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Home My WebLink About96-03293 ~~~~~~~~~~~~~-~-~~~~~----~--~-~ , -~ -~~- - ~ ~ ~ IN THE COURT OF COMMON PLEAS 8 ~ 8 · OF CUMBERLAND COUNTY 8 . . i STATE OF _ PENNA. ; · 8 , , ,La:mIE [)~ LEREW,. II N o. .~~~.32.~.3.,.. C~y'g..r!1.rm 8 8 ... ,. , "". , pla,i.ntHf ."", .. '.' :: 8 ,. Vel~IIS $ $ [)IANE.J.LEREW, ....i . 8 Defendant! ' ij 8 " a ~ ~ : DECREE IN : ~ DIVORCE : ~ ANDNOW.~~,...~,~.,.... 19.~P... It Is ordered and ! III decreed that ......" .~~Ei .1:1., .If;1jE;\'! . , . . . . .. . . , , . . . . . " . . , . . .. plaintiff, ~ ~ 8 !'l! and . . . . . . D~~, J,. LE(l;:W. . . , . . , . . . . . . . . . . . . . . . , , . . , . . . . . . . . . '. defendant, r, " ~ . are divorced from the bonds of matrimony., w". ~, ... , 8 ~ The court retains jurisdiction of the following claims which have ~ ~~ been raised of record In this action for which a final order has not YElt $ been entered; ~ : ,..."....,."......."..~........."........,..,...,../...,.......,. ~ .~ ~ ... ~ .;> s . ~ , Alt..t:"'-\~/IC/ {l,t' ~ ~..~J. il~ . tQ~,t/~ ~~. #'if- -7 ':' ~ ~ 7 Prolho'H>lnry I ~ ~ ',' -----------,--,'. . " .,... '. '--. ....~ ' --~~--~~~~------------------~ /J '~3 Y"t- :.~t.I. d:~ Itui~ ~adj ~ /.~ '.)3 ~ 'A~~~ ,,~;~ Z: X2~. . . . ~ I~ ff. ~ ~ LONNIE D. LEREW, ) IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . ) v. . NO. 96-3293 CIVIL TERM . ) DIANE J. LEREW , . CIVIL ACTION - LAW . Defendant ) IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the fOllowing information, to the court for entry of a divoroe decree: 1. Ground for divorce: irretrievable breakdown under section 3301 (C) of the Divorce Code. 2. Date and manner of service of the complaint: CERTIFIED, RESTRICTED DELIVERY MAIL, #Z 364 505 325, August 16, 1996. 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 plaintiff November 22, 1996; by defendant November 22, 1996. (b) (1) Date of execution of the plaintiff'S affidavit requirea by section 3301 (d) of the Divorce code: ; ~) ~te of service of the Plaintiff'S affidavit upon the .. ~.. trefe~nt: ~ ~,~ ~ Related claims pending: r)t.-, ;1B".:a )~ :J u . NONE Date and manner of service of the Notice of Intention .. 1 - . . .. To File praecipe To Transmit Record, a copy of which is attached if the decree is to be entered: .6 - 2 - ~ CI f: I~ ,~ .- .. :5..C ~ u"'_ :c ~l~ 0.. -.; ':15-! \ ~" ~ lXJ :l !-I) ~~4 i!1 (.) I.d HIe? c a ~ <0 C1l "Ill >... _I", _~IE.~JWtiEW.__.___...__________._.___._ rn the COlin 01 CGIJ1IIIQn P1c:aa 01 Cumbcrland CoIlIIlY, PCIlIII'yh'Uia. Plaintiff ---------------------------------------..------ VI. N.l. 96-3293 CIVIL TERM --.....--------..----------- CIvil. 19..__.. DIANE J. LEREW ________________J_____________________--.____ _~~IL_~{Q~_~JJ\~._-..-...--__._________. Defendant ----.-----------------------------...--------- IN DIVORCE ------...... ___... . .. 0._.. ___._. _.____________._ -..--------------------...-----.-..----------------.-..---...-----------..--------------------------.- Sirl .- -.- .---.-------------------------------......- .....------------.- .. -.. '----------------------.- ....~!~!g~._~~!D~~~s_~_tb~.~o_~l@j~_t~_______.___________________..________________.