HomeMy WebLinkAbout99-04419\S
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
P ?? y
t..
rerald Madrzykawski
NO. 4919 99
Plainti ff
VERSUS
Maryann Madrzvkowski
Defendant
DECREE IN
DIVORCE t , /.so
AND NOW, ,OWIT IS ORDERED AND
DECREED THAT *tA
Madrzykowski PLAINTIFF,
AND Maryann Madrzykowski ,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;
QDRO & Divorce Agreement Attached
OTHONOTARY
1
.1.
GERALD F. MADRZYKOWSKI.
Plaintiff
V.
MARYANN MADR%YKOWSKL
Defendant
IN Ti m COURT OF COMMON PLEAS OF
CIJM13ERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
IN 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:
Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Certified Mail - received and signed
for on July 28. 1999 by Defendant, attached as Exhibit "A".
3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce
Code: by the Plaintiff July 21, 2004; by the Defendant July 21. 2004
4. Related claims pending: None
5. Date and manner of service of the notice of intention to file Praecipe to transmit
record, a copy of which is attached: July 23 2004.
Date:
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M
ark F. Bayley, Esqu'
155 South Hanover Street
Carlisle. PA 17013
(717) 241-6070
Supreme Court ID No. 87663
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GERALD F. MADRZYKOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
V.
MARYANN MADR7_YKOWSKL
Defendant
IN DIVORCE
PROOF OF SERVICE
a SENDER: I also wish to receive the follow-
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s a Caoplae Items 1 andrar 2 for addilionai Services. ing services (for an extra fee):
Canplele items 3.4a, and 4b.
O Prim your name and address on the reverse of this form so that we cartreturn this
Addressee's A re
card to you.
O Attach Ihle form to the front of the maitpiece. or on the back it space does not 2.
eshictad Delivery
permit.
o wi te'Return Receipt Requeslad-on the maiplece below the article number. K
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C a The Return Receipt wio show to wham the article was delivered and the date
delivered
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DIVORCE AGREEMENT
THIS AGREEMENT, made this ?pv ! day of t L/ a L , 2004 by and
between Gerald Madrzykowski, hereinafter referred to as "HUSBAND", and Maryann
Madrzykowski, hereinafter referred to as "WIFE."
WITNESSETH: WHEREAS, I IUSBAND and WIFE were lawfully married on June 4,
1977; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of I-IUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling filly and finally their
respective financial and property rights and obligations as between each other, including, without
limitation by specification; the settling of all matters between them relating to the ownership and
equitable distribution and real and personal property; the settling of all claims and possible
claims by one against the other or against their respective estates and equitable distribution of
property and alimony for each party.
NOW, THEREFORE. in consideration of the promises and the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration,
receipt of which is hereby acknowledged by each of the parties hereto. HUSBAND and WIFE,
each intending to be legally bound, hereby covenant and agree as follows:
The parties intend to maintain separate and permanent domiciles and to live apart
from each other. The parties further intend to finalize a divorce. It is the intention
and purpose of this Agreement to set forth the respective rights and duties of the
parties while they continue to live apart from each other.
2. The parties have attempted to divide their matrimonial property in a manner that
conforms to just and right standards, with due regard to the rights of each party. It is
the intention of the parties that such division shall be final and shall forever determine
their respective rights. The division of existing marital property is not intended by
the parties to constitute in any way a sale or exchange of assets.
3. Further, the parties agree to continue living separately and apart from each other at
any place or places that he or she may select. Neither party shall molest, harass,
annoy, injure, threaten or interfere with the other party in any manner whatsoever.
Each party may carry on and engage in any employment, profession, business or
other activity, as he or she may deem advisable for his or her sole use and benefit.
Neither party shall interfere with the uses, ownership, enjoyment or disposition or any
property now owned and not specified herein or property hereafter acquired by the
other.
4. The consideration for this contract and Agreement is the mutual benefits to be
obtained by both of the parties hereto and the covenants and agreements of-each of
the parties to the other. The adequacy of the consideration for all agreements herein
contained is stipulated, confessed, and admitted by the parties, and the parties intend
to be legally bound hereby.
5. Each party to this Agreement acknowledges and declares that he or she, respectively:
A. Enters into this Agreement voluntarily after receiving the advice of counsel of
his or her own choosing or has voluntarily elected not to obtain counsel;
B. Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and obligations of the parties;
i
C. Has given careful and serious thought to the making of this Agreement;
D. Has carefully read each provision of this Agreement; and
E. Fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
6. Each party represents and warrants that he or she has made a full and fair disclosure
to the other of all his or her property, interests of any nature, including any mortgage,
pledge, lien, charge, security interest, encumbrance. or restriction to which any
property is subject. Each party further represents that he or she has made a full and
fair disclosure ofall debts and obligations of any nature for which he or she is
currently liable or may become liable. Each further represents and warrants that he or
she has not made any gifts or transfers of Marital Property f'or inadequate
consideration without the prior consent of the other. Each party acknowledges that,
to the extent desired, he or she has had access to all .joint and separate state and
federal tax returns filed by or on behalfot'both parties during the marriage.
