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HomeMy WebLinkAbout09-0466 J F:\DOCS\FL\DIV\Zvorsky.Mark - Divorce Compiaint.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF MARK JOSEPH ZVORSKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Oq - gtl(e ?lVi? ??f N1 KAREN LYNN (BRICKER) ZVORSKY, CIVIL ACTION - LAW 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 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF MARK JOSEPH ZVORSKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. KAREN LYNN (BRICKER) ZVORSKY, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT FOR DIVORCE 1. The Plaintiff in this action is MARK JOSEPH ZVORSKY, an ladult individual, who currently resides at 334 Fifth Street, New Cumberland, Pennsylvania 17070. 2. The Defendant in this action is KAREN LYNN (BRICKER) IZVORSKY, an adult individual, who currently resides at334 Fifth Street, New Cumberland, Pennsylvania 17070. 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 June 5, 2005, in Mechanicsburg, 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 one minor child, ANYA KAY ZVORSKY, who will be age three (3) this March, having been born on March 16, 2006, has 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 Idivorce. STONE LaFAVEjR--,'g SHEKLETSKI Eliz et . Stone, Esquire S e Court ID # 60251 Date: ZJ 4 ridge Street, P.O. Box E Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff 11 W V E R I F I CAT I O N 11MARK JOSEPH ZVORSKY 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. MARK JOSEP ZVO SKY Date:_ 112-:?-1ZUO-j 0 A c`s E' N ,? l r..? i ) ? C37 G Ann E. Rhoads, Esquire CLECKNER AND FEAREN 119 Locust Street P. 0. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 m rhoadsann@hotmail.co Attorneys for Defendant MARK JOSEPH ZVORSKY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09-466 CIVIL TERM KAREN LYNN (BRICKER) ZVORSKY, : CIVIL ACTION - LAW Defendant : IN DIVORCE NER TO COMPLAINT FOR DIVORCE AND NOW, this Hday of February, 2009, comes the Defendant, Karen Lynn Zvorsky, by her attorneys, Cleckner and Fearen, and respectfully avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Defendant admits that the marriage between the parties is irretrievably broken. 7. Admitted. 8. Admitted. 9. Defendant joins in the request of Plaintiff for entry of a decree of divorce. CLAIM OF RIGHTS CLAIMS FOR ALIMONY PENDMUS LITE 10. Paragraphs 1 - 9 of the Complaint and Answer are incorporated herein and made a part hereof by reference. 11. Defendant, Karen Lynn Zvorsky, avers that she does not have sufficient funds with which to support herself during the pendency of the divorce action. 12. Defendant, Karen Lynn Zvorsky, has custody of and cares for three (3) minor children from a prior marriage. 13. Defendant, Karen Lynn Zvorsky, has filed a petition for spousal support with the Domestic Relations Office of Cumberland County, Pennsylvania. 14. Plaintiff, Mark Joseph Zvorsky, has sufficient funds with which to support the Defendant, his wife in the form of alimony pendente lite. 15. Defendant, Karen Lynn Zvorsky, hereby avers that she does not have sufficient funds with which to adequately defend the divorce action lodged against her including but not limited to support for herself in the form of alimony pendente lite, and counsel fees, costs and expenses. 16. Plaintiff, Mark Joseph Zvorsky does have sufficient funds to support Defendant pending the divorce action. 2 WHEREFORE, Defendant, Karen Lynn Zvorsky, respectfully requests Your Honorable Court to order the Plaintiff Mark Joseph Zvorsky to pay alimony pendente lite. CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY 17. Paragraphs 1 - 9 of the Complaint and 1 - 16 of the Answer are incorporated herein and made a part hereof by reference. 18. Plaintiff and Defendant acquired marital property during their marriage. WHEREFORE, Defendant, Karen Lynn Zvorsky, respectfully requests that Your Honorable Court enter a decree in divorce equitably distributing marital property. CLAIM FOR ALIMONY, COUNSEL FEES, COSTS AND EXPENSES 19. Paragraphs 1 - 9 of the Complaint and 1 - 18 of the Answer are incorporated herein and made a part hereof by reference. 20. Defendant, Karen Lynn Zvorsky, hereby avers that she does not have sufficient funds in which to support herself upon the conclusion of the divorce action or to pay counsel fees, costs and expenses incidental with said divorce action. 21. Plaintiff, Mark Joseph Zvorsky does have sufficient funds in which to support Defendant upon the conclusion of the divorce action and to pay Defendant's counsel fees, costs and expenses incidental with said divorce action. 3 WHEREFORE, Defendant, Karen Lynn Zvorsky, respectfully requests Your Honorable Court to order Plaintiff, Mark Joseph Zvorsky, to pay alimony, counsel fees, costs and expenses. Respectfully submitted, CLECKNER AND FEAREN By : E JL]OZ? Ann E. Rhoads, Esquire 119 Locust Street P. 0. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 Attorney ID No.: 49631 Attorneys for Defendant, Karen Lynn Zvorsky 4 VERIFICATION I verify that the statements made in the Answer to Complaint in Divorce and Claim of Rights are true and correct to the best of knowledge, information and belief. 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 2''liJ??J k??' 41- A,/-- KA E LYIV ZVO SKY CERTIFICATE OF SERVICE I, ANN E. RHOADS, Esquire, hereby certify that a true and correct copy of the within Answer to Complaint in Divorce with Claim of Rights has been served upon the following individual, by first class, United States mail, postage prepaid, by placing a copy of the same at the post office in Harrisburg, Pennsylvania, on this day of ??