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HomeMy WebLinkAbout02-4391KARA K. GRIFFITHS, Plaintiff V. LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No: a L/ : Civil Action - Law : Divorce NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief or property or other rights important to you, including custody or visitation or your children. When the ground for 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, Dauphin County Courthouse, Harrisburg, 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 717-249-3166 ItAliA K. GRIFFITHS, Plaintiff LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO: : Civil Action - Law : Divorce COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Kara K. Griffiths, by her attorney, Kathy M. Shughart, and files this Complaint, based upon the following: 1. Plaintiff, Kara K. Griffiths, born December 12, 1973, is an adult individual and national of the United States of America, who currently temporarily resides at 412 Iroquois Street, Emmaus, Lehigh County, Pennsylvania 2. Defendant, Leonard R. Griffiths, born January 11, 1971, is an adult individual and national of the United States of America, whose last known address is 28 Watson Drive, Carlisle, Cumberland County, Pennsylvania. Plaintiff and Defendant were married on April 19, 1996 in Las Vegas, Nevada. 4. 5. There are no children of this marriage. Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 6. There are no pending actions in divorce or annulment in this jurisdiction or in any other jurisdiction brought by either Plaintiff or Defendant above-named. 7. Neither Plaintiff nor Defendant is presently a member of the Armed Forces on active duty. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken. 10. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 10. Plaintiff avers that Defendant has offered such indignities to the person of the Plaintiff so as to render Plaintiff's condition intolerable and Plaintiff's life burdensome. WHEREFORE, Plaintiffrequests your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT 2 - EQUITABLE DISTRIBUTION 12. Plaintiff incorporates by reference herein Paragraphs 1 through 11. 13. Plaintiff and Defendant have acquired property, both real and personal during their marriage from April 19, 1996 to the date of the filing of this Complaint in Divorce. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. ully submitted, Attorney for Plaintiff P.O. Box 6315 27 South Arlene Street Harrisburg, PA 17112-0315 (717) 540-8511 Supreme Court #39779 KARA K. GRIFFITHS, Plaintiff V. LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: : Civil Action - Law : Divorce KARA K. GRIFFITHS, Plaintiff V. LEONARD R. GRIFFITHS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: Civil Action - Law Divorce VERIFICATION I verify that the statements made in this Complaint in Divorce 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. IC)tR~ K~ ~'RI~FITHS, Plaintiff KARA K. GRIFFITHS, Plaintiff VS. LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4391 CIVIL : : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICF, I, Kathy M. Shughart, Esquire, hereby certify that a true and correct copy of the Complaint for Divorce was served on the Defendant by certified mail, restricted delivery, return receipt requested, on September 27, 2002, at the Defendant's last known address off Leonard R. Griffiths 28 Watson Drive Carlisle, PA 17013 Sworn to and subscribed before me this '-I ~4, day of C)c4-c-,~ e F ,2002. The return receipt card is attached hereto as Exhibit "A'. './ ~ gath9 M. S} u hm, 27 S. Arlene Street P.O. Box 6315 Harrisburg, PA 17112-0315 (717) 545-8511 Attorney for Plaintiff Notary Public Q~ NOTARIAL SEAL MELISSA A. POLING, Notary Public Lower Paxton Twp., Dauphin Coaaly My Commission Expires Sept. 1,2003 · C°mplele items 1, 2, and 3. Also con~® item 4 if Restricted De#very is desired. · Prfnt your name ar~ address on the reverse so that we can return the card to you. · Attach this card to the back of the mailplece, or on the front if space permits. LEONARD R GRIFFITHS 28 WATSON DRIVE CARLISLE PA 17013 RESTRICTED *DELIVERY 2, Article Number ~"ar~ f,~,, se,~,~,,/abe0 7000 0600 PS Form 3811, August 2001 Domestic Return Receipt - -'3~9- ' ---'Y ~'~;"~' G;"~m"t from item 17 if YES, ent~ de~,ve~ addrms below: [] No g Reglst~sd r'l Return Rec~pt for Merchandise In~l Mall 0028 3366 9778 EXHIBIT "A" KARA K. GRIFFITHS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 02-4391 CIVIL TERM : LEONARD R. GRIFFITHS,: CIVIL ACTION - LAW Defendant : IN DIVORCE PETITION TO WITHDRAW AS COUNSEL Kathy M. Shughart, Esquire, counsel of record for I<~RA K. GRIFFITHS, Plaintiff in the above-captioned matter, petitions the Court lo withdraw as counsel and in support thereof avers as follows: 1. The Plaintiffin the above-captioned matter is KARA K. GRIFFITHS, an adult individual residing at 412 Iroquois Street, Emmaus, Lehigh County, Pennsylvania. 2. The Defendant in the above-captioned matter, LEONARD R. GRIFFITHS, is represented by Gregory J. Katshir, Esquire. 3. Petitioner is Kathy M. Shughart, Esquire, counsel of record for Plaintiff, KARA K. GRIFFITHS. 4. Plaintiff notified Counsel that she would be retaining new counsel, and on or about June 19, 2003, the Plaimiffpicked up her file and signed a Release terminating the attorney/client relationship with Kathy M. Shughart, Esquire. A copy of said Release is attached hereto and incorporated by reference herein as "Exhibit A". 