HomeMy WebLinkAbout07-3341ABRAHAM LAW OFFICES
45 East Main Street, Hummelstown, PA 17036
(717) 566-9380
GINA K. DRAGOVICH : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 61- 330 C i v i I
TROY N. DRAGOVICH : CIVIL ACTION - LAW
Defendant : DIVORCE
NOTICE
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 in 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
Court Administrator, 0 Floor, Cumberland County Courthouse, Carlisle, Pennsylvania.
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:
Court Administrator
4`h Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
GINA K. DRAGOVICH : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 0 G 3 3 y l cw e
TROY N. DRAGOVICH : CIVIL ACTION - LAW
Defendant : DIVORCE
COMPLAINT
AND NOW, comes Plaintiff, Gina K. Dragovich, by and through her attorney, James W.
Abraham, Abraham Law Offices, Hummelstown, Pennsylvania and files the following:
COUNT I - NO-FAULT DIVORCE
(Pursuant to Section 3301(c))
1. Plaintiff, Gina K. Dragovich, is an adult individual who currently resides at 2709
Columbia Avenue, Camp Hill, Cumberland County, Pennsylvania.
2. Defendant, Troy N. Dragovich, is an adult individual who currently resides at 5019
Raven Wood Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 22, 1995 in Pittsburgh, Pennsylvania.
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. Plaintiff and Defendant are not members of the Armed Forces of the United States.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce
dissolving the marriage.
COUNT II - INDIGNITIES
9. Paragraphs 1 through 8 are incorporated herein by reference.
10. Defendant has caused such indignities against Plaintiff which has made life
burdensome and intolerable for Plaintiff, the innocent and injured spouse.
WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter a decree in
divorce dissolving the marriage.
COUNT III - EQUITABLE DISTRIBITION
11. Paragraphs 1 through 10 are incorporated herein by reference.
12. Plaintiff and Defendant have accumulated real and personal property and
other assets during the course of the marriage, which are marital property and marital assets; as
well as debts during the marriage which are marital debts.
13. Plaintiff is entitled to the fair and equitable distribution of Plaintiff s
equitable share of said property and assets in accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to equitably
distribute the marital property and debts hereto.
COUNT IV - ALIMONY, ALIMONY PENDENTE LITE,
COUNSEL FEES & COSTS
14. Paragraphs 1 through 13 are incorporated herein by reference.
15. Plaintiff s income and/or earning capacity through appropriate employment is
substantially and significantly less than Defendant's income and/or earning capacity and has
been substantially and significantly less throughout the marriage.
16. Plaintiff has insufficient funds to support herself in accordance with the standard of
living and station of life which the parties established during the marriage through appropriate
employment; and Defendant's substantially higher income enables Defendant to contribute to the
support and maintenance of Plaintiff and to pay alimony in accordance with the Divorce Code of
Pennsylvania.
17. Plaintiff is without sufficient funds to support herself and is unable to appropriately
maintain herself during the course of this litigation and the pendency of this action; and
Defendant's substantially higher income enables Defendant to pay alimony pendente lite to
Plaintiff in accordance with the Divorce Code of Pennsylvania.
18. Plaintiff is without sufficient funds to retain and/or continue to retain counsel
to represent her in this matter; and without competent counsel, Plaintiff cannot adequately
prosecute her claims against Defendant and adequately litigate her rights in this matter; and
Defendant's substantially higher income enables Defendant to pay Plaintiff s attorney fees and
costs of the litigation hereto.
WHEREFORE, Plaintiff respectfully requests Your Honorable Court to award Plaintiff
alimony, alimony pendente lite, attorney fees and costs.
Respectfully subn jXted:
James W. Abraham, Esq.
Abraham Law Offices
45 East Main Street
Hummelstown, PA 17036
(717) 566-9380
Attorney for Plaintiff,
Gina K. Dragovich
DATE: 6/6/07
VERIFICATION
I, (?; f KA- b if-A 6-() f ( C-# , the undersigned, hereby verify and
confirm that the foregoing document and the statements made therein are true and correct to the
best of my knowledge, information and belief. I further understand that any false statements
made herein are subject to the penalties of Title 18 Pa.C.S.A. Section 4904 relating to unworn
falsification to authorities.
