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HomeMy WebLinkAbout06-5739 fl\div\LASKOSKI,RICHARD v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-- S"7:J1 d'~l.t:T'C/:z-'Y} RICHARD W. LASKOSKI, Plaintiff CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW 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 the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 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 Count v Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 Telephone: (717) 249-3166 -1- v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(.- S'YJ'f' {!;ui(T€L"'1 CIVIL ACTION LAW IN DIVORCE RICHARD W. LASKOSKI, Plaintiff CLARA J. LASKO SKI , Defendant COMPLAINT 1. The Plaintiff in this action is Richard W. Laskoski, an adult individual, who currently resides at 56 Timber Road, Mechanicsburg, Pennsylvania 17050. 2. The Defendant in this action is Clara J. Laskoski, an adult individual, who currently resides at 56 Timber Road, Mechanicsburg, Pennsylvania 17050 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on August 6, 1983, in Camp Hill, 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 Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. -2- .. . II 1\ 7. The Plaintiff avers that one child, Nicole Ann Laskoski, has been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. 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 P.C.S. ~4904, relating to unsworn falsification to authorities. /~h;(~t Richard W. Laskoski Date: 9!J-f!()t / STONE LaFAVER S ne, Esquire ID #60251 reet, P.O. Box E and, PA 17070 717-774-7435 for Plaintiff -3- ~ ~ --- ~ w ~ f' ~ "\l ~ -- w 0-- ~ -- ...() \) . B ~ ~ ~ ~ c;:; o c::> -n ~~. ~ :;1." C (0:' p, rnp [,' -~tI -:;r1"1 f'-) --i J Y cD .. :1'1; e. ~ -::,?~ ."-" N ::::; ... ;;.:;..., .t;:"' :< ~::1 -- .....l -- II '- fl\div\LASKOSKI,RICHARD-affofservice RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff, Richard W. Laskoski, hereby certify that I served the Complaint in Divorce in the above captioned matter on the defen- dant, Carla J. Laskoski, at 56 Timber Road, Mechanicsburg, Pennsylvania, 17050, by United States Certified Mail, postage prepaid, restricted delivery, on October 6, 2006, as evidenced by the attached Certified Mail return receipts. SWORN TO AND SUBSCRIBED before me this (\'\'It day of Cu\-o\uv ~2006. ~~ '----- COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHLEEN KEIM. Notary Public New Cumberland Boro. Cumberland Co My Commission Expires Dec. 5. 2006 . J. -- U.S PO;,!d; Servlc t CERTIFIED MAIL RECEIPT (Domes//(.. llIall Dilly. No InbUldnce Cove/age Prov/cled) ITI ITI ru U'} M C] IT' C] Certified Fee I"- Return Receipt Fee (Endorsement Required) C] C] C] Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ /C:;J~ ~' ,,--,:-?:\ ~y OCT \t\ \ \ tl...,' _ ere.:- \:\ 2nllD . / ,,^'.'- ~IJ coco; ~l.5y C] ru ru N.~P/eaBe P,'nt C/ea't(T"o b1 ~mpleted 9Y mailer} ITI .m. [4Y~J.........a...s_1C..Q~k_\_..._.____...._......._._..._.___..... ~ :-.~Ji~~.~iow--"-".- . Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. I · Print your name and address on the n:werse I _ that we can.retum the card to you. . Attach this card to the back of the mailpiece. or on the front If space permits. 1. AttIcle Addressed to: C.\aXtLJ. ~OSlL\ ~ 1\~\ov RDa..,L IY\t~o I ~ O>stl o Agent o Addr-. C. Date of DellYery , 6_ 3.~ o Registered o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) as 2. =-~..wce"" 10CtG 3:l~D 0001 CC\OL 5~ 33 PS Form 3811. February 2004 DornIMIc Retwn ReceIpt 102l5ll5-02-M-1540 : J ,...., c;> (} c::,;) ,-,:::::.:' -n C c.......... :::1 ';'.. <, ; .: -1: -0 C") ~o ::i: z ~2 w sa .. 2.0 "?; <."J ~ -< c:> fl\div\LASKOSK=fRICHARD-~otiontoincorporate RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE MOTION TO INCORPORATE AGREEMENT INTO DECREE IN DIVORCE RICHARD W. LASKOSKI, Plaintiff in the above action, by his attor- neys, STONE LaFAVER & SHEKLETSKI, moves that your Honorable Court incorporate the attached agreement dated February 28, 2007, into the Decree in Divorce. STONE I . ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND P A 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF RICHARD W. LASKOSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW CLARA 1. LASKOSKI, Defendant : NO. 2006 -06-5739 CIVIL TERM PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this2g'~y of February, 2007, by and between RICHARD W. LASKOSKI, of Cumberland County, Pennsylvania, (hereinafter referred to as "Husband"), and CLARA J. LASKOSKI, of Cumberland County, Pennsylvania, (hereinafter referred to as "Wife"). WIT N E SSE T H: WHEREAS, Husband and Wife were lawfully married on August 6, 1983, and WHEREAS, one minor child has been born of this marriage, and WHEREAS, the parties have heretofore resolved those matters of custody of their minor daughter, Nicole Ann Laskoski, born October 19. 