Loading...
HomeMy WebLinkAbout99-02259 ;., ?r;:..' 2;;-' ';'Ff':;' -"", ~c, ,-"'::'~'","'';~ ., ,~;~(::,~..., Xi'S'?' "I:~ ":. ': ;':~'~" , " \?r'- :r;:",;; -'~'.'~.~ ',. ::'.' l"'; )::E tL~ I:"~" i".-,_'., r",;.....". . .. . ., cl :i', .. .',~ ':N .";'. ,~ . iOo :'~ :c; "'~ "-'." f'.'-' ~~. i'J .'. ~ '.' ~; ~ ? ,', ~ ,', * ~...; ,', ~ i ? ,', ~ ,', i'J ?, 6 , ~ i'J ;;: ~ Q 5'~ 8 ~ ~ ~ !.~ ~.; ~ '= f.'~ ~ ~.~ i ~.~ ~ t~ ,', jli ;,: ~ ~. ~ , . . .:~ ,:.}' .:.:-- ':C-"->>>' .:.:. .:cr<c.'<C-' 'M' ... ',:+:. .:c." .:+:. .:<<. .:+:. .:+:- .:+:. .:+:. ':.:":<~':c<>:+x>>>>:>:.xx+x;.:.:o:;.:+,...<.,.c<c<~ ,:., -.....-..- ~ ~ ~ ?' ~ I IN THE COURT OF COMMON PLEAS ~ ~ OF CUMBERLAND COUNTY ~ M . a " ~ ~ ;.; ~ '? ~ ~ 'w~ STATE OF ":1,'.' .:t PENNA. ~ '," ~.~ ~ ~,'.' ~ . ~~ II I II ~'. :, ....J.OYCE...L...LQMaARPO. . No. ,..,9.9.::-.ns,9..... ................, 19 ~ ..........................-.... .... ..l'laintiH...... V CI'SlIS ~ ~ ;.; ~ $ ~; ~ ~ ,', DECREE IN ~ D I VO R C E J:q~}(A-A! . . . . , . , , ~ . " 19~." it is ordered and ~ '? ~ >~ ~ ~.~ ~ '.' :; W ~; ~ ~'; a :.~ v ~ ~ ~.~ ~ '.~ ~ .....BARRy..!'... ,LQMllARPO. " ,I II .......... II II Pefendant AND NOW, . decreed that,.. ... , ".,. , !.oY.c)!:. ~... .L'O~.B.A.RP'O. ... ...,.,. ...... .., plaintiff, and....................... .Il-\~~,( ,11, .I,Q!:lI)-\!l.QQ..............." defendant, are divorced from the bonds of matrimony, The court retains jurisdiction of the foUowing claims which have been raised of record in this action for which a final order has not yet been entered; .,......., ,.,. ,~~~~~:?P~:~~.~~~~~~~~~~,~~:~~~~~~,~~~~~.~~~y.?~,.~??? ~~..., .,..,... ..., .,.iQ~orporated,berein.by.referen~e"but,i8,not.merged,into. the decree in divorce. ~ ~ ......p'. s J. ~ ~ ij ~ - ----~~_.~~..- .~ .....--'~-------.----,~........ .~.._.._~ - ~-~._-. ~ ~~~'~~-~---~-*_*_ro__~*~~_ 2 Husband agrees to make a cash payment to wife of $33,000.00. Within five days of signing of this Agreement, Husband will place on an interest bearing escrow account in the law linn of Broujos & Gilroy, P.C. that said $33,000.00, with interest to accrue in favor of Wife. Upon the issuance of a divorce decree between the parties. the linn ofBroujos & Gilroy, P.C. is authorized to transfer said $33,000.00, plus all accrued interest, to Wife by deliverance of said funds to Attorney Ronald E. Johnson. 3 The burial/ots located at Westminster Cemetery will be transferred to Husband. Wife agrees to execute any and all docwnentation required to effectuate this transfer. ' 4 With the delivery of the cash and cemetery lots as set forth in Paragraphs 2 and 3 above, the parties acknowledge that they have equitably divided all marital property, including both personal and real property. In connection with this division, the parties represent as follows: A. Each party waives any and all claims and rights of ownership or rights as a beneficiary to the Pension Plan or Retirement Plan of the other party. B. The parties hereby waive any claim of rights or ownership in any real estate titled in the other party's name. Specifically, Wife waives any ownership in the Sullivan County property currently titled in Husband's name. C. Both parties shall retain ownership of the vehicles they have in their possession. Husband will sign all documents necessary in order to transfer the jointly held motor vehicle to wife. Also, the parties will assume whatever loan may be on their respective vehicles and hold the other party harmless with regard to those loans, D. All items of miscellaneous of personal property of the parties have been divided, and each party waives any claims relative to items of personal property in the other parties' possession including personal belongings, bank accounts etc. 5 Wife shall deliver to Husband with the signing of this Agreement copies of all e-mail correspondence between Husband and a third party which Wife has in her possession. Furthennore, Wife verifies and represents by the signing of this Agreement that there are no additional copies of these documents in the control of Wife and she further verifies and represents that she has not made copies of these documents