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HomeMy WebLinkAbout01-6584IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BRUCE A. D~LITTLE, PLAINTIFF, Ve BONNIE L. DOOLITTLE, DEFENDANT, No. Civil Action--Divorce NOTICE TO DEFEND AND CLAIM OF 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. 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 2 LIBERTY AVENUE Carlisle, Pennsylvania 17101 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRUCE A. DOOLITTLE, PLAINTIFF, BONNIE L. DOOLITLE, DEFENDANT Civil Action---Divorce AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomare action con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulaminento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra pot cualquier otra queja o compensation reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la officina del Prothonotary, en la Cumberland County Court of Common Pleas, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL. HONORARIOS DEABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULIAMIENTO SEA EMITIDO. USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBELLEVAR ESTE PAPELA UN ABOGADO DE INMEDIATO SI NO TIENE O NO PUEDEPAGAR UN ABOGADO. VAYA O LLAME A LA OFFICINA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17101 (717) 249-3166 AVAILABILITY OF COUNSELING THE DIVORCE CODE OF PENNSYLVANIA REQUIRES THAT YOU BE NOTIFIED OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE IS SOUGHT UNDER ANY OF THE FOLLOWING GROUNDS: 23 Pa.C.S. & 3301(a)(6) .......Indignities 23 Pa.C.S. & 3301(c) ..........Irretrievable Breakdown; Mutual Consent 23 Pa.C.S. & 3301(d) ..........Irretrievable Breakdown; Two year separation where the court determines that there is a reasonable prospect of reconciliation. A list of marriage counselors is available in the Office of the Prothonotary Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. HAZLETT & OESTERLING Mechanicsburg, PA. 17055 (717) 790-0490 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRUCE A. DOOLITTLE, PLAINTIFF, VS. BONNIE L. DOOLITTLE, DEFENDANT, No. Otc& Sq Civil Action-mDivorce COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE 1. Plaintiff is Bruce A. Doolittle, an adult individual, sui juris and who currently resides at 19 East Main Street, Mechanicsburg, 17055 County of Cumberland, Commonwealth of Pennsylvania 2. Defendant, is Bonnie L. Doolittle, an adult individual, sui juris, who currently resides at 922 East Oak Street, Palmyra 17078 County of Lebanon, Commonwealth of Pennsylvania. JURISDICTION & VENUE 3. Plaintiff has been a resident of the Commonwealth of Pennsylvania for a period of more than 6 months. 4. The parties were married on the 16t~ day of January 1998, in Dauphin, Pennsylvania. 5. Neither the Plaintiff nor the Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of The Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or annulment instituted by either party against the other in this or any other jurisdiction. GROUNDS FOR DIVORCE COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (C) OF THE DIVORCE CODE. 7. The prior paragraphs are incorporated herein by reference. 8. The marriage between the Plaintiff and Defendant is irretrievably broken. After (90) days have elapsed from the date of the filing of this Complaint, plaintiff intends to file an affidavit consenting to a divorce. WHEREFORE, if the parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing and the serving of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to section 3301(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (D) OF THE 8. The prior paragraphs shall be incorporated herein as if fully set forth. 9. For the purposes of section 3301 (d) of the Divorce Code, the parties have been separated since October 15~ 2000. 10. The marriage is irretrievably broken. I 1. Plaintiff has been advised that counseling is available and that the plaintiff may have the fight to request that the court require the parties to participate in counseling. 12. In the event that consent from the defendant is forthcoming Plaintiff shall seek a unilateral divorce pursuant to and in conformity with section 3301 (d) of the Divorce Code subsequent to the filing of this Complaint upon the expiration of 2 years from the aforementioned date of separation if consent is not forthcoming pursuant to 3301 (C). 13. The parties do not have any biological children under the age of majority. WHEREFORE, if plaintiff request the Honorable Court to enter a Divorce Decree under section 3301 (d) upon the expiration of two (2) years from the aforementioned date of separation. HAZLETT & OESTERLING ATTORNEYS AT LAW Mechanicsburg, Pennsylvania 17055 (717) 790-0490 I verify that upon personal knowledge or information and belief that the statements made in this Complaint are tree 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: Plaintiff AMERICAN WITH DISABILITIE~q 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 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. BY THECOURT: Date: Je IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA BRUCE A. DOOLITTLE, PLAINTIFF VS. BONNIE L. DOOLITTLE, DEFENDANT Civil Action---Divorce Docket No. 01-6584 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 21st 2001, and served upon defendant on by way of an Acceptance of Service on 27th day of November 2001 and the same was executed by defendant on the ~ .~, day of ~2t,001. (Attached hereto). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have Elapsed from the date of service of the divorce Complaint. 3. I consent to the entry ofa fmal decree of divome. 4. I understand that I may lose fights concerning alimony, division of property, lawyers Fees or expenses ifI do not claim them before a divorce is granted. 