PERSONAL PROPERTY: WIFE shall retain sole possession of the trailer located
at 98 Regency South. Carlisle, where she now resides. WIFE shall be responsible for
any and all future and/or past lot rent, taxes and maintenance of said trailer.
All other personal property has been previously divided to the parties' satisfaction.
The parties have divided between them, to their mutual satisfaction, the personal
affects, household furniture and furnishings, and all other articles of personal property
which have heretofore been used by them in common, and neither party will make
any claim to any such items which are now in the possession or under the control of
the other. Should it become necessary, the parties each agree to sign any titles or
documents necessary to give effect to this paragraph upon request.
8. INCOME TAX RETURNS: All future income tar returns will be tiled separately
and the parties will each retain any refund due to them.
9. INSURANCE: HUSBAND shall provide medical insurance coverage for the
parties' daughter, Christa, until such time as she reaches the age of twenty-three (23),
provided that she remains a student and is eligible for coverage under HUSBAND's
policy.
10. HUSBAND'S PENSION: WIFE shall receive as her sole and separate property, a
portion of HUSBAND's pension, in the amount of $37,500.00. This sum is in
addition to any and all funds WIFE has already received from HUSBAND prior to the
date of this Agreement. Within thirty (30) days of the date of this Agreement,
HUSBAND's attorney shall prepare and submit a Qualified Domestic Relations
Order to HUSBAND's employer for release of the aforementioned lump sum.
HUSBAND shall be responsible for all attorney's fees associated with the preparation
of the Qualified Domestic Relations Order. Within three (3) days after obtaining the
Qualified Domestic Relations Order, HUSBAND shall present said Order to his
employer in order to allow the aforementioned funds to be immediately distributed to
WIFE.
11. OTHER ASSETS: HUSBAND waives any and all interests in any other assets
which were not mentioned by this Agreement owned by WIFE in the past, present or
liiture. WIFE waives any and all interests in any other assets which were not
mentioned by this Agreement owned by IiUSBAND in the past. present or future.
12. HUSBAND'S DEBTS: HUSBAND represents and warrants to WIPE that since the
separation he has not and in the future he will not contract or incur any debt or
liability for which WIFE or her estate might be responsible and shall indemnify and
save harmless WIFE from any and all claims or demands made against her by reason
of debts or obligations incurred by him.
13. WIFE'S DEBTS: WIFE represents and warrants to HUSBAND that since the
separation she has not and in the future she will not contract or incur any debt or
liability for which HUSBAND or his estate might be responsible and shall indemnify
and save harmless HUSBAND from any and all claims or demands made against him
by reason of debts or obligations incurred by her.
14. RETIREMENT ACCOUNTS: WIFE shall retain sole possession of all retirement
accounts which are or were in her name. HUSBAND shall retain sole possession of
all retirement accounts which are or were in his name. with exception to the above-
mentioned $37.500.00 from the Central Pennsylvania "reamsters Pension.
15 SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial
and material spousal support from each other and agree not to request or seek to
obtain alimony or spousal support and to immediately cancel any existing alimony or
support obligation which is currently in of lect.
12. HUSBAND'S DEBTS: I1USBAND represents and warrants to WIFE that since the
separation he has not and in the future he will not contract or incur any debt or
liability for which WIFE or her estate might be responsible and shall indemnify and
save harmless WIFE from any and all claims or demands made against her by reason
of debts or obligations incurred by him.
13. WIFE'S DEBTS: WIFE represents and warrants to HUSBAND that since the
separation she has not and in the future she will not contract or incur any debt or
liability for which HUSBAND or his estate might be responsible and shall indemnify
and save harmless HUSBAND from any and all claims or demands made against him
by reason of debts or obligations incurred by her.
14. RETIREMENT ACCOUNTS: WIFE shall retain sole possession of all retirement
accounts which are or were in her name. HUSBAND shall retain sole possession of
all retirement accounts which are or were in his name. with exception to the above-
mentioned $37,500.00 Isom the Central Pennsylvania Teamsters Pension.
15 SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial
and material spousal support from each other and agree not to request or seek to
obtain alimony or spousal support and to immediately cancel any existing alimony or
support obligation which is cunently in effect.
16. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise
provided herein, each party may dispose of his or her property in any way, and each
party hereby waives and relinquishes any and all rights he or she may now have or
hereafter acquire, under the present or future laws of any jurisdiction, to share in the
property or the estate of the other as a result of the marital relationship, including
without limitation, dower, curtesy. statutory allowance, widow's allowance, right to
take the intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the
other, execute, acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all
such interest, rights and claims.
