HomeMy WebLinkAbout01-2895STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: NO. O{ -- o
DANIELLE M. KORNBLUM, : IN DIVORCE
Defendant :
NOTICE TO DEIrEND ~ 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 ir~ttlevable breakdown of the mm'riag¢, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at:
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA~ER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE PdOHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LA~/ER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE ~ OFFICE SET
FORTH BELOW TO FIND OUT ¥~-IERE YOU CAN GET LEGAL HELP.
Cour~ Administrator
4th Floor, Cuml~rland County Courthouse
Cnrllal~ PA 17013
(717) 240-6200
STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.'
: CIVIL ACTION - LAW
V.
: NO. .zPqg'
.'
DANIELLE M. KORNBLUM, : IN DIVORCE
Defendant :
COMPLAINT UNDER SECTION 3301{e} OR SECTION 3301{d}
OF THE DIVORCE CODE
1. Plaintiff is Stephen M. Komblum, who currently resides at 388 Crossroads School Road,
Newville, Cumberland County, Pennsylvania, since June, 1996.
2. Defendant is Danielle M. Komblum, who currently resides at 619 North East Street, Apt. 2,
Carlisle, Cumberland County, Pennsylvania, since June, 2000.
3. Both Plaintiffand Defendant have been bonn fide residents h~ the Commonwealth for at least
six months immediately previous to the filing of this Complaint.
4. The Plaintiffand Defendant were married on September 10, 1994 at Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiffhas been advised that counseling is available and that Plaintiff may have the right to
request that the court require the parties to participate in counseling.
g. Plaintiffrequests the court to enter a decree of divorce.
Supreme Court I.D.
1
ANTHONY T. McBETH '. ·,
VERIFICATION
I, Stephen M. Komblum, Plaintiffin the foregoing action, verify that the facts set forth in the
attached document are true and correct to the best of my knowledge, information and belief. I so
state subject to the penalties of 18 Pa. C. S. §4904 (relating to unswom falsification to a/~ rities).
Date Ste~n' M. Kornblum t~
STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
plaintiff : CUMBERLAND COUNTY, pENNSYLVANIA
CIVIL ACTION - LAW
DANIELLE M. KORNBLUM, : IN DIVORCE
Def~Aant :
AlqqlOAVIT O1~ SERVICE pURSUANT TO PA. R. CIV. P. 405
I, Antimny T. McBeth, Esq., attorney for the Plaintiffin the captioned action, hereby swear
that I have served the Complaint upon the Defendant in the captioned action by wailing a certified
copy of same to her addressed as follows: Danielle M. Komblum, 619 North East Street, Apt. 2,
Carlisle, PA 17013. Said mailing was by first class mail, postage prepaid, certified, return receipt
requested. Said mailing was effected on May 16, 2001.
The return receipt, purportedly bearing the signature of the Defendant, and showing a delivery
date of Mayl 9, 2001, is attached hereto, marked Exlu'bit "A'' and incorporated herein by reference.
COMMONWEALTH OF PENNSYLVANIA .'
: SS:
COUNTY OF DAUPHIN '
sworn and sub~ribed before me this ~/'~/da~ of ~' ,2001.
My commissions expires:
2
Ir ANTHONY T. McBETH
so that we can return the card to you.
· Attach this card to the hack of the rr~llplane,..
or on the f~ont if npace permits. ' '
'~~ !t 'ff YES, enter ¢Jelively eddnlas below: [] No
ri/ , .. .~.,,...,.
4. Restricted Delivery? ~.xtra Fee) [] Yes
Exhibit "A"
STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
V. "
: NO. 01-2895 Civil Term
:
DANIELLE M. KORNBLUM, : IN DIVORCE
Defendant :
AFFIDAVrr OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 14,
2001.
2. The nmriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce aider service of notice of intention to
request entry of the 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 P8.C.S. §4904 relating to ufLsworn
falsification to authorities.
Date
STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
V.
