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HomeMy WebLinkAbout02-4631REAGER & ADLER, PC BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763 - 1383 Attorneys for Plaintiff RENE D. McCOMAS, Plaintiff KENNETH S. McCOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN 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 requested in these papers by the Plaintiff. You may Iose money or property or other rights important to you. 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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, PA 17013 1-800-990-9108 REAGER & ADLER, PC BY: Joanne Harrison Clough, Esquire Attorney I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 REAGER & ADLER, PC BY: Joanne Harrison Clough, Esquire Attorney I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attomevs for Plaintiff RENE D. McCOMAS, Plaintiff KENNETH S. McCOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C~ OR (D] OF THE DIVORCE CODE 1. Plaintiff is RENE D. McCOMAS, an adult individual who currently resides at 408 Allegheny Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is KENNETH S. McCOMAS, an adult individual who currently resides at 408 Allegheny Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 2, 1990 in Dallas County, Texas. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiffavers that there is one (I) child of this marriage under the age of eighteen years, namely: Kristen L. McComas, date of birth is March 25, 1991. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divome Code. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff Dated: Respectfully submitted, Attc ~lar~on Clough, EsquiJ I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone No. (717) 763-1383 Attorneys for Plaintiff VERIFICATION I, Rene' McComas, verify that the statements made in the foregoing document are tree and correct to the best of my knowledge, information and belief. 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. Rede McComas RENE D. McCOMAS, Plaintiff VS. KENNETH S. McCOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4631 Civil IN CUSTODY ACCEPTANCE OF SERVICE I, Kenneth S. McComas, defendant, verify that I hereby accept service of the Divorce Complaint on the date set forth here below. Kenneth S. McComas RENE D. McCOMAS, Plaintiff V. KENNETH S. McCOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAI~[D COUNTY, PENNSYLVANIA NO. 02-4631 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 26, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a f'mal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Rene ~. McCoam~s RENE D. McCOMAS, : Plaintiff : V. : KENNETH S. McCOMAS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4631 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 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. Rene fi.'l(4cC6'"omas RENE D. McCOMAS, : Plaintiff : V. : KENNETH S. McCOMAS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4631 CIVIL ACTION' - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Con~laint in Divorce under Section 3301(c) of the Divorce Code was fried on September 26, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of 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. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: /-,,~°'~- d..~ Kenneth S. McComas RENE D. McCOMAS, : Plaintiff : V. : KENNETH S. McCOMAS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4631 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 if I do not claim them before a divorce iis 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: I~enneth S. McComas r /,,.;,( .'i. Gouffer, Notary, $£;:~c;r .'.;p. JJlg Twp., RENE D. McCOMAS, : Plaintiff : : vs. : NO. 02-4631 Civil : KENNETH S. McCOMAS, : IN DIVORCE Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on the 8~ day of October, 2002, by signing an Acceptance of Service. Acceptance of Service was filed with the court October 11, 2002. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Rene D. McComas, Plaintiff, on January 9, 2003; by Kenneth S. McComas, Defendant, on January 23, 2003. 28,2002. Related claims pending: Settled by Marital Settlement Agreement dated October 'C MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~8'1~'- day of October, 2002, by and between Rene D. McComas (hereinafter "WIFE") and Kenneth S. McComas, (hereinafter "HUSBAND"); W I TN E S S E TH: WHEREAS, the parties hereto were married on June 2, 1990, in Dallas, Texas, and separated on 9-26-2002; and WHEREAS, the parties have one child of this marriage, Kristen L. McComas, bom March 28, 1991; and WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling completely the economic and other rights and obligations between each other, including, but not limited to: the equitable distribution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally 'bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. WIFE is represented by ]oa~ae Harrison Clough, Esquire of REAGER & ADLER, P.C. HUSBAND has been advised of his right to be represented by counsel of his own choosing but has elected to represent hin~elf in the negotiation and execution of this Agreement. The parties further declare that each. is executing the Agreement freely and voluntarily having either obtained sufficient knowledge and disclosure of their respective legal rights and obligations, or if counsel has not been consulted, expressly waiving the right to obtain such knowledge. The parties each acknowledge that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. DIVORCE ACTION. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code. A divorce action was filed by WIFE with the Court of Common Pleas of Cumberland County, Pennsylvania at Civil Action No. 024631 on September 26, 2002. The parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement or upon expiration of ninety (90) days after the service of said complaint on Husband. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Ag-reement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" and "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this.. Agreement. 