(Z9 2009, addressed as follows: Elizabeth B. Stone, Esquire STONE, LaFAVER & SKEKLETSKI 414 Bridge Street P. O. Box E New Cumberland, PA 17070 Respectfully submitted, CLECKNER AND FEAREN By: -? -- ?1 1 n E. Rhoads, Esquire PA Attorney ID 49631 119 Locust Street P. O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 C-w 1 C[? LAW OFFICES ELIZABETH B. STONE 3507 Market Street, Suite 303 "' ~ '~ Camp Hill, PA 17011 - ~~~ ~` '`, r . Telephone: (.717) 90'~-1500 ~ ~ ~ -`''~' ';~ - ~ :. . Facsimile: (717) 731-8115 ~~ ~' MARK JOSEPH ZVORSKY, § IN THE COURT OF COMMON PLEAS :Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. ~ NO. 2009-466 KAREN LYNN ZVORSKY, § CIVIL ACTION -DIVORCE Defendant § CERTIFICATE OF SF;RVICE I HEREBY C ERTIFY THAT I served a copy of the Affidavit Required by section 3301(d) of the Divorce Code, filed on October 12, 2012, on counsel for Defendant, on October 16, 2012. Certified Mail, Restricted Delivery., and by first class U.S. mail, addresses as follows: Ms. Ann E. Rhoads CLECKNER AND FEAREN ATTORNEYS AT LAW 119 Locust Street P.O. Box 11847 Harrisburg, P.A 17108-1847 ~~ Respectfully submitted., .y~~~~ .~_ '~" ~~ ~ i ~~ Elizab ~ Sto,~e,:~sq~uire Sub e Cou~~l~~. No.: 60251 ;, `; ~° . ~ ^ 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 Addresspped/~to: Gll9 E~~~c~S~ ~a~-- A. Sign ture /~/,L, ~,~ f'~Agent X ~'~--1/' ~~' ~ +~ 4''' ^ Addressee B. Receive by (Printed Name) C. of ldelivery ~_~~~ D. Is delivery address different from item 1? ^ Yes If YES, enter delivery address below: ^ No ~~ 3. Service Type .0'Certified Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. __ 4. Restricted Delivery? (Extra Fee) ^ Yes 2. Article Number 710 309[7 00[]0 183 537 _ ~~ (transfer from service 1. '"~ PS Form 3811, February 2004 Domestic Return Receipt to25s5-o2-M-~5ao ANN ~. BROADS, EsQvIRE PA Attaraey ID ~ 49631 Cl.eekner and Fearen 119 Locust street P. O. Box 11847 Harrisburg, PA 17108-1847 Tel: 717-238-1731 Fax: 717-238-8481 rhaadaan»@hotmail.com Attorneys for Defendant ~~= ~ NE~'~}~i~ ~N NO TAB; ,, Z~12 NOY -5 Ate 9: ~+p -~M~ERt~At~C Ct)'t3lVTY I'~'N~iSYLVANIA MARK JOSEPH ZVORSRY, Plaintiff vs. RAREN LYNN (HRICRER) ZVORSRY, Defendant IN THE COURT OF CC~L~ PLEAS OF CUMBERLAI4D COUNTY , PENl3YLVANIA NO. 09-466 CIVIL TERM CIVIL ACTION - LAi!i IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCEE CODE 1. I do not oppose the entry of divorce degree. 2. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to my statement of economic claims above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. I HAVE ALREADY FILED A STATEMENT OF ECONOMIC CLAIMS IN MY ANSWER TO COMPLAINT, FILED WITH THE PROTHONOTARY ON FEBRUARY 18, 2009, AND SERVED UPON THE PLAINTIFF ON FEBRUARY 17, 2009. I verify that the statements made in this counter-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: ~~ 2012 KAREN Y (BRIG ) ORSKY, Defendant CERTIFICATE OF SERVICE I, ANN E. RHOADS, hereby certify that on this day, I served a true and correct copy of the foregoing document upon the person(s) indicated below, by depositing same in the United States mail, first class postage prepaid, addressed as follows: Elizabeth B. Stone, Esquire The Law Office of Elizabeth B. Stone 3507 Market Street, Suite 303 Camp Hill, PA 17011 (Counsel for Plaintiff) 1~7~.---r ~... Date: ~D~:Qr a o1~~')., Ann E. Rhoads, Esquire PA Attorney ID 25675 CLECKNER AND FEAREN 119 Locust Street P. 0. Box 11847 Harrisburg, PA 17108-1847 (717)238-1731 LAW OFFICES OF ELIZABETH B. STONE 3507 Market Street, Suite 303 Camp Hill, PA 17011 Telephone: (717) 909-1500 Facsimile: (717) 731-8115 FIL:0-OFFiCE OF THE PROTHONOTARY 2014 APR 30 PH Li: 10 CUMBERLAND COUNTY PENNSYLVANIA MARK JOSEPH ZVORSKY, § IN THE COURT OF COMMON PLEAS Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. § NO. 2009-466 KAREN LYNN ZVORSKY, § CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on January 29, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of Divorce. 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: W3OPY LAW OFFICES OF ELIZABETH B. STONE 3507 Market Street, Suite 303 Camp Hill, PA 17011 Telephone: (717) 909-1500 Facsimile: (717) 731-8115 r:LED-OFFICE OF THE PROTHONOTARY 2014 APR 30 PM 4: '1 0 CUMBERLAND COUNTY PENNSYLVANIA MARK JOSEPH ZVORSKY, § IN THE COURT OF COMMON PLEAS Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. KAREN LYNN ZVORSKY, § CIVIL ACTION - DIVORCE Defendant NO. 2009-466 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF THE DIVORCE CODE 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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: LiLdQ/V Mark Zvor/, Playff Ann E. Rhoads, Esquire Pa. 1.D. No. 49631 244 West Main Street Hummelstown, PA 17036 Telephone: 717-482-8392 Attorney for Defendant MARK JOSEPH ZVORSKY, Plaintiff VS. DO1 I:k;L V THE PROTHONOTAin 2014 APR 30 PM to 10 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-466 CIVIL TERM KAREN LYNN (BRICKER) ZVORSKY, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 29, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: KAREN LYNN RICKER) ORSKY, Defendant Ann E. Rhoads, Esquire Pa. I.D. No. 49631 244 West Main Street Hummelstown, PA 17036 Telephone: 717-482-8392 Attorney for Defendant UF THE PROTHONOTARY 2014 APR 30 PM 10 CUMBERLAND COUNTY PENNSYLVANIA MARK JOSEPH ZVORSKY, Plaintiff v. KAREN LYNN(BRICKER) ZVORSKY, : IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA • • NO. 09-466 CIVIL TERM .