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HomeMy WebLinkAbout94-02990 .... ~ c '- ~ ~ 1 - V) 1 , ~ I , j , ! .C '0 13 , , i , - \ VJ I ~--~~~~~-~~~-~-~-~~---~~~~~~~.~.~'~~~~ . . --- ''- ., ~ w .. 0;0 . ,.. ~ ~.' ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ~ ... w ',' w ',' ~ ", w ~ .:., ~ w '" LINDA L. SLEDZ IN SKI ,u'uu il N (). ...,94::-,Z99,Q..CiIlU........,.. 1994 a '.' ~ ~.' Plaintiff ... ........ ~ ',' Ve1'SUS a '.' JOHN J. SLEDZ IN SKI , JR, . . . . . . . . . . . i :1 ~ '.' Defendant w ',' ." w '.' a '.' DECREE IN DIVORCE AND NOW, .. ..Il,tH.,:(.!?........ ..... 19 ,cr 1,.., it is ordered and decreed that,., ., ,. ,.L.I,Np.A, .L.', .S.L.~~Z.I.N,S,~I, , ..,.. ,.." ..,. "., ", plaintiff, and.""....."...., .~~~~.~: ,~~~~~7~~~7~ ,~~"..,',.,."....., defendant, are divorced from the bonds of matrimony. ~ '.' s~ ~ t. i ... ~ w ~.' ,', ~ w ',' ~ '.' 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; ~ ~ ". ~ ". ~P~I>",.",."""""..,....".,.,..."...,....",.,..".,.,..,......" a '.' ~ ~.' ;', !' ~ .,' ............. .................. .... ........ ........ ..... Dy The Cour}1 If '''~-'U/~~B b~l'i', ' ., AlIest ",L 1 /-L j/ 7./~, J. "'lV'~rl.Gt "'~ ~-r:.feHr-'7 ~~-H.'l r ~A> (j'b 'j , , "r? Prothonotary ~ ", ~ ~ ~ 7- ~ :;' - - - - - - -- ~.:..:. .~:. .:.:. .:.:. .:.: ~ S ~ ... ,', to * ;.~ t. ~ ~ " ~ ", w ", ,'. ~ ,', ~ ~ ~ ~ '? ~ '.' " ~ ,.' ~ w " ~ ~ '.' ~ ~.~ i ~.' , ~ '.' i ~.' ~ ... . ~ ~ ',' ~ '.' ~ ~ ... ~ * ,'. ~ ~ ',' s ~ . .~ ~" " - ~ ~~~**-~---**-*-*~*-***~. * .- .....- i AGREEMENT AGREEMENT made this Q7~ day of ~~ 199.6', by and between JOHN J. SLEDZINSKI, Jr. (HUSBAND) of 1304 South Market Street, Mechanicsburg, Pennsylvania and LINDA L. SLEDZINSKI (WIFE) of 10 Warrington Road, Dillsburg, Pennsylvania. WITNESSETH: WHEREAS, the Parties hereto are HUSBAND and WIFE, having been " married on June 30, 1979 Dillsburg, Pennsylvania. marriage, WHEREAS diverse unhappy differences, disputes and difficulties at South Mountain Union Church, There were no children born of this have arisen between the Parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the Parties hereto are desirous of setting 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 JAN M. WILEY " ASSOCIATES AnOINEY AT LAW 2 ."aw CIRCLE DILLS.UAG, p" 1711. JAN M. WILEY '" ASSOCIATES AnOINEY AT LAW ltA.LO CIRCLE DILUIURC. 'A 17t1t nerein, this Agreement shall continue in full force entered with respect to the Parties. 3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The Parties agree that the terms of th~s Agreement shall b incorporated but not merged into any Divorce Decree which may b entered with respect to them. The Parties further agree that th Court of Common Please which may enter such divorce decree shal retain continuing jurisdiction over the Parties and the subjec matter of the Agreement for the purpose of enforcement of any 0 the provision hereof. 4. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreemen shall be defined as the date of execution by the Party las executing this Agreement. 5. DISTRIBUTION The transfer of property, funds and/or documents provided fo herein shall only take place on the "distribution date" which shal be def ined as the date of execution of this Agreement unles otherwise specified herein. 6. ADVICE OF COUNSEL WIFE and HUSBAND declare that they have each had a full an fair opportunity to obtain independent legal advice of counsel 0 their selection; that HUSBAND and WIFE, cognizant of their right t JAN M. WILEY " ASSOCIATES AnORNIEY AT lAw 1 LULU aleu: DllU.VRG, 'A 1'701' jlegal representation, declares that it is their express, voluntary and knowing intention to be represented by same counsel with respect to the preparation and execution of this Agreement. HUSBAND and WIFE further declare that they are executing this Agreement freely and voluntarily. WIFE and HUSBAND declare that they have each had a full and fair opportunity to obtain independent legal advice of counsel of their selection. WIFE