DATE: lp - > '?
CERTIFICATE OF SERVICE
I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true
and correct copy of the foregoing document, by certified mail, upon the following person at the
following address on the date stated herein:
Troy N. Dragovich
5019 Raven Wood Road
Mechanicsburg, PA 17055
DATE: 6/6/07
James W. Abraham, Esquire
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GINA K. DRAGOVICH
Plaintiff
V.
TROY N. DRAGOVICH
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07 - 3341 CIVIL
: CIVIL ACTION - LAW
: DIVORCE
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this N/ day of , 2007, by and
between Gina K. Dragovich ("Wife"), of Camp Hill, Pennsylvania, and Troy N. Dragovich
("Husband"), of Mechanicsburg, Pennsylvania.
WITNESSETH
WHEREAS, the parties hereto are Husband and Wife, married on April 22, 1995 in
Pittsburgh, Pennsylvania. The parties are the parents of Nicholas Patrick Dragovich, born
December 1, 1997; Kayla Jean Dragovich, born March 5, 2000; and Cassie Lynn Dragovich, born
June 5, 2001.
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Husband and Wife to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of settling fully 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 of real and personal property, and the settling of any and all
claims and possible claims by one against the other or against their respective estates, as well as
any other matters related hereto.
NOW THEREFORE, in consideration of 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:
1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS:
This Agreement shall not be considered to affect or bar the right of Husband and Wife to an
absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to
such defense as may be available to either party. This Agreement is not intended to condone and
shall not be deemed to be a condonation on the part of either party hereto of any act or acts
on the part of the other party which have occasioned the disputes or unhappy differences which
may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault
divorce pursuant to the terms of Section 3301(c) of the Divorce Code of 1980, as amended February
12,1988.
2. 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. The parties agree that in the event of absolute divorce between them, they
shall nonetheless continue to be bound by all the terms of this Agreement.
3. DATE OF EXECUTION:
The "date of execution" or "execution date" of this Agreement shall be defined as the date
of execution by the party last executing this Agreement.
4. DISTRIBUTION DATE:
The transfer of property, funds and/or documents provided for herein shall only take place
on the "distribution date" which shall be defined as the date of execution of this Agreement, unless
otherwise specified herein.
5. CONSENT OF PARTIES/ADVICE OF COUNSEL:
Husband and Wife acknowledge that they fully understand the facts as to their legal rights
and obligations under this Agreement. Husband and Wife acknowledge and accept that this
Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and
voluntarily, and that the execution of this Agreement is not the result of any collusion or improper
or illegal agreement or agreements. Husband and Wife acknowledge that they have each had the
opportunity to have this Agreement reviewed by an attorney and/or have done so, prior to signing.
6. FINANCIAL DISCLOSURE:
The parties acknowledge, confirm and verify that each has relied on the substantial accuracy
of the financial disclosure of the other, except as set forth herein as an inducement to the execution
of this Agreement. In the event Husband or Wife has failed to disclose any information regarding
any marital asset and/or marital debt, the parties' reserve the right to equitable distribution of said
marital asset(s) and/or debt(s), even after the entry of a decree in divorce; and further reserve any
other rights which may arise from said non-disclosure, even after the entry of a decree in divorce.
7. PERSONAL PROPERTY:
Husband and Wife agree that Husband shall have and keep as his sole and separate
property, the 1997 Isuzu Rodeo and the 1967 Chevy Chevelle. Wife shall have and keep as her
sole and separate property the 2006 Chrysler Van. Husband and Wife shall be solely responsible
for any and all financial and legal obligations regarding their respective vehicles and shall
indemnify and hold the other harmless as to any default of their financial or legal obligations.
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Except as otherwise stated herein, Husband and Wife hereby acknowledge that they have
equitably divided all household furnishings and/or items, as well as all other personal property, to
their mutual satisfaction and neither party shall make a claim against the property as agreed upon
and/or in the other's possession.
