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HomeMy WebLinkAbout01-1797RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW 2001- 1'7 CIVIL TERM lin DIVORCE NOTICE 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 in divorce or annulment raay 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 man'iage counselors is available in the 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 WHiERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES 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 to 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. RONALD L. LAUTSBAUGH, Plaintiff JEANETT/~ N. LAUTSBAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIl, ACTION - LAW : 2001-/'7q7 CIVIL TERM : IN DIVORCE COMPLAINT IN D_._~ORCE PURSUANT TO_ SECTION 3301(e) O.~.F THE DIVORCE COD~E_ NOW comes the plaintiff, Ronald L. Lautsbaugh,, by his attorney, McKnight, III, Esquire, and files this complaint in divorce aga~[nst the defendant, Lautsbaugh, representing as follows: Marcus A. Jeanette N. 1. The plaintiff is Ronald L. Lautsbaugh, an adult individual residing at 30 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065. 2. The defendant is Jeanette N. Lautsbaugh, an adult individual residing at 620 East Camping Area Road, Rossville, Pennsylvania 17365. 3. The plaintiff has been a resident of the Commonweaith of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on August 2, 1998 in Mt. Holly Springs, Pennsylvania, and separated on August 1, 2000. 5. There have been no prior actions of divorce or for annulment between the parties. 6. There were no children bom to this marriage. 7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parfi~ to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN, N)~qlGH~ i& HUGHES Marcus A. McKnig Attorney for Plain~ West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I.D. No. 25476 Date: March k?~k , 2001 VERIFICATION The foregoing Compla'mt in Divorce is based upon info]rmation which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Complaint and they are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. RONALD L. LAUTSBAUGH Date: March ~'1Yx , 2001 RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW 2001- CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list ofmarfiag~ counselors in the Prothonotavd's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I p~icipate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. RONALD L. LAUTSBAUGH RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIl, ACTION - LAW : 2001-1797 CIVIL TERM : lIN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1!}20.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND : NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Jeanette N. Lautsbaugh, on April 1 I, 2001, by certified, restricted delivery mail, addressed to her at 620 East Camping Area Road, Rossville, Pennsylvania 17365, with Return Receipt Number 7099 3400 0018 4997 2220. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are trne and correct. I understand that false statements herein made are subject to the penalties o~t8 P'a. C.~. Section 4904, relating to ' MJmcus ESOUim Attorney fot~la'mtiff Date: April 12, 2001 Certified Fee Return Receipt Fee (Endorsement Required) Total Postage & Fees 3. $ q,3t¢ Postmark Here MS JEANETTE lq LAUTSBAUCH 620 E CAttING ,~eRA. Itl) KOSSVILLE FA · Complete items 1, 2, and 3. Also complete Received item 4 if Reeldcted Delivery is desired. -; · Pdnt your name and address on the reverse ao that we can return the card to you. C. Signature · Attach this card to the back of the melipiece, or on the front if space permits. 1. Article Addressed to: MS JF_.,AN~i"rI~ N LAUTSBAUGH 620 E CAI4PINC ARI~A ROSSVILLE PA 17365 Agent AddmMee delivery address enter deliveey address below: ~1 NO 3. Service Type [~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] C.O.D. Restarted D~w~.y~ ~ ~ 34 ) eel8 Z320 PS Fo~m 3811, July 1~ ~am·il~-~atum Re~#x ,, ~'zsee-~eaa-¢tao RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001-1797 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 27, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is grant~xt. I verify that the statements made in this affidavit are Wae and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. Date: July 27th ,2001 RONALD L. RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2001-1797 CIVIL TERM IiS DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE 'UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the ent~ of a final Decree of Divorce without notice. 2. I understand that I may lose fights 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 tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: July 27th ,2001 A RONALD L. LAUTSBAUGH ~ ~ Plaintiff RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ._ CIVIL ACTION - LAW : 2001-1797 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(¢) of the Divorce Code was filed on March 27, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are hnae and correct. I understand that false statements herein made are subject to the penalties of 18 l?a. C. S. Section 4904 relating to unswom falsification to authorities. ,2001 ~ JEANETTE N. LAUTSBAL~H RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001-1797 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 ifI do not claim them before a divorce is granteq. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ,2001 JEANET~fE 1~. LAUTSBA~H Defendant RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001-1797 CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of manSage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are Wac and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: {~1~ It4 q/ - ,2001 (~ - JEANETTE~N. LAUTSBA~H- RONALD L. LAUTSBAUGH, Plaintiff JEANETTE N. LAUTSBAUGH, Defendant : IN TIlE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001-179~ CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORU! To the Prothonotary: Tronsmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 330[(c) of the Divorce Code. 2. Date and manner of service of complaint: A ce~dfied copy of the Complaint in Divorce was served upon the defendant, Jeanette N. Lautsbaugh, on April 11, 2001, by cer~dfied, rest~Scted delivery mail, addressed to her at 620 East Camping Area Road, Rossville, Pennsylvania 17365, with Return Receipt Number 7099 3400 0018 4997 2220. 3. Complete either paragraph (a) or Co). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff: July 27, 2001; by defendant: July 14, 2001. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: August 1, 2001. Date defendant's Waiver of Notice in Sectioji 3301(c) Divorce was filed with the Prothonotary: August I, 2001. J/(~' ]\'~ ~IRE'' Attorney for Plain~ ~ MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this ~ day of April, 2001, by and between JEANETTE N. LAUTSBAUGH, (h~einafter referred to as "WIFE") and RONALD L. LAUTSBAUGH, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on August 2, 1998, in Mt. Holly Springs, Cumberland County, Pennsylvania. HUSBAND filed a Complaint in Divorce in Cumberland County, Pennsylvania, docketed at 2001- 1997 Civil Term on March 27, 2001. The parties hereto agree and covenant as follows: The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective fights and duties of the parties while they continue to live apart from each other. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. Further, the parties agree to continue living separately and apart from the other at any place or places that he or she may select as they have heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. The consideration for this contract and agreement is the mutual benefit to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: (a) is represented by counsel of his or her own c]hoosing; (b) is fully and completely informed of the facts relating to the subject matter of this Agreement and of the fights and liabilities of the parties; (c) enters into this Agreement voluntarily after receiving the advice of counsel; (d) has given careful and mature thought to the making of this Agreement; (e) has carefully read each provision of this Agreement; and (f) fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. This Agreement shall become effective immediately as of the date of execution. 2 It is the purpose and intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the fights of each Party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divorce Code relating to spousal support or alimony. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, inchading any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each Party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marriage. 3 REAL ESTATE: There was no real estate acquired during the marriage. o DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely responsible for her debts. Each party will indemnify and hold the other party harmless fi.om all obligation related to these debts. SPOUSAL SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to pay support or alimony pendente lite to the WIFE for herself. WIFE will not provide any financial support or alimony pendente lite to the HUSBAND. The parties also waive any right they have to receive alimony payments fi.om the other following the entry of the Divorce Decree in this matter. 10. PERSONAL PROPERTY: The parties agree that the personal property shall be divided as follows: HUSBAND shall receive the following items: (a) The personal property in his possession. (b) His bank accounts; (c) Any life insurance policy; and (d) His employee benefits. 4 WIFE shall receive the following items: (a) The personal property in her current possesshm., (b) Her bank accounts; (c) Any life insurance policy; and (d) Her employee benefits. The WIFE hereby waives all right and title which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property of the WIFE. Henceforth, each of the parties shall ovm, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes, as if he or she were unmarried. Each party agrees that neither will incur obligations, liens or liabilities on account of the other and that from the date of this Agreement, neither party shall contract or incur obligations, liens or any liability whatsoever on account of the other. 11. AUTOMOBILES: (a) HUSBAND agrees to waive any and all interest which he may have in the automobiles in possession of the WIFE. Co) WIFE agrees to waive any and all interest Which she may have in the automobiles in possession of the HUSBAND. They each waive any claim which they have in any automobile owned by the other party. 5 12. INSURANCE AND EMPLOYEE BENEFITS: ~Itte parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including but not limited to retirement, profit sharing or medical benefits of either party, shall be their own. WIFE waives all fight, title and claim to HUSBANDtS employee benefits, and HUSBAND waives all right, rifle, and claim to any of WIFE'S employee benefits. 13. BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, rifle and interest which she may have in the savings or checking or any other bank accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of the WIFE. 14. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 15. BREACH: If either party breaches any provisions of this Agreement, the other party should have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract will be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 6 16. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force ~md effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. The provisions of this Agreement are fully understood by both parties and each party acknowledgas 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. 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. APPLICABLE LAW: Commonwealth of Pennsylvania. 19. This Agreement shall be construed under the Laws of the 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 7 21. PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own costs and legal fees required to obtain and complete the divorce. 22. 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, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. IN WITNESS WI:IEREOF, the parties hereunto have set their hands and seals the day and year first above written. (~ JEANETTE i~., LAUTS~.~U~ - (SEAL) RONALD L. LAUTSBAUGI](J 8 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF YORK : SS: PERSONALLy APPEARED BEFORE ME, this _~/~_ y of ~ , 2001, a Notary Publio, in and for the Commonwealth o:~' Pennsylvania and County of Cumberland, JEANETTE N. LAUTSBAUGH, known to mc (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and ofl~ial seal. COMMONWEALTH OF PENNSYLVANIA : · SS: COUNTY OF CUMBERLAND : Notarial Seal Eric D. Witmer, Notary Public Carroll Twp., York County My C, "~mission Expires May 24, 2004 2001, a Notary Public, in and for the Commonwealth of P~nnsylvani/and County of Cumberland, RONALD L. LAUTSBAUGH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Scttlament Agreament, and acknowledges that he executed the same for the purposes therein contained. IN WITNESS W~EREOF, I have hereunto set my hand ~ad official seal. Merr~gr, Pennsylvania Association of Notaries INTHE COURT OF CONIMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. RONALD L. LAUTSBAUGH, Plaintiff VERSUS JEANETTE N. LAUTSBAUGH, Defendant NO. 2001-1797 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DECREE IN DIVORCE AND NOW,~ 7 DECREED THAT RONALD L. LAUTSBAUGH AND JEANETTE N. LAUTSBAUGH ARE DIVORCED FROM THE BONDS OF MATRIMONy. 2001 ., 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 ORDE~ HAS NOT YET BEEN ENTERED; The Marriage Settlement Agreement dated April 9, 2001 and signed by the parties is hereby incorporated into this By.put not merged.