HomeMy WebLinkAbout99-07642e,
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY °
STATE OF ra
PENNA.
LYNN Mxam,
_ _... N 99-7642 CIVIL TEEN
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........._.. Plaintiff__ ......................
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HENRY R. KOREIZKY,
Defendant
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DECREE IN
DI VORCE?-3.•i??•
2000
I.AA 3 AND NOW........... '............... >...... , it is ordered and y
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decreed that ......L?tru? MCCai? ................................ plaintiff, ;•
F?TII2Y KOREMKY
and .......................................................... defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
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been raised of record in this action for which a final order has not yet
been entered;
The Property Settlement Agreement dated October 27, 1999 shall be incorporated
.xnto.tiis Decxee.in.Divorce ...............................................
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Prothonotary
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
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This Agreement, made and entered into this r?2hay of e 1999, between Lynn
McGowan, of 468 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, hereinafter
referred to as "Wife," and Henry R. Koretzky, of 5609 River Road, Harrisburg, Dauphin County,
Pennsylvania, hereinafter referred to as "Husband."
WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to
each other on April 30, 1997 in Cumberland County, Pennsylvania;
WHEREAS, the parties hereto are now living separate and apart and desire to enter into an
Agreement respecting their property rights, regardless of the actual separation or other character
thereof and their other rights;
WHEREAS, both and each of the parties hereto have been advised of their legal rights and
the implications of this Agreement and the legal consequences that may and will ensue from the
execution hereof, and each has had the opportunity to consult with his or her own competent legal
counsel independent of each other;
WHEREAS, each parry warrants, as part of the consideration of this Agreement, that each
has fully and completely disclosed all information of a financial nature requested by the other, and
that no information of such nature has been subject to distortion or in any manner being
misrepresented; and
WHEREAS, the provisions of this property settlement agreement shall govern all past,
present and/or future claims for alimony, spousal support, counsel fees and costs, alimony pendente
Page 1 of 8
lite, equitable distribution, or other property rights, and all other claims which the wife or husband
has or might have against the other, except as set forth hereunder.
NOW, THEREFORE, the parties hereto intending to be legally bound hereby agree as
follows:
1. Separation. Husband and Wife do hereby mutually agree and consent to live separate and
apart and do further agree that it shall be lawful for the Husband and Wife at all times
hereafter to live separate and apart from each other, and to reside, from time to time, at such
place or places as they respectfully shall deem fit, free from any control or restraint or
interference, direct or indirect, by each other.
2. No Molestation, Harassment or Interference. Neither party shall molest, harass or
interfere with the other or compel or endeavor to compel the other to cohabit or dwell with
him or her by any means whatsoever.
3. Mutual Property and Estate Waiver. Except as otherwise expressly set forth herein, in
which event such express provision shall take precedence over this paragraph, the parties
hereto intend that from and after the date of this Agreement, neither shall have any spouse's .
rights in the property or estate of the other, and to that end both parties waive, relinquish, and
forbear the rights of dower or curtesy, rights to inherit, rights to claim or take the Husband
or Wife's or family exemption or allowance, to be vested with letters of administration or
letters testamentary, or to take against any will of the other, and each agrees with the other
if either should die intestate, his or her share shall descend to vest in his or her heirs at law,
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personal representatives, and next of kin, excluding the other as though he or she had died
a widow or widower. And each further agrees that should the other die testate, his or her
property shall descend to and vest in those persons set forth in the other's Last Will and
Testament as though the spouse so designated as beneficiary had predeceased the testator.
The parties further agree that they may and can hereafter, as though unmarried, without any
joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal
property which either of them now or hereafter own or possess and further agree that the
recording of this Agreement shall be conclusive evidence to all of his or her right to do so.
Each of the parties hereto further waives any right of election contained in Chapter 22 of the
Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an
equitable distribution of married property ordered by the Court subsequent to Section 3502
of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be
under any legal obligations to support the other, pay any expenses for maintenances, funerEl,
burial, or otherwise for the other and, to that end, each of the parties hereto does hereby
waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses,
or any type of financial assistance whatsoever from the other, except as otherwise expressly
provided for herein.