: NO. 01-2895 Civil
:
DANIELLE M. KORNBLUM, : IN DIVORCE
Defendant :
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER ~3301fc~ 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 fights concer~ino~ alimony, division of property, lawyer's iL-es or
expenses ifI 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 ~,,,uedi~tely after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that false
statenvznts be~in are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom
falsifications to authorities. ~ ~ ~/,~
D /70t
STEPHEN M. KORN-BLUM, : IN THE COURT OF COMMON PLEAS OF
plnlntiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
V.
: NO. 01-2895 Civil Term
:
DANIELLE M. KORNBLUM, : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 14,
2001.
2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elnpsed
from thc date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce aiter service of notice of intention to
request entry of the divorce.
I verify that the statements made in this at~xlavit are true and cmTect. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
falsification to authorities.
Date Dnmelle M. Kornblum, Defendant
STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
V. '
: NO. 01-2895 Civil Term
:
DANIELLE M. KORNBLUM, : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER $3301fe) OF THE DIVORCE CODE
I. I consent to the entry ofa fi~l decree ofdivorec without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses ifl do not claim them before a divorce is granted.
3. I understand that ! will not he divorced until a divorce decree is entered by the Court and that
a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unswom
falsifr~tiom to authorities.
· .\\M,~l~l, SERVER\PUBLIC~rogcr\Fa~nily Law~divorce~Kornblum Divorce\Entry of Appcarancc. doc.doc ·
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
STEPHEN M. KORNBLUM, ::
Plaintiff :: CIVIL ACTION--LAW
::
vs. :: NO. 01-2895 CIVIL TERM
::
DANIELLE M. KORNBLUM, :: IN DIVORCE
Defendant ::
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance for the Defendant in the above matter.
Roger M. Morgenthal, Esquire
I.D.# 17143
FISHMAN & MORGENTHAL
95 Alexander Spring Road, Suite 3
Carlisle, PA 17013
(717) 249-6333
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
STEPHEN M. KORNBLUM. :: CIVIL ACTION--LAW
Plaimiff ::
::
vs. :: NO. 01-2895 CIVIL TERM
::
DANIELLE M, KORNBLUM, ::
Defendm~t :: IN DIVORCE
NOTICE OF INTENTION TO RETAKE PRIOR NAME
Notice is hereby given that the Defendant in the above matter, in which a Final
Decree in Divorce was entered on the I st day of October, 2001, hereby elects to retake
and hereafter use her previous name of DANIELLE M. MARPOE and gives this written
notice avowing her intention in accordance with the provisions of the Act of December
16, 1982, P.L. 1309, 54 Pa. C.S. § 704.
DANIELLE M. I~ORNBLUM
TO BE KNOWN AS:
' -- DANIELLE M. MAPdCOE/-
Sworn to and subscribed before me this c{ ~ day of ~ l'~ff~ ,2001.
Notary Public
Nolafial Seal
Roy G. Poo~. Ncl~,r,~ Public
POST-NUPTIAL AGREEMENT
AGREEMENT made this day, 2001, by and between
STEPHEN M. KORNBLUM (hereinafter called Hushand~ and DANIELLE M. KORNBLUM
(hereinafter called "W~e").
WITNESSETH:
WHRREAS, the Parties hereto are Husband and Wife, having been married on September i 0,
1994, at Carlisle, Cumberland County, Pennsylvania.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
Parties and it is the intention of Hushand and Wife to live separate and apart for the rest of their
natural lives, and the Parties hereto are desirous of settling fully and finally the respective flnencial
and property rights and obligations as between each other, including without limitation:
1. Tbe settling ofall matters between them relating to ownership and equitable distribution
of real and personal property;
2. The settling of all matters between them relating to past, present and future support,
alimony and/or maintenance of Hushand by Wife or Wife by Husband;
3. In general, tbe settling ofany and all claims and posm~oie claims bY ona agaiust tbe other
or against their respective estates.
