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HomeMy WebLinkAbout05-3964GREGORY A. FORGIE, JN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE CATHERINE E. FORGIE, Defendant :NO. 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 relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 GREGORY A. FORGIE, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE CATHERINE E. FORGIE, Defendant :NO. Os 3 4G Y Coa -7Z, COMPLAINT AND NOW comes the Plaintiff, Gregory A. Forgie, who, by and through his attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which he avers that: 1. Plaintiff, Gregory A. Forgie, is an adult individual residing at 1117 Saffron Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, Catherine E. Forgie, is an adult individual residing at 8 Bayberry Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on September 10, 1994. 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. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs 1 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 he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. §§3301(c) or (d), Plaintiff, Gregory A. Forgie, respectfully requests the Court to enter a Decree of Divorce. DATED: of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 2 Respectfully submitted, VERIFICATION I, Gregory A. Forgie, 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 unworn falsification to authorities. DATED: -3 -pr Gregory orgie c O V A w v, ^\v r ? ?tl 1 f? ?C n GREGORY A. FORGIE, VS. Plaintiff CATHERINE E. FORGIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 05-3964 ACCEPTANCE OF SERVICE I, Catherine E. Forgie, hereby accept service of the -Divorce complaint filed in the above-captioned action. DATED: Ail- Catherine E. Forgie ca o ? CO ar! i?r " Y7 G7 PROPERTY SETTLEMENT AGREEMENT This is a Property Settlement Agreement entered into this ?h ay of 2007, by and between GREGORY A. FORGIE, of Cumberland County, Pennsylvania (hereinafter referred to as "Husband"), and CATHERINE E. FORGIE, of Cumberland County, Pennsylvania (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on September 10, 1994, and; WHEREAS, one child has been conceived of this marriage: Amanda E. Forgie whose date of birth is November 2, 1999; and WHEREAS, unhappy differences have arisen between Husband and Wife in 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 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: 1. SEPARATION: It shall be lawful for each 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 1 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. Upon execution of this agreement, both parties shall sign consents and waivers to the divorce action, which consents and waivers shall be promptly transmitted to counsel for husband who shall promptly transmit them to the Court with a Praecipe to Transmit and all appropriate documents to finalize this divorce. 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 existence, 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 Wife 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. OUTSTANDING JOINT DEBTS: All debts, obligations or liabilities incurred at any time in the past by either of the parties will be paid promptly by the party 2 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 harmless 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 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 harmless 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 AND RETIREMENT ACCOUNTS: Husband and Wife are owners of individual savings, checking, money market and retirement accounts at various institutions. 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 3 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. 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 incurred in respect to any such debts or liabilities, excepting, however, obligations of the parties hereto to each other under this Agreement. 4 10. DIVISION OF REAL PROPERTY: Husband and Wife own jointly the marital residence, situated at 1117 Saffron Drive, Mechanicsburg, Cumberland County, Pennsylvania. Husband and Wife agree that Husband will become the sole and exclusive owner of the marital residence. Wife agrees to transfer all right, title and interest in and to the real estate now titled as tenants by the entireties to the Husband and agrees to execute all deeds, documents, or papers necessary to effect such transfer of title. Wife will execute a Deed transferring the marital residence to Husband at the same time she signs this agreement. Husband's counsel will hold this Deed in escrow until the settlement on the refinancing on the marital residence. Husband and Wife agree that Husband will have 60 days from the execution date of this agreement to refinance the marital residence into his own name. Husband agrees to pay Wife the sum of $110,000.00 as her share of the equity in the marital residence and not as alimony. Husband and Wife further agree that Husband will be solely and separately responsible for payment of the mortgage, taxes, insurance and all other joint debt associated with the marital residence from the date of the parties' separation until the conclusion of the refinance of the same. Husband waives all of his right, title and interest in Wife's property located at 8 Bayberry Court, Mechanicsburg, Pennsylvania. 11. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, their personal property and the personal 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. 5 12. AUTOMOBILES: Husband and Wife agree that Husband shall be the sole and separate owner of the 2002 BMW and Wife shall be the sole and separate owner of the 2007 Toyota Camry. Husband and Wife agree to assume all responsibility for any outstanding debt balance on his/her respective vehicle, indemnifying and holding the other harmless from any financial responsibility arising from nonpayment thereon. Husband and Wife agree to execute any and all instruments and documents necessary in order to effectuate the transfer of title'to said automobiles. Husband and Wife also acknowledge that during the marriage the parties acquired a 1989 Porsche 944 which has since been sold and Husband received the proceeds from the sale of the same. 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. COLLEGE EDUCATION: Husband and Wife agree that Wife is currently the owner of two 529 Tap accounts for the benefit of the parties' child- Wife agrees to maintain these accounts until their child is eligible to attend college- Wife further agrees to provide Husband with periodic statements on this account, but not less than on an annual basis. 