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Home My WebLink About01-2260 FX . , - . . . . . . . . . Of. Of.:Ii '" :+:;r. . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, Janna Leiqh Mekulski No. n1-??fiO . VERSUS . Brian Gr~qorv Mekulski. . . . DECREE IN DIVORCE . . . . AND NOW, i) ~cc V'70 U . ('1 , Z{J(D! , IT IS ORDERED AND . . DECREED THAT .Trinnri T,jO,; ~'h M~lrl11sk:i PLAINTIFF, . . AND Brian Greqorv Mekulski , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . . . . . . . J. . . . . PROTHONOTARY - - . . . . . ;t;;t; '" '" '" . . '- '17'IC '_7. IT"L) ."'to-- ~"<~, x, -.',< ' ,J ~'-,",' "1 "..,~~_, ';,..." ~Y,-" ,"" '5'1'_'1". "_, ~ '. . ,.__,r _.,? f" r ,'" .",- ..",... - . -.-. .",~ ~lt~~''''''~.Td.;,;,;-'j'',t~;:'.-'",,,,,.:",\;,,,,,~,-Z,,,,,"~~.!.;,--.., - .iJ.ti:i:!1jj'llC' .i:.l:.:U~- t' -'if:0,;;;-'<~'l -'--'~ -;..,~\~.,.,l,;...,.~..,;,;iw--_- I~~[ )0/ ~ ",,-,-,' ~'''- c.~ eo(J '1 ~~L~~6 IN-1-y Uak'-( lUo+, I::..e.- 'h ~lLu:L -l-D 1) ~ . ~_~~{~~;,;,.J~_:ll",lSm,~~l_"",w,." _ ,.* ,~~,'X",=""""__ _ ,"""" ,>" _~ .,~,~ -,=-. . ~ ~~O,~ ..,-','_'u,'_i-;'__,~:""-"d<~)p ~~. -.. ~ ~-7: ~ I\\j 'If' .' .. , In The Court of Common Pleas of Cumberland County, Pennsylvania Janna Leigh Mekulski, CIVIL ACTION - LAW Plaintiff, ACTION IN DIVORCE 2co l' J. :2&{) VS. Brian Gregory Mekulski, COMPLAINT IN DIVORCE Defendant. Filed on behalf of P1aintiff,janna Leigh Mekulski. Counsel of record for this party: Peter]. Daley and Associates, P.C. Peter]. Daley II, Esquire 218 Wood Street California, PA 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Atty. I.D. # 70244 ;F;;;;;i::'::;::J~;{::\~;~~~~rt~1l,'?f',~_~:,nl'?2,~:?j!"',3,~~,',;y:._,':\ :il!-7':<':'}',_1~_'c ~Ys7 :'~~t,- ^>,".,-:::'o':r:;-'_,_:,,,"'''-,,'_ ~""_ ~ ',", ''''',,-,;qfi:: _-"-~ _ ~-t,_"',o,,,:,-~....~ "'~'" .,:~ ~_' , < Janna Leigh Mekulski, : IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERlAND COUNTY, PENNSYLVANIA vs. Brian Gregory Mekulski, CIVIL ACTION - IAW ACTION IN DIVORCE Defendant. 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. Ajudgment 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 child. 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 in Cumberland County. IF YOU DO NOT FILE A CLAIM FOR AUMONY, DIVISION OF PROPERTY, IAWYER'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 YOURIAWYERAT ONCE. IF YOU DO NOT HAVE A IAWYER 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, PA 17012 (717)249-3166 Janna Leigh Mekulski, : IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY PENNSYLVANIA vs. Defendant, CIVIL ACTION - LAW ACTION IN DIVORCE 7'l../?/- .2,2(,0 CLird. I~ Brian Gregory Mekulski, Complaint Under Section 3301 of the Divorce Code 1. The Plaintiff is Janna Leigh Mekulski, who currently resides at 27 Drexel Place, New Cumberland, PA 17070, Cumberland County, Pennsylvania 2. The Defendant is Brian Gregory Mekulski, who currently resides at 707 Apple Drive, Mechanicsburg, PA 17913, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 8, 1998, at St. Joseph Catholic Church, Mechanicsburg, Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. 'Ji:r ' .-' -;""';;' ,\:,:r,r/~,:-:-'-;:"<,':_,:,--'~' ~-'f'>~_~":'__;_:~~:-""_:~:;C, ~' ~:*:~.,v-_ ,. '.'Z" ..1;":.-'-,>1-~---~"-'-:g;:~_; - " -' '-'I. :,:';:-:-~_,--_":, "__"" '__" _ __ ~~., _ ,,__:,~~,,_", _~.~,"." ,'" , " -~,,-<, ,.." , 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's & Sailor's Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff and Defendant separated on or about August 22, 2000 and resumed co-habitation on January 7,2001 and were separated again on or about February 27, 2001. 8. There has been no prior action for divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 9. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. The parties have not entered into a written agreement as to support, custody, visitation, of the children, alimony or property division. COUNT I REQUEST FOR A FAULT DIVORCE UNDER SECTION 3301 (a)(6) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. Page 2 of 5 11,<~",' :"0> \~!,'t')f';J~~;_,,,,::'<';__'JTG>~;l~~O;',,,=,,j,_~, ::";r',.~'y,_~-,,c:m _,,,,r'>1", _ " ,,_, ",0_' _', <> ," ,,~.-,-_", -, ~I."_,_'" t,," , _"',~'>" ". _.", ,,~- , 12. Defendant has offered such indignities to the Plaintiff, who is the innocent and injured spouse, as to render Plaintiffs condition intolerable and life burdensome. 13. The action is not collusive, as defined by ~3309 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce, pursuant to ~3301(a)(6) of the Divorce Code. COUNT II REQ.UEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15. Mter ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also fIle such an affidavit. WHEREFORE, if both parties fIle affidavits consenting to a divorce after ninety (90) days have elapsed from the filing of Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to ~3301(c) of the Divorce Code. Page 3 of 5 '-'.,-1-:,:" .',,'-,:,.:-,.-;. . " . COUNT III REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301{d} OF THE DIVORCE CODE 16. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 17. At the appropriate rime, Plaintiff may submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, Plaintiff respectfully requests the court to enter a Decree of Divorce, pursuant to ~3301(d) of the Divorce Code, at the appropriate time. COUNT IV REQUEST FOR ALIMONY PENDENTE UTE AND ALIMONY UNDER SECTION 3701 AND SECTION 3702 OF THE DIVORCE CODE 18. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 19. Plaintiff is unable to sustain herself during the course of litigation. 20. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. Page 4 of 5 . 21. Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an Order of alimony in her favor, pursuant to ~3701 and ~3702 of the Divorce Code. 22. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff respectfully requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an Order of alimony in her favor, pursuant to ~370l and ~3702 of the Divorce Code. 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. Dated: I~ 0/ ~. E:\FORMS\Divorce\mekulski,janna.divorcecomp14.2.01.wpd Page 5 of 5 ;!~/:;. ::;,; ';, ~~ :;' ,~:,~~;'~t;;:~!r;';:~1~".,::i"\;S~(,~;;~::~_;~_A:_:,~,s:.'~_~:;:;::/ -" "'xn:'":-:~; - .~,)~, ,F," . ,'" ""'~l :,:-: ., -;c''''- ,- < .~ . ,'_.,,-,~,., "-_?,, .,,:::. - <. " - ~-" '!"-' . "-'~""~~r -, ,-1'__"'<"'_'>..' __"~'_'"_",.,,_ ,~ ,,' ," ~ f", <_, ,'7' ~_ .",~ - --,~~~ ~ ('::l :n:... ('\- .......... '- -1t:. -...") ~ '1 ---. " V( ~ ~ W 'j" d v~ ~ ~ ~ Q c I Yi , "-l " Q v 0 Vr Q .r,o ~~\J -::' , '\ ~ ~ '" '" ~ '" ~ s:- --- <.A 7\ j Cj ..-:~ '--..-, ! .3-> U) :~ ::i) -< ^ '" ',_-" e_._ _~ _" _., ,," ;Y,_ .,,-.,_' ,<"'t--;::- "O;f',<" ;:. ,'", ~^ - - ,:,'Tq~~,.,;,P"~:.' ')'S7:,~fjl-"",:,';'f~,,~'_~~v-;}':""*:<cl1','.~,j!,lT":*,!!'~', \,f):'!{/~F;:'.-'_:/'_"~"S:; ,-, '''''-:'~,0:~:"~< "-,,~--<:_"-:'~'~_"'~~' .-_,~': ,',""!:,,,,-_' '.',;,_,""FI":_7;,,'?1'f: 'd" _J" . ~~':~,~~'!i'o/' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-02260, P COMMONWEALTH OF PENNSYLVANIA: . CGllTY OF CUMBERLAND MEKULSKI JANNA LEIGH VS MEKULSKI BRIAN GREGORY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MEKULSKI BRIAN GREGORY but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LANCASTER County, Pennsylvania, to serve the within COMPLAINT - DIVORCE On May 22nd , 2001 , this office was in receipt of the attached return from LANCASTER as Kline 'ff of Cumberland County Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Lancaster Co 40.16 .00 77.16 OS/22/2001 PETER J DALEY & ASSOC Sworn and subscribed to before me this ..16 \!:: day of ~ 2hJ! A.D. Q7~f2~~ Prothonota y '",!'. ~-""'",""""",-, r.. ~, . ~ l .~ ~ ... ," ..." "1',- , . ./ SHER'IFF'S OFf=QCSE '.:.;:.~~::" ...... -"_ ":-'<i/: ... SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVAI:l.IA 17608-3480 . (717) 299-8200 ... ...... ..C'<.....,f>!"F,~$~TYPE./;.i,.... . ,... ..DQNQTOl;fACHANvcQPll;;S, 2. COURT NUMBER 1. PLA1NT1F\=/SI Janna Leigh Meku1ski 3. DEFENDANT/SI .Brian Gregory Meki1ski SERVE {\~~i~.O.n.F .IN. .M.DI~~~~ ~O:rANY, CORPORATION, ETC., TO BE SERVED. . 6. Al)Qi3~,~~d. AT ~~~JE',tH0i:$: 7. INDICATE .UNUSUAL SERVJCE: 0 DEPUTIZE 0 OTHER Now, . Mav 4 20 ~ . I, SHERIFF OF ~Im COUNTY, PA.~...~ y depotize ti' r~;:::m(""rI~i-pr County to execute thi r t r th to law. This deputation being made at the request and risk of the plaintiff. . . , ' ~ SHERfF1' 01' LANCAST COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL AS'5IST IN EXPEDITING SERVICE: 2001"':2260 4. TYPE OF WA"IT OR COMPLAINT: Divorce .. ~ ;';;':;,.',~. , '''~.,." .-,,,,,"~ ;;: H '" .() t:J ~ ,. ;;: '" 7< c: ~ '" 7< H Work.s Tuesday- Saturday CUMBE~tAND CO NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN --Any deputy sheriff levying upon or attachlnQ allY p'roperty under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of ~~ch deputy or the erlft to any plaintiff e 'n Jor any loss, destruction or removal of any such pro'perty before sheriff's sale thereat 9. SIGNATU}I or othe ORI 10. TELEPH(;)NE NUMBER 11. DATE PETER Di'lLEY (724) 938-8953 4/18/01 (This area must be completed if notice is to be mailed). PETER.J DALEY & ASSOC CUMBERLAND CO SHERIFF . ,SPACE. BELOW. FO.RiJSEOF SHERIFF ONLV.. ' '00 NOT WR!TE. SISLOWffIlSLINE....... . NAME of Authorized LCSO Deputy or Clerk 14. Date Aec,e'lved 15_ Expiration/Hearing date 1 3. I acknow.ledge receipt ot th e writ} o'complamlasindicaledabo'e. ANNETTE WALTON 717-29.5-3609 5/9/01 May 17,2001 16. I hereby C'ERTIFY and RETURN thatMhave personally sefVed, 0 have legal evidence of service as Show'n i'n "Remarks".D ha've executed as shown in "Remarks"', the writ orcomplaint descfribed on the indlviduaJ. company, corporation', etc., at the address shown above oron the individual, company, cor- poratJon:;',~tc., at the address inserted be:Jow by handing a TRUE and ATTESTED Copy !her~of; 17.01 hereb\-,certify and return a NOT FOUND because I am unable to 10cateJ~e indiVidual, company, corpo'ration. etc., naiii'ed above, (See rema'rks below) T 8. Name and litle of individual served (if not shown above) (Relationshlp-lo Defendant) 19. o No ,Seivice See RarOOrks Below {No. 30) 2 t. Date of Service ~2, Time 20. Address 6fwhere served (complete only l'f different than shown abovel (Street orRFD,ApartmentNo., City, Bora. Twp< State and:'ZIP Code) , 5-10-01 /0.;70 AM m,. EDST 23. ATTEMPTS Miles Dep. Int. a&> 24. Advance Costs R t li-lqt!2. 