Denis M. Katchmeric - Page 4




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          incorporated herein by this reference.  When the petition was               
          filed, petitioner resided in Fairfax County, Virginia.                      
               Petitioner and Karen A. Deluca (Ms. Deluca) were married in            
          1984.  On October 16, 2001, they separated.  Her attorney                   
          notified petitioner by letter dated December 7, 2001, that he had           
          been retained by Ms. Deluca for the purpose of obtaining a                  
          divorce.  In the letter, the attorney stated that he was “in the            
          process of preparing a Separation and Property Settlement                   
          Agreement” that would incorporate a provision requiring                     
          petitioner to pay Ms. Deluca $1,300 per month as spousal support            
          until their marital home was sold, and that after the sale his              
          obligation would be reduced to $1,000 per month.  The letter                
          further stated that the separation agreement, when prepared,                
          would incorporate the following additional terms:                           
                    A. Karen will file for divorce on a no-fault                      
               basis, based upon living separate and apart from you                   
               continuously, without cohabitation, for the appropriate                
               time required under Virginia law.                                      
                  *       *       *       *       *       *       *                   
                    C. You will continue to pay the mortgage on the                   
               marital home until it is sold.  Upon the sale of the                   
               home, after deduction of the customary costs of sale,                  
               you and Karen will divide equally the proceeds.                        
                    D. You will continue to provide health insurance                  
               for Karen.                                                             
                    E. You will retain as your separate property all                  
               investments titled in your name alone.  Karen will                     
               retain as her separate property all investments titled                 
               in her name alone.  In addition, Karen shall retain as                 
               her separate property all investments now titled in                    
               your joint names.                                                      





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