HomeMy WebLinkAbout01-2260 In The Court of Common Pleas of
Cumberland County, Pennsylvania
Janna Leigh Mekulski, CML ACTION - LAW
Plaintiff,
ACTION IN DIVORCE
2c, o I- 22L~0
Brian Gregory Mekulski,
COMPLAINT IN DIVORCE
Defendant.
Filed on behalf of
Plainfiff, Janna Leigh Mekulski.
Counsel of record for this party:
PeterJ. Daley and Associates, P.C.
Peter J. Daley II, Esquire
218 Wood Street
California, PA 15419
Phone: (724) 938-8953
Facsimile: (724) 938-8959
Atty. I.D. # 70244
!
I
Janna Leigh Mekulski, · IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, · CUMBE~D COUNTY,
PENNSYLVANIA
VS.
: CIVIL ACTION - LAW
Brian Gregory Mekulski, · ACTION IN DIVORCE
:
Defendant. :
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 child.
When the ground for divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in the
office of the Prothonotary in Cumberland County.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNUIA/IENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOUI~D 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 I,EGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17012
(717)249-3166
Janna Leigh Mekulski, : IN THE COURT OF COMMON PI.EAS
: OF
Plaintiff, :CUMBERLAND COUNTY
PENNSYLVANIA
: CIVIL ACTION - LAW
Brian Gregory Mekulski, : ACTION IN DIVORCE
·
~/~.o/..~t.o ~ -F'~
Defendant. :
·
Complaint Under Section 3301 of the Divorce Code
1. The Plaintiff isJanna Leigh Mekulski, who currently resides at
27 Drexel Place, New Cumberland, PA 17070, Cumberland County, Pennsylvania
2. The Defendant is Brian Gregory Mekulski, who currently
resides at 707 Apple Drive, Mechanicsburg, PA 17913, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to the fding of this
Complaint.
4. The Plaintiff and Defendant were married on August 8, 1998, at
St. Joseph Catholic Church, Mechanicsburg, Cumberland County, Pennsylvania.
5. The marriage is irretrievably broken.
6. Neither Plaintiff nor Defendant is in the military or naval service
of the United States or its allies within the provisions of the Soldier's & Sailor's Civil
Relief Act of the Congress of 1940 and its amendments.
7. Haintiff and Defendant separated on or about August 22, 2000
and resumed co-habitation on January 7, 2001 and were separated again on or
about February 27, 2001.
8. There has been no prior action for divorce or for annulment
instituted by either of the parties in this or any other jurisdiction.
9. 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.
10. The parties have not entered into a written agreement as to
support, custody, visitation of the children, alimony or property division.
COUNT I
REO_..UEST FOR A FAULT DIVORCE
UNDER SECTION 3301 (a) (6) OF THE DIVORCE CODE
11. The prior p~r~r~phs o£ this Complaint are incorporated herein
by reference thereto.
Page 2 of 5
!
12. Defendant has offered such indignities to the Haintiff, who is the
innocent and injured spouse, as to render Plaintiffs condition intolerable and life
burdensome.
13. The action is not collusive, as defmed by §3309 of the Divorce
Code.
WHEREFORE, Plaintiff respectfully requests that the Court enter a
Decree of Divorce, pursuant to {}3301 (a)(6) of the Divorce Code.
{~OIJNT II
REQUEST FOR A NO-FAULT DIVORCE
UNDER SECTION 3301(c) OF THE DIVORGE GODE
14. The prior paragraphs of this Complaint are incorporated herein
by reference thereto.
15. After ninety (90) days have elapsed from the date of the filing of
this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff
believes that Defendant may also file such an affidavit.
WHEREFORE, if both parties file affidavits consenting to a divorce
after ninety (90) days have elapsed from the filing of Complaint, Plaintiff
respectfully requests the Court to enter a Decree of Divorce, pursuant to {}330 l(c) of
the Divorce Code.
Page 3 of 5
COUNT III
REQUEST FOR A NO-FAULT DIVORCE
UNDER SECTION 3301(d) OF THE DIVORCE CODE
16. The prior paragraphs of this Complaint are incorporated herein
by reference thereto.
17. At the appropriate time, Plaintiff may submit an affidavit
alleging that the parties have rived separate and apart for at least two (2) years.
WHEREFORE, Plaintiff respectfully requests the court to enter a
Decree of Divorce, pursuant to §330 l(d) of the Divorce Code, at the appropriate
time.
COUNT IV
REQUEST FOR ALIMONY PENDENTE LITE AND ALIMONY
UNDER SECTION 3701 AND SECTION 3702 OF THE DIVORCE
CODE
18. The prior paragraphs of this Complaint are incorporated herein
by reference thereto.
19. Plaintiff is unable to sustain herself during the course of litigation.
20. Plaintiff lacks sufficient property to provide for her reasonable
needs and is unable to sustain herself through appropriate employment.
Page 4 of 5
21. Plaintiff requests the Court to enter an award of alimony pendente
lite until final heating and thereupon to enter an Order of alimony in her favor,
pursuant to {}3701 and {}3702 of the Divorce Code.
22. Plaintiff requires reasonable support to adequately maintain herself
in accordance with the standard of living established during the marriage.
WHEREFORE, Plaintiff respectfully requests the Court to enter an
award of alimony pendente lite until fmal heating and thereupon to enter an Order
of alimony in her favor, pursuant to {}3701 and {}3702 of the Divorce Code.
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsii~cation to
authorities.