6. to continue. To date, an appearance has not been entered by new counsel. Neither Plaintiff nor Petitioner desires for the attorney--client relationship WHEREFORE, Kathy M. Shughart, Esquire, respectfully requests this Honorable Court to issue a Rule upon Defendant, KARA K. GRIFFITHS, to show cause why Kathy M. Shughart, Esquire, should not be permitted to withdraw as counsel. Respectfully submitted, · Shughart, Esqui~ I.D. No. 39779 27 South Arlene Street P.O. Box 6315 Harrisburg, PA 17112 (717) 540-8511 RELEASE I, Kara Griffiths, hereby acknowledge that I have received my entire file from Kathy M. Shughart, Esquire, this day of June, 2003. Further, I hereby confirm that I wish to terminate the attorney/client relationship with Kathy M. Shughart, Esquire. "EXHIBIT VERIFICATION I, Kathy M. Shughart, Esquire, verify that the statements made in this Petition to Withdraw as Counsel are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. 4904 relating to unswom falsification to authorities. · SHUGHART, ESQUIRE 2O03 KARA K. GRIFFITHS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 02-4391 CIVIL TERM : LEONARD R. GRIFFITHS,: CIVIL ACTION - LAW Defendant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this /4 day of 5/~O-~u~ ~, 2003, upon consideration of the attached PetiIion to Withdrg.w assCou~.~el, a Rule is issued upon, Plaintiff, KAPOk K. GRIFFITHS, to show cause why Kathy M. Shughart, Esquire, should not be permitted to withdraw as counsel. RULE RETURNABLE ~.O DAYS FROM SERVICE. BY THE COURT: Jo ~ K. GRIFFITHS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVAN/A v. : NO. 02-4391 CIVIL TERM _. LEONARD R. GRIFFITHS,: CML ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this 17th day of November, 2:003, a tree and correct copy of the Petition to Withdraw as Counsel was served on the following person by United States Mail, postage prepaid, addressed as follows: Kara K. Griffiths 412 Iroquois Street Emmaus, PA 18049 Gregory J. Katshir, Esquire 900 Market Streeet Lemoyne, PA 17043 Respectfully submitted, K th , I.D. No. 39779 27 South Arlene Street P.O. Box 6315 Harrisburg, PA 17112-0315 (717) 540-8511 PROPERTY SETTLEMENT AGP~EMENT THIS AGREEMENT made and entered into this /J~ day of ~~~1, 2003, by and between LEONARD R. GRIFFITHS of the County of Cumberland, Commonwealth of Pennsylvania (hereinafter referred to as "Husband"), a n d KARA K. GRIFFITHS of the County Pennsylvania of Lehigh, (hereinafter referred to as "Wife"). Commonwealth of WITNESSETH: WHEREAS, the parties were married on April 19, 1996 in Las Vegas, Clark County, Nevada; and WHEREAS, certain differences have arisen between the parties and as a consequence thereof, they have chosen to live separate and and determine and related items, and set forth in the within apart; and WHEREAS, the Husband and Wife desire to settle matters of support, property settlement, also other matters that are more fully Agreement. NOW THEREFORE, in consideration of the promises, mutual covenants, and agreements hereinafter set forth, the parties hereto covenant, promise and agree with one another as follows: 1. Husband relinquishes his inchoate intestate rights in and estate of the Wife and the Wife on her part relinquishes her to the inchoate intestate rights in and to the estate of her Husband, and each of the parties hereto by these presents, for himself and herself, his or her heirs, executors, administrators or assigns, does remise, release, quitclaim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, of any and all claims or demands, damages, actions, be they civil or criminal, causes of action, or suits at law or in equity, of whatever kind of nature for or because of any matter or thing done, committed or suffered to be done by said other party prior to and including the date thereof, except that this release shall in no way affect any cause of action in absolute divorce which the Wife or Husband may contemplate against each other, nor shall this complete and final release in any way mitigate against acquire estate, 2, either of the parties hereto filing suit against the other in equity or at law enforce any right or covenant incorporated in this Agreement. Each of the parties further renounces and relinquishes any and all claims and rights that he or she may have or hereafter to act as executor or admi~istrator of the other party's unless such party shall specifically designate otherwise. It shall be lawful for the Husband and the Wife at all 2 times hereafter live separate and apart from each other and to reside from time to time at such plaoe or places as they deem fit, free from all restraint or interference, either direct or indirect, by each other. Neither party shall molest the other or compel the other to cohabit, dwell with, or support the other party by any legal proceeding. 3. SUPPORT, ALIMONY, ALIMONY PENDENTE LITE: Both parties waive and relinquish any claim for, or right to, or interest in any Order of alimony, alimony pendente lite, spousal supporE, or the like, from the other party. This provision, for the full and complete waiver of alimony, alimony pendente lite, spousal support or similar payment, is not modifiable by any Court, even if there should be a change in circumstances for the parties. 