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HomeMy WebLinkAbout95-00930 g' ,'~ ...LJ.- .,~. . .. - a . E. ~ L; .-j " _1 ~ ] J ~. cY . o Z ..:.:.- .:.:. .:.:. -.:.:.' '.:.:. .:.:..:.:. ".:.:..:c- .:.:. .:c. .:+:. .:+:. .:.:..:.:. .:+:. .:.:. .:.:. .:+:- ':.:":-~~':.:'::':.X:-:':':.'.:.:.:~.:.>:.:.:.' ..:~.,:-:...,=:<C<'~ ,0, ......-......,-- .JI fir ~ ' , ~ ~ s , .. ~ IN THE COURT OF COMMON PLEAS $ ~ ci ~ ~ ~ OF CUMBERLAND COUNTY ~ ~ STATE OF rt~ PENNA, w ~.' a ~.~ ..:; ~ ~ ~.~ ,', ~ ~ ~ ~., w '.~ ,.' ~ w '.' N () ,~.?,-::~}q"S.I.v~,!:>".:r.J:;~.!'I199 5 ~~ ~ ,', ~ ;it ~.~ ~ .'~ ~ ~.; " ~ w '.' ~ ~ .'~ S :; ~ !.~ JUDITH A, FELDMAN, ",,,, ""...... II iI i 'I w '.~ Plaintiff a ~.' Vel"-itls 'I " .......... I :1 " " w ~.~ ""RONALD "e, "FELDMAN, . ~ ~ ',' .'; W ',' Defendant. w ~.' . DECREE IN DIVORCE AND NOW, .., d.~.. .tfi..., ......" 19 ,~?,.., it is ordered and decreed that"","""'" 'JUDITH, it" ,FELDMW""""""", plaintiff, and", .... ........ ,RONALD, ,~, ,fl',I,Q/:l{ll'l,................ ".., defendant, are divorced from the bonds of matrimony, ~.: ~ :.~ ~ ,~ " ~ :'; ,', ~ ;i; '.~ ~ >; ,', ~ ~ $ ~ .. ~ " ~ ~.' ~ ~ " ,', ~ i f!! w ~,f ~ ", ~.~ ~ 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; Wk ,l>!'!-7" ~,t,,,!~, ~,e,t; ~~!'!!l1E!I)~, M~!'!~,"1~t;I!:, ,t;C?, !l~, ,~t;I~P,r:1?9F?,t;~c:l, .i.1"! 1::9, ,t;lJ~, , , , , , , .~~ 'f?,r.c.e , D,ec.~:~,' . , , , , , , , , , , , . , . , , , . , , , , , , , , , , . , , /.. ,--:, , '> ' , , , , . , , , . , , . , , ~ ~.' ~ ',' ,', ~ ~ ',' s ~ ~ r.' ,', ~ ~ ',' Oy\ T.he ~~/rl: " \.J(/\ \M/ AU..,,'::'_ " ,'L,., = ~ J. ~:!(4...!,t1:r' t.. tUtil':.!( ,~r;-l't..~1.~I"t-"' ~ .' .,/]:?.; )1<1 // ,:;:;;?, ny~7 V , P"Rho"~y ~ ,', ~ ~ 0;0 ~ ',' ~ ,~ ... .' ~ " " ~ ~ ~--~ /~ ->>. ~ ~:. s .. ~ ~ . ".. .__,____.~_.. _" ~ , . .~ I ~ )__~~~~**_~_****ro*~'ro~*~. J ;t/'7f' chi ((7'} /;';/JI *' ,iIf ,{L:t'l.l!,dt.(. .5' t<r,/11{- ,r;tfwt ,~.;j}/1c, "iff ,~7j /02:.<" ~. . ... 1995, by MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this { 'J!-rday of ~h~, and between JUDITH A, FELDMAN, hereinafter referred to as "Wife", and RONALD C, FELDMAN, hereinafter referred to as "Husband, " WITNESSETH: WHEREAS, Wife and Husband were lawfully married on April 8, 1983; and - -. WHEREAS, certain differences arose between the part'.tils as r-. a result of which they separated on June 24, 1992, and now live '-- separate and apart from one another, and are desirous ofseftling ~ . <..0 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 past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; and in general the eettling of any and all claims and possible claims by one against the other or against their respective estates for equitable distribution of all marital property; and a resolution of all mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised ~~th~ir ~espective counsel, lA', ( (", (Initials) v Wife, by her attorney Edward J, 'j-11 ~1' (/ ,. '/ . . (Initials) ro Weintraub, Esquire, and Husband by his attornoy, M, Peter Harer, Esquire, have come to the following agreement, NOW THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: l, SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit, 2, INTERFERENeE: 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 nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried, r?,(.r-. 2 CJ -Ii 1 ():w> , ... ~, WIFE'S DEBTS: Wife represents and warrants to Husband that since June 24, 1992 she has not, and in the future, she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her, 4, HUSBAND'S DEBTS: Husband represents and warrants to Wife that since June 24, 1992, he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might , be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him, 5, OUTSTANDING JOINT DEBTS: Husband and Wife acknowledge and agree that they have no outstanding debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement, Each party agrees to pay the outstanding joint debts as