• Defendant : CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) AND 3301(d) 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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: '-f-29 KAREN LAN B ZVORSKY, Defendant r• F LED -Q }• IC: OF THE PE-WT HONG LAR 20!4 APR 30 PI t+4 ! 0 9200- 4K66 CLz mAitymoik- vii T AGREEMENT THIS AGREEMENT is made this ag 'day of-p a , 2014, by and between MARK JOSEPH ZVORSKY (HUSBAND) and KAREN LYNN (BRICKER) ZVORSKY (WIFE), both of Cumberland County, Pennsylvania. WHEREAS, HUSBAND and WIFE were lawfully married on June 5, 2005, in Mechanicsburg, Cumberland County, Pennsylvania; and WHEREAS, one (1) child was born of this marriage, namely: Anya Kay Zvorsky, born March 16, 2006; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties desire to settle fully and finally their respective financial and property rights as between each other, including without limitation by specification: all matters relating to ownership and equitable distribution of real and personal property; all matters relating to past, present and future support, alimony or maintenance of the spouse; and, in general, the settling of any and all claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and of the mutual promises contained herein, and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to by legally bound, hereby covenant and agree as follows: 1. PERSONAL RIGHTS: HUSBAND and WIFE may and shall hereafter live separate and apart, wherever he or she may choose to reside, free from interference, authority and contact with the other, except as may be necessary to carry out the provisions of this Agreement. 2. EF%'ECT OF SUBSEQUENT DIVORCE: The parties hereby acknowledge that this Agreement is entered into in contemplation of divorce, and that the Agreement may be incorporated by reference into the divorce decree, but shall not merge with it. It is the specific intent of the parties that this Agreement survive any divorce judgment and be forever binding and conclusive upon the parties. Neither party shall seek any relief from the court such divorce action which is contrary to the terms of this Agreement, except as provided in the Pennsylvania Divorce Code at 23 Pa.C.S. Section 3105 3. EXECUTION DATE: The "date of execution" or "execution date" of this Agreement shall be defined as the date on which both parties sign this Agreement, or, if the parties sign on different dates, the date on which the last party signs. 4. MUTUAL RELEASE: (a) HUSBAND and WIFE do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of the other , of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of the other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other, by way of dower or curtesy, or claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance, or under intestate laws, or the right to take against a 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, (c) any County, Commonwealth or territory of the United States, or (d) any other country, or the right to act as Administrator, Administratrix, Executor or Executrix of the estate of the other; or any rights which either party now has or may have at any time hereafter for spousal 2 obligations from his or her attorney, and that he or she acknowledges that this Agreement is fair and equitable and is not the result of any coercion, duress, undue influence or collusion. 6. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that he or she has not heretofore incurred or contracted any debt, liability or obligation for which the other may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify, exonerate and save harmless the other party from every kind of debt, liability or obligation which may have, heretofore been incurred by him or her, including those for necessaries, except for the obligations of each arising out of this Agreement. 7. WARRANTY AS TO FUTURE OBLIGATIONS: WIFE and HUSBAND each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified and exonerated from any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise provided for by the terms of this Agreement, and that neither of them shall hereafter incur any liability whatsoever for which the other or the estate of the other may be liable. 8. SPOUSAL SUPPORT /ALIMONY PENDENTE LITE/HEALTH INSURANCE: HUSBAND currently pays WIFE spousal support in the amount of $619.00 per month pursuant to an order of court of the Court of Common Pleas of Cumberland County, Pennsylvania (Docket N. 00117 S 2009; PACSES Case No. 927110665). The parties agree that HUSBND "S obligation to pay WIFE spousal support shall terminate as of the first day of the month immediately following the entry of a decree of divorce of HUSBAND and WIFE. HUSBAND currently provides health insurance for WIFE and the parties' child through his employer. HUSBAND represents to WIFE that she will be eligible to obtain continued health insurance, at her expense, through HUSBAND "S employer under the provisions of COBRA. Neither party shall have any responsibility for payment of the other's unreimbursed medical expenses. 