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HomeMy WebLinkAbout07-6649 SAIDIS, a uj1??'??'\I iA??7& LEMDSE?1 ATWF0WV5.AT uW 26 West High Street Carlisle, PA KRISHNAN R. RAJAGOPAL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. a 7- GG t19 Cuhf ??, MA.LOUEDJE TALINGTING RAJAGOPAL, 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, FLOWER & LIN Y. r, Carol J. Lin ay, squire Attorney Id. 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff C -.0 KRISHNAN R. RAJAGOPAL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. `?- G G y 4 MA.LOUEDJE TALINGTING RAJAGOPAL, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Krishnan R. Rajagopal, an adult individual, residing at 1228 Hillside Drive, Carlisle, Cumberland County, Pennsylvania since 2005. 2. The Defendant is Ma.Louedje Talingting Rajagopal, an adult individual, residing, upon information and belief, at 2196 Redwood Road, Hercules, California 94547 since October 4, 2007. 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 July 31, 2004 in the Surigao City, Philippines. 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 SAIDIS, FLOWER & LINDSAY ATIORVErWT uw 26 West High Street Carlisle, PA 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. COUNTI INDIGNITIES 8. The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 9. Defendant has offered to Plaintiff, an innocent and injured spouse, such indignities as to render Plaintiff's condition intolerable and his life burdensome. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY SAIDIS, LINDSAY ATIOBdkYSa-MW 26 West High Street Carlisle, PA Dated: Carol J. Lind- ay, quire Attorney Id. 44699 26 West Hig treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 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. Krishnan R. R 'agopal Date: 10, -,? / - O I SAIDIS, FLOWER &z LENDS" 26 West High Street Carlisle, PA G a ., C-)J KRISHNAN R. RAJAGOPAL, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 07-6649 MA.LOUEDJE TALINGTING RAJAGOPAL, Defendant : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY Please enter my appearance on behalf of the Defendant, Ma.Louedje Talingting Rajagopal, in the above-captioned matter. Date: t , r - (,.,- o-7 U?_? - Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street } 04%0- Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Defendant ?? " °-- f r) j .? ?. `?J f i -- ? ? - , ..? ` ?? `? KRISHNAN R. RAJAGOPAL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-6649 - CIVIL TERM MA.LOUEDJE TALINGTING RAJAGOPAL, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Mark F. Bayley, Esquire, counsel for Defendant, accept service of the Complaint in Divorce in the above-captioned matter and certify that I am authorized to do so. BAYLEY & MANGAN SAMIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA ?. r Date Mark F. Bayley, squire 17 West South Street Carlisle, PA 17013 Attorney for Defendant C'°) ?a ? + r_,,,, ? -, '??. ? ^? ?? r??s F °r? ; T-, ? `___t?i . ? ?.f ? KRISHNAN R. RAJAGOPAL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ?, NO. 07-6649 - CIVIL TERM MA.LOUEDJE TALINGTING rv ;? RAJAGOPAL, "- N Defendant IN DIVORCE fn AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on November 1, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand SA MILS, FLOWER & LINDSAY AT1QWqM-AT- 26 West High Street Carlisle, PA that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: 11 1t ho Krishnan R. Rajagopal BAYLEY & MANGAN Mark F. Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 KRISHNAN R. RAJAGOPAL, Plaintiff V. MA.LOUEDJE TALINGTING RAJAGOPAL, Defendant OF 714E F 07? ? 0TARY 2010 nAR -5 P11 3: 12 CUB;?; rC?il4 i'??r IVt f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 07-6649 : IN DIVORCE COUNTER-AFFIDAVIT UNDER 43301(d) OF THE DIVORCE CODE 1. Defendant does not oppose the entry of a divorce decree without notice. 2. Defendant does not wish to make any claims for economic relief. Defendant understands that she may lose rights concerning alimony, division of property, lawyer's fees or expenses if she does not claim them before a divorce is granted. Defendant understands that she will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to her counsel immediately after it is filed with the Prothonotary. I, Mark Bayley, Esquire, attorney for Defendant, after conducting sufficient investigation regarding the within averments, verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S §4904 relating to unsworn falisification to authorities Date: `? ( k F. Bayley, Esquire, Attorney for: Ma. Louedje Talingting Rajagopal, Defendant KRISHNAN