set forth herein and further agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations, In the event that either party contracted or incurred any debts, other than those i1. C . f (Initials) specifically identified herein, since (Initials) 3 /)1/1' J June 14, 1992, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged, 6, MUTUAL RELEASE: Subject to the provisions of this Agreement, each party waives his or her right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce eode of 1980, Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or I herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement, Each party also waives his or her right to request marital counseling pursuant to 23 Pa,e,S,A, Section 3302, 7, EOUITABLE DISTRIBUTION: Upon execution of this Agreement and as equitable distribution Wife shall pay to Husband the sum of Two Thousand ($2000,00) [?, t,(- Dollars, (Initials) ~ ~,:;J- . (Initials) 4 A, eONTENTS OF HUSBAND'S RESIDENCE: Aa of the date of the execution of thia Agreement, Wife shall set over, transfer and asaign to Husband all of her right, title, claim and interest in and to the furniture, furnishings, fixtures, goods, appliances, equipment and personal items within Husband's residence, B. eONTENTS OF WIFE'S RESIDENeE: As of the date of the execution of this Agreement, Husband shall set over, transfer and assign to Wife all of his right, title, claim and interest in and to the furniture, I furnishings, fixtures, goods, appliances, equipment and personal items within Wife'S residence, e, MOTOR VEHIeLES: With respect to the motor vehicles owned by one or both of the parties, they agree that each shall have separate ownership of any vehicles now in the possession of either of them, All automobile insurance policies will reflect the ownership of each vehicle, D. INDIVIDUAL RETIREMENT AeeOUNTS, PENSIONS AND EMPLOYMENT BENEFITS: Both parties shall retain as their separate property, free and clear of all claims by the other, of their individual retirement accounts, pensions and all other benefits of em loyment. . r, r, (Initials) (Initials) 5 E, JOINT BANK AND eHARGE AeeOUNTS: All joint bank and charge accounts, credit card accounts and any other joint accounts shall be terminated and each party shall take those steps necessary to have the other removed as a responsible party from any such account, f, PROPERTY TO WIFE: The parties agree that Wife shall own, possess, and enjoy, free from any claims of Husband, the property awarded to her by the terms of this Agreement, Husband hereby quitclaims, assigns and conveys to Wife all such property together with any I insurance policies covering that property, and any escrow accounts relating to that property, This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife, G, PROPERTY TO HUSBAND: The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement, Wife hereby quitclaims, assigns and conveys to Husband all such property together with any insurance policies covering that property, and any escrow accounts relating to that property, This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property If,c,r (Initials) 6 . Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the waiver of alimony to by them are fair, adequate, and satisfactory and are based upon their actual need, their ability to pay, the duration of the parties' marriage and other relevant factors which have been taken into consideration by the parties, Although the approval of this Agreement by a court of competent jurisdiction in connection with this action in divorce or annulment filed by Wife shall be deemed an order of the court and may be enforced as provided in 12 Pa,e.S,A, Section 3701, as amended, this Agreement, insofar as it , pertains only to support and the payment of alimony following the entry of a final Decree in Divorce between the parties, may not be modified, suspended, terminated, or reinstated ~t the instance of request of the Wife or Husband, or subject to further order if any court upon changed circumstances of the Wife or Husband of a substantial or continuing nature, or for any reason claimed by either party whatsoever. Upon that condition, Husband and Wife hereby accept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for the support, maintenance or alimony, If. (, F, (Initials) t ~:; , (Initials) . 