17. CONSENT AND FINAL DECREE: Each of the parties agree to execute all
documents necessary to finalize a divorce.
18. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at
the request of the other. execute, acknowledge and deliver to the other party any and
all further instruments that may be reasonably required to give fill fierce and effect to
the provisions of this Agreement.
19. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal
effect have been fully explained to the parties and its provisions are fully understood.
Both parties agree that they are executing this Agreement freely and voluntarily.
HUSBAND'S legal counsel is Mark 17. Bayley, Esquire. WIFE'S legal counsel is
Heather Faust, Esquire. Both parties acknowledge that they reviewed this Agreement
with their above-named attorney.
20. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other
than those expressly set forth herein.
21. INDEPENDENT SEPARATE COVENANTS:
It is specifically understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent covenant and
Agreement.
22. VOID CLAUSES:
If any term, condition, clause or provision of this Agreement shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provision shall be stricken from this Agreement and in all other respects this
Agreement shall be valid and continue in full force, effect and operation.
23. APPLICABLE LAW: This agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
24. MODIFICATION OR WAIVER: 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
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.
25. SECURITY: HUSBAND does hereby empower WIFE's attorney or any attorney of
any Court of record within the Commonwealth of Pennsylvania or elsewhere at any
time or times hereafter to appear for him and, after declaration filed, confess judgment
against him in favor of WIFE as of any term of Court for the amount of any
delinquency, deficiency, or arrearages in the payment of support and alimony and any
and all other payments called for by any provision of this Agreement. including also
any attorney's commission for collection of five percent (5%) of the total amounts
required to be paid together with costs of suit; and does hereby waive and stay of
execution or other processes on such judgment, and holding inquisition on any real
estate levied on by virtue of any Writ sued out on such judgment is hereby dispensed
with and waived and condemnation agreed to, which real estate, may be sold under a
Writ of Fieri Facias or other lawful Writ, and all exemptions of property from levy
and sale on any execution under any law in force or hereafter passed is hereby waived
and further does hereby waive all errors, defects, and imperfections in entering the
said judgment or writ or any process of proceeding thereon or in any way touching or
concerning the same, and for the concession and entry of such judgment, this shall be
sufficient warrant and authority, and this power to coil less judgment shall not be
exhausted by confession ofjudgntent thercundar and shall remain available to said
WIFE for continued exercise of the same by the confession and entry of one or more
judgments at any time and from time to time thereafter.
26. PRIOR AGREEMENTS: It is understood and agreed that any and all Property
Settlement Agreements which may or have been executed or verbally discussed prior
to the date and time of this Agreement are null and void and of no effect.
27. BREACH: 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 reasonable legal tees
and costs incurred by the otter in enlbrcing their rights under this Agreement.
28. Unless otherwise stated herein, this agreement shall become effective immediately
upon its execution by both parties.
COMMONWEALTf101: ITNNSYLVANIA
SS
COUNTY OF CTJM13f{RLAND
PERSONALLY APPEARED BEFORE ME, A NOTARY PUBLIC FOR Cumberland
County, Pennsylvania, this _Widay of .2004. Gerald Madrzykowski,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
agreement, and acknowledge that he executed the same for purposes therein co ained.
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Date fitness
IN WITNESS WHEREOF, I have hereunto set my hand and official seal. the parties
have hereunto set their hands and seals the day and year first above written.
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PERSONALLY APPEARED BEFORE ME, A NOTARY PUBLIC FOR Cumberland
County, Pennsylvania, this 62-) day of Pt p r t 1 . 2004, Maryann Madrzykowski,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
agreement, and acknowledge that she executed the same for purposes therein contained.
Date Maryan Madrzykowski
-i l at? l o`t W--00. kkA t 2 Date Witness
IN WITNESS WHEREOF, 1 have hereunto set my hand and official seal.
? I` ? -' .=ARZONA
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Notary Public
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GERALD F. MADRZYKOWSKI,
Plaintiff,
VS.
MARYANN MADRZYKOWSKI,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
No. 9 7- ?y19 ?l v c /E 2 r?
CIVIL ACTION - IN DIVORCE
NOTICEJO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are warned that if
you fail to do so, the case may proceed without you and a decree of divorce or annulment
may be entered against you by the Court. A judgment may also be entered against you for
any other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for 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, Cumberland County Courthouse, Hanover and High Streets,
Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL-
MENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone: 717-249-3166
GERALD F. MADRZYKOWSKI,
Plaintiff,
VS.
MARYANN MADRZYKOWSKI,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
No. 9 9- Y,-1 19 % e•_
Civil Action - In Divorce
COMPLAINT
1. Plaintiff is Gerald F. Madrzykowski, who currently resides at 3077 Spring
Road, Carlisle, Cumberland County, Pennsylvania, 17013 since February 1999. Plaintiffs
Social Security No. is 280-34-9509.