Dated: , ,
II
for Haintiff
E:~OItMb'l~Divorce~mekulskijmmnnm.divorcecompl4.2.01.vvpd Page 5 of 5
SHERIFF' S RETURN - OUT OF COUNTY
CASE NO- 2001-02260, P
COMMONWEALTH OF PENNSYLVJ~XlIA-
o CQIrNTY OF CUMBERLAND
MEKULSKI JANNA LEI GH
VS
MEKULSKI BRIAN GREGORY
R. Thomas Kline , Sheriff or Deputy Sheriff who bein9
duly sworn accordin~ to law, says, that he made a dilic~ent search and
and inquiry for the within named DEFENDANT , to wit-
MEKULSKI BRIAN GREGORY
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of LANCASTER County, Pennsylvania, to
serve the within COMPLAINT - DIVORCE
On May 22nd , 2001 , this office was in receipt of the
attached return from LANCASTER .
Sheriff's Costs-
Docketing 18.00
Out of County 9.00
Surcharge 10.00 s Kline
Dep Lancaster Co 40.16 f of Cumberland County
.00
77.16
05/22/2001
PETER J DALEY & ASSOC
Sworn and subscribed to before me
this ~'~ ~. day o f ~
~..~/ A.D.
SH RIFF'S 0 FIC
50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 · (717) 299-8200
· SHERIFF SERVICE PLEASE TYPE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPI;S.
1. PLAINTIFF/S/
Janna Leigh Mekulski 2. COURT N'UMBER
3. DEFENDANT/S/ 2 0 01 - 2 2 6 0
Brian Gregory Mekilski 4. TYPE OF WRIT OR COMPLAINT:
~ 5. NAME OF INDIVIDUAL, COMPANY, CORPORA~C., TO BE SERVED. Divorce
SE~¥E J Brian Mekulski
~-- 6. ADDRESS (Street or RFD, Apartmer!!... No., '...C4ty~~~~~...a~lP Code)
AT ~* ~e:~t Ayahs L'a~:''' Street, Marietta. PA
..~.. ~.. ....... . ................ :i-Biddle
7. INDICATE U~-'~'~'A~ ~ '~ ~ ~ OTHER ' '
Now, ~ 4 20 01 , I, SHERIFF OF ~::~!~I~:R COUNU~~._d~e~~y deputize t_.h~riff of
r;Rn(,~.~ ~- Pr County to execute thi: th cDr.., ing
to law. This deputation being made at the request and risk of the plaintiff.
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SI~RVICE: ('
Works Tuesday- Saturday ."'-'.-,.
c
0
CUMBERLAND CO
------ .______.____._.
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION. N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under
within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on
the part of such_ ~ to any ~ for any loss, destruction or removal of any such pr.._~Ol:)erty before sheriff's sale thereof.
~ 10. TELEPHONE NUMBER
PETER DALLY (724) 938-8953 4/18/01
12. SEND NOTICE OF SERVICE COPY T~) NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed)
PETER J DALLY & ASSOC '
CUMBERLAND CO SHERIFF
SPACE BELOW FOR USE OF SHERIFF ONLY -- DO NOT WRITE BELO~W THIS LINE
13. I acknowledge receipt of the writ ~ NAME of Authorized LCSO Deputy or Clerk 14. Date Received 15. Expiration/Hearing date
or complaint as indicated above. "a~ETTE WALTON 717-295-3609 5/9/01 May 17,2001
16. I hereby CERTIFY and RETURN that I~have personally served, [] have legal evidence of service as shown in "Remarks", [] have executed as shown in
"Remarks", the writ or complaint desdribed on the individual, company, corporation, etc., at the address shown above oron the individual, company, cor-
p_._~_oration, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof.
17. E]I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) -"'
18. Name and title of individual served (if not shown above) (Relationship to Defendant) 19. E1No Service
See Remarks Below (No. 30)
20. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No. City, Boro, Twp. 1~ 22' Time
State and Zip Code) , --
23. ATTEMPTS
Oep. I-T~.
24. ~sts _
R 1' ~"~9"~ 100.00 30.50 J "'~..~~u~.i:.~..~.r'. 2~ ~'.CQsts 9. COSTDU,~
30. REMARKS'
· ?,')~. so 4NSWE..~
31 AFFIRMED and subscribed to before me this _.____~/. 32. Si.nature of ~- ~' ~~
34.
Dap. ~eriff ~ 133. Date
37. ' / / , ~36. Dat
Prothonotary/ · :~--7
MY COMMISSION EXPIRES
1. WHITE - Issuing Authori~ 2. PINK - AEorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's ~ice
'-' .... *" 'S 'H RI F'S OFFIC
, 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA17608-3480 . (717) 299-8200 '
SHERIFF !SERVICE '~,,
"~"" PLEASE TYPE
PROCESS RECEIPT,-i. and AFFiDAviT OF RETURN ....
1. PLAINTIFF/S/ m'" DO NOT DETACH ANY C, oPIES..:....,~,.~..,,. ·
· £NDA~-T/S~ ..... ' ......... ..
;-,.._ .. ..... .,_.~ .... _ "'~.-"-:.:'..,' i~ .... '._' i: !'".':'..
Z--"~~~'-dF"~DIVID~&L, COMPANY CORPORATION ETC
~-' ~' ~ ,:'". ": ;"" ?.. ;~. 1; :, .~-~ :.. -; ' , ., TO BE SERVED. - ............. _
~ ,6. ADDRESS (Street or RFD, Apartment No City Boro Twp State and ZIP Cod
' AT ~~;'.'~.-.':":: ~ .... '.' :'-,. ~ ~ ..... ,, ". .... ~ ................. .'
'~ ' · ' ' · ·:. (.:'1, t' .. ~' ~.'.,~. ;.'! !o .; 1¢.,' C.? , '.~ :"'~ ~'- '-" t": .' ~ . · '
· '-~ · ~ .... .,: t, r'- ! ~'~ r"~ '. ,: '~ ~ -, ........