1990, and have entered into a mutually agreeable verbal agreement; WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of Page 1 of 13 their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between 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 matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. Disclosure of Assets. Each party asserts that he or she has made a full and fair disclosure of all of the real and personal property of any nature whatsoever belonging in any way to each of them of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each party, and of every 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. Each party has been represented by an independent attorney, who was selected by the party whom he or she represents, in the negotiation and preparation of this agreement which has been fully explained to each party by that party's attorney. Husband has been represented by Elizabeth B. Stone, Esquire, and Wife has been represented by Carol J. Page 2 of 13 Lindsay, Esquire. Each party has carefully read this agreement and is completely aware, not only of its contents, but also of its legal effect. 3. Preparation of Agreement. This agreement has been prepared by the attorney for the Husband. Each party has read this agreement carefully and thoroughly, fully understands each of its provisions, and therefore signs it freely and voluntarily. 4. Lawfulness of 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, from time to time, may 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. 5. Freedom from Interference. Each party shall be free from interference, authority, and contact by the other, as fully as ifhe 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 to 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 peaceful existence, separate and apart from the other. 6. Release of Claims. Wife and Husband each do hereby mutually remise, release, quit- claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such Page 3 of 13 r other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which Wife or Husband may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any provision thereof. It is the intention of Wife and Husband to give to each other by the execution of this agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any provision thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein. 7. Warranty as to Future Obligations. Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable, and that 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 and hold the other party harmless Page 4 of 13 from and against all future obligations of every kind incurred by them, including those for necessities. 8. Debts and Obligations. Husband represents and warrants to Wife that, since their separation, Husband has not, and in the future will not, contract or incur any debt or liability for which the Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debt or obligations incurred by him. Wife represents and warrants to Husband that, since their separation, Wife has not, and in the future will not, contract or incur any debt or liability for which the Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debt or obligations incurred by her 9. Personal Property located at 56 Timber Road, Mechanicsburg, Cumberland County, Pennsylvania.. Husband and Wife have hereto agreed that certain items that are presently located or situated in the residence at 56 Timber Road, Mechanicsburg, Cumberland County, Pennsylvania belong to the Husband. Those items will remain in the marital home until the house is sold so that the Wife may enjoy the use of said items. Once the house is sold, the parties agree that Husband shall take possession of said items without claims by Wife. These items also include tools that are necessary for the upkeep and maintenance of the home while the Wife remains there. A list of those items is attached as Exhibit "A". All other items of tangible personal property shall be the sole property of wife. 10. Cash. All cash presently in the possession of either party shall be and remain their separate property, free and clear of any claim whatsoever on the part of the other. Page 5 of 13 I . 11. Pension/Retirement. Husband and Wife have agreed that to equally divide Husband's 401(k) plan which has a value of$12,714.00. Husband agrees to provide a copy of the plan description and any model Orders dividing said 40 1 (k) to Wife. Wife's attorney agrees to draft and Wife agrees to pay for said drafting of the Qualified Domestic Order (QDRO) when all information is received. 12. Automobiles and Motorcycles to Husband. The Husband shall be the sole owner, free and clear from any claim on the part of the Wife, of the 1996 Toyota Tacoma, 1995 Buell Motorcycle, 1994 Harley Davidson, 1989 Kawasaki Enduro, or their replacements. If necessary, Wife shall deliver executed certificate of title, sales and use tax form and any other documents necessary to convey title within ten days of a request from Husband. 