2. Defendant is Maryann Madrzykowski, who currently resides at 98 Regency
South, Carlisle, Cumberland County, Pennsylvania, 17013 since June 1997. Defendant's
Social Security No. is 176-36-4360.
3. The Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married June 4, 1977 in Westmoreland
County, Pennsylvania.
5. There have been no prior actions of divorce or annulment of marriage
between the parties.
6. The Defendant is not a member of the Armed Services of the United States
of America or its Allies.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
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. Section
4904 relating to unsworn falsifications to authorities.
G RtALD F. MAD DWSKI
IRA H. WEINSTOCK, P.C.
800 North Second Street
Harrisburg, PA 17102
Phone: 717-238-1657
By. "-- / WDULLEA BOWIE
Atty`.'I.D. No. 61888
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1. F
GERALD F. MADRZYKOWSKI,
Plaintiff
v.
MARYANN MADRZYKOWSKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed
on July 22, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice of
Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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
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JUN 2 8 2004
GERALD F. MADRZYKOWSKI,
Plaintiff
v.
MARYANN MADRZYKOWSKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
July 21, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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.
?i
M RYAN ADRZYKOWSKI
Date
Cl)
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GERALD F. MADRZYKOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
MARYANN MADRZYKOWSKI,
Defendant
IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
s 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
2. 1 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 THE FOREGOING 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.
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Date GERALD F. MADRZY SK
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GERALD F. MADRZYKOWSKI,
Plaintiff
v.
MARYANN MADRZYKOWSKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
2. 1 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. 1 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 THE FOREGOING 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
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GERALD F. MADRZYKOWSKI, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
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V.
MARYANN MADRZYKOWSKI, NO. 99-4419 Civil Term
-
Defendant : CIVIL ACTION - IN DIVORCE
IRA \
AND NOW, this IRA\ day of A : "` , 2001, the attached Stipulation
of the parties authorizing each party to receive a distribution of Ten Thousand Dollars
($10,000.00) from the recent settlement of Plaintiff's personal injury case, with the remaining
settlement being escrowed in an interest-bearing account, in both parties names, with Ira H.
Weinstock, Esquire as escrow agent, pursuant to this Court's Order of April 7, 2000, is hereby
approved by this Court. The terms of the attached Stipulation are hereby incorporated into this
Order as if fully set forth herein.
BY TH OURT:
0001--
I
GERALD F. MADRZYKOWSKI, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
V. NO. 99-4419 Civil Tenn
MARYANN MADRZYKOWSKI,
Defendant : CIVIL ACTION - IN DIVORCE
STIPULATION
Plaintiff, Gerald F. Madrzykowski recently received settlement of his personal injury case
which monies are currently held in escrow by Order of Court dated April 7, 2000 and recite the
following:
1. Mr. Madrzykowski received the remainder of his personal injury settlement which Defendant
alleges is marital property and part of the marital estate.
2. Defendant subsequently filed a Petition for Special Relief seeking to have the distribution
escrowed pending equitable distribution of the marital estate.
3. Following a hearing before Judge Guido, and with the agreement of the parties, the Court
issued an Order which specified that no withdrawals would be trade from the Keystone
Financial Accounts [Certificates of Deposit] without further order of Court or the express
written agreement of the parties.
4. The Order further stated that any additional proceeds from Plaintiff's personal injury action
would be placed in a joint interest bearing escrow account to be set up by Ira H. Weinstock,
P.C. using the social security numbers of both Plaintiff and Defendant, and that no
withdrawals could be made from that escrow account without further order of Court or the
5.
6.
express written agreement of the parties.
The settlement proceeds are $32,731.64.
The parties agree that of that amount, $12,731.61 shall be placed in an interest bearing
escrow account in both parties' names, with Ira H. Weinstock, P.C. as the escrow agent,
The parties further agree that of the remaining amount, each party shall receive a distribution
of$10,000.00, with that amount being directly deducted from the amount each party receives
in the equitable distribution of the marital estate.
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Heather Faust, Esquire
Attorney for Maryann Madrzykowski
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Wendy Dullea a ie, Esquire
Attorney for Ger d Madrrykowski
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GERALD F. MADRZYKOWSKI,
Plaintiff
V.
MARYANN MADRZYKOWSKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 CIVIL TERM
ORDER OF COURT
AND NOW, this 7th day of April, 2000, by
agreement of the parties, it is hereby directed that no
withdrawals will be made from the following Keystone
Financial accounts without further order of court or
express written agreement of the parties:
1. Certificate of deposit #3785010 in the amount
of $10,000.00.
2. Certificate of deposit 43782508844 in the
amount of $10,000.00.
