorce and Separation. The parties agree to the entry of a decree in divorce pursuant
to Section 3301(c) of the Divorce Code of 1980. Husband and Wife shall at all times hereafter have the
right to live separate and apart from each other and to reside from time to time at such place or places as
they shall respectively deem fit, free from any control, restraint, or interference whatsoever by the other.
Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her
by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the
part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living
apart.
A. The parties acknowledge that a divorce action has been filed in the Court of
Common Pleas of Cumberland County, Pennsylvania at docket number 00-6250.
B. The parties agree that they will execute and file Affidavits of Consent and
Waivers of Notice oflntention to Request Entry of a Divorce Decree in the aforementioned matter
simultaneously with the signing of this Agreement. Thereafter, counsel for Husband shall file a Praecipe
to Transmit Record and obtain a divorce decree.
2. Division of Property. Husband and Wife agree that the following constitutes an
equitable distribution of the marital property.
A. Husband's Property. The following property shall become the sole and
exclusive property of Husband:
(1.) The property and lot situate at 5261 Strathmore Drive, Mechanicsburg,
P A, subject to all existing liens and obligations. Wife shall execute a Deed transferring her interest in
this property to Husband simultaneously with the signing of this agreement. Husband shall remove
2
'1-.
" .
.)~'J1lJ~griilii:,~~
,.
.
obligations.
(5.) Individual retirement account # 65966857, held by Baird, a Northwestern
Mutual Company. This account had a balance of$67,419.12 as of September 30, 2001.
(6.) Individual retirement account #65966726, held by Baird, a Northwestern
Mutual Company. This account had a balance of $292,290.64 as of September 30, 2001.
(7.) Annuity 15-144-758, held by Baird, a Northwestern Mutual Company.
This account had a balance of$123,639.26 as of September 30, 2001.
(8.) The 1994 Chevy Conversion Van.
(9.) The 1986 Mastercraft Boat.
(10.) Roney Plaza Associates, LTD.
(II.) 25,000 shares of Biotech stock.
(12.) All personalty, household goods, checking and savings accounts currently
in Husband's possession.
B. Wife's Property. The following property shall become the sole and
exclusive property of Wife:
(1.) Individual retirement account #65966507, held by Baird, a Northwestern
Mutual Company. This account had a balance of $24,462.93 as of September 30, 2001.
(2.) Husband shall transfer a total of $225,000 from his retirement and/or
annuity account to Wife's IRA # 65966507, held by Baird, a Northwestern Mutual Company. If
necessary, counsel for Husband shall prepare a QDRO to effect the transfer from Husband's retirement
4
~
-
~
~,-~-'.,~ ~'j';'
,
,
accounts. Wife shall approve the transfer of funds comprising the $225,000.00.
(3.) The 2000 Subaru Impreza. Husband shall cooperate in signing the
necessary documents to transfer title of this vehicle to wife. This vehicle shall be transferred to Wife
free of any debt. Husband has satisfied the debt associated with this vehicle. Wife shall receive the
refund from the cancellation of the car insurance policy on this vehicle.
(4.) All personalty, household goods, checking and savings accounts in Wife's
possession, including but not limited to furs, jewelry, china, crystal and silver.
(5.) Husband shall make a cash payment to Wife in the amount of $50,000.
Husband shall make this payment by giving wife $25,000 upon the signing of this agreement. The
balance of $25,000 will be due within 30 days of the date this agreement is signed. This payment is
made to Wife as part of equitable distribution.
3. ~. Husband shall pay all taxes, penalties and interest associated with the filing of the
1997,1998 and 1999 joint tax returns. Husband shall provide Wife with documentary evidence of
payments made in the form of cancelled checks and payment invoices from the IRS. Husband agrees to
indemnify Wife and to hold her hannless from any further assessments, penalties and interest asserted
with respect to the tax returns filed previously by the parties. Should there be additional tax assessments,
penalties, interest or additional payments of any kind to be made on account of any such returns filed by
the parties, Husband agrees to pay and discharge the same. To the extent that Wife had items of income,
gain, deduction, loss or credit which Wife failed to disclose or improperly disclosed to Husband with
respect to any taxable year, Wife shall pay any additional tax, interest or costs of audit associated with
this amount.
5
" .
lir-~"''"~',~j
,
4. Additional Documentation. The parties agree to execute any deeds, assignments, titles
or other instruments necessary and appropriate to accomplish the aforesaid division of property.
5. Transfers Subject to Existing Liens. Notwithstanding any other provisions in this
document all property transferred hereunder is subject to the existing lien or liens set forth above. The
respective transferee of such property agrees to indemnifY and save harmless the other party from any
claim or liability that such other party may suffer or may be required to pay on account of such lien or
encwnbrance.
6. Representations and Warranties. The parties represent and warrant to each other that
the property described in this Agreement represents all of the property in which they have any right, title
and interest, and that such property is subject to no mortgage, pledge, lien, security interest,
encwnbrance or charge except those which are disclosed herein.
7. Equitable Division. By this Agreement the parties have intended to effect an equitable
division of their jointly owned property. The parties have determined that an equitable division of such
property conforms to a just and right standard, with due regard to the rights of each party. 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 is being effected without the introduction of outside funds or other property not
constituting a part of the marital estate. It is the intention of the parties to treat all transfers herein as
non-taxable.
8. Relinquishment of Rights. Except as expressly provided herein, Husband forever
relinquishes any right, title or interest he may now or hereafter have in any tangible or intangible assets
now belonging to Wife, and Wife forever relinquishes any right, title or interest she may now or
6
""
.'-1-
o
-
"' '~~~k
hereafter have in any tangible or intangible assets now belonging to Husband.
9. After-Acquired Property. Each of the parties shall hereafter own and enjoy
independently of any claim orright of the other, all items of property, be they real, personal or mixed,
tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to
dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were
unmarried.
10. Debts. Husband and Wife shall each be solely responsible for all debts in their respective
names, including but not limited to personal loans, charge accounts and credit cards. Both parties
represent and warrant to the other that as of the date of this Agreement they have not incurred, and in the
future will not contract or incur, any debt or liability for which the other or the estate of the other might
be responsible.
11. Liabilities. All debts, contracts, obligations or liabilities incurred at any time in the past
or future by either party will be paid promptly by said party, unless and except as otherwise specifically
set forth in this Agreement; and each of the parties hereto further promises, covenants and agrees that
each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified
and save harmless from all debts or liabilities incurred by him or her, as the case may be, and from all
actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and
counsel fees whatsoever pertaining to such actions, claims and demands. Neither party shall, as of the
date of this Agreement, contract nor incur any debt or liability for which the other or his or her property
may be responsible, and shall indemnify and save harmless the other from any and all claims or demands
made against him or her by reason of debts or obligations incurred by him or her and from all expenses,
7
'~< '!liI~jjj~IIlIi~~il\OII@/~:-
legal costs, and counsel fees unless provided to the contrary herein.
12. Counsel Fees. Costs and Expenses. Each party shall be responsible for his or her own
legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their
marriage.
