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HomeMy WebLinkAbout05-1328 .'~ '," cr~lv LINDA B. LEE, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. :ClVlL ACTION - LAW :IN DIVORCE PETER S. LEE, :NO. 0 f: - Golf C;o'cl~9L"'1 Defcndant 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 for any other claim or rclief 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 thc divorce is indignities or irretrievable breakdown of the marriage, you may requcst marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House I Courthouse Square Carlisle, Pennsylvania] 7013 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. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 170]3 (717) 249-3166 (800) 990.9] 08 -- '..' LINDA B. LEE, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY. PENNSYL VANIA Plaintiff v. :CIVIL ACTION - LAW :IN DIVORCE PETER S. LEE, C;u;L <-y-~ Defendant :NO. or; - IJ;M> COMPLAINT AND NOW comes the Plaintiff, Linda B. Lee, who, by and through her attorneys. Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, tiles this Complaint, in which she avers that: I. Plaintiff, Linda B. Lee, is an adult individual residing at 305 Allendale Way, Camp Hill, Cumberland County, Pennsylvania 170 II. 2. Defendant, Peter S. Lee, is an adult individual residing at 305 Allendale Way, Camp Hill, Cumberland County, Pennsylvania 170 II. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the tiling of the original Complaint. 4. Plaintiff and Defendant were married on October 15, 1988. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. .. " 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNTl REQUEST FOR A NO-F AUL T DIVORCE UNDER SECTIONS 3301 (c) OR (d) OF THE DIVORCE CODE 8, The averments contained in Paragraphs I through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she may havc the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa,C.S.A. 99330I(c) or (d), Plaintiff, Linda B. Lee, respectfully requests the Court to enter a Decree of Divorce. COUNT II EQUITABLE DlSTRJBUTlON UNDER SECTION 3502 OF THE DIVORCE CODE ] ] , The avennents contained in Paragraphs I through 10 of this Complaint arc incorporatcd herein by refercnce as though set forth in full. 12. Plaintiff and Defendant have acquired property, both real and personal, 2 .', . during the marriage which constitutes marital property subject to equitable distribution under the Divorce Code, 13. Plaintiff and Defendant each owned, prior to the marriage, both real and personal property which has increased in value during the marriage, and/or which has been exchanged for other property which has increased in value during the marriage, all of which property is marital property, subject to equitable distribution under the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff, Linda B. Lee, respectfully requests the Court to divide all marital property equitably between the parties. COUNT III REQUEST FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 15. The averments contained in Paragraphs 1 through 14 of this Complaint are incorporated herein by reference as though set forth in full. 16. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to completely support herself through appropriate employment. 17. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard ofliving established during the marriage. 3 WHEREFORE, Plaintilf, Linda B. Lee, respectfully requests the Court to enter an award of alimony in her favor. COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES UNDER SECTION 3702 OF THE DlVORC CODE 18, The averments contained in Paragraphs J through J 7 of this Complaint are incorporated herein by reference as though set forth in full. 19. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 20. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintift~ Linda B. Lee, respectfully requests the Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final heari ng and thereupon a ward such additional counsel fees, costs and expenses as deemed appropriate. DATED: ]-1/-05 Respectfully submitted, of Counsel /~~ - BECKLEY & MADDEN 2 1 2 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (7]7) 233-7691 4 VERIFICATION I, Linda B. Lee, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: 3 -j/--oS- ! \ () p\\- ~ - " "Q -.I:. .h. .\A.. ~ ".-0 B ~ '? . V) VI \> C> ~ c ? VJ \ w ~J r~ ~ "r--: 4- r .--1- W ~ "--, ';.,-;, ~,.:: .~':\ ";';__1 ~ ,'.. ;;.. ...-:;"" <..-;': - ~,"' 5~ _..'.. LINDA B. LEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW vs. : IN DIVORCE PETER S. LEE, : NO. 05 -- 1328 Defendant ACCEPTANCE OF SERVICE I, Susan M. Kadel, Esquire, hereby accept service of the Divorce Complaint filed in the above-captioned action on behalf of the Defendant, P~:ter S. Lee. DATED: 1'1~...?..s;. 1/"05" --,~/dL Susan . Kadel, Esquire ..--. - ~ p ..., = = """ en rt1 v I o "Tl :r n~-n -r.:Fn ::UCJ ~~~ (J.., J~ _.f'~ :..