15. ALIMONY: In the event that Wife has a serious reversal of her health condition, and becomes unable to work at least half time and does not qualify for social security or long term disability, if she chooses to ask for financial support from Husband, he agrees to pay her a sum calculated based upon his net monthly earnings as would be determined by the Domestic Relations Office of Cumberland County, calculating Wife's income as it would be calculated if they were in front of Cumberland County Domestic Relations Office, and utilizing the support formula for alimony pendente lite as provided 6 by the Rules of Civil Procedure of Pennsylvania, after taking.into consideration child support paid by Husband on account of the parties minor daughter, Amanda E. Forgie. Husband would not be obligated to make such a payment in the event that the parties' minor child is over 18 years of age, or if Wife has remarried or if Wife is cohabitating with a person of the opposite sex. This payment will be treated as alimony for tax purposes and therefore will be income to Wife and deductible by Husband on their respective tax returns for any and all years in which it is paid. 16. COUNSEL FEES: Husband and Wife agree that each will be solely and separately responsible for his or her own counsel fees without contribution from the other. 17. 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, 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 for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 18. ADDITIONAL INSTRUMENTS: 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. 19. VOLUNTARY EXECUTION: Wife has employed and had the benefit of counsel from Mary A. Etter Dissinger, Esquire, as her attorney. Husband has employed and had the benefit of counsel from Elizabeth S. Beckley, Esquire as his 7 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 this Agreement, 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 pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 20. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. This Agreement shall be binding upon the parties hereto, and there respective heirs, executors, administrators and assigns. 21. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed by both parties with the same formality as this Agreement. The failure of either party to 8 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. 22. SEVERABILITY: If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 23. INCORPORATION: In the event that the parties obtain a divorce, a divorce decree issued by a Court of competent jurisdiction RT* incorpo to the terms of this Agreement, but such incorporation shall not operate as a merger of this Agreement into the divorce decree, and this Agreement shall continue in full force and effect independently of such divorce decree. 24. DATE OF EXECUTION/EFFECTIVE DATE: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they did so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. This Agreement shall become effective and binding upon both parties on the execution date. 25. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 9 IN WITNESS WHEREOF, the parties have hereunto set their hands and seals Mary A. E er Dissinger, Esquire Catherine E. Forgie COMMONWEA?L?TH` OF PENNSYLVANIA ) COUNTY OF YJ' ? "t ???? SS.: On this the -R-& day of 2007, before me, the undersigned officer, personally appeared GREGORY A. FORGIE, 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. Notary Public (SEA ) My Commission Expires: COMMONWEALTH OF P NN$YLVW_ A NOTMAL WAL ANN M. NfdOWORE NOWy P?bNE Cdy of Hoftbuq, 0000 OMW * Cuba Son June S, 2= 10 the day and year first above-written. COMMONWEALTH OF PENNSYLVANIA ) p ) SS.: COUNTY OF On this the o?,2- day of 2007, before me, the undersigned officer, personally appeared CATHERINE E. FORGIE, 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. NO%RK SEAL ANNETTE PERKINS CAWN LL BOROUGH, iC CirwAlERtANUCOUNn Notary Public (SEAL) MY Cam* won Bq*96 Jul 22.20M My Commission Expires: tb'? f ?*,r :trpa? ze 11 ! J [`g 7 ? ' 3 -'rr'1 "? N Tl ch _ -c r GREGORY A. FORGIE, Plaintiff V. CATHERINE E. FORGIE, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE NO. 05-3964 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 3, 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 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. § 4904 relating to unsworn falsification to authorities. Dated: 6 Gregory A. /9-?- Forgie" r,a ^.; 27f rn ?. !`J Ul Om A" GREGORY A. FORGIE, Plaintiff V. CATHERINE E. FORGIE, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE :NO. 05-3964 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in 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. Dated: 6 41-0 Gregory A. For e N O d tx c- .?:.? .rte.. M cr N r-n T .. -0 m ?'' CLL N ? /` GREGORY A. FORGIE, JN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW :IN DIVORCE CATHERINE E. FORGIE, Defendant :NO. 05-3964 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 3, 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 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. § 4904 relating to unsworn falsification to authorities. 5 Dated: 1 Catherine E. Forgie ?i qtr: CD e GREGORY A. FORGIE, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVILACTION - LAW :IN DIVORCE CATHERINE E. FORGIE, Defendant :NO. 05-3964 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in 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. Dated: Au-2 Catherine E. Forgie C r J GREGORY A. FORGIE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE CATHERINE E. FORGIE, Defendant : NO. 05 -- 3964 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for the entry of a Decree of Divorce. 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Catherine E. Forgie, on August 14, 2005, by her personally accepting service of the same. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on May 29, 2007; by defendant on June 21, 2007. 4. Related claims pending: No economic claims have been raised. 5. (a) Date plaintiffs Waiver of Notice May 29, 2007, and it is being filed contemporaneously herewith. (b) Date defendant's Waiver of Notice June 21, 2007, and it is being filed contemporaneousslly/ herewith. DATED: 6 41 Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717)233-7691 liz eth S. Beckle Attorney for Plaintiff CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Mary A. Etter Dissinger, Esquire Dissinger and Dissinger 28 North Thirty-Second Street Camp Hill, PA 17011 /??T DATED: &4I try W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. GREGORY A. FOFGIE, Plaintiff VERSUS CATHERINE E. FORGIEI Defendant DECREE IN DIVORCE AND NOW, DECREED THAT GRWORY A. FORGIE 0,T1.1 yeo" . 2007 , IT IS ORDERED AND AND CATHERINE E. FORGIE ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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 Property Settlement Agreement between the. 'es shall be into ated into the final decree for F with the final Decree in Di , but shall not merge B ATTEST: J. PROTHONOTARY N 0. 05-3964 r? ii'