13. Waiver. In exchange for and in consideration of the promises and representations made
hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claims or
demand of whatsoever nature which he or she now has or hereafter can, shall or may have against the
other or the respective separate property of the other under the laws of the Commonwealth of
pennsylvania or any other governing state, country, territory or jurisdiction in the nature of spousal
support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative,
permanent or lump sum and right to seek equitable or community distribution or division or assignment
of property or similar marital rights. Wife shall withdraw the pending support action docketed at NO.
00-6250 in Cumberland County.
14. College Education Expense. The parties acknowledge and agree that Husband
shall pay the undergraduate college expenses which include room, board, tuition, books, fees and
related educational expenses incurred by their children that exceed funds received from grants,
scholarships, children's earnings, and funds available from Uniform Gift to Minors Accounts in
obtaining an undergraduate degree. This obligation shall only continue until each child reaches
the age of twenty-three (23), or graduates, whichever occurs first. Husband's obligation shall
cease prior to each child graduating or reaching age twenty-three (23) if either child fails to
maintain a minimum overall grade point average of2.0. In the event Husband becomes disabled
8
,,'..:. .:.J.,
_....oi'~ ~~;<iic-
and can no longer maintain gainful employment, Husband's obligations under this paragraph
shall be modified. In such event, Husband shall be required to make a good faith effort to
continue to pay for the children's college related expenses per this paragraph.
15. Full Disclosure. The respective parties do hereby warrant, represent and declare and do
acknowledge and agree that each is and has been fully and completely informed of and is familiar with
and cognizant ofthe wealth, real and/or personal property, estate and assets, earnings and income of the
other and that each has made a full and complete disclosure to the other of his or her entire assets and
liabilities and any further enumeration or statement thereof in this Agreement is specifically waived.
16. Releases. Each party does hereby remise, release, quitclaim and forever discharge the
other and the estate ofthe other from any and every claim that each other may now have, or hereafter
have or can have at any time, against the other, or in and to or against the other's estate, or any part
thereof, whether arising out of any former contracts, engagements or liabilities ofthe other, or by way of
dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take
against each other's will, or for support or maintenance, or of any other nature whatsoever, except any
rights accruing under this Agreement.
17. Indemnification. Each party represents and warrants to the other that he or she has not
incurred any debt, obligation, or other liability, other than described in this Agreement, on which the
other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding
is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act
or omission of such party, such party will at his or her sole expense, defend the other against any such
claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the
9
-
~
. ,_oj
~~-':'
other party in respect of all damages as resulting therefrom. Damages as used herein shall include any
claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation,
counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid
same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife
from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this
Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach
or default in perfonnance by Husband or Wife of any of the obligations to be perfonned by such party
hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation
threatened or instituted against either party which might constitute the basis for a claim for indemnity
pursuant to the tenns of this Agreement.
18. General Provisions. 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.
19. Fair and Equitable Contents. The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel. Each party acknowledges that he or
she has received independent legal advice from counsel of his or her selection and that each fully
understands the facts and has been fully infonned as to his or her legal rights and obligations. Each
party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and
that it is being entered into freely and voluntarily after having received such advice and with such
knowledge, and that execution of this agreement is not the result of any duress or undue influence and
that it is not the result of any collusion or improper or illegal agreement or agreements.
10
."" .1
ill. -"J1*;~_'i!
"~
20. Breach. It is expressly stipulated that if either party fails in the due performance of any
of his or her material obligations under this Agreement, the other party shall have the right, at his or her
election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other
legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any
services rendered by the non-defaulting party's attorney in any action or proceeding to compel
performance hereunder.
21. Execution of Documents. Each party shall on demand execute any other documents that
may be necessary or advisable to carry out the provisions of this Agreement.
22. Modification. No modification, rescission or amendment to this Agreement shall be
effective unless in writing signed by each of the parties hereto.
23. Severability. If any provision of this Agreement is held by a Court of competent
jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless
survive and continue in full force and effect without being impaired or invalidated in any way.
24. Applicable Law. This Agreement shall be construed under the laws of the
Co=onwealth of Pennsylvania.
25. Agreement Not to be Merged. This Agreement may be filed with the Court for
incorporation into the Decree of Divorce for purposes of enforcement only, but otherwise shall not be
merged into said Decree. The parties shall have the right to enforce this Agreement under the Divorce
Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this
Agreement as an independent contract. Such remedies in law or equity are specifically not waived or
released.
11
. _L
~J,
'ii!li'l!li:J!f;f,,-
.' #
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
Witness:
~I
.. "- ' j/
Jkd~ hL ~
Ladora M. Pastucka
Ck ~.-,.-'Ll!5
~n 1. Pastucka, D.D.S,
12
-
,. .~
-.:l
~-
~t.c_
....
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF DAUPIDN
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Ladora M. Pastucka, who being duly sworn according to law deposes and says that she is a
party of the foregoing Agreement and she executed same for the purposes therein contained.
Witness my hand and seal this c11.+J, day of {;IJLtJ.ViUJ.O.J ~ dt/O!.
~u.~
No Public
My Commission Expires:
NOTARIAL SEAL
Jean L. Kosier, Notary Public
City of Hummelstown,County of Dauphin
My Commission Expires Feb. 9, 2004
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF DAUPIDN
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Martin 1. Pastucka, D.D.S., who being duly sworn according to law deposes and says that he is
a party of the foregoing Agreement and he executed same for the purposes therein contained.
Witness my hand and seal this Zr'v-, day of ~J.JJI.^- ,2000.'
My Commission Expires:
13
Notarial Seal P bliC
Vicky L. FIlZ. ~ry ~nty
Harril\bu~9, Dex8U(res" DeC. 5. 2002
My CommISSIon P
. Association of Notaries
ember, Pennsylvania
.,-~"~, Co ,~~
~ .. ""~~ -
, .
.J:Dll!ili!l~:~-thi"'- ".~ -....;",.'iWa..\!!i.\\~mt~K~lWll'W<:;. j".. .~.........
~ I
..,_. .~~ .r-,
. -,? cE,_~ '", ,.. _
, ~
^
~
M,
1
~
r
I
....
f
~
0 C) 0
c: -0"1
s: Cl -..}
""Oc-,.:; ,.,1 j ;1~
Ii1P--;, C)
Z:J) 1'~ 70~)
zr.;~ -..l
c.n,^.
2('1 -0
_"_ ~i'~
- :::0:: ;2-(")
:zO
.b W t-:;f'n
)>c:: ~
~ );7
::0
<.T' -<
" -"-~.' ~
~
. ;, .~, ,
,'.
~",}M#,":
/ A VUcjw/lPraecipe to Transmit the RecordDecember 27, 2001 11 :35 AM
<
.
LADORA M. PASTUCKA,
PLAINTIFF
IN THE COURT OF COMMONS
PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
V.
NO. 00 - 6250
MARTIN J. PASTUCKA,
DEFENDANT
CIVIL ACTION - DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under 9330I(c) of the Divorce Code.
2. Date and manner of service of the Complaint: The Complaint was served via
certified mail on the Defendant on September 18, 2000. (See Affidavit of Service filed by
Plaintiff on September 22, 2000.)