100.00 30. REMARKS: S.T.A.: 31. j:0 34. 35. Signature of Sheriff .1 ""stIE~!.,5f ~..:~~F,~S~., 'f -33,Oale S-/C1-cJ/ 36 0"'::5'. fCJ, g~p~~:rW{e' of Prothonotary! MY COMMISSION EXPIRES 37 1. WHITE. Issuing Authority 2. PINK - Attorney 3. CANARY ~ Sheriff's 'Office 4. BLUE. SherIff's Office - ,..~:-~ ~;'\,j~~ L i:;:','V'T'- ''l'" "Wi I . j liJiillll n~ . "- '" .:;, CO. ~~1_~, (~)-} .,. .m -- '... " - "," .'<;:C'~;;; ~: ,. -, " ,3:, :U\ (r.-'!i ,,,J~~." . \,... "<C'<,i' '*~F' ,-<'-';1>'" J2_ ",'<t"-'.', """'['-i'F.',:.,, "'~~.l'iD';:<ilJli'!0lt!'~'!1 . . . 3n tb4t ~ourt of ~ommon ~l4ta6 of ~umb4trlan6 ~ount\?t ~4tnn6\?l"ania JANNA LEIGH MEKULSKI, CIVIL ACTION IA W ACTION IN DIVORCE Plain tiff, No. 01-2260 VS. MARRIAGE SETTLEMENT AGREEMENT BRIAN GREGORY MEKULISKI, Filed on behalf of: Plaintiff,janna Leigh Mekulski. Counsel of record for this party: Defendant. Peter J. Daley & Associates, P.C. Peter J. Daley II, Esquire 218 Wood Street California, Pennsylvania 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Atty. I.D, #62925 ..-~ r'_ n '_~_'~'._ '-~JFq' _,_ _ "<." ,_ ,_,,~'I~' ' "1 _. ~ , - ~~'" , ". < < 'A~' . Plain tiff, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, vs. CIVIL ACTION - LAW ACTION IN DIVORCE BRIAN GREGORY MEKULSKI, Defendant. No, 247 of2000-C marriage $rttlement 2{greement ~.~ ~ THIS AGREEMENT made this -30 day of ~ I '-'-- , 2001, at Cumberland County, Pennsylvania, betweenJann Lei:bMekUISki, hereinafter referred to as "WIFE" a n d Brian Gregory Mekulski, hereinafter referred to as "HUSBAND" WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on August 8, 1998; and WHEREAS, unhappy differences have arisen between the parties, and as a result they have lived separate and apart since February 27, 2001; and < . ;"."",,,-, ~-~"-' . - -,. ", ^ , -:'. t._,"' ~ o. - - ~."- , "'" ~" > . WHEREAS, a proceeding for'the divorce of the parties has been filed by the Wife in the Court of Common Pleas of Cumberland County, Pennsylvania at the above number and term and served on the Defendant, Brian Gregory Mekulski, on May 10, 2001; and WHEREAS, it is the desire and intention of the parties 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, includingwithoutlimitation: (1) the settling of all matters between them relating to the ownership of real and personal property; (2) 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 mutual covenants herein contained, and intending to be legally bound hereby, the parties agree as follows: 1. AGREEMENT PREDICATED UPON DIVORCE. ltis specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that, as defined in the Divorce Code, their marriage is irretrievably broken. The parties agree to take all legal steps (including the timely and prompt submission of all documents and the taking of all actions) necessary to assure a divorce pursuant to Section 330 1 (c) of the Divorce Code is entered as soon as possible. To that end, the parties agree to execute and promptly file affidavits of consent required to obtain a divorce pursuant to Section 3301 (cl ofthe Page20fll '. .,' .". ,-.,y,;;;-':"':r';~' , '-'-." l--;" ~. Divorce Code within ten (10) days of the execution of this Marriage Settlement Agreement. The parties agree to waive any notice required under the Pa. Rules of Civil Procedure, or under local rules. Husband shall be responsible for the prompt filing ofthe Praecipe to Transmit the Record. :j 2, ADVICE OF COUNSEL, Wife has been represented by Peter J. Daley II, Esquire, of Peter J. Daley & Associates, P.c. Husband has chosen not to retain legal counsel and Husband has chosen instead to negotiate directly with Wife and Wife's counsel, notwithstanding the fact that counsel for Wife has advised him that he has an absolute right to be represented by counseL Husband hereby acknowledges that he has done so willingly and that he fully understands the relevant law (including having reviewed the Divorce Code). Both parties acknowledge that they are familiar with and fully understand the relevant law and relevant facts, including the asset, liabilities, income [and expenses] of the other party, and that each is fully aware of his or her rights and obligations, Each party represents that he or she understands that, in the absence of this Agreement and as a matter of law: (1) as a surviving spouse, he or she might be entitled to a greater share in the decedent's estate than is provided for in this Agreement; and (2) as a separated and/ or divorced spouse, he or she might be entitled to greater support, maintenance, alimony pendente lite, counsel fees, costs, alimony, distribution of property, or other financial benefit arising from the marital relationship than is provided for in this Agreement. Page 3 of II :.," ,-~,_, n_ . '-''C,,-'''::;!,'-f':'-', ~, - " - i':_-I"- !, " ,~ , ~ w ,~ , - I -. > Notwithstanding the foregoing, the parties shall be bound by the terms of this Agreement. Each of the parties further acknowledges and agrees that, with such knowledge, and after having read this Agreement carefully and fully, this Agreement is fair, reasonable and equitable, that it is being entered into freely, voluntarily, and in good faith, and that its execution is not the result of any duress, undue influence, coercion, collusion and/ or improper or illegal agreement. 