has been represented in this action Jackie J. DeArmond, Esquire and Keith B. DeArmond, Esquire, 280 Market Street, Camp Hill, Pennsylvania. HUSBAND acknowledges that he has been advised that he shoul \ seek independent legal counsel but he has voluntarily elected no to do so. 7. PERSONAL RIGHTS HUSBAND and WIFE may and shall, at all times hereafter, liv separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by th other in all respect as fully as if they were unmarried. They ma reside at such place or places as they may select. Each may, fo his or her separate use of benefit, conduct, carryon or engage i any business, occupation, profession or employment which to him 0 her may seem advisable. HUSBAND and WIFE shall not molest harass, disturb or malign each other or the respective families 0 ,each other nor compel or attempt to compel the other to cohabit or swell by any means. or in any manner whatsoever with him or her. 8. MUTUAL RELEASES HUSBAND and WIFE 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, title and interests, of 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 wherever situate, which he or she 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 of curtesy, or claims in the nature of dower or curtesy or 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, JAN M. WILEY '" ASSOCIATES A"OlNn AT lAW :I IAILO alcu DILUIURG, rA 1111' whether arising under the laws of (a) the Commonwealth of PennsYlvania, (b) State, Commonwealth or territory of the United states, or (c) any other country, or any rights which either Party may have or at any time hereafter have for past, present or future "' JAN M, WILEY .. ASSOCIATES A"OINn AT LAW J .ARLO a.eLf. DlLUIIURC. rA 1111' jsupport or maintenance, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and any except, all rights and agreements and obligation of whatsoever nature arising or which may arise under tHis Agreement or for the breach of any provision thereof. It is the intention of HUSBAND and WIFE to give each other by the execution of this Agreement full, complete and general release with respect to any and property of any kind of nature, real, personal or mixed, which th other now owns or may hereafter acquire, except and only except al rights and agreements and obligations or whatsoever nature arisin or which may arise under this Agreement or for the breach of an provision hereof. 9. INSURANCE HUSBAND and WIFE mutually agree that neither shall have an type of insurance policies wherein the other is beneficiary. 10. INCOME TAX The Parties hereto will file a joint 1994 Federal Tax Return. However, Husband is solely and completely responsible for an monies due and owing to the Internal Revenue Service as well as th Commonwealth of Pennsylvania and any other taxing jurisdictio relative to the year 1994. As of this date, there are outstanding taxes due in the amoun \ JAN M, WILEY '" ASSOCIATES AnORNEY AT lAW lIAIW CRf.:U DIW.VIG, rA 1'701. lof $60,000.00 payable to the I.R.S. In the event that the Internal Revenue Service fergives all or any part of t~e back taxes then HUSBAND shall pay to WIFE one half of the amount of taxes forgiven by the I.R.S., all of which shall occur within two (2) years from the date hereof. 11. PERSONAL PROPERTY HUSBAND and WIFE hereby acknowledge tha~ they have heretofore divided all items of personal property, except for the following items which shall be delivered to WIFE within ten (10) days of the date of this agreement. The items are: 1. VCR 2. Brass, Glass lamp table 3. French Gold Mirror 4. 2 Pictures ( in living room ) 5. Photo Albums 6. Record Albums 12. BANK ACCOUNTS HUSBAND and WIFE acknowledge that any checking or savings accounts have already been divided between the parties. 