R. RAJAGOPAL, Plaintiff V. MA. LOUEDJE TALINGTING RAJAGOPAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-6649 : IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the within document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Carol J. Lindsay, Esquire 26 West High Street Carlisle, PA 17013 Dated: F. Bayley, EEsquire. Attorney for Defendant KRISHNAN R. RAJAGOPAL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-6649 - CIVIL TERM MA.LOUEDJE TALINGTING RAJAGOPAL, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this (,?qL - day of 1d Q , 2007, between KRISHNAN R. RAJAGOPAL, of 1228 Hillside Drive, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband, and MA.LOUEDJE TALINGTING RAJAGOPAL, of 2196 Redwood Road, Hercules, California, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on July 31, 2004 in Suraigao City, Philippines; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, on November 1, 2007, to the above term and number; 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 lite, 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: 1 (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 believe that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. The parties agree that upon the request of the other, they will execute and file the necessary documents to finalize the divorce, including Affidavits of Consent and Waivers of Notice, after the expiration of ninety (90) days from the date of service of the Complaint and Husband will move for the entry of the divorce decree at that time. (3) REAL PROPERTY: The parties acknowledge and agree that there is no real estate which is jointly held by them, but that in the course of their marriage, Husband's daughter purchased a property in Indiana and that Husband is obligated on the mortgage, having paid $40,000.00 of marital funds, borrowed and liquidated from his retirement plan, in order to purchase the property. Wife waives any claims which she has in the property on which Husband is obligated in Indiana. With regard to any obligation of Husband for a mortgage in Indiana, he indemnifies and holds Wife harmless. (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: 2 i. Husband's Capital One credit card, with a balance of $5,544.63; ii. Husband's Account Central credit card, with a balance of $1,203.90; iii. Husband's Orchard Bank credit card, with an outstanding balance of $1,040.00; iv. Husband's American Express Delta card, with a balance of $2,691.00; V. Unknown obligations for Federal and state income tax for 2005 and 2006. Husband shall pay the obligations set out above by making timely monthly payments in at least the minimum amount required by the creditors until paid in full. With regard to all such obligations, Husband will indemnify and hold Wife harmless. B: Post Separation Debt: In the event that either parry contracted or incurred any debt since the date of separation on October 4, 2007, 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 parry 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: The parties acknowledge and agree that Husband drives a leased BMW and owns a 1995 Mercedes titled in his name. Those vehicles shall be his own separate property. Additionally, the parties are owners of a Mitsubishi Galant, registered in the Philippines. Said vehicle will be Wife's exclusive property. Within ten days of any request by Wife, Husband will execute any documents necessary to transfer to Wife all his right, title and interest in the Mitsubishi Galant. Husband shall be solely responsible for any encumbrances on the motor vehicles he is retaining and Wife will be responsible for the encumbrances on any motor 3 vehicles she is retaining and with regard to those each shall hold the other harmless and indemnify her from any loss. (6) 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 parry 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) ALIMONY: (A) Alimony: Husband agrees to pay to Wife as alimony the sum of $1,500.00 per month commencing the 30th day of November, 2007 and continuing in equal amounts on the same day of each subsequent month until the occurrence of one of the following: 1. The death of Wife 2. The death of Husband 3. The remarriage or cohabitation of Wife with a member of the opposite sex not within the degrees of consanguinity 4. The payment of the amount set out above for a period of 27 months from 4 the date of the first payment. The parties acknowledge that they know one another's Social Security Number. Alimony payments shall be deductible from Husband's gross income for the purpose