NOW THEREFORE, h consideration of the premises and of the mutual promises,
covenants and undertakings hereinatter set forth, and fi)r other good and valuable consideration,
receipt of which is hereby acknowledged by each of the Parties he.to, Husband and W'd'e, each
intending to be legally bound hereby, covenant and agree as follows:
1. AGUg. lr. MENT NOT PREDICATED UPON DIVORCE: It is specifically
understood and agreed by and between the Parties hereto, and each of thc Parties does hereby
wammt and rgprcsent to thc other that thc execution and delivery of this Agreement is not predicated
upon nor made subject to any Agreement for the institution, prosecution, defense or for the non-
prosecution or non-dcfens~ of any action t~r divorce; provided, however, that nothing contained in
this Agreement shall prevent or preclude either oft. he Parties hereto from commencing, instituting
or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and
proper grounds, nor prevent either party from defending any such action which may be, has been, or
shall be instituted by the other Party, or from making any just or proper defense thereto.
NotwithstapAing the above, a material term of this agreement is the Parties' mutual promises to
cooperate fully, and to execute all documents necessary, to finalize thc divorce recently instituted by
Husband, namely Kornblum v. Kornblum, Cumberland County, Pennsylvania, Court of Cow,~on
Pleas, Case No. 01-2895 Civil Term. Thc Parties further agree that they shall execute all necessary
documents for fumiization of the said divorce contemporaneously with their execution of this
Agreement.
2. EFFECT OF DIVORCE DECREE: The Parties agree that unless otherwise
specifically provided herein, this Agreement shall continue in full force and effect after such time as
a final decree in divorce may be eotered with respect to the Parties.
3. AGI~V.V. MENT TO BE INCORPORATED INTO DIVORCE DECREE: Thc
Parties agree that the terms of this Asree~ shall be incorporated but not merged into any Divorce
Decree which may be entered with respect to them.
4. ADVICE OF COUNSEL: The provisions of this Agreement are intended to effect
a legally b/nding property settlement between the Parties. Hushuxl has been represented by
Anthony T. McBcth, Esquire, and W'de is represented by Roger M. Morgenthal, Esqu/re. Each party
acknowledges that he or she fully understands the facts and has been fully informed ss to his or her
legal fights and obligations, and each pa~ acknowledges and accepts that this ~ is fair and
equitable, that it is being entered into freely and voluntarily, and that this Agreement ami the
execution thercof is not the result of any duress, undue influence or collusion.
5. INTERFERENCE: Each par~ shall he free from all con~l, restraint, imerf~
or authority, direct or indirect, by the other h all respects ss fully ss if he or she were unmarried.
Each may reside at such place or places as he or she may select. Each may, for his or her separate
use or henefit, conduct, carry on or engage in any business, occupation, profession or etrq~loyrnent
which to him or her may seem advisable. This provision shall not he t~kcn, however, to he an
admission on the part of either Husband or Wife of the lawfuincss of the causes which led to, or
resulted in, the continuation of their living apart. Husband and Wife shall not molest, harass, disturb
or malign each other or the respective families of each other, nor in any way interfere with the
peaceful existence, separate and apart from the other, nor compel or attempt to cotrq~el thc other to
cohabit or dwell by any means or in any manner whatsoever with him or her.
6. MUTUAl, RELEASE: Husband and Wifo each do hereby mutually r,.m/se, relesse,
quit claim, and tbrever discharge the other and the estate of such other, for all thne to come, and for
MI purposes whatsoever, of and from any and all rights, tries and interests, or claims in or against the
property (including income and gain t~om property here~er aceruiag) of the other or against the
estate o f such other, of whatever nature and wherever situate, which he or she now has or at any time
heres_Rer may have against such other, the estate of such other, or any part thereof; whether arising
out of any former acts, contracts, engagements or liabilities of such other, or by way of dower or
eurtesy, or widow's or widower's rights, family exemptions or similar allowance, or under the
intestate laws, or the right to take against the spouse's will; or the right to treat a lifethne 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 the Co~mi~onwealth of Pennsylvanin, or any other
state, commonwealth or tvr~Rory of the United States, or any other country, or any right which Wife
may now have or at any time hereatter may have for past, present or furze support or maintenance,
alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the
marital relationship or otherwise, except, and only except, MI rights, agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or tbr the breach of any thereof.
It is the intention of Hushand and Wife to give each other, by the execution of this Agreement, a full,
complete and general release with respect to any and MI property of any kind or nature, real, personal
or mixed, which the other now owns or may herenRer acqu~e, except, and only except, MI rights,
agreements and obligations of whatsoever nature arising or which may m'ise tm. der this Agreement
or tbr the breach of any provision thereof.