3. COUNSEL FEES. Each party shall be responsible for payment of their own counsel fees in connection with this divorce proceeding. 4. PERSONAL RIGHTS. Husband and Wife may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Husband or Wife of the unlawfulness of the causes which led to, or resulted in, the continuation of their living apart. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party shall interfere with the other's employment or other business activities, or with the use, ownership, or disposition of any property now owned or hereafter acquired by the other. Page 4 of II " ',1_', I: I 5. GENERAL RELEASE OF ALL CLAIMS. Each party hereto releases the other from all claims, liabilities, debts, obligations, actions, and causes of action of every kind that have been incurred relating to or arising from the marriage between the parties. However, neither party is relieved or discharged from any obligation under this Agreement or any other instrument or document executed pursuant to this Agreement. 6. WAIVER OF ESTATE CLAIM. Except as otherwise herein provided, each party hereby waives, releases, and relinquishes any and all rights that he or she may now have or may hereafter acquire as the other party's spouse under the present or future laws of any jurisdiction: (a) to elect to take against any will or codicil of the other party now or hereafter in force; (b) to share in the other party's estate in case of intestacy; (c) to act as executor or administrator of the other party's estate. 7. NO DEBTS AND INDEMNIFICATION. Each party represents and warrants to the other that he or she has not incurred and will not incur any debts, obligations or other liability, other than those already described in this Agreement, on which the party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereafter initiated seeking to hold the other party liable of any debt, obligation, liability, act or omission of such party, such party will, at his or her sole expense, defend the other against any claim or demand, whether or not well founded and that he or she will indemnify or hold harmless the other party in respect to all damages resulting therefrom, PageS of 11 ", _"'", -" , -,,'-' - '''',f'.,, "'"'' - ,"-- , --''I:; '--~","~ I I , ' ~~ Each party agrees to indemnify or hold the other party harmless from and against all obligations of any kind incurred by them by previous conduct, and for all future actions or obligations, pursuant to the terms of the within Marital Settlement Agreement. 8. LIABILITIES. The parties hereto 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, liabilities incurred by the other prior to or after the effective date of this agreement, except as otherwise specifically provided for by the terms of this Agreement. 9. FULL DISCLOSURE. Each party asserts that he or she has made a full and complete disclosure of all of the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each part, and of every other fact relating in anyway to the subject matter of this Agreement. These disclosures are part of the consideration made by each party for entering into this Agreement. 10. PARTIAL INVALIDITY. IfanyprovisionofthisAgreementis held to be void or unenforceable, all of the other provisions hereof shall nevertheless continue in full force and effect. Page 6 of II ~: _" >- --~,'"",- - . 7/' " ~- ~,' - 1':' . -,. ~I ,'-;-0> , -r, 11. EXECUTION OF OTHER DOCUMENTS. Each party shall on demand execute any other documents that may be necessary or advisable to carry out the provisions of this Agreement. 12. ENTIRE AGREEMENT. This instrument contains the entire agreement of the parties and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. 13. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed by both parties with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, and either party, or their estates or heirs, shall have the right, by suit or otherwise, in law or in equity, to enforce this Agreement. 14. EFFECTIVE DATE OF AGREEMENT. This Agreement will become effective and binding upon both parties as of the date of execution of this Agreement. 15. EFFECT OF DIVORCE DECREE. The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered. Husband and Wife agree that the terms ofthis Agreement shall be incorporated into any divorce decree Page 7 of II ,I~._ C' ,,' _-.