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HomeMy WebLinkAbout07-2795ANTHONY M. MARMO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. O'7~ ,~ 79,5" ~'~ SUSAN A. MARMO, Defendant IN DIVORCE NOTICE TO DEFEND 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FIAWER ~ LINDSAY nnvnn~rs.,v uw 26 West High Stteet Cazlisle, PA SAIDIS, FLOW, ER & L SAY Carol J -Lindsay, squire Attorney Id. 44 26 West High S reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ANTHONY M. MARMO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. D ~- a 7 9S C'.c.~,t T..c,~ SUSAN A. MARMO, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Anthony M. Marmo, an adult individual residing at 1261 Kuhn Road, Boiling Springs, Pennsylvania 17007. 2. The Defendant is Susan A. Marmo, an adult individual residing at 1261 Kuhn Road, Boiling Springs, Pennsylvania 17007. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 2, 1989 in San Diego, SAIDIS, FIAWER ~ LINDSAY a1~YS..+r uw 26 West High Street Carlisle, PA California. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, I ' SAIDI OWER & LINDSAY I'i Carol J. Lin sa , uire Attorney Id 44 3 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ' Dated: ~'~G ~~ SAIDIS, LINDSAY .+riow~vs•.~ruw 26 West High Street Carlisle, PA r VERIFICATION 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. §4904, relating to unsworn falsifications to authorities. ~~~~ ~ ~.~y~- Anthony M. M o date: ~j~ ~ ~C' ~~ SAIDIS, I,IlVDS~ ,~mertetsnT•uw 26 West High Street Carlisle, PA ~aY a 3 zoos ~~ `\ M ~,~ , ~-- ~ ~ ~~ ; , L ~ -.-f _ ~ -• CO ~1 4 P (~+` .. t f K' ~ + ~ \l \\\..J~,fff • .~ l. I ~ 1- ~ ~ ~ ~ ~~ 1~~ 1 ~ r ` CJ ~T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU1V'I'Y, PENNSYLVANIA CIVIL ACTION -LAW ANTHONY M. MARMO, Plaintiff v. No. 07-2795 ~~ Term IN DIVORCE SUSAN A. MARMO, Defendant ACCEPTANCE OF SERVICE I, SUSAN A. MARMO, Defendant in the above-captioned case, do hereby depose and say that I personally received and accepted service of a true and correct copy of the Complaint in Divorce on the date written below. I understand that false statements herein are made subject to the penalties of i8 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. to SUSAN A. MARMO - c t y ~ Y ~- --° ._t - ' -c~ ~ ~ ~ ~ - ' , _.. ---! :- _ .. , -_~ , .. _, _ ~ .~'a 'te - 4`~s i y ~• ~ ~ ~ ~• ~~~ e e ANTHONY M. MARMO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-2795 CIVIL SUSAN A. MARMO, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on May 8, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct 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. 4904 relating to unsworn falsification to authorities. Date: ~~f~ !3 - ~' ~~ ..: ,~sc,9~-- Anthony M. rmo PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST EWTRY OF A DIVORCE DECREE UNDER§ 3301 (c) OF THE DIVORCE COiDE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 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 SAIDIS, FIAWER ~ LIlVDSAY 26 West High Street Carlisle, PA and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct 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. 4904 relating to unsworn falsification to authorities. Date: ~~~'~ .%5~~ ~= ~%~~ / Anthony M. o C ~ r ~ -:1 ~ . -, r ; ~ -tZ r ~ , . ' -- ~~~ - : : „_~ _ ~; Cam' - . ~. E' ,~1 _~ c:. .Er.T ~~~ 4"~ ANTHONY M. MARMO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-2795 CIVIL SUSAN A. MARMO, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on May 8, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct 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. 4904 relating to unsworn falsification to authorities. Date: ~ C0 6 Susan A. Marmo DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not c!airr; thel,-, before a divorce 's granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court SAIDIS, ~tiOWER ~ LINDSAY 26 West High Street Carlisle, PA and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct 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. 4904 relating to unsworn falsification to authorities. Date: (D a ~~~,-- ~, i!~ t Susan A. Marmo ~ rya ~ ~~ ~.'t'` - ~ 3 --~ ~ " }: ~ --f a~ ~ ~-.a ;; ~ i;:' ~-+~ ~_~. _ i_t"1 .:;; ~ ;~3 ANTHONY M. MARMO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. SUSAN A. MARMO, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT a~ ~ THIS AGREEMENT made this ~e!~ day of ~~ , 2007, between ANTHONY M. MARMO, of 1261 Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania, hereinafter refer-ed to as Husband, and SUSAN A. MARMO, of 1261 Kuhn Road, Boiling Springs„ Cumberland County, Pennsylvania, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on April 2, 1989, in San Diego, California; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 07-2795 Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente life, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: i (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action, and will execute and file the Affidavits of Consent and Waivers of Notice to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and Husband shall move for the entry of the divorce decree at that time. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 1261 Kuhn Road, Boiling Springs, Pennsylvania. The parties agree to list the marital home for sale. Until the sale of the marital home, the parties may both remain residing in the marital home and they will contribute to its upkeep and the expenses associated with it as they have in the past from the joint account into which the parties will deposit their income. The parties will share the cost of maintaining the house so long as they are living together in it. In the event that Wife leaves the marital home before its sale, Husband will remain residing there, paying the utilities and maintaining the house. He will pay the cost of minor repairs totaling less than $200.00 and the parties will equally share the cost of repairs which exceed that amount. The parties will equally pay any real estate taxes which may come due on the house before its sale. 2 Upon sale, and after payment of the usual costs of sale, the parties will equally split the proceeds. For the tax year ending 2007, they will equally share the deduction for real estate taxes paid. The parties acknowledge that Husband is purchasing a condominium in Summerfield, Carlisle, Cumberland County and that he may make a deposit from his share of the marital estate as set out below. Wife waives any right, title or interest which she may have in the condominium which Husband will be purchasing. (4J DEBT: A. MARITAL DEBT: Husband and Wife acknowledge and agree that there are no outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement. B: POST SEPARATION DEBT: In the event that either party contracted or incurred any debt after the date of this Agreement, the party who incurred such debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred provided, however, that the parties shall share living expenses attendant upon the maintenance of the marital home as set out in paragraph 3 above. C: FUTURE DEBT: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party by said party, and shall hold harmless and indemnify the other party from any lass thereon. (5) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall 3 from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (6) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Within ten days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Husband will retain the 1996 J-30 Infiniti and Wife will retain the 2002 I-35 Infiniti. Neither vehicle is encumbered with a lien. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. Nevertheless, the parties will equally divide two PNC investment accounts which are jointly held, account number 84669281 (stock and money market fund) and account number 72462456. Such division shall take place at a time convenient to the parties, but within thirty (30) days of the date of this Agreement. The parties will also equally divide in kind their U.S. government I bonds, so that each has equal value in I bonds. It is the intention of the parties to make an equal division of the investment assets and to also make an equal division of any tax consequences occasioned by their division so that neither party is required to report on his or her 2007 tax return more tax than the other because of the division of investment assets. 4 With regard to retirement assets, the parties also agree to an equal division. The division shall be accomplished by using values of the various assets on the day of the entry of the Decree in Divorce or such other date as the parties may agree. An approximation of an equal division is accomplished by Husband's transferring from his T. Rowe Price IRA account number 430418500 $91,000.00 into an IRA for Wife as soon as may be conveniently done. Husband will instruct T. Rowe Price to apportion the payment among the funds which make up the account proportionate to the present distribution within the account. However, as soon as the Decree in Divorce is entered, the parties will calculate an exact value of their retirement assets with adjustments, Husband to Wife or Wife to Husband, of such amounts as are necessary to completely equalize the distribution. This equalization shall take place from an IRA, if possible, or, if not possible, by a distribution from a cash account. Attached hereto as Exhibit "A" is a list of assets and their valuation date and the distribution anticipated by the parties to this Agreement. The parties are owners of four bank accounts. Wife will retain her PNC checking account and Husband his PNC checking account. The parties will equally divide the joint PNC checking account and money market account upon the sale of the marital home. The parties intend an equal division of the bank accounts and will make any adjustment required to equalize that division. Nevertheless, the joint PNC checking account shall remain open receiving the incomes of the parties and accessed by the parties to pay their ongoing expenses until the sale of the marital home, or until Wife leaves the marital home. In the event Husband receives a refund of Social Security and Medicare taxes withheld from severance pay, he will provide to