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HomeMy WebLinkAbout03-6439JASON J. JANCSE, Plaintiff JENNIFER D. JANCSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : iViL^C O -L^W NO: 3ttoL 1N DIVORCE/CUSTODY 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 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, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JASON J. JANCSE, Plaintiff JENNIFER D. JANCSE, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO: ~- ~,,~2~? : IN DIVORCE/CUSTODY COMPLAINT UNDER SECTION 3301(c) OF TItE DIVORCE CODE 1. Plaintiffis Jason J. Jancse, who currently resides at 1917 Reservoir Drive, Cumberland County, Carlisle, Pennsylvania, 17013 since 2000. 2. Defendant is Jennifer D. Jancse, who currently resides at 1917 Reservoir Drive, Cumberland County, Carlisle, Pennsylvania, 17013 since 2000. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 22, 1999, in Cumberland County, Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 requests the Court to enter a Decree in Divorce. 9. A Custody Complaint has been filed contemporaneously with this Complaint regarding the couple's children. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & BAYLEY Mark F. Bayley, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 87663 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. / ~ -' l ~ ~ Cb ~ Z/ason J. Jancs~/,~intiff COUNT I CUSTODY The plaimiff is Jason J. Jancse, residing at 1917 Reservoir Drive, Carlisle, Pennsylvania 17013. The defendant is Jennifer D. Jancse, residing at 1917 Reservoir Drive, Carlisle, Pennsylvania 17013. Plaintiff seeks custody of the following children: Name Present Residence DOB Age Joshua J. Jancse 1917 Reservoir Drive 10/26/97 6 years Carlisle, PA Jada L. Jancse 1917 Reservoir Drive 2/22/01 2 years Carlisle, PA The children were not bom out of wedlock The children are presently in the custody of Plaintiff and Defendant who resides at 1917 Reservoir, Cumberland County, Carlisle, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons Jason and Jennifer Jancse List All Addresses 39 Derbyshire Drive Carlisle, PA Dates 1997-1998 Jason and Jennifer Jancse 22 Coral Drive Carlisle, PA 1998-2000 Jason and Jennifer Jancse 1917 Reservoir Drive Carlisle, PA 2000-present The mother of the children is Jennifer L. Jancse, currently residing at 1917 Reservoir Drive, Carlisle, PA.. She is married. The father of the children is Jason J. Jancse, currently residing at 1917 Reservoir Drive, Carlisle. He is married. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons. Name Relationship Jennifer D. Jancse Wife Joshua J. Jancse Son Jada L. Jancse Daughter The relationship of defendant to the children is that of mother. the defendant currently resides with the following persons. Name Relationship Jason J. Jancse Husband Joshua Jancse Son Jada L. Jancse Daughter Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children and claims to have custody or visitation rights with respect to the children. The best interest and permanent welfare of the child wilt be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. ..~ /~' · l '~ -- [ --~ --~ ~'~ tiff_son J. Janc)~, Pl~fiff JOHN J. JANCSE PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO,UNIW, PENNSYLVANIA 03-6439 CIVIL ACTION LAW ~NN~ERD. JANCSE : ~CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, December 17, 2003 , upon con sideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 08, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be 'present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl~. FOR THE COURT. By: /s/ Hubert X. Gilroy, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilitie, s and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hear/rig or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FiND OUT WHERE YOU CAN GET LEGAL llELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JAN 2 7 2004 JOHN J. JANCSE, Plaintiff V JENNIFER D. JANCSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-6439 CIVIL : IN CUSTODY CO~TO~ER ! AND NOW, this ~ day of ~"~ ~, ,2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Jason J. Janese, and the mother, Jennifer D. Jancse, shall enjoy joint legal and joint physical custody with the minor children, Joshua J. Jancse, born October 26, 1997, and Jada L. Jancse, born February 22, 2001. 2. Physical custody shall be with the parties sharing physical custody equally pursuant to the schedule that the parties have arranged, which may he modified at times because of father's work schedule or for other reasons. However, the schedule the parties shall abide by shall be such that the parties generally equally share custody on a 50/50 relationship. 3. The parties shall also handle the schedule of physical custody such that they share or alternate holidays depending upon a schedule worked out between the parties. 