8. REAL PROPERTY:
Husband and Wife hereby agree that the marital residence, located at 2709 Columbia
Avenue, Camp Hill, Pennsylvania, is marital property. Husband and Wife agree that said residence
shall be sold and the parties shall equally divide the net sales proceeds. The parties shall fully
cooperate with any and all requirements for purposes of selling the property, including but not
limited to, signing the deed. Pending said sale, Husband and Wife shall remain responsible for any
and all financial obligations as to the property, including but not limited to, payment of the
mortgage, utilities, taxes and insurance as the parties have done since separation.
9. PENSION AND RETIREMENT BENEFITS/FINANCIAL ACCOUNTS:
Husband and Wife shall forever waive any and all past, present or future, legal or equitable
interest in any pension and/or retirement benefits of the other, which either party may have now or
in the future; and neither party shall make any claim against the other's pension or retirement
benefits at any time
10. CHILD SUPPORT/ALIMONY:
Husband and Wife agree that Husband shall pay $1,000.00 per month in child support and
$500.00 per month in alimony, directly to Wife, for a total of $1,500.00 per month, which shall be
paid bi-monthly directly to Wife in the amount of $750.00 per payment on the 1s` and 15th of every
month. The alimony shall be paid for a period of five (5) years, which monthly payments shall
commence upon the date of signing of this Agreement. The alimony shall be non-modifiable as to
term and amount. Alimony shall otherwise terminate upon the re-marriage, death or cohabitation
of Wife. The child support is modifiable and each party reserves the right to modify the child
support amount and payment terms by agreement or through Domestic Relations. Husband shall
maintain medical insurance coverage for the children. Husband shall maintain medical insurance
coverage for Wife until the divorce is final.
11. AFTER ACQUIRED PROPERTY:
Each of the parties shall own and enjoy, independently of any claims or right of the other,
all items of personal property, tangible or intangible, and/or real property, acquired by him or her,
after the date of final separation, on or about March 6, 2007, with full power in him or her to
dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she
were unmarried.
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12. WIFE'S DEBTS:
Wife represents and warrants to Husband that since the date of final separation, on or about
March 6, 2007, she has not contracted or incurred any debt or liability for which Husband or his
estate might be responsible and Wife further represents and warrants to Husband that she will not
contract or incur any debt or liability after the execution of this Agreement for which Husband or
his estate might be responsible. Wife shall indemnify and save harmless Husband from any and all
claims or demands made against Husband by reason of debts or obligations incurred by Wife.
13. HUSBAND'S DEBTS:
Husband represents and warrants to Wife that since the date of final separation, on or about
March 6, 2007, he has not contracted or incurred any debt or liability for which Wife or her estate
might be responsible and Husband further represents and warrants to Wife that he will not contract
or incur any debt or liability after the execution of this Agreement for which Wife or her estate
might be responsible. Husband shall indemnify and save harmless Wife from any and all claims or
demands against Wife by reason of debts or obligations incurred by Husband.
14. WAIVER OF RIGHTS:
The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act
of 1980, as Amended February 12,1988, particularly the provisions for alimony, alimony pendente
lite, spousal support, equitable distribution of marital property, attorney fees and expenses. Both
parties agree that this Agreement shall conclusively provide for the distribution of property under
the said law and the parties hereby waive, release and forever relinquish any further rights they may
respectively have against the other for equitable distribution of marital property, attorney fees and
expenses.
15. PERSONAL RIGHTS:
Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall
be free from any control, restraint, interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried. They may reside at such place or places as they may
select. Each may, for his or her separate use or benefit, engage in any business, occupation,
profession or employment which to him or her may seem advisable. Husband and Wife shall not
molest, harass, disturb or malign each other or the respective families of each other nor compel or
attempt to compel the other to cohabitate or dwell by any means or in any manner whatsoever with
him or her.
16. MUTUAL RELEASE:
Except as otherwise stated in this Agreement, Husband and Wife each hereby mutually
remise, release, quitclaim and forever discharge the other and the estate of each other, for all time
to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or
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claims in or against the property (including income and gain from property hereafter accruing) of
the other or against the estate of each other, of whatever nature and wheresoever situate, which he
or she now has or may have at any time m the future.