4 9. REAL PROPERTY: HUSBAND agrees to transfer all his title and interest in the real property situate at 334 Fifth Street, New Cumberland, Cumberland County, Pennsylvania, by special warranty deed, and WIFE agrees to refinance the existing loan secured by a mortgage against said real property so that HUSBAND is relieved of any personal obligation for said loan. In order to effectuate this agreement regarding said real property, the parties agree as follows: (a) WIFE agrees to complete settlement of a refinance of said loan by no later than sixty (60) days from the Execution Date of this Agreement. (b) HUSBAND agrees to provide the following to WIFE's attorney, Ann E. Rhoads, Esquire, by no later than five (5) days prior to the date of settlement of the aforementioned refinance: (1) Certified funds of One Thousand Dollars ($1,000.00); and (2) An executed special warranty deed. Ann E. Rhoads, Esquire, will hold these funds and the deed, in trust, until settlement occurs. (c) HUSBAND will pay the sum of Fifteen Hundred Dollars ($1,500.00) to WIFE on or before May 15 of each year that HUSBAND claims the parties' child as a dependent for income tax purposes, beginning with the tax year 2013. 10. MOTOR VEHICLES: The parties agree that WIFE shall have sole use and ownership of the automobile in her possession. HUSBAND shall have sole use and ownership of the automobile in his possession. Each party shall be solely responsible for all remaining amounts owed on his or her automobile and holds the other harmless from any obligation in connection therewith. 11. PERSONAL PROPERTY: The parties have divided between themselves, to their mutual satisfaction, all items of tangible personal property previously used by them in the marital home, as well as all bank accounts or other intangible personal property. Neither party shall make any claim to any such item of tangible personal property or intangible personal property, whether said items are marital property or said items are separate personal property of either party, which are now in the possession or under the control of the other party on the Execution Date of this Agreement. Intangible personal property shall be deemed 5 to be in the possession or under the control of the party with physical possession or control of the tangible evidence of said property. 12. PENSION/IRA: The parties agree that each shall retain sole ownership of his or her IRA, pension, retirement plan or other tax deferred savings investments, and each hereby waives any and all interest in said assets of the other, including, but not limited to, equitable distribution of said assets and the right to receive any benefit from said assets whatsoever in the event of the other's death; provided, however, that nothing hereby shall be interpreted to prevent either HUSBAND or WIFE from designating the other as the beneficiary of any such assets after the date of entry of a decree of divorce, to which designations only the waiver of beneficiary rights provisions of this paragraph shall not apply. 13. LIFE INSURANCE: The parties agree that each will retain ownership and control of any life insurance policies he or she may own_ HUSBAND and WIFE each hereby waive any and all interest in any policy of insurance the other may own, including but not limited to the right to receive the proceeds as a beneficiary of such policy in the event of the other's death; provided, however, that nothing hereby shall be interpreted to prevent either HUSBAND or WIFE from designating the other as a beneficiary of life insurance after the date of entry of a decree of divorce, to which designations only the waiver of beneficiary rights provisions of this paragraph shall not apply. 14. INCOME TAX DEDUCTIONS: HUSBAND and WIFE agree that HUSBAND shall be entitled to the income tax dependency deduction for their child, Anya, each year; conditioned upon HUSBAND "S fulfillment of the obligation set forth above in Sub- paragraph 9(c) each year. 15. INTENDED TAX RESULT AND INDEMNIFICATION: By this Agreement the parties have intended to effectuate, and by this Agreement have divided their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any 6 way a sale or exchange of assets. As a part of the division of the marital properties and the marital settlement contained herein, the parties agree to save and hold each other harmless from all income taxes assessed against the other resulting from the division of the property as herein provided. 16. REAL PROPERTY OF HUSBAND: WIFE waives any and all interest of any kind in real property titled in HUSBAND "S name alone and situate at 8 Drexel Hills Circle, New Cumberland, Cumberland County, Pennsylvania. 17. WAIVER: Except as otherwise provided herein, HUSBAND and WIFE do hereby waive, release and give up any rights they may respectively have against the other for alimony, support, maintenance, alimony pendent lite, counsel fees and costs. Further, it shall be, from the Execution Date of this Agreement, the sole responsibility of the respective parties to sustain themselves without seeking any support from the other party. 18. FULL DISCLOSURE: Each party asserts that he or she has made full and complete disclosure of all real and personal property of whatsoever nature and wherever located belonging in any way to each of them, of all the debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each of them, and of every other fact relating in any way to the subject matter of this Agreement or hereby waives any further disclosure. Such disclosures which have been made are part of the consideration made by each party for entering into this Agreement. 19. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both the parties. 20. PENNSYLVANIA LAW APPLIES: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the Date of Execution. 7 21. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 22. 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. 23. OTHER DOCUMENTATION: HUSBAND and WIFE covenant and agree that they will forthwith (and within at least ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. 