13. AFTER ACOUIRED PERSONAL PROPERTY Each of the Parties shall hereafter own and enjoy, independently of any claims or right of the of her, all items of pe~sonal property, tangible or intangible, hereafter acquired by , JAN M, WILEY " ASSOCIATES ""OlNEY A' LAW J IAILO CIRClE DIWIURU,'A IT'DI' ~im or her, with full power in him or her to dispose of same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 14. WIFE'S DEBTS WIFE represents and warrants to HUSBAND that since the Parties marital separation, she has not contracted or incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of this Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify and save harmless HUSBAND " from any and all claims or demands made against him by reason of debts or obligations incurred by her. 15. HUSBAND'S DEBTS HUSBAND represents and warrants to WIFE that since the Parties marital separation, he has not contracted or, incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or incur any debt or liability after the execution of this Agreement for which WIFE or her estate might be responsible. HUSBAND 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. "' . JAN M, WILEY '" ASSOCIATES A"OANEY AT lAw J IARLO ClRCL! OILUIURC. rA '''If I HUSBAND agrees to be responsible for all obligations made during the course 'of this marriage, including, the mortgage to Farmers Trust co., all back taxes of Internal Revenue Service, Pennsylvania State Department, real Estate taxes and any other debts that were mutually incurred during the marriage. HUSBAND agrees to completely indemnify WIFE for the payment of all these debts and hereby agrees to be totally responsible for the same. 15. AUTOMOBILES WIFE presently has in her possession a !991 190 Mercedes Benz entitled into WIFE's name alone. However, both parties are makers 'of a loan to Farmers Trust, which WIFE will put in her own name within thirty (30) days of the signing of this agreement. 16. CONSIDERATION HUSBAND agrees to pay unto WIFE the sum of Twenty Thousand ($20,000,00) within ten days of the signing of this agreement, The parties stipulate and agree that the aforementioned sum is in the nature of alimony or support and shall be an obligation not dischargeable in any bankruptcy petition filed by HUSBAND. If HUSBAND files for bankruptcy within 5 years of the date of this agreement, this agreement shall constitute conclusive evidence of the parties intent that the obligation of this paragraph is in the nature of support and maintenance and is not dischargeable in \ JAN M, WILEY '" ASSOCIATES AnORNEY AT LAW 2 IARLO aReu:. . DIWIURG. .A nil. ,bankruptcy under the current bankruptcy law or any amendment thereto. Furthe~more, if HUSBAND institutes an action in bankruptcy or any other bankruptcy proceeding is instituted in which WIFE rights to the alimony or to the aforementioned drums hereunder becomes a matter for Judicial Review, HUSBAND agrees to consent to any motion filed by WIFE with the Bankruptcy Court requesting that the Bankruptcy Court abstain from deciding the dischargeability of this obligation and any other obligation due her hereunder in order to allow the Cumberland County Court of Common Pleas to rule in this issue. If for any reason HUSBAND is successful in having this obligation discharged in bankruptcy or if \ any payments made to wife are deemed a preference by a court of competent jurisdiction in bankruptcy, then the parties agree that this agreement shall be null and void as a resolution of WIFE's pending economic claims in a certain divorce action filed in the Court of Common Pleas of Cumberland County. Furthermore, wife shall have the right to prosecute her economic claims in the divorce action as if this agreement h ad not been entered and any order of support entered. 