13. Automobile to Wife. The Wife shall be the sole owner, free and clear from any claim on the part of the Husband, of the 2000 Volkswagen Jetta, or its replacement. If necessary, Husband shall deliver executed certificate of title, sales and use tax form and any other documents necessary to convey title within ten days of a request from Wife. 14. Property Not Provided For. The parties hereto agree that they have, by the terms of this agreement, settled, to their mutual satisfaction, all rights that either may have in their property, whether owned by them jointly or separately, real and personal, and wheresoever situated. Any property not specifically provided for in this agreement, which the Husband or Wife owns or has the right to control or possess, shall be and remain his or her property, free and clear from any claim on the part of the other. 15. Real Estate. The parties hereto are owners of a home at 56 Timber Road, Mechanicsburg, Cumberland County, Pennsylvania. The home is encumbered by a first Page 6 of 13 mortgage in favor of Husband's parents and a home equity line of credit as well. Neither party will borrow any further money on the home equity line of credit. Both parties will advise the lender that the line of credit shall be closed. Wife shall reside exclusively in the marital home with the parties' child until the marital home is sold. The house will be placed on the market for sale on or about June 30, 2007. Pending sale, Husband will pay the first mortgage payment and the home equity line of credit payment, the full amount of the principal and interest due each month as he has in the past even if the first mortgage holders are willing to take a lesser payment. Additionally, Husband will pay the real estate taxes for the marital home. The parties will list the house for sale with a real estate agent agreeable to the two of them and they will take the advice of their real estate agent as to any repairs or improvements required to prepare the house for sale. The parties will equally split the cost of those repairs. Pending sale, Wife will be solely responsible for the payment of her personal taxes and the utilities, homeowners' insurance, trash removal and routine upkeep and maintenance on the home. Upon the sale of the marital home, the parties will pay from the proceeds the usual costs of sale, including real estate commission and transfer tax and will payoff the first mortgage and the home equity line of credit. The parties will equally divide the remaining proceeds provided, however, that on the date of sale, Husband will pay to Wife $20,000.00 from his share of the proceeds. Husband's obligation to pay the first mortgage, the line of credit and the taxes on the home shall substitute for an obligation of child support. The parties understand that should wife Page 7 of 13 file for child support while living in the marital home prior to its sale, Husband's obligation to pay the mortgage, home equity loan and real estate taxes shall terminate. For purposes in filing their joint Federal and State income tax returns for 2006, the parties have hereto reached an agreement with regard to filing said returns jointly by filing Married. The parties have agreed to share equally in any tax refund if there is one. For the year 2007, the parties agrees that Husband shall be entitled to claim as a deduction the real estate taxes and interest thereon. Wife will retain the right to claim the minor child as a dependency exemption on her Federal income tax return for 2007, and for as long as the dependency exemption for the child is available. In the event that Husband fails to make the mortgage and home equity line of credit payments as set out herein, on the date of settlement, he will pay to Wife an amount equal to any missed principal or interest payment in addition to any other obligation set out herein. 16. Waiver of Alimony. The parties herein acknowledge that by this agreement they have each respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient financial resources to provide for their comfort, maintenance and support in the station of life in 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, and alimony pendente lite. 17. Enforcement. If either party shall bring an action or other proceeding to enforce this agreement, or to enforce any judgment, decree or order made by a court in connection with this agreement or the divorce of the parties, and if the other party is found to be in breach of this Page 8 of 13 agreement, the prevailing party shall be entitled to reasonable attorney's fees from other party if a Court Order is necessary to enforce this Agreement.. 