6 10. INeOME TAX RETURNS: The parties have heretofore filed joint federal and state tax returns, Both parties agree that in the evont any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith, Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the I cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns, ll, WAIVERS OF CLAIMS AGAINST ESTATES: 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 have 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, curtesy, statutory allowance, widow's allowance, right to take intestacy, right to take against the will of the other, and right to act as 7(' f Ii' " (Initials) administrator or e~ecutor of the other's ~(InitialS) " 9 estate, Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims and both parties will revoke prior wills or testamentary documents, l2, AGREEMENT NOT PREDIeATED ON DIVORCE: It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery I of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non- prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto, It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to execute this Agreement, jR,c.r (Initials) ""'b;jd ,1'~if' ..oh . . (Initials) 10 . knowingly and understandingly hereby waives any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole or in part, Husband and Wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement, l3, SUBSEQUENT DIVOReE: Wife at her cost by her eounsel will conclude the action for divorce under 3301 of the Divorce Code, Docketed in I Dauphin County, No, 95-930 eivil Term, Husband will consent to the jurisdiction of the eourt to enter a final Decree in Divorce and will indicate that all economic claims have been resolved. Both parties shall execute the necessary Affidavits and/or Counter-Affidavits to proceed and other documents required under 330l(c) or 330l(d) of the Divorce Code, In the event that such divorce action is concluded, the parties shall be bound by the terms of this Agreement which shall be incorporated by reference into the Divorce Decree, shall not be merged in such Decree, and shall not be modified, but shall in all respects survive the same and be further binding and conclusive upon the parties, This Agreement shall be incorporated for the purposes of enforcement only, tf(. (, r: 11 i~Ay 14', BREACH AND ENFOReEMENT: If either party breaches any provision of this Agreement, the other party shall have the right at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of legal I I I' fees and costs incurred by the other in enforcing his or her rights under this Agreement, A, It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in Equity, and the parties I hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said eourt on the ground that there is an adequate remedy at law, The,parties do not intend or purport hereby to improperly confer jurisdiction on a eourt in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of eourts in Equity over agreements such as this one, B, Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and in such eVjnt i: .0 . Cr. is specifically understood and (Initials) for and in (Initials) l2 , ' specific consideration of the other provisionu and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay, e, Each party further hereby agrees to pay and to save and hold harmless the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any way whatsoever, or shall pay upon, or in terms or provisions of this Agreement by reason of any of the terms or consequence of any default or breach by the other of any of the , terms