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. Cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: Bruce A. Doolittle, ~laintiff IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY, COMMONWEALTH OF PENNSYLVANIA BRUCE A. DOOLITTLE, Plaintiff, BONNIE L. DOOL1TYLE, Defendant No. 2001-6584 Civil Action - Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DVORCE 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 txue and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: Bruce A. Doolittle, Plaintiff IN TIHg COURT OF COMMON PLEAS OF CAMERON COUNTY, COMMONWEALTH OF PENNSYLVANIA BONNIE L. DOOLITTLE, : Plaintiff, : : No. 2001-6584 .. V. : Civil Action - Divorce _. BRUCE A. DOOLITTLE, : Defendant : WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DVORCE DECR~ 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. Section 4904 relating to unsworn falsification to authorities. Date: Bonnie L. Doolittle, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA BRUCE A. DOOLITTLE, PLAINTIFF VS. BONNIE L. DOOLITTLE, DEFENDANT Civil Action--Divorce Docket No. 01-6584 AFFIDAVIT OF CONSENT 1. A complaint in divo~rce under Section 3301(c) of the Divorce Code was filed on November 21st 2001, and served upon defendant on by way of an Acceptance of Service on 27th day of November 2001 and the same was executed by defendant on the Iq .'~]2 , day of t~~2001. (Attached hereto). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have Elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers Fees or expenses ifI do not claim them before a divome is granted. 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. Cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: A/-//_ ~ ~._ Bonnie L. Doolittle Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA BRUCE A. DOOLITTLE : Plaintiff, : ._ BONNIE L. DOOLITTLE Defendant No .~ : Civil Action - Divorce ACCEPTANCE OF SERVICE I Bonnie L. Doolittle, accept service of the Complaint in Divorce, Notice to Defend and Notice of Availability of Counseling in the above-captioned matter. I acknowledge that I am the Defendant in said matter or that I am authorized to accept on behalf of the Defendant. Date { Bonnie L. Doolitfle, Defendant or Authorized Agent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Bruce A. Doolittle, : PLAINTIFF, : VS. : Bonnie L. Doolittle, : DEFENDANT, : Civil Action---Divorce Docket No. 01-6584 PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Please Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(C) of the Divorce Code. 2. The complaint in Divorce was filed on the 21st day of November 2001 and served by Acceptance of Service dated December 4th 2001. (Attached hereto) 3 The plaintiff, signed his Affidavit of Consent and Waiver of Notice of Entry of a Divorce Decree on the 25~ day of April 2002 which is attached hereto. 4. The plaintiff served his affidavit of consent, Counter-Affidavit, and Waiver of Notice of Intent to request Divorce Decree on defendant on the 5~ day of April, 2002 and the same was signed by defendant on the 11~, day of April 2002. 5. There are no related claims pending as between the parties hereto and listed herein to the extent that all marital issues have been settled by way of a Marital Settlement Agreement which was executed on the 26th day of April 2002. 6. The defendant signed a Waiver of Notice of Intention to Request Entry of Divorce Decree on the 11th day of April 2002 pursuant to Rule 1920.72 a copy of which is attached hereto D,te: ~/~ 0/~)~ ~ Mechanicsburg, PA. 17055 717-790-0490 Atty. I.D. 69528 SEPARATION AND PROPERTY SETTLEMENT AGREEMENT OF BRUCE A. DOOLITTLE AND BONNIE L. DOOLITTLE THIS AGREEMENT, made this_.,t~a_.~, day of /l~/0p_~J! , 2002, by and between Bruce A. Doolittle, hereinafter referred to as "Husband", and Bonnie L. Doolittle hereinafter referred to as "Wife". WlTNESSETH: WHEREAS, Husband and Wife were lawfully married on 16~ day of January 1998; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous, therefore, of entering into an agreement which will provide for support, distribute their marital property, and will provide for their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised, have come to the following agreement. NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs successors and assigns thereby, covenant, promise and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other as fully as if he or she was single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried Wife represents and warrants to Husband that since their separation, she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims and demands made against him by reasons of debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since their separation, he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims and demands made against her by reasons of debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: Husband and Wife agree that they haVe no outstanding debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement that are not otherwise specifically addressed by provision of this Agreement. In the event that either party contracted or incurred any debts since the date of separation, any party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged. 6. MUTUAL RELEASE: Subject to the provisions of this Agreemem, each party waives his or her right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an 8. REAL PROPERTY The parties are neither the legal nor equitable owners of any real property that would otherwise be subject to division and distribution. 