It is further ordered and directed that any
additional personal injury proceeds, net of attorney's fees
and costs, recovered by the Plaintiff as a result of a
pending or contemplated personal injury action shall be
placed in a joint interest bearing escrow account to be set
up by the law firm of Ira Weinstock, P.C. using the Social
Security numbers of both the Plaintiff and Defendant. No
withdrawals may be made from said account without further
order of court or express written agreement of the parties.
This order is an agreed upon resolution to the Defendant's
Petition for Special Relief filed on March 27, 2000.
By the
Edward E
Wendy Dullea Bowie, Esquire
For the Plaintiff
J. Paul Helvy, Esquire
For the Defendant
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GERALD F. MADRZYKOWSKI IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARYANN MADRZYKOWSKI : NO. 99-4419 CIVIL TERM
: CIVIL ACTION - IN DIVORCE
AND NOW, this 3Z day of MARCH, 2000, a hearing on defendant's Petition
for Special Relief is scheduled before this Court on Friday, April 7, 2000, at 2:00 p.m.
Pending further order of court, Jason Weinstock, Esquire, and any and all
members or employees of the Law Firm of Ira H. Weinstock, P.C. are enjoined from
distributing to or on behalf of the plaintiff Gerald F. Madrzykowski any funds that may
come into his or their possession as a result of any pending or contemplated personal
injury action.
By the
Jason M. Weinstock, Esquire
Wendy Dullea Bowie, Esquire
J. Paul Helvy, Esquire
:sld
E. Guido, J.
DO
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FEN L'iL`.%,,!
THE LAW FIRM OF ORIGINAL
KILLIAN & GEPHART
210 PINE STREET
1 P. O. Box Goa
ARRISBURG. PENNSYLVANIA 17108.0886
CERTIFIED COPY W 2 9 LOO
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GERALD F. MADRZYKOWKSI
Plaintiff/Respondent
V.
MARYANN MADRZYKOWSKI
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-4419 Civil Term
CIVIL ACTION - IN DIVORCE
ORDER OF COURT
AND NOW, this day of , 2000 it is hereby ordered and decreed
that:
1. Respondent shall forward to Petitioner's counsel the entire amount of any
personal injury proceeds which he has received from Attorney Jason Weinstock thus far.
2. Petitioner's counsel shall place said proceeds in escrow upon the receipt
pending agreement of the parries or further Order of Court.
3. Attorney Jason Weinstock shall forward any further proceeds from any
personal injury actions which he receives on behalf of the Respondent to counsel for the
Petitioner to be placed in escrow pending agreement or further Order of Court.
By the Court,
J.
GERALD F. MADRZYKOWKSI
Plaintiff/Respondent
V.
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
NO. 99-4419 Civil Term
MARYANN MADRZYKO WSKI
Defendant/Petitioner
CIVIL ACTION - IN DIVORCE
DEFENDANT'S PETITION FOR SPECIAL RELIEF
AND NOW, comes the Defendant, MARYANN MADRZYKOWSKI, by and through
her attorney, Killian & Gephart and does hereby aver as follows:
I. The Petitioner is Mary Ann Madrzykowski, an adult individual who currently
resides at 98 Regency Woods South, Carlisle, Pennsylvania 17013.
2. The Respondent is Gerald F. Madrzykowksi, an adult individual who currently
resides at 3077 Spring Road, Carlisle, Pennsylvania 17013.
A divorce action was initiated by the Respondent to the above-captioned action
on July 21, 1999.
4. Since that time, counsel for the Petitioner has learned that the Respondent is
a Plaintiff in a personal injury claim the underlying cause of which occurred during the
course of the marriage.
The Petitioner believes and therefore avers that any funds received from the
aforesaid personal injury claim are marital.
6. In an effort to ensure that these funds were not dissipated by the Respondent,
on December 30, 1999, counsel for the Petitioner forwarded correspondence both to the
Respondent's personal injury attorney and his divorce attorney asking that said funds be
placed in escrow. True and correct copies of said letters are attached hereto and marked as
Exhibits "A" and "B."
7. On January 6, 2000, counsel for the Petitioner forwarded correspondence to
Respondent's divorce counsel documenting their conversation of January 5, 2000, wherein
Respondent's divorce counsel indicated that she would be forwarding documentation
regarding the Respondent's personal injury suit. No information regarding Respondent's
personal injury suit was ever provided.
8. As a result, the Petitioner has forwarded Interrogatories and Request for
Production of Documents regarding said personal injury settlement to Respondent's divorce
counsel.
9. Since the issuance of the aforesaid letters, counsel for the Petitioner has been
advised that Respondent's personal injury counsel, Jason Weinstock, Esquire, has completely
ignored correspondence directed to him and has distributed proceeds from said personal
injury settlement to the Respondent.
