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ROBINSON .'NO l,lIIV,U,o
AnoaNfY5 "N" '. '''NUUO.' '" I."..
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CFlIl.flll'rED lnUE
~NO CC).IlEC r COpy
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IN THE COURT OF COMMON
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The court retains jurisdiction of the following claims which have .
be.n raised of record in this action for which a final order has not yet .
been enter.d;
None. And that the terms, provisions, and conditions of a certain .
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,poJ',llted, ,into. .this. .Decree, and ,Ordor. by, ,refez;eJ\ce ,as, .f.ully, .as, t:hough .
the same were set forth herein at length. Said Agreement shall not 8
merge i h but shall survive this Decree and Order. .
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OF CUMBERLAND COUNTY
STATE OF *' PENNA.
LINDA K. JASTRON
N ().~~~S.,a.~'~H :.1.~~~H' 19
Vl\I'SlIM
JOHN C. JASTRON
I,
P
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DECREE IN
DIVORCE
AND NOW, . , '" . , '1~~. , , , .l.f':. . , , " '. 19, ,9,S. " it is ordered and
decr.ed that ,,~~.I'\ql,l, !<.', ,~!l~.t;:r;Q\'I""".....,."..".",.",.,. plaintiff,
and "J?~,~ ,C:: 7 . ,~~s ~;r,~~ . . , . , . . . , , , , . . . , . . , , . , , , , , , , . . , , . . . , " def.ndant"
are divorced from the bonds of matrimony.
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MARRIAGE SETTLEMENT AGREEME~T
THIS AGREEMENT, made this ~ day of O~}-ObM~- 1994,
by and between LINDA ~. JASTRON, of Mechanic.burg, Cumberland
Count.y, penn.yl vania, hereinafter referred to a. "Wi fe," and
JOHN C. JASTRON, of Mechanic.burg, Cumberland County,
P.nn.ylv.nia, hereinaft.er referred t.o as "Husband."
WIT N E SSE T H:
WHEREAS, Husband and Wife were lawfully married on July 18,
19U; and
WHEREAS, difference. have ari.en between Hu.band and Wife
in con.equenc. of which they intend to live .eparate and apert
of each otherl and
WHEREAS, Husband and Wife have made a full disclosure of
their ....t. to each otherl and
WHEREAS, Husband and Wife de. ire to settle and determine
their right. and obligations with respect to each other,
including the disposition and dist.ribution of property rights
end int.r..t. between them.
NOW, THEREFORE, in consideratIon of the mutual promiaes,
covenant. and undertakings hereinafter set forth and for oth.r
good and valuable con.ideration, receipt of which i8 hereby
.cknowledg~d by each of the Partie. hereto, Wife .nd Huaband,
. .
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.ach intending to be legally bound hereby, covenant and agre. .1
follow. I
1. SEPARATION. It shall be lawful for each Party
at all time. hereafter to continue to live separate and apart
from the other Party at .uch places a. he or .he may from time
to time choose or deem fit. The foregoing provi.ions shall not
be taken as an admission on the part of either Party of the
lawfulne.. or unlawfulne.s of the cau.e. leading to their living
apart.
2. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE.
The Partie. agree that the term. of this Agreement shall be
incorporated into any Divorce Decree which may be entered with
r..pect to them at the request of either party. The Partie.
agree that the Court of Common Pleas of Cumberland County,
Pennlylvania, shall retain continuing jurisdiction over the
Parties and the Agreement for the purposes of enforcement of any
of the provisions thereof.
The Parties agree that unless otherwi.e specifically
provided herein, if . Decree is entered divorcing the parties,
although thl. Agreement shall be incorporated into laid Decree.
this Agreement shall not merge with, but Bhall continue in full
force and effect after .uch time as a Final Decree in Divorce
may be entered with respect to the Parties and may be enforced
in an action independent of the Divorce Decree. The Partie.
agree and it is the intent of each of them that even though thil
Agreement may be enforced either under the provisionB of the
Pennsylvania Divorce Code or in an action independent of the
. .
.
