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HomeMy WebLinkAbout02-4788 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A. KURTZ, Plaintiff v, CNIL ACTION - LAW NO, 2002-" "') ?y JACQUE A. KURTZ, Defendant IN DNORCE 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 lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa, You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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, P A 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A, KURTZ, Plaintiff CIVIL ACTION - LAW v, NO, 2002 - L/1f? JACQUE A. KURTZ, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this I st day of October, 2002 comes Plaintiff, Cheryl A. Kurtz, by and through her attorneys, Hanft & Knight, P,C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Cheryl A. Kurtz, who currently resides at 62 Parsonage Street, Newville, Cumberland County, Pennsylvania 17241, 2. The Defendant is Jacque A. Kurtz, who currently resides at 4 Maple Lane, Newville, Cumberland County, Pennsylvania 17241, 3, The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediatelypreceding the filing ofthis Complaint in Divorce. 4. The parties were married on January 21, 1984, in Dauphin County, Pennsylvania, 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended, 6. There have been no prior actions for divorce or annulment between the parties, 7, Alternatively, Plaintiff avers that the Defendant has offered such indignities to her, the injured and innocent spouse, as to render her condition intolerable and her life burdensome, The foregoing facts are averred and brought under Section 3301(a)(6) of the Divorce Code of 1980, as amended, 8. The Plaintiffhas been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same, WHEREFORE, Plaintiff requests Your Honorable Court enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. COUNT II: EQUITABLE DISTRIBUTION 9. The averments set forth in Paragraphs 1-8 are incorporated herein by reference, 10, The parties hereto have accumulated substantial marital assets during the marriage. Plaintiff requests this Honorable Court enter an Order equitably distributing the marital assets, WHEREFORE, Plaintiff requests Your Honorable Court enter an Order for equitable distribution, Respectfully submitted, HANFT & KNIGHT, P,C. i dsay Gin ch clay, Esquire Attorney I.D, No, 87954 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 F\U~er Folder\Firm DocslGendocs2002\2878_1 .divcomp, wpd Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language ofthe document is that of counsel and not my own. I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief, To the extent that the content of lhe document is that of counsel, I have relied upon counsel in making this verification, This statement and verification are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties, . ~ ,., 1 Ii I i (J/,/ ,I Cheryl " Kurtz ,/ i/LT , .. .(,1,' \ \ G F:\User Folder\firm DocslGendocs2002\2878_] .div,comp.wpd ~~ - l.J -- ..., w 1-' c .. "" ~ (") 0 c '" ~ <::) :-0 li'l r"') fl q)[}! -< ~,..,. I ~5_-.' -<.". .. ~'CJ 1.l -" -' E:c-, :J, '" -- 00<') ~~/--, )0- '~, s.~ ~ V\ LI'\ ~::;; '- ::> Ir, e '& =< (~ '" -- t ~ o -n '1 ~ --~f~ ~ ,;., J CJ :d C) ;'':;;11 >:; 2 ..~.J -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A. KURTZ, Plaintiff CIVIL ACTION - LAW v. NO. 2002- 4788 JACQUE A. KURTZ, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Rebecca R. Hughes, Esquire, accept service of the Complaint in Divorce in the above- captioned matter on behalf of my client, Jacque A. Kurtz, and I certify that I am authorized to do so, IRWIN, McKNIGHT & HUGHES Rebecca R. Hughes, Esquire Attorney I.D. No, 67212 60 West Pomfret Street Carlisle, Pennsylvania 17013 Attorneys for Defendant F:\User Folder\Firm Docs\Gendocs2002\287S.1.accept.serv, wpd ('") a 0 ~ 1'0 q LJ Q ./ t ~; C') 'Jj I ...-/ ,; " i;:; -' .~ "'.'-. , c/) u' ;::~ '., c (~) ~:J -+j .. .. , ,::-.,.. \.. . . <: ) )> ('. /, / ~ ?i ::;~;.; -~ :0 ... -, .... -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHERYL A. KURTZ, Plaintiff No, 2002 - 4788 v, CIVIL ACTION - LAW JACQUE A. KURTZ, Defendant (In Divorce) NOTICE OF ELECTION TO RETAKE MAlDEN NAME TO THE PROTHONOTARY: Notice is hereby given that the Plaintiff, in the above matter, being the recipient of a Divorce Decree, issued on January 11, 2005, hereby elects to retake and hereafter use her maiden name of CHERYL A. SLABONIK, and gives this written notice avowing her intention in accordance with the provision of 54 Pa,C.S.A. 9704(a). Date: do -"-'-05 ~QI~ CHE A. KURTZ i TO BE KNOWN AS: / (J. ~;l~~ A. SLABONIK IN THE COURT OF COMMON P1LEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHERYL A. KURTZ, Plaintiff No. 2002 - 4788 v. CIVIL ACTION - LAW JACQUE A. KURTZ, Defendant (In Divorce) COMMONWEALTH OF PENNSYLVANIA SS, COUNTY OF CUMBERLAND AFFIDAVIT On this, the/ }~y of ~b.tl..n~ 2005, before me, a Notary Public, personally appeared Cheryl A. Kurtz, known ~e, or satisfactorily proven to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and official seal. . NOTARIAl. SEAL I CLAUDIA A B. REWBAKER, NOTARY PUBLIC Carlisle Bora, Cumberland County My Comm!ss;or: ExpiI"es April 4, 2005 , ~) 6v ,,"b7lu,~ , Notary Public ,.