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HomeMy WebLinkAbout05-1082 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Tadman S, Glossner, v, Defendant CIVIL ACTION - LAW NO, fJj - I{)~ d.. CIVIL TERM IN DIVORCE Jodie E, Martin, You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, . Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 Phone: (717)249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the Court, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Tadman S. Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, Defendant CIVIL ACTION - LAW NO, CIVIL TERM IN DIVORCE Jodie E, Martin, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Tadman S, Glossner, an adult individual, who resides at 35 Susquehanna Hill Road, Duncannon, Perry County, Pennsylvania 17020, 2. Defendant is Jodie E, Martin, an adult individual, who resides at 116 Mountain View Drive, Enola, Cumberland County, Pennsylvania 17025, 3, Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint, 4, Plaintiff and Defendant were married on September 12,1998 in Marysville, Perry County, Pennsylvania, 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction, 6. The marriage is irretrievably broken, 7. Plaintiff has 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, 8, Plaintiff requests the Court to enter a Decree in Divorce, WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate, Respectfully submitted, ROMINGER, BAYLEY & WHARE ~ 155 S, Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court I.D, # 87663 Attorney for Plaintiff Date: ~-- Z - 0) Tadman S, Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, Defendant CIVIL ACTION - LAW NO, CIVIL TERM IN DIVORCE Jodie E, Martin, VKRTFICA TION 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, 94904, relating to unsworn falsification to authorities, Date: 7/2 , lo~ ~G!f:"j;ff "- % 2. .-' 0 ~ Y\ ~ "'" ~ "'\ 4) r5~1 <J' ..... \, ~ '$ -r:.-.:;:l ~ ~ {t"\ ~ 1. \ ~ ~hi ~ k':'~~" ~ %.- , ~~~. ~. ~L "" \ ~ ~ ...", ,.-,\ "'- W , ~C.~ -:::r:. O~ , :;:0;. ~ --J 'j>-"l 8 CJ ~ ~ __A --... ~ , .", \J ~\ 3 0 ~~:} - :..c::. U\ -...J 71.6. /)r - I Of i!/ MARITAL SEP ARA TION AGREEMENT THIS AGREEMENT, entered into on the specified date: below, by and between Tadman S. Glossner, (hereinafter referred to as "HUSBAND") and Jodie E. Martin, (hereinafter referred to as "WIFE"), WITNESSETH: WHEREAS, HUSBAND and W1FE were lawfully married on September 12,1998; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND 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 their respective financial and property rights and obligations as betw(:en each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all claims and possible claim~ by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consid('ration of the promises and the mutual promises, covenarlts and undertakings hereinafkr set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each oflhe parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1, The parties intend to maintain separate and permanent domiciles and to live apart from each other, It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner that conforms to a just and right standard, with due regard to the rights of each party, It is the intention of the parties that such division shall be final and shall forever determine their respective rights, The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, 3, Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever, Each party may carryon and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, el\ioyment or disposition pf any pror'~lty now owned and not specified herein or property hereafter acquired by the othcr 4, The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other, The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby, 5, Each party to this agreement acknowledges and declares that he or she, respectively: A, Enters into this agreement voluntarily after receiving the advice of counsel of his or her own choosing or has voluntarily elected not to obtain counsel; B. Is fully and completely informed of the facts relating to the subject matter of this agreement and of the rights and obligations of the parties; C, Has given careful and serious thought to the making ofthis agreement; D, Has carefully read each provision of this agreement; and E, Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of arty nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which h,~ or she is currently liable or may become liable, Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other, Each party acknowledges that, to the extent desired, he or she has had access to all of the above information from the other party, Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on behalf of both parties during the marriage, 7. DEBTS AND LIABILITIES: It is further mutually agreed by and between the parties that WIFE will be responsible for the following debts, liabilities, contracts and payments relating to the same: a. Mortgage related to the residence at 116 Mountain View Drive, Enola, P A 17025. WIFE will refinance Mortgage into her own name as soon as possible, b, Lease and insurance costs related to M&T Lease LLC on 2001 Jeep Grand Cherokee; and c. All accounts related to utilities and other miscellaneous accounts for