Divorce Decre. in accordanc. with Section 3502 of the
penn.ylvania Divorc. Cod., the provisions of this Agre.ment
ragarding the disposition of .xisting property rights and
interests betw.en the Parties, .limony, alimony pendent. lite,
coun..l fe.s and expenses shall not be subject to modification
by any Court.
3. SUBSEQUENT DIVORCE:. Th. Parties h.r.by
acknowl.dge and .xpress th.ir .greem.nt that the marriage i.
irretri.vably brok.n, and the parti.s agr.e to cooperate in any
n.c....ry way to obtain. mutual cons.nt, no-f.ult divorc.,
pursuant to S.ction 330l(c) of the Pennsylvania Divorc. Cod..
4. INTERFERENCE. Each Party shall be fr.e from
interference, authority, and contact by the oth.r, .s fully ft.
if h. or she w.r. single .nd unmarried, except as m.y be
n.cess.ry to c.rry out the provisions of this Agreement.
N.ith.r Party sh.ll molest the other or attempt to molest the
oth.r, nor comp.l the other to cohabit with the other, or in any
way h.rass or malign the oth.r, nor in any way interf.r. with
the p.aceful existence, separ.te and apart from the oth.r.
5. ~IFE'S DEBTS. Wife represents and w.rr.nt. to
Hu.b.nd that she will not contr.ct or incur any debt or
liability for which Husband or his estate might b. responsibla
and .he .hall ind.mnify and s.v. harmle.. Hu.band from any and
all claims or demands mad. against him by r.ason of debt. or
obligations incurr.d by her.
6. HUSBAND'S DEBTS. Husband r.pre..nts and
warrant. to Wife that he will not contract or incur any debt. or
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liability for which Wife or her estate might be re.ponsible, and
he ahall indemnify and save harmle.. Wife from any and all
claim. or demands made against her by rea.on of debt. or
obligations incurred by him.
7. MARITAL DEBTS. With respect to the debt.
incurred during the marriage, Husband shall a..ume .ole repayment
re.ponsibility of the VISA bill in the approximate amount of
four-thousand ($4,000.00) dollars and shall indemnify and hold
Wife harmless for any claim made against her relative to this
debt. Wife .hall assume .old repayment responsibility of the
Lowe's Bill in the approximate amount of one-thousand
five-hundred ($1,500.00) dollars and shall indemnify and hold
Hu.band harmles. for any claim made against him relative to this
debt.
8. MUTUAL RELEASE. Subject to the provisions of
this Agreemont, each Party has released and discharged, and by
this Agreement, does for himself or herself, and his or her
heirs, legal representatives, executors, administrator. and
.s.igns, release and discharge the other of and from all cause.
of action, claims, rights, or demands, whatsoever in law or
equity, which either of the Parties had or now has against the
other, except for any and all cau.es of action for divorce and
except for any and all causes of action for breach of any
proviaions of this Agreement.
g. DISCLOSURE or PROPERTY. Husband and Wife
acknowledge and agree that they have made a full and complete
disclo.ure to the other of all information pertaining to the
.
.
Partie.' .eparate and marital property owned, po......d and/or
controlled by the other at the time of the .eparation of the
Partie. and, furth.r, that the Hu.band and Wife voluntarily and
intelligently agree to waiv. any right. which th.y may have to
rec.iv. an Inv.ntory and Apprai..m.nt of all prop.rty owned or
po......d by them, .ither jointly or individually, at the time
of the deliv.ry of thi. Agr..ment or of the comm.nc.m.nt of any
action of divorce.
10. EOUITABLE DISTRIBUTION. Husband and Wife
acknowledge and agree that the provi.ion. of thi. Agreement with
re.pect to the di.tribution and divi.ion of marital and .eparat.
prop.rty are fair, .quitable and sati.factory to th.m ba.ed on
the length of their marriage and other relevant factor. that
have be.n taken into con.ideration by the Parties.