7. PERSONAL PROPIKRTY: Husband and Wife do hereby acknowledge that they
have already divided MI of their personal property to their muttud satisfaction including, but not
limited to, jewels, clothes, furniture and other personalty. Accordingly, Huslxmd and Wife waive
any claim, right, title or interest that they may have in any personal property that is currently in
possession of the other party. As part of their obligations pursuant to this subparagraph, Husband
4
and Wife both agree to execute any document necessary to effectuate the full transfer ofporsonal
property as outlined h this paragraph, and in any event will execute nil necessary documents within
thirty (30) days from the date of execution of this Agreement.
8. REAL ESTATE: Wife shall convey to Husband all right, title and h'Rerest that she
has to the Parties' marital home, colloq**islly known as 388 Crossroads School Road, Newville,
Pennsylvania. In turn, Husband shall take one of the following actions with respect to the existing
mortgage on the marital home held by PHH Mortgage Services:
a. Husband shall undertake his best efforts to obtain a loan by which the existing
mortgage will be satisfied, with Husband remaining exclusively responsible for repayment of
the new loan that he would obtain to effect the satisfaction ofthe existing mortgage. Should
Husband elect to obtain a new mortgage to safis~ the existing mortgage, Husband shall be
exclusively responsible for all costs associated with the new mortgage, including appllcatinn
fees, appraisal fees and settlement charges; or
b. Hushend and grlfe shaH undertake mutual efforts, and cooperate fully, in obtaining
from PHH Mortgage Services (should PHH Mortgage Services permit it) a document to be
filed with the Cumberland County Recorder of Decda to the effect that Wife is released tiom
aH liabilities on the existing PHH Mortgage Services mortgage; in this instance, Husband
would be exclusively responsibie for repayment of the existing mortgage to PHH Mortgage
Services; or
c. If Husband is unable to obtain a new mortgage to satisfy the existing PHH
Mortgage Services mortgage despite a good faith effort to do so, and if PHH Mortgage
Services is unwilling to provide for recording a document that exonerates Wife from nil
liability on the existing mortgage, then the parties will undertake their best efforts to sell the
marital home and divide the net proceeds ofsuch n sale eq~mlly. If the parties need to resort
to a sale oftbe marital home, they shall be obligated to accept any offer that is at least eighty
percent (80%) of the sales price then listed for the home at thc time the offer is made. The
parties specifically conterrq~iate and understand that thc sale of thc nmrital home is be done
only as a last resort, and the parties contemplate that Husband will, in fact, be able either to
obtain a new mortgage that would pay off the existing mortgage or that PHH Mortgage
Services would provide a document suitable for recording that would exonerate Wife from
all liability on thc existin8 PHH Mortgage Services mortgage. Regardless of any other
provision in this paragraph, Wife shall renmin exclusively responsible for any non*real estate
taxes in her name (per capita, occupation, etc.), whether curremly owed or to be assessed in
the future.
9. AI~rER-ACOUIRED PERSONAL PROPERTY: Each of the Parties shall
hereinafter own and enjoy, independently of any claim or right of the other, all items of personal
property, tangible or intangible, acquired by him or her after the date of this Agreement, with full
power in him or her to dispose ofthe same as fully and effectively, in all respects and for all purposes,
as though he or she were unmarried.
10. DMSION OF VEHICLES: With respect to tbe vehiclas owned by one or hoth of
the Parties, or the net proceeds or value derived f~om any prior sale or trade in thcreo~ they agree
a. The vehicle that Husband is driving shallremsiq titled in his name and shall be the
sole and exclusive property of Hushand. If thc vehicle is not tried exclusively in Husband's
name, Wife hereby agrees to sign whatever documents are necessary to effectuate title of that
vehicle in Husband's name alone.
6
b. The vehicle that Wife is driving shall remain titled in ber n~ne and shall be the sole
and exclusive property of Wife. If the vehicle is not titled exclusively in Wife's name,
Husband hereby agrees to sign whatever decunmRs are necessary to cffectuatc title of that
vehicle in Wife's name alone.