24. NO WAIVER OF DEFAULT: The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not affect the right of such part hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 25. COUNSEL FEES AND EXPENSES FOR ENFORCEMENT: Each party agrees that he or she will pay the reasonable counsel fees and costs incurred by the other in bringing an action to enforce the terms of this Agreement, but only in the event that said party is successful in such action. 26. SEVERABILITY: If any tern, condition, 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. 27. HEADINGS NOT PART OF AGREEMENT: Any heading preceding the text of a paragraph is inserted solely for convenience of reference and shall not affect the meaning, construction or effect of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals. Witness 9 • 6 KAREN L (B C R) ZVORSKY COMMONWEALTH OF PENNSYLVANIA : COUNTY OF On this, the day o undersigned officer, personally appe to be the person whose name is subscribe same for the purposes therein contained. SS , 2014, before me, a Notary Public, the OSEPH ZVORSKY, known to me (or satisfactorily proven) o the foregoing instrument and acknowledged that he executed the IN WITNESS WHEREOF, I have hereunto se i y hand and notarial seal. Notary Public COMMONWEALTH OF PENNSYLVANI COUNTY OF SS On this, the oZ 9 day of ,4 pr; / , 2014, before me a Notary Public, the undersigned officer, personally appeared KAREN LYNN (BRICKER) ZVORSKY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ,31L11 avr...17 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Lauren E. Snavely, Notary Public Hummelstown Boro, Dauphin County My commission expires December 10, 2017 STATE OF PENNSYLVANIA COUNTY OF C „,rn►' �Gt►1cl On this, the / 5� day of —Tab4?ck A 1ccl)it+'r appeared ehzu%h'`I T3 to be a member of the bar of the highest court of said state and a subscribing witness to the within instrument, and certified that h they as were) personally present when Mar a 2voes)b whose name subscribed to the within instrument executed the same, and that said person j ); z a h R 5.A3 ft acknowledged that h e (he /she /they) executed the same for the purposes therein contained. Apr S'4-u i' ,20 Jy ,before me , the undersigned officer, personally , known to me (or satisfactorily proven) In witness whereof, I hereunto set my hand and official seal. 76&664t, A 74,friii/L Notary Public Printed Name: T IT, i ® Imo+ J)rkgri My Commission Expires: OMMONWEPLIWOFRENNSYLVAMA - NOTARIAL SEAL ,TABETHA A TANNER '"Notary Public CAMP HILL BORO.. CUMBERLAND CNTY My Commission Expires Jan 28. 2018 MARK JOSEPH ZVORSKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. • NO: 09 - 466 CIVIL KAREN LYNN (BRICKER) ZVORSKY, : Defendant IN DIVORCE ORDER OF COURT OP AND NOW, this /06-6- day of 2014 , the economic claims raised in the proceedings having been resolved in accordance with a marriage settlement agreement dated April 29, 2014, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, '/0 : Oak. Key' A. Hess, P.J. cc: Elizabeth B. Stone Attorney for Plaintiff E. Rhoads Attorney for Defendant (16r re.5 /Y1134 .5 ., c) rrrJ m rrt UP I ...... CD Lw C-11 • 1 ' , , PLED-OF ICE OF THE PROTHONOTARY 201t1 APR 30 PM 4: 1 1 MARRIAGE SETTLEMENT AGREEMENT CU.p E N S Y LV! l LAND A TY THIS AGREEMENT is made this_. ,qday of - a ,2014,by and between MARK JOSEPH ZVORSKY(HUSBAND)and KAREN LYNN (BRICKER)ZVORSKY (WIFE), both of Cumberland County,Pennsylvania. WHEREAS,HUSBAND and WIFE were lawfully married on June 5,2005, in Mechanicsburg,Cumberland County,Pennsylvania; and WHEREAS, one(1) child was born of this marriage,namely: Anya Kay Zvorsky,born March 16,2006; and WHEREAS, diverse,unhappy differences, disputes and difficulties have arisen between the parties,and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties desire to settle fully and finally their respective financial and property rights as between each other, including without limitation by specification: all matters relating to ownership and equitable distribution of real and personal property; all matters relating to past,present and future support, alimony or maintenance of the spouse;and,in general,the settling of any and all claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and of the mutual promises contained herein,and for other good and valuable consideration,the receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to by legally bound, hereby covenant and agree as follows: 1. PERSONAL RIGHTS: HUSBAND and WIFE may and shall hereafter live separate and apart, wherever he or she may choose to reside, free from interference, authority and contact with theother,except asmay be necessary to carry out theprovisions of this Agreement. 2. EFFECT OF SUBSEQUENT DIVORCE: The parties hereby acknowledge that this Agreement is entered into in contemplation of divorce,and that the Agreement may be incorporated by reference into the divorce decree,but shall not merge with it. It is the specific intent of the parties that this Agreement survive any divorce judgment and be forever binding and conclusive upon the parties.Neither party shall seek any relief from the court in such divorce action which is contrary to the terms of this Agreement,except as provided in the Pennsylvania Divorce Code at 23 Pa.C.S. Section 3105 3. EXECUTION DATE: The"date of execution"or"execution date"of this Agreement shall be defined as the date on which both parties sign this Agreement, or, if the parties sign on different dates,the date on which the last party signs. 