Wife one half of the amount of the refund. (8) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony 5 i pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Husband is represented by Carol J. Lindsay, Esquire and Wife has been advised that she may be represented by an attorney of her choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. The parties agree to equally share the costs associated with their divorce including the filing fees and the attorney's fees of each. After the entry of the Decree in Divorce, the parties will make any payments necessary, one to the other, in order to equalize their costs. (10) 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 full force and effect to the provisions of this Agreement. (11) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent 6 y of his or her separate income on the aforesaid joint returns. (12) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (15) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, 'r maintenance, alimony, alimony pendente life, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or Gaims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in 8 connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (17) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. 9 (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: ~_ Ant ony M. o <~ - GiaaA._ Susan A. Marmo io COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF On this, the )'d'ay o , 2007, before me, the undersigned officer personally appeared ANTHO ~ARMO, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. ~L) itle of Off I~TARIAL SEAL MERLEI~ J. MARMEWtA, M4TARY PUBLIC CARLISLE CUMBERLAI~ COUN11~ PA MY CQMMI~SION EXPIRES JI~IE 2418 COMMONWEALTH OF PENNSYLVANIA COUNTY OF (~,~u..~H ~ n ss On this, the d2l day of l'Ytc~ , 2007, before me, the undersigned officer personally appeared SUSAN A. MARMO, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. (SEAL) Title of Officer COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wanda Mae Myers, Notary Public _ MY~EDec.11 2010 Member. Pennsylvania Association of Notaries 11 Anthony and Susan Marmo -Assets equal distribution (as of 3/31107 & 4!17/07) Institution Account # type as of Total Tony Sue Real Property House Joint est $285,500 $142,750 $142,750 1996 J-30 Infiniti Joint X X 2002 1-351nfiniti Joint X X PNC Inves#ments PNC 84669281 Jt Ten WROS 3/31/07 $9,603 $4,802 $4,802 PNC 72462456 Jt Ten WROS 3/31/07 $283,175 $141,588 $141,588 sub total $292,778 $146,389 $146,3$9 Bonds US Gov 1-Bonds Joint 4/17107 $34,824 $17,412 $17,412 Joint total $fi13,102 $306,551 $306,551 Retirement Accounts Tony T. Rowe Price 530418500 IRA 4/17107 $276,000 $185,480 $90,520 (1) PNC 406885801RA 3/31/07 $9,914 $9,914 $0 Tvny sub total $285,914 $195,394 $90,520 Sue PNC-1 RA 64799201 IRA 3/31 /07 $51,140 $0 $51,140 Sharp Annuity 3131/07 $53,365 $0 $53,365 SERS 3/31/07 $370 $0 $370 Sue sub total $104,875 $104,875 Retirement total $390,789 $195,394 $195,395 Grand total $1,003,891 $501,945 $501,946 (1) $91,000 to be rolled over from Tony's T. Rowe Price IRA to Sue's PNC IRA. t~7 ~ Y ,J ° . ";'1 ,_. .,t ;» '--~ fi.-~T ; LL :}, ..~ - j~.~l t. .3 ~~ ~~. :.~ ~~ ~~ THONY M. MARMO, Plaintiff v. USAN A. MARMO, Defendant CIVIL ACTION -LAW NO. 07-2795 CIVIL IN DIVORCE PRAECIPE TO TRANSMIT RECORD o the Prothonotary: Kindly transmit the record, together with the following information, to the Court for ntry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Code. 2. Date and manner of service of the Complaint: Counsel for Defendant pted service of the Complaint on May 16, 2007. An Acceptance of Service was filed the Court on May 17, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code s executed: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA By Plaintiff: August 16, 2007 and filed with Prothonotary on August 17, 2007 By Defendant: August 16, 2007 and filed with Prothonotary on August 17, 2007 4. Related claims pending: The terms of the Property Settlement and partition Agreement dated May 21, 2007 are incorporated, but not merged, into the cree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was d: SAIDIS, FIAWER ~ LINDSAY ~~:~W 26 West High Street Carlisle, PA By Plaintiff: August 16, 2007 and filed with Prothonotary on August 17, 2007 By Defendant: August 16, 2007 and filed with Prothonotary on August 17, 2007 SAIDIS. Fl Carol J. Lindsay, s~ Supreme Court I 26 West High Street Carlisle, PA 17013 717-243-6222 ~"-, ~y q:1.. ._, ..T.3 ~-~... ' ' ~'~ ~ - ' ~ t 4 ~ ~ , ~ a.. , ~ ~ ; t r'i. ~ ~- ~ t" , i-`.: ; ; ~. r -, ) ` _ ~ V ~`.~ ~~ i N T'H E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ANTHONY M. MARMC~ ,, _.; VERSUS SUSAN A. MARMO 07-2795 NO. DECREE IN DIVORCE AND NOW, ~~ ',-~~~, IT IS ORDERED AND ANTHONY M. MARMO DECREED THAT PLAINTIFF, AND SUSAN A. MARMO DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF REC IN THIS ACTION FOR WHICH A F{NAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement dated May 21, 2007 are incorporated, but not merged, into this Decree in Divorce. BY TH E CQSU RT: ATTEST: ~ J, _._. PROTHONOTARY r _` ,,, :., ~. _~ co ~ ~ ~ -~ ~ •-