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HomeMy WebLinkAbout07-2180KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff LYUBOV BATAZHAN, Plaintiff V. YURIY BATAZHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 67-,M0 O;vi l Term : DIVORCE 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. 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 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: 1 Courthouse Square, Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE 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, PA 17013 (717) 249-3166 OR (800) 990-9108 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff LYUBOV BATAZHAN, Plaintiff V. YURIY BATAZHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0'7- a 1 Fly e4'? -a `T- : DIVORCE COMPLAINT IN DIVORCE COUNTI Request for a No-fault Divorce Under Q301(c) of the Domestic Relations Code 1. Plaintiff is LYUBOV BATAZHAN, who currently resides at 426 Meadow Drive, Camp Hill, Cumberland County, PA 17011. 2. Defendant is YURIY BATAZHAN, who currently resides at 760 Markham Court, Lewisberry, PA 17339. 3. Plaintiff has been a bona fide resident 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 April 28, 1985 in the Ukraine. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. The parties are parents of one minor child, Angelina Batazhan and one child who has reached the age of majority. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(c) of the Domestic Relations Code. COUNTII Request for Alimony Under §§ 3701 of the Domestic Relations Code 9. Plaintiff hereby incorporates Paragraphs 1 through 8 of her Complaint as if fully set forth herein. 10. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to fully support herself through appropriate employment. Husband is able to provide reasonable financial support to Plaintiff. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order of final alimony in her favor pursuant to §§3701 of the Domestic Relations Code. COUNT III Request for Equitable Distribution of Marital Property Under X3502 of the Domestic Relations Code 11. Plaintiff hereby incorporates Paragraphs 1 through 10 of her Complaint as if fully set forth herein. 12. The parties are owners of marital property subject to equitable distribution. 13. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties and the marital debts of the parties without regard to marital misconduct in such proportions as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Honorable Court enter an Order of Equitable Distribution of marital property and marital debts pursuant to §3502 of the Domestic Relations Code. DATED: y" KE ET F. LEWIS, ESQUIRE Attorney for Plaintiff I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. 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. Dated: 07 )YU4, N. iJ6A"TAZHAN i4 ..a cvlk 0 I v CA z 9-sQ?0 oO n1 1 9u b CO 0 C N T TI J,J ITT r _ CD -77 i - _- CD LYUBOV BATAZHAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2180 YURIY BATAZHAN, Defendant DIVORCE AFFIDAVIT OF SERVICE I certify I served the Complaint upon the Defendant, YURIY BATAZHAN by U.S. certified mail, addressee only, postage prepaid at Harrisburg, PA and that Mr. Batazhan received, and signed for, the Complaint on April 21, 2007, as evidenced by the receipt attached below. DATED: 4/24/07 KEqNET14 F. LEWIS, ESQUIRE Attey I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the hack of the mailpiece, or on the front If space permits. 1. Article Addressed to: ul4 Nfaz?n AA(?Mn CX(t L?,wi5ben?l P4 j?33? A. C. 6.6 deYLrery address dI faent from bm 1? Wyse If YES, enter delNery address below: 0 No -7 s o Q???asn Cc), rl fied Mau 0 Express Mau 3.Hegistered lypa O Return Receipt for mwdwx be 0 Insured Mall O C.O.D. 4. Restricted Deuvey7 (Extra F94 )a yes 2. ArtkcleeNumbw 7006 g10o 0004 3476 0923 Ps Form 3811, February 2004 Domestic RMurn Receipt 102595-02-*1610 ; €r riT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LYUBOV BATAZHAN, ( NO. 07-2180 Civil Term Plaintiff I V. YURIY BATAZHAN, DIVORCE Defendant PRAECIPE FOR ENTRANCE OF APPEARANCE TOPROTHONOTARY: Please enter the appearance of N. Christopher Menges, Esquire Whose address is: MENGES, McLAUGHLIN, CUNNINGHAM & KALASNIK, P.C. 145 East Market Street York, PA 17401 (717) 843-8046 As Attorney for: Yuriy Batazhan, the Defendant in the above-captioned case. Date: 141111D7 4 N. hrist er ges, Esquire Sup. C . I.D.