or provisions of this Agreement by reason of which either party shall be obliged to retain on engage counsel to initiate or maintain or defend proceedings against the other at law or equity or both in any way whatsoever, provided that the party who seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or in part, before there would be any liability for attorney's fees and costs of litigation, It is the specific agreement and intent of the parties that a breaching or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or herself as well as the other party in endeavoring to protect and enforce his or her rights under this Agreement, d?rr (Initials) ~(InitialS) 13 '. ,. . . " l5, ADDITIONAL INSTRUMENT: Each of the parties shall from time to time, at the request of the other, oxecute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. l6, VOLUNTARY EXEeUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and I equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence, The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel, l7, ENTIRE AGREEMENT: This Agreement contai~s the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable aQd satisfactory to them /?,(,F. (Initials) ~) /) ,7" (Initials) tJ I l4 , .. , " .0,1 based on' th'e length of their marriage and other relevant factors which have been taken into consideration by the parties, Both parties hereby accept the provisions of this Agreement with respect to the 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 aga:nst the other for equitable distribution of their property by any court of competent jurisdiction pursuant to 23 Pa.C,S,A, Section 350l et, ~ or any other laws, Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing I herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement, lB. DIseLOSURE: Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, the sources and amount of the income of such party or every type whatsoever and of all other 'facts relating to the subject matter of this Agreement, 19, MODIFIeATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if .// C'. F, (Initials) writing and -1 "1.. (Initials) l5 '. .f t " , " .'.1 , executed with the same formality as this Agreement, The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, 20, PRIOR AGREEMENT: It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect, 2l, DESeRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only, They shall have no effect whatsoever in determining the rights or obligations of the parties, 22. INDEPENDENT SEPARATE eOVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement, 23, APPLIeABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, 26, VOID eLAUSES: If any term, condition, clause or provision of this Agreement kCF shall be determined or declared or invalid in ~}~~v\! I,' (Initials) (Initials) l6 '. .. . . .' I " ..' I,. .' , COMMONWEALTH OF PENNSYLVANIA eOUNTY OF 11 a..'O'~ ss. BEFORE ME, the undersigned authority, on this day personally appeared Judith A. Feldman known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and considerations therein expressed, I of GIVEN ~~ UNDER MY HAND AND SEAL OF OFFICE THIS 714 day , 1995, NOTARIAL SEAL JANICE L, GLENN, Notal'f Public Duncannon, P6111'/ J~r'i.'i,' 1998 My commission Exp r6S ' lB JUDITH A, FELDMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND eOUNTY, PENNSYLVANIA vs, NO, 95-930 eIVIL TERM RONALD e, FELDMAN, Defendant CIVIL ACTION - LAW IN DIVOReE PRAECIPE TO TRANSMIT REeORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the eourt for entry of a divorce decree: l, Ground for divorce: Irretrievable breakdown under I ) section 330llc) IX) Section 330l1D) of the Divorce eode, (eheck applicable section), 2, Date and manner of service of the eomplaint: Restricted Mail/Return Receipt Requested - Februarv 24, 1995. 