' '. ..... ~ , .'.-' t- .... ~.~' .-., .~ · .., . . ....
! 7. INDICATE UNUSUAL" SERVICE: [] DEPUTIZE E] OTHER '"~ 7r','-','~ .-. -,. · .... ,...; - ' ' ~ ' ~ .... "' ' '" "~' '"'
-'"- ~'~:." .": ." ~'::
i ! Now, ?..,3,... ~ 20 ..(' ~- · '1 SHERIFF oF:~,-,~~ER COUNTY, PA., do hereby deputize the Sheriff of
" ~t~ ~r°i:~ltoYft~heeX-~J .this Writ and make return thereof
ill ._ ---_ . . t.e. s.~,,,,
to law. This deputation being made at the re~lue n -
8. SPEClA e plaintiff..2. _____ ------_------ according .~-;
[ . ; · · ~: :' . ,
'~.,...., .,- ,~ ¥- f, ,..., -..-
· .: .'-- ~, ~ ;' :::-' r':. ,-'., ,: .~. ~-.~ ....-::: ,......:!? ~ ~ :...., ,!
¢'
· ~[' ~:',U:'-': i'.';., i:. '? 5~-:',.. ;~7 !;.; :"., -,
.... ,,,....-
NOTE ONLY APPLICABLE ON ~RIi' OF EXECUTION: N.B. ~AIV'"~'~~ OF'WA?CHMAN _ Any deputy sheriff levying upon or attaching any property under
within writ may leave same without a Watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without
i the part of such deputy or the eh?riff to__~ny plaintiff herein for andy toss destruction -
'~'. --- -- --- ~ " · . ., . liability on ·
:"¢4 ~ ~,..^.u.~ o, o_. re~o.a, o, ~"er,.'s.a!e ~ereo,.
'.?.
¢:; . "°"C".°'. __L_ :, ,, -' .-... ,. . ,
'i..~2. SEND NOT~C£ O~ S£RV~C£ CO~,Y ~O ~E ~) ~O5~£S~ a~LSW- T~, ar , .---.---
:.;.?':' ~:;:;? : :'", ..-...' ; ..... -"'*~i[ ,~.._ ...--& ml)l®l®d if not~c~ ~s to · -..
,. ,.... ' .......... ' ............. ..-'..~ ;'~;.O;i ' ~)e me,led)
".., ...
:'~"'"'-"*'" :,:"'"" '-, ?'. ""..' ! J': (.:L.;- :~;i;'~"¢,, 'r
.,.;
...... ~..~.. ,,
-"' .... ted above. ~ z~'-.*,N.' .,;....,r,..,~ ;..... .', ,, - ,.,..,-. ............. . ~-. ~vuo · · .
:'?:" ,.., .ere.. C...,.. a.....U.N,..:' '.ave e. ::~ ...,.a,, , a.:,
kSet(~ th_e..,wr, t o.r.complaint des ed onPth Ofa~h~*ce as shown in "Remarks", E] have executed as shown in
.-..... , ., a[ [ne address inserted below by handing, aTRUE ~ind' ~'-TTi~ED COPY tl~ere;i address shown above or on the individual, company, cor-
f 7. [] I hereby certify and return a 01'.' FOUND becaase I am unable'-;to'.locate the individual, company, corporation etc., named above. (See remarks below)
N ~' .... - .... ' '
18. Name and title of individual served:(if ~,
; " ' : See Remarks Below (No. ,30)
~!' 20'Addres~erved(c°mplet' ' ove)(~treetorRFD, partment No., City, aoro, Twp.
State and Zip Code)
AM
M~~ "' ' I '":'; .... ;'" ':' ;;'? ~':F~S.T
23. ~I'TE . ./':':; ....... ".,'
· - ..... , ; EDST
'"*'""ce °°"'
I ...... "" '.
30. REMARKS:"'~'~-~ :'"' ...... ' ,~ . r'
I "" '"; ":'"
r .''
·
S.T.A.'
-,.. .
· ~. . . .. ..
?-:i;-' ' - ' " ' ": "~" "'
,': .... ~ . .
· ...
..
;:!.'~;, · . .: ' · ........
· : ." ,,. .......
;~.;.i:_:.:,---- , __ .. .... . ... . , . .....
i:::""31. AFFIRMED and subscr, ibed to before me thi~ ~ "/ ~ ~L : : ~
; ' ;: "' ; '" ; ...... , .... '' so'~s~.-~ ""
F.-:L;.. . .. . ."
::"i",. ,a, o, ....... ;
~ -~ ~,-,,; ,-- ..¢ .:.. ~ . .- _ . . '%.,. .....~,~':.;:.:.-;~, ;'::~.
,,- ."' :.,...,; .' ; --"
-, ... -. ..... . .? . ·
MY COMMISSION EXPIRES '" ,': ...
· . · , ,,~..¢, .
1. WHITE - Issuing Authority 2. PINK - Attorney 3..'cANARy. Sheriff's OffEe 4; BLUE- Sheriff's Office ~ "'"'"iJ'"J. ~ ~E~i~ "~'
? '~ ...%. . . . . .
'...
~ .'.
-
· -..,-
3n the ~ourt of ~ommon 'l~leao o.f
· umberlanO ~ount~, 'l~enno~l~an~a
JANNA LEIGH MEKULSKI, CIVIL ACTION LAW
ACTION IN DIVORCE
Plaintiff,
VS. No. 01-2260
MARRIAGE SETTLEMENT
AGREEMENT
BRIAN GREGORY
MEKULISKI, Filed on behalf off
Plaintiff, Janna Leigh Mekulski.
Counsel of record for this party:
Defendant.