The titles or lease agreements to said vehicles shall be executed by the Parties, if
appropriate, for effectuating ~msfer as herein provided on the date of execution of this
Agreement, and said ex~uted titles shall be delivered to the proper party on the dism'butinn
date. For purposes of this Paragraph, the term *titleH shall be deemed to include "power of
attorney" if the title or lease agreement to the vehicle is unavailable due to financing
arrangements or otherwise. In the event any vehicle is subject to a lien or encumbrance, the
party receiving saki vehicle as his or her property shall take it subject to said lien and/or
encumbrance and shall be solely respons~le therefor, and said party further agrees to
indemnify, protect and save the other party harmless from said lien or encumbrance. Each of
the Parties hereto does specifically waive, release, renounce and forever abandon whatever
right, title and interest he or she may have in the vehiele(s) that shall become the sole and
separate property of the other pursuant to the terms of this Paragraph.
11. INCOME TAXES FOR CALENDER YEAR 2000: The Parties have paid all
income taxes owed for the calender year 2000, and have divided the hab'~ity for the taxes to their
mutual satisfaction~
12. LIABILITIES: The Parties have previously allocated tbe liabilities o ftbeir marriage
to their satisfaction.
7
13. WARRANTY AS TO EXISTING OBLIGATIONS: Each Party represents that
he or she has not heretofore incurred or co~z~'ted for any debt, liability or obligation for which the
estate of the other Party may be responsible or liable, except as may be provided for in this
Agreement. Each Party agrees to indemnify or hold the other Party harmless from and against any
and all such debts, liabilities or obligations of every kind which may have heretofore been inotrred
by them, including those for necessities, except for the obligations arising out of this Agreement.
14. WARRANTY AS TO I~ffrURE OBLIGATIONS: Husband and W'n~ each
covenant, warrant, represent and agree tha~ he or she will now and a~ all times hereat~er seve harmless
and keep the other indemnified from all debts, charges and liabilities incurred by the other aRer the
date of this~ Agreement, except as may be otherwise specifically provided for by the tem~ of this
Agreement, and that neither o fthem shall heresfler incur any liability whatsoever for which the estat~
of the other nmy be liable.
1 $. WAIVER OF ALIMONY. SUPPORT AND MAINTENANCE: Hnshand and
Wife do each hereby waive, release and give up any rights they may respectfully have against the
other for alimony, support, or ~ce. It shall be from the date of this Agreement the sole
responsibility of each of the respective Parties to sustain themselves without seeking any support from
the other party. The Parties hereby acknowledge that by this Agreement each has respectively
secured and maintained a substantial and adequate fund with which to provide himself or herself with
sufficient financial resources for comfort, wnlntenanse and support in the station o flife to which they
are accustomed.
16. RETIREMENT ACCOUNTS: Each party shall retain exclusive title, ownership
and control of any right, title or interest he or she may have in any 401 (K), pension plan or any other
account or entity designated for his or her retirement.
17. OTH~.R ~NTATION: W'ffe and Hushand envenant and agree that they
will execute, within thirty (30) days from the date of execution of this Agreement, any and all written
instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be
necessary or desirable for the proper effectuatinn of this Agreement in order to carry out fully and
effectively the terms of this Agreement.
! 8. FULL DISCLOSURE: Each party asserts that he or she has made a full and
co,,~,lete disclosure of all of the real and personal property, of whatsoever nature and wherever
located, belonging in any way to either or both of them, of all the debts and encumbrances incurred
in any manner whatsoever by either or both of them during the marriage, of all sources and amounts
of income ofeach party, and of every other fact relating in any way to the subject matter ofth/s
Agreement. These disclosures are part of the consideration made by each party for entering into this
Agreement.
19. ENTIRE AGREEMENT: This Agreement contahs the entire understanding
between the Parties. There are no representatinns, warranties, covenants or undertakings other than
as expressly set forth hereh.
20. WAIVER OR MODIFICATION TO BE IN WRITING: No modifwation nor
waiver of any of the terms hereof shall he valid unless in writing and signed by both Parties, and no
waiver of any breach hereof or default hereunder shall he deemed a waiver of any subsequent default
of the same or similar nature.