4. Spousal Support/Alimony. Husband shall pay Wife seven hundred dollars ($700.00) per
month for a period of two (2) years from June 1999 to June 2001. The parties agree that the
amount of $700.00 per month shall constitute the Husband's sole monetary support and
maintenance provided to Wife during said period and Wife shall not seek payment of any
Page 3 of 8
The parties agree that the federal income tax refund for the 1998 year in the amount
of approximately two thousand dollars ($2,000.00) shall be divided equally between
the parties. Upon signing this agreement,
of the funds to Husband.
Wife shall immediately forward one half
g. Personal effects. All items of personal effect such as, but not limited to jewelry,
ium!WO
luggage, sports equipment, hobby collections and books (out not including
f property, personal or otherwise,specifically disposed of pursuant to this
V c ? agreement) become the absolute and sole property of the party who has had the
die ti ? ?of6Bri2xci?'ASc ,,Y7•?,;?
principal use thereof ondo??
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11-IW pRgANgJand each party hereby surrenders any interest he or she may have in such
tangible personal property of the other.
6. Debts. The parties acknowledge that there are no outstanding joint debts in existence which
may be considered marital debts. In the event there are outstanding debts, those debts shall
be the sole responsibility of the party who incurred them.
7. Future Debts. The parties further agree that neither will incur any more further debts for
which the other may be held liable, and if either party incurs a debt for which the other will
be liable, that party incurring such debt will hold the other harmless from any and all liability
thereof. erj, ey??r?l
Within one (1) ear of the d?ioa s to tance the existing retin
8. Real Property.
mortgage of the former marital home, located at 468 Mountain Road, in Boiling Springs,
so as to specifically remove Husband's name from the
Pennsylvania,
Page 5 of 8
rim .
mortgage. 1??
To this end, Husband agrees to uraediatial
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execute any necessary documents reasonably related to the refinancing of the marital home.
Upon execution of this agreement, the parties agree that this property, specifically including
any and all equity therein, shall become Wife'ssole and separate property and Husband shall
convey all of his right, title, and interest in and to the marital residence to Wife, and he shall
execute any and all deeds, documents, orpapers necessary to affect such transfer oftitle upon
request. Furthermore, Wife shall have exclusive possession of the marital hare.
9. Waiver of Alimony. Except as otherwise expressly set forth herein, in consideration of the
mutual agreement of the parties voluntarily to live separate and apart and the provisions
contained herein for the respective benefit of the parties and other good and valuable
consideration, the parties agree to waive any and all claims for any alimony.
10. Pension. Both parties agree to waive any claims they may have to any pension or
.?O?te retirement /?cti
eft benefits of any kind, earned during the marriage, by the other party.
11. Counsel Fees and Court Costs. The parties agree that if either party incurs any other legal
fees or court costs associated with this agreement, those fees and costs shall be bome by that
party exclusively.
12. Breach. In the event that either party breaches any provision of this Separation and Property
Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce
the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the
other party. In the event of breach, the other party shall have the right, at his or her election,
Page 6 of 8
to sue for damages for such breach or to seek such other and additional remedies as may be
They failure of either party to insist upon strict performance
available to him or her, of ay of ttn Marsh of this Agrearent OBU not be oaz-trts3 as a
Haws of rV abseg-mt: ch-ult. /;t v5 Z
13. Enforcement. The parties agree that this marital settlement agreement or any part or parts
hereof may be enforced in any court of competent jurisdiction.
14. Applicable Law and Execution. The parties hereto agree that this marital settlement
agreement shall be construed under the laws ofthe Commonwealth of. Pennsylvania and shall
bind the parties hereto and their respective heirs, executors and assigns. This document shall
be executed as original and multiple copies.
