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NOW, THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed an essential pan hereof in consideration of the foregoing recitals, the mutual promises, covenants and undenakings herein set fonh, and for good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVlCE OF COUNSEL HUSBAND and WIFE declare that they have each had a full and fair opportunity to obtain independent legal advice of counsel of their selection, WIFE has been independently represented by Barbara Sumple-Sullivan, Esquire, HUSBAND is cognizant of his right to legal representation and declares that he has been independently represented by Max Smith, Jr" Esquire. Each party further declares that they are executing this agreement freely and voluntarily. having obtained such knowledge and disclosure of they legal rights and obligations and that they acknowledge that this agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion, 2. PERSONAL RIGHTS HUSBAND and WIFE,may and shall, at all times hereafter, live separate and apart, Each shall be free from all control, restraint, interference or authority, direct or indirect. by the other in all respects ~, is she or he were unmarried, except as may be n~essary to carry out the provisions of this Agreement, Each may reside at such place or places as she or he may select, 2 " , 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, This provision shall not be taken. however. to be an admission on the part of either HUSBAND and WIFE of the lawfulness of the causes which led to. or resulted in. the continuation of their living apart. HUSBAND and WIFE shall not molest. harass. or malign the other or the respective families of each other. nor compel the other to cohabit or dwell in any manner with him or her, nor in any way interlere with the peaceful existence, separate from each other, 3, DEBTS Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable except as otherwise provided herein and that except only for the rights arising out of this Agreement, neither party will hereafter incur any liability whatsoever for which the other party 'or the estate of the other party will be liable, Each party agrees to indemnify and hold hannless from and against all future obligations of every kind incurred by them. including those for necessities, Additiona\1y. WIFE agrees to be solely liable and responsible for the following marital debts. This specific indemnification shall include but nOI be limited to the following creditors: 1. UGI Federal Credit Loans $1.674.32 2, Hechingers 360,70 3, Home Depct 180.92 -- 4, Added Dimension 444.30 3 ~ the panies does hereby specific:ally waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to any of the above said items which are the sole and separate property of the other, This document shall constitute a bill of sale for said sole property, 6. REAL ESTATE WIFE owns real estate at 721 Walton Street, Lemoyne, Pennsylvania. Said house is encumbered by equity lines of credit with Dauphin Deposit in the amount of $54,817.58, As indicated in paragraph 3, WIFE shall be solely responsible for these debts. HUSBAND agrees simultaneously with the execution of this Agreement, to execute a Quitclaim Deed releasing any rights, title and interest to said property which he may have. 7, MOTOR VEHICLES HUSBAND shall have sole title and possession of the parties' leased 1996 Mercury Sable and indemnify WIFE against any obligation on said lease. WIFE shall have sole title and ownership of the parties' 1989 Ford Escort, Both panies agree to cqoperate to execute all papers necessary to effectuate the transfer, Further. HUSBAND agrees to execute all paperwork necessary to transfer full title of the 1987 Chevy Cavalier to its rightful owner, WIFE's daughter, Michele, --, 5 .. or courtesy of widow's or widower's rights, family exemption or similar allowance, 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 participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, commonwealth or territory of the United States, or (c) any other country, or and rights which HUSBAND or WIFE may have or at any time hereafter have for the past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except. all rights and Agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators and assigns, that he or 'she will never. at any time hereafter, sue the other pany or i.