the benefit of 116 Mountain View Drive, Enola, PA 17025, The Parties agree that HUSBAND will be responsible for the following debts, liabilities, contracts and payments relating to the same: a, Loan related to the purchase of stock in Marinak and Glossner D,D,S. P,C, HUSBAND will refinance this loan into his own name as soon as possible; b, Lease and insurance costs related to Fulton Bank on 2002 Dodge Quad Cab 4x4 Pickup; and c, ACS Dental School loan, The Parties agree that HUSBAND and WIFE shall split the following debts, liabilities, contracts and payments relating to the same: a, Pet care including food, toys, and veterinary bills associated with Duke and Rookie until their deaths; b, Filing fees regarding the divorce; c, Cost of rewriting wills for HUSBAND and WIFE; and d. All existing credit card debt to be paid oult of First National Bank of Marysville mutual checking account, 8, CASH ASSETS AND OTHER ASSETS: The Parties agree that WIFE will assume full ownership ofthe following assets: a, Marital residence at 116 Mountain View Drive, Enola, P A 17025 and all furnishings currently within the home; b, 2001 Jeep Grand Cherokee; c, Savings account with National Bank of Marysville containing approximately $7,500,00; d. Roth IRA account with TD Waterhouse (account #43892388); and e, City of Harrisburg Retirement Plan, The Parties agree that HUSBAND will assume full ownership of the following assets: a, Stock associated with Marinak and Glossner D,D.S, P,C,; b. 2002 Dodge Quad Cab 4x4 Pickup; c, Brokerage Account with Waddell and Rf:ed (account #35101916); d, Roth IRA account with TD Waterhouse (account #43892387); e, Marinak and Glossner 40l(k) plan; f, TIAA Cref Retirement Plan; and g, Any and all other assets and/or interests associated with Marinak and Glossner D,D.S,P,C, The Parties agree that HUSBAND and WIFE shall equally split the following assets: a, Scottrade brokerage account #35297650 worth approximately $37,946,93; b, First National Bank of Marysville mutual ,~hecking account worth approximately $11,151.42 (prior to all credit card debt being paid out of this account); c. 2004 Federal tax return; d, Pay Pal Money market account worth approximately $124,06; and e, PSECU checking account worth approximately $56,00, 9, PERSONAL PROPERTY: The Parties have previously separated personal property not otherwise mentioned by this Agreement to their satisfaction, 10, SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be granted, 11, WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, 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, Additionally, each party waives and relinquishes any and all rights to share in any estate inheritances or bequests the other may rel~eive and/or be entitled to, 12, INCOME TAX RETURNS: All future income tax returns following the 2004 tax return will be filed separately and the parties will each retain any refund due to them, 13, DIVORCE: HUSBAND will immediately file a divorce complaint with the Cumberland County Prothonotary and pay all applicable filing fees, WIFE agrees to accept service of the divorce complaint and HUSBAND and WIFE agree to voluntarily execute all necessary documents to finalize a divorce, 14, BREACH: In the event ofthe breach of this agreement by either party, the nonbreaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek specific performance of the terms of this agreement, where such damages are not ascertainable, All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain mom:tary damages and/or specific performance of this agreement shall be recoverable as part of the judgment entered by the court, 15, ADDITIONAL INSTSRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. 16. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect are fully understood by both parties, HUSBAND's legal counsel is Mark F, Bayley, Esquire, WIFE is unrepresented and acknowledges that she may obtain review of this agreement with independent legal counsel and has either done so or has voluntarily chosen not to do so. 17, ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covemmts or undertakings other than those expressly set forth herein, 18. APPLICABLE LAW: This agreement shall b(: construed under the laws ofthe Commonwealth of Pennsylvania, 19, PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which mayor have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 20, parties, This agreement shall become effective immediately upon its execution by both IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on the date indicated below, WI ESSES: / Idw- ~f ;;JL 3-'-{-OS Date l: aDman S, Glossner Cft:-~ ~ ' :d-- / ?1ffa~' 'ttIa.L Jodi . Martin 3-I-P~ Date COMMONWEAL TH OF PENNSYL VANIA : SS COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County Pennsylvania, this Ljr,C day of /lJ4.efi f-- ,2005, Tadman S. Glossner, known to me (or satisfactorily proven) to be the person whose name is subs(:ribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained, IN WITNESS WHREOF, I have hereunto set my hand and official seal. NoialioI Sclal UndaJ..JiITlper,IIIoIarYPltlIic CliIIi*IloIO. ~ Colriy MIl Ca..IMiOn ElqlII\l8 JoiI23. 2006 ........"'