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HomeMy WebLinkAbout05-0672 BELTRAN S. ESTRADA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. OS - fc/7~ CWlL'-rVLh'j : IN DIVORCE TINA MARIE LEWIS, 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 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 Prothonotary's Office, Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 (717)-249-3166 (800) 990-9108 BELTRAN S. ESTRADA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W ~ NO. OS - (\.,;J~ I ~ : IN DIVORCE TINA MARIE LEWIS, Defendant COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, BELTRAN S. ESTRADA, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, TINA MARIE LEWIS, upon the grounds hereinafter set forth: I. Plaintiff is BELTRAN S. ESTRADA, an adult individual, residing at IIII Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is TINA MARIE LEWIS, an adult individual, residing at Route 2, Box I 87-E, Pennington Gap, Lee County, Virginia. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. Defendant is a resident of Virginia. 4. The Plaintiff and Defendant were married on December 4, 1996 in Winston-Salem, Forsyth County, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties. BELTRAN S. ESTRADA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-672-CIVIl TERM TINA MARIE LEWIS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on February 7, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 after service of Notice of Intention to Request Entry of the Decree. I verifY that the statements made in this Affidavit are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. DATED: '<~O-OS- ~ \~/Ju, eltran S. Estrada, Plaintiff ~ _Tt....':J.+., ,}.;, (") s= -r) ':::~ r;1 ~ Z,"": -":",,., J__".'.. ~:~,d ~ ~f~:: z --:j -< ,- ""-{;].~,"',c,i!.fl'jillf~~!:fi!W~~."",~""""""",,,~;:;G-i'1'1J11::,,,,;-,h"""" ",'"' "\""""."'.~ ...., = = eon '- c: , I U1 ffl ::rl_ rnpl -om ~l'Jt"J aT :"--1 C) -r: :!j ~~(~ ('Srn ,-~ :;>> .J..' -< -v :3: '>? .t:" ..0 BELTRAN S. ESTRADA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-672-CIVIL TERM TINA MARIE LEWIS, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330UC) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. DATED: j.... 3D - O~ ~da, ~4 ~ Plaintiff o C 7' ',)ie' f'Tlf. -7' ,., ~: [ ~t: ~;'i~:' ":PC: z; :< ;"',: ,1 .,< "",.1' ",.."J\,,~,. ,..., = = ..... C- eo ..- I ()"l -to ::J::: r:-? :r:- \D ~ ..... :r:..,... rn-- -o~ 60 ~~t O-M- -7 ' '5 ~ ~ '< - 6. Plaintiff is a resident alien of the United States of America and Defendant is a citizen of the United States of America. 7. The Defendant is not a member ofthe Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff, BELTRAN S. ESTRADA, respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code. Respectfully submitted, DATED: l.~ 3~ tJ> ~'k.~- A Robert B. Lieberman, Esquire 500 N. Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Plaintiff ~ VERIFICATION I verify that the statements rnade in the foregoing Complaint in Divorce are true and correct based upon my personal knowledge, information and belief. I understand that false staternents herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. DATED: ..2.,~,oS ~G~~ Beltran S. Estrada, Plaintiff (J ~ 70 '\- -0 ~ . ? _ w lI( ~ ~ C> ~ -J ""'Y ?- ',; ~ ~ \\ 'c~; \ --' F ':'? c .-~ o'~ ------ . BELTRAN S. ESTRADA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-672-CIVIL TERM TINA MARIE LEWIS, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEAL TH OF PENNSYL VANIA SS. COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and says: I. That on February 7, 2005, a Complaint in Divorce was filed on behalf of Plaintiff and against Defendant in the above case. 2. That on February 11,2005, I forward by certified mail, return receipt requested, restricted delivery a copy of the Complaint in Divorce to Defendant, Tina Marie Lewis, at Rt. 2, Box 187-E, Pennington Gap, Lee County, V A. 3. That the aforesaid copy of the Complaint in Divorce sent to Defendant, Tina Marie Lewis, was delivered on February 18,2005 as evidenced by the return receipt card signed by Defendant and attached hereto. . . 4. That to the best of my information and belief the signature on the return receipt card is, in fact, the signature of Defendant, Tina Marie Lewis. ~ B ~~JlER~AN F~q""' Attorney for Plaintiff SWORN TO and subscribed befo,re. me lhis ;( 3'Zb day of h?:ft-uAtL-Y ,2005. <0 Ul .J] [J'" U.S. Postal Service CERTIFIED MAIL RECEIPT (DomestIc Mall Only; No Insurance Coverage ProVIded) (;j.l~-^-^td.1={Jr~ r tary Public (. i.OMMONWt:Al.J PENNSYLVANIA NOTARiAL SEAL CHERYL L FERGUSON, NolaIy NIlIc ClIy 01 H~fI~1. DauphIn Counly My ---........... ,- ',,",v 0.'" 6 2008 \.AIlI1~!!I~"^ .>,,....,~:I '.._.< ~ L_~_ rT1 p""g,,~_3. ,5 Q ~ Certified Fee I I. d 0 o f ~- CJ Return Receipt Fee I I. 0 lEndorsementReqUiredi~' I ~ _ Restricted DelivRry Fee '7~ ,Endorsement Requiredl , J... Total Postage & Fees $ s-; t5~~~] r-....----------...-- My Commission Expires: rOostlTlark Here CJ o o r'l ru o o [" 1-/1-0":: ..__QL__~..l_.__.