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HomeMy WebLinkAbout08-54491.11 In the Court of Common Pleas of Cumberland County, Pennsylvania KARISSA D. ZERBE, ) VS. Plaintiff, 9 n , , L No. Qg- Silt/ tv? FJL? SETH D. ZERBE, CIVIL TERM 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 ground for 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: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania KARISSA D. ZERBE, Plaintiff, VS. No. C) ? ? Sy ? 1 ? ? v + l SETH D. ZERBE, CIVIL TERM Defendant. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Michael S. Travis Attorney at Law ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9509 mst@mtravislaw.com In the Court of Common Pleas of Cumberland County, Pennsylvania KARISSA D. ZERBE, Plaintiff, VS. No. U 5 Y 9 q Ct,?U-7Z SETH D. ZERBE, CIVIL TERM Defendant. IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by her attorney, Michael S. Travis, respectfully represents: 1. Plaintiff is Karissa D. Zerbe, who resides at 1013 Apache Trail, Mechanicsburg, Cumberland County, Pennsylvania, since June 14, 2008. 2. Defendant is Seth D. Zerbe who resides at 132 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania, since February 2008. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 10, 2005 at Shiremanstown, Cumberland County. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. 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. 9. Neither party is in the Military Service in the United States. 10. Plaintiff requests the court to enter a decree of divorce. 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. C.S. § 4904, relating to unsworn falsification to authorities. Date: ?af ) 0 0 Ga P--,) Attorney for Plaintiff I . D. # 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 arissa Aerbe, intiff Rsla o ,__. LQ N Co t'r'1 n w t k-l Lki cc 1 4 c.n 7.aw Gi cry 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, ) VS. ) No. 2008- 5449 SETH D. ZERBE, ) CIVIL TERM Defendant. ) IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT Counsel of record: Michael S. Travis, Esquire for Plaintiff 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 mst@mtravislaw.com 1 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this S?day of? to2008, by and between Seth D. Zerbe, (hereinafter referred to as "Husband,") and Karissa D. Zerbe, (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, that Husband and Wife were lawfully married September 10, 2005; and WHEREAS, there were no children born of this marriage; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; DEFINITIONS (a) Date of Execution of this Agreement. The phrase "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the parties if they each have executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. (b) Distribution Date. The phrase "distribution date" shall be defined as fourteen days following the entry of a final decree in divorce and the filing of Waivers of Appeals by each party. If the fourteenth day falls on a weekend or holiday, the distribution date shall be the next business date. 2. ADVICE OF COUNSEL The parties have had an opportunity to review the provisions of this Agreement with their respective counsel. Husband is represented by . Wife is represented by Michael S. Travis, Esquire. Husband and Wife acknowledge that this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full accounting of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purpose of this Agreement. Each party agrees that he or she shall not at any future time raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement with the exception of disclosure that may have been fraudulently withheld. 3. 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 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 as to the lawfulness or unlawfulness of the causes leading to their living apart. 4. 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 the agreement. Neither party shall molest the 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, follow, stalk, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. DIVISION OF PERSONAL PROPERTY Excepting the property described on Exhibit "A", the parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible marital property. Neither party shall make any claim to any other such items of marital property, or to the separate personal property of either party, which are now in the possession and/or under the control of the other. Wife shall be entitled to all items of personalty in the marital residence excepting those scheduled on Exhibit A. Financial Accounts. The parties have equally divided all joint checking, savings and other non-retirement accounts to their mutual satisfaction. The parties agree to retain their separate financial accounts. The parties agree to cooperate in transferring any title or document to accomplish the above distribution. Neither party will make further claim to any joint financial account following the distribution date of this Agreement. 6. SPOUSAL SUPPORT/ALIMONY PENDENTE LITE Neither party shall be entitled to spousal support or APL. 7. ALIMONY Wife and Husband represent and acknowledge that they each have sufficient property for her or his reasonable needs and are able to support herself or himself through appropriate employment and/or assets according to the standard of living which they are accustomed to and waive the right to receive alimony. 8. AUTOMOBILES The parties were the owners of two automobiles at separation, a 1999 Saturn, driven by Wife, and a 2001 Chevrolet Monte Carlo driven by Husband. The Saturn shall be the property of Wife. The Chevrolet shall be property of Husband. The Chevrolet is encumbered by purchase money loan, the Saturn is not. Husband shall be responsible for the purchase money loan on the Chevrolet. He agrees to indemnify and hold Wife harmless for that loan. Should any action be required to transfer title or other document of ownership, the parties will take steps to transfer and reflect ownership as soon as possible after the distribution date. Both parties agree to assume all responsibility and hold each other harmless for any and all liability, including insurance, costs and expenses associated with ownership of the above. The costs of any title transfers or fees shall be borne equally by the parties. 