James A Marchewka, Esquire
222 West Pike Street
Canonsburg, Pa 15317
Mr. Marchewka,
I am writing with regard to my wife, Angella C Perry, and her lack of compliance with the "Marital Settlement Agreement".
As per the Marital Settlement Agreement document: Paragraph 13, Disposition of Real Estate
The parties agree that the marital residence known as 271 Linden Road, Canonsburg, Washington County, Pennsylvania will be conveyed to husband, Keith J Perry. Wife, Angella Perry shall convey to husband any and all rights title and interest in the former marital residence. Husband shall be responsible for the mortgage and shall hold wife harmless thereon. If he is able to refinance to remove her name from the mortgage completely, he will so. If, however, he cannot obtain the loan, he will continue to pay the existing mortgage until such time as he chooses to attempt to refinance on some other occasion. Wife will execute a deed conveying any and all of her rights, title and interest in said real estate which will be held by her counsel until Mr. Perry's refinancing is completed. Wife's counsel, James A Marchewka, Esquire, will hold the "quit-claim deed" in escrow pending the refinancing and removal of wife's name.
I have refinanced the house on January 27th, 2004, which is almost one year ago. To date, I have received nothing from you regarding the "quit-claim deed", which I am requesting at this time.
I no longer retain an attorney, as I was under the impression all was taken care of and a divorce would be the result. This does not seem so.
Please send me the "quit-claim deed" and update me as to the status of the divorce my wife filed for.
Thanks in advance,
Keith J Perry
271 Linden Road
Canonsburg, PA 15317