__ 'city."stitv,"Zlf; Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: Tina Marie Lewis Rt. 2, Box 187-E Pennington Gap, VA 24277 D. Is delivery address different from item 1? If YES, enter delivery address below: ~e ice Type ertified Mail o Istered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. . 4. Restricted Delivery? (Extra Fee) es 2. Article Number (Transfer from service label) PS Form 3811. August 2001 7002 1000 0005 3929 9658 Domestic Return Receipt 102595-02-M-0835 BELTRAN S. ESTRADA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-672-CIVIL TERM TINA MARIE LEWIS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 7, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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. 94904 relating to unsworn falsification to authorities. aJt~\ Jll{p IJ >~ ~ Tina Marie Lewis, Defendant DATED:q~/3-o 5 c! ~~ ..., = ~j; ~ -.; l" - ""'" :>: 9.. ..-\ -:c.""t"'i. fn~ 1.- -()\-"...\ ~PL -'-)IL' ~T:5~~ ~;-:'rn ~2\ ?E! .-<:: to .' s:- "'" --- BEL TRAN S. ESTRADA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 05-672-CIVIL TERM TINA MARIE LEWIS, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verifY that the statements made in this Affidavit are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. DATED: ~- J)-C~ ("..~, ll{dJb ~arie Lewis, Defendant Q, ..-\ :r;..,., rl1~ ~)Q ()C) :, ~:t;)~ :::;; .'/: rl'l ',2, ;;; ~ ,..., "'" <:;;:::) U" ,,, r"fl -0 N S'7 ~2 N .' x:- CoW MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this l1~day of ~~fJf ~ ,2005, by and between Beltran S. Estrada, hereinafter called "Husband" and Tina Marie Lewis, hereinafter called "Wife". WITNESSETH: WHEREAS, Husband and Wife were legally married on December 4, 1996, in Winston-Salem, Forsyth County, North Carolina; and WHEREAS, there were three children were born of this marriage, namely, Miriam L. Estrada, Adrian L. Estrada and Diego L. Estrada; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations. NOW THEREFORE, in consideration of the premises and covenants contained herein, it is agreed by and between the parties hereto that: 1. SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness ofthe causes leading to their living apart. The parties agree that they have been living separate and apart at least since April 7, 2004. 2. INTERFERENCES Each party shall be free from interference, authority and control by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to molest the other party, or in any other way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. 3. DIVISION OF REAL PROPERTY The parties own no real estate. 4. DIVISION OF PERSONAL PROPERTY The parties have divided their personal property to their mutual satisfaction. 5. EQUITABLE DISTRIBUTON Except as specifically provided for in this Agreement, the parties agree that they have satisfactorily equitably divided all their marital property. 6. PENSIONS Each party shall retain as their sole and separate property any pension benefits in their own name including, but not limited to, IRA's, 401(k) plans, 403(b) plans or other pension benefits, including disability benefits. 7. MOTOR VEHICLES The parties acknowledge the existence of a 1999 Ford Expedition which is currently titled jointly with a loan due Ford Motor Credit. Wife hereby agrees, upon request, to transfer all her right, title and interest in and to the aforesaid vehicle to Husband. Husband agrees to assume the full and sole responsibility for the obligation due Ford Motor Credit. 8, CREDIT CARDS AND LOANS The parties represent that there are no credit cards or loans in their joint names except for the obligation due Ford Motor Credit. 9. LIFE INSURANCE Each party shall retain any life insurance policies in their names individually including any cash value related thereto and each party shall have the right to name beneficiaries of life insurance proceeds. 10. TAX RETURNS For tax year 2005 and thereafter, the parties shall file separate tax returns. 11. CUSTODY Husband and Wife hereby agree that legal custody of the parties' minor children shall be shared and that primary physical custody shall be with Wife subject to Husband's liberal rights of partial custody at such times and places as the parties may hereinafter agree. 12. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement or seeking such other remedy or relief as may be available to him or her. 13. FULL DISCLOSURE Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever and of all other facts relating to the subject matter of this Agreement to which such party may reasonably require to make an informed decision regarding this Agreement. 14. ADDITIONAL INSTRUMENT Each of the parties shall upon request execute and deliver to the other any documents necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails to comply with this provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably incurred as a result of such failure. 