(a). RIAL PROPERTY. The Parties acknowledge that
they jointly rent the property at 212 South York Street,
Mechanic.burg, Cumberland County, Pennsylvania. Pur.uant to the
current Protection from Abuse Order, Hu.band is excluded from
the.. pr.mi.es for a period of one (1) year. Even upon the
expiration of that one (1) year, Husband agrees that Wife and
her children shall solely remain in said premise.. Further, the
Partie. .hall cooperate in all necessary re.pects to allow Wife
to ex.cute a lease wherein she is the sol. l...ee. Wife agr...
to timely pay all utilities, repairs and improvement. a..ociated
with the upkeep of the rented property and shall indemnify and
.ave Hu.band harmle.. from any and all claim. or d.mands mad.
again.t him.
,
(b), PERSONAL fROPERTY. The Partie. have divided
between them.elve., to their mutual satisfaction, all item. of
tangible, perlonal property previously u..d by them in the
.arital home. Specifically, the woodshop tool., hardware and
lumber shall become Husband's possessions. The hand-made item.
.uch a. the kitchen cabinets (rose and tall) shall become
Hu.band's po.sessions. Additionally, Husband ohall be given the
oak clock, the oriental rug, the bar stools and the restaurant
dish~. and pots and pans. The living room VCR and TV, and bike
Ihall also become Husband's property. Husband shall also have
possession of the items that were given to him by hio father,
including but not limited to the set of crockB, copper boiler,
violin and accordion, Husband shall have pos.ession of the
mirrors in the bedroom (stand up and wall) as well as the wine
collection, wine rack, and cast iron bell. Wife shall retain
the two (2) hand-made double-door cabinets (kitchen and linen),
the butcher block and the bed, All other items of personal party
have been divided to the mutual satisfaction of the parties,
Neither Party shall make any claim to any Buch item of tangible
personal property whether said items are marital property or
laid items are separate perBonal property of either Party.
(c). MOTOR VEHICLES. With respect to the vehicles
owned by the Parties, the Honda shall become the Bole and
exclulive property of Wife, which title shall be transferred to
her by Husband contemporaneously with the .igning of this
,
Avreement. The van, shall become the sole and exclulive property
of Huaband, which title shall be transferred to him by Wife
contemporaneously with the ligning of this Agreement.
(d). EMPLOYMENT-RELATED BENEFITS. With regard to
e.ployment, each party hereto waives any interest they may have
in the other's retirement, peneion or other employment-related
beneUtI.
(e). CHECKING AND SAVINGS ACCOUNTS. With regard
to checking and savings accounts, each party hereto waives any
interest they may have in the other's personal checking and
.avings accounts.
Both Parties hereby accept the provisions of this Agreement
with respect to division of property in lieu of and in full and
final settlement and satisfaction of all claims and demands that
they may now have or hereafter have against the other for the
equitable distribution of their property by any Court of
competent jurisdiction pursuant to Section 3502 of the Divorce
Code or any other laws. Husband and Wife voluntarily and
intelligently waive and relinquish any rights to seek a
Court-ordered determination and distribution of marital
property, but nothing herein shall constitute a waiver by either
Party of any right. to seek their relief of any Court for the
purpose of enforcing the provisions of this Agreement.
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11. ALIMONY, ALI~ONY PENDENTE LITE, COUNSEL PEES AND
EXPENSES. Both Partie. accept the provisions of thia
Agreement in lieu of and as full and final settlement and
aati.faction of all claims snd demands that they may now or
hereafter have against the other for alimony, alimony pendente
lite, counsel fees or expenses, or for any other proviaion for
support and maintenance before, during or after the commencement
of any proceedings for the divorce or annulment between the
Parties. With regard to employment, each of the Parties hereto
waive any interest they may have in the other's retirement,
pension, or other ~mployment-related benefits.
12. WAIVER or CLAIMS AGAINS~ ESTATE. Except as
herein otherwise provided, each Party may dispose of his or her
property in any way, and each Party hereby waives and
relinquishes any and all rights he or she may now or hereafter
acquire, under the present or future laws of any jurisdiction,
to share in the property or the estate of the other as a result
of the marital relationship, including, without limitation,
dower, courte.y, statutory allowance, widows allowance, right to
take property under equitable distribution, right to take in
intestacy, right to take against the will of the other'. estate,
and who will, at the request of the other, execute, acknowledge
and deliver any ~nd all instruments which may be neceseary or
adviaable to carry into effect this mutual waiver and
relinquiahment of all such intereete, rights and claim..