10. The Petitioner believes and therefore avers that the Respondent is entitled to
further proceeds from the aforesaid personal injury claim.
2
11. Given the actions of Jason Weinstock, Esquire (Respondent's personal injury
counsel) thus far, the Petitioner believes and therefore avers that absent a Court Order,
Attorney Weinstock will distribute any further personal injury funds to his client.
12. The Petitioner believes and therefore avers that absent a Court Order the
Respondent will dissipate the personal injury proceeds which represent a significant portion
of the marital estate.
WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter an
Order (1) requiring the Respondent to forward to Petitioner's counsel the entire amount of
any personal injury proceeds which he has received from Attorney Jason Weinstock thus far;
(2) requiring Petitioner's counsel to place said proceeds in escrow upon the receipt pending
agreement of the parties or further Order of Court; (3) requiring Attorney Jason Weinstock
to forward any further proceeds from any personal injury actions which he receives on behalf
of the Respondent to counsel for the Petitioner to be placed in escrow pending agreement or
further Order of Court.
J. P ulYWlvy, Esquire
lian & GephartL
,01 218 Pine Street
P. O. Box 886
Harrisburg, PA 17108
(717) 232-1851
Dated: March 21, 2000 Attorney I. D. #53148
Attorneys for
Defendant/Petitioner
EXHIBIT "A"
THE LAW FIRM OF
KILLIAN & GEPHART, LLP
JOHN O. KILLIAN 216 PINE STREET
SMITH S. OEPHART P. O. BOX 666
THOM" W. SCOTT
JANE COWEN PENNY HARRISBURG, PENNSYLVANIA 17los-oses
TERRENCE J. MCGOWAN TELEPHONE (7n) 232-1651
PAULA J. MCOCRMOTT
J
P FAX NO. (717) 236.0592
.
AUL HELW
BRAOLEY A. SCH UTJER W W W.killianpephart.com
CHAOWICI( O. BOOAR
December 30, 1999
Jason M. Weinstock, Esquire
IRA H. WEINSTOCK, P.C.
800 North Second Street, Suite 100
Harrisburg, PA 17102
RE! Madrzykowski v. Madrzykowski
No. 99-4419; In Divorce
Dear Jason:
copy
VIA FAX 238-6691
and Regular Mail
it is my understanding that a check in the amount of $50,000
is being sent to you from Nationwide regarding the claim of Gerald
Madrzykowski. Please be advised that I represent Mr.
Madrzykowskils wife, Mary Ann Madrzykowski, regarding the parties'
divorce. The funds which have been forwarded to you are marital
property subject to equitable distribution. It is my understanding
that Mr. Madrzykowski is being represented by Wendy Bowie in this
divorce.
I have enclosed a copy of the letter which I have forwarded to
Ms. Bowie asking that these funds be placed in escrow. Please
contact me immediately upon receipt of this correspondence and let.
me know whether your client will agree to placing these funds in
escrow pending the final equitable distribution of the parties'
marital assets.
JPH/ph
Enclosure
CC: Mary Ann Madrzykowski
V
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J. Pi
EXHIBIT "B"
Copy
THE LAW FIRM OF
KILLIAN & GEPHART, LLP
218 PINE STREET
JOHN D. KILLIAN
SMITH B. GEPHART P. O. BOX 886
THOMAS W. SCOTT HARRISBURG. PENNSYLVANIA 1 7 1 08-0886
JANE GOWEN PENNY TELEPHONE (717) 232-ISSI
TERRENCE J. MCGOWAN
PAULAJ. McDERMOTT FAX NO. (717) 238-0592
J. PAUL MELVY www.killianpephart.COM
BRADLEY A. SCHUTJER
CHADWICK O. BOGAR
December 30, 1999
VIA FAX 238-6691
and Regular Mail
Wendy Dullea Bowie, Esquire
IRA H. WEINSTOCK, P.C.
800 North Second Street, Suite 100
Harrisburg, PA 17102
RE: Madrzykowski v. Madrzykowski
No. 99-4419; In Divorce
Dear Wendy:
I received a copy of the enclosed correspondence indicating
that a check in the amount of $50,000 is being sent to Jason
Weinstock, Esq., as a result of an accident which occurred on April
13, 1998. Given the fact that the parties separated in February of
1999, these proceeds are clearly marital property. I suggest that
these proceeds be placed in escrow pending the resolution of this
case. If I do not hear from you regarding this request within
seven (7) days of the date of this letter, I will file a petition
with the court seeking an order which will require your client to
place these funds in escrow.
JPH/ph
Enclosure
CC: Mary Ann Madrzykowski
CERTIFICATE OF SERVICE
I, MARIA BARLETTA LaRUE, an employee with the law firm of Killian & Gephart,
do certify that I served a true and correct copy of the within document upon the following
by depositing a copy of same in the United States mail, postage prepaid, addressed as
follows:
Wendy Dullea Bowie, Esquire
IRA H. WEINSTOCK, P.C.