3. (a). Affidavits of consent required by 93301(c) ofthe Divorce Code for both
Plaintiff and Defendant, are being filed simultaneously with this Praecipe.
(b)(l). Date of execution of the affidavit required by 93301(d) of the Divorce
Code: N/ A;
(b )(2). Date of filing and service of the Plaintiff's affidavit upon the respondent:
N/A.
4. Related claims pending: None.
11
"rrT
'-' ,., ~"
~
iIDl_:~~\_JlliI
.
"
,-",~,'.,c',-, __ ,_
~ - = ~.
'R
~ 'iiI.Il.
'-"- ~
~
'"'liil.l1.liiIiLj~_';d'~
1iIIi~~~'
g 0 0
-n
s:: '=' ---1
""Om rYI d1i1J
mrTi (J
Z:r.:1 N ,~at~J
Zc'
(1),.2" _J ()6
,L
~C! " :::j."
--,L-ii
~o :E: ~?D
)>~ ~? ':=:"Jii
LJ
,...,
~ :55
c:> -<
""
'., -~-,-",
""""''"'''''''''''~,
5815-J.4
.
.
5. (a). Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy ofwrnch is attached: N/A.
(b). Date Plaintiffs Waiver of Notice in !l330l(c) Divorce was filed with the
Prothonotary: December 27, 2001.
(c). Date Defendant's Waiver of Notice in !l3301(c) Divorce was filed with the
Prothonotary: December 27,2001.
SMIGEL, ANDERSON & SACKS, LLP
Date:
( .2. - "27- 0/
,
By:
,LUL)
LeRoy Smigel, Esquire
J.D. # 06917
Ann V. Levin, Esquire
J.D. #70259
2917 North Front Street
Harrisburg, P A 17110
(717) 234-2401
Attorneys for Plaintiff
~m<"~
5815-14
.
.
LADORA M. PASTUCKA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
v.
NO. 00 - 6250
MARTIN J. PASTUCKA,
Defendant
CIVIL ACTION - DIVORCE
CERTIFICATE OF SERVICE
I, Ann V. Levin, Esquire, attorney for Defendant in the above-captioned matter, do
hereby certifY that I served a true and correct copy ofthe Praecipe to Transmit the Record was
served on counsel for Plaintiff by depositing same in the U.S. Mail, fIrst class, postage prepaid,
on the 27th day of December, 2001, addressed as follows:
John J. Connelly, Jr., Esquire
James, Smith, Durkin & Connelly, LLP
P.O. Box 650
Hershey, P A 17033-0650
Smigel, Anderson & Sacks, LLlP
By: Lu~
teRoy Smigel, Esquire
I.D. # 06917
Ann V. Levin, Esquire
I.D.#70259
2917 North Front Street
Harrisburg, P A 1711 0
(717) 234-2401
Attorneys for Defendant
"".s'
~1~:!;1i'~~~~~~~~- ~:OO~i'JlliiIltidtr ~'[-m~Lr'- "
.
~ ~---
.-,
"."
>C, ~_ ,,'
--1l!If!I1
-".
IflililUJ ,"
;,~,._-.,~
l!,l
I
-~
,
il
!I
:1
i,
:-j
iJ
:1
i;
"
11
:1
:1
,I
I
I
!
.,
J
j
~
,
,
,
"
,
0 0 0
C 'T\
s.: c:l -.
;:HW r"T1 f{1~J
("')
z:o N -,-[Tl
ZC "i'}d
0)";:'" --.l '~?~J
,,<2:
'20 -0 {~~~
)>or 3
2: "
::;;.~ '-:? {srn
'-'
~ >'
:0
CD -<
. ", ~
>>,,",' "-~
,_" e- 'p _.~ _, '0_" . ~ . "^,_
--
. ~,' ' .'
,,,,--~.-, ~.--\".' ." .~ ~','--.-; ., ""'_"~"'_r.
;'-'" '
-
iII.',,-
LADORAM. PASTUCKA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. 00- l...lS"'O G'u:C '-r'iA..J.r.,
MARTIN J. PASTUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following papers, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a Decree in 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 the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at the Cwnberland County Court House, One Courthouse Square, 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 TillS 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.
Cwnberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone: (717) 249- 6
- '- ~ . 'i
,-""'--<'.-" ',".,,;;,-, . ,,,'c
~ . < . - -..., h - . , ,_''_ - ,
LADORA M. PASTUCKA,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
v.
. . .-.-
: NO. tiC.. &,.lSIJ &;.J I ~
MARTIN 1. PASTUCKA,
Defendant
: 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. lbis 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
.'i
,- 1-. ~
-' "~ -,l"_.~ - _ ;_,t~>" '--. --
""1I;:1I'.,t-
LADORA M. PASTUCKA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
:NO. (.r()- t..2S0 ~ 'f.u---
MARTIN J. PASTUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
1. Plaintiff is Ladora M. Pastucka, who currently resides at 6810 Clubhouse Drive,
Harrisburg, Dauphin County, Pennsylvania 17111.
2. Defendant is Martin J. Pastucka, who currently resides at 5261 Strathmore Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on March 28, 1980, in York, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The Plaintiff is a citizen of the United States of America.
7. The Defendant is not a member of the Armed Services of the United States of
America or its Allies.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
,'L,
.'<.-~"".. '. .,'n__ 'C;" ;." =',' ,~' ';",';;;.;.'1 ' _~." .,' ,","", " ,," ,
" ~ , <.
The parties to this action have been separated since June 8, 2000.
10. Plaintiff requests the Court to enter a Decree in Divorce.
COUNT II
CLAIM FOR EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
11. Plaintiff and Defendant are the owners of various real and personal property,
motor vehicles, bank accounts and insurance policies acquired during their marriage which are
subj ect to equitable distribution by this Court.
COUNT III
CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE
12. Plaintiff is unable to support herself through appropriate employment.
13. Plaintiff lacks sufficient property and income to provide for her reasonable needs.
COUNT IV
CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES
UNDER SECTION 3702 OF THE DIVORCE CODE
14. Plaintiff does not have sufficient funds to support herself and pay the counsel fees
and expenses incidental to this action.
15. Defendant is full and well able to pay Plaintiff alimony pendente
lite, counsel fees and expenses incidental to this divorce action.
~'~,,-, ".~"'-,~- ,-;,-~
.~-- - - -. -
'-'''--'"
:i":
WHEREFORE, the Plaintiff requests the Court to enter a Decree:
a. dissolving the marriage between the Plaintiff and Defendant;
b. equitably distributing all property owned by the parties hereto;
c. directing the Defendant to pay alimony to Plaintiff;
d. directing the Defendant to pay alimony pendente lite Plaintiffs counsel fees and the
cost of this suit; and
e. for such further relief as the Court may determine equitable and just.
JAMES, SMITH, DURKIN & CONNELLY
Date q - -5 -{)O
.'. ~. -~-=-,'-- "--,...;;.'"-
. ;""; 'j, .",,,, - - j.-",' '-', ~ ,-' ~ ,~,;,;" '.j., .
