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HomeMy WebLinkAbout04-0887 ELIZABETH VINCETT -FOURLAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL DIVISION - LAW ; NO. 2004- f61 CIVIL TERM NICKOLAS G. FOURLAS, Defendant : IN DIVORCE 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 grounds 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 Prothonotary's Office at the 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, CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 ELIZABETH VINCETT -FOURLAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL DIVISION - LAW NICKOLAS G. FOURLAS, Defendant NO. 2004- CIVIL TERM IN DIVORCE COMPLAINT AND NOW comes Plaintiff, by her attorney John H, Broujos ofBroujos & Gilroy, P.C" and sets forth the following: I. Plaintiff is Elizabeth Vincett-Fourlas, who currently resides at 1355 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Nickolas G. Fourlas, who currently resides 818 N. West Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The parties were married on October 23, 1983 in Carlisle, Cumberland County, Pennsylvania, 5. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 6, 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. 7. In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. divorced from the Defendant. the Plaintiff be March I, 2004 \ \' Jo H. Broujos, ~ire No. 06268 ~At rney for Plaintiff BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 (717) 243-4574; Fax: (717) 243-8227 I verity that the statements made in this pleading 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: j -, -CJ If - )t! .LA' I~dfs-~~ ~~cett-Fourlas ~ r,.) ~. ..} (',J '. --,-'- . , "\- . ~ n -- --..\) ~ C) <J) - 0 ~ Q ~ ~ ~ t, J;;' -., ~ ~ '0 ~ c:'~ C), V' ELIZABETH VINCETT -FOURLAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL DIVISION - LAW NICKOLAS G. FOURLAS, Defendant : NO. 2004 - 887 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE I, John H. Broujos, Esquire, being duly sworn according to law, do depose and state that a copy of the Complaint and Notice to Plead filed in the above referenced matter was served on Defendant Nickolas G. Fourlas by U.S. First Class, Certified Mail, on March 2, 2004 at the address below. Copy of Return Receipt is attached, Nickolas G. Fourlas 818 N. West Street Carlisle, PA 17013 ~~ March 5, 2004 ohn . Broujos, Esquire No. 6268 At orney for Plaintiff BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 (717) 243-4574; FAX (717) 243-8227 Sworn and subscribed before me this S~ day of March, 2004, Left' l, (;;U)~ Notary Public Notarial Seal Bridget Ann Con:ornn, NotaJy Public Carlisle BOlO, Cumberland County My Commission Expires June 10, 2006 Member, PennsylvamaAssoclatlonolNolaIfes ,-- ,- .::'~;r', ~.:.--/-- ..,...~ (~:;. :7 ..::j -< , "'" = = .&- :x ". ;;0 I Ul ~ ~ ~~~ ~ --i :r: -r. 0:0 zO Om :;:-t ..:> -;0 :< :t':P ::l: w (.:> /\'"'<-'.1- c.vvd 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: D. Is delivery address different from item 11 If YES, enter delivery address below: .AJ', "'-/<-" la~ 6. p.,u.r{~> '8' I ff Jf. We.>T J-I C~ J,o/l J7 01] 3. Sen~ Type ~;ertified Mail o F~egistered o Insured Mail o Express Mail o Return Receipt for Merchandise DC,O,O, 4. Res,tricted Delivery? (Extra Fee) 2. Article Number (Copy from service label) loqq 3'f0z::> Daft ""OL PS Form 3811 , July 1999 Domestic Return Receipt o Agent o Addressee DYes o No DYes 10259S.0Q-M.0952 UNITED STATES POSTAL SERVICE III/II First~Clasli. Mail '. Postage & Fees Paid USPS Permit No. G~10 . Sender: Please print your name, address, and ZIP+4 in this box' ~ "" H. B r<>L'-Jo S. IIrouJoe a -UF, P.C. 4 NorIh Hanover allt Carl..... PA 17013 l .' .' 