PeterJ. Daley & Associates, P.C.
PeterJ. Daley II, Esquire
218 Wood Street
California, Pennsylvania 15419
Phone: (724) 938-8953
Facsimile-(724) 938-8959
Atty. I.D.//62925
JANNA LEIGH MEKULSKI, · IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, · CUMBERLAND COUNTY, PENNSYLVANIA
·
· CIVIL ACTION - LAW
vs. . ACTION IN DIVORCE
BRIAN GREGORY MEKULSKI, '
·
Defendant. ' No. 247 of 2000-C
lf~arria~te ~¢~tlement ~~ireement
THIS AGREEMENT made this ~0'~'~ay of' ~~/~/~-~ 2001,
at Cu~bed~nd County, Pennsylvania, between Jann~Lei~~Mekuls~,
hereinafter referred to as ,,~~,,
n
Brian Gregory Mekulski, hereinafter referred to as "HUSBAND"
WITNE$$ETH:
WHEREAS, the parties hereto are Husband and Wife, having been
married on August 8, 1998; and
WltE~, unhappy differences have arisen between the parties, and as a
result they have lived separate and apart since February 27,2001; and
WHEREAS, a proceeding for the divorce of the parties has been filed by the
Wife in the Court of Common Pleas of Cumberland County, Pennsylvania at the
above number and term and served on the Defendant, Brian Gregory Mekulski, on
May 10, 2001; and
WHEREAS, it is the desire and intention of the parties to live separate and
apart for the rest of their natural lives, and the parties hereto are desirous of settling
fully and finally their respective financial and property rights and obligations as
between each other, including without limitation: (1) the settling of all matters between
them relating to the ownership of real and personal property; (2) in general, the
settling of any and all claims and possible claims by one against the other or against
their respective estates.
NOW, THEREFORE, in consideration of the mutual covenants herein
contained, and intending to be legally bound hereby, the parties agree as follows'
1. AGREEMENT PREDICATED UPON DIVORCE. It is specifically
understood and agreed by and between the parties hereto and each of the said parties
does hereby warrant and represent to the other that, as defined in the Divorce Code,
their marriage is irretrievably broken. The parties agree to take all legal steps
(including the timely and prompt submission of all documents and the taking of all
actions) necessary to assure a divorce pursuant to Section 3301 (c) of the Divorce Code
is entered as soon as possible. To that end, the parties agree to execute and promptly
file affidavits of consent required to obtain a divorce pursuant to Section 3301 (c) of the
Page 2 of Il
Divorce Code within ten (10) days of the execution of this Marriage Settlement
Agreement. The parties agree to waive any notice required under the Pa. Rules of
Civil Procedure, or under local rules. Husband shall be responsible for the prompt
filing of the Praecipe to Transmit the Record.
2. ADVICE OF COUNSEl. Wife has been represented by PeterJ.
Daley II, Esquire, of PeterJ. Daley & Associates, P.C. Husband has chosen not to
retain legal counsel and Husband has chosen instead to negotiate directly with Wife
and Wife's counsel, notwithstanding the fact that counsel for Wife has advised him
that he has an absolute fight to be represented by counsel. Husband hereby
acknowledges that he has done so willingly and that he fully understands the relevant
law (including having reviewed the Divorce Code). Both parties acknowledge that
they are familiar with and fully understand the relevant law and relevant facts,
including the asset, liabilities, income [and expenses] of the other party, and that each
is fully aware of his or her rights and obligations. Each party represents that he
or she understands that, in the absence of this Agreement and as a matter of law:
(1) as a surviving spouse, he or she might be entitled to a greater share in the
decedent's estate than is provided for in this Agreement; and (2) as a separated and/or
divorced spouse, he or she might be entitled to greater support, maintenance, alimony
pendente lite, counsel fees, costs, alimony, distribution of property, or other financial
benefit arising from the marital relationship than is provided for in this Agreement.
Page 3 of II
dffre °Wled~e 'each o£,. -e £Oreffo'
~ol ernent is ~ ' ao~ a~ the Dartie_ _ ~og, the ~
'°otarib. ta~r, ~e~ ct ha~_ s th~ther ~~Oes
tbeit o,.._ ~~,~ % e~loSio~ ~_ ~t ~ts e~eeoti ,t ~t ~s bei,~celblly and
'~ Co~,~ ~~I_ ~ ~Od/o~ . ~o~ &_ "g e~t° ~Oll~
er& Se~ ~~o 'os ~. e re
~ero U th ori,_ aDa rt - °sba~ ~ eedi~ ~ ~ ~a v~
O theh. sable >, Ccopatio,~ ePamte. Pectsas~,,'
. cart of . ' ~ als % '" Pro~_ . Use or ~ ~Yas i
to, Or res.. e ther N, ' . O~sio~ sa - ~io~ Oe e "enefit, c rShe
VPe/or _ ~ ~storh or~ ~°ation of ,~ °f tbe un, c~, hO~ev¢ ~O~ch to
artec,. ,aalivn ~neir li. ~ ~a~ulv % to b~
whatso~ w- to co~_ o, each ot~ ~nff apa~' "ess of t~ c an
~ent o~ ~th hi~ e Other ~ the res~ qSbaod~ ~Ses
~ ' °t~er k Or her ~. o c%abi, ~ective~~ ~o~ ~~
~*o~ oosin_ ' ~ Vei,~ · or ~._ ~ilios
~crtY~ow~ ',cas actiD~' "'erpart.. . ~weYbya~ ~ °lbacb
~~ed or her~ ~~' or ~h ~;hall '~ter~ y~ea°s °r
catie~ac~ t~e OSe ,e ~ith ,~
~e~ ? th
4 of e o ~ o~
~ ~ ther.