\ ..tq. 1-~ ~ ~ ~ ~ ~ :f3 C:,; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A. KURTZ, Plaintiff No. 2002 - 4788 v. CIVIL ACTION - LA JACQUE A. KURTZ, Defendant (In Divorce) PROPERTY SETTLEMENT AND SEPARATION AGREE ~ -- THIS AGREEMENT is made this ~ day of jO..v\IJ...()X~ ' BY and BETWEEN Cheryl a, Kurtz of 62 Parsonage Street, Newville, Cumberlan County, Pennsylvania, hereinafter referred to as Wife, A N D Jacque A. Kurtz of 4 Maple Lane, Newville, Cumberland County, Pennsylvania, h reinafter referred to as Husband, RECITALS R.l: The parties hereto are Husband and Wife, having been joined in ma January 21, 1984, in Dauphin County, Pennsylvania; and R,2: Differences have arisen between the parties, in consequence of w have lived separate and apart since on or about August 1,2002; and R.3: The parties have resolved that it is not possible to continue the marital relationship between them for reasons known to them, in consequence of which ey are living separate and apart; and CAK~ Page 1 of15 R.4: It is the desire and intention of the parties, after long consideration, to amicably adjust, compromise and settle all property rights, in, to or against the property or estate of the other, including property h subsequently acquired by either party, and to settle all disputes existing bet een them, including any claims or rights that they may have under the provisions of the P sylvania Divorce Code, as amended; and R.5: The parties also desire to settle their issues of counsel fees and co s, and the settling of any and all claims and possible claims against the other or ag inst their respective estates; and R,6: The parties desire to resolve all claims pending between them, inc ding the settlement of all of their respective property rights and other rights growing 0 of their marriage relationship including, but not limited to, all matters between them relat ng to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs; and R,7: Husband and Wife declare that each has had a full and fair oppo nity to obtain independenl legal advice of counsel of their selection; that Husband as been independently represented by Rebecca R, Hughes, Esquire, and that Wife h s been independently represented by Lindsay Gingrich Maclay, Esquire; and R.8: Both Husband and Wife each covenant that they have made II and complete disclosure to the other of his and her respective property holdings and come; and R,9: Each party has had an opportunity to verifY the financial disclosur of the other. Discovery, if any, has been conducted to the satisfaction of each party Eac p~){ CAK ( d Page 2 of 15 JA J\J'- has had the opportunity to investigate further the financial disclosure of the ot er, and has had access to any desired books and/or records to investigate further. Each p y had an opportunity to do an independent valuation of the assets, liabilities and income f the other party. To the extent either party decided not to pursue further discovery and in estigation, he or she did so voluntarily and specifically waives the right to challenge this greement based on the absence of fu1l and fair disclosure, NOW THEREFORE, with the aforegoing recitals being hereinafter inco orated by reference and deemed an essential part hereof and in consideration of the cov nants and promises hereinafter to be mutua1ly kept and performed by each party, as we1l a for other good and valuable consideration, receipt of which is hereby acknowledged, and t e parties, intending to be lega1ly bound, hereby agree as fo1lows: (I) SEPARATION: It sha1l be lawful for each party at a1l times hereafter to live separate and apart from the other party at such place or places as he or she om time to time may choose or deem fit, free from any control, restraint or interference from the olher, Neither party will molest the other or endeavor 10 compel the other to c habit or dwe1l with him or her by any legal or other proceeding, Neither party sha1l dis arage or discredit the other in any way, nor in any way injure his or her reputation; nor sha1l either