____... -.-.------------------------.-------------------------------------------------------------------- .-----..--..-----------------...-------------.---....-------...-....-....-.--....--....-..--....-..--....---.. -------------....... ..--....-----.-.-..--- --.-....--- -----...... .-..........---..-.. .....-.... ...----... ---------------.--.. ----------.-------...------- ..-.............-...----. -- .-...-..----.-.... To --Lawranl"t.a. tJ.a.11r.a...____________._ ProlnOnotary .Tl'l~ "") '- --~---_... 19.!Ib._ ~ " E? . ~L ))\ . C<L -------------- John M. AtlOr.Iey for Plainliff, " ~^' .\ ). ,po .,.t f . ,.' ',I '} I rl' ":: 'J ) ,j" i.~ ..., or ". j . Ji.~" '. "Jo.' 't' . \, .i~r' ~ . . ; .. .~ ' I t . 'I ,t. :.t',' "v . ~r ~ I fl l'; t ,I. I, f r i I. I , , , I. ..~' \ ... ~ 'j'i,1 I i' ! " { I ;;" rill, I': , ~"" ~~ . " -....-. - .....~ ----.-.... -;:-- ....,... '::t ... Ul , -J to. c::: 1-: r-t!. "' , 1\ .. ' ., - , .~ ~ Q } :-. ." I ~. I (, . ;,.1, 'J ~ -;1 -! ::1 :;, . '~.. <..:> ~ '''' I,) l'v) 1".- -" l~ ~ ~ \'1 -., lid ~ .. I~; .:.1 .... "'j .u. It. HI I "" 01. 0 en () r;.,.. cJ ;~ .... ... ii J .. .~ ~ .. ~ I z j- ~~ ~~ 11 ~ ~ i. ~ = ~ ~ ' . . ~ I ~ P = I> . ~I I ~ .., I z ~ ~ ~ ~ q ~ IIJ = I ~, ~>- ~~i~ -f~i~ I ,0 :Z .~ .- i~ '0 : .:~ :~:Q. ~. , :- ~i : !:S : I Jtil '0 . s : : !U i : . .' .. .. 'l1' '" "'.. . . , : . 1 LONNIE D. LEREW, Plaintiff ) . . ) . . ) . . ) . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 910. .3J.c;l3 Ci....d /fa-Itl v. DIANE J. LEREW, CIVIL ACTION - LAW IN DIVORCE Defendant 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 b~ entered against you by the Court. A judgement 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 grounds 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, Cumberland county Courthouse, Carlisle, Pennsylvania. 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. Court Administrator One Courthouse Square Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 ,VL rn. t:~ L<- ohn M. Eak n arket Square Building echanicsburg, PA 17055 Attorney for Plaintiff . ~ LONNIB D. LEREW , ) IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . ) v. . CIVIL ACTION - LAW . ) NO. 9" ~.lJ9J (!,'ul {-rc~"7 DIANB J. LBRBW , . . Defendant ) IN DIVORCE COMPLAINT IN DIVORCE 1.) plaintiff is Lonnie D. Lerew, who currently resides at 42 East Locust street, Apt. B, Mechanicsburg, cumberland county, Pennsylvania. 2.) Defendant is Diane J. Lerew, whose last known address was 21 Rosedale, Hershey, Dauphin county, Pennsylvania. 3.) Plaintiff has been a bona fide resident in the commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4.) The Plaintiff and Defendant were married on January 21, 1989, in Cumberland County, Pennsyl.vania. 5.) There have been no prior actions of divorce or for annulment between the parties. 6.) The marriage is irretrievably broken. 7.) Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the Court require the parties to participate in counseling. 8.) Plaintiff requests the Court to enter a decree of divorce. - 1 - " .