# 23 6 C) C) CZ) cz LYUBOV BATAZHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2180 YURIY BATAZHAN, Defendant DIVORCE SETTLEMENT AGREEMENT THIS AGREEMENT, is made this day of fitjqas? , 2007, by and between LYUBOV BATAZHAN ("Wife") and YURIY BATAZHAN ("Husband"). W I T N E S S E T H• WHEREAS, the parties, currently Husband and Wife, will be obtaining a decree in divorce; and WHEREAS, by this Agreement, the parties have intended to effectuate and equitably divide their marital property and marital debts; and WHEREAS, diverse unhappy differences and difficulties have arisen between the parties and it is their intention to live separate and apart for the rest of their lives and to settle any claims by one against the other or against their estates. NOW THEREFORE, with the foregoing recitals being incorporated by reference and deemed as an essential part hereof and in consideration of the premises and of the mutual promises set forth herein and for other good and valuable consideration, receipt of which is hereby acknowledged, the parties, each intending to be legally bound hereby, covenant and agree as follows: 1. 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 with respect to the parties. This Agreement shall be incorporated, but not merged into the final decree in divorce. 2. FINANCIAL DISCLOSURE. The parties confirm each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to executing this Agreement. No representations have been made by either party to the other, or by anyone else, as to the financial status of the other except as set forth in this Agreement. 3. ADVICE OF COUNSEL. Wife has been advised regarding this Agreement by her attorney, Kenneth Lewis. Husband has been advised regarding this Agreement by the attorney of his choice or has chosen to forego obtaining such counsel. Both parties acknowledge this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received independent legal advice, or choosing not to do so. The parties acknowledge this Agreement is not the result of duress or undue influence and is not the result of any collusion or improper or illegal agreement(s). This Agreement shall be construed as if drafted by both parties. 4. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. The parties understand each has the right to obtain from the other party a complete inventory of all the property either or both parties now own or owned as of the date of separation, and that each has the right to have such property valued by appraisals or otherwise. The parties understand they have the right to have a Court hold hearings and make decisions on the matters covered by this Agreement. Both parties understand a Court's decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Both parties waive the following procedural rights: a. The right to obtain an Inventory and Appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code. b. The right to obtain an Income and Expense Statement of the other party as provided by the Pennsylvania Divorce Code. 2 C. The right to have the Court determine which property is marital and which is non-marital and equitably distribute between the parties that property which the Court determines to be marital. d. The right to have the Court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including but not limited to possible claims for divorce, spousal support, alimony, alimony pendente lite, counsel fees, costs and expenses. 5. PERSONAL RIGHTS. Husband and Wife, may live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as if they were unmarried. Husband and Wife shall not harass, disturb or malign each other or the respective families of the other nor attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 6. MUTUAL RELEASES. Except as provided in this Agreement, Husband and Wife each mutually release and forever discharge the other and the other's estate from any rights (including income and gain from property hereafter accruing) of the other or against the other's estate, which he/she now has or may hereafter have against the other or the other's estate, arising out of any circumstance, including dower or curtesy, or claims in the nature of dower or curtesy 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 other rights of a surviving spouse to participate in a deceased spouse's estate, regardless of the jurisdiction. The release includes any rights which either party may have or at any time hereafter have for past, present or future spousal support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, 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 the 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. 3 7. PERSONAL PROPERTY. a) The parties confirm they have relied on the completeness and substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge there has been no formal discovery conducted in their pending divorce action. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owned by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his/her counsel prior to the date of this Agreement is expressly reserved. In the event either party, at any time hereafter, discovers such an undisclosed asset, the party shall have the right to petition the Court of Common Pleas of Dauphin County to make equitable distribution of said asset. The non-disclosing party shall be responsible for payment of counsel fees, costs and/or expenses incurred by the other party in seeking equitable distribution of said asset unless the Court finds that payment of such fees would not be equitable. In such event, the Court can deny fees or limit the amount of fees to be paid. Notwithstanding the foregoing, the Agreement shall in all other respects remain in full force and effect. b) The parties agree to make the following disposition and settlement with respect to their marital personal property: i) The parties agree they have already divided their personal property to each's satisfaction, other than as provided for in this Agreement. ii) Each party will retain the checking, savings and/or money market accounts listed in his/her sole name. Each party waives any and all interest he/she may have in the other party's accounts. iii) Husband shall be the sole owner of his minimal retirement plan with Harley Davidson. Wife waives all interest in such account. iv) Wife shall be the sole owner of the 2000 Honda Odyssey 2000. Husband shall be the sole owner of the 2002 BMW X5 and the 1986 GMC vehicle. The parties shall promptly sign any and all documents necessary to transfer the vehicles to effectuate this paragraph. The party retaining each vehicle shall be fully responsible for all payments related thereto and will hold the other harmless and indemnify the other from any claims arising from the ownership or operation of any such vehicles. As soon as is practicable, Husband shall refinance the debt associated with the BMW so Wife will not be listed as a debtor. 4 v) Wife shall retain her design business, which the parties acknowledge has a de minimis value. 8. REAL ESTATE. The parties acknowledge they are co-owners of a home and land located at 780 Markham Ct, Lewisberry, PA 17339. Husband shall become the sole owner, with Wife transferring all her interest in the property. Husband shall indemnify and hold Wife harmless from any and all debts or claims associated with that property. Husband shall refinance the property or otherwise remove Wife's name from the home loan as quickly as possible, but in any event, within four (4) months from the date of this agreement. Husband shall be responsible for any and all debt associated with the home and shall indemnify Wife from any claims regarding the home. In exchange for Wife transferring her interest in the real estate, Husband shall perform the following: a) Husband shall pay to Wife the sum of $70,000.00 at or before the time of the refinancing. b) Husband shall pay to Wife for assistance with medical/insurance costs, the sum of $350.00 per month for a period of two (2) years, beginning with the first month she is no longer eligible to remain on Husband's health insurance plan. These monies are part of the overall property distribution and are not alimony. 9. AFTER-ACOUIRED PERSONAL PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were not married. 10. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. The parties hereby waive and surrender any rights and/or claims they may have to interim or final alimony, alimony pendente lite and spousal support. 5 11. ATTORNEY'S FEES AND COSTS. The parties waive and surrender any rights and/or claims they may have to interim or final counsel fees and/or costs. 12. DEBTS. a) The parties acknowledge there are no debts existing for which both parties are liable other than debts associated with the real estate and the BMW vehicle covered above. b) Each party shall be solely responsible for all debts listed in his/her sole name. Each party shall indemnify and hold the other harmless against all actions or collections of whatever kind arising from these debts. c) Each party represents he/she has not incurred any liability for which the other may be responsible except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, except for the obligations arising out of this Agreement. d) Each party shall immediately close out any and all joint credit card accounts, bank accounts and any other financial accounts in both parties' names. 13. WARRANTIES TO FUTURE OBLIGATIONS. Husband and Wife each agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. 14. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 6 15. BREACH. The parties agree that if either fails in the due performance of any of his or her obligations under this Agreement, the other party shall have the right at his or her election to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal remedies as may be available and said other party shall have the right to recover his or her reasonable legal fees and costs for any services rendered by his or her attorney. 16. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take all steps and execute, acknowledge and deliver to the other party any further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 17. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 18. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior Agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or 7 similar nature, nor shall it be construed as a waiver of strict performance or any other obligations herein. 21. SEVERABILITY. If any term or provision of this Agreement shall be determined to be invalid, then only that term or provision shall be stricken and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 22. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text subparagraphs hereof are inserted solely reference and shall not constitute a part shall they affect its meaning, construction 23. TAX ADVICE. of the paragraphs and for convenience of of this Agreement nor or effect. Both parties acknowledge and agree they have had the opportunity to retain their own accountants, certified public accountants, tax advisor, or tax attorney with reference to the tax implications of this Agreement. Further, neither party has been given any tax advice whatsoever by their respective attorneys. Further, both parties hereby acknowledge they have been advised by their respective attorneys to seek their own independent tax advice by retaining an account, certified public accountant, tax attorney or tax advisor with reference to the tax implications involved in this Agreement. Further, the parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent tax advipe. witn ss witn ss YU IY BA AZHAN 8 :..,? ?? * -' Z -r, G '? _r, w ?? 1 ..? r. (`J ' `?'?t 1 E `° (lt L. ? -f LYUBOV BATAZHAN, Plaintiff V. YURIY BATAZHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2180 DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on April 18, 2007. 2. The marriage of 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 in Divorce after service of notice to intention to request entry of the decree. 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. Dated: 0610 07 C`? ra t3 ?cam cam, LYUBOV BATAZHAN, Plaintiff V. YURIY BATAZHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2180 DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on April 18, 2007. 2. The marriage of 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 in Divorce after service of notice to intention to request entry of the decree. 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. Dated: 0 1 1,t 6 t Y RIY BA AZHAN r.7 ? ` ,-? ?s =_? '`' ? ' n??? r ? ?= ?: ? fl? ? .?- ?-. tv _r ? =; ?'`? t*.? ry.+. .?.: ?? c .•, , ?. LYUBOV BATAZHAN, Plaintiff V. YURIY BATAZHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2180 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: 6117 0 ? (//u 1"t, 1 C4 6 1ee u Y IY B TAZHAN t'v ? -rt STi,- c G 'T? LYUBOV BATAZHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-2180 YURIY BATAZHAN, Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: o ell ,n LY OV BA HAN ? "`' Ca - k-t c? ?, --? ? r? ?. ?` , `r < ;? . . ? _.-- y t't. ''?.- f ...1 ?? ?? ??k LYUBOV BATAZHAN, Plaintiff V. YURIY BATAZHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2180 DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section M 3301(c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail signed by Defendant on 4121/07; Affidavit of Service filed 4/26107. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on 8!17107; by the Defendant on 8117/07 (all filed concurrently with this Praecipe). 4. Related claims pending: NONE, Parties entered into ronerty settlement agreement incorporated into divorce decree. DATED: 01)0? '^'* KE ET F. LEWIS, ESQ. Attorney I.D. 169383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ? ? ? -•' <? ,.?.? %' ?-? r f i ? ? - C ? ^f t# j7 ? t" i .'L , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. LYUB01( PXT7 4-47M VERSUS yukly sha z ymi No. d 9-zl gD DECREE IN DIVORCE AND NOW, L / IT IS ORDERED AND DECREED THAT 1.--I V I?T? V BArff zj I PLAI NTI FF, AND YULTY I.?TI ZWA?J 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; BY THE COURT' AT-MSTA , / '-l 17 ., '.-? J. PROTHON bvtllot m oed, ? efpl? . 40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LYUBOV BATAZHAN, NO. 07-2180 Civil Term Plaintiff I V. YURIY BATAZHAN, Defendant DIVORCE PRAECIPE FOR EXIT AND ENTRY OF APPEARANCE TO PROTHONOTARY: Please withdraw the appearance of N. Christopher Menges, Esquire whose address is MENGES, MCLAUGHLIN, CUNNINGHAM & KALASNIK, PC 145 East Market Street York, PA 17401 Telephone: (717)843-0846 as Attorney for Yuriy Batazhan, Defendant, in th ove cap oned case. DATE: ? \Z and please ENTER the appearance of case. Sup. Ct. ID # 2 66 Yuriv Batazhan, pro se, in the above captioned whose address is 780 Markham Ct. Lewisberry, PA 17339 DATE: '0 1 /0)- /-)-00g 007090 0301 ?? Y 44Y Bat an, pro se C ? ? --d t..... i ? T: ? ?? .? t?. ?..??. y ?t? '.?? '? .?