of them act or permit anyone else to act in any way which might tend to create any dis ffection or disloyalty or disrespect between the members of the family of either party, E h party shaH be free of the interference, authority or contact by the other as if he or she w s single and unmarried except as maybe necessary to carry out the terms of this Agreemen or any Custody Stipulation and Agreement and/or Order of Court, CAK l cJc Page 3 of 15 (2) DIVORCE: The parties acknowledge that the marriage is i etrievably broken and that they will secure a mutual consent no-fault divorce decree, Si ultaneous with the execution of this Agreement, the parties agree to execute their respectiv If either party fails or refuses to execute and file the foregoing docu ents, said of Consent and Waiver of Notice Forms necessary to finalize said divorce, failure or refusal shall be considered a material breach of this Agreement and s all entitle the other party at his or her option to terminate this Agreement. (3) REAL PROPERTY: The parties acknowledge that they are joint owners of the premises more commonly identified as 4 Maple Lane, Newville, C mberland County, Pennsylvania (hereinafter referred to as the "Marital Residence"), Accor ing to an appraisal conducted by Larry Foote at the request of the parties, the appraised va ue of the Marital Residence at or around the parties' date of separation was Eighty-One housand ($81,000,00) Dollars, Said Marital Residence is currently encumbered by a int first mortgage obligation with M&T Banle The parties acknowledge that the balance 0 the first mortgage at or around the date of the parties' separation was approximatel Eleven Thousand ($11,000,00) Dollars, The parties further acknowledge that the first ortgage of her right, title and interest in and to said property to Husband, free of all enc with M&T Bank is in both parties' names, Contemporaneously with the executi of this Agreement, Wife agrees that as part of this property settlement, she will convey an and all except the outstanding first mortgage, which Husband agrees to assume and pa in due course, and that Wife will execute and deliver a Special Warranty Deed, pre ared at Husband's expense, to Husband conveying any interest Wife may have in and to said prope7:b. and. CAK 0. ! Page 4 of 15 Rebecca R, Hughes, Esquire, agrees to hold the Deed in escrow until s ch time as Husband is able to refinance the first mortgage solely into his name, Hu and shall refinance the first mortgage into his own within sixty (60) days of the execut on of this Agreement. Until such time as Husband is able to refinance the first mortg ge on the Marital Residence, Husband specifically agrees to hold Wife harmless with re rd to any and all payments associated with the Marital Residence from the date of eparation, forward, including, but not limited to the first mortgage payments, taxes, ho eowner's insurance and repairs, Wife agrees to execute any and all documents, within fiv (5) days of a request to do so by Husband, in order to effectuate the refinance of the mortg ge solely into Husband's name, Upon Husband successfully refinancing the first mortgage into his own ame and providing a time-stamped copy of the Satisfaction Piece for said joint mortgage to Wife's attorney, Rebecca R. Hughes, Esquire, shall record the Deed, at expense, conveying the Marital Residence from Husband and Wife to Husband, DEBT: Each of the parties hereto covenants and agrees that he or she has not in the past and will not at any time in the future incur or contract any debt, arge or liability for which the other of them, their legal representatives, or their property restate may become liable; and each of them further covenants at all times to keep the 0 er free harmless and indemnified of and from all debts, charges and liabilities her fier or heretofore contracted by them, except as hereinafter provided, A. MARITAL DEBT: Other than those debts enumerated wi agreement, Husband and Wife acknowledge and agree that no other outstanding debts and obligations which are marit which the other might be liable incurred prior to the signin Agreement. Page 5 of 15 CAK Qolc 1. Except as otherwise herein provided, each of the arties will pay all current bills and outstanding bills inc ed on or before the date of separation of the parties, Augus 1, 2002, to the same extent that he or she has been paying em in the past and neither party shall incur any unusual bill which will bind the other party, Husband hereby agrees t return to Wife any and all joint credit cards or charge pi es that he may have in his possession, The parties further agree