4. MUTUAL RELEASES. Each party absolutely and unconditionally release the other and the estate of the other from any and all rights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Page 2 of 10 Each party absolutely and unconditionally releases the other and his or her heirs, executors, and estate from any claims arising by virtue of the marital relationship of the parties. The above release shall be effective whether such claims arise by way of widow's or widower's rights, family exemption, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to partidpate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, Commonwealth, or territory of 'the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this Agreement an absolute and unconditional release from all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The parties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Each party understands that he/she had the right to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair and equitable, and that the terms adequately provide for his or her interests, and that this Agreement is not a result of fraud, duress or undue influence exercised by either party upon the other or by any person or persons upon either party. Page 3 of 10 6. SEPARATION/NON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were tmmarried. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. WIFE and HUSBAND shall not harass, disturb, or malign each other or the respective families of each other. 7. REAL PROPERTY. The parties are the joint owners of real property located at 408 Allegheny Drive, Mechanicsburg, Cumberland Cotmty, Pennsylvania, 17055. I~FUSBAND and WIFE agree in consideration of the other property transfers and promises set forth in this Agreement that HUSBAND shall transfer any and all right, title, claim or interest ihe has whatsoever in this real property to WIFE. WIFE agrees to indemnify and hold HUSBAND harmless on any taxes, monthly mortgage obligations or other debt associated with this real estate. The parties further acknowledge that the property is currently listed for sale and that WIFE shall be entitled to receive all of the proceeds from the sale of said real estate. %%riFE shall also have exclusive possession of said real estate on and after November 1, 2002. HUSBAND is to execute a Deed prepared at WIFE's expense transferring said property to WIFE contemporaneously with the execution of this Agreement. HUSBAND shall pay WIFE the sum of $3,000.00 as set forth in Paragraph 18 of Exhibit "A' attached to this Agreement. 8. DEBTS. If a party has acquired debt, the parties agree that each shall assume full and complete responsibility for his or her own debts. HUSBAND represents and warrants to WIFE that since the separation 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 he shall indemnify and save WIFE harmless from any and all claims Page 4 of 10 or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. WIFE represents and warrants to HUSBAND that since the separation 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 he shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. HUSBAND specifically agrees to be solely responsible for' the EDS VISA credit card debt account number 5117 5307 4900 7193. HUSBAND agrees to indemnify WIFE and hold her harmless on said obligation. 9. RETIREMENT BENEFITS. HUSBAND hereby waives his right, title and interest to any of WIFE's pension and/or retirement and any and all other retirement benefits otherwise disclosed. WIFE hereby waives her right, title and interest to any of H-USBAND's pension and/or retirement and any and all other retirement benefits otherwise disclosed. The parties specifically waive any and all other retireraent benefits obtained by the parties pre-marriage, during marriage, and post-separation. ~[he individual who holds said benefits shall own the property solely and individually. Each party waives their right to title and interest to the other party's benefit. 10. BANK ACCOUNTS. The parties acknowledge that they have divided the marital bank accounts to their satisfaction. The bank accounts held solely in individual names shall become the sole and separate property of the party in whose name it is registered. Each party does hereby specifically waive and release his/her right, title and interest in the other party's respective accounts. Page 5 of 10 11. LIFE INSURANCE. HUSBAND hereby waives any right, title, claim or inlLerest he may have in any life insurance policy of WIFE. WIFE waives any right, title, claim or interest she may have in any life insurance policy of HUSBAND. 12. PERSONAL PROPERTY. Except as set forth here below, the parties hereto mutually agree that they have divided all furniture, household furnishings and personal property between them in a manner agreeable to both parties. The parties mutually agree that each party shall from and after the date of this Agreement be the sole and separate owner of all tangible personal property in his or her possession. The personal property of the parties shall be divided as set forth on the distribution agreement executed by the parties on 10-14-02 and. attached hereto as Exhibit A. 13. VEHICLES. The parties own a 1996 Honda Civic. WIFE agrees to transfer her interest in said vehide to HUSBAND and sign any documents necessary to effectuate said transfer. HUSBAND shall pay any costs assodated with the transfer of this vehicle. 14. SAVINGS BOND FOR COLLEGE. The parties specifically acknowledge that during the course of the marriage they have purchased savings bonds in HUSBAND'S name totaling appro:~imately $5,500.00 for college education costs for their daughter Kristen. HUSBAND agrees to execute any documents necessary to transfer said savings bonds from his name to his daughter and his WIFE's name. WIFE specifically agrees said bonds will be used for Kristen's college education. Both parties agree said savings bonds are not marital property subject to eq~aitable distribution. Page 6 of 10 15. CUSTODY HUSBAND and WIME agree that WIFE should have primary physical and legal custody of the minor children Kristen L. McComas. HUSBAND shall have reasonable periods of visitation with the child at such times as mutually agreed upo~ by the parties. 