4. MUTUAL RELEASE: (a) HUSBAND and WIFE do hereby mutually remise,release,quitclaim and forever discharge the other and the estate of the other,for all time to come,and for all purposes whatsoever, of and from any and all rights,title and interest,or claims in or against the property(including income and gain from property hereafter accruing)of the other or against the estate of the other,of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against the other,the estate of the other or any part thereof,whether arising out of any former acts,contracts,engagements,or liabilities of such other,by way of dower or curtesy,or claims in the nature of dower or curtesy, or widow's or widower's rights,family exemption or similar allowance,or under intestate laws, or the right to take against a 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, (c)any County,Commonwealth or territory of the United States,or(d)any other country,.or the right to act as Administrator,Administratrix,Executor or Executrix of the estate of the other; or any rights which either party now has or may have at any time hereafter for spousal 2 . support or maintenance,alimony,alimony pendente lite, counsel fees,costs or expenses and equitable distribution of marital property,whether arising as a result of the marital relation or otherwise;except the right to spousal support/alimony pendente lite,which shall terminate upon the entry of a decree in divorce of the parties and all rights and agreements and obligationsof whatsoever nature which arise or which may, arisepursuant to.this Agreement or for any breach of any provision hereof. It is the intention of HUSBAND and WIFE to give each other by the execution of this Agreement a full,complete and general release,except and only except as to any and all rights and agreements and obligations which arise pursuant to this Agreement and for the breach of any provisions hereof. (b) It is specifically understood and agreed to by and between the parties hereto that each accepts the provisions herein in lieu of and in full settlement and satisfaction of any and all of his or her rights against the other for any future claims on account of • spousal support and maintenance/alimony pendente lite after the entry of a divorce decree between them;that it is specifically understood and agreed that the payments,transfers and other considerations herein recited so comprehend and discharge any and all such claims by each against the other,and are, inter alia, in full settlement and satisfaction and in lieu of their future claims against one another on account of maintenance and spousal support/alimony pendente lite after entry of a divorce decree between them, and also for future alimony, future alimony pendente lite,counsel fees,costs and expenses,as well as any and all claims to equitable distribution of property both real and personal and any other charge of any nature whatsoever pertaining to any divorce proceedings which have been or may be instituted in any court in the Commonwealth of Pennsylvania or any other jurisdiction whatsoever. 5. ADVICE OF COUNSEL: HUSBAND and WIFE declare that they have each had a full and fair opportunity to obtain independent legal advice from counsel of this selection;that HUSBAND has been independently represented by Elizabeth B. Stone, Esquire, and that WIFE has been independently represented by Ann E. Rhoads,Esquire. HUSBAND and WIFE each further declare that he or she is executing this Agreement freely and voluntarily,having obtained knowledge and disclosure of his or her legal rights and 3 obligations from his or her attorney, and that he or she acknowledges that this Agreement is fair and equitable and is not the result of any coercion,duress, undue influence or collusion. 6. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that he or she has not heretofore incurred or contracted any debt,liability or obligation for which the other may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify, exonerate and save harmless the other party from every kind of debt,liability or obligation which may have heretofore been incurred by him or her, including those for necessaries,except for the obligations of each arising out of this Agreement. 7. WARRANTY AS TO FUTURE OBLIGATIONS: WIFE and HUSBAND each covenant,warrant,represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified and exonerated from any and all debts,charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise provided for by the terms of this Agreement, and that neither of them shall hereafter incur any liability whatsoever for which the other or the estate of the other may be liable. 8. SPOUSAL SUPPORT/ALIMONY PENDENTE LITE/HEALTH INSURANCE: HUSBAND currently pays WIFE spousal support in the amount of$619.00 per month pursuant to an order of court of the Court of Common Pleas of Cumberland County,Pennsylvania(Docket N. 00117 S 2009; PACSES Case No. 927110665). The parties agree that HUSBND"S obligation to pay WIFE spousal support shall terminate as of the first day of the month immediately following the entry of a decree of divorce of HUSBAND and WIFE. HUSBAND currently provides health insurance for WIFE and the parties' child through his employer. HUSBAND represents to WIFE that she will be eligible to obtain continued health insurance, at her expense,through HUSBAND"S employer under the provisions of COBRA.Neither party shall have any responsibility for payment of the other's unreimbursed medical expenses. 