-__~~Of~ )(~~ 0 9z~'(j ~lbU'l ' COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County Pennsylvania, this / day of i!kJ~__, 2005, Jodie E. Martin, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained, IN WITNESS WHREOF, I have hereunto set my and and official seal, COM ONW - 'fH of PMISYLVANIA r: NOTARIAL SEAL KITTY M, GLASSER, Notary Public SiI\1ll1' Spring Twp., Cumbe~and Coll1ly ,~_~~ Expires Ju:r 27. _~. ~ .,,' -l:~' .' ' n C": C. :;; ~ ...., cc, = "-', '--- c.:: r~'. o ., -< ffip: -r'1n-~ ::)d ',_! T " () ~2~:q .."}rn ~:::l _J> ~JJ ,-< w --, -,,. -"-'.. N c.J1 ... Tadman S. Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Defendant CIVIL ACTION - LAW NO, 05 -1082 CIVIL TERM IN DIVORCE Jodie E. Martin, AFFIDAVIT OF CONSEI'IT 1, A Complaint in Divorce under 93301(c) of the Divorce Code was filed on March 2, 2005. 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 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. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, &-?:O-~ Date o c; ;.( ~"\;;'..' ~"i.;; 0. ~~< .~~~.~, ?~ ';;5 "'" eft t..-_ c:::: r - c.:> ~ ..--l :!:-n rr\r:': ~<Mtrr,,; :DY c~~c> 6~~ Z.f'n \~ --..... /1) :-< -0 ::;;: ~ (fl .;:- Tadman S. Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, Defendant CIVIL ACTION - LAW NO, 05 - 1082 CIVIL TERM IN DIVORCE Jodie E. Martin, ~FFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 2, 2005, 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 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, 7-/~-05 ~.~'~ Jodie E. Marti Date (') c::; ?-:'. ....~nl ~~i; ~,~ ~ :~~\ -7 3. ~ e r - w ~ ~.,., ftlr -or:q :01- S?\i~, ']:"'1 0(') f!-{il '"~ ~ -0 ::J:; ~ c..n Jo;' - Tadman S. Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, Defendant CIVIL ACTION - LAW NO, 05 - 1082 CIVIL TERM IN DIVORCE Jodie E. Martin, WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 if.} 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, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, 6 -?/i)"iJS Date ~;;"'!~ Q '" ~, -c:" Cr~i'; <;,>' 6:>~ r:~t ~~~': -- c.. ~. I'-> = <::> en t- c: .. R, :r..,.. rnp ""'Om -''19 ?-''') 6 ::-j-,; -" """) ;:5<"5 'C':rn ~~ -". .:::;;.. " 0< w '"'0 :s: ~ U\ .s:- - Tadman S, Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Defendant CIVIL ACTION - LAW NO, 05 - 1082 CIVIL TERM IN DIVORCE Jodie E. Martin, WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (g 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. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 1-1:J.-o'$' ~LY}/a.t-<- Jodie E, Martin Date (") ~ "'.~ ;~~~ ~~: r': ::::::: ~;~~I Jo- 5:- ::;! r--> = = CJ' <- c:: .- ~ ~.." rnp "orQ ~n:""'" ~------\ L 1...-" C) -~'Tj I--"lJ ;i~fJ ".~ ~ '-< c..> -0 :;. ~ <-n .;:- - Tadman S, Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, Defendant CIVIL ACTION - LAW NO, 05 - 1082 IN DIVORCE CIVIL TERM Jodie E, Martin, A.f:CEP'I:,\JltC;;.E.Q.F SERVJ.CE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Jodie E, Martin, in the above-captioned action and I certify that I am authorized to do so. '3' ,,-() 5' Date BY: ~:u E)t1a..1Z- JodI artm, Defendant (') ~,~:, r--' <= = "'" '- c;::. ,- - r' ~ :'j v:> -0 :>>~ r;-? <J\ ..,- o -n :t..,., rl1-~'::: -010 :l~} r..;; Q/::> i~J~; '':::-:::\ -2:.\'5 :< Tadman S, Glossner, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, Defendant CIVIL ACTION - LAW NO, 05 - 1082 CIVIL TERM IN DIVORCE Jodie E, Martin, PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown undt:r 9 3301(c) of the Divorce Code, 2, Date and manner of service of the Complaint: Deftmdant signed Acceptance of Service on March 3, 2005, 3, Date of execution of the affidavit of consent required by Ii 3301(c) or The Divorce Code: by the Plaintiff June 30, 2005; by the Defendant July 12,2005. 4, Related claims pending: None 5, (b) Date Plaintiffs Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: on July 13, 2005; Date Defendant's Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: on July 13,2005, Date: July 13, 2005 Mark F, Bayley, Esquire Rominger, Bayley & Whare 155 S, Hanov,er Street Carlisle, PA 17013 717) 241-6070 Supreme Court LD, # 87663 Attorney for Plaintiff (") ~ "!:-;; -C('l n'';'1 '-7" ?7;~ ,,__. c'- ~;t_..' );-"" -;; ~ -<. ~ = c.T' ~ r- - w -0 -'$;,' -- Q. :::e...,.-, fn ~- r;: -of.c-j -<:-"..1, 60 ::3-r< .\----.n ~~~~\ J":' ;,Q .-<. t:Y '-" .r.:- , , . . . . . . , . . . . , . . . . . , . . . . . . . . . . . . . . . , . . . , . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . " . . . . ;f.:+::+::+i:f. ., :+::f. ;t;:f. Of. ;Ii :f.;f. :+::f. :+: , .. . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Tadman S. Glossner Plaintiff VERSUS Jodie E. Martin Defendant AND NOW, DECREED THAT AND PENNA, No. 2005 1082 DECREE IN DIVORCE ~ cP; (TO c:1 f. 'SO,.~ . ,(JD6", IT IS ORDERED AND Tadman S. Glossner , PLAINTIFF, Jodie E. Martin , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY, l+.;Ii;+;:+: '+'. . . . . . . . . . . . . . . . . . . . . . , . . , . , . . , . . . . . , . , . . . . . . . J. . . . . . . , . . , . , . . . , . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 't:,+,+.'f. 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; None. The Marital Settlment Agreement is By incor with the Divorce Decree . Am'{!~~J PROTHONOTARY :f. 'l' :f. "',., 'f. Of. :f... '+' 'f' . .. '+' '+' 'f':f. _;:# 2' J'tl=:" "'f!J,t, 517- 11'L. fr4 fr-'" ~ 4Hv""" 50 IN " .. .... "-,.