4. REAL PROPERTY: It is noted that the parties were joint owners of certain real estate known and identified as Watson Drive, real property the 28 Carlisle, and have amount of $25.200.29. Pennsylvania. The parties have sold said realized ~oceeds. from the sale in the Said funds have been placed in and escrow account. Upon the execution of this Agreement, distributions from the escrow account shall be as follows: To Husband: $14,284.07 To Wife: $6863.18 To Providian towards the debt at account number 800-922-5000: $1,215.72 (This payment represents payment in full) To Citizens Bank towards the debt at account number 800-922- 9999: $1,952.99 (This payment represents payment in full) To MBNA towards the debt at account number 4313-0876-5300- 8038: $884.33. 5. MOTOR VEHICLE: The 2001 Dodge Stratus currently titled in the Wife's name, shall remain as the sole and exclusive property of the Wife. The Husband does waive and relinquish any and all claims to or against said vehicles. Wife shall be responsible for any debt associated with said vehicle. o Walter & Jackson. a Verizon Savings PENSIONS: Husband is the owner of a 401(k) plan with Wife is the owner of a Verizon Benefit Plan and Plan. Husband relinquishes any right, title or interest he may have in said Plans of Wife. Wife relinquishes any right, title or interest in said Plan of Husband. Husband shall retain the entire balance in his Plan. Wife shall retain the balance in her Plans. Husband and Wife agree to execute any and all documents that may be necessary or required in order to relinquish his or her interest in the other parties Plan. 7. PERSONAL PROPERTY: Each party shall retain as their sole and separate property all household goods, furniture and furnishings, and own personal effects, now in possession of the respective parties. Each party acknowledges that the items of personalty and household goods and furnishings have been distributed to the satisfaction of the parties. It is specifically noted that this includes their clothing, jewelry, and other purely personal effects. Additionally, joint bank account held by the divided between the two. 8. FUTURE DEBT: each party acknowledges that any parties has been satisfactorily Each of the parties hereto covenants and agrees that they incur or contract which either of property or their forth in this Agreement; have not or will not at any time in the future any debt, charge or liability whatsoever for them, their legal representatives, or their estate may become liable, other than those set and each of them further covenants at all times to keep the other free, harmless and indemnified of and from all debts, charges and liabilities hereafter contracted by them. 9. JOINT MARITAL DEBT: Husband agrees to assume, be exclusively responsible, and hold Wife harmless for the payment in full of the following debts: 1. MBNA account number 4800-1218-3210-5710 2. MBNA account number 4313-0876-5300-8038 (Debt remaining after the $906.00 payment as set forth above in Paragraph 4) Wife agrees to assume, be exclusively responsible, and hold Husband harmless for the payment in full of the following debts: 1. MBNA account number 4313-0814-9700-0673 Each party shall be responsible for any other debt that he or 5 she has individually incurred. he or she has, since the date liability for which the other agrees that he Each party represents that neither of separation, incurred any debt or might be responsible. Each party or she will indemnify and hold the other harmless from any and all claims made against the other by reason of debts or obligations of him or her. 10. COUNSEL: It is acknowledged that Husband has received independent legal advice from his counsel, Gregory J. Katshir, Esquire and Wife has received independent legal advice from John J. Connelly, Jr., Esquire. It is agreed that each party understands the legal impact of this Agreement and acknowledges that the Agreement is fair and reasonable and that each party intends to be legally bound by the terms hereof. 11. VOLUNTARY EXECUTION: Each party acknowledges that he or she fully understands the facts and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily and that the execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 12. DIVORCE: The parties acknowledge that Wife has filed a Complaint in Divorce at Number 02-4391 In the Court of Common Pleas, Cumberland County, Pennsylvania. In conjunction with the execution of this Agreement, the parties shall execute and file Affidavits of Consent, Waivers of Counseling and Waivers of Notice of Intention to Request Entry of Divorce Decree. Counsel for Wife shall immediately process the documents and secure a Decree in Divorce. Counsel for Wife shall provide a copy of the Decree to Husband. 13. EQUITABLE DISTRIBUTION: The parties agree and acknowledge that they have reached a fair distribution of property. has received their share of any and all marital That each party estate matters, unless otherwise noted in this Agreement. The parties again acknowledge that they will retain full ownership of any items in their possession, and expressly waive and relinquish any claim against any of the personalty, tangible assets, intangible assets, or any other matter, of the other party, unless otherwise noted in this Agreement. 14. The parties specifically acknowledge that the settlement arranged herein is an equitable distribution of the property of the parties, and each party waives distribution of marital property by a Court. 