17. DEFAULT OR DELAY IN PAYMENTS FOR OBLIGATION PERFORMANCE UNDER AGREEMENT In the event that either party defaults with respect to any payments to be made hereunder, or any obligation to be performed "' ~ereunder, and in addition to any and all other remedies provided in any other documents or agreements, and said default is not remedied within ten (10) days after sending of a written notice by certified mail to the defaulting party specifying said default, the defaulting party hereby agrees to indemnify the party injured, or to reimburse him or her for any and all attorneys fees and disbursements resulting from or made necessary by the bringing of any suit or other proceeding, whether by complaint or counter-claim to enforce any obligation or to collect such payment, providing such suit or other proceeding results in a Judgment, Decree or Order in favor of the suing party. In the event such suit or other 'proceedings results in a Judgment, Decree or Order against the suing party, the suing party shall reimburse the other party for any and al expenses, costs, attorneys fees resulting from or made necessary by virtue of the bringing of such suit or proceeding. 18. REAL ESTATE WIFE agrees upon the signing of the agree to relinquish all of her right, title, and interest in and to all of the jointly owned real estate, which is situate at 1304 South Market Street, and 1306 South Market Street, Mechanicsburg, Pennsylvania. JAN M. WILEY .. ASSOCIATES AnORNIY AT LAW 1 .ARLO ClICU OIWIUIC. PA 11IIt 19. FINAL EOUITABLE DIVISION OF PROPERTY The Parties agree that the division of all property set forth in Agreement is equitable and in the event an action in Divorce is JAN M, WILEY 4 ASSOCIATES AnORNE\' At LAW J IAILO CIRCLE DILLBUIC. 'A 1101' !commenced, both Parties relinquish the right to divide property in any manner not consistent with the terms set fort herein. It is further the intent, understanding and agreement 0 the Parties that this Agreement is a full, final, complete an equitable property division. 20. WAIVER OR MODIFICATION No modification or waiver of any of the terms hereof shall b valid unless in writing and signed by both Parties and no waiver 0 any breach hereof or default hereunder shall be deemed a waiver 0 any subsequent default of the same or similar nature. \ 21. MUTUAL COOPERATION Each Party shall, at any time and from time to time hereafter take any and all steps and execute, acknowledge and deliver to th other Party, any and all further instruments and/or documents tha the other Party may reasonably require for the purpose of full force and effect to the provisions of this Agreement. 22. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with he law of the Commonwealth of Pennsylvania. 23. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the benefi , of the Parties hereto and their respective heirs, executors administrators, successors, and assigns. j 24. INTEGRATION This Agreement constitutes the entire understanding of the Parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 25. NON-MERGER \ It is the Parties intent that this Agreement does not merge with the Divorce Decree, but rather, it continues to have independent contractual significance and each Party maintains their contractual remedies. 26. OTHER DOCUMENTATION WIFE and HUSBAND covenant and agree that they will forthwith (and within at least twenty (20) days after' demand therefore)! execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree, should be so executed in order to carry out fully and effectively the terms of this Agreement. 27. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless JAN M. WILEY " ASSOCIATES AnOINn AT L\W 2 IARLa CIRCLE DILuaURC. PA 1'711' and until terminated under and pursuant to the terms of this Agreement, The failure of either Party to insist upon strict :~_~~.i:!"f~__~ -.. '-') ;- i'-- ,---. -- .... u.1 ~ " , , c: . .i ?~ ...-- - i-- "- -. l-) (\:-- ';~J ;,':~ \ - \ - , j.) i..