18. Payment of Attorney Fees. Each party of this agreement hereby agrees that each of them will be solely responsible for the full payment of all attorney's fees and other costs heretofore and hereafter incurred, respectively, by each of them in connection with the negotiation, preparation, and execution of this agreement, and in connection with any action commenced by either party with respect to the divorce of the parties. Each party further agrees hereby to indemnify and hold the other party harmless from any demand, claim, loss, cost and expense (including additional attorney's fees) arising from a failure to pay all ofthe aforesaid attorney's fees and other costs. 19. Informed and Voluntary Execution. Each party to this agreement acknowledges and declares that he or she, respectively: A. Is fully and completely informed as to the facts relating to the subject matter of this agreement and as to the rights and liabilities of both parties. B. Enters into this agreement voluntarily after receiving the advice of independent counsel, free from fraud, undue influence, coercion or duress of any kind. C. Has given careful and mature thought to the making of this agreement. D. Has carefully read each provision of this agreement. E. Fully and completely understands each provision of this agreement. 20. Mutual Cooperation. The Husband and the Wife shall each concurrently herewith, or at any time hereafter on the demand of the other, execute any other documents or instruments, Page 9 of 13 and do or cause to be done any other acts and things as may be necessary or convenient to carry out the intents and purposes of this agreement. 21. Severability. If any provision in this agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired in invalidated in any way. 22. Reconciliation. If there should be a reconciliation of the parties after the date of execution of this agreement, this agreement shall nevertheless continue in full force until it is modified or abrogated by another written instrument to that effect signed by each of the parties hereto. 23. Future Earnings. All income, earnings or other property received or acquired by either party to this agreement on or after the date of execution of this agreement shall be the sole and separate property of the receiving or acquiring party. Each party, as of the effective date of this agreement, does hereby and forever waive, release and relinquish all right, title and interest in all such income, earnings or other property so received or acquired by the other. 24. Waiver of Rights. Each of the parties hereby irrevocably waive all rights which he or she may have to request any court to equitably distribute the marital property of the parties or to have alimony, alimony pendente lite or counsel fees awarded to either party, it being the express intention of the parties hereto to fully settle all claims which they have with respect to each other in this agreement. Each of the parties further agree to consent to the entry of a Decree in Divorce. Page 10 of 13 25. Waiver of Breach. The waiver of any term, condition, clause or provision of this agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this agreement. 26. Survival of Agreement. If any term, condition, clause or provision of this agreement shall, by its reasonable interpretation, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the parties hereto, said term or terms, condition or conditions, clause or clauses, provision or provisions, shall be so construed, being the express intention of both parties hereto to have this agreement govern their relationship now or hereafter, irrespective oftheir marital status. 27. Jurisdiction. This agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and both parties consent and agree to the jurisdiction and venue of the Court of Common Pleas of Cumberland County, Pennsylvania, on account of any suit or action brought with respect to this agreement or any provisions or matters referred to in any provisions thereof. 28. Agreement Binding on Parties and Heirs. This agreement shall be binding in all its terms, conditions, clauses and provisions of the parties hereto and their respective heirs, administrators, executors and assigns. 29. Divorce. Husband and Wife agree, upon the expiration of the ninety (90) day waiting period, to execute all Affidavits of Consent and other documentation necessary to have a divorce decree entered pursuant to Section 3301(c) of the Divorce Code of Pennsylvania on the ground that the marriage is irretrievably broken. Page 11 of 13 30. Incorporation of Agreement into Divorce. The parties agree that this document shall be filed with the Prothonotary to the civil action docketed at Cumberland County No. 06- 5739, a motion shall be filed that shall incorporate this agreement into the divorce decree, and shall never merge with the divorce decree. 31. Headings. The headings or captions preceding the paragraphs in this agreement are inserted for convenience of reference only and shall not be construed in interpreting this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year above first written. ;~~~. RICHARD W. LASKOSKI 'J /... ..?