- . . . I verify that the statements made in this Complaint 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. ~~~ ~M~r- Lonn e O. Lerew Plaintiff Date: I"L~ ' 1996 e GvL n M. Eak n 1006351 rket Square Building echanicsburg, PA 17055 Attorney for Plaintiff - 2 - LONNIB D. LEREW, ) IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . ) v. . NO. 96-3293 CIVIL TERM . ) DIANB J. LEREW, . CIVIL ACTION - LAW . Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT LONNIE D. LEREW, heing duly sworn according to law deposes and says: 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed June 12, 1996. .; '~:. The marriage of Plaintiff and Defendant is irretrievably btoken and 90 days have elapsed from the date of filing the ,.Campl[aint. . r" '" '3'. I consent to the entry of a final Decree in Divorce. " l:; i 04. I understand that if a claim for alimony, alimony ~p.ndsnte lite, marital property or counsel fees or expenses has not b8en filed with the Court before the entry of a final Decree irt' Drvorce, the right to claim any of them will be lost. 5. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 6. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to ms upon request. 7. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce decree being handed down by the Court. 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. Sec. 4903 relating to false swearing. Dated: fforc.'Iljc>f. 22, J<j'l(, ~~~ Z;onn e D. Lerew, Plaintiff me 1996. ~ C\l i;; It) .. :.;i~ - r 8~ 5! :c a.. 'J~ ~ ..0 :S{'l "'. ffi ~~ ~ U life l>.J (I) Q ~ !l. ~ 0 . LO:NHl:E D. LEREW, ) IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . ) v. . NO. 96-3293 CIVIL TERM . ) DJ:AHE J. LEREW, . CIVIL ACTION - LAW . Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT DIANE J. LEREW, being duly sworn according to law deposes and says: 1. A Complaint in Divorce under Section 3301 (c) of the DivoJ'ceCode was filed June 12, 1996. If" ~, roo ' /",. f 2. ';the marriage of Plaintiff and Defendant is irretrievl\bly I,';brokliln and 90 days have elapsed from the data of filing the {Complaint; ~!; r-' ~:.3.J; consent to the entry of a final Decree in Divorce. 1 ;:4.': l: understand that if a claim for alimony, alimony ~enaente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to cl~im any of them will be lost. 5. l: have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 6. l: understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 7. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce decree being handed down by the Court. I verify that the statemenls 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. Sec. 4903 relating to false swearing. Dated: /1- .;?.;? ~ 91- A(Ja?t./ f ~ ) Df:~e J .t%erew, Def'endant Sworn and SUbscribed to befo>e me this ~ day of A,'Dl)<>n.,\?",. , 1996. -_......._._--~ ~ ~ ~ t:' .. ~~ I~ ;; 8 j; c.. ~~, ~ ~ ~ <J~ ~ ~ ~~ ~ \D ::J o Q"> U LONNIE D. LEREW, ) IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . ) v. . NO. 96-3293 CIVIL TERM . ) DIANE J. LEREW, . CIVIL ACTION - LAN . Defendant ) IN DIVORCE WAIVER OF NOTICE OF INTENTION '1'0 REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I ccnsent to the entry of a final decree of divorce without notice. . . : ~2. I-understand that I may loae rights concerning alimony, i "ll!vision ot, property, lawyer's fees or expenses if I do not , 1.'._ .' 