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HomeMy WebLinkAbout08-4876f F:\DOCS\FL\DIV\Hegedus,La3zlo-3301(c) complaint & verification.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF LASZLO HEGEDUS, Plaintiff V. PATRICIA A. HEGEDUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. O?- y??? c! ftl? CIVIL ACTION - LAW 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 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 Courthouse, Carlisle, PA 17013. 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. MidPenn Legal Services 401 East Louther Street Suite 103 Carlisle, PA 17013 Telephone: (717) 243-9400 ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF LASZLO HEGEDUS, Plaintiff V. PATRICIA A. HEGEDUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 8'- y?7G cave I tU CIVIL ACTION - LAW IN DIVORCE 0 T ?orc.e- COMPLAINT 1. The Plaintiff in this action is LASZLO HEGEDUS, an adult individual, who currently resides at 1450 Pines Road, Etters, Pennsylvania, 17319. 2. The Defendant in this action is PATRICIA A. HEGEDUS, an adult individual, who currently resides at 72 Mall Road, Etters, Pennsylvania, 17319. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on October 6, 1984, in New Cumberland, Cumberland County, 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 Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that two children, CRISTI LAUREN HEGEDUS, and ADAM KYLE HEGEDUS, both adult children, have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. STONE LaFAVER & SLETSKI By l' Elizab Su m 4 Rr New C Tel h L 1 C , Mb k-j U1tC n. J t D # 60251 Koour ge treet, P.O. Box E land, PA 17070 e 717-774-7435 orneys for Plaintiff Dated: 2- E?? V E R I F I C A T I O N LASZLO HEGEDUS states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. 11? / LASZ aEG DUS Date: W ? a A W l U? n C1 w r_ 73 0 W M ?Gyw' T? AGREEMENT po _-, {?, THIS AGREEMENT, made this Say of -JL4k-*-_, 2010, by and between LASZLO HEGEDUS, of York County, Pennsylvania, (hereinafter referred to as "Husband"), and PATRICIA A. HEGEDUS, of York County, Pennsylvania, (hereinafter referred to as "Wife"); WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 6, 1984, in New Cumberland, Cumberland County, Pennsylvania; and WHEREAS, two children has been born of this marriage both of which have reached the age of majority and are fully emancipated and not a party to this agreement; WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. -1- NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. Disclosure of Assets. Each party asserts that he or she has made a full and fair disclosure of all of the real and personal property of any nature whatsoever belonging in any way to each of them of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each party, and of every other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. Advice of Counsel. Husband has been represented by Elizabeth B. Stone, Esquire who has drafted this legal document. Wife has been represented by Timothy J. Colgan, Esquire. This agreement has been fully explained to Husband and Wife by their respective attorneys. Each party acknowledges by their signature of this document that each has carefully read this agreement and is completely aware, not only of its contents, but also of its legal effect. 3. Lawfulness of Senaratlon. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 4. Freedom from Interference. Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the ?"2" other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. Release of Claims. Wife and Husband each do hereby mutually remise, release, quit-claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which Wife and Husband may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the execution of this agreement a full, complete and general release with respect to any and all property of any kind or nature, real, -3- personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 6. Warranty as to Future Obligations. Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable, and that except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold the other party harmless from and against all future obligations of every kind incurred by them, including those for necessities. 7. Personal Property. Wife and Husband do hereby acknowledge that they have heretofore divided the marital property including, but without limitation, jewelry, clothes, furniture and other personalty and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. 8. Automobile to Husband. Husband shall be the sole owner, free and clear from any claim on the part of the Wife, of the 2007 Ford F150. If necessary, Wife shall deliver an executed certificate of title, sales and use tax form and any other documents necessary to convey title within ten days of a request from Husband. "4" 9. Automobile to Wife. Wife shall be the sole owner, free and clear from any claim on the part of the Husband, of the Volkswagen Jetta. If necessary, Husband shall deliver an executed certificate of title, sales and use tax form and any other documents necessary to convey title within ten days of a request from Wife. 10. Property Not Provided For. The parties hereto agree that they have, by the terms of this agreement, settled, to their mutual satisfaction, all rights that either may have in their property, whether owned by them jointly or separately, real and personal, and wheresoever situated. Any property not specifically provided for in this agreement, which the Husband or Wife owns or has the right to control or possess, shall be and remain his or her property, free and clear from any claim on the part of the other. 