~ -rt ~;::~(=s ;;.')11"1 ;=t i> 5:J .< :!? -:;::.,. w o '... .,. PROPERTY SETTLEMENT AGREEMENT 5"'lc- {SL,.. This is a Property Settlement Agreement entered into this .::5~ day of J~ (; 20M, by and between PETER S. LEE, of Cumberland County, Pennsylvania (hereinafter referred to as "Husband"). and LINDA B. LEE, of Cumberland County, Pennsylvania (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 15. 1988. and; WHEREAS, unhappy differences have arisen between Husband and Wife III consequence of which they are now living separate and apart from each other; and WHEREAS, Husband and Wife are now in the process of obtaining a divorce. and. consequently. they desire to settle and determine finally and for all time both their respective financial and property rights, including any and all claims which either of them may have against the other. NOW THEREFORE, in consideration of this Property Settlement Agreement, and of the mutual promises, covenants and undertakings set forth herein. and incorporating the above "WHEREAS" clauses herein by reference, the parties hereto, each intending to be legally bound, hereby agree as follows: ]. SEPARATION: It shall be lawful for eaeh party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. ... 2. INTERFERENCE: Each party shall be free from interference, authority and contact 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 the other or attempt or endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the other's peaceful ex istence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the separation 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 that she shall indemnify and save harmless Husband from any and all claims or demands incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wile or her estate might be responsible, and that he shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him, 5. OUTST ANDING .JOINT DEBTS: All debts, obligations or liabilities incurred at any time in the pa~t by either of the parties will be paid promptly by the party which incurred such debt. obligation or liability, unless except as otherwise specifically set forth in this Agreement. Each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save hannless and keep the other or his or her estate indemnified and saved harmless from all debts or liabilities incurred by him or her, as the case may be, and from all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and counsel fees whatsoever 2 . '. appertaining to such actions, claims and demands. Neither party shall, after the date of this Agreement, contract or incur any debt or liability for which the other or his or her property might be responsible, and shall indemnify and save hamlless the other from any and all claims or demands made against her or him by reason of debts or obligations incurred by her or him, and from all costs, legal costs and counsel fees incurred in connection therewith unless provided to the contrary herein. 6. BANK ACCOUNTS, RETIREMENT ACCOUNTS AND INSURANCE: Husband and Wife are owners of individual savings, checking and pension accounts and insurance at various institutions, and Husband hereby releases all claims in and to all accounts in the name of Wife, and Wife hereby releases all claims in and to all accounts in the name of Husband, and each party shall retain as his or her separate property each account currently titled to that party. Husband and Wife agree to sign, upon request and after execution of this Agreement, any titles or any other documents reasonably necessary to give effect to this Section. 7. HUSBAND'S RELEASE: Husband does hereby release, remIse, quitclaim, and forever discharge Wife and the Estate of Wife from any and all claims that he now has or may hereafter have against Wife, or in, to, or against her Estate or any part thereof, whether arising out of any former contracts, agreements, engagements. or liabilities of Wife, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Wife's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever. excepting only those rights accruing to Husband under this Postnuptial Agreement. 3 . '" 8. WIFE'S RELEASE: Wife does hereby release. remise. quitclaim. and forever discharge Husband and the Estate of Husband from any and all claims that she now has or may hereafter have against Husband. or in, to, or against his Estate or any part thereof, whether arising out of any former contracts. agreements. engagements. or liabilities of Husband. or by way of dower or claim in the nature of dower. spouse's right or under any intestate laws or the right to take against Husband's Will. or for equitable distribution, support. alimony, alimony pendente lite, or maintenance of any other nature whatsoever. excepting only those rights accruing to Wife under this Postnuptial Agreement. 