3, eomplete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by section 330l(c) of the Divorce eode: By Plaintiff , By Defendant (b) (l) Date of execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce eode: February l6, 1995, (2) Date of filing of Plaintiff's Affidavit required by Section 330l(d): February 24, 1995, .. . , I i i ! i!; - I'..> 1'0.:' 1.0.. <oJ - .. ="t.: LO <..r1 .. . (2) Date of service of the Plaintiff's Affidavit upon the Defendant: Februarv 24, 1995, 4, Complete the following paragraphs: (a) Related claims pending: None, (b) Claims withdrawn: N/A, (c) elaims settled by agreement of the parties: N/A, (d) state whether any written agreement is to be incorporated into the Divorce Decree: Yes - Marital Settlement Agreement, If yes, attach a true and correct copy of the fully executed agreement to the proposed Decree that is submitted herewith, 5, I certify that the Notice of Intent to File Praecipe to Transmit as required by Rule 1920,42(e) was mailed on April 6th 1995, and a copy thereof is attached, I further certify that all other documents required by Rule 1920,42(C) are enclosed herewith, ~ Edward J, Weintraub, Esquire l30 Walnut Street Harrisburg, PA l7l0l (717) 238-2200 10#17441 eounsel For Plaintiff Date: 5/l/95 , ' ., '. LAW OFFICE EDWARD J. WEINTRAUB 130 WALNUT STREET HARRISBURG, PENNSYLVANIA 17101 , . (717) 238.2200 FAX (717) 238.9280 .. ". t, , . " \ , JUDITH A, FELDMAN, Plaintiff vs, IN THE eOURT OF eOMMON PLEAS eUMBERLAND eOUNTY, PENNSYLVANIA NO, 1!I il30 C!c (h...t JL~-I'y'\..... eIVIL ACTION .. LAW IN DIVOReE RONALD e, FELDMAN, Defendant NOTIeE TO DEFEND AND eLAIM RIGHTS YOU HAVE BEEN SUED IN eOURT, 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 eourt, 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, eumberland County eourthouse, 1 eourthouse Square, earlisle, Pennsylvania l70l3, IF YOU DO NOT FILE A eLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER I S FEES OR EXPENSES BEFORE A DIVOReE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO eLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONeE, IF YOU DO NOT HAVE A LAWYER OR eANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU eAN GET LEGAL HELP, COURT ADMINISTRATOR 4TH FLOOR .. eUMBERLAND eOUNTY eOURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA l70l3 (7l7) 240-6200 JUDITH A, FELDMAN, Plaintiff IN THE eOURT OF COMMON PLEAS eUMBERLAND eOUNTY, PENNSYLVANIA NO, eIVIL AeTION - LAW IN DIVOReE v~. RONALD e, FELDMAN, Defendant eOMPLAINT UNDER SECTION 330lldl OF THE DIVOReE eODE AND NOW comes Judith A, Feldman, by and through her attorney, Edward J, Weintraub, Esquire, who states the following in support of the within eomplaint: I l, Plaintiff is Judith A, Feldman, an adult individual whose address is 256 North Walnut Street, Rear, Lewistown, Mifflin County, Pennsylvania l7044, 2, Defendant is Ronald e, Feldman, an adult individual who. currently resides at Box 953, Mechanicsburg, eumberland eounty, Pennsylvania l7055, 3. Both the Plaintiff and the Defendant have been bona fide residents of the eommonwealth of Pennsylvania for a period of at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on April 8, 1983 in Hagerstown, Maryland, 5, There have been no prior actions for divorce or annulment of the marriage between the parties instituted by either of them in this or any other jurisdiction, 6, The marriage is irretrievably broken, ~ '. . '. JUDITH A, FELDMAN, Plaintiff IN THE COURT OF COMMON PLEAS eUMBERLAND eOUNTY, PENNSYLVANIA NO, vs, RONALD e, FELDMAN, Defendant CIVIL AeTION - LAW IN DIVOReE eOUNTER AFFIDAVIT UNDER SECTION 330l(d) OF THE DIVOReE eODE 1, Check either (a) or (b): (a) I do not oppose the entry of a divorce decree, ( ) (b) I oppooe the entry of a divorce decree because [eheck (i), (il), or both] (i) The parties to this action have not lived separate and apart for a period of at least two (three) years, ( (ii) The marriage is not irretrievably broken, ( 2. eheck either (a) or (b): , , (a) I do not wish to make any claims for economic relief, 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights, . I . " 11...l I verify that the statements made in this eounteraffidavit are true and correct, I understand that false statements herein are made subject to the penalties of lB Pa, e,s, Sec, 4904 relating to unsworn falsification to authorities, Ronald C, Feldman NOTIeE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this eounteraffidavit, (;) ~~~ -."" 