11. Real Estate Marital Home. Husband and Wife are the owners of real estate situate at 1450 Pines Road, Etters, York County, Pennsylvania (hereinafter "the marital home"). Husband shall retain the marital home as his sole and separate property. The parties acknowledge that they took out a mortgage with Citibank to pay off the balance on the Delaware home identified in paragraph 12 herein. The mortgage balance is approximately $65,000. Husband shall refinance this obligation or assume this obligation within 60 days of the execution of this agreement. Contemporaneous with the refinance or assumption, Wife shall sign a deed conveying all right, title and interest in and to the marital home to Husband. Said deed shall be prepared by counsel for Husband. Until such time as Husband refinances or assumes the mortgage on the marital home, Husband shall be responsible for all costs and expenses related to the home, including but not limited to, the mortgage, taxes, insurance, utilities, maintenance and upkeep on the property and -5- shall indemnify Wife and hold her harmless as to same. Husband shall be entitled to any and all deductions for income taxes or for other valid purposes not named herein. 12. Real Estate Delaware Home. Husband and Wife are the joint owners of real estate situate at 33279 Sassafras Court, Ocean View, Sussex County, Delaware (hereinafter "the Delaware home"). Wife shall retain the Delaware home as her sole and separate property. The parties acknowledge the Delaware home came from Wife's side of the family. There is currently no mortgage or any other lien on the Delaware home. Husband hereby agrees to convey, transfer and grant to Wife his right, title and interest in the Delaware home. From the equity in the Delaware home, Wife shall pay Husband the sum of $20,000.00 within 60 days of the execution of this Agreement. Contemporaneous with and in consideration for Wife's payment to Husband pursuant to this paragraph, Husband shall sign a deed conveying all right, title and interest in and to the Delaware home to Wife. Preparation of said deed shall be Wife's responsibility. Wife shall be responsible for all costs and expenses related to the Delaware home, including but not limited to, the mortgage, taxes, insurance, utilities, maintenance and upkeep on the property and shall indemnify Husband and hold him harmless as to same. Wife shall be entitled to any and all deductions for income taxes or for other valid purposes not named herein. Additionally, Wife shall pay to Husband the sum of $10,000.00 payable in $1,000.00 annual installments as additional equitable distribution. The annual payment shall be suspended and forgiven based upon Husband's ability to use the property for no more than 50 days per calendar year with adequate notice to Wife and permission from Wife. Husband's use shall not be for more than seven (7) consecutive days. Upon the expiration of 10 years from the date of -6- this Agreement or upon Wife's relocation to the Delaware home as her primary residence, Husband's right to use the property shall permanently cease. In the event Wife relocates to the Delaware home as her principal residence, any amount still due and owing on the $10,000.00 additional equitable distribution identified herein shall be due and payable to Husband within 60 days of Wife's relocation to the Delaware home. 14. Spousal Support/Alimony Pendente LitelAllmonv. The parties acknowledge that by this Agreement they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources for their comfort, maintenance and support. Therefore, except for the provisions of this Agreement, the parties hereby expressly waive, discharge, give up and release any and all rights and claims which they may now or hereafter have by reason of the parties' marriage, separation or divorce to alimony, alimony pendente lite, support or maintenance. From the date of this Agreement, it shall be the sole responsibility of each party to sustain himself or herself without seeking any support from the other. 15. Pensions and Retirement. The parties are each the owner of retirement benefits. Husband has retirement benefits through his employment with Gannett Flemming. Husband shall become the sole and separate owner of these retirement benefits, free of all claim of right, title or interest by Wife. Wife has retirement benefits as a result of her employment with the Commonwealth of Pennsylvania. Wife shall become the sole and separate owner of these retirement benefits, free of all claim of right, title or interest by Husband. - 7w Both parties agree to sign any and all documentation required to give effect to this provision within ten (10) days of a request by the other party. 