800 North Second Street, Suite 100
Harrisburg, PA 17102
Jason M. Weinstock, Esquire
IRA H. WEINSTOCK, P.C.
800 North Second Street, Suite 100
Harrisburg, PA 17102
Maria Barletta LaRue
Killian & Gephart
218 Pine Street
P.O. Box 886
Harrisburg, PA 17108
(717) 232-1851
Dated: March A 1, 2000
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THE LAW FIRM OF
KILLIAN & GEPHART
216 PINE 9 BEET
P. O. Box 986
HARRISBURG. PENNSYLVANIA 17108.0886
1
ORIGINAL CERTIFIED COPY
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GERALD F. MADRZYKOWKKI
Plaintiff
V.
MARYANN MADRZYKOWSKI
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
CIVIL ACTION - IN DIVORCE
ANSWER AND COUNTERCLAIM
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. This averment contains a request for relief and as such
requires no response.
WHEREFORE, Defendant, MARYANN MADRZYKOWSKI, respectfully
requests that a Decree of Divorce be granted.
COUNTERCLAIM
Defendant, MARYANN MADRZYKOWSKI, by and through her counsel,
Killian & Gephart, LLP, makes the following Counterclaim:
10. The averments of Paragraphs 1 through 9 are hereby
incorporated by reference thereto.
11. Plaintiff and Defendant are the joint owners of various
assets which are subject to equitable distribution by this Court.
WHEREFORE, Defendant, MARYANN MADRZYKOWSKI, respectfully
requests that the Court equitably divide the marital property.
CLAIM FOR ALIMONY UNDER SECTION 501 OF THE DIVORCE CODE
12. The averments of Paragraphs 1 through 11 are hereby
incorporated by reference thereto.
13. The Defendant believes and avers that she is entitled to
an award of alimony pursuant to the provisions of the Divorce Code.
CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL
FEES COSTS AND EXPENSES UNDER SECTION 502
OF THE DIVORCE CODE
14. The averments of Paragraphs 1 through 13 are hereby
incorporated by reference thereto.
15. The Defendant believes and avers that she is entitled to
an award of reasonable alimony pendente lite, counsel fees, costs
and expenses.
16. Plaintiff is fully well and able to pay Defendant alimony
pendente lite, counsel fees, costs and expenses incidental to this
divorce action.
WHEREFORE, the Defendant requests the Court enter a Decree:
a. Dissolving the marriage between Plaintiff and
Defendant;
b. Equitably distributing all marital property owned by
the parties hereto;
C. Directing the Plaintiff to pay alimony to the
Defendant;
d. Directing the Plaintiff to pay alimony pendente lite
and Defendant's counsel fees and the costs of this proceeding;
e. Such further relief as the Court may determine
equitable and just.
Respectfully submitted,
KILLIAN & GEPHART
V J Paul Helvy, E uir
ttorney I.D. # 148
218 Pine Stree
P. O. Box 886
Harrisburg, P 17108-0886
(717) 232-1851
Attorneys for Defendant
Date: October 18, 1999
I hereby verify that the statements of fact made in the
foregoing document are true and correct to the best of my
knowledge, information and belief. I understand that any false
statements therein are subject to the penalties contained in 18
Pa.C.S.A. 94904, relating to unsworn falsification to authorities.
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Ma nn Madrzykowsk'
LAi
CERTIFICATE OF SERVICE
I, J. PAUL HELVY, ESQUIRE, do certify that I served a true and
correct copy of the within document upon the following by
depositing a copy of same in the United States mail, postage
prepaid, addressed as follows:
Wendy Dullea Bowie, Esquire
Law Offices of Ira H. Weinstock, P.C.
800 N. Second Street, Suite 100
Harrisburg, PA 17102
218 Pine Street
P.O. Box 886
Harrisburg, PA 17108
717) 232-1851
Dated: October 18, 1999 (Attorneys for Defendant
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GERALD F. MADRZYKOWSKI, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-4419 Civil 'term
MARYANN MADRZYKOWSKI,
Defendant CIVIL ACTION - IN DIVORCE
ORDER OF COURT
JNK
AND NOW, this N day of G-, 2004, pursuant to the parties'
Agreement to the entry of the attached Central Pennsylvania Teamsters Retirement Income Plan
Qualified Domestic Relations Order, it is Hereby Entered.
J.
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GERALD F. MADRZYKOWSKI. : IN TI IE COURT OF COMMON PLEAS OF
Plaintiff' : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4419 Civil Term
V.