15. The Entire Agreement. The parties acknowledge and agree that this marital settlement
agreement contains the entire understanding of the parties and supersedes any prior
agreement between them. There are no other representations, warranties, promises,
covenants or understandings between the parties other than those expressly set forth herein.
16. Incorporation and Judgment for Divorce. In the event that either husband or wife at any
time hereafter obtain a divorce in the action for divorce between them, or otherwise, this
agreement and all of its provisions shall be incorporated into any such judgment for divorce,
either directly or by reference. The Court, on entry of judgment for divorce, shall retain the
right to enforce the provisions and terms of this marital settlement agreement.
17. Additional Instruments. Each of the parties shall on demand or within a reasonable period
thereafter, execute and deliver any and all other documents and do or cause to be done any
other act or thing that may be necessary or desirable to effectuate the provisions and purposes
of this Agreement. If either party fails on demand to comply with this provision, that party
Page 7 of 8
shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a
result of such failure.
IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first
written above.
WITNESS: Vy( ?,
L McGowan
to
Henry ,<. Koretzky
Date
Page 8 of 8
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IN THE COURT OF Cav1MON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LYNN MCGOWAN,
Plaintiff NO. 99-7642 CIVIL TERM
VS.
HENRY R. KORETZKY,
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information; to the court
for entry of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under Section 3301 (c)
y%jxk%Tffl of the Divorce Code. (Strike out inapplicable section)
2. Date and manner of service of the complaint: Certified mail, restricted delivery
to the Defendant on December 30, 1999 and received by Defendant on January 4, 2000. .
3. Complete either Paragraph A. or B.
A. Date of execution of the affidavit of consent required by Section
3301 (c) of the Divorce Code: by the plaintiff March 31, 2000
by the defendant April 11, 2000
B. (1) Date of execution of the plaintiff's affidavit required by
Section 3301 (d) of the Divorce Code:
(2) Date of service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: None. The Property Settlement Agreement dated
October 27, 1999 shall be incorporated into the final Divorce Decree.
5. Indicate date and manner of service of the notice of intention to file
praecipe to transmit record, and attach a copy of said notice under Section
3301 (d)(1)(i) of the Divorce Code Waiver of Notice signed by Plaintiff
on March 31, 2000 and by Defendant on April 11, 2000
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Attorney for PlaintiffpD0002=
Keirsten W. Davidson
Attorney I.D. #78243
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Johnson, Duffle, Stewart & Weidner
By: Kcirstcn W. Davidson
I.D. No. 75243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
LYNN MCGOWAN,
V.
Plaintiff
HENRY R. KORETZKY,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
IN DIVORCE
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 pages by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR
EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 71, //;?. CIVIL TERM
CIVIL ACTION - LAW
Johnson, Duffle, Stewart & Weidner
By: Kcirsten W. Davidson
I.D. No. 78243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
LYNN MCGOWAN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 99- '1Ly2- CIVIL TERM
V.
CIVIL ACTION - LAW
HENRY R. KORETZKY, IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
tJNDER SEGTIONS 3301(q) OR 3301(0) OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Lynn McGowan, by and through her attorneys, Johnson, Duffle,
Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Henry R. Koretzky:
1. The Plaintiff is Lynn McGowan, an adult individual, residing at 468 Mountain Road, Boiling
Springs, Cumberland County, Pennsylvania.
2. The Defendant is Henry R. Koretzky, an adult individual, residing at 5609 River Road,
Harrisburg, Dauphin County, Pennsylvania.
3. The Plaintiff and Defendant were married on April 30, 1997, in Carlisle, Pennsylvania.
4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania at least six months immediately prior to the filing of this Complaint.
5. There has been no prior action for divorce or annulment of marriage between the parties in this
or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of marriage counseling and she may have the
right to request that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce
under Section 3301 (c) of the Divorce Code.
JOHNSON, DUFFIE, STEWART & WEIDNER
By:l
Keirsten W. Davidson
:129722
VERIFICATION
I verify that the statements made in this Divorce Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false statements made herein are made subject to the
penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities.