that any debts incurred on said joint credit cards or ch ge plates subsequent to the date of separation, shall be th sole and exclusive responsibility of the party who incurred said debts and the debt-incurring party shall save harmless the other party from any obligation or institutions of suit ther under. B: POST SEPARATION DEBT: In the event that ei er party contracted or incurred any debt since the date of sep ration on August 1, 2002, the party who incurred said debt shall be r sponsible for the payment thereof regardless of the name in which th debt may have been incurred. C: FUTURE DEBT: From the date of this agreement nei er party shall contract or incur any debt or liability for which the 0 her party or his or her property or estate might be responsible d shall indemnifY and save the other party harmless from any and II claims or demands made against him or her by reason of debts or 0 ligations incurred by the other party, (5) MOTOR VEHICLES: The parties acknowledge that Husband, indi idually, holds title to a two (2) vehicles, which are currently in his possession, Wifi hereby relinquishes any right, title or interest she may have in and to the vehicles cu ently in Husband's possession, Husband shall acquire and maintain separate insurance on all vehicles in his possession, Husband specifically agrees to assume full responsi 'lity for and pay in due course, any encumbrance on the vehicles currently in Husband's pos ession, Husband shall hold Wife harmless and indemnifY Wife from any loss thereon. CAK 0, O-fC Page 6 of 15 ~ The parties acknowledge that Wife, individually, holds title to a 1 94 Dodge Caravan, Husband hereby relinquishes any right, title or interest he may have i and to the 1994 Dodge Caravan, Wife shall maintain separate insurance on the 1994 Car an, Wife specifically agrees to assume full responsibility for and pay in due course, any en umbrance on the 1994 Caravan and Wife shall hold Husband harmless and indemnify Hus and from any loss thereon, (6) TANGIBLE PERSONAL PROPERTY: Except as otherwise provided herein, the parties hereto mutually agree that they have effected a satisfactory ivision of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from an after the date hereof be the sole and separate owner of all such property presently in is or her possession whether said property was heretofore owned jointly or individual by the parties hereto, This Agreement shall have the effect of an assignment or bill of ale from each party to the other for such property as may be in the individual possessi n of the parties hereto, (i) Wife shall, within ten (10) days of the execution of this A be permitted, at a time convenient for both parties, to marital home to obtain videos of Jacob's wrestling matches family videos, It is specifically contemplated that Wife shal borrow approximately sixty (60) videos from the home for the sole purpose of copying and will return when completed, These vid s will become the property of Husband; and (ii) Husband shall, simultaneously with the execution of this Ag provide to Wife the camcorder case, along with any attachments for the Kirby sweeper; and Page 7 of 15 ~ JI. L CAK C - (iii) Wife shall be permitted to enter onto the marital propert in order to remove up to half the asparagus plants and up to half of he daffodil bulbs, The removal of these plants will occur during the ime of year best for removing these items without destroying same, The parties will cooperate with one another in order to set a date a d time for removal of these plants and bulbs, During removal of said bulbs, neither party shall speak to the other unnecessarily, and s all limit all speech to that which is necessary to effectuate this claus Husband shall be notified and shall be given the option to be pr sent when Wife removes these items from the marital property; h ever, the removal of these items will occur no more than ten (10) ays after a request by Wife to remove said plants and bulbs; and (iv) Simultaneous with the execution of this Agreement, ife shall provide to Husband his yearbook, dictionary, and water pi cher from his mother. (7) INTANGIBLE PERSONAL PROPERTY: Each part hereto hereby relinquishes any right, title or interest he or she may have in or to any ntangible personal property currently titled in the name of or in the possession of the ot er party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual tirement accounts, employment benefits, including retirement accounts, savings plans, pens on plans, stock plans, 40lK plans, and the like, Husband acknowledges that the marital property of the parties includes an marital