of filing federal income tax returns and includible in Wife's gross income for the same purpose. The alimony payment set out herein shall be payable directly by Husband to Wife at the address set out on the first page of this Agreement or such other address as Wife shall advise Husband of in writing. In the event that Husband fails or refuses to make such payment in a timely manner, at Wife's request, the obligation may be payable to the Office of Domestic Relations of Cumberland County or the Office of Domestic Relations of a county having jurisdiction over Husband. Enforcement shall be by attachment of Husband's wages in that event. In the event that an overpayment in the amount of alimony is made, Wife will refund said overpayment to Husband within ten days of receipt and notice of its payment in error. (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 Mark Bayley, 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 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. 5 (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: A: The parties have heretofore filed joint Federal and State income tax returns for 2004. The parties have not filed joint Federal and State income tax returns for 2005 and 2006. Wife will cooperate with Husband in filing such joint returns, signing them within ten (10) days of their preparation. 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, for tax years 2004, 2005 and 2006, such tax, interest, penalty or expense shall be paid solely and entirely by Husband. B: Wife agrees, upon the request of Husband, to join in the filing of a 2007 joint Federal and Pennsylvania income tax return. Husband will pay the balance of the tax due on the return. Husband will bear the expense of preparing all joint tax returns. Any refunds due on the tax return shall be Husband's sole and exclusive property. (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. 6 (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 or demands whatsoever in law or in equity; 7 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. 8 (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. (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. This agreement shall be modified only upon the written agreement of both parties, and shall survive any reconciliation or attempted reconciliation of the parties. 9 i 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: r? K7RISHN JAG PAL ZA el- MA.LObQJE ALI N RAJAGOPAL 10 KRISHNAN R. RAJAGOPAL, Plaintiff V. MA.LOUEDJE TALINGTING RAJAGOPAL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-6649 - CIVIL TERM IN DIVORCE n c UEr G? z PRAECIPE TO TRANSMIT RECORD To the Prothonotary: N a -'G : 3} C7 cr; 'L v t, p x3 Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: Mark F. Bayley, Esquire, counsel for Defendant, accepted service of the Complaint on November 5, 2007. An Acceptance of Service was filed with the Court on November 7, 2007. 3. Date of the execution of the Affidavit required by Section 3301(d) of the Divorce Code: January 11, 2010; Date of filing and service of the Plaintiff's Affidavit upon the Respondent: January 21, 2010. 4. Related claims pending: None. Ill?i i ?I SAID S, FIA ? LEND anowEts• •uw 26 West Hig Street Carlisle, A III 5. Date and manner of service of the Notice of Intention to file Praecipe, a copy of which is attached: March 5, 2010 by regular mail to counsel. SAIDIS, FLQWER &LjNDSAY Carol J. Lindsay, E00-ire Supreme Co o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this 3) day of III 0h Ch , 2010, a true and correct copy of the foregoing document was served upon the party listed below, via First Class Mail, postage prepaid, addressed as follows: Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 II SAIDIS, FLOWER & LINDSAY Carol J. Lindsay, Esquire Supreme Court ID No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 v --- - -1 7A R Sz '` LIND AY A77 )RNEY5• •uw 26 West Hi Street Carlisle, A i I I KRISHNAN R. RAJAGOPAL V. MA.LOUEDJE TALINGTING RAJAGOPAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6649 DIVORCE DECREE / AND NOW, 1 ' 2-010 , it is ordered and decreed that KRISHNAN R. RAJAGOPAL , plaintiff, and MA.LOUEDJE TALINGTING RAJAGOPAL defendant, are divorced from the bonds of matrimony. 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.") NONE. (The terms of the attached Marital Settlement Agreement, dated November 6, 2007, are incorporated but not merged into this Decree in Divorce.) By the Court, Gl - 11--1- I d CAC4-. y.ly- ?o 1? n dso?. /Vcrt; c-p- uYN C5 4oi-0.t) mcL. ke-8 MOLA 14e_8 +C lol? +o 'may U ll)?W-6