and given them to any other individual, II I I ! I , Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other sate, country, or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification and revision thereof shall alter, amend or vary any tenn of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or its decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to pennit this Agreemcnt to survive any judgment and to bc forever binding and conclusive upon the parties, 12 Husband and Wife do hereby mutually remise, release, quit claim or forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, of whatever nature and wherever situate, which he or she now has or at anytime hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any fonner acl~, contracts, engagements or liabilities of such other or by way of dower or courtesy of claims in the nature of dower or courtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country or any right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is thc intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 13 Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments or documents that may be reasonably required to give full force and effect to the provisions of this A!,'feemenl. i I 14 A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon the 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, 15 This Agreement contains the entire understanding of the parties and thero;. are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 16 It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 17 If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. 18 This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, 19 If any tenn, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation, 20 Except as otherwise set forth herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. >- ~ ~ M ~~ I-" 8 luQ ():7::: c..)--=.. ~ ():;;: n: ~~i~ :;;;: r;:')~ .1--.. ~t~: a ~:;~ . f,' _'1z u.!6~ c" "':15 Et~l '-" '.1 =:> ':':"4fl- fCc """ :.~ lc, C'\ '.-,) 0 0'\ U j " ,? ~ 'I. , " f~ >- ~ a; M is l.UQ 5 ::;).,.. <'-)""- 8~ i+=~':l ~ ,..."'" "'" 0> go '~5:! r,: 0 ~~~ :::II:'; N teLL' C.!) rl:- if ul65 ::J -, "'" (9 a.. '"_ en -" 0 ::;) en U ~ ,... ;- l., e ,.; @ iE~ ~:; , 'B 'V Wel : s.:~ (~) .).. .. Gj l,_-. (.&:: 'J_.I ;,'._j . (')1_- ~ ~ :2 1 ',- In ... ClI. ','.: l.lJ" / 0:1; , (!: ....... fL 'I b.,- - f':- ~, l(1.. IL C'> ~) (.) 0- U -J:.~ -f-.~ ~~~ u... t:'- ~ ~ R ~-:l1 CJ ('/ z o CIl ~ Z:t~", :=.:J",S!:l O...]l:::- :;-~e~~ CIl ~ ",0 c1iN Z--~ =="'li~o:: ~~==a-- Q<~ ~ ., ~ ; >- - i;; cr; c-; ~ lu(') c5 :5S; u:< - O2 0:0 =c: (J " '..I.:I.. VJ: '" C)Ih [-.J-' ,!,p <::> ..;s:! '.' "" lUC.., C\J ,.)<; fI!tu C.!l 'DiD -,' -. :1:)' f-' ;;;; ._0.: "- t:rl -or.: C5 0\ a ! tf) ~ - ~~ <!l 8~ :c ~j; c... ~~ ~ co .~ 0.., ::'1z u:l1J (.!l IX: en ~ ~ ilia.. :;:;: u.. 0"> ::J 0 0"> c..> JOYCE L. LOMBARDO, ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v. : CIVIL ACTION. LAW BARRY P. LOMBARDO, Defendant : NO, 99-2259 ; IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER A 3301(e) 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 I do not claim them beFore a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, ~4904, relating to unsworn falsification to authorities, Date: ~/;l. ~/fcr 'i; , ;.~ ~\ J .';l " " .y r " , ~ II) ~ ~i .- ::>~ M 8~ :l!: 0- ~~ gC co --'i:J) 15! ::5.z CCrn cet" (.!l uJ ::> ~a. r!: oCt u... (1\ [3 0 (1\ ., :i I I JOYCE L. LOMBARDO Plaintiff BARRY p, LOMBARDO Defendant TO: The Prothonotary : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION : NO.: 99 - 2259 CIVIL TERM : IN DIVORCE PRAECIPE Please enter the appearance of Hubert X. Gilroy, Esquirc on bchalf of Dcfcndunl Burry P. Lombardo, Datc: c4( Ql Q1 H~Uire Broujos & Gilroy, P.C, 4 North Hanovcr Street Carlislc, P A 17013 717-243-4574 >- \.D '- " 9:: Lr~ r:: " ~ ?,-~~-) UJf:2 c.Jej c: ::i:\~ H:2., '"\-j ~c: " '~. C, .I'ff) C N ,;~5i ~", c"" :.:.lIlJ LL:~L 0_ ~:-! n.. ~. ~, --:; u_ en :::> 0 Co'" 0 >- '-" .~ a; /.r) r- i.:!: .~;>- :'.hj lL..q ',,1 0"',. ", --(", ii.: '. " l-t-:i. :~, (")1_. '- r '.': '=' 'r; G'.. <'.' lLr:. ,. ~~.! c:.: f" CI._ :",j ::t. ., """ :.1.. C" -' 0 C... 0