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Home My WebLink About94-00264 "- , 11\ d - 'N d E. I/) .d - ~ c. .', ~ ~ '.' ~ ~ ~ ~ '.' .' ~ '.' ~ '.' ~~ ~~ ~ ,', s ,', ~ ~ s ~ '.' 8 ~ '" <:" ,', ~ " ~ ~ M ,.' ~ ~. ~ <:" s ..""..r.......,.". -' **~-@~~~~~~*~*-----*)~.~:*~~_...~~~ ~ l-- '--'-. . ._- -- , ----..-Y" A_ j :1 IN THE COURT OF COMMON PLEAS : w w '0' '7 ~ ~ ',' OF CUMBERLAND COUNTY ~ STATE OF 1~ PENNA, ~ .~ ,', ~ w '.' ." ~ :;: <:" ~ ~, w ,~ ~/ '.' ~ ,', ~ KONSTANTINO A. MAZIAS 8 N o. ..~.6.4....... .... c:::rY,J::L.." 1994 ,', ~ \'1l)....Il~ ,', ~ GEORGIA MAZIAS i ',' i '7 i ',' i, AND NOW, '. i DECREE IN ;. f I V 0 R C E j. q wi fA : . . , . . . . . . . . . . . . . . . . . " 19W.., it is ordered and S decreed that,. . . , ... ~~~~~.~~~~? .~: . ~.~~~~~. ... .. , ... .. . . . " plaintiff. and. ,. . . .. . , .. . . . C:;~.~~~~~. .l>!~~.I.~~. . .... .. .. .. . . . . . . . ..... ", defendant, are divorced from the bonds of matrimony, 8 ~ * s 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; IJ ...........,...,.IJ,O,...~..,...,.........................,.........., ~ '.' s ~ ~ ..................... ......... ......................... I~ 1~ ~ J. ~ 1 : ~~ I: ,~ ~-( Prothonotnry ~~ , . :~ . . ~ ~ ~ r. . -;: ',:- ;. .. , ~.' '~.' ..... ...~. ...... '" ." k~~ ;{)~ '0', ;~ . . -- ,~ ~ ...' -:.;. -:.;. .:+;. .:.;. .:+;. -:+;. .:+:. .:+:. .:+:. .:+;. .:+;. .:+:. .:+:. .:+:. .:+:. .:.,:. .:.:. .:+:. .:+;. .:.;. .:+:. .:+:.' . '. . " ~ ' -. AGREEMENT AND NOW, this t.1L. 0 f h day of 11 P R / L , 1994, it is agreed by and between Konstantinos Mazias (hereinafter referred to as "Husband") and Georgia Mazias (hereinafter referred to as "Wife") that: WHEREAS, Husband and Wile were married on October 12,1969, in Greece; and WHEREAS, Husband and Wife have acquired certain property and incurred certain debts during the course of the marriage; and WHEREAS, the marriage between the parties is irretrievably broken; and WHEREAS, Husband and Wife wish to equitably divide the property of their marriage between themselves; THEREFORE, Husband and Wife have agreed to the following terms as consideration for the dissolution of their marriage and the distribution oftheir marital assets: 1. Wife will retain the marital residence and pay to Husband the sum of$30,OOO.00(Thirty Thousand and 00/100 Dollars) for his interest in the marital home. Payment is to occur on July I, 1994 at which time Husband will convey by deed his interest in the property located at 335 F Street, Carlisle, Cumberland County, Pennsylvania. A legal description of the property known as the marital home is attached hereto as Exhibit "A". lof4 '.' ,~ , 2, Husband will retain his bedroom suit consisting of (I) bed frame, (I) mattress and box spring, (2) nightstands, (I) dresser with mirror, and (I) bureau chest of drawers. 3, Wife shall retain sole ownership and possession orall other personal property located within the residence at 335 F Street, Carlisle, Cumberland County, Pennsylvania. 4. Husband will receive his automobile. 5, Each party will retain any cash accounts/deposits held in their individual names. 6, Husband will pay to Wife S540.00(Five Hundred Forty and 00/100 Dollars) per month in child support from the date of this agreement until August 31, 1994. 7. Wife will consent to a divorce pursuant to 23 Pa. C.S. ~3301(c) in the case before the Court of Common Pleas of Cumberland County numbered 264 CIVIL 1994. 