2,MAY 0'/- no; ~ 7;;'" AGREJ<:MENT {'Z-- ~ ~ THIS IS AN AGREEMENT made this ~daf ";;f May, 2006 by and between ELIZABETH VINCETT-FOURLAS of 1355 Zimmerman Road, Carlisle, PA 17013, hereinafter referred to as Wife, and NICKOLAS G. FOURLAS of 818 N. West Street, Carlisle, P A 17013, hereinafter referred to as Husband; WHEREAS A. Husband and Wife were married on October 23, 1983, in Camp Hill, Cumberland County, Pennsylvania; B. Husband and Wife have four children: George, age 21, born 7.28.84; Alethea, age 18, born 5.25.87; Kenneth, age 14, born 7.4,91; and Thomas, age 9, born 5,21.96; and C. Various differences have arisen between Husband and Wife, whereby they have been living separate and apart since August 27, 2003; and D. Husband and Wife have agreed to maintain separate and permanent domiciles and to live apart from each other; NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, Husband and Wife agree as follows: 1. REAL PROPERTY. Husband conveys to Wife all of his right, title, and interest in the marital home jointly owned by the parties, consisting of residence at 1355 Zimmerman Road, Monroe Township, Carlisle, Pennsylvania, deed to which is attached hereto as an exhibit and made a part hereof. Husband agrees to be responsible for all charges, mortgage payments, taxes and insurance as presently established. Wife agrees to refinance the home within 60 days from A?- the date of this Agreement and upon refinancing and settlement aflB Bate sf rl;,,<;,,~~ aeerec, at IV which time Wife will assume all obligations under her own mortgage. Both parties represent that &J there are no judgments, liens, notes, or other encumbrances of which they have knowledge relating to said property existing and recorded on the date of this Agreement and on the date of recording of the deed, confirmed by lien search at the time of recording of the deed. Wife agrees to indemnifY, save, and hold harmless Husband against any and all claims, causes of action, suits or litigation for money owed, damages, indirect or consequential, including legal fees, arising out of failure of Wife to so pay such liens and encumbrances. Copy of deed is attached. Husband will execute deed upon signing of this Agreement, to be held in escrow by attorney for Wife until final decree of divorce is signed by the Court, at which time the attorney shall deliver the deed to Wife, subject to final clean lien search; Husband in the meantime agreeing not to impose any impediment to the divorce and to sign a consent and any other document required to finalize the divorce, Wife agrees to record the deed on or shortly after decree in divorce is signed. 2. PERSONAL PROPERTY. Husband and Wife have agreed between themselves on distribution of personal property owned, each conveying to the other all of his or her right, title, and interest therein, Wife conveys to Husband all of her right, title, and interest in '98 Ford Taurus SW in Husband's name. Husband is responsible for arrangements and costs for transfer. Husband conveys to Wife all of his right, title, and interest in '90 or 2004 Ford Escape in Wife's name, Each party agrees to assume and to pay and to indemnify and hold harmless the other from any and all claims for the balances due to any lending institution for the vehicles. W~~ <t"-t.\t~ 3. CREDIT CARDS. TlJo., l'",li"" J",o.,U/Sl1;Le that Wife's father helped to pay off the credit card debt and Wife cancelled all the credit card accounts. Each party has had their own account and will indemnify, save, and hold harmless each other against any claims, causes of actions, or money owed, damages, indirect or consequential, including legal fees. arising from the failure of either party to violate this provision, agreeing to make full disclosure of all credit cards and debts at time of settlement. Wife warrants that there are no joint credit obligations for which Husband could be liable and ifthere are, she agrees to pay them. Husband will surrender all credit cards to wife, as follows: American Express card, Mastercard, Bon Ton, Discover. all other cards agreed to by each spouse, Each spouse will certify that the other has no otheI marital obljgfltions for which that spouse will b~ responsible. /l-'Lfa+h'.l1'> WJ'I\ CIPt;.(... '-ffA.l,. jt2in+- Wc()~ t:.V"Cc.U'f- au~' a~1U(..(- Each party is satisfied that that party has sufficient knowledge of the otller's assets. IE ~ 4. OTHER ASSETS. Husband and Wife each conveys his or her right, title, and interest in savings and checking accounts, life insurance, and pension programs in the name of the other spouse. 