~ ,. _, "". ,', ,_,_~, ,-. _ - - ~ ,- --~-',. ,r,: -, -',-" , -, I . - -. which may be entered with respect to the parties. The parties further agree that the Court of Common Pleas which may enter such divorce decree shall retain continuing jurisdiction over the parties and the subject matter of the Agreement for the purpose of any enforcement of any of the provisions thereof. 16. BREACH OF AGREEMENT; COST OF SUIT TO ENFORCE. If either party shall default in the performance of any of the provisions of the Agreement, and if the other party shall institute a legal proceeding to enforce the performance of such provisions by the defaulting party, then the defaulting party shall pay to the other party the costs and expenses incurred by the other party, including reasonable attorney's fees, in connection with such proceeding. The provisions of this Article shall be in addition to and without prejudice to any other rights and remedies to which the aggrieved party may be entitled. 17. GOVERNING LAW. 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. 18. HEADINGS. Any headings preceding the text of the paragraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement, nor shall they effect its meaning, construction, or effect. 19. EQUITABLE DISTRIBUTION OF ASSETS. Page 8 of II \?~"- ~,- .' - ",-., ,""C", ~" ,- :: ~,",I - ',' --"-~,., ~,'-' -~, ' -~--~ -~ ~ . . . . a. Personal Property Except as herein provided, all personal property now in the possession or control of the Husband shall be the sole and exclusive property of the Husband, and all personal property now in the possession or control of the Wife shall be the sole and exclusive property of the Wife. b. Motor Vehicles The partieshereto agree that Wife shall retain the 2000 Ford Explorer, and Husband shall waive any and all interest he may have to said vehicle. Husband shall retain the 200 1 Jeep Wrangler, and Wife shall waive any and all interest she may have to said vehicle. 20. PENSIONS. The parties hereto forever waive any and all interest and rights he or she may have in the other party's pension or pensions or employment benefits through their respective employment during the course of the marriage. The parties acknowledge that they have each fully disclosed their respective pension information and employment benefits through their respective employment. 21. TAXATION. The parties acknowledge that they have been separately advised by their respective attorneys that there may be certain tax consequences pertaining to this Agreement, that neither attorney has furnished tax advice with respect to this agreement, that each party has been directed and advised to obtain independent tax advice from qualified tax accountants or tax counsel prior to signing the agreement and that they have had the opportunity to do so. Page90fll !":",. '- _ _ _'0_,'","_,_ ,__r,_,,_ ^ " '. t -",- -'<' .,' ~ ,",' .." " -'-'^ ". , ~, . ~> .. 22. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, COUNSEL FEES AND COSTS AND ANY AND ALL RIGHTS PROVIDED BY THE DIVORCE CODE OF PENNSYLVANIA OR ANY OTHER RIGHTS BASED ON ANY OTHER LAW OR SOURCE. The parties hereto hereby agree to waive the right to seek Alimony, Alimony Pendente Lite, Spousal Support, Counsel fees and costs and further waive any and all rights or privileges provided by the Divorce Code of Pennsylvania or any other rights based on any other law or source forever. IN WITNESS WHEREOF, the parties, intending to be legally bound hereby, have hereunto set their hands and seals on this Agreement the day and year first above written. SIGNED: \ WIFE ~~? ~~~ ~J!.li. BRIANGR G RYMEKULSKI , HUSBAND Page 10 of II :-"~-~r . -,- - ,-,~,_1'C .-t" ".",. 1-"-" . . -~ , , ~ I~~ . v , _~ ' ," , r" IIW -~~~'~-__j,-, _'0 ""_'.'co"_'" "',) ~ .". ,< '" ."......'lliIJiTmTi 22;L;":, ?~c_' ./ /. ~' ," ::-! s.:-: -eJ" 17mlTffillll<fiiiliiT1 .. ~,,__~''ll<l)~~~~,,_,1,",'''!~'~:1!'^''_"'_~~_ ~1l:mr "fy,H?"it."" , I:.::' J~;m::,-i 'T~nr r ,,"~ ~" , ~o "0" __ ~'. - -. COMMONWEALTH OF PENNSYLVANIA COUNTY OF IJJIlSI-//;(){'...-jOA! AND NOW, this~y of rJ.utAtJ:i, 200 I, before me, the undersigned officer, personally appearedJ anna Leigh Mekulski, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement and acknowledged the same to be her act and deed and desired the same to be recorded as such. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: COMMONWEALTH OF PENNSYLVANIA COUNTY OF //1 1../[7 fl_<;7 t:R Notarial Seal ,Julie Webster, Notary Public CalifornIa Boro, Washington County My Commission Expires Nov, 1, 2003 Member, Pennsylvania Association at Notaries AND NOW, this.3.2. day of~, 2001, before me, the undersigned officer, personally appeared Brian Gregory MekuIjiki, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement and acknowledged the same to be his act and deed and desired the same to be recorded as such. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY PUBLIC My Commission Expires: , ---~ NolaIial Seal B8ItJeIa!wl AltIlA; NolaIy P= - 'r "'b.I\ Bolo, I..arlcllIIter L,!!.~~~Jlm.ll' _ Pagellofll ,~ ,) ....,.'1 C\', , "",,",-, ,- '-,,1 !'''k'''' '..r'7'.__-_~,',,~"__,. -'. .' ,:--',~" -', '--:l_' -,'" ~- 1\. c,~ ' lli $ ".,,,,, .,~._~ 'r-'--~~1 ,~ .