,
.
13. BREACH. If either Party breaches any
provi.ion of this Agreement, the other Party .hall have the
right, at hi. or her election, to lue for damage. for auch
breach or .eek such other remediea or relief as may be advi.able
to him or her, and the party breaching this Contract .hould be
re.ponsible for payment of legal fees and cost. incurred by the
other in enforcing their rights under this Agreement.
14. ENTIRE AGREEMENT. This Agreement contain. the
entire understanding of the Partiel and there are no
representations, warranties, covenants or undertakingl other
than those expressly set forth herein.
15. MODIFICATION AND WAIV~R. The modification or
waiver of any of the provilionl of this Agreement shall be
effective only if made in writing and executed with the sam.
formality al this Agreement. The failure of either Party to
insist upon strict performance of any of the provisions of thi.
Agreement shall not be construed al a waiver of any .ub.equent
default of the eame or similar nature.
16. DESCRIPTIVE HEADINGS. The descriptive
heading. u.ed herein are for con~enience only. They shall have
no effect whatsoever in determining the rights or obligation. of
the Partie..
17. INDEPENDE~T SEPARATE COVENANT. It i.
.pecifically underltood and agreed by and between the Parti..
hereto that each paragraph hereof shall be deemed to be a
.eparate and independent covenant and agreement.
.
LINDA K. JASTRON, I IN THE COURT or COMMON PLIAS
I CUMBERLAND COUNTY, PINNSYLVANIA
Plaintiff , I
v.. I
I NO. 94-5864 Civil Tera
I
JOHN C. JASTRON, I
I
Defendant. I CIVIL ACTION - LAW 1M DIVORCI
PRAECIP~ TO TRANSMIT RECORD
To the Prothonotary I
Tran.mit the record, together with the following inforaation, to
the court for entry of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of .ervice of the Complaint I peraonal,
hand-delivery on October 13, 1994.
3. Date of execution of the Affidavit of Con.ent requirad by
Section 3301(c) of the Divorce Code: by Plaintiff on January 17,
1995, by Defendant on January 17, 1995.
4. There are no related claim. pending.
Re.pectfully Submitted,
BY~~
Gerald S. Robinaon, laquire
ROBINSON . GERALDO
Attorney I.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrllburg, Pennay1vania 17110-5320
P17) 232-8525
Attorney for PlainUff
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ROlJlN"ON ANh Of.RAlIJO
Ar,r(l.N~n ANIl cA.'~t IU ,*"
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LINDA K. JASTRON,
vs.
Plaintiff,
I IN THE COURT OF COMMON 'LEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
: NO. qtj - S<!tutf ~~
I
JOHN C. JASTRON, I
I
Defendant. CIVIL ACTION - LAW IN DIVORCE
NOTICE TO 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 caa. may
proceed without you and a decree of divorce or annulment may b.
entered against you by the Court. A judgment may alao be entered
against IOU for any other claim or relief requested in theae paper a
by the P aintiff. You may lose money or property or other righta
important to you, including custody or visitation of your children.
When the ground for the divorce is indignitiea or irr.etrievabl.
breakdown of the marriage, you may request marrJ,Age counseUng. A
.liat of marriage counaelors is available in the Office of the
prothonotarr at the Cumberland County Courthouse, High and Hanover
Street, Car isle, 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 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 LAWYER REFERRAL SERVICE
Court Administrator's Office
Cumberland County Courthouse, 4th Floor
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
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LINDA K. JASTRON,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.
JOHN C. JASTRON,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I--DIVORCE UNDER SECTION 330llCl OF THE DIVORCE CODE
1. Plaintiff i. LINDA K. JASTRON, who currently re.ides at 212
South York Street, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant i8 JOHN C. JASTRON, whose last known address was
212 South York Street, Mechanicsburg, Cumb~rland County, Pennsylvania.
3. Plaintiff has been a bona fide resident in the Commonwealth
for at least six (6) months immediately previous to the filing of thi.