,~ -m~J;
VERIFICATION
I verify that the statements made in this Pleading 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:
Cj- 5-()()
~Fh>ii3?~
LaClora M. Pastucka, Plaintiff
"0 ..0
','-, '- . -, ---'. -~ -1IIi1Ji
c'_~' _ _ "~,__
, " 1. Co< ;. ~~;.;. .r ,;l ,- d. -~-,
~ 'r,"n~. ,~
~.
.
CJ r:",)
C c.-:.
(:) <- (/')
p ~ :J"" t7"l
~ ....... ~~ .'-J
~ ?t~ h .0 < ~
~ cr.-,_ (,,~')
, .~
S::-(.J
....... ~ 8 ~ 0 6 ~~E~
(;\ D
......
<> , I L
Cl -' :.)
(} itJ .....< (:J
Ov .
r- ~
J- ~
i
r"
5f
,- . ~
"-~" ~
.~
, - ,~ <
~,
~;,~
_.; - r
_ ~ \''::'.0
,
-; ~.--.:)
~
,-- -, f~~
~"
=<
j'"-"
, .
- --"- - ~-'- -'" - .. '-'N
"
LADORA M. PASTUCKA,
PLAINTIFF
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 2000-6250
MARTIN 1. PASTUCKA,
DEFENDANT
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAYIT OF SERVICE
,
I
COMMONWEALTH OF PENNSYL V ~
: ss.
COUNTY OF DAUPlllN
AND NOW, this did daYOf,~ ,2000, personally appeared before
me, a Notary Public in and for the State and (:;ounty aforementioned, John 1. Connelly, Jr., Esquire,
who, being duly sworn according to law, deI10ses and says that a copy of the Complaint in Divorce
I
was served on the Defendant, Martin J. Pastticka, on September 18, 2000 by certified mail number
70993400000929160946, addressee only, teturn receipt requested, as evidenced by the return
receipt card attached hereto and made a part hereof.
Sworn to and subscribed
before ill! thisrJJM-
day of ~ f1b .JYKJxll.,,2000.
~~~~,!U
NOTARIAl.. SEAl..
Jean L. Kosier, Notary Public .
City of Hummelstown,County of Dauphin
My Commission Expires Feb. 9, 2004
~ . "~. "..
" ,',',;w,,;.
" ".C- '-~--' -;, ~'~- . I
,-I _~__
_:. -
u,., .... ~'""~'
'" .'" h." "_,,, ., ,,>:l'~,_ " r~ _, , ,V,_~ "f""",~_ '_~_"'_' ,,,,,,.,..
'"-'
,~ - ,"'
. -.-,,..-~..,. .'
L "=
-~ ,',
-""-'
;,_,_., ''-" .,'_'_ " -.H'~
o
c:
:s:
-00]
rotTl
Z:D
:ZC.
U)~
20
'<
2;;0
~~
-<
.
.
,
I
.,}
~-...:J
:/~~A
i.:.::i
-;,>
?i!.
to
~
^~- ,<
'w'"""-F.'-'''d'_
,. , '"'~" -"'~'---. -- '- '-',' ~ '
,>;"',,,,"0;",,
'o~~'l!:!~
LADORA M. PASTUCKA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00 - 6250 CIVIL TERM
MARTIN 1. PASTUCKA,
Defendant
: CML ACTION - LAW
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 13, 2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3. I consent to the entry of a fmal 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 divorce 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.A. Section 4904, relating to
unsworn falsification to authorities.
Date: 1~/.;J-.7/t)1
y;Z/
\. . . /
tl ~ilfI-:JA..- astu-~~
Ladora M. Pastucka, Plaintiff
"-,'",
,,'.. ,,' ".
~
'N,'
'" "
'.".
, .,~~'."'-"
";i-'c,J:.i.o
'_<,. ,., '", _~ '~^'r'
,.~- ,-
'0"
''',.-.;;--<,:''-ill.,;''.,;;.:..;',;<'';''
.",
..
,~-
""",-'
,"..
,
(") 0 0
C ,,- -"n
s: Cl
;:gm rT1 "Tl
t:p M
z_.., N '?,\-::;
7C"
~~~ - ~:~~;C;
~C; --0 'T -oi
i> ~""'"" ~~ (':J
:z0 ~.
=0 '''-:? :-")jT;
>c ~
Z ",~
::0
~ (T\ -<
^
"";".-" 'c;-'
. ....".
~" .,-',
"'---,--',--
.
LADORA M. PASTUCKA,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00 - 6250 CML TERM
MARTIN J. PASTUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER ~3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! 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.SA Section 4904, relating to
unsworn falsification to authorities.
Date: I~/c;iol
~ .......)
~~O<o-- 7v~d~eh-
Ladora M. Pastucka, Plaintiff
~ -'->~
""":",_i
'.
.\".'
. ~ ,-.., .'~ - ,.
'-', ~''"''''''--''''''-^ -~._~- ,~
0 c~ ,~
'_,w_"
C 'T~
7' ;::::J
~~~^
"""OlJJ ~-
i-j
f1lrl'i ('"")
2:1.-' 1''':>
ZC~
~:(::', --j
r2C) ~.'O
~Q ::1:
--= c~ ~?
>c
:z;
=< (T>
,.~,~' ,
~ , ~'- - .,- '''~"' '-', -~
.,-,',- ",,,~' 'C ;.",co
\- . '~---
- .;e,i
, '
;I
,~
LADORA M. PASTUCKA,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00 - 6250 CIVIL TERM
MARTIN J. PASTUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 13,2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the 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 divorce 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.A. Section 4904, relating to
unsworn falsification to authorities.
Date:
w ff?~
Martin 1. PastuAa, Defendant
,,,,,.;;,~c "~c. ,." ..,' -,.,<,., .~ "";;"'''-,. .' ,J .. ,n ,'W.'..,~'P'<,.. ~ ~:',-,~' , .,.4'''''' " M ,. , , "
, , ~. . '"~~- .
...
("), CO 0
c:: ~n
s:: CJ -~,
""Om ('1 "'0
rnrn C"? ;::T1:~~
Z::C ,
Z;:-- N ~,;,!E\
mE:: -.J
~.,--- ;ki
;2C; -c -.L-:-~
~o ~ " . C)
-'";..
:>9 w ;':;'=;~ fn
,~
~ ~
~
....! --<
",0 ., .~__._' ~,
_ ~"~ ~, __~W _,. _ ~..
.^-,
, ~o
w
j\'_"">;,k_,"'_
, c"; ,~, ~-,- 1",,'-- ,'_"',
:.-' ,,;~
." ',. Ioii ~- > ..-c' ,-,
~ ""-~.
',. ,.
. ,"- ~
~
LADORA M. PASlUCKA,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00 - 6250 CIVIL TERM
MARTIN J. PASlUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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! 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.A. Section 4904, relating to
unsworn falsification to authorities.
Date:
9ah0~
Martin 1. Papellcka, Defendant
"";;.... ;.'V', ">"""
..UIl!!l"."