5. ,- · Each part hereto r
the other · . ..
~rom all clmms, habd~ties, debts, obli,~ation .... , . y eleases
~ ~, ~tcuons, anc~ causes of action
of every kind that have been incurred relating to or arising from the marriage between
the parties. However, neither party is relieved or discharged from any obligation
under this Agreement or any other instrument or document executed pursuant to this
Agreement. ·
6. WAIVER OFESTATE CLAIM. Except as otherwise herein provided,
each party hereby waives, releases, and relinquishes any and all fights that he or she
may now have or may hereafter acquire as the other party's spouse under the present
or future laws of any.jurisdiction. (a) to elect to take against any will or codicil of the
other party now or hereafter in force; (b) to share in the other party's estate in case of
intestacy; (c) to act as executor or administrator of the other party's estate.
7.
warrants to the other that he or she has not incurred an~ Each party represents and
will not incur any debts,
obligations or other liability, other than those already described in this Agreement, on
which the party is or may be liable. Each party covenants and agrees that if any
claim, action or proceeding is hereafter initiated seeking to hold the other party liable
of any debt, obligation, liability, act or omission of such party, such party will, at his
or her sole expense, defend the other against any claim or demand, whether or not
well founded and that he or she will indemnify or hold harmless the other party in
respect to all damages resulting therefrom.
Page 5 of II
Each party agrees to indemnify or hold the other party harmless from
and against all obligations of any k/nd incurred by them by prev/ous COnduct, and for
all fUture actions or °bligations, pursuant to the terms of the w/thin Mar/tal Settlement
Agreement.
8. ~. The parties hereto each COvenant, warrant, represent
and agree that each will now, and at all times hereafter, save harmless and keep the
other indemnified from all debts, charges, liabilities incurred by the other prior to or
after the effective date of this agreement, except as otherw/se specilically provided for
by the terms of this Agreement.
and COmplete d~ · Each party asserts that
£ull 'sclosure o,~ .. he o
t all of the real an-~ - r o,,c has made a
nature and wheresoever located belong/ng in any way to each of them, of all debts
~' personal property of whatsoever
and encumbrances incurred in any manner whatsoever by each of them, of all SOurces
and amounts °fincorne received or receivable by each part, and of every other fact
relatingin any way to the subject matter of this Agreement. These disclosures are part
of the Consideration made by each party for entering into this Agreement.
to be void If anyProvision of this Agreernen '.
or unenforceable, all of the other nr ,,;-:_ _ tis held
continue in full force and effect. '- °~'a~°ns tiereof shall nevertheless
Page 6 of I I
· ~' ~~~~r~ON_OFoT _
demand execute any oth~NT$. Each .party shall on
' uOCUments that may be necessa~ or
the pro~sions of this Agreement. ad'sable to carry out
12. ~
agreement o~the parties and there are n~ This instrument contains the entire
representa6ons, warranties, COvenants, or
underta~ngs other than those expressly set forth herein.
of the pro~sions of thio ~-- ~. A modi~cation or Waiver of any
~ agreement shall be effective only if made in writing and
executed by both parties Mth the same formality as this
either party to insist upon strict performance of anyAgreement' The failure of
of the pro~sions of this
Agreement shall not be construed as a W~ver of any subsequent default of the same
or similar nature, and either party, or their estates or heirs, shall have the right, by suit
or Othe~se, in law or in equity, to enforce this Agreement.
become ffec · This Agreement
Agreement. parties as of the date of execution of ~11
this
othe CE DEC~E .
.... ~u hereto, this Agreement s
effect after such time as a final decree in divorce may be entered. Husband and Wife
agree that the terms of this Agreement shall be incorporated into any diVorce decree
Page 7 of II
which may be entered with respect to the parties. The parties further agree that the
Court of Common Pleas which may enter such divorce decree shall retain continuing
jurisdiction over the parties and the subject matter of the Agreement for the purpose
of any enforcement of any of the provisions thereof.
16.
If either party shall default in the performance of any of the provisions of the'
Agreement, and if the other party shall institute a legal proceeding to enforce the
performance of such provisions by the defaulting party, then the defaulting party shall
pay to the other party the costs and expenses incurred by the other party, including
reasonable attorney's fees, in connection with such proceeding. The provisions of this
Article shall be in addition to and without prejudice to any other rights and remedies
to which the aggrieved party may be entitled.
17. GO~VERNING LAW. This Agreement shall be constru
accordance with the laws of the Commonwealth °fPennsylvania which are in ed in
as of the date of execution of this Agreement. effect
18. H~ING$. Any headings preceding the text of the paragraphs hereof
are inserted solely for convenience or reference and shall not constitute a part of this
Agreement, nor shall they effect its meaning, construction, or effect.
19.
Page 8 of I I
a. Personal Property Except as herein provided, all personal
property now in the possession or control of the Husband shall be the sole and
exclusive property of the Husband, and all personal property now in the possession
or control of the Wife shall be the sole and exclusive property of the Wife.
b. MOtor Vehicles The parties hereto agree that Wife shall retain
the 2000 Ford Explorer, and Husband shall waive any and all interest he may have
to said vehicle. Husband shall retain the 2001Jeep Wrangler, and Wife shall waive
any and all interest she may have to said vehicle
· ·
20. ~~_]_0~~. The parties hereto forever waive any and all interest
and rights he or she may have in the other party's pension or pensions or employment
benefits through their respective employment during the course of the marriage. The
parties acknowledge that they have each fully disclosed their respective pension
information and employment bene/its through their respective employment.