16. T Mae. The parties agree that they shall file their 2009 income tax returns in such a way as to maximize the tax benefit and minimize the tax liability to both of them. The parties have previously filed joint Federal and State tax returns. They agree that in the event any deficiency in Federal, State or local income tax is proposed, or any 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. To the extent that a deficiency is the result of an error and not as the result of misrepresentation or failure to disclose the nature and extent of income as aforementioned, the parties will share any such tax, interest, penalty or expense in proportion to their incomes as of the year in question. IT Medical Insurance. Each party to be responsible for their own medical insurance. 18. Debts of the uarties. By date of this agreement, the parties agree that any debt incurred post-separation shall be their own individual debt and agree to indemnify the other should any action to recover be instituted against the other for non-payment. 19. Payment of Attorney Fees. Each party of this agreement hereby agrees that each of them will be solely responsible for the full payment of all attorney's fees and other costs heretofore and hereafter incurred, respectively, by each of them in connection with the negotiation, preparation, and execution of this agreement, and in connection with any action commenced by either party with respect to the divorce of the parties. Each party further agrees -8- hereby to indemnify and hold the other party harmless from any demand, claim, loss, cost and expense (including additional attorney's fees) arising from a failure to pay all of the aforesaid attorney's fees and other costs. 20. Ltibrmed and Voluntary Execution. Each party to this agreement acknowledges and declares that he or she, respectively: A. Is fully and completely informed as to the facts relating to the subject matter of this agreement and as to the rights and liabilities of both parties. B. Enters into this agreement voluntarily after receiving the advice of independent counsel, free from fraud, undue influence, coercion or duress of any kind. C. Has given careful and mature thought to the making of this agreement. D. Has carefully read each provision of this agreement. E. Fully and completely understands each provision of this agreement. 21. Mutual Cooperation. The Husband and the Wife shall each concurrently herewith, or at any time hereafter on the demand of the other, execute any other documents or instruments, and do or cause to be done any other acts and things as may be necessary or convenient to cant' out the intents and purposes of this agreement. 22. Severability. If any provision in this agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired in invalidated in any way. 23. Reconciliation. If there should be a reconciliation of the parties after the date of execution of this agreement, this agreement shall nevertheless continue in full force until it is -91 modified or abrogated by another written instrument to that effect signed by each of the parties hereto. 24. Waiver of Rights. Each of the parties hereby irrevocably waive all rights which he or she may have to request any court to equitably distribute the marital property of the parties or to have alimony, alimony pendente lite or counsel fees awarded to either party, it being the express intention of the parties hereto to fully settle all claims which they have with respect to each other in this agreement. Each of the parties further agree to consent to the entry of a Decree in Divorce. 25. Waiver of Breach. The waiver of any term, condition, clause or provision of this agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this agreement. 26. Survival of Agreement. If any term, condition, clause or provision of this agreement shall, by its reasonable interpretation, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the parties hereto, said term or terms, condition or conditions, clause or clauses, provision or provisions, shall be so construed, being the express intention of both parties hereto to have this agreement govern their relationship now or hereafter, irrespective of their marital status. 27. Dispute Regarding the Agreement: In the event that a dispute arises as to a party's obligation pursuant to the terms of this Agreement, the parties agree to commit themselves to an effort at out of court resolution through mediation or through the collaborative law process prior to initiating court intervention. However, in the event those efforts should fail and one party is found to be in breach of the terms of this Agreement, the other party would have the right, at his -10" or her election, to seek damages for such breach or to seek such other and additional remedies as may be available to him or her. 28. Jurisdiction. This agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and both parties consent and agree to the jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania, on account of any suit or action brought with respect to this agreement or any provisions or matters referred to in any provisions thereof. 