~ "i,;";;;.,',; 'i;-,,,-,;,;,;<<,',,;-.""'0;,-" .'., ' ),_,.:
.~,,_"' 'd 0_0_
",~ ,,----
'1iII.!
.""",,~.,,;,,,;;;~ "';;;;;.,,. ;'.",-",,,,,,,,,, , ,.
"~,-- ^.- "-~- .^
,-,
..,d'-;;'''''--''''
.", ....,"",."
,'i',",;.,'"" ";"" H. ".""d', "...
..
(") 0 0
c: ""l'1
;;:: Cl --,I
'"Om ,., l""r:"
!;2gj C')
z-' N '~?9
C/) \.,~".. .,......!
-<2:: 0
~C) -0 L
>'0 3: ~g
:;2 *' ...,
~ ~
-.J -<
~.
,,;
.,. - ,--~ --.
~. ~
J ,_
~, ~,"-_.~ -,
" '':'_,"<,,,'ci-:'!:-~,' ,..j-;L.,"
',V -'16
LADORA M. PASTUCKA,
Plaintiff
v.
: N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO. 00-(.,..215-6 ~tt~~
: CML ACTION - LAW
: IN DIVORCE
MARTIN 1. PASTUCKA,
Defendant
PRAECIPE TO ENTER SOCIAL SECURITY NUMBERS
TO THE PROTHONOTARY:
Please enter the following social security numbers in the above-captioned divorce action:
Ladora M. Pastucka - 165-54-6614
MartinJ. Pastucka-192-40-1635
JAMES, SMITH, DURKIN & CONNELLY LLP
Date: q - S- ()D
~,,'
_.~_ c:.' --'," _.-,.. ;.s,~, . .'.'
~,' - ~. >-,-~ ""
,~C u.
--- ~
II]
~, ,
~""''--'<-- '"
, ~<
--,<,-
"<,
o
~
-,-:;::
Q"ii:';-:'
.<c:::::;
~i:-~'-:
:~~:'=-_!
-~7 '-_'
~:; ~~
~=J
-<:
,
~-.
"I
I
(--'
c
,:0
:~
c) ~,
.--,
'-1-'
-":)
;:..0
r"
,~
:::::::1
~:::J
-<
~
"
"
="
.r-""'-"~_b!_~__,"-;i
LODORA M. IPASTUCKA,
Plaintifli'Petitioner
VS.
IN TBE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION - DIVORCE
MARTIN J. PASTUCKA,
DefendantJRespondent
NO. 00-6250 CIVIL TERM
IN DIVORCE
DR# 30,088
Pacses# 337102666
ORDER OF COURT
AND NOW, this 261h day of September, 2000, upon cousideration of the attached Petitiou for
Alimony Pendente Lite andlor counsel fees. it is hereby directed that the parties and their respective
counsel appear before R.J. Shaddav on October 24. 2000 at 9:00 A.M. for a conference, at 13 N. Hanover
St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.IW
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY TIIE COURT,
George E. Hoffer, President Judge
MailN'pieson:.
"'...M..,.,w.,,,.........'.'.... .1
~"'2fl'!ll'iffo::' .
Petitioner
< Respondent
John Connelly, Jr., Esquire
)1.1.
, Conference Officer
Date of Order: September 26, 2000
YOU HAVE THE RIGHT TO A LAWYER, WBO MAY ATTEND TBE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTB BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
""~'-;'-' ,
.";_~,,,."' ';_i<.~_' 4' -- -"_';""",,,,.-.,,,.' ;-:"""";'
I
Ii
!I
il
II
II
I]
b
r:
II
II
II
IJ
Ii
,
'~"- ~.,
~o' " ,~~. "
,:"
----.-'..:.',
Of'
FILEfJ-OFfJCE
[',:"\r\T,-Jn~ jI~,,,.,\oy
j :'_,'1: "....'!\;i,...:!rJl
Oil <:,;FP 2',
v \...,_, .......
~" 3 3'-
!-'~ . ....
. II "., w
CUMbt}iJ\i~O COUNll
PENi\lSYLVA\IiA .
,--,~-~-_ ,,"'b.".J>" ",,,,~,',":_,i:. h'-__' Or _u:.,- ,,_. .".. -,-.,;~"'c.~'''"''''.~ h-
"'''"''''
11111
,~ __IOOl~.,!",J.,mj~~~JiIII'.tt'l!f'''''''iC'Jf'''r-!l>''.~!f[j'0'F~>Ii\IIH';;''~~~'I,j';,l,w,'!!i I_"",;~I!,,, ~
-';;..,)
0_'_
'- -
'" ~';:'-h
, -' .'_\',C;"_" - '~. "'_4~' '_
.j
-
LADORA M. PASTUCKA,
Plaintifti'Petitioner
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
:NO. CU- (...2S'C:) C;,-,~C T~
MARTIN J. PASTUCKA,
Defendan1JRespondent
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW, comes the Petitioner, Ladora M. Pastucka, and through her attorneys, James,
Smith, Durkin & Connelly LLP, and avers as follows:
I. The Petitioner is Ladora M. Pastucka, who currently resides at 6810 Clubhouse
Drive, Harrisburg, Dauphin County, Pennsylvania 17111.
2. The Respondent is Martin J. Pastucka, who currently resides at 5261 Strathmore
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Ibis Petition is being filed concurrent with a Complaint in Divorce in which a claim
has been raised for alimony pendente lite. A copy of said Complaint is attached hereto and marked
Exhibit "A".
WHEREFORE, your Petitioner respectfully requests this Honorable Court to schedule a
conference with Domestic Relations to hear the alimony pendente lite claim.
Respectfully submitted,
JAMES, SMITH, DURKIN & CONNELLY LLP
Date: q, - / !r () ()
~D''''''-?f''A
~,~..-. >-
_. '^" '_'h
, _oJ"'_'_, ~", '-cJ~-'-~' -, '-,""'n'
_<. ~. "'<_';-"~-,;;;,;;',o: ~'--.i .
I:'
VERIFICATION
I verify that the statements made in this Pleading 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:
q - /3 - ()()
:?ftU/&ld- \~tkd-
,~.
t,,' " " '" -'0 ., ,.j", C IT. I"~
EXHIBIT "An
",~-o';~C'=',X'0~..~ ". _>""e'-,' -, "'''.,
~--'-..,
"
~ ~~'""'''_'''''\In,-,~l'
t.
LADORA M. PASTUCKA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO.
MARTIN J. PASTUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following papers, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a Decree in 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 the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO mID OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone: (717) 249- 6
1~.~.iw_lJ"i,I;;I!!.,-i'#1c."
LADORA M. PASTUCKA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO.
MARTIN J. P ASTUCKA,
Defendant
: CML 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
~ ---
. ,
~-~'fu~k~,j
LADORA M. P ASTUCKA,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO.
MARTIN 1. P ASTUCKA,
Defendant
: CML ACTION - LAW
: IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
1. Plaintiff is Ladora M. Pastucka, who currently resides at 6810 Clubhouse Drive,
Harrisburg, Dauphin County, Pennsylvania 17111.