-'-~--' '"' __"-'j"~ H,' - l. ; . .~ ~"..,.-ti -W,~.," . .1 _ ~"T~;;f"",,;-Np,- f, ~,~11l1<j!l~t-<>l"''''''''" "l;/('fnl ....'.n''i1nl''j1ill'l.~fll1 TI'I'!!UmllT'r"Cf'" C) (~ ~..- -_-::~ <:.,; -~, n-~ i: -/ ';;':c. ci! __ f~~\. L> -__ -:.. t:-': A~-(-'-) ~. ~t.:> ,-0::" -- ""', --") -, ~!it"'''"''''_'_~'' ,'^'" "!'':''i~~_ ~~ . . ,__) ~,'I ~:r1il!~_,<'![! ". n},~",,~( ~ In the Court of Common Pleas of Cumberland County, Pennsylvania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Plain tiff, NO. 01-2260 AFFIDAVIT OF CONSENT VS. Filed on behalf of: Janna Leigh Mekulski, Plaintiff. BRIAN GREGORY MEKULSKI, Counsel of record for this party: Defendant. Peter J. Daley & Associates, P.C. 218 Wood Street California, Pennsylvania 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Peter J. Daley II, Esquire Atty. I.D. # 70244 ;:,1,-,0,.; :.: ,y-",-'--:''''<"':~~',,':''-> '--'~''''" ." '''I",~j~-:,,:; ""-'. ,-',- ,~' '"""J" . " Plain tiff, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, VS. BRIAN GREGORY MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Defendant. No. 01-2260 Affidavit of Consent 1) A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 18, 2001. 2) The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. , , Date: q.... 1/ .... () I +"~'~:--" . ~ /-'~ i'1-','~"_' "', .e-f~ ~:;_I ,- f _" - _~ , , :1 f;; .~ ' <'c' ~,<,"',,",," , ,~,_ " ',' ""R~",'" , . "we,."""" N_~ y;-<>"~-",, ,..,- ~"-'!''"r'..~J, _.'.: ,~.""'_';'",Jf');;;'..r, ',_-'~:'''''Cj~ ~ ,.I () ~- ,- <' '"1')(;3 n'in'; L,:'" ~~~~ ",<,,c, r-~I ~l....._. d?:C) -"-0 )>C~ 2: -i -< - '1 '< '--'\ i".._, U) r" -0 \..0 :J, '-' :N" _'_~':-''''' "..,-..", ;t " :JF,:~tW;1jWffi."~"_...""",'!.";'IlJ!"If'_ ~-"'-""!1"" . " "'~"'f"- .~~"-:c...,,,_,~.~Ji I y In the Court of Common Pleas of Cumberland County, Pennsylvania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Plain tiff, NO. 01-2260 WAIVER OFNOTICE VS. Filed on behalf of: Janna Leigh Mekulski, Plaintiff. BRIAN GREGORY MEKULSKI, Counsel of record for this party: Defendant. Peter J. Daley & Associates, P.c. 218 Wood Street California, Pennsylvania 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Peter J. Daley II, Esquire Atty. I.D. # 70244 :'!c.;:;p~ ,."_"_V;i~_-_~ ,- ___,_,_~,__:",!" ". " -, - -~ ,~'~ I ' --,,-, !,' .^ . , Plaintiff. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COlJNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, vs. BRIAN GREGORY MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Defendant. No. 01-2260 Waiver of Notice of Intent to Request Entry of Divorce Decree Under Section 330I( 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 with 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: q~ 11-6 , . >;.'! -.,Cr...J , ~') .. . " -,"'''~'''~'' ,:< ' ';' --~ ,,' " -" - ->~I ' ..- ",' ~- " -'1'~,,_ ,- ," ~ I I t ~ "".<"" !\lilii" ,,,_'.d,,, ..,~",.~.. CO"'" , . ~ _._~.~ ~ '1""iiIll . . (') C.: r:..') C ,c ""7'" ~j') :-~ 01J0,: ~ , r-rtr,' ," ~t--; 1e,D CD i''", --('./', ~C: j'~~ .,-,_. 2;~, :;?:, :)'\ ::2. ~,-! -'- '. ~,." __,~"1__ ',',_>,::,'_','':1' -,,;,! ' " ~~~~~~" ,"".,.=",~..' I ~""~-,- ,.JIll.llk~,,_,:", , ~ _'_~_,_.' ,,!Iq', _,_~..,..... _';"_f,_"~,:,"'o,,L- In the Court of Common Pleas of Cumberland County, Pennsylvania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Plaintiff, NO. 01-2260 AFFIDAVIT OF CONSENT VS. Filed on behalf of: Brian Gregory Mekulski, Defendant. BRIAN GREGORY MEKULSKl, Counsel of record for this party: Defendant. i It,_ ,,'" "_',' "~~""''''''''_''';;'> ",",,-,~,. ,< _'~ - :,,':1 i, I . - Plain tiff, IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, vs. BRIAN GREGORY MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Defendant. No. 01-2260 Affidavit of Consent 1) A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 18, 2001. 2) The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Date: I 0 Ion / f7 { I ( ~ >>:,/2 BRIAN ~RY MEKULSKI !t:.",",^ ~,">", ",/,,"~ _nY':<:'-'"','_""", _,C,-,,, -_'-'~' I", -_-_,~_''',- .,_.< " _~"." ""'- de,. ',-' . Wi' ~ T'!'._ ~ ~ ~,. ,.~ .'~''''''" (') c: ~;:,: "0 OJ nln1 Z:"'T; 65S~; -<~C Ce.:'; )> LC) :1'>8 Z :;;! ,., . ml (:) ,~ '--/ -1'1 ;;z: ?2 " ;?~ >:~~) :ii~~ :;;:j :0 -< U1 -0 _.::'~ N Vl (J1 II "..._...,~.,..,',.... ,. rr,lKl,,_, ,~~',"''fJ.''i'!''''r",' . '0"; ,,,Jlil,,t;;,,,..,,,, ~- ":\ '~"~~'-- $l.~,~~~,,: -- ~,. :r:~~ ".<." ,'" -<, ~ In the Court of Common Pleas of Cumberland County, Pennsylvania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Plaintiff, NO. 01-2260 VS. WAIVER OFNOTICE BRIAN GREGORY MEKULSKI, Filed on behalf of: Brian Gregory Mekulski, Defendant. Counsel of record for this party: Defendant. i";" , ~:- ,'""i/_, ,,.~-" "1' 1-' ~~,~ , . Plain tiff, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, VS. BRIAN GREGORY MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Defendant. No. 01-2260 Waiver of Notice of Intent to Request Entry of Divorce Decree Under Section 330I( 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 in 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 with be sent to me immediately after it is filed with the Prothonotary. Date: 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. S 4904 relating to unsworn falsification to authorities. ~~ BRIAN GORY MEKULSKI lol-:J~/()I I (' '"':.;). :i.:~ -;''ii~_ < ..,,_ " ,',' (-:-'::, '" - ;,n ,.. '.. . '--- ',-~ _: _ _I ,>,,, - ~ - ~ " . p i I ,", "' - ....