Except as otherwise stated in this Agreement, Husband and Wife each hereby further
mutually remise, release, quitclaim, waive and forever discharge the other and the estate of each
other, for all time to come and for all purposes whatsoever, of and from any and all rights which
either party may have, or at any time hereafter have, for past, present or future equitable
distribution of marital property, attorney fees, costs or expenses, whether arising as a result of the
marital relation or otherwise, except, and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the breach of any
provision thereof.
It is 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.
ITWAIVER OR MODIFICATION TO BE IN WRITING:
A modification or waiver of any of the terms of this Agreement shall be effective only if in
writing, signed by both parties and executed with the same formality as this Agreement. No waiver
of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of
the same or similar nature.
18. MUTUAL COOPERATION:
Each party shall, at any time and from time to time hereafter, take any and all steps and
execute, acknowledge and deliver to the other party, any and all future instruments and/or
documents that the other party may reasonably require for that purpose of giving full force and
effect to the provisions of this Agreement.
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. AGREEMENT BINDING ON HEIRS:
This Agreement shall be binding and shall inure to the benefit of the parties hereto and their
respective legatees, devises, heirs, executors, administrators, successors and assigns in the interest
of the parties.
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21. OTHER DOCUMENTATION:
Wife and Husband covenant and agree that they will forthwith and within thirty (30) days
after demand or due date, execute any and all written instruments, assignments, releases,
satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or
desirable for the proper effectuation of this Agreement, and as their respective counsel
shall mutually agree, should be so executed in order to carry out fully and effectively the terms of
this Agreement.
22. 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 subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict performance of any other obligations
herein.
23. BREACH:
If either party breaches any provision of this Agreement, the other party shall have the
rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which
the party may have, and the party breaching this Agreement shall be responsible for payment of
attorney fees and all costs incurred by the other in enforcing his or her rights under this
Agreement.
24. SEVERABILITY:
If any term, condition, clause or provisions 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. Likewise, the failure of any party
to meet his or her obligations under any one or more of the provisions herein, with the exception of
the satisfaction of the conditions precedent, shall in no way avoid or alter the
remaining obligations of the parties.
25. LAW OF PENNSYLVANIA APPLICABLE:
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
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26. HEADINGS NOT PART OF AGREEMENT:
Any headings preceding the text of the several paragraphs/provisions and subparagraphs
hereof, are inserted solely for convenience of reference and shall not constitute a part of this
Agreement nor shall they affect its meaning, construction or effect.
27. DIVORCE:
The parties hereto agree that their marriage is irretrievably broken, and subsequent to the
filing of a Complaint in Divorce, both parties agree to enter into a mutual consent divorce under
Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended February 12,1988. The
parties further agree to sign the necessary documents, including the Affidavit of Consent and
Waiver, concurrently with the execution of this Agreement. This Agreement shall be incorporated,
but shall not merge, into the final decree in divorce.
WITNESS WHEREOF, the parties hereto, have set their hands and seals the day and year
first above written.
Witness:
A K. DRAGOVICH
TROY K. DRAGOVICH
7
COMMONWEALTH OF PENNSYLVANIA
( SS:
COUNTY OF Cc- u c.jr &4-r"C
On this -r741 day of , , 2007, before me, the
subscriber, a Notary Public, in and for the said Commonwealth and County, came the above-named
person, Gina K. Dragovich satisfactorily proven to me to be the person whose name is
subscribed to the within instrument and acknowledged that she executed the same for the purposes
stated herein contained and that such instrument may be filed and/or recorded.
WITNESS my hand d Notarial seal.
NOTARY PUBLIC
MY COMMISSION EXPIRES:
NWEWOPPE-NNSYLVANIA
and 1N Gamy H(I BAbmham, d County
My Gommles30, 2009
Member, Pennsylvania Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF 17U&4
SS:
On this day of , 2007, before me, the
subscriber, Notary Public, in and for the said Commonwealth and County, came the above-named
person, Troy N. DraLOylch ,satisfactorily proven to me to be the person whose name is subscribed
to the within instrument and acknowledged that he executed the same for the purpose herein
contained and that such instrument may be filed and/or recorded.
WITNESS my hand and Notarial Seal.