portion of Wife's 401K plan through her employment with Carlisle Companies, c. The approximate value of Wife's 40lK with Carlisle Companies, 1nc, as of September 0,2002 was Forty-Two Thousand Eight Hundred Seventy-Two and 22/100 ($42,872,22) Dollars, all of which was vested, See Account Statement dated September 30, 2002, attach hereto as Exhibit "A" and incorporated herein by reference, Husband further acknowle es that he has been informed of his right to obtain an independent appraisal of Wife's ret ement, and an~~ interest therein, and, notwithstanding same, in exchange for Wife CAK \ Page80f15 JA her interest in the Marital Home, Husband hereby forever waives and relinquish s any right, title, interest or claim he might otherwise have in and to Wife's aforesaid reti ement plan through Carlisle Companies, lnc, Husband acknowledges that the marital property of the parties includes portion of Wife's IRA through Merrill Lynch, stemming from her fonner emplo AMP, lnc, The approximate value of Wife's IRA with Merrill Lynch, as of S 2002 was Twenty-Two Thousand Four Hundred Eighty-Five and 411100 ($ Dollars, See Account Statement dated September 27,2002, attached hereto as ibit "B" and incorporated herein by reference, Husband further acknowledges that h informed of his right to obtain an independent appraisal of Wife's retiremen and any marital interest therein, and, notwithstanding same, in exchange for Wife wiving her interest in the Marital Home, Husband hereby forever waives and relinquishes title, interest or claim he might otherwise have in and to Wife's aforesaid retir through Merrill Lynch, Husband further acknowledges that the marital property of the parties inc marital portion of Wife's pension through her employment with Carlisle Comp ies, lnc, The account balance of Wife's pension with Carlisle Companies as of Septembe 5, 2002 was Nine Thousand Four Hundred Seventy-Three and 24/100 ($9,473.24) Doll s, See Account Statement dated September 5, 2002, attached hereto as Exhibit 'C" and incorporated herein by reference, Husband further acknowledges that he has been i formed of his right to obtain an independent appraisal of Wife's pension, and any marital interest therein, and, notwithstanding same, in exchange for Wife waiving her interest in the Marital CAK ~J-- Page 9 of 15 J Home, Husband hereby forever waives and relinquishes any right, title, interest r claim he might otherwise have in and to Wife's aforesaid pension through Carlisle Comp ies, Inc, (8) LIFE INSURANCE: To the extent either party has a life insura ce policy, each party will retain their respective separate policies and will be pennitte to name anyone they wish as the designated beneficiary under their respective policies, (9) WAIVER of ALIMONY: The parties acknowledge that each s income and assets satisfactory to meet his and her own reasonable needs, Each party claim he or she may have, one against the other, for alimony, spousal support 0 alimony pendente lite, (10) ATTORNEY'S FEES: Except as otherwise provided herei , each of the parties waives the right to receive a payment for counsel fees from the other, and each shall be responsible for his or her own counsel fees, costs and expenses, if suc fees or expenses are incurred, (11) ADVICE of COUNSEL: The parties hereto acknowledge an declare that each has had a full and fair opportunity to obtain independent legal advice of c unsel of their selection; that Husband has been independently represented by Rebecca R, Esquire, and that Wife has been independently represented by Lindsay Gingrich aclay, Esquire, Each party acknowledges and accepts that this agreement is, un er the circumstances, fair and equitable, and that it is being entered into freely and vo ntarily after having received such advice and with such knowledge as each has soug t from CAK cc~ Page 10 of 15 counsel, and the execution of this agreement is not the result of any dures or undue influence, and that it is not the result of any improper or illegal agreement or agr (12) ADDITIONAL INSTRUMENTS: Except as otherwise herei each of the parties shall from time to time, at the request of the other, execute, ac and deliver 10 the other party, within five (5) days of any request 10 do so, further instruments that may be reasonably required to give full force and ef provisions of this Agreement. (13) INCOME TAX: The parties hereto agree to file separate i come tax returns for all ongoing years, specifically including 2004 and 2005, (14) BANKRUPTCY: The parties hereby agree that the provisio s of this Agreement shall not be dischargeable in Bankruplcy and expressly agree to rea