5. CUSTODY. Husband and Wife shall have shared legal custody. Mother has primary physical custody subject to reasonable visitation rights of Father. 6. TAX RETURNS. Husband and Wife will file separate tax returns for all levels of government. 7. RELEASE ON EQUITABLE DISTRIBUTION. Except as otherwise set forth herein, Husband and Wife each hereby releases the other from any and all claims, or demands arising out of the party's right to equitable distribution of personal and real property under Section 401 of the Divorce Code, or any rights or claims in the personal or real property in the possession of the other party arising under the law, 8. ALIMONY AND SUPPORT. Husband and Wife each hereby release the other from any and all claims, or demands for alimony or support, excluding child support, which claims or demands may be based on Section 501 of the Divorce Code or under any other provision of the law. 2 ,. .' 9. COUNSEL FEES. Husband and Wife each further releases the other from any and all claims or demands for counsel fees and expenses, which claims or demands may be based on Section 502 of the Divorce Code. 10. INDEMNIFICA nON FOR DEBTS. Neither Husband nor Wife shall contract or incur any debt or liability for which the party or his or her property or estate might be responsible and shall indemnify and save harmless the other party from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. 11. GENERAL RELEASES. Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A, All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. and dower; All rights of courtesy and dower and all claims or rights in the nature of courtesy 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: (I) 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; Q, 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: 3 , " 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. 12. 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. 13. Husband hereby agrees to execute all necessary documents, pleadings or affidavits in order that Wife may proceed with obtaining a no-fault divorce. 14. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. If any provisions of this Agreement are held to be invalid or unenforceable, all other provisions shall continue to be in full force and effect. 15. 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. 16. 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, 17. 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. 4 , .' 18. LEGAL COUNSEL. Husband and Wife each has had the opportunity to have legal counsel to represent each of them in the negotiation and preparation of this Agreement and has either been so represented or has voluntarily chosen not to be represented. Husband and Wife each has carefully read this Agreement and is completely aware, not only of its contents, but also of its legal effect. 19. This Agreement shall bind the parties hereto, their respective heirs, executors, and assigns. IN WITNESS WHEREOF, Husband and Wife hereto intending to be legally bound hereby have hereunto set their hands and seals the day and year first above written. WITNESS Eli >' 5 '. ' 0 ...., ~ "'" s~: c:~"} 0' 'l::'i' -..,'" ...... n:l "'" ff,fTI -< v, ~y c:> --/~; -;::) ::t: '.,J,t'J C.J OCn ._,1 ~-."" c.., '11 .-.,:'. cP '-< Elizabeth Vincett-Fourlas, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL DIVISION Nickolas G. Fourlas, Defendant NO. 2004-887 CIVIL TERM PRAFCIPE TO TRANSMIT RFCORD 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 S330l(c) JJ0l(J)(1) uftll" Divu,,,,, CuJ" (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: I J S Fir.! Ch.. C"rtifi"ci MHil MHr~h) )004 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by S330l(c) of the Divorce Code: by Plaintiff: MHY)~ )OO() ; by Defendant: MHY)() )OO() (b) (1) Date of execution of the affidavit required by S330l(d) of the Divorce Code: /44 (2) Date of filing and service of!he Plaintiff's affidavit upon the respondent: 4. Related claims pending: N()m~ 5. Complete either (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 of Plaintiff s Waiver of Notice in S330l(c) Divorce was filed with the Prothonotary: MHY IJO )OO() Date Defendant's Waiver of Notice in S330l(cioDivorce was filed with the Prothonotary: r-... ohn H. Broujos, Esquire 268 mey for 'PlaintifflDefendant BROUJOS & GILROY, p,c. 4 North Hanover Street Carlisle, P A 17013 Date: May 30, 2006 Q t~ ~::;.: ," "".' """ c.::I. a' :% -:;P(" ...