2, Defendant is Martin 1. Pastucka, who currently resides at 5261 Strathmore Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3, Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on March 28, 1980, in York, Pennsylvania
5, There have been no prior actions for divorce or annulment between the parties.
6, The Plaintiff is a citizen of the United States of America.
7, The Defendant is not a member of the Armed Services of the United States of
America or its Allies.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
_ ........~..M"'~,M;;:;::i-~'I"--
The parties to this action have been separated since June 8, 2000.
10. Plaintiff requests the Court to enter a Decree in Divorce.
COUNT II
CLAIM FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
11. Plaintiff and Defendant are the owners of various real and personal property,
motor vehicles, bank accounts and insurance policies acquired during their marriage which are
subject to equitable distribution by this Court.
COUNT ill
CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE
12. Plaintiff is unable to support herselftbrough appropriate employment.
13. Plaintiff lacks sufficient property and income to provide for her reasonable needs.
COUNT IV
CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES
UNDER SECTION 3702 OF THE DIVORCE CODE
14. Plaintiff does not have sufficient funds to support herself and pay the counsel fees
and expenses incidental to this action.
15. Defendant is full and well able to pay Plaintiff alimony pendente
lite, counsel fees and expenses incidental to this divorce action.
" ~L_u.,<"",.MW
WHEREFORE, the Plaintiff requests the Court to enter a Decree:
a. dissolving the marriage between the Plaintiff and Defendant;
b. equitably distributing all property owned by the parties hereto;
c. directing the Defendant to pay alimony to Plaintiff;
d. directing the Defendant to pay alimony pendente lite Plaintiff's counsel fees and the
cost of this suit; and
e. for such further relief as the Court may determine equitable and just.
JAMES, SMITH, DURKIN & CONNELLY
Date q - 5 -(){)
.~~~I1;t-m,,"';.
VERIFICATION
I verify that the statements made in this Pleading 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: 1- .5- ()[)
,'7J.1m;<)];-h~~dUL-
Ladora M. Pastucka, Plaintiff
~ ^' ,-, ~& <0"".< '~.---c;,..,-.,,_~_ ":'-' ,-",,- -""'~-"h,~
'.
LADORA M. PASTUCKA,
Plaintift7Petitioner
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA
: NO.
MARTIN 1. PASTUCKA,
Defendant/Respondent:
: CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, John 1. Connelly, Jr., Esquire, of James, Smith, Durkin & Connelly, attorney for the
Petitioner, Ladora M. Pastucka, hereby certify that I have served a copy of the Petition for Alimony
Pendente Uta on the following on the date and in the manner indicated below:
U.S. MAIL. FIRST CLASS. PRE-PAID
Martin 1. Pastucka
5261 Strathmore Drive
Mechanicsburg, PA 17055
JAMES, SMITH, DURKIN & CONNELLY
DATE:
Q-j,3-DD
,
""',~ - - - ,<'
0'",0 "
,",,""',...l;'
,'.
~'-
,..'_ ' "'" ,0 ,~
o
-,~-- .
Cl
C
:CJ
-ci'-,
Q;:
L::.... '
;.--
~? ;-: .
)>~;
..
-~
~
-,
c-,
-"
~/)
"'1
'.1
L.
~'~..:
";1
~. - )
()'<
~~
-
- ~-, -
"".".-
__....-""'"',''''~.ilU.!
LADORA M. P ASTUCKA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 00 - 6250
MARTIN J. PASTUCKA,
Defendant
CNIL ACTION - DNORCE
NOTICE TO PLEAD
TO: Ladora M. Pastucka, Plaintiff and
John J. Connelly, Jr., Esquire, Attorney for Plaintiff
YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer and
COWlterclaim to Complaint in Divorce within twenty (20) days from service hereof or a
judgment may be entered against you.
By:
LeRoy Sm el, Esq re
LD.#09617
Ann V. Levin, Esquire
LD.#70259
2917 North Front Street
Harrisburg, P A 1711 0
(717) 234-2401
Attorneys for Defendant
, - ,- "",,',,' ',..,;..-- ";'" ,'-;;L...:.-:~-
_d'i~"'","I;j,.*,~,
58l5M l-4Answer to Divorce Complaint! A VLlkld September 27, 2000
LADORA M. PASTUCKA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYL V ANlA
v.
NO. 00 - 6250
MARTIN J. PASTUCKA,
Defendant
CIVIL ACTION - DIVORCE
. DEFENDANT'S ANSWER AND COUNTERCLAIM TO
COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE
AND NOW, comes Defendant, Martin J. Pastucka, by and through his counsel, Smigel,
Anderson & Sacks, and answers Plaintiffs Complaint as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Denied.
9. Defendant is without sufficient information to establish the truth of the alleged
averment.
10. Denied.
II. Admitted.
12. Denied.
13. Denied.
14. Denied.
IS. Denied.
I~
--;."
.,.,;....-,:;--;
~h>ijihi\i,_
COUNTERCLAIM
AND NOW, comes Defendant/Plaintiffin Counterclaim, Martin J. Pastucka, by and
through his counsel, Smigel, Anderson & Sacks, and avers as follows:
COUNT I
DIVORCE UNDER 3301(a)(2) OF THE DIVORCE CODE
16. Defendant/Plaintiff in Counterclaim repeats and realleges the averments of
paragraphs I through 15 which are incorporated by reference herein.
17. Plaintiff/Defendant in Counterclaim has committed adultery.
18. It is believed that Plaintiff/Defendant in Counterclaim has engaged in an
extramarital relationship with an individual named Ralph Spontak.
WHEREFORE, Defendant/Plaintiff in Counterclaim requests the Court to enter a
Decree in Divorce pursuant to Section 3301(a)(2) of the Divorce Code.
COUNT II
DIVORCE UNDER 3301(a)(6) OF THE DIVORCE CODE
19. Defendant/Plaintiff in Counterclaim repeats and realleges the averments of
paragraphs 1 through 18 which are incorporated by reference herein.
20. Plaintiff/Defendant in Counterclaim has offered such indignities to
Defendant/Plaintiff in Counterclaim, the innocent and injured spouse, as to render his condition
intolerable and life burdensome.
WHEREFORE, Defendant/Plaintiff in Counterclaim requests the Court to enter a
Decree in Divorce pursuant to Section 3301(a)(6) of the Divorce Code.
- - &.'"
" -,"
"1'1; M,"""""'';';;:',
COUNT III
COUNSEL FEES. COSTS AND EXPENSES UNDER SECTION 3702
21. Defendant/P1aintiff in Counterclaim repeats and realleges the averments of
paragraphs 1 through 20 which are incorporated by reference herein.
22. Defendant/Plaintiffin Counterclaim does not have sufficient funds to pay counsel
fees, costs or expenses incidental to this action.
WHEREFORE, Defendant/Plaintiff in Counterclaim requests the Court to award him
counsel fees, costs and expenses.
