The URL can be used to link to this page

Home My WebLink About05-2197 MARK S. PETRUNAK, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. () ') - ;)t'l:j Civil Term KAREN L. PETRUNAK, Defendant : ACTION 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 e following pages, you must take prompt action. You are warned that if you fail to do so, th 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 n these papers by the Plaintiff. You may lose money or property or other rights important to ou, including custody or visitation of your children. Where 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 t the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, T E OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HEL Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 . MARK S. PETRUNAK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05'-,;l. ,ql Civil Term KAREN L. PETRUNAK, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Mark S. Petrunak, a competent adult individual, who resides at 9 Heatherwood Drive, Dillsburg, Pennsylvania. 2. Defendant is Karen L. Petrunak, a competent adult individual, who resides at 801 Sandbank Road, Lot 24, Mount Holly Springs, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for t least 6 months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and the Defendant were married on May 16, 1998 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties 6. Plaintiff has been advised that counseling is available and that plaintiff may hav right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together, namely, Bethany Renee Pet ak, date of birth, November 11,1999, and Jessica Leigh Petrunak, date of birth May 6, 2001. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United tates of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verifY that the statements made in this Complaint are true and correct. I understan that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to un om falsification to authorities. /}t?sJ ~ Mark S. Petrunak, Plaintiff Date: "l Zip . 0 '5 e Adams, Esquire . No. 79465 6 South Pitt Street arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~ ~ v.J \).l ~ ~ (8 0 "" ~ s;;; = 0 = 0 ~r0 c.n -n - :r>- ~ ~. ~ -0 :>:J ni~ N :no ~ ~t.') ..... ~~6 -- - ~~.~~ :> -rl; % '-CJ ::l'.: rS:p - ~.() '" ~ :;.?: - ~5nl .. -..{ ::;2 U1 )"> :n ~ ..... .< ~ v-. MARK S. PETRUNAK, : IN THE COURT OF COMMON PLEAS Plaintiff V. : NO. 05 - 2197 Civil Term KAREN 1. PETRUNAK : CIVIL - CUSTODY Defendant AFFIDAVIT OF SERVICE AND NOW, this May 4,2005, I, Jane Adams, Esquire, hereby certify that pn May 3, 2005, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE was served, via certified mail, return receipt requested, addressed to: Karen 1. Petrunak ~I Sandbank Road Lot 24 ount Holly Springs, Pa. 17065 EFENDANT ' . 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~e front jf space permits. 1. Article Addressed to: o ,Agent Add_ D.I_~_ i eryaddressdifferentfromitem1? DYes /-11 YES, enter delivery address below: ~ No ~\1;n L. r e -tYVh lA t:- C(b \ SClY\J bci.Vl k gd l--ot J~ Mt ~n'1 S?r'lfVj(, fA I/o -- 3. Service Type . Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) . Yes 2. Article Number (Transfer from service {abeO PS Form 3811 , March 2001 7004 1350 0003 7143 7010 Domestic Return Receipt 102S9S-01-M-1424 dams, Esquire o. 79465 6 uthPitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF .'('",c", ,1'\'. ->, q~ C) C; _0 'c_~ ~ - _:f;~ ~. -"" \ cr' ~ ....., ?"~ B ~" J;:' "",-'" :17 ~~ ~~. ::1. C) -,<I q.." nic~ ~" -,,"',C: '::~jS?\ .1 '-"1"<- ,:~\,n "J:~ ~ "'" MARK S. PETRUNAK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 05 - 2197 Civil Term KAREN L. PETRUNAK, Defendant : IN CUSTODY AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on April 27, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 also understand that false statements herein are made subject to the penalties of 18 Pa.e.S. 4904, relating to unsworn falsification to authorities. Date: G/'J- / b ~ '&- ) , Q . ~2nak, Plaintiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 6330He) AND 6330Hd) OF THE DIVORCE CODE I. I consent to entry of a fmal decree of divorce without notice. 2. I understand that [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. ~4904 relating to unsworn falsification to authorities. ~ / 5G/ " ~ ~ak, Plaintiff Date: b/7(~ \Il (') G r-> = = "'" ,- S 1 0:.> -c -:;; ~ ~..,.. \tIC':' ..-.;:4." -,)0 \~ :Q: - tJ' <J'. MARK S. PETRUNAK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 05 - 2197 Civil Term KAREN L. PETRUNAK, Defendant : IN CUSTODY . AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 330 I (c) of the Divorce Code was filed on April 27, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 1 verifY that the statements made in this affidavit are true and correct 1 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. 