<:. c..> o -0 - ..> Q, ~-n rnr:; -om -pc;:. , -) ~::'.~S.,..,: ~::t>'0 '~~ ~ tf? c..> ...0 F . ELIZABETH VINCETT -FOURLAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL DIVISION - LAW NICKOLAS G. FOURLAS, Defendant : NO. 2004 - 887 CIVIL TERM : IN DIVORCE PLAINTIFF'S COMBINED AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under 9 3301(c) of the Divorce Code was filed on March I, 2004, 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. I consent to the entry ofa final Decree of Divorce without notice, 4, 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. 5, I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy ofthe Decree will be sent to me immediately after it is filed with the Prothonotary. 6. I 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 veritY 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. 94904 relating to unsworn falsification to authorities. o ~:; ~"'~ ..,..) l'[i ri":i: -7 . 1.::;;, ,,', "'" = c:~ Cf' ~ ~ (,.;I Cl ~.~: \. .;'::". ,,:::..; -u :;!: (,.;I .' W 0:> ~ ~~ n1~ :gf7J ,~.S, ,....-,C_^' X~:~ .~~(~ "fr:,tl1 ~ '", ~ , , Date: .s /4:5'10(,. SAIDIS. FLOWER & LINDSAY ........'omIl:"YSoAT.1AW 26 West High Street Carlis\e,PA ELIZABETH VINCETT.FOURLAS, Plaintiff : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION - LAW : NO, 2004-887 CIVIL TERM v, NICKOLAS G. FOURLAS, Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under 93301 (c) of the Divorce Code was filed March 1, 2004, 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:D-J5 .0<.. ~..t ~ud'.- Nickolas G, Fourlas DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERII 3301 leI 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 Affidavit are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, 4904 relating to unsworn falsification to authorities, Date: 5 .a,5 - 6 (, ~~uA~~,L Nickolas G, Fourlas ~ 0 'C5 ~ c: = ::o-~.. a' -on~ :;!t. ~:rl qH.; ?'" -< -r1~ zr c.:> :nt( ':-'') <::) ';~(j '1/ -0 ~.-,-'i\ -j."O' ;;:;:--;.... ",...' ::% '~~B ~~: I Om r"C:: <.;? -"< 7~ - ..::~\ c.:> ~ '-<.. .s:> '"'" CL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELIZABETH VINCETT -FOURLAS, Plaintiff NO. 9>1/1. CIVIL 20 ~ v. ACTION IN DIVORCE NICKOLAS G. FOURLAS, Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 3tst day of M~ ,2006, hereby elects to retake and hereafter use her previous name of Elizab V mcett. ~~5-AM-~ ~ ature - Elizabeth Vincett-Fourlas) ~ d::~I- (Sign ure - Ehzabeth Vmcett) COMMONWEAL TH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the ::3 J 6-& day of appeared Elizabeth Vincett, within document, and ackno contained. , 2006, before me a Notary Public, personally wn to me to be the person whose name is subscribed to the edged that she executed the foregoing for the purpose therein IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. ~~~ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelly Brooks, Notary Public Cartisle Boro, Cumberland Counly My CommIe8ion Expil'tl Aug. 5, 2009 Member, Pennlytvanla AllooIatlon of Notarl.. I'-J = c.:;.::) ~ o 11 :;:i m:!:l r- -um ~;~6 ~~j ~~ 3rtl .,--1 .J> ::0 -< '- ~:.::: ....i~ I m :I; ~ N CXl ;I; ;I; Of. ;I; ;., ;., IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. ;I; ;I; ;., ;I; ELIZABETH VINCETT-FOURLAS L PLAINTIFF No. 2004 887 VERSUS NICKOLAS G. FOURLAS l DEFENDANT DECREE IN DIVORCE AND NOW, ~~'i ~ \ Sl"< 2006 , IT IS ORDERED AND DECREED THAT ELIZABETH VINCETT-FOURLAS , PLAI NTI FF, ;I; AND NICKOLAS G. FOURLAS , 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; ~N~. BY THE COURT: PROTHONOTARY ;I; ;I; ;I; ;1;;" ;I; ;I; ;I; ;I; Of. ;I; ;+; ;+; ;I; ;I; ;I; ;I; ;I; ;+; ;I; ;I; ;+; ;I; ;I; ;+; Of. J. ~ ~ ~ ~'*' ~It, ?(/'. 1/. ? ~'R!'? 'C~.,pv 'J(J-?"'l .; . ',"~' - J"',;'