21. ~~T_.I_~. The parties acknowledge that they have been
separately advised by their respective attorneys that there may be certain tax
consequences pertaining to this Agreement, that neither attorney has furnished tax
advice with respect to this agreement, that each party has been directed and advised
to obtain independent tax advice from qualified tax accountants or tax COunsel prior
to signing the agreement and that they have had the opportunity to do so.
Page 9 of II
22. AT.TMONY, AI.TMONY PENDENTE LITE, SPOUSAL
SUPPORT, COUNSEL FEES AND COSTS AND ANY AND AT.I. RIGHTS
PROVIDED BY THE DIVORCE CODE OF PENNSYLVANIA OR ANY
OTHER RIGHTS BASED ON ANY OTHER LAW OR SOURCE. Thc
·
hereto hereby agree to waive the fight to seek Alimony, Alimony Pendente Lite,
Spousal Support, Counsel fees and costs and further waive any and all rights or
privileges provided by the Divorce Code of Pennsylvania or any other fights based on
any other law or source forever.
IN WITNESS WHEREOF, the parties, intending to be legally bound hereby,
have hereunto set their hands and seals on this Agreement the day and year first
above written.
WIT't
'"~' ( ~/-/d~ SIGNED'
~/~~ - 0 yANNA LI~IGHt MEKULSKI,- '
WIFE
HUSBAND
Page I0 of I I
· COMMONWEALTH OF PENNSYLVANIA .
C 0 UNTY OF ~,,~
AND NOW, this.,~~ay of,4 ,2001, before me, the undersign fficer,
personally appearedJa~l~la Lelg]l l~IeIl~own to me (o ~--:~,' ..... ed o
person whose name is subscribed to the within Marriage Settlement Agreement and acknowledged
v r ~',u~ac~only proven) to be the
the same to be her act and deed and desired the same to be recorded as such.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA .
C 0 UNTY' OF ~.
AND NO.W, this~ day of ,' . ,2001, before
personally appeared I~ria~l Gre~'o~.,, ~~ me, the undersigned officer,
be the person whose name is subscribed to the within Marriage Settlement Agreement and
c, -a' "x~alll~ki~ known to me (or satisfactorily proven) to
acknowledged the same to be his act and deed and desired the same to be recorded as such.
IN WITNESS WHEREOF, I hereunto set my hand and ofticial sea/.
·
My Commission Expires:
Page II of' II
~.~. · ,~ ..
· ? ~'. ~ .:.',
~. ~'. '.:.... : .
-..
,?. ~,-"'~ ~.-:'-, · .
.-2---" '"':- "'~'2 .
-~..:.'., ~. ....
In the Court of Common Pleas of
Cumberland County, Pennsylvania
JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW
ACTION IN DIVORCE
Plaintiff, NO. 01-2260
AFFIDAVIT OF CONSENT
vs. Filed on behalf off
Janna Leigh Mekulski, Plaintiff.
BRIAN GREGORY Counsel of record for this party:
MEKULSKI,
PctcrJ. Daley & Associates, P.C.
218 Wood Street
California, Pennsylvania 15419
Defendant. Phone' (724)938-8953
Facsimile: (724) 938-8959
PeterJ. Daley II, Esquire
Atty. I.D. # 70244
! !
JANNA LEIGH MEKULSKI, · IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, 'CUMBERLAND COUNTY, PENNSYLVANIA
VS.
· CIVIL ACTION - LAW
BRIAN GREGORY MEKULSKI, · ACTION IN DIVORCE
Defendant. · No. 01-2260
Affidavit of Consent
1) A Complaint in Divorce under Section 3301 (c) of the Divorce
Code was filed on April 18, 2001.
2) The marriage of the 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: t~" "l'~ ~I ~U~L~~
In the Court of Common Pleas of
Cumberland County, Pennsylvania
JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW
ACTION IN DIVORCE
,
Plaintiff, NO. 01-2260
WAIVER OF NOTICE
vs. Filed on behalf off
Janna Leigh Mekulski, Plaintiff.
BRIAN GREGORY Counsel of record for this party:
MEKULSKI, PeterJ. Daley & Associates, P.C.
218 Wood Street
California, Pennsylvania 15419
Phone' (724) 938-8953
Defendant. Facsimile: (724) 938-8959
PeterJ. Daley II, Esquire
Atty. I.D. # 70244
JANNA LEIGH MEKULSKI, · IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, 'CUMBERLAND COUNTY, PENNSYLVANIA
VS. ·
· CIVIL ACTION - LAW
BRIAN GREGORY MEKULSKI, · ACTION IN DIVORCE
Defendant. · No. 01-2260
Waiver of Notice of Intent to Request Entry of
Divorce Decree Under Section 330I(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 with 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 su~bject to the penalties of18
PA C.S. § 4904 relating to unswor,~ falsification to authorities.
~~ A LE~GH M~KULSKI
In the Court of Common Pleas of
Cumberland County, Pennsylvania
JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW
ACTION IN DIVORCE
Plaintiff, NO. 01-2260
AFFIDAVIT OF CONSENT
VS.
Filed on behalf off
Brian Gregory Mekulski, Defendant.
BRIAN GREGORY
MEKULSKI, Counsel of record for this party:
Defendant.
JANNA LEIGH MEKULSKI, ' IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, 'CUMBERLAND COUNTY, PENNSYLVANIA
VS.
· CIVIL ACTION - LAW
BRIAN GREGORY MEKULSKI, · ACTION IN DIVORCE
·
Defendant. · No. 01-2260
Affidavit of Consent
1) A Complaint in Divorce under Section 3301 (c) of the Divorce
Code was filed on April 18, 2001.
2) The marriage of the 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.