16. BANKRUPTCY OR REORGANIZATION PROCEEDINGS. In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney fees and costs incurred in the enforcement of this paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless o£ Federal or State law to the contrary, and each party waives any and all right to assert that obligation hereunder is discharged or dischargeable. The parties mutually agree that in the event of bankruptcy or financial reorganization proceedings by either party in the future, any monies to be paid to the other party, or to a third party, pursuant to the terms of this Agreement shall constitute support and maintenance and shall not be discharged in bankruptcy. 17. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE. The parties hereby expressly waive, release, discharge and give up any and all rights or claims which either may now or hereafter have for spousal support, alimony pendente lite, alimony, or maintenance. The parties further release any righl.~s that they may have to seek modification of the terms of this Agreement in a court of law or equity, with the understanding that this Agreement constitutes a final determination for all time of either party's obligations to contribute to the support or maintenance of the other. Page 7 of 10 18. ATTORNEY FEES, COURT COSTS. Each party hereby agrees to be solely responsible for his or her own counsel fees, costs and expenses. Neither shall seek any contribution thereto from the other except as otherwise expressly provided herein. 19. ATTORNEYS' FEES FOR ENFORCEMENT. In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecting and enforcing his or her rights under this Agreement. 20. WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a.) The right to obtain an inventory and the appraisement of all marital and non-marital property; (b.) The right to obtain an income and expense statement of either party; (c.) The right to have all property identified and appraised; (d.) The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; and (e.) The right to have the court make all deterrninations regarding marital and non-marital property, equitable di[stribution, spousal support, alimony pendente lite, alimony, counsel fees and costs and expenses. 21. MUTUAL COOPERATION. WIFE and HUSBAND shall mutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of documents. Page 8 of 10 22. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 23. APPLICABLE LAW. This Agreement shall be Pennsylvania~ construed under the laws of the Commonwealth of 24. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 25. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared johatly by the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. This Agreement is executed in duplicate, and in counterparts. WiFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. Witr(ess ' Re~: D. McComas enneth S. McCorn~s--~ Page 9 of 10 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF : On the ~ day of ~ ., 2002, before me, a Notary Public in and for the Commonwealth of Pennsylvania, the tmdesigned officer, personally appeared Kenneth S. McComas, known to me (or satisfactory proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. IOASSANDRA T, ROSENBAUM, Notm'y Pu~icl I Camp Hill Bom, Cumbe~nd County I Notary Public Com ,on . pi as: COlVIMONWEALTH OF : : ss. COUNTY OF / t_~ : On the ~~ day of -.. ~ 2002, before me, a Not~ Public in ~d for ~e Co~onwe~ of Pe~sylv~ia, ~e umdesi~ed officer, person~ly appe~ed Rene D. McComas, kno~ to me (or sa~sfacto~ proven) to be on of the p~es exem~g ~e fomgo~g ~s~ument, ~d he ac~owledges ~e forego~g ~s~ment to be his free a~ ~d deed. IN WITNESS WHEREOF, I have hereunto set my hand. and notarial seal the day and year first above written. I~' - NOTARIAL SEAL GABSANDRA T, ROBENBAUM, Notary Public Camp Hilt Boro, Cumberland County My Commission Expires December 4, 2004 Notary Public My Commission Expires: Page 10 of 10 EXHIBIT "A" Ren & Kenneth McComas - Division Of Property 408 Allegheny Drive · Mechanicsburg, PA 17055 5,' DOG RENI5 All money from the sale of the house.' All Money in savings & checking accounts at PNC Bank under Ren~ D. McComas All of my furniture purchased before marriage - sofa, Ioveseat, coffee table, 2 end tables & lamps Double bed & 2 dressers 6. TV & VCR (new) 7. Kitchen table & 4 chairs 8. Microwave & cart 9. Refrigerator 10. 87 Honda Civic 11. Washer & Dryer 12. Bikes 13, Smaller Bookshelf 14, Kristen keeps all of her stuff 15, Futon 16, $5500 - US Savings Bonds For Kristen's College Fund, 17, All Money in 401K at The Sentinel (Lee Publishing) and my IRA at Edward Jones, 18, $3000,00 to cover cost of any bills before the. sale of the house, Al! mOney remaining will be reimbursed after closing with a detailed summary of how and if the money was spent, 19, PNC Credit Card under the name of Ren~ D, McComas 20, Tuition Account Program: Accessible only to Ren6 D, McComas 2, 3, 4, 5. 6. 7, 9. 10, 11, 12, 13, 14, KENNETH Pioneer Stereo Entertainment Center TV & VCR (old) Lazy bo!/recliner Computer & desk Tall bookshelf & storage cabinet Queen Bed w/sheets & quilt (1) dresser 96 Honda Civic Freezer Redwood lawn furniture EDS Visa and EDS Credit Union Acct. All money in Credit Union & All debt on EDS Visa Visa Acct: 5117 5307 4900 7193 Expires: ;~03. EDS Credit Union Acct. #73528003 Remove Ren~ D. McComas from the accounts. All Money in savings & checking accounts at PNC Bank under Kenneth S. McComas cat once settled Credit cards with both of our names will be canceled. EXXON/MOBIL, Captial One Visa, Bonton, JC Penney & Hechts Kenneth S, McComas Date { b --/--/.- Date IN THE COURT Of COMMON Rene D. McComas VERSUS Kenneth S. McComas OF CUMBERLAND COUNTY STA'¥E OF PENNA. No. 02-4631 PLEAS DECREE IN DIVORCE AND NOW,. DECREED THAT Rene D. McComas , '~::~, IT IS ORDERED AND , PLAINTIFF, AND Kenneth S. McComas , 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 terms of the parties' Marital Settlement Agrer. ment dated October 28, 2002, and attached hereto are incorporated herein but not merged herewith. BYTHE ~URT: / ATTES' J0 PROTHONOTARY