'J ]/ ,'- ./ L/ ./ DZ~!oCt WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 63301(.) AND 63301(d) OF THE DIVORCE CODE I. I consent to entry of a fmal 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 this affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. ) ~ Date: tR/06/0b (') f~ ,..., ~ '- ,- ...~~. ....-(.... ~- "i:_",l:' fJ\\-: '"r" ~..- c...,:: r=~ :;!-1 ::< I 0:> -0 :;>; ~ :(-n r1"1-- , 1;;, -0'" "IJY (::),.:-, .~srt ?,~:~~~ 'C:::'r1i S ~ - .' ()'l 0" ,.. MARK S. PETRUNAK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 2197 Civil Term KAREN L. PETRUNAK, Defendant ACTION IN DIVORCE fA THIS AGREEMENT, made this 7 day of a ~ - , 2006, by and between, KAREN L. PETRUNAK, of Mount Holly Springs, ~;Yl;~i;hereinafter referred to as "WIFE", and MARK S. PETRUNAK, of Dills burg, Pennsylvania, hereinafter referred to as "HUSBAND" . WITNESSETH: WHEREAS, Husband and Wife were lawfully married on May 16, 1998, in Cumberland County, Pennsylvania, and; WHEREAS, there were two children born of this marriage; WHEREAS, 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 desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Jane Adams, Esquire, as his attorney. The Wife has elHflleyea liRa HRa lRe lleRefit er eetlllsel -of- in- P?D ~ , as Hef atteffill)i. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. Wife has been advised of her right to counsel, voluntarily elected to forego representation, and understands that Jane Adams, Esquire is only representing Husband. 3. SEP ARA nON. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose ofthis agreement to set forth their respective rights and duties while they continue to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may cany on and engage in any employment, profession, business or other activity as he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Divorce in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. Wife hereby expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree. judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remany. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. 6. MUTUAL RELEASE OF ALL CLAIMS. Other than as provided in this agreement, each party may dispose 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, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. 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 interest. rights, and claims. 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold hannless from the other and against all future obligations of every kind incurred by them, including those for necessities. 8. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. All loans payments due for the Explorer and Camper. Once these loans are paid off, Husband will sign over all his right, title and interest in these items to Wife. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. All payments for the 1000 trails loan. Once this loan is paid off, Wife will sign over all her right, title, and interest to this item to Husband. 9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each party to the education, training, or increased earning power of the other party; the opportunity for each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. As such, the parties acknowledge that Husband or Wife's obligation to make the payments defined in this agreement shall not be subject to termination, discharge, or discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. At the time ofthe implementation of this alimony award, which may be made through the appropriate Domestic Relations of support office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may select, such party shall then be responsible for any such debts extinguished through the other party's bankruptcy as described herein. 10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all ofthe property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. Wife shall receive the Crib, the small desk, the large bookcase, half the photos, the rototiller, and $147.73. 11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The Explorer and Camper shall be and remain the sole and exclusive property of Wife. Wife shall pay for and maintain insurance on these vehicles and shall provide husband with a proof of insurance as long as his names are on the titles promptly upon his request. (b) The Geo Tracker shall be and remain the sole and exclusive property of Husband. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days after full satisfaction of all loans on the vehicles and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12. MARITAL HOME. The marital home has been sold and the proceeds have been satisfactorily divided by the parties. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. Other than as provided in this agreement, the parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. Husband and Wife agree that $15,600 will be transferred from Husband's retirement into a separate retirement account for the sole benefit of Wife. Husband and Wife will cooperate with preparing a Qualified Domestic Relations Order if necessary. 14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively have against the other for alimony, support, or maintenance. It shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. All alimony to be paid under this agreement shall terminate upon the recipient's remarriage or cohabitation with a person of the opposite sex. 15. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their knowledge all federal, state, and local taxes required to paid with during the marriage and during the periods covered by such tax retums have been paid. Husband and Wife further represent that there are no tax deficiencies proposed or assessed against Husband and/or Wife for such periods, and neither Husband nor Wife executed any waiver of the Statute of limitations on the assessment or collection of any tax for such periods. If any deficiency in federal, state, or local income taxes is proposed, or any assessment of any such tax is made against the other party by reason of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife shall indemnifY and hold harmless the other against and from any and all tax, interest, penalty, or expense relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax, interest, and penalties or expenses shall be paid solely and entirely by the responsible party as determined to be attributable to that party on account of misrepresentation or failure to disclose relevant information of income on the aforesaid joint returns. 16. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 17. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 18. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 21. NO WAIVER OF DEF AUL T. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 22. SEVERABILITY. 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 only that term, condition, clause, or provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 23. BREACH. If either party breaches any provisions ofthis agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 24. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: ~~,~ U ltness ,~\~~ KAREN L. PETRUNAK, Wife Date: &, -(., -tJ '" COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the (, dayof:i ~ , 200" before me, the undersigned officer, personally appeared KAREN L. PETRUNAK known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that tit/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ./..5 otary :eOIllUoNWEALTH OF PE NSYLVANIA Notarial Seal aonnie L. Shelley, Notary Public My co lIUtI~t_:cumberlandCounty My CommiSSlon ExplfesOcl.19, 2008 . Member. Pennsvlvanig Associ8.tion Of Notanes SEAL , . " . ~()i~ 1 ess Date: Co . J. (p ~s~ M . TRUNAK, Husband COMMONWE. ALTH~F ENN .YLVANIA 'fl".'i\ O(l&~ ,..A ):ss C6UNTY OF ~d1 ERLAND ) On this, the ~1J- day of Q",~ , 200' before me, the undersigned officer, personally appeared MARK S. PE1Jl:UN~~known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. ) IN WITNESS WHEREOF, I hereunto set my hand and official seal. commission expires: SEAL MMONWEALTII OF 1i. Notarial Seal J8IIe Adams, NOlllIy PubIio Carlisle Iloro. eumbedlnd COU8lY My Commission Expires Sept. 6, 2llO8 , ~--- n ;.", .-' ","'> .~.., v' , CP o -11 :?--n r-nc "!"lCC '.-....,.... ,;~I>i) .c' --r, ,.'') _. )1-n _:~-\ 55 -< ..... en (.n MARK S. PETRUNAK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 05 - 2197 Civil Term KAREN L. PETRUNAK, Defendant : IN CUSTODY PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 9330l(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, return-receipt requested, on: May 3, 2005. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: June 7, 2006. By Defendant: June 6, 2006. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: June 8, 2006. Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: June 8, 2006. Date: ~ 1 \ ~ \ ~ e Adams, Esquire . No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff o ?::: '" C"::;:) C~::;) =' <-- c::.: o -n -l X:n rnl~ -arT, ~:)D .' ~ ~;~~:, ',}24 ::~rn 55 ,.< w " (J1 CO . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . STATE OF PEN NA. Mark S. Petrunak, Plaintiff No. 2005 - 2197 Civil Term No. . . VERSUS . . Karen L. Petrunak, Defendant . . . . . . . DECREE IN DIVORCE crl(:~' ,Jt;i)fo, IT IS ORDERED AND . . . . AND NOW, -:::r v-e. ~ . Mark S. Petruank DECREED THAT , PLAI NTI FF, Karen L. Petrunak . AND . 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; None; the marriage settlement agreement which was executed June 7, 2006, and . . J. filed June 8, 2006, shall be incorporated . PROTHONOTARY . . . . ATTEST: . . .;/;' ff ~ ~ *.Le-? ~~$~~/'P <Xl-L~''l .. ~ ~ . ..., ",' _..40