__ . : '-,~ :'.J L ..) ADDENDUM This Addendum to the Agreement executed on the d9f1t day of "iY/lU..eA , 1996, between 10hn 1, Sledzinski, lr, and Linda L. Sledzinski is made this ~ day of "fIt~ , 1996 and is incorporated into and shall be deemed to amend and supplement the aforementioned Agreement. I: I I . ADDITIONAL COVENANTS, In addition to the covenants and agreements made in the Agreement executed the tJql'1 day of~, 1996, 10hn 1, Sledzinski, lr, (Husband) and Linda L, Sledzinski (Wife) further covenant and agree as follows: The Parties acknowledge that they are joint owners of certain real property located in Perry County described below: ALL THAT CERTAIN TRACT orland situated in Carroll Township, Perry County, Pennsylvania, being more fully bounded, limited and described as follows to wit: BEGINNING at a point on the eastern dedicated right-of-way line of Route 34; thence continuing along said dedicated right-of-way line North one (01) degree forty-six (46) minutes fifty (50) seconds West a distance of two hundred fifty-eight and twenty-five hundredths (258,25) feet to an iron pin on the eastern side of the dedicated right-of-way line of Route 34 at Lot No.2: thence along Lot No, 2 North eighty-nine (89) degrees fifty-six (56) minutes forty-six (46) seconds East to an iron pin at Lot No, 3; thence along Lot No, 3 North forty-six (46) degrees fifty-five (55) minutes forty-two (42) seconds East two hundred thirty-seven and sixty-four hundredths (237,64) feet to an iron pin on the southern side of Sled Drive (50 feet wide): thence along the southern side of Sled Drive the following courses and distances: by a curve to the right having a radius of seventy-five (75) feet and an are distance of fifty-seven and twenty-eight hundredths (57,28) feet to a point; thence South eighty-six (86) degrees fifty (50) minutes zero (00) seconds East a distance of four hundred thirty-three and thirty-three hundredth (433,37) feet to a point on the southcrn side of Sled Drivc at other land of the Grantor herein; thence along the last mentioned lands South eight (08) degrees thirty-nine (39) minutes thirty-three (33) seconds East three hundred seventy-nine and ninety-four hundredths (379,94) feet to a point at lands NIF of lames A Gordon; thence along the last mentioned lands North eighty-nine (89) degrees forty-nine (49) minutes thirty-two (32) seconds West a distance of eight hundred Page 2 seventy-three and ninety-six hundredths (873,96) feet to a point on the eastern side of the dedicated right-of-way line of Route 34, the point and place of BEGINNING, CONTAINING 6,888 acres and being designated as Lot No, 6 on a Final Subdivision Plan for 10hn Sledzinski dated December 18, 1985, and recorded in the Office of the Recorder of Deeds in and for Perry County, Pennsylvania in Plan Book 26, at page 108. UNDER AND SUBJECT, NEVERTHELESS, to all restrictions, covenants, rights-of-way and easements of prior record, IT BEING a portion of the same premises wiich H.B, Snyder and Ethel M, Snyder, his wife, by their deed dated October 6, 1953, and recorded in the office of the recorder of Deeds in and for Perry County, PeMsylvania, in Deed Book 147, at page 620, granted and conveyed unto 10hn 1. Sledzinski and Edna C. Sledzinski, his wife, The said Edna C, Sledzinski, died on October 22, 1971, thereby vesting full fee simple title in her husband, 10hn 1. Sledzinski, 10hn 1, Sledzinski has since intermarried with Ehtell.Sledzinski and together they are the grantors herein, Husband agrees to transfer all right, title and interest in the above described real estate unto Wife, It is understood by and between the parties that it is intended that the aforementioned real property be sold on the open market. It is agreed by and between the parties that in the event that Wife's share of the proceeds of the sale of the above described real property does not equal or exceed the sum of thirty thousand dollars ($30,000,00) then Husband agrees to pay unto Wife the difference between those sums received by Wife from the sale of the real property and the sum of thirty thousand dollars ($30,000,00), Page 3 The following changes should be made to the aforementioned Agreement: 10, INCOMETAX The first paragraph should be amended to read: The parties hereto will file a joint 1995 Federal Tax Return, However, Husband is solely and completely responsible for any monics duc and owing to the Internal Revcnue Service as well as the Commonwcalth of Pennsylvania and any othcr taxing authority rclativc to the ycar 1995, 11. PERSONAL PROPERTY This paragraph should be amended to read: Husband and Wife hereby acknowledge that they have heretofore divided all items of personal property to their mutual satisfaction. 