29. Agreement Bindinn on Parties and Heirs. This agreement shall be binding in all its terms, conditions, clauses and provisions of the parties hereto and their respective heirs, administrators, executors and assigns. 30. Hendim. The headings or captions preceding the paragraphs in this agreement are inserted for convenience of reference only and shall not be construed in interpreting this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year above ESQ. TIMOTHY I.-COLIrAN, ESQ. _11- COMMONWEALTH OF PENNSYLVANIA COUNTY OF Crn . ss. On this, the e day of 3ux? , 2010, before me, a Notary Public, the undersigned officer, personally appeared LASZLO HEGEDUS, known to me to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JENNIFER A. MEARKLE, Notary Public New Cumberland Boro. Cumberland Co. My Commission Expires July 7, 2012 /Notary Public COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF Vedk On this, the 141lay of UP-6- , 2010, before me, a Notary Public, the undersigned officer, personally appeared PATRICIA A. HEGEDUS, known to me to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. MA.,%-? No r COMMONWEALTH OF PENNSYLVANIA Notarial Seal Tmathy J. Colgan, Notary Public DllMxn Boro, York County My Commission Bores Oct 3, 2010 Member, Pennsylvania Association of Notaries -12' ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF Pit-!.v4 i t THc" PPOTP ? IJK ARY 2010 JUN 23 PM 2: ZU EUVlkri "4U- G:- OWN PE NNSYt Y iA, LASZLO HEGEDUS, Plaintiff V. PATRICIA A. HEGEDUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4876 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT l . A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 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: to - By: LAS ,L H GEDU S, Plaintiff ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF FILED-4, Fir,, THE PRO i -AKXARY 2010 JUN 23 Pill 2. 19 CUMBHH'A L) t;k? PENNSYLVANA. LASZLO HEGEDUS, Plaintiff V. PATRICIA A. HEGEDUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-4876 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 this 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: 4- S-10. -- - By: _ LASZL DUS, Plaintiff LASZLO HEGEDUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-4876 PATRICIA A. HEGEDUS, Defendant CIVIL ACTION - DIVORCE o AFFIDAVIT OF CONSENT N ti w 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed uga t I rV "SA 2008. rz C 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 1E- ?. ? Date Patricia A. Hegedus Defendant LASZLO HEGEDUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-4876 PATRICIA A. HEGEDUS, Defendant CIVIL ACTION -DIVORCE Q _ C WAIVER OF NOTICE OF INTENTION TO RE UES - ?R N ENTRY OF A DIVORCE DECREE UNDER w SECTION 3301(c) OF THE DIVORCE CODE ; 1. I consent to the entry of a final decree of divorce without notice. , 0 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. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. G-*.J ? Date Patricia A. Heg Defendant iCN ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF 7-11 2010.x. i r a LASZLO HEGEDUS, Plaintiff V. PATRICIA A. HEGEDUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4876 CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Timothy J. Colgan, Esquire, Attorney for Patricia A. Hegedus, Defendant, in the above captioned matter, accepted service of a copy of the Complaint in Divorce filed on August 14, 2008, to the above term and number on or about September 3, 2008. t? Timothy J. Co gan, squire, Attorney for Patricia A. Hegedus, Defendant LASZLO HEGEDUS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-4876 t , PATRICIA A. HEGEDUS, Defendant CIVIL ACTION -DIVORCE r PRAECIPE TO TRANSMIT RECORD 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 Section 3301(c). 2. Date and manner of service of the Complaint: The Defendant Accented Service of the Complaint on or about September 3, 2008, said Acceptance of Service was filed with this Honorable Court on July 26, 2010. 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. June 15, 2010 . By Defendant: June 15, 2010. (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: N/A. 4. Related claims pending: All related claims were settled by a Marital Settlement A¢reement dated June 15, 2010, and filed with the Court on June 23, 2010 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 Plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 23. 2010; Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 23, 2010. Date: ? 2G 10 T By: ?- Timothy J. Colgan, Esquire Supreme Court I.D. #77944 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 502-5000 (Attorney for Defendant) IN THE COURT OF COMMON PLEAS OF LASZLO HEGEDUS :CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICIA A. HEGEDUS 2008-4876 NO. DIVORCE DECREE AND NOW, G~~ quJ ~ -3 02~ `~ , it is ordered and decreed that LASZLO HEGEDUS plaintiff, and PATRICIA A. HEGEDUS ,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.") All related claims were settled by written Marital Settlement Agreement dated June 15, 2010, and filed with the Court on June 23, 2010. By the Court, Attest: ~ Prothonotary s ~ N ~ io c~-a. c~p~ nom.; ~ ~d $ • ~i • !o its-h ~., mc~.~ led -~o -}~ ~ ~'~- ~'''''~ C~`~,"