firm any and all obligations contained herein. In the event a party files such bankruptcy an thereto obtains a discharge of any obligations assumed hereunder, the other party the right to declare this Agreement to be null and void and to terminate this Agr which evenl the division of the parties' marital assets and all otherrights determin by this Agreement, including alimony, shall be subject to court determination the same s if this Agreement had never been entered into, (15) COMPLETE DISCLOSURE: The parties do hereby arrant, represent, acknowledge and agree that each is fully and completely informed 0 and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of t e other CAK~ Page 11 of 15 and received any such information requested, Each has made a full and compIe disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived, (16) WAIVER of APPRAISALS: The parties acknowledge t at they are aware of their respective rights pursuant to the Pennsylvania Divorce Code to 0 ain formal valuations or appraisals of the real estate, the personal property, the vehicles, retirement accounts and businesses, some or all of which were acquired during the m therefore constitute marital property, However, the parties have determined th not undertake the expense to have these items appraised and/or valuated, that the division of property as set forth in this agreement, represents a fair and equitable distribution, (17) RIGHTS and RESPONSIBILITIES: Husband and Wife ackno each of them has read and understand his and her rights and responsibilities Agreement and that they have executed this Agreement under no compulsion to d a voluntary act. (18) FULL SETTLEMENT: Except as herein otherwise party hereby releases the other from any and all claims, or demands up to th date of execution hereof, It is further specifically understood and agreed by and bet een the parties hereto that each party accepts the provisions herein made in lieu of an in full settlement and satisfaction of any and all of said party's rights against the other or past, present and future claims on account of spousal support, maintenance, alimony, ali ony CAK~ Page 12 of15 / pendente lite, counsel fees, costs and expenses, equitable distribution of mari al property and any other claims of the party, including all claims which have been raise or may be raised in an action for divorce, (19) RELEASE of ALL CLAIMS: Except as otherwise provi ed herein, each party releases and discharges completely and forever the other from any a all right, title, interest or claim of past, present or future spousal support, division 0 property, including income of gain from property hereafter accruing, right of dower or c rtesy, the right to act as administrator or executor of the estate of the other, the right to a 'stributive share of the other's estate, any right of exemption in the estate of the other, or any other property rights, benefits or privileges accruing to either party by virtue of thei marriage relationship, or otherwise, whether the same are conferred by statutory or comm n law of the Commonwealth of Pennsylvania, or any other state, or of the statutory or co of the United States of America. Except as provided herein, the parties specific ly waive any and all rights that they may have to equitable distribution of marital prope y and/or alimony and counsel fees, except those counsel fees sought in the event of a brea h of this Agreement, or any other marital rights as provided in the Pennsylvania Divorce de, Act 26 of 1980 or any amendment thereto, It is further specifically understood and agreed by and between the partie hereto, that each party accepts the provisions herein made in lieu of and in full settle ent and satisfaction of any and all of said parties' rights against the other for any past, pre ent and future claims on account of spousal support; maintenance; alimony; alimony pend counsel f1~s, costs and expenses, except those counsel fees, costs and/or expenses so CAK QML- Page 13 of 15 J the event of a breach of this Agreement; equitable distribution of marital prop and any other claims of each party, including all claims raised by them in the Divorce ction to be filed between the parties, (20) SEPARABILITY of PROVISIONS: If any tenn, condit on, clause or provision of this agreement shall be detennined or declared to be void or in lid in law or otherwise, then only that tenn, condition, clause or provision shall be stricke from this Agreement and in all other respects this agreement shall continue in full force, effoct and operation, (21) GOVERNING LAW: All matters affecting the interpretat n of this Agreement