~ or her heirs, executors, administrators and assigns, for the purpose of enforcing any of the rights relinquished under this paragraph, Each of the parties further covenants and agrees that he or she will pennit any will of the other to be probated and allow administration upon his or her personal, real or mixed estate and allow effects to be taken out by the person or persons who would have been entitled to do so had HUSBAND or WIFE died during the lifetime of thi other. Each of the parties hereby releases, relinquishes and waives any and all right to act as executor or executrix or administrator or administratrix of the other's estate. 10 .! '. , , COMMONWEALTH OF PENNSYLVANIA COUNTY OF '1::vJ,tlt j~ ) ) 55, ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared JOHN E, SHAFFER who being duly affirmed according to law, deposes and says that the facts and mailer set forth in the within and foregoing MarItal Settlement Agreement Jre true and correct to the best of his knowledge. information and belief, (l/(/? JOHN YSfrAF{j , )ffirmed and subscribed to before me this -;,'/ day Of~~,~ 1997. ~"~L. ~...~ R.cIl""R.~rI.ISa.1 ~~ _ Sll~lJth.nn reiber, Nolaty PuOIIc NOrA Y PUBLIC MYCommjWo'/~..~~Coynly .m 1,1997 r, .nnlYlVlm. 'OC. on 0 0 I. My commission expires: (SEAL) COMMONWEALTH OF PENNSYLVANIA ) ) SS, COUNTY OF CUMBERLAND ) Before me. the undersigned officer. a Notary Public in and for said Commonwealth and County. personally appeared YOURLANE J. SHAFFER being duly affirmed according to law. deposes and says that the facts and mailer set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of her knowledge, information and belief, ~J 4/JU1 fl,,jj, f/;1} URLANE J, 5Pf'AFFER ,CJh day of -::in~, 1997, My commission expires: (SEAL) , NOT,.RIM. SEAL , \ &eIbA" SUlnp4t.SuIl1v1n, Notory p~c . rtand 8ctO Cumber'l" . a New Cumbe bpI'"~ Nav, ,~, Hl99 My Com~"tOn 14 oC 1Il.r. 0 oC:> 0 H ..1~ l>: .... .... ... 041 :z 0. III .... C UUE-<11 ~ ~ :z '... III tLl 10-' :z Eo-4 :zZ ... 'tl l>::>I1Z 041 C C l>:IIlH ... :Eo. '... .OJ E-<I1Z ~ :E III 1>:.... HIIlOt... 0 '3: ..... 41 OJ :F. UO Q ., U)<oC 0. t...O tilt... '" ~ Z E-<.J t... ZOt...11 E ~ ., t...z I>: 0( oC ou >< ;. 0::> I 41 :c l>:11 H C E i oJ 0 t... III E-<E-<IIl"" >- E-<UZ oeE-<o ~ '" r... 0( ~ 0 z .... l>: 0 ..; OUhZ ..lV'J .. Z N 0..,41 :c .., E-<H:> I!: '" OZ....U oe III ;. I1r...Or... 1fi ,: ... UoCUI>: ~ o.HHO I ..1<0 E-< '" ""l>:r...tIl ::lE '" '" l>: :> iii < ffi '" :C11..J'" ..1 Ulilr...", < E-<lXlHC Z I>: I1U<11 ... :>: . :E:> :>: ::> < :> C Z::;'H:2 0 0 l>: .., Z ...UU... .., )< 0. < c- -' ..~, ~" ...... ,,...,. . .:, { , ' , ~~...~ "---..;.~ ---........ JOHN E. SHAFFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-2787 Clvi.l T<:>rm YOURLANE J, SHAFFER, Defendant CIVIL ACTION - LAW IN DIVORCE " ;. r PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infor- " II' mation, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown llnder Section (x) 3301 (c) ( ) 3301 Cd) of the Divorce Code. (Check applicable section). 2. Date and manner of service of the complaint: " " bv certified m~i I on M~y 7q lqQ~ ,,' 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plain- tiff ~Janl]iiry 11 1 QC;7 ~ by Defendant January 10, 1997 (b) (1) Date of execution of the Plaintiff's affida- vit required by Section 3301 (d) of the Divorce Code: ; (2) date of service of t~e Plain- tiff's affidavit upon the Defendant: , i I i, I 4. Related claims pending: None . II};;; ~ A~Orney for (x) laintiff ( ) Defendant , , ~ \,:; I . R-0 -~ ......... .......... '\ iJ.r-:::, .~ ~ ~ C'\~ - - '0 < CI):Z << ILl> .J~ r:l.CI) :z:Z 0:Z EILl Er:l. o -3: U:>O< to..~.J 001 o E-<U:Z IX 0 OO....t.l 8~t~ 1Ll.J<O :c!:l.J> E-<lll....~ E> :zO....Z ....UUH ~~~ G:-~<t' '~ l'" ~ v<::l ~~\r"'\' o ... ... '"' '... c '"' 10 ILl C 'tl U '... C IX It\ 'IV 0 ~ IX'" > ~' ~ r:l. t.l IV .... IX to. 0 0 to. i:ll: ILl 0( :z :J ~ to.. ::c to.. Ul .... ",Q < . <II ... t.I ~ ~ ~ :c . :z CI) > .., ~E ~ ~ .... . t.l < .J is ~ ILl :z r:l. .:i ~ 0 ~ 0( E :z ..J 0 V) .; "- :c IX U . It: 0 :J ~ i .., 0 >- ~ :: " JOHN E. SHAFFER, Plaintiff VB. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- VJ'lCivil Term CIVIL ACTION - I~W IN DIVORCE YOURLANE J. SHAFFER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU "AVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt ar.tion. You arp. 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 marriage, you must request mar- riage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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 Gr.T LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4th FLOOR 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 3387 (717) 240-'j200/ ') , " 1/ , ;-1--,( '. I I ,\ ~ f~' (.' ,.'