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HomeMy WebLinkAbout06-7202 tlldi vlG LOGO WSKI,J ANET -affofconsent JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 330l(c) of the Divorce Code was filed on December 19, 2006, and served December 20, 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 falsi fica- tion to authorities. j-02/-o7 ~1~ Mnet S. Glogowski, aintiff Date () ~; ~~?r ~i. ':-;,.:~ 5.;; r--.:> <::::) C:;) --.r ::it ~ :::0 N W -0 =r: o ." :2 rn ::n r- -om :I:Jy 90 ~~ '-I ):..... ::0 -< S't c..n o fl\div\G LOGOWSKI,JANET -affofconSenl JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 330l(c) of the Divorce Code was filed on December 19, 2006, and served December 20, 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. ~ 4904 relating to unsworn falsifica- tion to authorities. 3 --J /- 0 1 ~.~, Defendant Date () ~ -offJ ~n ~~ ~; :".""J- 's.:. f'..,,) c:::> c::;:) --.I ::1l: ~ :;.0 N W ~ :r! rn~ :go .~~~ ~: :1:-n (~ ("5 .<..... I" :~ ~ =< -0 :1: ~2 <:11 o tl\di vlG LOGO WSKJ,JAN ET -waiver JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, 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. 3-;)/- 67 ~~' J ~t S. GIOgO~Ski, aintiff Date ~ c:::> c:::::> --' :::i: ::> :::0 N W -0 :i: o .." ~ ni:D r- ., 1"1"': :00 ,,,:) T '.-10 ~- -rr- -- -rl :;?e; 51'11 ,.;...! ?Ii -< w . . U1 o fl\di v\G LOGO WSKI,J ANET -waiver JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, 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. 3 - ) I -0 1 Date Josep .. -; , o c -off. rr,rr ..:-.. ~- 6~:,L r;(' ..::~ ~..... .c._? .~ ~!;~::.~ (- J:~ C~: :~ .......c ....., c:::;) c::::l -.J :x > :;0 N W -0 :::;: ~ -I ffl;!! ;Em (:)~ --l C' :r: :n 0-:: zM 8 ~ =< Y? U1 JANET S. GLOGOWSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, 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) JJ01(d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: December 20, 2006 - via personal service . 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 March 21, 2007 by Defendant March 21, 2007 (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: 3.23~~ Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: 3"Z).or ~~. Attorney for Plaintiff ,...." ..::::> c:::::t -..J :x > :;;:0 N W ~ ~:n :pFn c3? :1:1 ~?, :511 ->- C"') OfTI ?E =< ;~ c.:? U't N .. l fl\div\GLOGOSKI,JANET-3301c JANET S. GLOGOWSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. D~~7B.o~ c,ivil JOSEPH J. GLOGOWSKI, 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 County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 Telephone: (717) 249-3166 -1- ~ T I I JANET S. GLOGOWSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Ol.. 7,),0 2. ~ /-L- v. JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is JANET S. GLOGOWSKI, an adult individual, who currently resides at 122 Wesley Drive, Mechanicsburg, Pennsylvania 17055. 2. The Defendant in this action is JOSEPH J. GLOGOWSKI, an adult individual, who currently resides at 591-23 Geneva Drive, 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 30, 1969, in State College, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -2- "'" . ~. 6. The Plaintiff avers as the grounds upon which this action lS based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that all children born of the marriage are of legal age and are not minors. 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. Date: /2/-/2/)0(, ~J' , -- - JANET ' S~KI STON~~ B~~~i-?-- Supreme Court ID #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff -3- C) /"-..) ~ c~ = (J L::-~J C-",,- .1 - CJ ~ ~ ..c :.::;j C> r'~' rnFJ C"j ~ 0\ l! ; ~ 00 0 1..0 c::~ ~ ~ C~~ (l) -0 -a -";',,," ~ D N l ..j,~ (.,.., I ~ ... fl\div\GLOGOWSKI,JANET-affofservice JANET S. GLOGOWSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA} ) SS: COUNTY OF CUMBERLAND ) I, Gerald J. Shekletski, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, JOSEPH J. GLOGOWSKI, at 414 Bridge Street, New Cumberland, Pennsylvania, 17070, by person service as evidenced by the attached Acceptance of Service. .'of,/ Gerald Attorney at SWORN TO AND SUBSCRIBED before me this a\~ day :~6' COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHLEEN KEIM, Notary Public New Cumbertand Boro.,Cumberland Co. My Commission Expires Dec. 5, 2010 _II fl\div\lacceptservice JANET S. GLOGOWSKI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Joseph J. Glogowski, defendant in the above captioned matter, accept service of a certified copy of the Complaint in Divorce filed December 19, 2006 , to the above term and number. December 20, 2006 Date Jose Defendant /"--, C...:J ("':-.) c7' c:J f"rYt o ~'v --' --0 ~ \ ,,' fl\di v\GLOGO WSKI,J ANET -motiontoincorporate JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION - LAW IN DIVORCE MOTION TO INCORPORATE AGREEMENT INTO DECREE IN DIVORCE JANET S. GLOGOWSKI, Plaintiff in the above action, by her attorneys, STONE LaF AVER & SHEKLETSKI, moves that your Honorable Court incorporate the attached agreement dated December 29,2006, into the Decree in Divorce. STONE LaF AVER & SHEKLETSKI fl\agm\glogowski AGREEMENT THIS AGREEMENT, made this :l9/7t day of a..