1"\.. c-, ;- . - '(-\.J ~ C::s~ ("l'-:"J C"l .".""C....j "1 L: ";l~ -, __l1t'" i: JI.., ;" V....., ;I'rl ~< -, . r-:r. _ ~ f":J ....U..-" ,;O~';~' Z..-.Z(') i';'-~' 'tnl ;.~~ ..... -c .< - u:> U'1 N x.. ~ L 'f' ~ .., ...... ,...... ,-.. I...lv LN .......... c::::,..., 10- ~"St.- <->, C~ ':J\ V <'I ....... C.. C' , , & ... X- :>: l." ~ ' "... '.-) ." " ;u .. L.r, ;:::; ,,-, w ,. -0 .., :x: ... ..- T '. c..o ...... , JUDITH A, FELDMAN, IN THE eOURT OF eOMMON PLEAS plaintiff eUMBERLAND eOUNTY, PENNSYLVANIA vs, NO, 9y-'" 93iJ 01 'v,1 -- I t1,I..., RONALD e, FELDMAN, CIVIL ACTION - LAW Defendant IN DIVORCE COUNTER AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVOReE CODE \ 1, eheck either (a) or (b): (a) I do not oppose the entry of a divorce decree, (b) I oppose the entry of a divorce decree because [eheck (i), (ii), or both] (i) The parties to this action have not lived separate and apart for a period of at least two (three) years, ( ) (ii) The marriage is not irretrievably broken. ( ) (iii) The Defendant I s economic position will be prejudiced if a ~ 2, eheck either (a) or (b): bifurcated divorce is granted (~ (a) I do not wish to make any claims for economic relief, 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 ) I wish to claim economic relief which may include vr alimony, division of property, lawyer's fees or expenses or other important rights. ( (b) I verify that the statements made in this Counteraffidavit are true and correct, I understand that false statements herein are made subject to the penalties of lB Pa, e,s, See, 4904 relating to unsworn falsification to authorities. /) .,/ ' CiYLr1.J!..t- onald C, Feldman r? -/' - lCt.l'''-U'l. NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this eounteraffidavit, '. ,.. , .a . Compte,,, h.mI 1 .nd/o' 2 for additional HMe... 'I . Compll" Itlm. 3. and ... . b. i ,... Prlnt 'tour nlfnl .nd Iddrl" on the ,.....rt. of thl. form '0 thl, w. can "turn tN, Clfd to you. .. . AttICh thll form to Iht front 01 IhI mlllpltCl, Of on tht beck If 'P'C' , dotl not permit,. . I . Wrtta "R.tum R.celpt AItQUt.ted" un the mallPec, below the artieSt number 'ti . - n.. Return RectftJt wlllhow to whom thllrtlclt WI' d,IIY1M Ind thI dill 6..11'..'0<1, ' 'I 3, Artlcl. Addre...d lor " M.' Po'terHarer, Esquire ", 8l50'Derry Street, Sui te. A . ,Harrisburg, PA 17ll1-5260 I '.1.0 wish 10 rec.lv. thl following 1I",lcII (fa, .n exlre f"I' 1, 0 Add"...... Add".. 2. 0 R..trlct.d D.llv.,.,. Consult oltmaatet for 'ell. 4"'- A!li~I! Number ,P 147335 118' 4b, S'IVI Typ. o R. II.d .nlll.d o ExP'OII Mill 7, o In,u'~d OCDD , o R.turn Rec.lpt lor 8, , .' 1,' ~ U,8.O'P,0,"......7_ DOMESTIC RETURN RECEIPT P 147 335 118 ~ Receipt for . Certified Mail '. No In!>lJfilf1CI! Co...milllll P,OVltJ!HI ~ 00 nut tJ~IJ for tn!l!rllillfonal Mall ',~.'" ......1 tSPtl RU~IJf~t!1 M;' Peter Harer, Esq. .8150"Derry st. ,Suite Hbg; '17111-5260 $ ( 1,., 1'.11" '" , ,n .. ), I () ',< i -; ,'" T $ ':1 ," ':1 '00 '-';1 , ' " " Notice of Intent 'Il 'c I \J,I,.4'!h"j "l;":~~,.', ....,,~"'~ ~'~l , ' . .<\ ' . '!"hkl.'I'""",:", "."', LAWOFFlCE"", ~ .~\...w."~,,.! "J > f. ' , " . ... , -1" :.4.~ i~ ~ II '. .' t I ,'" . . ! ''i V ;0.."...<.., f' ,,\'~ '," ,-" " , ' ~ ' . ',\""'<1";.:; ".' ..','.: :.' ,." ";,EDn''''RD J WEINTRAUB "1";>;'1.:.. :'ii'l~F~""'I"'i."{':ll~: ,",' t. YW'I,.' . ~ v" ,. ." oJ-" ~\'F '\" ~ "I" . J ~ '". ~.,t"~\"\tt"".t'l'''(~ ~t. i.,~...,1 \r..., I ~{,"" 1 ' ".', .l" ' , 130 WALNUT STREET " "~lf~'~ ".:...'''tc''';'''~)' '7"" ." -'; l ' ., '".,. -. . ~~;1.~~~1l:.t;~~fq:li..