In the Court of Common Pleas of
Cumberland County, Pennsylvania
JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW
ACTION IN DIVORCE
Plaintiff,
NO. 01-2260
vs. WAIVER OF NOTICE
Filed on behalf off
BRIAN GREGORY Brian Gregory Mekulski, Defendant.
MEKULSKI, Counsel. of record, for this party:
Defendant.
JANNA LEIGH MEKULSKI, · IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, 'CUMBERLAND COUNTY, PENNSYLVANIA
VS. ·
· CIVIL ACTION - LAW
BRIAN GREGORY MEKULSKI, · ACTION IN DIVORCE
Defendant. · No. 01-2260
Waiver of Notice of Intent to Request Entry of
Divorce Decree Under Section 330I(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 with 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 1
PA C.S. § 4904 relating to unsworn falsification to authorities.
Date'
BRIAN Gi~ZGORY MEKULSKI
3n the ~ourt of ~ommon 'l~leao of
· umberlanO ~ount~, 'l~enno~loania
JANNA LEIGH MEKULSKI, CIVIL ACTION - LAW
ACTION IN DIVORCE
Plaintiff, No. 01-2260
AFFIDAVIT OF NON-
vs. MILITARY SERVICE
Filed on behalf of:
Plaintiff, Janna Leigh Mekulski.
BRIAN GREGORY MEKULSKI, Counsel of record for this party:
Peter J. Daley and Associates, P.C.
Peter J. Daley II, Esquire
Defendant. 218 Wood Street
California, PA 15419
Phone' (724) 938-8953
Facsimile: (724) 938-8959
Atty. I.D. ~ 70244
JANNA LEIGH MEKULSKI, · IN THE COURT OF COMMON PLEAS
· OF
Plaintiff, · CUMBERLAND COUNTY,
: PENNSYLVANIA
vs.
: ACTION IN DIVORCE
BRIAN GREGORY MEKULSKI, :
: No. 01-2260
Defendant. :
COMMONWEALTH OF PENNSYLVANIA ·
COUNTY OF WASHINGTON '
Personally appeared before me the undersigned, a Notary Public in and for
said County and State, Peter J. Daley II, Attorney for the Plaintiff and duly authorized to
execute this affidavit, and states that the affiant knows of his own knowledge the Defendant
herein to wit: Brian Gregory Mekulski, is not in the military service as defined in the
Solders' & Sailors' Relief Act of 1940 and Amendments there to for the following reason:
Defendant currently resides at 707 Apple Drive, Mechanicsburg, Pennsylvania.
Affiant fimher says that the obligation sought to be enforced in this suit is
not an obligation against a surety, guarantor, end ther person liable, primarily or
secondarily, for a part in the military service.
s._~-_--ibed
Sworn
and
to
before/~e this ~/' "day
of~/~, 200/.
. .
n:' ~... "
:,~, .- ,.\,'
....
NOTARY PUBLIC Notarial Seal - '!
I Julie w~"s't~'iTNbtary public _
My commission expires' Bore, Washington County
~mbor, ~,nnsyhtania ^ssociatm ol
G:\CtA~NT$~/~kul~ki, JannaL~igh\Non-Milita~ ^ffida¥it.wpd
3n tl~e ~ourt of ~ommon *l~leao
· umberlan~ ~ount~, 'l~enno~l~an~a
_
·
,
]ANNA LEIGH MEKULSKI, CIVIL ACTION - LAW
ACTION IN DIVORCE
Plaintiff, No. 01-2260
PRAECIPE TO TRANSMIT
vs. RECORD
Filed on behalf of.'
Plaintiff, Janna Leigh Mekulski.
BRIAN GREGORY MEKULSKI,
Counsel of record for this party:
Peter ]. Daley and Associates, P.C.
Peter .l. Daley II, Esquire
Defendant. 218 Wood Street
California, PA 15419
Phone: (724) 938-8953
Facsimile. (724) 938-8959
Atty. I.D. # 70244
JANNA LEIGH MEKULSKI, ' IN THE COURT OF COMMON PLEAS
o
OF
Plaintiff, · CUMBERLAND COUNTY,
· PENNSYLVANIA
VS. .
· ACTION IN DIVORCE
BRIAN GREGORY MEKUI,SKI, ·
' No. 01-2260
Defendant. ·
'l raecipe to e ranamit I ¢cor
To the Prothonotary:
Sir or Madam:
Kindly transmit the record, together with the following information, to the
court for entry of a divorce decree.
1. Ground for divorce: irretrievable breakdown under DRC § 3301 (c).
2. Date and manner of service of the complaint. May 22, 2001, personal
service by the Sheriff of Cumberland County.
3. Date of thc execution of thc affidavit of consent required by DRC §
3301 (c). by plaintiff, September 9, 2001, by defendant, October 23,
2001.
4. Related claims pending: None.
.
5. Date of Plaintiff's Waiver of Notice in §3301 (c) divorced was filed
(a): by plaintiff, September lff~. 0 , by defendant, November
15, 2001.
Atto:
~n the ~ourt of ~ommon
~aobin~ton ~ount~,
JANNA LEIGH CIVIL ACTION - LAW
MEKULSKI,
ACTION IN DIVORCE
No. 01-2260
Plaintiff,
AFFIDAVIT OF SERVICE
VS.
Filed on behalf off
Plaintiff, Ianna Leigh Mekulski.
BRIAN GREGORY
MEKULSKI,
Counsel of record for this party:
Peter J. Daley & Associates, P.C.
Peter J. Daley II, Esquire
Defendant.
218 Wood Street
California, PA 15419
Phone' (724) 938-8953
Facsimile' (724) 938-8959
Atty. I.D. #70244
IANNA LEIGH MEKULSKI, · IN THE COURT OF COMMON PLEAS
· OF
Plain~, ' WASHINGTON COUNt,
. PENNSYLVANIA
VS.