4. Each party shall also be entitled to enjoy 2 weeks of uninterrupted custody during the summer months when the parties may exercise vacation. The parties shall advise each other at least 30 days in advance as to when they desire to exercise their vacation time, with the party who provides the first notice having preference for any specific time. 5. The parties shall exchange information with respect to phone numbers and addresses and the parties shall also advise the other parent in the event they are taking the minor children out of state over night. Both parents shall ensure that the children have appropriate child scats for purposes of transporting in automobiles. Additionally, neither party shall be under the influence of alcohol when transporting the children to such a degree that would render them incapable of safe driving. This order is entered pursuant to an agreement rcached by the parties at a custody conciliation conference. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the Custody Conciliator. CC: · ~ane Adams, Esquire ~fvIark F. Bayley, Esquire BY THE COURT, JASON J. JANCSE, Plaintiff V JENNIFER D. JANCSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : C1VIL ACTION - LAW : : NO. 03-6439 CIVIL : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Joshua J. Jancse, born October 26, 1997 and Jada L. Jancse, born February 22, 2001. A Conciliation Conference was held on January 23, 2004, with the following individuals in attendance: The father, John J. Jancse, with his council, Mark F. Bayley, Esquire, and the mother Jennifer D. Jancse, with her council, Jane Adams, Esquire. 3. The parties agree to the entry of an order and the form is attached. DATE MARTIAL SEP.4RA TION_4 GREEMENT THIS AGREEMENT, made this /.~/'~ day of ~ ~/~./~'a~/c~ ,2004 by ~d between Jason Jancse, hereina~er refe~ed to as "HUSBAND", ~d Jennifer Jancse, hereina~er refe~ed to as "WIFE." WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on May 22, 1999; and 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 and real and personal property; the settling: of all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and 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: The parties intend to maintain separate and permanent domiciles and to live apart fi.om each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. The parties have attempted to divide their matrimonial property in a manner that conforms to just and right standards, with due regard[ to the rights of each party. It is the intention of the parties that such division shall be: final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition or any property now owned and not specified herein or property hereafter acquired by the other. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to this agreement acknowledges and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of counsel of his or her own choosing or has voluntarily elected not to obtain counsel; B. Is fully and completely informed of the facts relating to the subject matter of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the raaking of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all his or her property, interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any natm:e for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all .joint and separate state and federal tax returns filed by or on behalf of both parties during the marriage. DEBTS: It is further mutually agreed by and between the parties that the debts of the parties existing as of the time of the execution of this agreement shall not be finally released or addressed by the foregoing agreement, and that any debts incurred by the parties after the execution of this agreement shall be the sole responsibility of the party incurring that obligation. REAL PROPERTY: The parties agree that HUSBAND shall retain exclusive possession and exclusive ownership interests in the marital residence, located at 1917 Reservoir Drive, Carlisle, PA 17013. HUSBAND shall bear the responsibility for maintaining timely payments on the mortgage, taxes and insurance on the marital residence. HUSBAND shall make every reasonable effort to refinance the parties' obligation regarding the marital residence in his name by January 1, 2005. WIFE shall relinquish any interest in the marital residence to HUSBAND by cooperating in signing off of the Deed and other related documents. As soon as the house is refinanced into the HUSBAND'S name. PERSONAL PROPERTY: WIFE shall retain sole possession of the 2002 Ford Windstar. HUSBAND shall maintain responsibility for making payments on the Windstar through August of 2004. Thereafter, WIFE shall maintain responsibility for making payments on the Windstar. Upon satisfaction of any outstanding loans on the vehicle, HUSBAND shall relinquish any interest in the vehicle to WIFE by cooperating in the signing of the vehicle title and any other related documents. All other personal property belonging to the parties has been separated to the parties' satisfaction at the date of this agreement. 10. INCOME TAX RETURNS: The parties shall file a joint income tax return for the tax year 2003, and shall divide equally any refund due therefrom. All future income tax returns will be filed separately and the parties will each retain any refund due to them. Each party shall be permitted to claim one (1) of the parties' children as a dependent for all tax purposes. 