NOTARY L C
MY COMMISSION EXPIRES:
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Cathy L. Youngblood, Notary Public
Lemoyne Boro, Cumberland County
My Commission Expires June 22, 2010
Member, Pennsylvania Association of Notaries
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GINA K. DRAGOVICH : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 3341 CIVIL TERM
TROY N. DRAGOVICH : CIVIL ACTION - LAW
Defendant : DIVORCE
AFFIDAVIT OF SERVICE
I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, Gina K.
Dragovich, in the above-captioned action, hereby affirm that the Complaint in Divorce filed
herein, was served upon Defendant, Troy N. Dragovich, by certified mail on June 14, 2007, as
verified by the green return receipt card from the US Post Office, which is attached below:
¦ 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 back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
7m-6 /V. o'
S7> 144 vtr. C&OM 4 0.0
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A- Sig
E3 X Agent
t"I ressee
B. ?ved by (printed Name) C D g of livery
roc .1 cco,/ 1
D. Is deliverg address dif ifi- from Item 1 f ? VNes
if YES, enter delivery address below: A No
3. iService ype
UrCertifled Mail ? Express mail
? Reglstered ? Return Receipt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
7006 2150 0000 7635 3681
PS Form 3811, February 2w4 porrbsgc pegxn Receipt 10259"2-W1540
DATE: 12/12/07
James W. Abraham, Esquire
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GINA K. DRAGOVICH : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 3341 CIVIL
TROY N. DRAGOVICH : CIVIL ACTION - LAW
Defendant : DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 6,
2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of service and filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to
request entry of the Decree.
I verify that the statements made m the Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to
the unworn falsification to authorities.
DATE: -/1 //q/p? ' l -
TROY N. RAGOVICH, Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE UNDER SETION 3301(c) OF THE DIVORCE CODE
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 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.A. Section 4904, relating to the
unsworn falsification to authorities.
DATE: 11 f V21
TROY N. D GOVICH, WDefendant
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GINA K. DRAGOVICH : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 3341 CIVIL
TROY N. DRAGOVICH : CIVIL ACTION - LAW
Defendant : DIVORCE
AFFIDAVIT OF CONSENT
2007.
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 6,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of service and filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to
request entry of the Decree.
I verify that the statements made in the Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to
the unsworn falsification to authorities.
DATE:
INA K. DRAGOVIC Plaintiff
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE UNDER SETION 3301(c) OF THE DIVORCE CODE
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 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.A. Section 4904, relating to the
unsworn falsification to authorities.
DATE:
A K. DRAGOVICH, Plaintiff
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ABRAHAM LAW OFFICES
45 East Main Street, Hummelstown, PA 17036
(717) 566-9380
GINA K. DRAGOVICH : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 3341 CIVIL TERM
TROY N. DRAGOVICH : CIVIL ACTION - LAW
Defendant : DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the Record, together with the following information, to the Court for the entry
of a divorce decree:
1. Ground for Divorce: irretrievable breakdown under Section x 3301 c
( ) 3301(d)(1) of the Divorce Code.
2. Date and manner of service of the Complaint: June 14, 2007 by certified mail; see
attached Affidavit of Service.
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 Plaintiff on 12/5/07; and by Defendant on 11/19/07.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the
Divorce Code:
(2) Date of filing and service of plaintiff's affidavit upon the Defendant
4. Related claims pending: None pursuant to 11/19/07 Marital Settlement Agreement.
5. Complete either paragraph (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached:
(b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: 12/12/07.
(c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 12/12/07.
Respectfully sub itted:
James W. Abraham, Esquire
Abraham Law Offices
45 East Main Street
Hummelstown, PA 17036
(717) 566-9380
DATE: 12/12/07 Attorney for Plaintiff, Gina K. Dragovich
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
GINA K. DRAGOVICH
VERSUS
33 1/i
No. 07 3441- 2007
TROY N. DRAGOVICH
DECREE IN
DIVORCE
AND NOW, 2007
GINA K. DRAGOVICH
DECREED THAT
AND
TROY N. DRAGOVICH
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, IT IS ORDERED AND
, PLAINTIFF,
,DEFENDANT,
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;
The Marital Settlement Agreement, dated November 19,2007, attached hereto,
shall be incorporated, but shall not merge, into the
vorce.
I'ROTHONOTAHY
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