21. LAW OF PENNSYLVANIA APPLICABLE: This Agreement shall he construed
in accordance with the laws of the CoJ,a~onwealth of Pennsylvanin.
22. AGI~.~MENT BINDING ON HEIRS: This Agreement shall be binding nod shall
inure to the benefit of the Parties hereto and their respective heirs, executors, administrators,
successors and assigns.
23. ~,t_~t~~: Ifeny term, 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
Agrecmem shall be valid and continue in full force, effect and operation. Likewise, the failure of any
Party to meet his or her obligations under any one or more of the paragraphs herein, with the
exception oftbe satisfaction oftbe conditions precedent, shall in no way void or alter the remaining
obligations oftbe Parties.
24. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text
of the several paragraphs and subparagraphs hereof are inserted solely for the convenience of
reference and shall not constitute a part of this Agreement, nor shall they effect its meaning,
construction or effect.
iN WITNESS WHEREOF, tbe Parties hereto have set tbeir hands and seals tbe daY and year
first above-written.
WITNESS:
STEPt~Iq M. KORNBLUM
DANIELLE M. KORNflLUM
I0
COMMONWEALTH OF PENNSYLVANIA :
: SS.
:
COUNTY OF
Cotmnonwealth and County, personally appeared STEPHEN M. KORNBLUM, known to me (or
satisfactorily proven) to be the person whose name is suhem'hed to thc within Agreement, and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WttEREOF, I hereunto set my hand a~A ot~ial seal.
Notnfl~l Szal
I Moli~ $. SnC~~r Not~/
My Commissk~ Ex~ires: Harrisbuq~, _om~.phin...Co~y~.
My Commission Expires veo.
(SEAL) Mzmber, Pennsylvania AssOciation ot
COMMONWEALTH OF PENNSYLVANIA :
: SS.
Ot,.m rlttr :
On this, the o~aY of~, 2001, before me, a Notary Public in and for said
Couu~onwealth and County, personally appeared DANIELLE M. KOR.NBLUM, known to me (or
satisfactorily proven) to he the pe~on whose name is subsen'hed to the within Agreement, and
acknowledged that she executed the same f~r the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal
[ r~OT,KW~J. SE~L
~y ¢ommiss~o~ £x~res: I TmO* L. ~I~Y, Notary Pddc
ANTHONy T. McBb-TH ',
STEPHEN M. KORNBLUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
: CIVIL ACTION - LAW
V. :
: NO. 01-2895 Civil Term
.-
DANIELLE M. KORNBLUM, : IN DIVORCE
Defendant :
PRAECI~E TO TRANSMIT RECOI~n
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Cour~ for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Codc.
2. Date and manner of service of compiaint:
May 19, 2001 via certified mail, return receipt requested (substantiated by aflkiavit
of service filed May 22, 2001)
3. Date ofcxecmion of the air]davit of cousent required by Section 3301(c) of the Divorce
Code:
By Plaintiff.' August 17, 2001
By Defendant: August 27, 2001
4. Rciatcd claims pending: None. Post-nuptial agreernem filed contemperaneously he~v~h
$. Da~e that Waiver of Notice was filed with the Prothonotary:
By Plain~. Contemperaneously filed herewith this filing, projected to he
August 31, 2001
By Defendant: Contemperam~usly filed herewith this filing, projected to he
August 31, 2001
(717) 238-3686
Supreme Court I.D. # 53729
IN the COURT OF COMMON PLEAS
Of CUMBERLAND COUNTY
State Of .~. PENna.
.STE~ItKN.. M ... KORNltL[JM, ....................................
N ~..o.j...r..2..8..~..s.....c. iv.,.i.~....~.~..rl~)
.~.a..S ~.J~!~E...~!.,...!~.9!~.~LU~, .................................
decreed thct ............~..~ :. [~ ............... plointiff,
ond ...................... ~%~Fk%~. ~.-.. ~93~ ............ defendant,
ore di~rced from fhe bonds of mofrimony.
The courf refoins jurisdiction of the following cloims which hove
been roised of record in fhis ocfion for which o finol order hos not yef
been entered;
gncorp~r~2~ .her~n. hy. refarence ....................................
.......... ~;0,~