8. The provisions ofthis Agreement and their legal effect have been fully explained to the parties by their respective counsel, Diane G. Radcliff, Esquire for Wife and Mary Kollas Kennedy, Esquire of Kollas & Kennedy for Husband. Each of the parties acknowledges and agrees that, after having received such advise and with knowledge, this Agreement is, under the 20f4 " " circumstances, fair, reasonable, equitable, that it is being entered into freely, voluntarily, and in good faith and that the execution of this Agreement is not the result of any duress, undue influence, coercion, collusion andlor improper or illegal agreement, The parties further acknowledge that they have agreed to waive any specific enumeration of their respective assets, estate, liabilities, and sources of income for the purposes of this Agreement. 9, The parties agree that unless otherwise specifically provided herein this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. Husband and Wife agree that the tenus of this Agreement shall be incorporated, but not merged into any divorce decree which may be entered with respect to the parties. The parties further agree that the Court of Common Pleas which may enter such divorce decree shall retain continuing jurisdiction over the parties and the subject matter of the Agreement for the purpose of enforcement of any of the provisions thereof. WHEREFORE, the parties being in agreement, intending to be legally bound, hereto set their hand this day, k 1Jf't:{ f/o..1--, /"71097 11- l'it.t,fh-'-0 Konstantinos A. Mazlas G eo 1-19 ; u.. 1'1 (I ? l' ,~ Georgia Mazlas . , tUlCdo- I Ii I Mary Kol Kennedy, Esq. Attorney or Husband 30f4 .,. J,. . . '. '. EXHIBIT "A" I\LL that cl!rtaill lot of ground wi th the improvements thereon erected situated in the Fifth \Yard of the lJorough 01' Carlisle, Cumberland County, Pennsylvania, lJllulllled and described as follows: BEGINNIUG at a IJoint on the 1I0rth side of "F" street which point is located 174 feet East of the Eastern line of Franklin street, and at the Eastern line of an unnamed 16 fl!et wide public alley; thence by the Eastern line of said alley Horth 14 degrees East 150.0 feet to an iron pin at another IInlHu'leu 10 1'el!t wide pllblic alley; thence by the Southern line 01' said jJlllJlic alley :30uth 76 delIrees 15 minutes East 40.0 feet to an iron Jlljt<!; thence lJy prollerty now or formerly of Glenn R. i\dams, et ux., :.loutll 13 dellrees 14 minutes 10 seconds West 150 feet to n point; thenee by tile ;lorthorn line of "F" Street Uorth 76 degrel!R 1!i minutes I'/est !iU.U feot to till! ,,1lace of Deainning. BEING the major .vortion uf Lots lias. 10 and 20 of Bloclt 34 of Plan of lots Itnown as Carlisle Land and lmvrovement Company recorded in the office of Recorder of Deeds for Cumberland County in Misc. Docket Mo. 11, page 572. BEllm improved with a one story brick ranch dwelling known as No. ,,:3311 "F" Street, Carlisle, Pennsylvania. BEING the same which Richard E. Thompson and Lois A. Thompson, his wife, by their deed dated August 16, 1971 and recorded in the office aforesaid in Deed Boolt "I", Vol. 24, Page 013, conveyed to Wayne A. Arbegast and Shelby J. Arbeaast, llrantors herein. 4of4 ..".. en - = c.... N .-I N ~>- "':<~"I "' '- ~ - . ~~ {; '::.;:.