Complaint.
4. The Plaintiff and Defendant were married on July 18, 1991 in
Maryland.
5. There have been no prior actions of divorce or for annulment
between the Parties.
6. The marriage is irretrievably broken.
7. Neither Party is a member of the Armed Forces of the United
States or any of its alli$8.
8. The Plaintiff ha. been advised of the ava~lability of
counseling and that either Party may compel the other by Order of
Court to attend counseling sesslon..
WHEREFORE, Plaintiff respectfully reque.t. that your Honorable
Court enter a Decree in Divorce under Section 330l(c) of the Divorce
Code.
COUNT II..EQUITABLE DISTRIBUTION
9. The Plaintiff incorporates by reference Paragraph. 1 through
8 of the Complaint for Divorce as fully set forth herein.
10. During the marriage, Plaintiff and Defendant have acquired
variou. items of marital property, which are subject to equitable
distribution under Section 3502 of the Pennsylvania Divorce Code of
1980, as will be fully set forth in the Plaintiff's Inventory and
Apprai.ement to be filed pursuant to the Pennsylvania Rule. of Civil
Procedure.
11. Plaintiff and Defendant have been unable to agree a. to an
equitable division of marital property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably
divide all marital property.
Respectfully submitted,
:I. ,
RO INSON AND GERALDQ
4407 North Front Stre.t
P.O. BOll 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney I.D. .27423
Att~rney for Plaintiff
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~OtllNlON AND O-'\~~INAL
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C~ATIFIIiD TRUE
AN..CORREcr C~
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LINDA~. JASTRON,
I IN THE COURT or CoMMON PLIAS
I CUMBERLAND COUNTY, PENNSYLVANIA
Plalntiff, I
I
I NO. 94-3864 Clvl1 Term
I
I
I
vs.
JOHN C. JASTRON,
CIVIL ACTION - LAW IN DIVORCI
Defendant.
PROOF OF SERVICE
1, Gerald S. Robinson, Attorney for Plaintlff, do hereby
that on the 13th day of october 1994, a true and correct copy
certl fy
of the
Plalntlff's complaint for Dlvorce under sectlon 3301(C) of the
code was served on the follow1n9 lndlvidual by hand-dellvery.
of service ls evidenced by "Exhiblt one" (attached).
Divorce
proof
John C. Jastron
4407 North Front street
Harrisburg, pennsylvanla 17110
Respectfully submitted,
By
~ra . n
ROBINSON . GERALDO
Attorney I.D. No. 37433
4407 North Front Street
P.O. Box 5330
Harrlsburg, pennsylvania 11110-5330
(117) 332-8535
Attorney for Plaintiff
oatedl
october 14, 1994
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, . .
. . ,
LINDA K. JASTRON,
v..
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PINNSYLVANIA
Plaintiff, I
I
I NO. 94-5864 Civil Term
I
JOHN C. JASTRON,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
A~~F~g~~i~T~~I~~~~~~I~cgG~~:~~NG
1. A Complaint in Divorce under Section 330l(C) of the Divorce
Code was filed on the 13th day of October 1994.
2. Defendant acknowledges that service of the Complaint was mad.
by personal hand-delivery on the 13th day of October 1994.
3. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
Complaint.
4. I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in coun8eling. Being 80 advis.d, I
do not requeat that the Court require counseling prior to a Divorce
Deere. being handed down by the Court.
5. I consent to the entry of a Final Decree of Divorce.
6. I understand that if a claim for alimony, alimony pendente
lite, marital property or counsel fees or expenses haa not b.en filed
with the Court before the entry of a Final Decree in Divorce, the
right to claim any of them will be lost.
I i I" '.""p.~
....
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I verify that the atatement. made in thi. Affidavit ar. true and
correct. I under.tand that fal.. .tatement. herein are made .ubject
to the penaltie. of 18 Pa. C.S. Section 4904, relating to un.worn
fal.ification to authoritie..
Dated I
01/17/95
~c~
John C. Ja.tron, Derendant