11. SUPPORT AND ALIMONY: Except as provided herein, both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be granted. 12. RETIREMENT ACCOUNTS: Both parties hereby waive and forego all interests in each other's retirement account. WIFE waives any interest in HUSBAND'S 401K account. 13. CASH PAYMENT: In consideration of the within agreement, HUSBAND shall pay to WIFE $17,000. A. Schedule o_~ment_s: In order to satisfi~ HUSBAND'S $17,000 obligation, HUSAND will provide to WIFE the sum of $7,000 at the end of February, 2004. HUSBAND shall provide to wife the balance of $10,000 on or before September I, 2004. If HUSBAND does not pay the $10,000 on September 1, 2004, HUSBAND will continue making payments on the 2002 Ford Windstar. 14. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each party may dispose of his or her property in a~ay way, and each party hereby waives and relinquishes any and ail rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or thc estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take the intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 15. _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. 16. VOLUNTARY EXECUTION: Both Parties fully understand the terms of this agreement and were given full opportunity to discuss said terms with their respective attorneys. Both parties agree that they are executing this agreement freely and voluntarily. Both parties acknowledge that it has been suggested to them that they review this agreement with independent legal counsel and have either done so or have voluntarily chosen not to do so. 17. ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 18. APPLICABLE LA__~W: This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 19. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 20. This agreement shall become effective immediately upon its execution by both parties. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. Date Date Jffson Jancse / / Jennifer Jancs~ .... I .... Date Wi~ss c/T Sworn or affirmed to and acknowledged before me, this ,//rt~i day of /r~ ?~'~ ,2004. (SEAL) ~'Fo~tary Public) & ~ JASON J. JANCSE, Plaintiff JENNIFER D. JANCSE, Defendant IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO: 03-6439 CIVIL TERM · IN DIVORCE/CUSTODY JASON J. JANCSE, Plaintiff V. JENNIFER D. JANCSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLANID COUNTY, PENNSYLVANIA : CIVIL ACTION'- LAW :NO: 03-6439 CIVILTERM : IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 12, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 FALSIFICATION TO AUTHORITIES. ~-//-~ Date ,/o'ASON J. ;JA~NC~E. JASON J. JANCSE, Plaintiff JENNIFER D. JANCSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW 'NO: 03-6439 CIVIL TERM · IN DIVORCE/CUSTODY WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER~ § 3301{c) OF THE DIVORCE CODF 1. I consent to the entry of a final Decree of Divome 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 Cour~ 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 THE FOREGOING 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 FALSIFICATION TO AUTHORITIES. Date SON j. JASON J. JANCSE, Plaintiff JENNIFER D. JANCSE, Defendant · IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · NO: 03-6439 CIVIL TERM 'IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 12, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Diivorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN ']-HE FOREGOING 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 FALSIFICATION TO AUTHORITIES. Date JASON J. JANCSE, Plaintiff JENNIFER D. JANCSE, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW :NO: 03-6439 CIVIL TERM :IN DIVORCE/CUSTODY WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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 'THE FOREGOING 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 FALSIFICATION TO AUTHORITIES. Date JEI~NIFER D. JANCSEv r-- JASON J. JANCSE, Plaintiff V4 JENNIFER D. JANCSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL ACTION - LAW NO: 03-6439 CIVIL TERM IN DIVORCE/CUSTODY PRAECIPE TO TRANSMIT RE,CORn TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. Date and manner of service of the Complaint: December 30, 2003 was served on Defendant by Certified, Return Receipt Requested and Restricted Delivery U.S. Mail. Date of execution of the affidavit of consent required by § 3301 (c) or The Divorce Code: by the Plaintiff March 11, 2004; by the Det~ndant March 11, 2004. Related claims pending: None Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: March 18, 20(}4. Date: March 18, 2004 155 South Hanover Street Carlisle, PA ][7013 (717) 241-6070 Supreme Court ID No. 87663 INTHE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE Of ~~~ PENNA. Jason J. Jancse VERSUS Jennifer D. Jancse NO. 03-6439 Civil DECREE IN DIVORCE AND NOW,~ DECREED THAT Jason J. Jancse lt IS ORDERED AND __, PLAINTIFF, AND Jennifer D. Jancse ,DEFENDANT, ARE DIVORCED FROM ThE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE fOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; A marital settlement agreement is, attached hereto but not merged with the divorce decree, PROTHONOTARY