~ ~,' L ,WI .. .. ~<, "' _.Iry '')f.__~",,~,~~~%i~l7' ~ "Y,",,'__!,__,' - __ , I; ~.. . 0 c:> 0.-' ,~ C -,-, s: z ---' -ocr c::> .....i~ rnG'l ",;.::: Z:::rj -,-,;-[1 ZI:;:-_ <.r ,,",[J ClJZ .~~g. (;:0 ',' ~O :::r: 8~;~ ~.c t::1 PC -,'"' 2': {..'1 b =< :0 (Jl -< ~ -'~~,' "_~~ _1~,.n "1 -ir'- <~1 ~~" 2fn th~ ~ourt of ~ommon ~l~aG of ~umb~rlan6 ~ount\?, ~~nn6\?l"ania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Plaintiff, No. 01-2260 VS. AFFIDAVIT OF NON- MILITARY SERVICE Filed on behalf of: Plaintiff, Janna Leigh Mekulski. BRIAN GREGORY MEKULSKI, Counsel of record for this party: Defendant. Peter J. Daley and Associates, P.C. Peter J. Daley II, Esquire 218 Wood Street California, pA 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Atty. I.D. # 70244 , Ii!"",.,. V', ."0 ,-~-, ,. Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, vs. ACTION IN DIVORCE BRIAN GREGORY MEKULSKl, No. 01-2260 Defendant. :flffioJ"it COMMONWEALTH OF PENNSYLVANIA COUNTY OF WASHINGTON Personally appeared before me the undersigned, a Notary Public in and for said County and State, Peter J. Daley II, Attomey for the Plaintiff and duly authorized to execute this affidavit, and states that the affiant knows of his own knowledge the Defendant herein to wit: Brian Gregory Mekulski, is not in the military service as defmed in the Solders' & Sailors' Relief Act of 1940 and Amendments there to for the following reason: Defendant currently resides at 707 Apple Drive, Mechanicsburg, Peunsylvania. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety, guarantor, endorse, ther person liable, primarily or secondarily, for a part in the military service. i , '01"''''''-- ......'\ ,,'a 1,1 'II "....... i)' ..~... , .,,"1., .. .' ..:'1.\1, ,," ;.. , .. ,.. .. '"oj'..... " .. ...~' 'If'" "i',,(':, ~ . -', .' -j'.", - .'~ ""PI,,,,' - ... '"', 'j :'. _- , ". J.' -'--'\,:,..; \;, ; "". ~ . 3:~!,..:JO ~....; .~'''- _l', ' ,;V-",-_ , \ ~\....,~~~~_~,', ~'.~-~-~1 . """'\""""U' ","'''Ift>,;',I,.' ~ "-. (i;", .>' ,\", " ", "'\ ' -'"." _ i.~. .,J Ii 1.J \ '- ", ' '0'0' - I~_""",u,..,.,..." "~i~:/r. ~~! ~; :;1J.iLot;-~ . NOTARY PUBLIC Notarial Saai , Julie Webster, Notary Public CalKomia B~ro. Washington County My CommiSSion Expires Nov, 1. 2003 Member, PennsylvamaASSOclatlon at Notaries My commission expires: G:\CUENTS\Mekulskl, JannaLeigh\Nor.-Mj!(tary Affidavlt.wpcl -'f~ c..'....' . 't fl'__" ~ - '.< ., ',,',"",' --'.'---, , ,___~~_~,.~_~,,_'""".'T. _ ", .''''''-_',,,,,,,~_~ L ~ \ r~ _, - .-.- ~".~ ',_ 'o,~"'~.' ,~.,:U I ,~ "'~'I ,",' ~ ," " .>"" .. n",",'''''~''_'''''' ,"'" "'--,'''-~Ti!ln 'li'f o C ;:::;; 5Jlt.t {-;' ,~ ~/ ' ;_--:i:...:., '-': 'f: l= ,.."c :::1 -< ~,~=~, ."",_c' l!IMl!~I~'9'M'~,~l~~~~, ':::J "'1 -~-') ~-' j t..:;. f C~': ,~ "-'<"'1'-~,'__!'""",~p, . . . 3n th~ Q.:ourt of Q.:ommon ~1~a6 of Q.:umb~rlan6 Q.:ount~1 ~~nn6~1"ania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Plaintiff, No. 01-2260 VS. PRAECIPE TO TRANSMIT RECORD Filed on behalf of: Plaintiff, Janna Leigh Mekulski. BRIAN GREGORY MEKULSKI, Counsel of record for this party: Defendant. Peter J. Daley and Associates, P.C, Peter J. Daley II, Esquire 218 Wood Street California, PA 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Atty. LD. # 70244 \",:,.,-"",,--, -~"" "..,,,,".-,.. _,.>:?,'~__ ._, _.,"__,~~--C= ~_~I _ .". ,., ~ ,~~~~~ .,._ . . Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKl, vs. ACTION IN DIVORCE BRIAN GREGORY MEKULSKl, No. 01-2260 Deiendant. ~ra4tdp4t to 1[ran~mit 1~4tco..6 To the Prothonotary: Sir or Madam: Kindly transmit the record, together with the following information, to the coun for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under DRC ~ 3301(c). 2. Date and manner of service of the complaint: May 22, 2001, personal service by the Sheriff of Cumberland Counry. 3. Date of the execution of the affidavit of consent required by DRC ~ 3301 (c): by plaintiff, September 9,2001, by defendant, October 23, 2001. 4. Related claims pending: None. 5. Date ofPlaintifPs Waiver of Notice in ~3301 (c) divorced was flied (a): by plaintiff, September 19, 0, by defendant, November 15,2001. tiff L"c - '0; ,',5"-"<:''''__'_,_,'''~'i',~,i';'-~__~'' -"0__"'" '-~c?",,'_:I-" ~'". ,~,' , ., 0, ~ , < ~ ~~,~,,'.- ^" ._.- '" <<. ~~. "'-"_~_"_'~_w,,,^,,,o_hW' _,",~",_"_._^_ 'V~> -. n ~: -DC: [""I ! f~ 7-r 2;:- -,,',.. -"".. ~" 0_(-, ..,~,,-.- _l~> ,C~. ....;:::- =<! mIDI \ ::::1 1 ~ -) ~~_. -,-' , (P -, ,,~ lll, ).,,", "_. ,M, ",-,~"" ""j'r",~!I~'~1)'!...,,~"~C',m~~IW1'-'~l611!)