15, AUTOMOBILES The second sentence should be amended to read: Wife agrees to endemnifY Husband and hold him harmless from the car loan secured by the 1991 190 Mercedcs Bcnz, 16. CONSIDERATION Dclctc first paragraph and the first scntcncc of the second paragraph should be amcnded to rcad: The partics stipulatc and agrec that any sums payable to Wife by Husband shall be pursuant to the aforcmcntioned provisions related to the sale of the above described real property shall be considered to be in the nature of Alimony or support and shall be an obligation not dischargeable in any bankruptcy petition filed by Husband, t.~...." ,........:..";,,"..1;,.,... LINDA L, SLEDZINSKI. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS, : NO. lJ4-29911 CIVIL TERM : CIVIL ACTION. LAW JOHN J. SLEDZINSKI, JR., Defendant : 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: J. Ground for divorce: irretrievable breakdown under Section JJOI(c) ofthe Dh'orce Code. 2, Date ofsen'ice of the complaint: June 11, 1994. Certified Mail Receipt attached 3, Complete either paragraph (a) or (b) (a) Date of execution of of the affidavit of consent required by Section 330 I (c) of the Divorce Code' by Plaintiff: March 29, 1996: by Defendant: March 29, 1996, (b) Date of e.=ution of Plaintil1's Affidavit required by Section 330 I(d) ofthe Divorce Code: and date of service of the Plaintil1's Affida\'it upon the Defendant: 4, Relate claims pending: No related claims pending S, Dale and manner of Senice of Notice of Intention to file Praecipe to Transmit record, a copy of which is attached if the decree is to be entered under section 3301(d) (I) of the Divorce Code: 6. Date and mailer ofsenice of Notice of Intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301(c) of Dh'orce Code . or date of e.xecution of waiver of Notice oflntent: by the Defendant: March 29, 1996, by the Plaintiff: March 29, 1996 and date of filing of both waivers: with this document. Respectfully submilled, DeArmond & DeArmond . Date:~~ f,~ ~g)i, ~~ Keith B. DeArmond, Esquire Sup, CI. 1.0, #I 58878 28(HI Market Street CampHiII.PA 17011 (717) 730.lJ]lJ4 i..,. 'lC~',' '" '~~,~,'~,':"'~',,"'{",' 2~.' ..,i,,',"k.,.,.,';;,'.i;,"",:,.,'.....,..,,;..:........:./.'.'.:,'," ',.'*.,',.,..:,',.'~,.., .,'".' .".,..'.;,.," ',' ~,"c;:..,., ,,;,,:,,' f'.,t,."."i~~,',Wr,-ilti..~ .r"..to,'. ~;..i,r""",~, >.' '.'1Yj W .'Cliijljllll.f~'3,'.nd'" . ..b.." '",..;. ..' ,\<\.:-'..'.':1'> ..:;:C-:; :fOlIci~;~'liot"f" 1~ ~it~JfJ::=,~~~~'jhe.~~~~~,~..~~~~'~ ~i.~;-, j~h;;~:\':t~;;.~~~f~~~jl\~~'~_ ',.. ~I ..~AllllChlhlOlomltOlhOti.lni..,.tiio~;.fO"u..~Il0Pac0:;: " '1.;0 Aild-.....:A~tg( ,j Ir.~~=R;';'~jRoq....~;...u..~~....~"';';';" .. 2:,d.A~~;g;':';};~ItKi~~:I:~ f ~.d:.~~OlUI!\RocoIpt""lIlowto_thoonlclo""__andtho_ . ". :""'~'l1l1 ,.;I'&~';~,I'~.~~I:;~~;~ ~'ed,;~: " . ,'. ' . '~;~rdC~O=:..r..;.:,..:t.f;,..:;:~.. .,';.!:....,'.,~~'.'..,i.. '; >,. ". " , . z.......,. ,'... '.'. ,j f ;'X:;~." ';. i,..\;': _ - _" ';' " . \ " _ _ ';JIIJ - ':<. '-_._-o.~t:-:>,:._',;;.:;"I ~,,: ;,:.,~",~~' ",\\".."",:r.", ..,.,~k.Q.2(~S~,I, Je" ~. . ,4b. S, .rvlceTypa" ',...",..,.,..,...,...,;,.t,.".,.,,'.,\,,',i:,',., ! jii' ;'1',<::". " ,0 Regllt.red '0 IllIUred.."..:,.,,;..,... iJl:l,,';\,'('~'O:U, ,C"'.,,^~_f....&- C'.(... 'Ql{C.rtlfled ",DCOD "';::";;;:~'<~f: j~ ",~", -:0 ,-~., J .......IiIlL\ .,;)\; .,'", 'R R....;;;;.I.-...'.....'.'...:I !~ ';V?;:\::",' '.,' . . , D Expr... M.II.o tlUm .....pt:.~ri4.; :~~>I:O~~c:.s~~ <?A \ oSS 7. 0.1 O~'I ~ryi ,;.,;J~ If:' ::~:~~~~.tur. ~~dre....) , '8.A~......:.Add,...10~IVll.~~~~j " "'J:> " f..l. paid)," ",. ,.,'q".', .. I"~;; '~"..~ . , : t. iii. L."nir,~;~.;~~"Y;r; if"~; "'k <.,< . ..",;,lly,!:I.".,;~;;",fI~;~ h}.