Respectfully submitted,
Date: October 6, 2000
Smigel, Anderson & sac~ ,,~
By: ;f)M..if
LeRoy Smi I, Esquire
I.D. # 06917
Ann V. Levin, Esquire
LD. #70259
2917 North Front Street
Harrisburg, P A 17110
(717) 234-2401
Attorneys for Defendant, Martin J. Pastucka
"~" .
,~-~ ,~.- ; - . .-.",
__i",'i.~-",,'
VERIFICATION
I, Martin J. Pastucka, verify that the statements contained in the foregoing pleading are true
and correct to the best of my knowledge, information and belief. I understand that false statements
therein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to
authorities.
Date: /b/S//)()
I
~,t ~k-
MARTIN J. ~STUCKA
-
,.
~ <
- ~--" "~-,~ ~._,,; . - ~ "' - . -,
",*,~"d,,~ti,.
LAD ORA M. PASTUCKA,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6250
MARTIN J. PASTUCKA,
Defendant
CIVIL ACTION - DIVORCE
CERTIFICATE OF SERVICE
I, Ann V. Levin, Esquire, attorney for Defendant in the above-captioned matter, do
hereby certifY that I served a true and correct copy of Defendant's Answer and Counterclaim to
Complaint Under Section 3301 of the Divorce Code on counsel for Plaintiff by depositing same
in the U.S. Mail, first class, postage prepaid, on the 12th day of October, 2000, addressed as
follows:
John J. Connelly, Jr., Esquire
James, Smith, Durkin & Connelly, LLP
P.O. Box 650
Hershey, P A 17033-0650
Smigel, Anderson & Sacks
By ,L IL)
LeRoy Smigel, Esquire
LD. # 06917
Ann V. Levin, Esquire
LD. #70259
2917 North Front Street
Harrisburg, P A 17110
(717) 234-2401
Attorneys for Defendant
".6
I
-,..r\"~_ --i[iIlJ.[~iijj;;lli'
~ ~~"" '.' '",''''_~~__c_~" , _~ . ~_,_._c,' - .,
!lIJrl.JW~~
.,.-
'c'
.-~
";-,'. "'"
- ~"
<~ ~- ,., - - ,',_ dO '
-
~
~~L
::..:< r~__-
U;",-.':
r::
;?::C~
.c_ '-',
s.::; >~::
2.
:<.
."---" ~~,
q
~,
<-~
'--'
0:-":'
r,"":')
_ ~l
--i
c:o
'.0
tS
-'1
CD
'-:;_:,:)
j:-n
~:-i
d;'~
=<
.,
- .
-
-.""""_~I'~";.~
LADORA M. PASTUCKA,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
v.
NO. 00-6250
MARTIN J. PASTUCKA,
DEFENDANT
CNIL ACTION - DNORCE
CF,RTTFTCATR OF SF.RVTCR
I, Ann V. Levin, Esquire, Attorney for Defendant, do hereby certify that on the 24th day of
October, 2001 I served an original and one (1) copy of Defendant's Interrogatories addressed to
Plaintiff's counsel in the above-captioned matter, by depositing same in the United States Mail, first
class, postage paid, addressed as follows:
John J. Connelly, Jr., Esquire
James, Smith, Durkin & Connelly
P.O. Box 650
Hershey, P A 17033
SMIGEL, ANDERSON & SACKS, LLP
By: Lv d~~)
Ann V. Levin, Esquire
!.D. # 70259
2917 North Front Street
Harrisburg, PA 17110-1260
(717) 234-2401
Attorneys for Defendant
,~ ".'
.~ ~ ',"
IJll>l
rBi. ~-,.;.. -~. "1iM~~~ill-~
. ''-'/IIf'.
~ili~
.. ~~
-
0 0 0
C ~.n
:S, 0 :_:.3
""00::1 n -c_'-; "
nltT, -l r~
Z::G N '_c.--
Z~::: \..0 ;:,/"/
(J) ,".,
-<L_ '-';CJ
r.:::C; -0 "
-:PC >-.~ -"
~;::-.....O
2': ,::-.::..rn
~C) ~
..-Y c= '~
~
=1 r0 :.s
-<. ~
. .
-~'"I",>h;
5815.14
LADORA M. PASTUCKA,
PLAINTIFF
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 00-6250
MARTIN J. PASTUCKA,
DEFENDANT
CIVIL ACTION - DIVORCE
CERTIFICATE OF SERVICE
I, Ann V. Levin, Esquire, attorney for Defendant in the above-captioned matter, do hereby
certify that I served the foregoing Request for Admissions Pursuant to Pa.R.Civ.P.4014 upon
counsel for Plaintiff by depositing same in the U.S. Mail, fust class, postage prepaid, on the 24th
day of October, 2001, addressed as follows:
John J. Counelly, Jr., Esquire
James, Smith, Durkin & Connelly
P.O. Box 650
Hershey, P A 17033
SMIGEL, ANDERSON & SACKS, LLP
By: Lc/L ~
LeRoy Smigel, Esq.
LD. #: 09617
Ann V. Levin, Esq.
I.D.#: 70259
2917 North Front Street
Harrisburg,PA 17110
(717) 234-2401
Attorneys for Defendant
"0',',
~:-, ~-
""""'-'-'
~~Ii-lljj.h-'~!>i
,,-"'''.'''-
""~-"-1l~~;ji< -l1D!.!1A
-~ ~ ",
IM-......."'~
.
11'~?'liliIlIiI
JI!IWU
L1Jill
o
c
~
-rJC.L:
rnj'c:
Z:L.
~ ~~~~
r:;C,'
~O
--0
)::;'C
Z
-'
-<
o
()
'~n
o
.-')
':...,
N
1..0
.'-
;-71
, .
.v
'-, "1,
-:0' -Cl
~'--;'~O
tj;-r1
-'-i
~
:0
-<
r.......,
'"
'.....",. '~.,,-,'" y" .' '
~ e" n, ,-'C.' ,
,
-
LADORA M. PASTUCKA,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00 - 6250 CIVIL TERM
MARTIN J. PASTUCKA,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO WITHDRAW CLAIMS
TO THE PROTHONOTARY:
Please withdraw the claims for Equitable Distribution, Alimony, Alimony Pendente
Lite, Counsel Fees, Costs and Expenses in the above-captioned divorce action.
JAMES, SMITH, DURKIN & CONNELLY LLP
Date:~
By:
J J C el, Jr., Esquire
A; 0 ey or PI . ntiff
Post Offic 650
Hershey, PA 17033
(717) 533-3280
PA LD. No. 15615
.'..'.'M"
,,--_.~, ,,~.~-~"
...'". ".llIlf
" -,," .>< ."'+' ,~ :(.
-
~- ,-
,-"
--~
""'-<'~'-'~'.-
-' . ",,-~ "
o
~
-UcP
mm
zx
Z'-.'
m'c,
""j':~:>,"
-..--<:"-.
,<0
~O
~g
~.
