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HomeMy WebLinkAbout02-0871Debbra J. Blosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 0~ ~°?l CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Debbra J. Blosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 0,~,,-~P'7! CIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Debbra J. Blosnich, an adult individual, currently residing at 6105 Locust lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Rudolph Samuel Blosnich, an adult individual, currently residing at 6105 Locust Lane, Mechanicsburg, County, Pennsylvania 17050. 3. Plaintiff and Defendant are bonaflde residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 25, 1993 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. 9. Plaintiff and Defendant are citizens of the United States of America. The parties have lived separate and apart since February 6, 2002 and continue to live separate and apart as of the date of this Complaint regardless of their residing at the same mailing address. 10. There have been two minor children born of this marriage; Jeremy M. Blosnich born September 4, 1997 and Christopher J. Bosnich, born May 28, 2000. 11. Currently, an Order of Court has been issued relative to the filing for child support before the Domestic Relations Section and a conference in this matter is scheduled for March 13, 2002 at 13 North Hanover Street, Carlisle, PA 17013 at 2:00 PM. 12. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Date Respectfully Submitted TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divome Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Debbra J. BI5 ~n~ilch - CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Divorce Complaint upon Rudolph Samuel Blosnich, by Certified Mail (Restricted Delivery and Return Receipt Requested) and depositing same in the United States Mail, first class, postage pre-paid on the ,;;707''~ day of 7~,'~,--x¢~-~.~- , 2002, from Carlisle, Pennsylvania, addressed as follows: Rudolph Samuel Blosnich 6105 Locust Lane Mechanicsburg, Pennsylvania 17050 TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Debbra J. Blosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 0~- o8~ ! CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF SERVICF I HEREBY CERTIFY THAT I served a true and correct copy of Divorce Complaint filed in the above captioned case upon Rudolph S. Blosnich, by certified mail return receipt requested on February 19, 2002, 2002 addressed to: Rudolph S. Blosnich 6105 Locust Lane Mechanicsburg, PA 17050 and did thereafter receive same as evidenced by the attached Post Office receipt card dated February 21, 2002. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVITI OF SERVICE ARE TRUE 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. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff services (for an extra fee): [3 A~re~see's Adclm~ 2,~J%stfic~:l D~livm,~ ~ ~ 2511 0009 2827 8707 ~ , . / ~ 7. Dam of DelNe~ 5. ~lv~ B~ (~it,i Name) ~ B. A~e~'s ~ (~ if ~u~t~ and Debbra J. Blosnich, Plaintiff V. Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA , : NO. 02-871 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE PRAECIPE TO TRANSMIT CUSTODY ORDER TO THE PROTHONOTARY: AND NOW this 19th day of September, 2002, the Plaintiff submits a mutuall agreed upon Custody Stipulation and requests that this Honorable Court enter an Order granting the acceptance thereof. Datc~ ~ Respectfully Submitted TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Debbra J. Blosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-871 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE CUSTODY STIPULATION AND NOW, this /~-J~ · day of ~v'~,-" J~ -' , 2002, it is hereby stipulated and agreed between the parties as follows: 1. Jeremy M. Blosnich, born September 4, 1997, and Christopher J. Blosnich, born May 28, 2000 are the natural children of Debbra J. Blosnich, Plaintiff, and Rudolph Samuel BIosnich, Defendant. 2. Shared legal custody of the children as contemplated by the Act of October 30, 1985, P.L 264, 23 P.S. {}5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the children shall be in the mother subject to the following periods of partial custody with the father. a. Every Sunday to Wednesday from Sunday at 1:00 PM to Wednesday at 8:00 AM. 4. Alternating holidays from 8:00 AM to 8:00 PM. The holidays shall be New Year's Day, Martin Luther King Day, President's Day, Easter, Memorial Day, 4th of July, Labor Day, Columbus Day and Veteran's day with the father having custody during four of the holidays on odd numbered years and the balance in even numbered years. Mother shall have custody New Year's Day, President's Day, Memorial Day, Labor Day and Veteran's Day beginning 2003. ) 5. The parties shall alternate the Christmas holiday. The father shall have custody of the children from 6:00 PM on Christmas Eve until 3:00 PM on Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the children from 3:00 PM Christmas day until 6:00 PM on December 26~ in odd numbered years and the father shall have this period in even numbered years. Thanksgiving shall be treated in the same manner as Christmas. 6. Mother shall have physical custody from 8:00 AM until 8:00 PM on Mother's Day and Father shall have physical custody from 8:00 AM until 8:00 PM on Fathers Day, 7. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. The party receiving custody shall provide transportation from the custodial parent's residence. 8. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the children. 