/ j' " .. MAX J. SMITH, J ., Esqu re Attorney for ~laintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 HI.111"''oINll c:cJllINONWIALTH DfI ,.,..n... DlI'MT"NT DfI HlAlTH vtTAL. ...CCNIIlDI Cumberland DlVORCI []I RICORD OF OR ANNULMINT (CHECK ONE) 0 ITATI ~L.1 NU"'II" COUNTV ITATI 'ILI DATI HUSBAND , NAMI (Fl1'If) John I-, E. IL"~ Shaffer DATI 0< IlRTH . OW:I 0< ",ATH 7 USUAL oceu~TION 'SlaM Of FOtWfItI Counf1)') Pennsyl vania . I-I 09 (o.y) ,"r 18 1963 3 RISIDINCE 382 N, $".., 01 R.O C/')i 8on:I. Of JIt'/iI ~liddlesex Road, Carlitde, Courll)' StaM Cumberlarld, PA 8 NUMII" (W THIS MAJII..IAOE I RACI WHITI .LAC' QTHER fSotdtvl 1 ~ 0 0 WIFE (FIfI') ,AlHJdMI Yourlane ,1. Salesman . MAIDIN NAMI Twigg 10 AlBIDINeE 1- Shaffer DATI 0< IIRTH 11 PlACl 0< BIATH 14 USUAL OCCU""TION .,.- PA (S,." Of FOfW(Jn Country) Pennsylvania . (Mont'" 10 ro.y) 'Nt 13 1955 721 $,,.,,,,,/tO Walton St., elf)!. 801'1), OfJlt'/il Lemoyne, eoun". Cumberland, 12 NUMIIA Of 1HIS MARRIAGE . AACE WI-UTE 2 IRJ BLACK o OTHIR {Speclfyl o Manager " (Mon''') 10 (Day) 22 I_I 1989 18 PLACI 0' (County) noms MARRIAOE 11A NUMB.R m CHILDREN THIS MAFtAIAGI 0 Las Vegas, 178 NUMBER cw OEPINDINT CHILDREN UNDER 11 o (St.,. or Frn~ft Country) Nevada 18 PLAINTI" HUSBAND WljrE I!J 0 OTHER rSoec:ltyl o " DATE CW THIS MARFUAOIE DleREl ORANTlD 10 HUSBAND WIFE ~ o OTHER ISpeclfy) o .. NUMB.A OF HUSBAND WI1E SPLIT cus100v OTHER ISf)Kityl CHILDAEN TO 0 0 0 CUSTODY m N/A .. CATI Of OleFIn (Monrh) (0.1') "..." " SIGNATURI 0' TAANBCAIIiNG CLlAK 21 lEOAL GI-\OUNOS FOR OIVOACE OR ANNULMENT Irretrievable DAn RIPOFlT SENT (AIon"') 10 VITAL AlCOROS breakdown (0....) ('liar) '" JOHN E. SHAFFER, . , IN THE COURT OF COMMON PLEAS . Plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA I v. . NO. 96-2787 Civil Term . I YOURLANE J. SHAFFER, I CIVIL ACTION - LAW Defendant . IN DIVORCE . AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301 of the Divorce Code was filed on May 20, 1996. 2. The marriage of Plaintiff and Defendant is irre- trievably broken, and ninety days have elapsed since the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Di- vorce. 4. I have been advised of the availability of mar- riage counseling and understand that I may request that the Court require that my spouse and I participate in counsel- ing. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advisod, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Di- vorce without further notice. , , ~. 1 t,. ~ .. lJ,1 . (,) 'I r" " , l i/( - (,~ i-' L~ I G: I , ~ I , J (,- , , - , ': " ',' ,', , , ~ , ' , , ~ " JOHN E, SHAFFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, No, 96.2787 Civil Tenn YOURLANE J, SHAFFER, Defendant CIVIL ACTION, LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ms.TRY OF A DIVORCE DECREE UNDER 1J30Hc) OF THE DIVORCE CODE \, 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, J. I understand that I will not be divorced until a divorce dec;ree 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 made herein are subject to the penalties of \8 Pa,C,S, ~4904 relating to unsworn falsification to authorities, , ' , :1 DATE: /- 1- 97 '1.lrulMl1c ~ .'Iil~ YPURLANE J. HAPPE ,I I j.-. l1.1\ (', ' [{; ~:,~ 1-: I:' ~ II.,' I,.. I " ',' -,. r~,. ; ,.; ,>> , , ~,~. I ~ " , , " \ , l.: , , , .. " " , " " " , , , , , , '" , ~ ,... ',. - I.~; , (;; ;~ !~ ~ :t; .J. ~ n.. r~ j::; c' C'? 'it) " ).~ fi.!:~, - -. Jfe lr:~ .'~ i!-: Co) t5 <n :'5 (I' t..) .', , ~ R ~ ~ ~ ,. ~ li l, " I , -'. '" , 01" " , " I'. , , il. 1-"' , , 'I'. . . . .' . . . . .. . .. " .. , .. , . II 'Ii " I ~OHN E, SHAFFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYI,VANIA " !i v. No. 96-2787 Civil Term I i ~OURLANE J. SHAFFER. Defendant CIVIL ACTION - LAW IN DIVORCE :1, " I' CERTIFICATE OF SERVICE I. BARBARA SUMPLE.SULLlV AN, ESQUIRE. do hereby certify that on this date. " r I served a true and correcl copy of Ihe PRAECIPE TO ENTER APPEARANCE. in the above- I , captioned mailer upon the following individual{s). by United Slates firsl-c1ass mail. postage ~repaid. addressed as follows: ! !. Max J. Smith. J~., squire ' James. Smith & rkln P.O. Box 0 .... HarrlsburK,' p~,/~n. s . MI.. ~~3,'06(SQ. / ~vO/ " Aarbara sum~I:~S~~:'ESqU~ _____. 549 Bridge Street New Cumberland. PA 17070-1931 (717) 774-1445 Supreme Courtl.D, 32317 Allorney for Defendant !: ii . PATE: lime 13. 1996 I, :1 " I' I ! ;\ , " ! , ' i 2