- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: March 27, 2008