15. WIFE'S DEBTS Wife represents and warrants to Husband that she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and Wife shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 16. HUSBAND'S DEBTS Husband represents and warrants to Wife that he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and Husband shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 17. WAIVERS OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 18. REPRESENTATION Husband is represented by Robert B. Lieberman, Esquire and Wife, cognizant of her right to legal representation, declares that it is her express, voluntary and knowing intention not to avail herself of her right to counsel and chooses instead to represent herself with respect to the preparation and execution of this Agreement. The parties acknowledge that they fully understand the facts and their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and voluntarily, after having reviewed the entire Agreement and that execution of the Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 19. TAX PROVISIONS The parties believe and agree that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. 20. ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other that those expressly set forth herein. 21. PRIOR AGREEMENT It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 22. MODIFICATION AND WAIVER Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The '. failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 23. GOVERNING LAW This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 24. INDEPENDENT SEPARATE COVENANTS It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 25. VOID CLAUSES If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then and only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 26. ENTRY AS PART OF DECREE The parties shall, contemporaneously herewith, execute Affidavits of Consent and Waivers of Notice of Intention to Request Entry of a Divorce Decree in order to have a Decree in Divorce entered in the case docketed to No. 05-672 in Cumberland County, Pennsylvania. ", 27. DOMESTIC RELATIONS CODE OF THE COMMONWEALTH OF PENNSYLVANIA Each party waives any claim that they may have against the other under the Domestic Relations Code or other laws of the Commonwealth of Pennsylvania including, but not limited to, spousal support, alimony, alimony pendente lite, counsel fees, costs and equitable distribution of marital property. IN WITNESS THEREOF, the parties hereto intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. WITNESS: ~~.~ ~ 51!~ --C eltran S. Estra a ~bD..&.o ~ J~ a~ ~ rt;.~ri~ Tina Marie Lewis . ~ COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF DAUPHIN . ') o\,ub On thIS ~ 01. day of - .S:?c-~l$f.R- ,2005, before me, a Notary Public, personally appeared BELTRAN S. ESTRADA, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. ~~_tn, .It J:. i Nota;~ . ~ ".;OMMONWEAJJIL~~ PENNSYLVANIA NOTARIAL SEAL * * * * * * * CH~RYl L F~RGUSON, Notary Public City of H81risbt.irg, Dauphin County ~'L~~.!~~ 1':.~il:~S APril B, 2008 COMMONWEAL TH OF VIRGINIA ss. COUNTY OF LEE On this ~ay of ~ef+' , 2005, before me, a Notary Public, personally appeared TINA MARIE LEWIS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. fh~ ~fJhtlH' tYf,ltt{! ~ 1- J 1-07 ~~.dJ~ Notary blic o ~~. r-" -c.:.:~-'"'" '''-':::) 'of' C C-"'~', ,."",, \ Cr\ ..-. \........1 -\,,\ -;"/.. ~.'~,,~ ..- -,- tf\ cr" BELTRAN S. ESTRADA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-672-CIVIL TERM TINA MARIE LEWIS, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for Divorce: Irretrievable Breakdown/Mutual Consent under Section 3301(c) of the Divorce Code. 2. Date and Manner of Service of the Complaint: February 18,2005, on Defendant, TINA MARIE LEWIS, as evidenced by an Affidavit of Service filed in the Prothonotary's Office of Cumberland County on February 24, 2005. 3. Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: Plaintiff on June 30, 2005. Defendant on September 13,2005. 4. Related claims pending - None.. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 5, 2005. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September 21,2005. Respectfully submitted, DA TED: 't -' 1:')' oS BY:~~.~ Robert B. Lieberman, Esquire, 500 N. Third St., Twelfth Floor P.O. Box 1004 Harrisburg, P A 17108-1004 (717) 236-1485 Attorney for Plaintiff C) c:, '0 r-' r:::::i ..::-;:. C.~I C) C~) -'~ , . ,-"~ '-' ' en -J - , , , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . , . . . . .. . . :f':+: :+: "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF BELTRAN S. ESTRADA, Plaintiff VERSUS TINA MARIE LEWIS. Defendant AND NOW, DECREED THAT AND PEN NA. No. 05-672-CIVIL TERM DECREE IN DIVORCE o'-~ \ "\ BELTRAN S. ESTRADA TINA MARIE LEWIS ARE DIVORCED FROM THE BONDS OF MATRIMONY. 2005 ~ '2-00~ IT IS ORDERED AND :f.:f. :to+; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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; , PLAINTIFF, , DEFENDANT, The Separation and Property Settlement Agreem..nt dated September 13, 2005 is incorporated, but not merged, into the withjLn Decree in Divorce. ATTE: ( rJ~- r --------- . PROTHONOTARY . 'f.'f 'f'f'f 'f'f.:t= :f . , . . . . . . . . . . . . . . J. . . . . . " . ,jp g ~ ~ 50. j,t 01 ~ r ., ~ Ml.f"J ')d.$!" .