and the rights of the parties hereto shall be governed by the la s of the Commonwealth of Pennsylvania, (22) INCORPORATION into DIVORCE DECREE: The Parties this Agreement shall continue in full force and effect after such time as a final Divorce may be entered with respect to the parties, Upon entry of the D provisions of this Agreement shall be incorporated by reference or in substance, but they shall not be deemed merged into such Decree, The Agreement shall survive Decree in Divorce, shall be independent thereof, and the parties intend that all oblig tions contained in this Agreement shall retain their contractual nature in any enti rcement proceedings, whether enforcement is sought in an action on the contract itself at I w or in equity, or in any enforcement action filed to the Divorce Caption. (23) BREACH: In the event that either party breaches any provisio Agreement, he or she shall be responsible for any and all costs incurred to enfi rce the Agreement, including, but not limited to, court cost and counsel fees of the other CAKQC'i- Page 140f15 J~ the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may b available to him or her. (24) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, repre entations, or agreements, oral or written, of any nature whatsoever, other than those herein c ntained, (25) AGREEMENT BINDING on PARTIES and HEIRS: It is derstood and agreed that not only the parties hereto, but also their heirs, administrators, exe utors and assigns, shall be bound by all the terms, conditions and clauses of this Agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legal y bound hereby, have hereunto set their hands and seals to this Agreement the day and ear first above written, WITNESS: I :P~~/~ iW v~ J?, W d(~Jc& ~ 0-.\ Cheryl ,Kurtz CAK~ Page 15 of 15 Exhibit "A" emum 000873 CHERYL A KURTZ 62 PARSONAGE STREET APT] NEWVILLEPA 17241 Carlisle Companies, Incorp rated Account Statement Statement Date: 10-1-2002 Soc, Sec, Num: · Employment Status: Active Here is a summary of your Carlisle Corporation Employee Incentive Savings Plan account as of September 30, 2002. Personal Information Birth Date Hire Date Location 11-26-1956 07-11- 1988 CARLISLE TIRE&WHEEL Contribution Rates Carlisle Corporation Employee Incentive Savings Plan Elected Rates Before-Tax After-Tax 0% 0% Your Contribution Credits Pre-87 After-Tax Contributions Prorated After-Tax Contributions Before-Tax Withdrawable Amount $0,00 $159,94 $15,552,69 delivered by He,,-fltt; C6099-000873 Closing Bala" ~count Total $20,585.06 $22,287,16 $42,872.22 Before-Tax Employer Match Total As of September 30, 2002 you were 100% vested in the company matching accmmt. Your vested account balance was $42,872.22, For More Information If you need additional information, call Benefits Express™ at 1-888-292-4540. 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" ~ ~ '" "" n o ... o c)> ",(1) '" :r om " )> -<!; "'z ~ 0 ",m 0)> 00 "'0 OlO ~ C "'z ~-I 00 .,> -r- " 0 S.c ~> o -l :l _ '" 0 z ( \ ('~ t'-~' , ::> ,-;.) -.' c.. ~ 0') (-.,) -< f',,' s~~ -., ;r\~, -: ~:~~ \~1 ;:? t~? , ( ) ;---n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CHERYL A. KURTZ, Plaintiff No, 2002 - 4788 v, CIVIL ACTION - LA JACQUE A. KURTZ, Defendant (In Divorce) AFFIDA vrr OF CONSENT COMMONWEALTH OF PENNSYL VANIA ) SS. COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code w s filed on October I, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninet (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of the Notice of Intention to Request Entry of a Divorce Decree. I verify that the statements made in this Affidavit are true and correct to the st of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of IS Pa. C.S" Section 4904 relating to unsworn falsi cation to authorities. Date: .-3- 10-0$ laintiff SVlf~rn to anif sub ~ day ot' !. ribed before me this 2005, i'!,.i;":"Li'.I_':IU P/l.T'::<~i('iA A Pi:; - fO,'! NChry p; ,',.,Iif, L0':/i,;r ';)a~!on I" O~UPh;,'; CO!~;;~;~~ ,"i'<~ ~'o.',\:'';:j ~:~; C) ;::i:~ ~,.. ,-- ~:":. ~,}:) (...:.) , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A. KURTZ, Plaintiff No, 2002 - 4788 v, CIVIL ACTION - LA JACQUE A. KURTZ, Defendant (In Divorce) DE 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 0 property, lawyer's fees or expenses if! do not claim them before a Divorce is grant 3. I understand that I will not be divorced until a Divorce Decree is ent ed by the Court and I further understand that a copy of the Decree will be s nt to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct to the st of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to a thorities. Date: l-l,--~( , ("",j c:.? t.:~.:.