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HomeMy WebLinkAbout07-6128KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 60y CIVIL TERM CIVIL ACTION-LAW 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 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, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - f a? CIVIL TERM CIVIL ACTION-LAW DIVORCE COMPLAINT 1. Plaintiff is Kellie L. Diodato, an adult individual who currently resides at 912 Burr Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Robert M. Diodato, an adult individual who currently resides at 205 Yellow Breeches Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 1994 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. COUNT II -EQUITABLE DISTRIBUTION Ii 8. Plaintiff hereby incorporates by reference paragraphs 1 through 7 above. l Ii 9. The parties have acquired real estate, personal property, including ii automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: 10 (1.:)1 Michael A. Scherer, Esquire I. D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff • VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: 0 d, Ind, 2007 Kellie L. Diodato 64 21 a - c -5 U = ?p vn c ? KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6128 CIVIL TERM CIVIL ACTION-LAW PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint filed in the above-captioned matter on October 18, 2007. Respectfully Submitted, O'BRIEN, BARIC & SCHERER g k4' ?? L'^ - Michael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dirldomesticld iodato/reinstate.pra 0 ???` b ? ?'a ? ?'?` ` ?a v. '? ,`j`_ cri ?? ?,? c.} SHERIFF'S RETURN - REGULAR CASE NO: 2007-06128 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DIODATO KELLIE L VS DIODATO ROBERT M NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon DIODATO ROBERT M the DEFENDANT , at 1420:00 HOURS, on the 20th day of February-, 2008 at 3 KEYSTONE DRIVE MECHANICSBURG, PA 17050 ROBERT M DIODATO by handing to a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.64 Postage .58 Surcharge 10.00 A x'10 P / ? 00 o 3 Sworn and Subscibed to before me this day So Answers: ,700,0 R. Thomas Kline 02/21/2008 OBRIEN BARIC SCHERER By: Deputy Sheriff 0 f A. D. s? KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2007-6128 CIVIL TERM IN DIVORCE PRAECIPE Please enter my appearance on behalf of ROBERT M. DIODATO, Defendant in the above captioned matter. SAIDIS, FLOWER & LINDSAY Carol J. Lindsey, quire Supreme Co rt ID o. 44693 26 West High reet Carlisle, PA 17013 717-243-6222 SAIDIS, FLONVER & LINDSAY nrrowvetsnruw 26 West High Street Carlisle, PA Dated: ?J C: CERTIFICATE OF SERVICE On this J-- day of December, 2008, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individuals, via first class mail, postage prepaid, addressed as follows: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 SAIDIS, FLOWER & LINDSAY Carol J.`Lindsa , s uire Supreme Court I o. 44693 26 West High S et Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER & LINDSAY nt'toerffts•?•uw 26 West High Street Carlisle, PA f77 . 14:43 7172436510 SAIDIS FLOWER R LIND PAGE 01/01 KELLIE L. DIODATO, ?!-? T; ,, 4URT OF COMMN PLEAS Plaintiff CUJ RLAND COUNTY, ,ENNSYLVANIA 7009 APR - v_ : No 7-6128 CIVIL TER( ROBERT M. DIODATO,'=> Defendant DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce IC,ode was filed on October 18, 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. L4- -S T-0'1 Robert M. Diodato I consent to the entry of a final Decree of Divorce without notice. SAIDIS, LOWER & UNDSAY nrn . , ..m?tmv ZC• T+gh SCYCct Carlisle, PA 2. 1 understand that I may lo"e rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is grant6d. 3. I understand that I will not be divorced until a Divorce Del~ree 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 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 falsificatiok) to authorities. Date: L-1- 3 -L?IA Robert M. Diodato KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6128 CIVIL TERM CIVIL ACTION-LAW PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 18, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: C?:L Kellie L. Diodato LED- ..ty;3 s , Y 2009 APR 20 Phi Io 01 CE O ,;. FqT' KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-6128 CIVIL TERM IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this I ?? day of 2009, between KELLIE L. DIODATO, of 912 Burr Avenue, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Wife, and ROBERT M. DIODATO, of 205 West Yellow Breeches Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on May 21, 1994 in Cumberland County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania on October 18, 2007 to Number 2007- 6128, 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 to, all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. i 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: (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. Upon the execution of this Agreement, the parties shall execute and file Affidavits of Consent and Waivers of Notice, necessary to finalize said divorce. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 205 Yellow Breeches Road, Carlisle, Cumberland County, Pennsylvania. Husband presently resides in the marital home. The parties have listed the marital home for sale and will agree to any offer within 2% of the listing price. Further, in the event that the parties' real estate agent recommends a reduction in the sale of the house, the parties will follow his or her recommendation unless they agree to the contrary. Upon the sale of the marital home, the parties will pay off the first mortgage and home equity line of credit encumbering the marital home. The parties will also pay the usual costs of sale. From the net proceeds, Wife shall receive $10,600.00 and the balance of the proceeds shall be equally divided between the parties. In the event Husband can no longer afford the payment of the 2 mortgage and moves from the marital home, the parties will equally divide the mortage payment, the real estate taxes and insurance until the home can be sold. (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that in the course of their separation, they paid off approximately $4,500.00 for a Visa card and that there is no other debt which is 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 since the date of separation on July 4, 2006, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. 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. (5) 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 (10) 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. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Wife will retain the 2002 Honda which is not encumbered by a lien and Husband will retain the 2002 Chevrolet which is not encumbered by a lien. Husband will also retain a 1964 Ford replication vehicle and a camper titled in his name only. 3 (6) TANGIBLE PERSONAL PROPERTY: With the exception of those items of personal property in Husband's possession, which will be the sole and separate property of Wife, and which are listed on Exhibit "A" attached hereto, 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 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. (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. (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 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. Wife is represented by Michael A. Scherer, Esquire and Husband is represented by Carol J. Lindsay, Esquire. 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 4 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. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (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 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 5 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, maintenance, alimony, alimony pendente lite, 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 6 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 claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in 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; 1. 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 7 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. (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: elli E Diodato Robert M. Diodato 8 EXHIBIT "N' Household Items: Leather ottoman Vase with flower arrangement Treadmill Bow flex weight machine Glass sofa table Framed mirror Sony stereo 3 Speakers Sony CD player 2 Wooden stands LL Bean corner desk with printer stand Elephant stand Upright freezer Storage shelf Floor runner carpet Decorative church Salon equipment: Massage table Aesthetics work chair Microderm abrasion machine Aesthetics equipment station Aesthetics work chair 9 RED OF THE 2003 Ai R 2u Fi1 4: 0 j }i KELLIE L. DIODATO, Plaintiff V. ROBERT M. DIODATO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6128 CIVIL TERM CIVIL ACTION-LAW 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 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: The Sheriff of Cumberland County, Pennsylvania served Complaint upon Defendant on February 20, 2008. 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 April 10, 2009; and Defendant on April 3, 2009 B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 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: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER v Mic el A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 T THE 2009 APR 20 PM 4.0 1 KELLIE L. DIODATO V. ROBERT M. DIODATO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2007-6128 DIVORCE DECREE AND NOW, A»,_1 21,` zoo t , it is ordered and decreed that KELLIE L. DIODATO , plaintiff, and ROBERT M. DIODATO bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The parties Marital Settlement Agreement dated April 1, 2009 is incorporatbd but not merged herein as a final Order of Court. By the Court, 4-1 J. thonotary r{, a v9 cs)q? , ,?? \ a4 &444W 4 4k?lt?