15. The parties expressly waive and relinquish any right to or claim for any entitlement provided by law and not expressly provided for herein. It is acknowledged by the parties that the receipt of those benefits and distributions set forth in this Agreement are in full satisfaction of or any entitlement provided 7 for by law. 16. FULL DISCLOSURE: The parties acknowledge that they have made, to each other, a full and complete disclosure of all related to the assets and/or liabilities of the marital and that they waive any specific listing or documentation for the purposes of this Agreement. 17. ENTIRE UNDERSTANDING: This Agreement constitutes the There are no representations matters estate, thereof, entire understanding of the parties. or warranties other than those expressly herein set forth. 18. GOVERNING LAW: The parties agree that all questions pertaining to the effect and validity of this Agreement, and the administration of its provisions, shall be governed by the laws of the Commonwealth of Pemnsylvania. The parties agree that any further action to be brought for the enforcement of this Agreement shall be brought in the Courts of Cumberland County, Pennsylvania. 19. BREACH: If either party defaults in the due performance of any of the terms, conditions and/or covenants of this Agreement on his or her part to be performed, the other party shall have the right to sue for specific performance, damages for such breach, or seek such other remedies or relief as may be available to him or her and the party breaching the Agreement shall be responsible for payment of any attorney's fees, costs and expenses incurred by the other party in enforcing his or her rights under this Agreement. 20. VOID CLAUSES: If any term~ condition, clause or provision of this Agreement shall be determined to be void or invalid at law or for any other reason, then only that term, condition, clause or provision shall be stricken from this Agreement as is deemed to be void or invalid at law, and in all other respects this Agreement shall remain in full force and effect. 21. AGREEMENT AS PART OF DECREE: This Property Settlement Agreement shall be incorporated, but not merged, into the Divorce Decree to be issued in this matter in the Court of Co~on Pleas of Cu~erland County, Pennsylvania. 22. INDEPENDENCE: This Agreement shall maintain its independent vitalityf and shall survive any incorporation, by reference or otherwise, with separate Order of Court. WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year aforesaid intending to be legally bound hereby. KARA K. GRIFFITHS, Plaintiff LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : : NO. 02-4391 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A Compla'mt in Divorce under Section 3301(c) of the Divorce Code was filed on September 12, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c~ OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 above are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relat'mg to unswom falsification to authorities. Date: KARA K. GRIFFITHS Plaintiff V. LEONARD R. GRIFFITHS Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-4391 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on Septeraber 12, 2002 and served on September 20, 2002. An Affidavit of Service was filed on October 8, 2002 and is of record. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I 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 counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made and correct. I understand that false subject to the penalties of 18 Pa.C.S. falsification to authorities. in this affidavit are true statements herein are made ~4904 relating to unsworn DATE: ~onard R. r KARA K. GRIFFITHS, Plaintiff V. LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 02-4391 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATE: ~~ndant KARA K. GRIFFITHS, Plaintiff LEONARD R. GRIFFITHS, Defendant : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA : : NO. 02-4391 : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section (XX) 3301(c) ( ) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: September 27, 2002; by restricted, certified mail number 7000 0600 0028 3366 9778. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: by Plaintiff.' December 15, 2003; Defendant: December 11, 2003. (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pend'mg: All claims of record have been settled pursuant to a Property Settlement Agreement dated December 15, 2003. 5. Date and manner of service 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) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff: December 15, 2003; by Defendant: December 11, 2003. and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce Decree: Plaintiff's and Defendant's Waiver are being filed simultaneously with this Praecipe. JAMES, SMITH, DIETTERRICK & CONNELLY LLP Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 iN THE cOUrT OF COMMON OF CUMBERLAND COUNTY STATE OF .~/~_ PENNA. KARA K. GRIFFITHS, Plaintiff NO. 02-4391 PLEAS VERSUS LEONARD R. GRIFFITHS, Defendant DECREE IN' DIVORCE AND NOW, ~)~-. 2~ DECREED THAT Kara K. Griffiths ~l::XO~, IT IS ORDERED AND ~ PLAI NTIFF~ AND Leonard R. Griffiths DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; The attached ProDerty Settlement Aqreement is hereby not merged, into this Decree in Divorce. BY THe COURT: //~/ ATT : //~~ J. PROtHONOTArY