~ "~~"\-' ;1'-' \~., :'< :p',,' .-I[ ," , ' ~,ll""'''I''~''.;:~7'1 ,~...\-., '.",,' '. I . HARRISB~~SVLVAN,^17101 "j"...k,s,,,rsv"l.: ,~l'"".'l,.;,.. . \ . i':"i:'."..\n?~,::":;", ?",':' :. .... , ." (717) 238,2200' . FAX (717) 238,9280 ..... ~r;\<~\l'};: li ,,.... ': ~ ';, '. . '. . ;''':;~i;-,X::\i~\;~~f:f,f~#.Y;~~~~i~~l . ..'! ;''i':';;,i';'''J:''?CI,\5;,.,~~~ . ..,..... ..........."",.........'..,., ';"'V"i"~ill\I ...." : .".....,..'...'..;;;::~;',;.:;;;~t,;~~~~iHi~~i~1~ VS, IN THE COURT OF eOMMON PLEAS eUMBERLAND eOUNTY, PENNSYLVANIA NO, 95-930 eIVIL TERM JUDITH A, FELDMAN, Plaintiff RONALD e, FELDMAN, Defendant IN DIVOReE eERTIFIeATE OF SERVIeE I, Edward J, Weintraub, Esquire, hereby certify that on the 6th day of April, , 1995, I served the Notice of Intention To Request Entry Of Divorce Decree, upon eounsel for Defendant M, Peter Harer, by eertified Mail/Return Receipt Requested, addressed as follows: M, Peter Harer, Esquire 8150 Derry Street, Suite A Harrisburg, PA l7lll-5260 q=1id. Edward J, Weintraub, Esquire l30 Walnut Street Harrisburg, PA l710l (717) 238-2200 eounsel for Plaintiff ,-;; ~ - ...;, --' ',' ,'~" -~ .:~ j I' ! .,t'": b. -" '"" -.J .r::.. g -." ~ <.0 <.r, '..... , .":;1'" ~" " ,~",\~r;'~~\~f0:;d\:it~,:>:','\'l;r~ri~';,n:::j,~.:,~W,OFFICE.. .', . "#C~."..,\f:"''.' "ct."",-j,~>.!. -""''''', "..." EDWARD J.WEINTRAUB ;~~~W~~?\f:f:!if';:'t~;,~..~~":~~,::!;::,.>;::.\'~ii: '.:'~~li~::~~;~~~~1;10i: .' r;";::'~it :;:;,:\:,:';:, ..' ":: ' '., (7171238-2200 .', FAx (717) 2~,9280 JUDITH A, FELDMAN, Plaintiff IN THE COURT OF eOMMON PLEAS eUMBERLAND COUNTY, PENNSYLVANIA NO, 95-930 eIVrr, 'I'ERM eIVIL AeTION - LAW IN DIVOReE vs, RONALD e, FELDMAN, Defendant eERTIFIeATE OF SERVIeE I, Edward J, Weintraub, Esquire, hereby certify that on the ~/f~ day of February, 1995, I served a true and correct copy of the Notice To The Defendant of Plaintiff's Affidavit and eounter Affidavit Under Section 330l(d) of the Divorce eode and eomplaint Under Section 330l(d) of the Divorce eode upon Ronald C. Feldman, Defendant, by depositing same in the United States Post Office, Harrisburg, Pennsylvania, Restricted Mail/Return Receipt requested, addressed as follows: Ronald e, Feldman Box 953 Mechanicsburg, PA l7055 -_.....--------- EDWARD J, WEINTRAUB, ESQUIRE l30 Walnut Street Harrisburg, PA l7l0l (717) 238-2200 ATTORNEY FOR PLAINTIFF f;Jit~~i;~iJ1W,~~,~;J\i:. ..~ . ,.C_. I '., t{J~:t'l'u;'t.;.\,,;!,~.,,\.,J.,..;,.,.; -i",; I~~B~~~"~ { .,,~_:.. '-.1 ~ ': ~~... .l,'.;' ,.,'~ . ~ '" ,:;;f ;~. -_I " '.- \~,~~ c:' ;:1 ," .;r. -"1 ..1.3:::; -II r~ 00 ~1 .r:.;:..",:~ .. ~,,~ ~. ~ ,., ~. J. -<'" .< ~ CO '" -.. N & \D -0 = . c.c U1 !~~i~;If:!t~1~~<': LAW. OFFICE , . . 'EDW\RDJ.,WEINrRAlJS' . . l~!:I'iUTS1REET, ". HARRISBURG, P~SVi.VANIA17101<. ,17171238,2200 '.FAX 1117) 238.9280 vs, IN THE eOURT OF eOMMON PLEAS eUMBERLAND COUNTY, PENNSYLVANIA NO, 95-930 eIVIL TERM JUDITH A, FELDMAN, Plaintiff RONALD e, FELDMAN, Defendant eIVIL ACTION - LAW IN DIVOReE AMENDED eOUNTER-AFFIDAVIT UNDER SEeTION 330l(d) OF THE DIVORCE CODE I wish to amend my eounter-Affidavit previously filed in this matter, 1. eheck either (a) or (b): (a) I do not oppose the entry of a divorce decree, (.I) (b) I oppose the entry of a divorce decree because [eheck (i), (ii), or both] (i) The parties to this action have not lived separate and apart for a period of at least two (three) years, ( ) (ii) The marriage is not irretrievably broken, ( ) 2, eheck either (a) or (b): (a) I do not wish to make any claims for economic relief, 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) (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. ( I verify that the statements made in this Amended eounter- Affidavit are true and correct, I understand that false Etatements herein are made subject to the penalties of lB Pa. C,S, Sec, 4904 relating to unsworn falsification to authorities, ,j) ,// IJ -I-: ~ /J{"'-1{I~( ,;j.{(!tt((t(1 ~6nald e, Feldman