Date: 0 5 ?.,
Lynn McGowan
4 7 i
Johnson, Duffle, Stewart & Weidner
By: Keirstcn W. Davidson
I.D. No. 78243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
LYNN MCGOWAN,
Plaintiff
V.
NO. 174, y2 CIVIL TERM
CIVIL ACTION - LAW
HENRY R. KORETZKY,
IN DIVORCE
Defendant
AFFIDAVIT
LYNN MCGOWAN, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of,marriage counseling and understand that I may
request that the court require that my spouse and I participate in counseling.
2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I participate in
counseling prior to a divorce decree being handed down by the court.
I 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: 1919
Lynn McGowan
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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Johnson, Duffle, Stewart & Weidner
By: Kcirsten W. Davidson
I.D. No. 75243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
LYNN MCGOWAN,
V.
Plaintiff
HENRY R. KORETZKY,
Defendant
CERTIFICATE OF SERVICE
NO. 99-7642 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
I hereby certify that on the 301b day of December, 1999, 1 served a true and correct copy of the
foregoing Complaint in Divorce upon the Defendant, Henry R. Koretzky, by certified mail, restricted delivery,
to her mailing address at 5609 River Road, Harrisburg, PA 17110, return receipt requested, attached hereto
and made a part hereof.
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By: (,),&k
Keirsten W. Davidson
:129722-6
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Defendant
AFFIDAVIT OF CONSENT
Johnson, Duffle, Stewart & Weidner
By: Keirsten W. Davidson
I.D. No. 78243
301 Markel Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
LYNN MCGOWAN,
V.
Plaintiff
HENRY R. KORETZKY,
NO. 99-7642 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
19991. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 23,
.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing the Complaint.
3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request
entry of the decree.
4. 1 have been advised of the availability of marriage counseling, understand that the Court
maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate
in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in
counseling prior to the divorce becoming final.
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 unswom falsification to
authorities.
)ate: 3
:133083
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
? V,
/Lynn McGowan, Plaintiff
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Johnson, Duffle, Stewart & Weidner
By: Keirstcn W. Davidson
I.D. No. 78243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
LYNN MCGOWAN,
Plaintiff
V.
HENRY R. KORETZKY,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(q) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 this Waiver are true and correct. 1 understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Date:2M ?)nn 7 ,
ynn McGowan, Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7642 CIVIL TERM
CIVIL ACTION - LAW
:133083.3
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Johnson, Duffle, Stewart & Weidner
By: Kcirsicn W. Davidson
I.D. No. 78243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
LYNN MCGOWAN,
Plaintiff
V.
HENRY R. KORETZKY,
Defendant
AFFIDAVIT OF CONSENT
NO. 99-7642 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 23,
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing the Complaint.
3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request
entry of the decree.
4. 1 have been advised of the availability of marriage counseling, understand that the Court
maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate
in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in
counseling prior to the divorce becoming final.
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 unswom falsification to
authorities.
Date: /i a o
:133083-2
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
J ?--
Henry-R. Koretzky, Def `dent
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Johnson, Duffle, Stewart & Weidner
By: Keirsten W. Davidson
I.D. No. 78243
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
LYNN MCGOWAN,
Plaintiff
V.
HENRY R. KORETZKY,
Defendant
IN DIVORCE
WAIVER OFNOT/GINTENVON To
B€4UEST ENTRY OFA DIVOR E D 0BEE
UNDER -CTION 3 01/ 1 OF THE DIVOR E CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyers 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 this Waiver are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Date:
:733083-4 ?
ry R. Ko etrky endant
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Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7642 CIVIL TERM
CIVIL ACTION - LAW
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER I
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: April 20, 2000
DOCKET NUMBER: 99-7642 Civil Term
PLAINTIFF/PETITIONER SS# 129-38-7993
NAME: Lynn McGowan
DEFENDANT/RESPONDENT SS #
NAME: Henry R. Koretzky
198-50-7663