BRIAN GREGORY MEKULSKI, ' CML ACTION - LAW
· ACTION IN DIVORCE
Defendant. '
· No. 01-2260
.' ffiO x, it of ¢rx, ic¢
COMMONWEALTH OF PENNSYLVANIA '
COUN~ OF WASHINGTON '
Before me, the undersigned authority, personally appeared, Peter J. Daley II,
Attorney At Law, who says that he has this 10~ day of May, 2001, caused a true and correct
copy of the foregoing Complaint in Divorce to be served upon the Defendant, Brian
Gregory Mekulski, at his place of employment at Wyctt Ayers Laboratories, 206 North
B iddle Street, Marietta, Pennsylvania, by Deputized/Servi through Lancaster County,
Pennsylvania, evidenced by the Sheriffs Return :hed hereto.
:y for~ laintiff
Sworn to and subscribed
.. ~"~.
before me this //q~/~ day
of December 2001.
. .:
· . .~.... ,..
~ t?". ~j~.'~:"%71 .,,'~ ."
· % X :~ ............'"N'"
/N~ary Public % e ,~2 .,.. -~\ ,,,'
My Commission Expkes' '?-
·
SHERIFF'S OFFICE
; 50 NORTH DUKE STREET, P,O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 ° (717) 299-8200
SHERIFF SERVICE ~ PLEASE TYPE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN I DO NOT DETA__C_H ANY C PIES.
2 COURT NUMBER
1. PLAINTIFF/SI I 2 0 0 ]-- 2 2 6 0
Janna Leigh Mekulski ~RIT O'R~PLAINT
3. DEFENOANT/S/ I D iv O r c e
Brian Gregory Mekilski
5. NAME ~AL, COMPANY. CORPORATI~:' TO BE SERVED.
,
6. ADDRESS .(Street or RFD, Ap~rtme~t.-;N6;ii:,.'cit¥:'''.~~p~';' 'S'':'tate'; an~l Z::IP .Code)
~ERVE ~_ Brian Mekulski ~'"6:! .
W~e..~:i..[.:.:...A.y..e..rs.....:L.~b,.~;~.~!~i~:~..:.i~,.~;,i .?i:.~i!:..,.-Bi.dd:i.e.-.' Street, Marietta, PA.
AT '.,-::..' ..... .'. "- ' ..... ' "~':::-" '" """ "'"""'": ......... :'" ' .......
7. INDICATE UNUSUAL' SERvIcE~ ~ ~ ~ oTHER ' ' ~']-]'iTI~T' ~
he deputize the~,S._,i3,eriff 3f
--~ow Ma_Y 4 -- 20 01 ,, SHERIFF OF ~E[R co. U.N..TY,,.P.~v,~~Y~,,t.r~
' __ County to execute tn~;lll~'~ ~ ~"~~~'
-~'--~"~ t~; ~ and risk of the pla,nt,ff. ~ "" SHERIFF bFLANCAS¥.~.I~ COUNTY
~o law. This deputation being made at VICE:
...
Works Tuesday- Saturday
CUMBERLAND CO ___ sheriff levying upon or attaching any property under,
...-.---------- without liability on
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy ,
iafter may leave same without a watchman in custody of whomever is found in possession, notifying person of levy or attachment.
r removal of any such property before sheriff's sale thereof·
' . . · destruction o ~N~i--
· DATE [writ
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BE~ ~ ~r~ ~ be completed if ~ is to be mailed) PETER J D~EY & ASSOC
CUMBERL~D CO SHERIFF
· SPACE BELOWFOR USE OF SHERIFF ONLY -- D'~<WRIT'E BELOW THIS LINE~
.... ' ~ ~C~' Exgiration/Hearing
' ' NAMEof Authorized LCSO Deputy °r Clerk 1 5/9/01 [May~ 17 , 200
13. I acknowledge receipt of the writ }
or complaint as indicated ab°ve' ~ETTE WALTON 717-295-3609
ed Q have legal evidence of sewice as shown in Remarks", ~ have executed as shown in
N [hat.have personally sew , · at the address shown above or on the individual, companY, cor-
I hereby CERTIFY ~nd RE~R on the individual, company, corporation, etc.. [,
16. "Remarks", the writ or complaint des ed
poration, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof. . , arks below)
,
17 ~ I hereby cedify and return a NOT FOUND because I am unable to locate the individual .company, corporation etc., named above (See re~
18. Name and title of individual served (if not shown above) (Relationship to Defendant) 19. ~No Sewi~ .
' . ' ~ Remake BeI~ (No. 30)
20 Address~fwherese~ed~c~mp~ete~n~Yifdifferentthansh~wnab~ve)(~treet~rRFD~Apa~mentN~City~B~r~Twp~ ~ . Date of
State and Z,p Code)
~s~ --~~ Se~ice C0sts 26. Nota~ ~er'. !~ ........ -~. -;;;~-~
o0.oo .
I
"-
. I ' ..
,.
SO ANSWER.
D/ _ -
~.
,~y COMMISSION EXPIRES
INTHE COURT OF COMMON PLEAS
C..-F CUMBERLAND COUNTY
ST/~.~E OF ,~~, ~~ PENNA.
Janna Leiqh Mekulsk~
NO. _0~-2260
VERSUS
I
Br~an Gte or Mekul k'.____
DECREE IN
DIVORCE
DECREED THAT ,T;ann;=, T_,e~h -~_gk,_,!sk! __, PLAINTIFF,
AND______Br~an Gre or Mekulsk~ , DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THiS ACTION f'or WHiCh A FINAL ORDEr HAS NOT
YET BEEN ENTERED;
BYThE C
PROTHONOTARY