9. Neither parent shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent or hamper the free and natural development of the children's love and respect for the other parent. 10. Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. 11. Regardless of which parent retains custody of the children, both parties shall share with each other the children's report cards and other papers affecting the children's education, medical condition and welfare. 12. Primary Physical Custody as outlined above shall be changed as mutually agreed upon by the parties. Date Debl~a J. Blosnich Date ' Rudo/Iph ~an~uel Blosnich Debbra J. Blosnich, Plaintiff Vo Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-871 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE ORDER OF COURT AND NOW, this e-w-- Stipulation dated September 10, 2002 and signed by effective the date of this Order. Modification of the Custody applicable law at the time of filing day of ,,3~~._~.~, 2002, the Custody both parties is entered and Stipulation can be obtained pursuant to the CC: ,,-'Galen R. Waltz, Esquire P. Richard Wagner, Esquire / PI. FI= Debbra J. Blosnich, Plaintiff ~.. V. Rudolph Samuel Blosnich, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-871 CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE PRAECIPE TO TRANSMIT CUSTODY ORDER TO THE PROTHONOTARY: AND NOW this 19th day of September, 2002, the Plaintiff submits a mutually agreed upon Custody Stipulation and requests that this Honorable Court enter an Order granting the acceptance thereof. Dat~ ' Respectfully Submitted TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Debbra J. Blosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-871 CIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE CUS TOD Y S TIPULA TION AND NOW, this---/<r]'~" day of~,._¢/,(.,- [~, ,- , 2002, it is hereby stipulated and agreed between the parties as follows: 1. Jeremy M. Blosnich, born September 4, 1997, and Christopher J. Blosnich, born May 28, 2000 are the natural children of Debbra J. Blosnich, Plaintiff, and Rudolph Samuel Blosnich, Defendant. 2. Shared legal custody of the children as contemplated by the Act of October 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the natural parents. 3. Primary physical custody of the children shall be in the mother subject to the following periods of partial custody with the father. a. Every Sunday to Wednesday from Sunday at 1:00 PM to Wednesday at 8:00 AM. 4. Alternating holidays from 8:00 AM to 8:00 PM. The holidays shall be New Year's Day, Martin Luther King Day, President's Day, Easter, Memorial Day, 4th of July, Labor Day, Columbus Day and Veteran's day with the father having custody during four of the holidays on odd numbered years and the balance in even numbered years. Mother shall have custody New Year's Day, President's Day, Memorial Day, Labor Day and Veteran's Day beginning 2003..---- ) 5. The parties shall alternate the Christmas holiday. The father shall have custody of the children from 6:00 PM on Christmas Eve until 3:00 PM on Christmas Day in odd numbered years and the mother shall have this period in even numbered years. The mother shall have custody of the children from 3:00 PM Christmas day until 6:00 PM on December 26~ in odd numbered years and the father shall have this period in even numbered years. Thanksgiving shall be treated in the same manner as Christmas. 6. Mother shall have physical custody from 8:00 AM until 8:00 PM on Mother's Day and Father shall have physical custody from 8:00 AM until 8:00 PM on Father's Day, 7. The exchange of custody shall occur at the custodial parent's residence, unless other arrangements are made and agreed to by both parties for an alternate place for the exchange of custody. The party receiving custody shall provide transportation from the custodial parent's residence. 8. The custodial parent shall inform the non-custodial parent immediately of all medical appointments and problems pertaining to the children. 9. Neither parent shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent or hamper the free and natural development of the children's love and respect for the other parent. 10. Both parents shall have liberal and reasonable telephone contact with the children when the children are in the custody of the other parent. 11. Regardless of which parent retains custody of the children, both parties shall share with each other the children's report cards and other papers affecting the children's education, medical condition and welfare. 12. Primary Physical Custody as outlined above shall be changed as mutually agreed upon by the parties. Date Date ' RudOlph S%-~uel Blosnich SEPARATION AGREEMENT AND PROPERTY SETTLEMENT This Agreement, made and entered into this ,,2.~ '~ 'day of '~',J ~ ,2003, between Debbra J. Blosnich, of Mechanicsburg, Cumberland County, Pennsylvania, herein referred to as "Wife," and Rudolph Samuel BIosnich, of IVlechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Husband." WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on September 25, 1993, in Cumberland County, Pennsylvania; WHEREAS, there have been two (2) children borrl of this marriage between Husband and Wife, to wit: Jeremy M. Blosnich, d.o.b. September 4, 1997 and Christopher J. Blosnich, d.o.b. May 28, 2000. WHEREAS, the parties hereto are now living separete and apart within the same residence and desire to enter into an Agreement respecting their property rights regardless of the actual separation or other character thereof and their other rights, including the Wife's right to support and maintenance; WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof, and each has had the opportu~nity to consult with his or her own competent legal counsel independent of each other; WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish ail of her rights to be supported by Husband and all of her rights of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to counsel fees, or expenses and, other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtsey, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future; NOW THEREFORE, the parties hereto intending to be legally bound hereby do hereby mutually agree as follows: 1. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 2. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3. Mutual Power and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take pracedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in property or estate of the other, and to that end both parties waive, relinquish and forbear the rights of dower of curtsey, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other ('lie testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though married, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real personal property, but without any power 1:o impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution or married property ordered by the Court subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenance, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 4. Child Custody. The parties have entered into a Stipulation regarding the custody of which Stipulation was made an Order of Court on Child Support. The parties have entered into a Child Support Agreement confirmed by the attached March 12, 2002 Iletter advising of the acceptance of bi- weekly child support in the amount of $550.00. b. Medical Care for the Children. The parties agreed that the children shall be carried upon the employer sponsored medical insurance programs provided to Husband. The parties further agree that any medical or dental expenses for the children not covered by insurance shall be divided equally between them. Distribution of Marital Assets. c. The parties agree that the items of personall property listed below at Exhibit A shall be the sole and exclusive property of Wife/Husband. All other personal property obtained by the parties during the marriage shall be sole and exclusive property of the Wife/Husband. Henceforth, each of the parties shall own, have and enjoy, independently of any claim of right of the other party, all items of personal property of every kind, nature and description and wheresoever situated which are now owned or held by or which may hereinafter belong to the Husband their children and filed at 02-871 September 24, 2002. 5. Support a. or Wife respectively, with full power to the Husband or Wife to dispose of the same as fully and effectually in all respects and for all purposes as if he or she were unmarried. d. The parties agree that the 2001 Ford F-150 shall be the sole and separate property of the Husband. The 1995 Ford Contour shall be the sole and separate property of the Wife. e. Personal effects. All items of personal effect such as but not limited to jewelry, luggage, sports equipment, hobby collections and books but not including furniture or any other property, personal or otherwise specifically disposed of pursuant to this Agreement shall become the absolute and sole property of the party who has had the principal use thereof or to whom the property was given or from whom it was purchased, and each party hereby surrenders any interest he or she may have in such tangible personal property of the other. 7. Debt. The parties have divided all outstanding debts. The parties agree that they will each be responsible for their individual debts incurred subsequent to the separation of the parties and that each party shall hold the other party harmless for the debt incurred subsequent to the separation. Husband agrees to be solely responsible for any remaining debt relative to the 2001 Ford F-150 truck retained by the Husband. 8. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either' party incurs a debt for which the other will be liable, that party incurring such debt will hold the other harmless from any and all liability thereof. 9. Real Property. The parties agree that the real property located at 6105 Locust Lane, Mechanicsburg, Cumberland County, Pennsylvania shall be valued at $176,500.00 and transferred into the name of Wife. Wife agrees to assume the existing mortgage and to hold husband harmless for any debt thereto"~. The parties shall execute all documents concerning the transfer of title to Wife. In consideration, Wife shall waive all rights to the PP&L stock held by Husband and to the Pension proceeds. Both parties agree to execute any and all future documents reasonably related to the transfer of title to th,9 marital home and cooperate in the prompt payment of ail marital debts as outlined above. Husband agrees to vacate the residence and remove all of his personalty from the residence before July 13, 2003. 10. Alimony. Wife agrees to accept alimony and Hu~sband agrees to pay alimony through February 1, 2004 from the date of signing this Agreement. Husband agrees to pay to wife Two Hundred Twenty-five Dollars ($225) bi-weekly. In the event of either the remarriage of the Wife or the Wife's cohabitation during the alimony payment time period, the alimony obligation shall cease as of the date of remarriage or cohabitation. 