~ .. .I' ~ .., n . , ~Y. en l'J "" n.. -= .;J '~';';'; .. ~:t.... -, ~;Q - ~ 1Il~ III :J 0( Z ~ Z z ffi~~~~_ :ll: i( C >- . 0 In f Q III 0 Z- Z~:tZ::! <ZZIIl;:: a: a: D._ ~UlO~:f~ I: ., _ i( 0 J: O - Do - ~ :ll: 0( u '" .~ KONST ANTINO A. MAZIAS, PlaintilT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA : NO, 264 CIVIL 1994 v, GEORGIA MAZIAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the fonowing information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under ~3301(c) of the Divorce Code, 2. Date and manner of service of the Complaint: Served January 25, 1994 by Deputy Sheriff, Cumberland County. 3. Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code: by plaintilTon April 25, 1994; by defendant on April 25, 1994. 4. Related claims pending: None, - ~,,""''''- .,. G1I - :s= Co- N' ...., N ...,.. ...:,- "C'J('. . .... ",}.. ...<r,., ::e c:;; .:"-; ~~J;:'~':' h'.-, ~ :;:~:-.. <:1">' ....... '" .... """ :w.' ..;.;. " . , , . KONST ANTIN<Y A. MAZIAS, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA ; NO. d(oY. CIVIL 1994 : CIVIL ACTION - LAW : IN DIVORCE GEORGIA MAZIAS, Defendant 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. Ajudgment 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Court Administrator One Courthouse Square Carlisle. Pennsylvania 17013-3387 (717) 240-6285 , KONST ANTINO A MAZIAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v, : NO. CIVIL 1994 GEORGIA MAZIAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Konstantino A. Mazias, by and through his counsel, William C, Kollas, Esquire, and respectfully represents as follows in support of the within Complaint: 1. Plaintiff is Konstantino A. Mazias, an adult individual currently residing at 335 F Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Georgia Mazias, an adult individual currently residing at 335 F Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 12, 1969 in Greece, 5. There have been no prior actions of divorce or for annulment between the parties, 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. , COUNT 1- DIVORCE PURSUANT TO ~330I(R)(6)- INDIGNITIES 7, Paragraphs 1 through 6 ofthis Complaint are incorporated herein by reference as though set forth in full. 8, Throughout the marriage Defendant has caused the innocent and injured Plaintiff to suffer such indignities as to render Plain tift's condition intolerable and life burdensome, COUNT 11- DI~ORCE PURSUANT TO !53301(c) OR (d) OF THE DIVORCE CODE 9, Paragraphs 1 through 8 of this Complaint are incorporated herein by reference as though set forth in full, 10. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff prays that judgment and decree be entered as follows: (a) As to Count I, that a decree be entered divorcing Plaintiff from the bonds of matrimony with the Defendant pursuant to 23 Pa,C, S. ~3301(a)(6); or 2 (b) As to Count II, and in the alternative, that a decree be entered divorcing Plaintiff from the bonds of matrimony with Defendant pursuant to 23 Pa.C,S. ~ 3301(c) or (d), RESPECTFULLY SUBMITIED, DATE:-"S\"I....\ll\fl .21) \9'\~ ~~LtJ/lL- William C, Kollas, Esquire Law Offices of William C. Kollas P.O. Box 433 Camp Hill, Pennsylvania 17001 Telephone: (717) 731-1600 1.0. No. 06341 A TfORNEY FOR PLAINTIFF 3 ~;1;<: , VERIFICATION I verIlY Iballbe stalements made in Ole foregoing COMPLAINT arc true and correa to the besl of my Infonnation, belief and knowledge, I understand Oml false statements bereln are made subject to Ole penalties of 18 Pa. C.S.A. 4904, relating 10 unsworn falsification 10 aulborlties, BY: _'*0'?'