MARYANN MADRZYKOWSKI,
Defendant CIVIL ACTION - IN DIVORCE
CENTRAL PENNSYLVANIA TEAMSTERS RETIREMENT INCOME PLAN
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW come the Plaintiff, Gerald F. Madrzykowski, represented by Mark F. Bayley,
Esquire, and Defendant, Maryann Madrzykowski, represented by her counsel, Heather Faust,
Esquire, and in support ofa Central Pennsylvania Teamsters Retirement Income Plan Qualified
Domestic Relations Order aver as follows:
I. IDENTIFYING INFORMATION-
1. The Participant is Gerald F. Madrzykowski.
The Participant's social security number is 280-34-9509.
The Participant's address is 3077 Spring Road, Carlisle, PA 17013.
2. The Alternate Payee is Maryann Madrzykowski.
The Alternate Payee's social security number is 176-36-4360.
The Alternate Payee's address is 98 Regency Woods South. Carlisle, PA 17013.
The Alternate Payee's date of birth is August 16, 1946.
3. The parties were married on July 14, 1977 and separated on February 2, 1999.
4. The parties have raised claims ofequitable distribution of marital property
pursuant to the Pennsylvania Divorce Code.
11. METHOD OF DIVIDING PARTICIPANT'S BENEFITS:
1. The Plan shall pay to the alternate payee a portion of the Participant's vested
accrued benefit under the Plan.
a. The alternate payee shall receive a lump payment of $37,500.00.
2. The Fund shall separately account for the benefits awarded in paragraph I of this (Y
b?
Section II as soon as administrable after this Order is determined to be a QDRO. t j n
M
The Alternate Payee shall be credited with net income, loss or expense from the
date this Order is determined to be a QDRO. V
3. The Alternate Payee may elect to receive payment from the Plan in any form in
which benefits may be paid under the Plan to the Participant (other than in the
form ofajoint and survivor annuity).
4. The Alternate Payee may select a beneficiary to receive her benefits in the event
the Alternate Payee should die prior to receiving all of her benefits by tiling a
Beneficiary Designator form with the Fund office. In the event the Alternate
Payee should die prior to receiving benefits, the Plan shall pay benefits to a
beneficiary selected by the Alternate Payee on a Benericiary lomi provided by the
Fund office on request. or if no beneficiary is selected, to the Alternate Payee's
estate.
5. The Alternate Payee may elect to receive payment from the Plan at the
Participant's earliest retirement age. or. if earlier, at the earliest date permitted
under the Plan For purposes of this paragraph. the Participant's earliest
retirement age means the earlier of(i) the date on which the Participant is entitled
to a distribution under the Plan, or (ii) the later of (a) the date the Participant
attains age 50 or (b) the earliest date on which the Participant could begin
receiving benefits under the Plan if the Participant separated from service.
Coi i r Po ;> C-> aF 'rh 1 a
III. OTHER PROVISIONS: PG r a 5 < ?)-7 i h c. c? r ) t C'+
CA a tm P r r r-*+ ! t i-c d J ti cl c or
1. This Order is intended to constitute a Qualified Domestic Relations Order within h
the meaning of Section 414(p) of the Internal Revenue Code of 1986, as amended P (? n
M C cI n
in Section 206(d) of the Employee Retirement Income Security Act of 1974, as + }Z
amended, and shall be interpreted in a manner consistent with such intention. ° Ir-c
2. The Court shall retain jurisdiction to amend this Order to the extent necessary to p cJ C 0
establish or maintain its status as a Qualified Domestic Relations Order. e (? d.
3. It is recognized that the Alternate Payee may elect to commence receiving benefits b y
before the Participant retires. If the Alternate Payee so requests, the Participant t h
will cooperate with the Alternate Payee in substantiating a claim or application to N n F
the Fund and shall provide any documentation or information reasonably nMAVA
necessary to establish their eligibility for benefits.
We. the undersigned. hereby agree to the entry of the above
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Date
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Date
Date
June 05 .1. Q0
Date
Mad
F. Bayley.
I leather Faust. Esquire
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GERALD F. MADRZYKOWSKI,
Plaintiff
v.
MARYANN MADRZYKOWSKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-4419 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
MARYANN MADRZYKOWSKI, being duly sworn according to law, deposes
and says that she is the Defendant in the above-captioned divorce action in which a final
decree from the bonds of matrimony was entered and she hereby elects to resume her
prior surname of REID and, therefore, gives this written notice avowing said intention, in
accordance with #704 of the Act of November 15, 1972, P.L. 1063, 54 PA C.S.A. 704.
To be kn wn a
Sworn and subscribed to
before me this 3 d day of
??? OFFICIAL SEAL
/ YI L 2004. WILLIAM A. LEYVA
/ RTE !Tr- /fix-2unIh IN L l ? N0IM PUBLIGANTY
PIMA COUNTY
Comm. Eery. July 23, 2005
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