-Q?~W- , 2006, by and between JANET S. GLOGOWSKI, of Cumberland County, Pennsylvania, (hereinafter referred to as "Wife"), and JOSEPH J. GLOGOWSKI, of Cumberland County, Pennsylvania, (hereinafter referred to as "Husband") ; WIT N E SSE T H: WHEREAS, Husband and Wife were lawfully married on August 30, 1969, and 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 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 -1- 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 receiv- able 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. Contents of Aareement. 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 Aareement. This agreement has been prepared by the attorney for the Wife. The Husband has read this agreement carefully and thoroughly, fully understands each of its provisions, and therefore signs it freely and voluntarily. -2- 4. Lawfulness of Seoaration. 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 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. 5. Personal Riahts. 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 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, and each of the parties hereto completely understand and agree that neither shall do or say anything to the children of the parties at any time which might in any way influence the children adversely against the other party. 6. Freedom from 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 to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, -3- nor in any way interfere with the peaceful existence, separate and apart from the other. 7. Release of Cla~s. 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 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 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 -4- 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 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 thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 8. Debt. Husband and Wife have settled between them responsibilty for payment of any and all debt of the marriage. Husband shall be solely responsible for payment of Members 1st account , having an approximate balance of <6,/3'13. gD-I;;; future debts incurred by the parties shall be ~ ~ W1?umber /(oc.fLJ hO - 6 L ,~v as of this date. All their individual responsibility. 9. Personal Property. Wife and Husband do hereby acknowledge that they have heretofore divided the marital property including, but without limitation, jewelry, clothes, furniture and other personalty and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of Wife shall be -5- the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other~ ~~~Le1lL:::; wll.Ldl cl.Le LLe ;:,ule II date of execution hereof. ouJ 3~paratc propC:lrr-~T sf th<:. 6~hGJ5 from the 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. 11. Cash Payment bv Husband. The Wife shall receive and the Husband shall deliver or cause to be delivered to the Wife at or before the signing of this Agreement the sum of $25,0000.00 and shall also pay to Wife the additional sum of $5,000.00 to be paid in 12 consecutive monthly installments of $425.000 each commencing (J 12. Automobiles. Wife and Husband shall be the sole owner, free and clear from any claim on the part of the other, of their respective automobiles. Wife and Husband agree to sign any documents, if necessary, required to retitle their automobiles. 13. 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 -6- 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. 14. Real Estate. Wife hereby agrees to convey, transfer and grant to Husband her right, title and interest in the real estate known as 122 Wesley Drive, Mechanicsburg, PA 17055 upon receipt of confirmation that she has been removed from all liability under Washington Mutual loan number 0061017240. Husband agrees to assume as his sole obligation any and all mortgage payments, taxes, claims, damages or other expenses incurred in connection with said premises, and Husband agrees and covenants to hold Wife harmless from any such liability or obligation. 15. Waiver of A1~onv. 