""",.
o
CI
f71
n
N
-'
-0
:;:'::
m., "
,
I
,
,
o
-n
o
;r;
:.y>t5J
':~-:;~~,),
--.,,~--r'
';..c)(')
~rn
:0
'<
-
(;1
~
,~ &<'-~"'Wi,,'~^
In the Court of Common Pleas of CUMBERLAND County, Peunsylvania
DOMESTIC RELATIONS SECTION
LADORA M. PASTUCKA ) Docket Number 00-6250 CIVIL
Plaintiff )
vs. ) PACSES Case Number 337102666/D30088
MARTIN J. PASTUCKA )
Defeudant ) Other State ID Number
ORDER
AND NOW, to wit on this
14TH DAY OF JANUARY, 2002
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or G() Other
ALIMONY PENDENTE LITE PETITION filed on SEPTEMBER 13, 200 in the above captioned
matter is dismissed without prejudice due to:
THE PARTIES'S MARRIAGE SETTLEMENT AGREEMENT AND THEIR DECREE IN DIVORCE ON
DECEMBER 28
o The CeI
petitioner.
~~
DfYl
,instated upon written application of the plaintiff
BY THE COURT:
DRO: RJ Shadday
xc: plaintiff
defendant
John Connelly, Jr., Esquire
LeRoy Smigel, Esquire
JUDGE
Edgar B. Bayley
,'nAIL _r-'~.
',. .:,...;:1 . . _"i~,: ;,~ :1:
~.,..
1'11/.0)"
Service Type M
Form OE-506
Worker ID 21005
^:'''''''"''.'~~~''~j,it!;M4.!'>3.!~,~_"'''',i>h'll',m;:.'''''-'4li!!,,J.;,Jiiii,m''''''i>-~~,;(~~m~.i\i;%U~_....'..~.,~.!1'".'~~l:il~r " ~~>
I
0 0 r..-:J
r- l'J
~~ "n
.~- ,
"--0 C' ~
;,":/..
m n ~~i'" -C'
Z "l i;'j
Z r-
(f)~ u-; l..,'"
-/~..:
~~, ':'::':( (~)
~C ~T.J --;-,
._o:.~r-. -~-f-'" ::c,d ::rJ
z , -')
)> (j ~....) i=-n
C
Z -.
=2 ':." :b
-<
" ~
~~ ,~-
t,
~
LADORA M. PASTUCKA,
PLAINTIFF
IN,THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-06250 CNIL TERM
MARTIN J. PASTUCKA,
DEFENDANT
CNIL ACTION - DNORCE
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW, this ~r day of \~ -; 2002, it appears to the Court as
y
follows:
1. The parties hereto were husband and wife and a divorce decree has been entered
by this court to the above referenced docket number.
2. Martin J. Pastucka (Social Security No. 192-40-1635) hereinafter referred to as
"Participant", current and last known mailing address is 5261 Strathmore Drive, Mechanicsburg,
PA 17055.
3. Ladora M. Pastucka (Social Security No. 165-54-6614) hereinafter referred to as
"Alternate Payee", current and last known mailing address is HOO Woodridge Drive,
Middletown, PA 17057
4. This Order shall apply to Accounts No. 6596-6857 and 6596-6726 held by Baird,
a Northwestern Mutual Company, hereinafter, "Accounts".
5. To accommodate the marital property distributed between the parties, IT IS
ORDERED, ADJUDICATED AND DECREED as follows:
A. It is the intent of this Court that the provisions of this Order operate as an
effective assignment for the Alternate Payee's interest in the Accounts as set forth below under
both state and federal laws, for all purposes.
.
, '., ~ ~
.~
~ .r.$',,,,*~,_
5815.14
B. Baird, a NorthwestemMutuaICompany;'shal1transfer.to-Altemate-Payee--
$225,000 from the Accounts as follows:
(I) $183,000 shall be transferred from account # 6596-6726;
(2) $42,000 shall be transferred from account # 6596-6857.
C. The distribution of $225,000 shall be transferred to: Alternate Payee's Account
No.: 6596-6507, held by Baird, a Northwestern Mutual Company.
,
The distribution is to be paid as soon as administratively possible following the
date this Order is approved as a Qualified Domestic Relations Order.
D. Nothing contained in this Domestic Relations Order shall be construed to require
Baird, a Northwestern Mutual Company:
(I) To provide to the Alternate Payee any type or form of benefit, or any option, not
otherwise available under the Accounts, or
(2) To pay any benefits to the Alternate Payee which are required to be paid to
another alternate payee under another domestic relations order previously determined by Baird, a
Northwestern Mutual Company, to be a Qualified Domestic Relations Order, or
(3) To require Baird, a Northwestern Mutual Company, to provide increased benefits.
E. This Qualified Domestic Relations Order has been drafted in accordance with the
marital property distribution agreed to by the parties. The transfer of Account funds pursuant to
this Qualified Domestic Relations Order is not intended by the parties to constitute in any way a
sale or exchange of assets, and the division is being effected without the introduction of outside
funds or other property not constituting a part of the marital estate. It is recognized that the
parties intend this transfer to be non-taxable.
,. ~"*"-,,
5815-14
F. The parties are-directed.to timelysubmit.all doCUl1l€llts,. including releases, that.
are required to finalize this Order.
G. This Court reserves jurisdiction to issue further orders as needed to execute this
Order.
H. A certified copy of this Domestic Relations Order shall be served upon Baird, a
Northwestern Mutual Company.
By
J.
.~
'~f[ Pff
t.O '.
R Lei!
~toJJelll
\
""diJJ,O'!F 'Dill~'_;IiliUI~~w..f~~~~~~~~I:l.IiI_.i;;'~''';;~"'' ; "
,,,v," '.
'"
p- ~,-
"~
'., r-d'
"'-'_'r
~"Q,
J~
.....1~'1
..., .
~ti
t5~
r G
~
t-,-
,
~~l'.
5815-1A
" ..
LADORA M. P ASTUCKA,
PLAINTIFF
IN1HECOURTOFCOMMONl'I:EAS-'~"'~-
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2000-06250 CIVIL TERM
MARTIN J. PASTUCKA,
DEFENDANT
CIVIL ACTION - DIVORCE
STIPULATION
AND NOW, this ~) day of =;~
, 2002, counsel for the
parties in the above referenced action hereby stipulate and agree that the Order attached hereto
encompasses the intent of their respective client and that it may be adopted as a Court Order.
SMIGEL, ANDERSON & SACKS
By:k tJ ~
Ann Levin, Esquire
J.D. #: 09617
2917 North Front Street
Harrisburg, P A 1711 0
(717) 234-2401
Attorney for Plaintiff
Attorney for Defendant
.J;;.'0.;..;;:e/',
.
'.^';"G..:"T "'Ill~IliI~~~lRll~,*,,"~'!I;~t!!i~iM'
","
,,-~'~
..
I""
,-~
-<~,
., ..... ,.
() Cl 0
C r....,) ,'"t
-~
s.. :1!':
"O(D ;!,7All
52~l:1 ;;"-:J ~
ZC:: I -, (';--j
-0
cn c~. .,:- \"
-<.--c..' c;
(:::: c:~ ~
~ -r] ~~-,
C) -',," ',:~~\ --,",
~ ~~
j> 0 ~
C 'J
2; --,
:"'''1 ~
-< 0 -<
~