9. MUTUAL INDEMNIFICATION: Each party represents that no debts, liabilities. or obligations have been incurred or contracted for for which the other party or the Estate of the other party may be responsible or liable. except those specifically identified in this Agreement. Each party hereto shall hereafter keep the other and his or her heirs and personal representatives indemnified and saved harmless against and from all debts and liabilities contracted for or incurred by or on behalf of the indemnifying party. and against and from all actions, proceedings. claims, demands. costs, attorneys' fees and expenses incun'ed in respect to any such debts or liabilities, excepting, however. obligations of the parties hereto to each other under this Agreement. 10. DIVISION OF REAL PROPERTY: Wife owns the marital residence. situated at 305 AlIendale Way. Camp Hill, Cumberland County, Pennsylvania. Husband and Wife agree that Wife will remain the sole and exclusive owner of the marital residence. 4 . ' . ] ]. DIVISION OF PERSONAL PROPERTY: The parties have divided between them. to their mutual satisfaction, their personal property and the persona] effects. household furniture and furnishings, and all other articles of personal property which have theretofore been used by them in common. and neither party will make any claim to any items of personal property which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. 12. AUTOMOBILES: Husband and Wife agree that Husband shall be the sole and separate owner of the 200] Toyota Tacoma and Wife shall become the sole and separate owner of the 2001 Toyota Solara. Husband and Wife agree to assume all responsibility for any outstanding debt balance on his or her respective vehicle, indemnifying and holding the other harmless from any financial responsibility arising from nonpayment thercon. Husband and Wile agree to execute any and all instruments and documents necessary in order to effectuate the transfer of title to said automobiles. 13, LIFE INSURANCE POLICIES: Husband and Wife agree to waive any and all claims and relinquish all rights and interest they may have in any and all life insurance policies of the other. 14. COUNSEL FEES: Husband and Wife agree to be solely and separately responsible lor his or her own counsel fees, 15. BREACH: If either party breaches any provision of this Agreement the other party shall have the right. at his or her election. to sue lor damages lor such breach. to sue for specific performance. and to seek such other remedies or relief as may be available to him or her. and the party breaching this contract shall be responsible lor 5 . ,6 , . . payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: Each ofthe 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. 17. VOLUNTARY EXECUTION: Wife has employed and had the benefit of counsel from Elizabeth S. Beckley. Esquire, as her attorney. Husband has employed and had the benefit of counsel from Susan M. Kadel, Esquire as his attorney. Each party acknowledges that he or she fully understands the facts and has been fully informed as to his or her legal rights and obligations. and each party acknowledges and accepts that this Agreement is. under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and/or with such knowledge as each party desires, and that execution of this 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. Also, each party hereto acknowledges that under the Pennsylvania Divorce Reform Act. the Court has the right and duty to determine all marital rights of the parties. including divorce, alimony, alimony pendente lite. equitable distribution of all marital property or property owned or possessed individually by the other. counsel fees and costs of litigation and, fully knowing the same and being advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties, and each party waives their respective right to have the Court of Common Pleas or any Court of competent jurisdiction make any determination or order affecting the respective parties' right to a alimony, alimony 6 ... -.. 22. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in detennining the rights or obligations of the parties, IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written, ~h~~ Susan M. Kadel. Esquire Pe l5,~~ c#ff! (K/i;m~ COMMONWEALTH OF PENNSYLVANIA ) ) 55.: D0\Ap\i; r\ ) COUNTY OF . 3 r(\ On thIs the ----=- day of '"} AI'"\W'I ~ ~ , 2001 before me. the undersigned officer, personally appeared PETER S. LEE. known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument. and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. Lf{~i~\A AU ~. fL;L" My Commission Expires: NOOOM~oN%i!ALTH OF PENNSYLVANIA Notarial Seal Mar" B. laRue, Notary Pu!]k: Derry Twp., Dauphin County My Commission Expires NOlI, 8, 2009 Member, Pennsylvania Association of Notaries 8 ...- COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 1JfJ7A pdJ/ j/ ) SS.: ) On this the /3~y of J}duiulj . 2005, before me, the undersigned officer, personally appeared LINDA B. LEE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF. I have hereunto set my hand and notarial seal. My Commission Expires: COMMONWEAlTH OF PENNSYLVANIA NOTARIAL SEAL ELIZABETH ~. BECKLEY. Notary Public CI~ ot HarnsDurg, Dauphin County M'. .' .<m1mlS3lOll Expires March I 7, 200~ . . 9 C\ .....,:1 r..~' .:~ ,-;".. o -n :.-:1 -q rij L,,) I ("-.J r"-' --..I ~ LINDA B. LEE, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNS YL V AN IA Plaintiff v. :CIVIL ACTION - LAW : IN DIVORCE PETER S. LEE, Defendant :NO. 05 - 1328 AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 14, 2005. 2. The marriage of plaintiff and 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 after service of notice of intention to request entry ofthe decree. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsitication to authorities. Dated: j-3;-O(P ~; () (>~-, -.n c-., '"'1 c:.~ ".J I N ~.D r:? 0-' . LINDA B, LEE, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLV ANIA Plaintiff v. :CIVIL ACTION - LA W : IN DIVORCE PETER S. LEE, Defendant :NO. 05 - 1328 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330t(C) OF THE DIVORCE CODE I. 1 consent to the entry of a tlnal decree of divorce without notice. 2. I understand that I may lose rights concernmg 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 alter it is filed with the prothonotary. I veri fy that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn talsification to authorities. Dated: j- 3/- 0(0 1 AJ::~)' , fJAJ).-+-!4 - in a B. Lee c-: ~,.; r~) C~ ,..-,.> (;...1'" ..," reI t:>J t N ':'(1 :.:.? 01 -0 t:? C'il LINDA B. LEE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-1328 PETER S. LEE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 14, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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! 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904, relating to unsworn falsification to authorities. Date: iJ~ P er S. Lee, Defendant /3/c'G .--< ~::':~ C) (;~::- ~'i I L.... ~, 1'"", C-'J I 1"'\) -' ~) C'l ., LINDA B. LEl', Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : DAIJPIIIN COUNTY, PENNSYLV ANIA v. : CIVIL ACT]ON - LA W : IN DIVORCE PETER S. LEE, Defendant : NO. 05 -- 1328 PRAECII'E TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record. together with the (j)llowing information, to the COLllt for the entry of a [kcree or Divorce. I. Ground {()l" divorce: irretrievable breakdown of the marriage Ilnder Section 3301(c) of the Divorce Codc. 2. Datc and manner of scrvice of the Complaint: the complaint was servcd on Peter S. Lce, by his attorncy. Susan M. Kadel. Fsquire, accepting service of thc same on March 25, 2005. 3, Date ofexeeution of the af"lidavit ofeonscnt rcquircd by Section 3301(c) orthe Divorce Code: by plainti IT on January 3\, 2006; by defendant on January 3. 2006. 4. Related claims pending: None, 5. (a) Datc plaintifrs Waiver or Notice January 31. 2006, and it is being liled contemporaneously herewith. (b) Date defendant's Waiver of Notice January 3. 2006, and it is being filed conlcmporaneously herewith. DATED: ~~ =<0" BFCKLEY & MADDEN 212 North Third Street 1',0. Box 11998 Harrisburg, I' A \7\ 08 (717)233-7691 of Counsel If' CERTIFICATE OF SERVICE 1. Elizabeth S. Beckley. Esquire. herehy certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. DATED, J-MG SERVICE BY FIRST CLASS MAIL: Susan M. KadeL Esquire .lames Smith Dielleriek & Connelly 1',0. Box 650 lIershey.I'A 17033 ~ .' _on -n r-t'l 'Co I r" -'Ci -....... r-.~: - 'f'f.:t;F.;+: . . . . ;+:;+:;+:;+:;F.;+:;+: ;F.:f. ;+: ;+: ;t;+:;F. ;F. ;+: ;F.if.if. ;F.if. ~~if. ~:f.if. ;F.if.;t;+:;F. ;F.if.if.'f.'f.;F.if.;F.;+: 'f.;+:~if.;F. if.'f.'f.;F.if. IN THE COURT OF COMMON PLEAS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . OF CUMBERLAND COUNTY STATE OF LINDA B. LEE, Plaintiff VERSUS PETER S. LEE, Defendant . . . . . . . . . . . . . . . . . PENNA. No. 05 -- 1328 DECREE IN DIVORCE 4"' tf,'ooA.tt1 . 2006 AND NOW, F~t. ~ --, DECREED THAT LINDA B. LEE . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . AND PETER s. LEE r IT IS ORDERED AND , 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; The Property Settlanent Agreanent between the parties shall be incorporated into the final decree for purposes but shall not merge with . . . . . . " . . . ATTEST: I ~- k.~. PROTHONOTARY .. . .. 'f.'f.;F.if. if. . . 'f.;F. :f.'f.'f.'f.if.;F. if.;+:;F.'f."" . , . . , . . . . . , . . . . . . . . . . . . . . , . . . . , . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . J. . . . . . . . . . . . . . . . . . ;F.;F.fI;;+:'f. ';:" ffri' ~.,.,f /.nyf" /n / )1 /-7""?i f;>!' ;cre - r~ -'U , C /(r/"fJ' Y fl-/'(T~'" 44'" Pc,." 01 - ( . .