11. Pension. Wife agrees that her entitlement of pension proceeds is set off by Husbands equity established in the Locust Lane residence as previously stated herein at paragraph 9. 12. Counsel Fees and Court Costs. Each party agrees to pay their own attorney fees and cost incurred in the preparation of this document, as; well as the preparation and filing of the divorce action captioned at 02-871 Civil Term and the Custody Order filed at the same number. If either party incurs any other legal fees or court costs, those costs will be borne by the party exclusively. 13. Divorce. The parties acknowledge that an action for divorce between them has been filed by Wife and is presently pending a divorce between them in the Court of Common Pleas of Cumberland County to the caption Debbra J. Blosnich v. Rudolph Samuel Biosnich, 02-871 Civil Term. The parties acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully here, by all claims raised by either party in the divorce action. The parties acknowledged they have executed simultaneously herewith the necessary Affidavits of Consent for the entry of a final divorce decree in that action. 14. Breach. In the event that either party breaches any provision of this Separation and Property Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 15, Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any Court of competent jurisdiction. 16. Applicable Law and Execution. The parties hereto agree that this Marital Settlement Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 17. The Entire Agreement. The parties acknowledge and agree that this Marital Settlement Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are not other representatives, warranties, promises, covenants or understandings between the parties other'lhan those expressly set forth herein. 18. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or things that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. Rudolph Samuel Blosnich April 25, 2002 Blosnich Household Property Distribution upon divorce shall 1~ as follows: Debbra Blosnich shall retain possession of the following: ASSET ROOM Sofa/Loveseat TV Stand TV/VCR CD Changer Curtains ½ dishes Cannister set Sugar bowl/Creamer Butter Dish/Gravy Bowl Dining Set Corios/Contonts Large Picture Wall Candle Holders Desk Jeremy's Bed-dresser Toybox ShelffContonts Christopher-shel/Tcontents Queen Spare Bed Dresser fi.om spare room Christopher-dresser Hall vanity Kirby outdoor furniture/cookbooks Living Room Living Room Living Room Living Room Living Room Kitchen Kitchen Kitchen Kitchen Dining Room Dining Room Dining Room Dining Room~l~all Basement Upstatrs Upstairs Upstan's Upstarts Upstaws Upstairs Upstairs Upstarts OTHER ITEMS Rudolph S. Blosnich shall reiain possecsion of the following items: ASSET ROOM End Table Living Room Stereo/Speakers Living Room Microwave Kitchen Coffee Pot Kitchen ~ dishes Kitchen Curtains Kitchen Table/Chairs Kitchen Washer/Dryer Basement Treadmill Basement Entire Master Suite Upstairs Table Upstairs Camping Equipment Garage Paint Roller Garage Tools Garage EXItIBIT A Longerberger basket for Mail Dining/Living Curtains Other Items Other It~as Kitchen items to be divided; Christmas ornaments to be divided; Bath items Debbra J. Blosnich, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02-871 CIVIL TERM Rudolph Samuel Blosnich, Defendant : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under §3301(c) of the Divorce Code was filed on February 20, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divome after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Debbra J. BI(JsQ~h Debbra J. Blosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-871 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER .~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division o 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. {}4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Debbra J. Bios i~ :)ebbra J. BIosnich, Plaintiff V= Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-871 CIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on February 20, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice o' Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~udolph l~arhuel Blosnict~ '" Debbra J. BIosnich, Plaintiff Rudolph Samuel Blosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-871 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301{c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Debbra J. BIosnich, Plaintiff Rudolph Samuel BIosnich, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-871 CIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divome Decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) §3301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified, Returned Receipt mail delivered on February 21,2002. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. By Plaintiff: June 25, 2003 By Defendant: June 19, 2003 4. Related claims pending: None. 5. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: June 25, 2003 By Defendant: June 19, 2003 ~n R. Waltz, E/~re Attorney for Plaifrfiff IN THE COURT OF COMMON OFCUMBERLANDCOUNTY STATE Of ,~_,~~ ~ D~A~A J. RT/~NTC~4 Plaintiff VERSUS Defep~a~t PENNA. PLEAS NO. 2002 ~71 DECREE iN DIVORCE AND NOW,~ , 200 , IT is ordered AND DECREED THAT D~A~A J, , PLAINTIFF, 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 FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; attached hereto is incorporated but ' ' ' thls Final Dlvor¢~ D~e. BY ATTEST: ~~C J' )THONOTARY