~J:l>. .. .., .e.CII'O:I--.7t. DOMEST,lC"ETU~~REl:~Jm:f;~ f.~~iiC;~',:''- '~":!t'i:';"!-'-',, ',' ',' - ."-, -.~ ,.'-.", ,,-, ",- >~/>;:r~~~at' , I ) ... . ":1" ~ ff:: ..... "" (...., - :- .",>- ..-,.. u,,,:_:'~ ?} ~? ~t ~'.~ ~,. ~-' . ,-- i';'} (T') t-' .~ .~ ,~ :::;L~ ~ ~ --, .: 7,~t~J~~~~:~1J7~1o' '-' ". M~ "1 - ~~ i \ ~~ . . , , LINDA L, SLEDZINSKI, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS, ; NO, f)'/ - .;J9?~ Cud \Zt4,., : CIVIL ACTION - LAW JOHN J. SLEDZINSKI JR., DEFENDANT : 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 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 divorce is indib'l1ities 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, Pennsylvania. 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 UA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 ,.._"",~"\...:",,,1I'o . . Wherefore, the PlaintitTrequests this Honomble Court to enter a Decree of Divorce in this matter pursuant to 3301(c) or 3301(d) of the Divorce Code. ac le'l rmon, Esquire Attorney ID Number 64177 2800 Market Street Camp Hill, PA 17011 (717) 730-9394 DA TE(]L(fM ,J.. /1 U ,1994 , Pl4>~YJ!!i, , . . . LINDA L. SLEDZINSKI, PlaintitT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 94-2990 CIVIL TERM VS. CIVIL ACTION - LAW JOHN J. SLEDZINSKI, JR., Defendant IN DIVORCE AFFIDA V1T OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 3,1994. 2. The marriage ofPlaintitTand Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry ofa 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 verilY 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. Date: :J.0l r-9(, -..,. ,n 1"-'-- '. ! .. , k II . ~ ( " ;....~ , j:'? r: . .- .~.. c.; . ~;j , C' a il c. . >~ i:.:: r .-, ~':<- ~:lJ - C, ;. .~:. :;. , , " ,-) " I' , , .~ tr) i.... 2: ..:~~ ,. ,,' w!,' _. ~{~ c._{ f]=:r ':I:t t. _. , (u,' ..::;... 1 ' '::J ~ -, j-'-l t'i \ , -, (J ...:: .!.. , . " ..:3 " - . ., " . . - . LINDA L, SLEDZINSKI, PlaintitT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 94-2990 CIVIL TERM VS. CIVIL ACTION - LAW JOHN 1. SLEDZINSKI, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 3,1994. ' 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint, 3. I consent to the entry ofa final Decree of Divorce, 4, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted, I verilY 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, Date: '7J/c,ud ..J. 9. /99~ ~ . ... '.. . - . LINDA L. SLEDZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 94-2990 CIVIL TERM VS, : CIVIL ACTION - LAW JOHN J. SLEDZINSKI, JR" Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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, Section 4904 relating to unsworn falsification to authorities, Date: 'n{Ia<.d .z. '1 /916 , , r~d'a. 0( b~ Li da L. Sledzinski, Plainti >- cr; ~: C IJ).., (.);:.' . IL'" Cl: _ y,' ,.., L~' .. - I," '- ~:;: .q) ..-- '-~:,. _.t_>-" .J< .:1:J -.,.. :: ] ! _.:Ti ':::> ..... l:~ '" I', C. I.E'. ~::.) i, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LINDA L, SLEDZINSKI Plaintiff NO. 94-2990 CIVIL ACTION - LAW vs, JOHN J. SLEDZINSKI, JR" Defendant IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above malter, having been granted a Final Decree in divorce from the bonds of matrimony having been entered on the/7{/ day of 4MJ , 1996, hereby elects to retake and hereafter use her previous name of Linda L. Myers ._~~q~~~,~~ Signature - married n e) ~~""~ ~ 'n~/ ignature - to be kno as) STATE OF PENNSYL VANIA ss. COUNTY OF 1A : 11 On the /9 day of dp\.JU!___ , 1996, before, a Notary Public, personally appeared Linda L, Sledzinski, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. A'- '7&1 MfA...!'} fJ ,fiFaA. Notary Public NOT A"Al Sf~l lANA A. McOEAny. Notary Pv~.~it Camp Hill Boro. Cumbar:..",d Co.. flJ, My CommbJl'on [apl,.. Nov, a. 1 ~~;~ ~ i <;::.. ~- ~ ,,' '~ ......, ~ -,. 1'- M !',.;, J '. .. C'J .~:;-~ .~ .. , t1.1. ( 2:. E~: 1..' . ' 1.- ~'- . .~-- :::3 fl ~~; )~ ~~ ~ ~~ '-. ". S} . - ..,. ,1(:] ;1.J... " ; -, ~, ~-, . , ,