9. MOTOR VEHICLES: The parties hereby agree that the party in whose possession there remains a Motor Vehicle shall continue to own this motor vehicle free and clear from any claims legal or equitable that the other party may assert. To the extent the vehicle in possession of either or both parties in is both parties names then the party relinquishing ownership shall sign title of said vehicle over into the other spouses name. All existing automobile insurance policies that are jointly held shall be transferred to the respective party's individual names and each will assume sole financial responsibility for payment to the same. 10. SUPPORT: . 4,~J~w/~h sl~l Husband agrees to pay to Wife suppo 1 end on October 15~ 2002 in the amount as established by Domestic Relations of Cumberland County on the 31st day of August 2001. Wife upon the signing of this document agrees, covenants, and promises that she shall relinquish, release and waive all claims against Husband for support and the same shall cease entirely including but not by way of limitation Alimony, Spousal Support, Alimony Pendente Lite and any and all other forms of legal and/or equitable support except as outlined herein. Husband upon the signing of this document agrees, covenants, and promises that she shall relinquish, release and waive all claims against Wife for support and the same shall cease entirely including but not by way of limitation Alimony, Spousal Support, Alimony Pendente Lite and any and all other forms of legal and/or equitable support 11. BANK ACCOUNTS/PENSION PLANS: The parties release any interest in the opposite spouse's Pensions, bank accounts, stocks, bonds, or any other tangible or intangible assets wheresoever located and accumulated prior to, during, and/or subsequent to the dissolution of their marriage. All existing bank accounts shall closed and accounts thereafter shall be kept in each of the party's separate names. 12. COUNSF, I, FI~,F,,q AND EXPENSES: Husband and Wife Acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provisions for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. 13. WAIVERS 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 estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, intestate share, right to take against the will of the other, and right to act as administrator or executor of the others estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instnunents which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 14. SUBSEOUENT DIVORCE: Husband intends to file a no-fault compla~st Wife. Husband and Wife each agree 'to jurisdiction of the Court of Common Pleas of.~nia~n County and further agree to sign an affidavit of consent to be filed in said divorce action. In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agreement which may be incorporated by reference into the Divorce Decree, shall not be merged into the Divorce Decree, and shall not be modified, but shall in all respects survive the same and be further binding and conclusive upon the parties. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted and prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanem shall affect or modify the financial terms of this Agreement. This Agreement may be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. 15. _RRlr, ACH AND ENFORCEMENT: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other such remedies or relief as may be available to him or her, and the party breaching this Agreement should be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. A. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. the parties to not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of Equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and in such event it is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay. C. Each party further hereby agrees to pay and to save and hold harmless the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any way whatsoever, or shall pay upon, or in consequence of any default or breach by the other of any of the terms or provisions of this agreement by reason of which either party shall be obliged to retain or engage counsel to initiate or maintain or defend proceedings against the other at law or equity or both in any way 23. INDEPENDENT SEPARATE COVENANTS: It is specifically nnderstood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 24. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 25. ~ If any terms, conditions, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 26. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 10 IN WITNESS WHEREOF, the parties hereto have set their hand and seals the day and year first above written. Bruce A. Doolittle Commonwealth of Pe~n.~ylv~ia County of Cumberland On this, the ~b ~' ,day of 4pIg/' / A.D. 20(h~. before me a Notary Public Bruce A. Doolittle, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. INWITNESS WHEREOF, !he~setc.~~~_;seal~ Notarial Seal I Kenneth L. Schlegel NotanJ Public IM~ ¢o~mi$~ion Expi~ ~p~. 4, Bonnie L. Doolittle Commonwealth of Pennsylvania County of ~o o~ On this, the I,~ t L ,day of ]~r', ~" A.D. 2001, before me a Notary Public appeared Bonnie L. Doolittle , known to me (~r satisfactorily proven) to be the person whose name is subscribed 'to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Seal Title of Officer NOTARIAL SEAL ELLEN ROSENBLOOM, Notary Public City of Harrisburg, Dauphin Coun~ [_[~ G~r~ni~sion I~xpires IVlav 8. 2003_._~ 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~~ PENNA. BRUCE A. DOOLITTLE VERSUS NO. 01-R~4 DECREE iN DIVORCE AND NOW, ~?~ ~ DECREed That BRUCE A. DOOLITTLE AND BONNIE L. DOOLITTLE ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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; THE MARITAL SETTr.EMENT AGreEMENT ~Y~CUTED BETW~-EN THE PARTIES SHALL BE INCORPORATED INTO THE FINAL DIVORCE DECREE A;T~St: /0 Jo PROTHONOTARY