~lilW.IlJ1~"'-'_'1""r_"."f".."AAnjl]fl:m~r!l, '-'~ ~~"'~'IJ' , I lJn tb~ ~ourt of ~ommon ~1~aG of maGbington ~ount\?t ~~nnG\?I"ania JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE No. 01-2260 Plaintiff, AFFIDAVIT OF SERVICE VS. Filed on behalf of: Plaintiff, Janna Leigh Mekulski. BRIAN GREGORY MEKULSKI, Counsel of record for this party: Defendant. Peter J. Daley & Associates, P.e. Peter J. Daley II, Esquire 218 Wood Street California, PA 15419 Phone: (724) 938-8953 Facsimile: (724) 938-8959 Atty. I.D. #70244 ,<..,,, ,',',~- -".'.' n~/_", '_;_.'-.,_ ,'" ,---' ". , , ~.,'" ,'_~__I_" '_'~__" _.,..,. ",' ""-T ' '_' , " , " '.<-- ) Plaintiff, IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY, PENNSYLVANIA JANNA LEIGH MEKULSKI, vs. BRIAN GREGORY MEKULSKI, CIVIL ACTION - LAW ACTION IN DIVORCE Defendant. No. 01-2260 ~ffi6a"it of t;~ke COMMONWEALTH OF PENNSYLVANIA COUNTY OF WASHINGTON Before me, the undersigned authority, personally appeared, Peter J. Daley ll, Attorney At Law, who says that he has this 10th day of May, 2001, caused a true and correct copy of the foregoing Complaint in Divorce to be served upon the Defendant, Brian Gregory Mekulski, at his place of employment at Wyett Ayers Laboratories, 206 North Biddle Street, Marietta, Pennsylvania, by Deputized;8l\:rvi e through Lancaster County, Pennsylvania, evidenced by the Sheriff's Return of Se . c ttached hereto. Sworn to and subscribed before me this l!f:!!!. day of December 2001. My Commissiou Expires: Notarial Seal Julie Webster, Notary Public California BolO, Washington County My CommissiOn Expires 'Nov, 1, 2003 Member. PennSylValliaJ\sSOCiauonol NotarieS "i,t__i~"< '.~'( ,.' "1\, d "". ~~...'h',.~ ~/},..."J'~~. }./~,I\'ASJ", Yc' . ; ,,\:'if~i~~\;?'~j ~ 1 ",1--1... ')--':'~-'!.':,-N';" '()": ;: :.. \J.... '.. ...;- ~;"":,,,<i'~ o. ('" .:;- '~,. ,/ ....~l"i'i",i.\ ...... ,..."....._ . .....,. .s"... ........ -"\'~.. ". f; 3n.1' .... "'" ii. " ~\,,, 'JfiHUIl\l'" ~;" , ~t,'; ~b~ N Public ~" ,- ~"'. -',' ".,,- ~~ -,.~- -~ --, . . ,.'., .'. ,.,..'.,. .."-.,. SHER'I-FF'S DFFl8E .... :....'00-,~,..:.::... ~-- -'-.-~" "" 50 NORTH DUKE STREET, P,O, BOX 83480. LANCASTER, PENNSYLVANIA 17608-3480 . (717) 299-8200 . SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAINTIFF/SI .. ,. "..., ." .. .. .' ,.,.,..., ,....PL,E~$FTIj:l1; ..... ...... .......... ... '. 'po NOT PEt-AcH -ANYCOP!E$, 2 COURT NUMBER Janna Leigh Mekulski 3. DEFENDANT/SI Brian Gregory Mekilski SERVE {5;;i~O~ IN~l~~~~~~M~AN.Y' CORPORATION, ETG., TO BE SERVED. . ~~. AD AFO, Apart - ,- ,,', _",.0 AT 7. INDICATE UNUSUAL SERVICE: 0 DEPUTIZE 0 OTHER Now. 'Mav 4 20 ~ . I, SHERIFF OF ~Ilm COUNTY, PA,~d ey deputize th r:~nr.:=:lc;::+-pr County to execute thi , t r"th to law. This deputation being made at the request and risk of the plaintiff, ' . SHE:RIFF OF LANCAST COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITJNG SERVICE: 2001-2260 4. TYPE OF WAlT OR COMPLAINT; Divorce ,",'0',,,,,,,, .'.,", ~..lo;- ;3: H [J) () t:l ~ ;;: '" " @ [J) " H Works Tuesday- Saturday CUMBERLAND CO NOTE ONLY ,APPUCABlE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custOdy of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of ~~ch deputy or the edff to any plalntiff e '0 for any loss, destruction or removal of any such property before sherlff's sale thereof. 9. SIGNATUR or olhe ORI 10. TELEPHONE NUMBER 11. DATE PETER DALEY (724) 938-89.53 4/18/01 (This area must be completed if notice is to be mailed). PETER,J DALEY & ASSOC CUMBERLAND CO SHERIFF Sl'ACE. !3E.LOW FORVSI;.OfOs}iEFlII:'FoNI.Y'. "DO'NOT 'NRITESEI.OW. nllS LINE. ' 13 I k I 'd ' t f th 't} NAME of Authorized LeSO. Deputy or Clerk 14, Date Received 15. Expiration/Hearing date . ac nowe gerecelp 0 eWn . ,. o,complaintas;nd;catedabove, ANNETTE WALTON 717-295-3609 5/9/01. ,May 17,2001 16.1 herebyCERTIFV and RETURN thatMhave personally served, 0 have legal evidence of setviceas shown in "Remarks",O have executed as shown in uRemark.$". the writ or complaintdesGibed on the IndiVIdual, company. cOfpo~atJOr1, etc., atthe address shown above oron the individual, company, cor- poralion,~etc.. at the address inserted below by handing a TRUE and ATTESTED COPV:.thereof, 17.01 here6'y certify and return a NOT FOUND because 1 am unable to locate the individual, company, corporation, etc., named above. (See I"emari<s below) 18. Name an'd title of individual served (if not shown above) (Re1ationship'to Defendant), 19_ ONOSerVJce See Remarks Below (No. 30) 21, Dale of ServIce 22 Time 20_ Addressof where served (complete only if different than shown abo.ve) {Streetor RFD.ApartmentNo..Cfty, Boro, Twp. State and-Zip Code) , 5-10-01 /o~<:; AM ,... """ EOST 23. A TTEMP1:'S S.T.A.: 31, 5~p~~:rWle 01 35 Signature of ShEinlf i 33, Date S /17- 0/ 36 O";s-. I'd. 34, 37. Prothonotaryl MY COMMiSSION EXPIRES 1, WHITE - Issuing Authority 2. PINK ~ Attorney 3. CANARY. Sheriffs Office 4. BLUE ~ Sheriff's Office L " 'I ~ ~ _r." ~~_~~" ~ , (') c r-: '1:; (' ~ rr , L 1-'1 --7 ':""") U1 .~....: -~ r' C ,- 'v > , ,. .:2: C, ~> :"J , 'I C:.: - "/..::: - , ::< _on C-i _!..J -- I'IDlillm1jlllll!llI!H'l!lM,~'\"';IWll\Y\tli!1!1/!I!I._~~':~</!Kil)'<t'lHel!f5C~"",-,.''';-''''''''''''"-'''-';''.,-,,*i,",::l1~'''~~~-;;<1.g/ff.f,~1tlJlli'IIf'''';;;'ffi'"11~~