4 9. DIVISION OF REAL PROPERTY The parties were owners of real property located at 132 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania, containing a residential dwelling. The real estate is encumbered by a mortgage in favor of HSBC Mortgage Corp. in the approximate amount of $149,000. Both parties shall remain responsible for payment of the mortgage until sale. Within 45 days of the Execution Date of this Agreement, the parties shall list the residence for sale. The parties shall use a Realtor acceptable to both parties, and list the property at a price recommended by the Realtor. If no buyer is found for the property within 6 months, the parties agree to re-list the property for sale. The parties agree to accept a reasonable price of sale. Any profits after cost of sale shall be divided equally between the parties. Any deficiency will also be shared equally. Following the Execution Date of this Agreement, the parties agree to equally share any claims regarding the mortgage obligation. Husband shall pay any property maintenance, or upkeep expenses. Any unexpected costs such as mechanical repairs for furnace, plumbing or the like shall be equally shared. 10. PENSION, RETIREMENT ACCOUNTS, INVESTMENT AND SAVINGS ACCOUNTS At the time of separation, the parties were titled to the following retirement accounts. Composition of accounts (as of June 16, 2008) Husband: Pension/Retirement account: John Gross 401(k) $ (approx.) Wife: Pension/Retirement/401(k) account: none. Neither party shall make further claim to a retirement or financial account of the other party. 11. MEDICAL INSURANCE Neither party is required to maintain medical insurance coverage for the benefit of the other party following the entry of a Decree in Divorce. Husband shall notify his employer within 5 days of the signing of this Agreement to terminate Wife's insurance coverage. 5 12. MARITAL DEBTS (a) During the course of the marriage, the parties incurred the following joint obligations: Discover Card $3,500 (all approx) AT&T 5,500 Victorias Secret 181 Wife and Husband represent that they have taken all steps necessary to make sure that no credit cards or similar accounts exist which provide for joint liability. From the date of execution of this Agreement, each party shall use only those cards and accounts for which that party is individually liable. Wife shall assume, indemnify and hold Husband harmless for the AT&T account; Husband shall assume, indemnify and hold Wife harmless for the Discover card account. Miscellaneous: Wife signed for a viola lease with the Horn Hospital for Husband's niece, Gabrielle Zerbe. Husband shall make arrangements to assume this lease within 30 days of the Execution Date of this Agreement. He further agrees to indemnify and hold Wife harmless for this debt. (b) The parties have accumulated various debts during the marriage. Husband shall be solely responsible for the payment of any and all debt in his name. Wife shall be responsible for the payment of any and all debt in her name. Debts incurred solely in Husband's name(all values approx): Macy's $538.00, Goodyear $106. Wife: Bon Ton $343, Express $92, Member's 1 st, Target $800.00. (c) Since separation, neither party has contracted for any debts which the other will be responsible for and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. 13. FILING AND PAYMENT OF TAXES The parties agree to file separate income tax returns for the year a decree in divorce is entered. The parties represent that they have filed all income taxes for each year up to the year a Decree in Divorce is entered. The parties agree to indemnify and hold the other party harmless for any unfiled or due taxes individually. 14. DIVORCE The parties agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and allow to be filed the necessary documents to obtain a divorce under Section 3301(c) or 3301(d) of the Divorce Code. 15. DEATH PRIOR TO DIVORCE If either Husband or Wife dies before the entry of a final decree in divorce between the parties, this Agreement is deemed to survive the death, and the parties, heirs or assigns shall enter into the same status as after the Agreement was entered into. 16. INCORPORATION This agreement is to be incorporated for the purposes of enforcement, but not merged into any subsequent Decree in Divorce. 17. CONTINUED COOPERATION The parties agree that they will, after the execution of this Agreement, execute any and all written instruments, assignments, releases, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this Agreement. 18. COUNSEL FEES Except as otherwise provided for in this Agreement, each party shall be responsible for his or her own legal fees and expenses. 19. BREACH If either party breaches any provision of this Agreement, the other parry shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement or for seeking such other remedies or relief as may be available to him or her. 20. VOLUNTARY AGREEMENT The provisions of this Agreement are fully understood by both parties and each party acknowledges that the Agreement is fair and equitable; that it is being entered into voluntarily; and that it is not the result of any duress or undue influence. 21. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all 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 the estate of the other as a result of the marital relationship, including without limitation, dower, curtsey, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate. 22. BINDING EFFECT This Agreement shall be binding upon the parties' heirs, successors and assigns. 23. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formalities as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 24. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time of this Agreement are null and void and of no effect. 25. ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those 8 expressly set forth herein. 26. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall not have any binding effect whatsoever in determining the rights or obligations of the parties. 27. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, nd the yea first written above. Witness i Hess the parties set their hands and seals the day SepfiD_ We, Husband D. Zerbe, Commonwealth of Pennsylvania : : ss County of `6atL&j;,?n ; PERSONALLY APPEARED BEFORE ME, this eday of 200 a notary public, in and for the Commonwealth of Pennsylvania, Seth D. Zerbe, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. jM R W!N haft COQ Ism x.1 W Commonwealth of Pennsylvania : :ss Curnbon?c?? County of otary ublic PERSONALLY APPEARED BEFORE ME, this -E'day of 200 a notary public, in and for the Commonwealth of Pennsylvania, Karissa D. Zerbe, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that she executed the same for the purposes herein contained. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Hope A. Mattos, Notary Public Hampden Twp., Cumberland County My Commission Expires Oct. 11, 2008 Member. Pennsylvania Association Of Notaries '0?? ?? (Y\Ojjc?? Notary Public AM JAMW" tl"e ; vw Oro: EXHIBIT A If house is placed with real estate agent for liquidation, the following personal property items may be utilized as sales incentives. If the items are not used as sale incentives, they become the property of Husband. Lawn Mower Weed Whacker Washer and Dryer Basement Refrigerator Gas Grill Humidifier Personal Property items for Husband: Kitchen TV Kitchen appliances Dishes, pots and pans, knife set Patio table and chairs Ironing board and iron Dining room table and chairs Sweeper TV and Entertainment Cabinet Throw Carpets Coffee Table Leather Couch Stereo Unit Clothing Rack Bath and Bed accessories Bed mattress and spring set Black Bed, mattress and spring set Chinese pictures Personal Property items for Wife All "cherry" items throughout house Silverware Red trash canister Computer and Printer DVD unit Two Clothes Dressers Rocking chair Pie Safe Curio cabinet and contents Two round tables Chaise lounge Antique Civil War desk Cedar chest Dragon Chest Blanket Chest Coat rack Naughty chair Bookcase C7 tr ? rn r `> ON ?y? "ivfm In the Court of Common Pleas of Cumberland County, Pennsylvania KARISSA D. ZERBE, VS. Plaintiff, No. 2008-5449 SETH D. ZERBE, CIVIL TERM Defendant. IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. - lee4g - - Se (h D. rbe Date: q,/1 OS address: Ca•-?.P i-1 ? { l ?A- 17(.? J j -v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, VS. No. 2008-5449 SETH D. ZERBE, CIVIL TERM Defendant. IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, hereby elects to resume the prior surname of Karissa Dee Kerchner, and gives this written notice pursuant to the provisions of 54 P.S. § 704. Date: I U - a 3. Signature 13idjhature of name ein resumed COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUmYj/'?(1C? On th&?Y&y of , 2008, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. l. In Witness Whereof, I have hereunto s hand anM7 bQ?? Notary Public ;'-.A&AONWEALTH OF PFNNSYLV"1?' -;,; ,. NOTARIAL SEAL DENISE L. TRAVIS, Notary Public Hampden Twp., Cumberland County {' h7y Commissioi Expires Aprll 20-,-20'-1 c y , l?J ? Fr, i5 -sti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, ) VS. ) No. 2008-5449 SETH D. ZERBE, j CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on September 15, 2008. 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. 1 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 herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATED: ' KarXs a D. Kerch\ Karissa D. Zerbe (ma Plaintiff surname), C w t .. Fn cp CJ) 3:: 511'', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, ) VS. ) No. 2008-5449 SETH D. ZERBE, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on September 15, 2008. 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. 1 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 herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATED: - Z D C) 3, Defendant rri G rill IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, ) VS. ) No. 2008-5449 ) SETH D. ZERBE, ) CIVIL TERM Defendant. ) IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (q) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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. DATED: Plaintiff surname), cra ? y+ I 1"n -i i v !"'j C73 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, ) VS. ) No. 2008-5449 ) SETH D. ZERBE, ) CIVIL TERM Defendant. ) IN DIVORCE WAIVER OF NOTICE 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. 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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: I"L " 20 "C) 8 Defendant -j C3 m r! v? iv -7 T; C rr Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZERBE, Plaintiff, ) VS. ) No. 2008-5449 SETH D. ZERBE, ) CIVIL TERM Defendant. ) IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Service accepted by the Defendant on September 17, 2008. The Acceptance of Service was filed on September 22, 2008. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on December 21, 2008; by Defendant on December 20, 2008. 4. Related claims pending: None. Economic claims resolved by Marriage Settlement Agreement dated September 5, 2008. 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: December 29, 2008. Date Defendant's Waiver of Notice in § 3 ivorce was filed with the prothonotary: December 29, 2008. Wcdel S. Travis Attorney for Plaintiff rf? :..., rri IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KARISSA D. ZFRRF, V. SETH D. ZMRE • NO. 2008-5449 AND NOW, .Dez,., -lcr -?a , ze Q 8 . it is ordered and decreed that Karissa D. Zerbe , plaintiff, and .Seth D. zerbe , 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.") The Marriage Settlement Agreement slated September 5„2008 is incorporated but not merged into this Decree. By the Court, .1g-, -el -el 50, /1;