4 9. REAL PROPERTY: HUSBAND agrees to transfer all his title and interest in the real property situate at 334 Fifth Street,New Cumberland,Cumberland County, Pennsylvania,by special warranty deed,and WIFE agrees to refinance the existing loan secured by a mortgage against said real property so that HUSBAND is relieved of any personal obligation for said loan. In order to effectuate this agreement regarding said real property,the parties agree as follows: (a) WIFE agrees to complete settlement of a refinance of said loan by no later than sixty(60)days from the Execution Date of this Agreement. (b) HUSBAND agrees to provide the following to WIFE's attorney,Ann E. Rhoads,Esquire,by no later than five (5)days prior to the date of settlement of the aforementioned refinance: (1) Certified funds of One Thousand Dollars($1,000.00); and (2)An executed special warranty deed. Ann E. Rhoads,Esquire,will hold these funds and the deed,in trust,until settlement occurs. (c) HUSBAND will pay the sum of Fifteen Hundred Dollars($1,500.00)to WIFE on or before May 15 of each year that HUSBAND claims the parties' child as a dependent for income tax purposes,beginning with the tax year 2013. 10. MOTOR VEHICLES: The parties agree that WIFE shall have sole use and ownership of the automobile in her possession. HUSBAND shall have sole use and ownership of the automobile in his possession. Each party shall be solely responsible for all remaining amounts owed on his or her automobile and holds the other harmless from any obligation in connection therewith. 11. PERSONAL PROPERTY: The parties have divided between themselves,to their mutual satisfaction,all items of tangible personal property previously used by them in the marital home,as well as all bank accounts or other intangible personal property.Neither party shall make any claim to any such item of tangible personal property or intangible personal property,whether said items are marital property or said items are separate personal property of either party,which are now in the possession or under the control of the other party on the Execution Date of this Agreement. Intangible personal property shall be deemed 5 to be in the possession or under the control of the party with physical possession or control of the tangible evidence of said property. 12. PENSION/IRA: The parties agree that each shall retain sole ownership of his or her IRA,pension,retirement plan or other tax deferred savings investments,and each hereby waives any and all interest in said assets of the other, including,but not limited to, equitable distribution of said assets and the right to receive any benefit from said assets whatsoever in the event of the other's death;provided,however,that nothing hereby shall be interpreted to prevent either HUSBAND or WIFE from designating the other as the beneficiary of any such assets after the date of entry of a decree of divorce,to which designations only the waiver of beneficiary rights provisions of this paragraph shall not apply. 13. LIFE INSURANCE: The parties agree that each will retain ownership and control of any life,insurance,policies he or she may own.HUSBAND and WIFE each hereby waive any and all interest in any policy of insurance the other may own,including but not limited to the right to receive the proceeds as a beneficiary of such policy in the event of the other's death;provided,however,that nothing hereby shall be interpreted to prevent either HUSBAND or WIFE from designating the other as a beneficiary of life insurance after the date of entry of a decree of divorce,to which designations only the waiver of beneficiary rights provisions of this paragraph shall not apply. 14. INCOME TAX DEDUCTIONS: HUSBAND and WIFE agree that HUSBAND shall be entitled to the income tax dependency deduction for their child,Anya,each year; conditioned upon HUSBAND"S fulfillment of the obligation set forth above in Sub- paragraph 9(c) each year. 15. INTENDED TAX RESULT AND INDEMNIFICATION: By this Agreement the parties have intended to effectuate,and by this Agreement have divided their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not,except as may be otherwise expressly provided herein,intended by the parties to constitute in any 6 way a sale or exchange of assets.As a part of the division of the marital properties and the marital settlement contained herein,the parties agree to save and hold each other harmless from all income taxes assessed against the other resulting from the division of the property as herein provided. 16. REAL PROPERTY OF HUSBAND: WIFE waives any and all interest of any kind in real property titled in HUSBAND"S name alone and situate at 8 Drexel Hills Circle, New Cumberland,Cumberland County,Pennsylvania. 17. WAIVER: Except as otherwise provided herein,HUSBAND and WIFE do hereby waive,release and give up any rights they may respectively have against the other for alimony, support,maintenance, alimony pendent lite, counsel fees and costs. Further,it shall be,from the Execution Date of this Agreement,the sole responsibility of the respective parties to sustain themselves without seeking any support from the other party. 18. FULL DISCLOSURE: Each party asserts that he or she has made full and complete disclosure of all real and personal property of whatsoever natureand wherever located belonging in any way to each of them,of all the debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or. receivable by each of them,and of every other fact relating in any way to the subject matter of this Agreement or hereby waives any further disclosure. Such disclosures which have been made are part of the consideration made by each party for entering into this Agreement. 