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 suffi- cient 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, alimony pendente lite or maintenance. It shall be from the date of this agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. -7- 16. Warrantv as to Future Obliaations. 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 or hold the other party harmless from and against all future obligations of every kind incurred by them, includ- ing those for necessities. 17. Pension/Retirement. Husband and Wife do hereby waive any and all interest which they may have in the any and all retirement accounts of the other. 18. Info~ed 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 relat- ing 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. -8- E. Fully and completely understands each provision of this agreement. 19. 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, 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. 20. Severabilitv. If any provision in this agreement is held by a court of competent jurisdiction to be invalid, void, or unenforce- able, the remaining provisions shall nevertheless continue in full force and effect without being impaired in invalidated in any way. 21. 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. 22. Future Earninas. 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 -9- income, earnings or other property so received or acquired by the other. 23. Waiver of Riahts. 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. 24. 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. 25. Survival of Aareement. 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 of their marital status. -10- 26. Jurisdiction. This agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and both parties consent and agree to the jurisdiction of the Court of Cornmon 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. 27. Aareement Bindina 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. 28. 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. 29. Headinas. 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. f#AJ ~( JAN s. GLodows (SEAL) -11- . . JOS~~~~GOWSKI ( SEAL) -12- \'00..> (;:;;;) c::;:) --.wi :x ...~ o -n :r." m- r- 7BS ~~~, ~, ::1j :-:-:0 csrn ~ ~ .< ::u N c....:> -0 3: ':":.' .r:- \..0 [Ii [Ii Of. [Ii Of. Of. Of. ft; [lift; Of. Of. [Ii [Ii [Ii [Ii Of. ;!; ;!;[li0f. Of. Of. Of.;t; ;t; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY JANET S. GLOGOWSKI, PENNA. STATE OF ;t; ;t; ;t; ;!; ;t; ;t; ;t; ;t; ;t; No. 06-7202 Civil Plaintiff VERSUS JOSEPH J. GLOGOWSKI, ;t; [Ii Defendant ;t; DECREE IN DIVORCE AND NOW, \"\ ~ ~ L~ , 1. C>t)? , I TIS 0 R D ERE DAN D 17 DECREED THAT JANET S. GLOGOWSKI , PLAINTIFF, AND JOSEPH J. GLOGOWSKI , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; The parties Agreement dated December 29, 2006, is hereby incorporated, but not merged, into the Decree in Divorce. ;t; ;t; ;t; ;t; ;t; ;t; ;!; ;t; ;t; ;t; ;t; ~* ~ ~ '" ;t; "';t;;!; '" ;t;;t; Of. By THE COURT: ATTE~ t \.~...\ ~ (~~ PROTHONOTARY Of. Of.Of.Of. "'Of.Of.0f.Of."'ft;'" ;t; Of."''''~ '" Of.0f. :+;~ :f.:f.:f.~:f.:f.:f.:f. "'Of.~'l! Of. Of. ;!; Of- Of- Of- Of. Of. ;!; Of- Of. Of. Of- Of. ;t; Of- Of- Of. Of. Of- Of. Of- Of- ;t; Of- Of- Of- Of- ;t; Of- ;t; Of- Of- Of- Of- ft; Of- Of- Of- Of- ft; ;t; Of- Of- ~ ;t; ;t; ;t; ;t; Of- Of- Of- ~ Of- ;t; ;t; ;t; ~ J. Of- Of- '" '" '" '" '" '" '" '" ~ ;!; "'Of.~ -,fr 7 ~ r:yu., '-.0 ';C' [ _~ P"~ 4J.pr? tJ? {pE' .. ", J...... .' - ~, lji ;'- ~....., nldivlG LOGOWSKI,JANET -molionloincorporale JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION - LAW IN DIVORCE AMENDMENT TO THE MOTION TO INCORPORATE AGREEMENT INTO DECREE IN DIVORCE JANET S. GLOGOWSKI, Plaintiff in the above action, by her attorneys, STONE LaF AVER & SHEKLETSKI, moves that your Honorable Court incorporate the attached agreement dated December 29,2006, into the Decree in Divorce. No Judge has ruled upon any other issue in the same or related matter. There is no opposing counsel of record therefore concurrence of any opposing counsel is not required. STONE LaF AVER & SHEKLETSKI o c ~-;' ......, b ~ :It. j;;9 ?O N oJ:) ;:2, :.?, -0 --"!? ~ Q, --t fF,~ ;-1'1 :g I:? .~;,~)~ tl~] :.? :~~ .~! ~l~~ .:~ ~ :..<. r:;3 .. - (...) flIdi v\G LOGO WS KI,J AN ET -ordertoincorporate cl .7 M~ t8 2llO7 ~ JANET S. GLOGOWSKI, Plaintiff : IN THE COURT OF COM ON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-7202 Civil JOSEPH J. GLOGOWSKI, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER ~t\\ \ AND NOW, this \ day of J 911"" ,2007, the Agreem~nt between the I parties dated December 29,2006, and attached hereto is hereby incorporated into tht Decree in Divorce. I BY THE COURT: \t 1. J1 J. ~ ~ "'t) Ii '..1 L I : I Hd 6 - HdV LOOl