-2 ~/~,~./",'?;Jp.-, a-r~,jJ7' ~ KONSTANTINOS A. MAZIAS V DATED: JaoU8l)' ~l . 1994 ..... en . ,< ? ~ .J.-1j d ,~ -u i a~ s.. v1 o \.0 \.\) (- I] (J o ':I o lI) >;.. ::t";: if: ~J~. ,..t ~ ~ ~..~-!~ ~N ", .~ J' ..' l.r .-. :,;\.J IM:t:'-". ::> 04'\ \Ij- ...... "" -" ....... { ]., r -a oJ C C 'I' )./. 0- - l.t) :II -b (J \J1 o 00 of. III t! - - o 'n~ -:$ ~ ~ .' ..,...............~w...~ . . - . -. . .... .:. ~~ . . . '," .... . ;... ~. .... .. .... .'. .......~....t. to "~"",",,'l'~"'i_' .~.... ..;.. . . .'.....,'___...;.0..........._........,. - SIlERI FF' S RE'I'URN CO>lMONWEAL'Ili OF PENNSYLVANIA: COUNTY OF CLMBERLAND In The Court of Common Pleas of Cumberland County, Pennsylvania No. 264 Civil Term 1994 Complaint in Divorce Civil Action Law Konstantino A. Mazias VS Georgia Mazias Weslev Cook , ~R~XllQr Deputy Sheriff of Clmberland County, Pennsylvania, who being duly swom according to law, says, that he served the within Complaint in Divorce Civil Action Law upon Georqeia Mazias ,thedefendant, at 8:20 . o'clock p.M. EST / ~Jln on the 25 day of January , 19-2...4at , 335 F Street, Carlisle , Clmberland County, Pennsylvania, by handing to Georqia Maz ias a true and attested copy of theComplaint in Divorce Civil Action Law and at the SaJro time directing her attention to the contents thereof and the "Notice to Plead" endorsed thereon, Sheriff's Costs: Docketing Service Affidavit Surcharge 14.00 2.80 So an;;w~rs: ~. ," . ~ :~- , ~- T ~~",....~G.<: . 2.00 18.80 Pd. by Atty. 1-26-94 R. Thanas Kline, Sheriff by Sworn and subscribed to before Ire /1 this j/~ day of I..._~.......u~... , f 19-21_ A,D. C)''IL' (2.,. Jll, ";', Prothonotary 11..~11 . ," ".- . ......,......~_.~ . ' KONST ANTINO A MAZIAS, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA : NO. 264 CIVIL 1994 GEORGIA MAZIAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. 21,1994, A complaint in divorce under ~3301(c) of the Divorce Code was filed on January 2, The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3, I consent to the entl)' ora final decree of divorce, 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 falsification to authorities. DATE: II- P R I L. <l r- ) I r!j c; Lf .)to '0 > fa.~ h'V/c-"l;:? Jt--/ ~h~ Konstantinos A. Mazias, Plaintiff t/ "::I'" en - ~~ :.(~ '-'.... ...-.& ~..t';-...." '::~.;-:- ::.::: "'- "" ~ Nl c:n ...... ... .... .... '.-; - . -4~ " ..;,'- -:t c:;\".' , . vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 264 CIVIL 1994 KONSTANTINOS A. MAZIAS, PLAINTIFF GEORGIA MAZIAS, DEFENDANT CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 21, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not bee filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 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. Section 4904 relating to unsworn falsification to authorities. Dated: April 25, 1994 , \ Ge.oJ.'J'~/:"" Hcsz.2/&,-,\ GEORGIA-MAZ IAS DIANE C. RADCLIFF A TTORSE\'.A T-LA W 1HR TRISIU.f. ROAn CAMP 11I1.1.. P,\ IiOIl :-'._"~,l,' .,..:.- -:r en - en ...... ... a.. ..ex >-.. "'... 'f... "'-,"1 UJ")7.~ '= ~ r;'''1 .....<;-"--:.,. ~....-, J;-- ~~ r' 'x .J..r. ';"... ..1'7;''' " ..' '" :c e..- N .-t N