19. WAIVER OR MODIFICATION TO BE IN WRITING:No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both the parties. 20. PENNSYLVANIA LAW APPLIES: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the Date of Execution. 7 21. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 22. 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. 23. OTHER DOCUMENTATION: HUSBAND and WIFE covenant and agree that they will forthwith(and within at least ten(10)days after demand therefor)execute any and all written instruments,assignments,releases, satisfactions,deeds,notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. 24. NO WAIVER OF DEFAULT: The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not affect the right of such part hereafter to enforce the same,nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the sameor similar nature,nor shall it be construed as a waiver of strict performance of any other obligations herein. 25. COUNSEL FEES AND EXPENSES FOR ENFORCEMENT: Each party agrees that he or she will pay the reasonable counsel fees and costs incurred by the other in bringing an action to enforce the terms of this Agreement,but only in the event that said party is successful in such action. 26. SEVERABILITY: If any tern, condition, 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. 8 27. HEADINGS NOT PART OF AGREEMENT: Any heading preceding the text of a: h isinserted solely for convenience of referenceand shall not affect the. meaning, construction or effect of this Agreement. IN WITNESS WHEREOF,the parties hereto have set their hands and seals. Alaril SUS' -H •RS's/ tJL'_ Witness KAREN L 4 (BRIG R)ZVORSKY 9 COMMONWEALTH OF PENNSYLVANIA • SS COUNTY OF • On this,the day o 2014,before me,a Notary Public,the undersigned officer,personally ap i-. .. MARK JOSEPH ZVORSKY,known to me(or satisfactorily proven) to be the person whose name is subscri►-o o the foregoing instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF,I have hereunto se iay hand and notarial seal. Notary Public COMMONWEALTH OF PENNSYLVANI . SS COUNTY OF • On this,the o2 1 day of Apr; / ,2014,before me a Notary Public,the undersigned officer,personally appeared KAREN LYNN(BRICKER)ZVORSKY,known to me(or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF,I have hereunto set my hand and notarial seal. otaryNPublic OOM WSNWEALTh OF PENNSYLVANIA NOTARIAL SEAL Lauren E.Snavely,Notary Public Hummelstown Boro,Dauphin County My commission expires December 10,2017 STATE OF PENNSYLVANIA COUNTY OF CC„;M6er Loy/ On this,the / S day of Apr; I , 20 1y ,before me —TabQ ex i - 1 G 0 A.r ,the undersigned officer, personally appeared e:I13,42h4 73. ►ilf , known to me (or satisfactorily proven) to be a member of the bar of the highest court of said state and a subscribing witness to the within instrument, and certified that he/they as were)personally present when Mork S 2vo«ly whose name i S subscribed to the within instrument executed the same, and that said person )J a a •B. slime, acknowledged that h i (he/she/they) executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. 7.1,664„ --4,,v,taA.. Notary Public Printed Name:777,h4-to, My Commission Expires: NOTARIAL SEAL 'ABETHA A TANNER ' ` = *tory Public CRAP HILb.8 O..CUMBERLAND CNTY m Jon 28,2018 My Con>a3�i}�n Fxpi HE PRO FBONN L,: 2014 MAY -2 PM 14: 06 CUMBERLAND COUNTY LAW OFFICES ELIZABETH B. STONE PENNSYLVANIA 3507 Market Street, Suite 303 Camp Hill, PA 17011 Telephone: (717) 909-1500 Facsimile: (717) 731-8115 MARK JOSEPH ZVORSKY, § IN THE COURT OF COMMON PLEAS Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v. § NO. 2009-466 KAREN LYNN ZVORSKY, § CIVIL ACTION - DIVORCE Defendant § PRAECIPE TO TRANSMIT 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. Date and Manner of Service of the Complaint: United States Postal Service, first class mail,postage prepaid,certified,restricted delivery. Filed on January 29, 2009; Proof of Service evidenced by the Answer to Complaint in Divorce filed on or about February 17,2009, and served upon undersigned counsel by Defendant's counsel; the Certificate of Service was filed with the Court on October 12, 2012. 3. Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: Filed by Plaintiff on October 12, 2012; by signed by Defendant on April 29, 2014, and filed with the Court on April 30, 2014. 4. Related Claims Pending: no other marital claims pending. All marital claims were settled by the enclosed Marital Settlement Agreement dated April 29, 2014, to be incorporated but not merged into the Divorce Decree. 5. Date of Filing Waivers of Notice: Plaintiff's Waiver of Notice is filed with this Praecipe to Transmit. Defendant's Waiver of Notice is filed with this Praecipe to Transmit. Respectfully submitted, .., Elizabet :fine squire Attorn- f. la''tiff Su. ,-m- our .D. No. 60251 LA I OF, CE OF ELIZABETH B.STONE (/' 35: .rket Street, Suite 303 Cam. ill, PA 17011 (717 909-1500 : IN THE COURT OF COMMON PLEAS OF MARK JOSEPH ZVORSKY cuMBERLAND COUNTY, PENNSYLVANIA V. • • KAREN LYNN ZVORSKY : NO. 2009-466 DIVORCE DECREE AND NOW, t,ary . ' , 20 'y , it is ordered and decreed that MARK JOSEPH ZVORSKY , plaintiff, and KAREN LYNN ZVORSKY , 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 Marital Settlement Agreement dated April 29, 2014, signed by the parties is hereby incorporated, but not merged into the Decree in Divorce. By the Court, Yom-- _ __!� � t tt�ttt ^ 414 4 tt 1411 u °t re 44E, - Prothonota c/� Ceri-Copy ri\ai led fv d-H11 Sbne NafiCe+ expli mailed +o at hi- hoads 0:5),