/'" ,~~ J/LASKOSKI \../ i J ,. Page 12 of 13 SONY 36" TV STEREO SOUND SYSTEM AND SPEAKERS MUSIC CD'S GUITAR AND CASE TOOLS AND TOOL BOXES RELATED GARAGE EQUIPMENT (JACKS, STANDS, COMPRESSOR, ETC.) GARAGE STORAGE CABINETS AND CONTENTS ASSORTED COPPER POTS JOHN DEERE TRACTOR EXHIBIT "A" Page 13 of 13 ""'" <:::::> c=> -..J :x :~::- ;:.0 (\,) 00 o ." :r mfQ -om :.DO c:? /) ~~ :11 2.:(") om --.{ ;-.;-- ~ :::z ~~ r:? (..) -.J r- fl\div\LASKOSKI,RICHARD-affofconsent RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on September 29, 2006, and served October 6, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after servlce of notice of intention to request entry of the decree. 4. 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. 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 falsifica- tion to authorities. 7/1/07 Date I ~/JY~. Richard W. Laskoski, Plaintiff (') ,..., 0 <::> C = -n $::: ...... ....CJCJ:c' :J::: :r.., mr-' ;:p.. ;-~. ~ :;0 mp -7 -om ""-~ T'-) (/) -.,...tr-J co ->;.11 ,~/' ~~~l ~(~ ~r;.- -0 z'> :1t (~o j; 1._, ;:,:s-.:.fTl r- N ,_J Z -I :< (.~ ~ en -< fl\div\LASKOSKI,RICHARD-affofconsent RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on September 29, 2006, and served October 6, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsifica- tion to authorities. Date 3 /..y/O 7 / / ,{,. ' Clara J ~../ (/ ,I . ,./.:; ./ 2_,::: . {'0J---.- .''''- Laskoski, Defendant (') c: ~~ \JC't ~r: ~s, k?C- )> ~', ~:,=~~ _.C~. Z ~ ,...., c:::> = -.J :J: :;p.. :;:;0 N CD o -n :2.." m- .. -om :1'JO ,-' } ,jC..> ~~ 3m -I ~ -< -0 3: N W -..J fl\div\LASKOSKI,RICHARD-waiverofnotice RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 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 falsifica- tion to authorities. :;/1107 DJte' ;2;~4t; rt~, Richard W. Laskoski, Plaintiff (") s; v~~r mr' 7~^1 ..<:.."~ ~,' > .t~j :;.. ~<-' ~r' ~.'-""'" '.., ~;:: ,-~ ~"'!,--.. ~ ~:;j '-- Z -..; --< "" c:::::I <= --' :::: :'1> ::::0 N (X) o 11 :r n,:D ... -nm "Dc bl .-iCJ -"-j. _.L-~.. '~4C5 (c;)m ~ S::1 -< -0 ::z:: N .. w -s fl\div\LASKOSKI,RICHARD-waiverofnotice I I RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 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. 5 4904 relating to unsworn falsifica- tion to authorities. ~L;Y!o 7 Da ef I . . l,( J: .J L i/V ./~ v/ l.....:_~_ .it(/"-'" Clara J. Laskoski, Defendant o ~ <' l)O) mi; , 2? t',~. CD.; i;~ '1~-:" c: -~7 ~ -<. ~ => = -..l :J't :.n- :::0 N (Xl -0 ::;:: o -n ~-n nlj:;; -o~ :oy 00 =t=H (40 r:;m ~:~ ~ N .. W -.: RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE 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. Ground for divorce: irretrievable breakdown under ~3301(c) J301(d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: October 6, 2006 via United States Certified Mail, postage prepaid, restricted delivery. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code: by Plaintiff ~ebraarl 28, 3-t -2007 ; by Defendant 3-5-01 (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: No claims raised 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: 3-J 51 -07 Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: 3-a9-ol (') c: <~ -003 ml';', ~S'; rs~: __L' .,;;:-, ~""- ~-( .<::.{- j; ,-' c z =<: "" <= c::::. -..I ::J: > :::0 N CD -0 :x ~ w .....,J ~ :r! n..:n Fn :BQ ':~6 ~'j-r; ('5'J ZO (:)m -I 55 -< f_\div\~AS~OSKI,RICHARD-o~derto~ncorporate RICHARD W. LASKOSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-5739 CIVIL TERM CLARA J. LASKOSKI, Defendant CIVIL ACTION LAW IN DIVORCE o ROE R AND NOW, this t.{.r day of ~ , 2007, the Property Settlement Agreement between the parties dated February 28, 2007, and attached hereto is hereby incorporated into the Decree in Divorce. BY J. A..1I\lr1(j'.'" ...r'''n'' ..;:....1 ,.J I 0 :~ ~{d 1- ~:d\J LOOl 1\-1\./' (',:':;1.1 i ('!~,I :J' '1' ..lJU~ ^\JV.L~..I'I....I' L.....Il~~lJ ,,,,..,In __ ::rJl:i ::O-{!:lll::l Of. Of. Of. Of. Of. Of. Of. Of. it>Of.0f. Of. Of. Of. Of. Of. it> 0f.0f. Of. Of. Of. Of. Of. Of. Of.Of.;tO:I;Of.Of. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY Of. Of. PENNA. STATE OF Of. Of. Of. Of. Of. Of. Of. Of. ;to Of. Of. RICHARD W. LASKOSKI, PLAINTIFF No. 06-5739 CIVIL TERM VERSUS Of. Of. CLARA J. LASKOSKI, DEFENDANT DECREE IN DIVORCE ~ t( ,J-OO ~ IT IS ORDERED AND Of. Of. AND NOW, Of. ;to Of. RICHARD W. LASKO SKI Of. DECREED THAT , PLAI NTI FF, CLARA J. LASKO SKI AND , DEFEN DANT, 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 parties Property Settlement Agreement dated February 28, 2007, is hereby incorporated, but not merged, i Of. cree in Divorce. By ATTESi'~~ PROTHONOTARY ,., ,.,,.,,., ,., ,.,,., ,.,,.,,., ,., ,.,,.,,.,,., '1':1; 'fOf.,., ,., Of.:I;'f'" :1;'1' 'I' Of. Of. :I; Of.:I;:I;'f'f ;f.:I;Of.;f. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. J. ;+; Of. Of. Of. Of. Of. Of. ;+; Of. ;to Of. 'I' Of.;f.~ r Lw ~ ~ If 1111 fpq""X' 7f' 1- ~ ./J/I ,>IYL1 L o. ! I. fi / .lK'P ~ r{l II1RYrI rv ~!P ' . . . ',' , . ,<.0 '..