~ l_'"' ,,'~, V ~'11 '-' :.:;'~ \ I ,-.0 c..) ~- - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A. KURTZ, Plaintiff No, 2002 - 4788 v, CIVIL ACTION - LA JACQUE A. KURTZ, Defendant (In Divorce) AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYL VANIA ) SS, COUNTY OF CUMBERLAND ) ! I. A Complaint in Divorce under Section 3301(c) of the Divorce Code wa filed on October 1, 2002, 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 in Divorce after service of the otice of Intention to Request Entry of a Divorce Decree, I verifY that the statements made in this Affidavit are true and correct to the be t of my knowledge, information, and belief. I understand that false statements herein e made subject to the penalties of 18 Pa, C.S" Section 4904 relating to unsworn [alsifi ation to authorities, Date: ~ <l-L 04- A, Swo,r to and Dribed before me this ~ day of ~c ,2004. , Notary Public . ,,',,; /J.:J.',',. r-.) ~~ ,;,~'l <-- ,..- ~ ~f', ",,';"- .-, -:)'.:..-.." 1" 'F-~ --('"lll' . c.' -.-: __',1-1 . -~., 'J~~'~ ,_0' rJ) <..fl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CHERYL A. KURTZ, Plaintiff No, 2002 - 4788 v, CIVIL ACTION - LA JACQUE A. KURTZ, Defendant (In Divorce) E 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 0 property, lawyer's fees or expenses if I do not claim them before a Divorce is grant 3. I understand that I will not be divorced until a Divorce Decree is eote ed by the Court and I further understand that a copy of the Decree will be s nt to me immediately after it is filed with the Prothonotary. I verity that the statements made in this Waiver are true and correct to the b st of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. ~4904, relating to unsworn falsification to a thorities. Date: ~ C) (' r-.l '--.:::?, ':.r; (- . .;~"'~ . " ..- ___l (~~:\ .....\ .-;........ \-,-\;::::. 'n ~?~) .,1 ( , ) ~-~-. . - -~_.\ >:C") -~,'t-'c. j \.[? 0) (J'\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL A. KURTZ, Plaintiff No, 2002 - 4788 v. CIVIL ACTION. LA JACQUE A. KURTZ, Defendant (In Divorce) PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the Record, together with the following information, to t Court for entry of a Decree in Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) oft e Divorce Code, 2. Date and manner of service of the Complaint: Defendant accepted ' e, by and through his attorney, by having his attorney sign an Acceptance of Se ice on or about October 15, 2002. The Acceptance of Service is docketed at he above- captioned term and number, verifYing same. 3. As required by Section 3301(c) of the Divorce Code, Plaintiff ex cuted her Affidavit of Consent on January 6, 2005. Defendant executed his .davit on December 9,2004. The parties' respective Affidavits were filed on Janu 7,2004. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice under Section 3301(c) of the Divorce ode was executed on January 6, 2005. Defendant's Waiver was executed on De mber 17, 2004. The parties' respective Waivers were filed on January 7, 2004, Respectfully Submitted, Date: Jin~_lt J 1004 \J ~------ By: / Un95ay Gin c Mac y, E VAttorney 1.D. , 87954 I 029Scenery Drive Harrisburg, Pennsylvania 17 09 (717) 657-4795 Attorneys for Plaintiff :.;-'( t~ r...-> ,-" c._ C) -n -' \? :'~~) UJ ,.,'+:'+:'+:'+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + + + + + . + + + . . . + + + + . . . + + + . + + + + + . . + + + + . + + . + + . + . + + . . . + + 'I' 'f + 'I' 'f 'f 'f.+ '+: ;+;;+;;1; ;I; . '+:'+:'+: 'f '+: '+:;1;'1' :+;;+;:f 'f 'f '+: 'Ii'+: '+:'+: '+: '+:;1; '+: 'f:f. '+: 'f '+: ,+::f.:f:+:;€,+: Of '+: ,+:'+di'+:;+;;+; '+: '+:;+;:+.:+: + '+: IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY STATE OF PENNA, CHERYL A. KURTZ, Plaintiff No. 2002-4788 (Civil T rm) JACQUE A. VERSUS KURTZ, + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Defendant DECREE IN DIVORCE AND NOW,~~"~ \ 2005 (\ IT IS ORDERE Cheryl A. Kurtz , PLAINTIFF, DECREED THAT Kurtz Jacque A. , DEFENDAN , AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA YET BEEN ENTERED; None. The parties' Property Settlement and Separation Agreement . . . . . . January 6, 2005 is herein incorporated, ..b):l~;;.? merged. , A / / . . . . . . .':--., . + ATTEST: ) + + + . . + + + + 'to,., +;,.,,.,,.,,., ~ PROTHON . + +i Of '+: +. 'f:+.Of'f,+:'f + +: +: '+: +: + Of +: 'f +: Of 'f +. '1':+'+:+:+:++:'1' . "'+."''+0 '+0 .. ;+; 'f;t; +;t; 'f 'I' +: T+ + . . . + . + + . . . . . . . . + + . + + . . . + + . . . . . + . . . . + . + . . . . AND HAVE NOT ated ARY . + . . . J. (~ff;/ .z i/r'" ?~!/o 9J 7..'/ ( '7w"'; fft-~ ~ qr:_1h4c P'P 91. '0 .