'claim them before a divorce is granted. I' . to'. 3. I understand that I will not be divorced until a divorce t' .". .' 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 any false statements herein are subject to the penalties of 18 Pa.C.s. 4904 relating to unsworn falsification to authorities. Dated: ~E'CE""dl6<.. /7. 199(, ~j.~ Lonn e D. Lerew, Plaintiff ~ Q ~ ~ If fil CJ~ :l: (J2f:: u.. t.:\;,i: B: Cl:) s~ - l.t.. W I:il~ ;J;. LLJ C"J -.. I-" Cl ~ It. ~ 0 LONNJ:1l: D. LEREW , ) J:N THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PEHNSYLVANJ:A . ) v. . NO. 96-3293 CJ:VJ:L TERM . ) DJ:AHE J. LEREW , . CIVJ:L ACTION - LAW . Defendant ) IN DIVORCE WUVEa OF NOTICE OF INTENTION TO RHQUBST ENTRY OP A DIVORCE DECREE UNDER SECTION 3301(0) 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, t'"1 ~ivision of property, lawyer'S fees or expenses if I do not claim,~hem 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 oopy of the de~ree will be sant to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. J: understand that any false statements herein are subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: I:J. 11- 9ft, ~j~ ane J. &6rew, Defendant I c ~ M & "" .;J :;; O. :It: (J.r,. Q.. o~ I~ -, 00 ~: -.)' - _-1:-:1 if W ffife Lt., c .... lI. \0 ~ 0 0' ,', t LOHHIB D. LBRBW , ) IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA ) v. . NO. 96-3293 CIVIL TERM . ) DIAHB J. LBRBW , . CIVIL ACTION - LAW . Defendant ) IN DIVORCE CERTIFICATE OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) JOHN H. EAKIN, being duly sworn according to law, deposes and says that he served a true and correct copy of the Complaint in Divorce filed to the above term and number on the Defendant, DIANE J. LBREN, 21 Rosegarden Avenue, Hershey, PA 17033, by certified mail, restricted delivery, Item #Z 364 505 325, on August 16, 1996, and the return receipt card signed by Diane J. Lerew was received for said certified Item #Z 364 505 325 as shown by receipt for certified mail and return receipt card attached hereto. ;, , .. ~' - ,:,"m:'.l'~n Z 36'1 50S 3i!S Receipt for Certified Mail No Illsu,anco Covor.l\JU Pluvldotl 00 flol Will 1m InllllllllllOlllll MUll ISOll AOVOfSO) ~ '" - 11 ! g llD M ! :e " . f" .; , " Avenue /ll'I"",II",.""t',!."".I".1 I"WI",.,.", UJl" [.It,,,,,,,,',l f;"l"jt' II.., "'1,1 ~,I"l\"'''111U W"",,, (J,ll". ,1',,110,1<1""'" I'; '.Hlll h.,q, ....fr'" PO'trl',I'~ r!l t' r I i""l i " V''':'';.~'"::i;:''' ;,,'l.,.. ilojl"'_'tIor~I",',~'I'i" 1'",' LI'.~"""'3'iInd..a"'I:"-'I':" ,.'" III I k. .;;=~= ::'ICSdfI, lIonthl revtfHOftN"Ofm~,thJ.,w,.on i~' -. ,'AttKh INe toml to tht front.r ~ ml6lpttct, or an lhI back If.,... ,_not........'" il: ~r~~:w-:;:=:::-~"::= 2. 'lK.R..trlcted Dellv.ry I 8 ._.. ",'"," Con..6;; .tm..", 10' I... '1,,13' Anl.1e AddrHUd to: ""Z ~~%' ~osbe:hs : . Diane J. Lare" ,. .b. 8.rvl.. Type , 21 . Roeesarden Avenue D,R.gl."red D Inlurod Hersney ,PA 17033 III C.nlfl.d D COD D Exp.... M.II 7, D.t. 01 D.llve.y , I ,II.~ "'!.~, \0 "lCoI~. tho 10lloWlng ....,1... II., 'an ""1 fHI: . 1. D Add........Add.... ADDIUlSSEE ONLY 1: I J 10' i ! l ,oqu..tld J 8. Add...... .nd ,.. f. p.fdl gn.w.. IAv.ntl ! J.. Form .n, D-*' 1\ ..,.1. Gl'Q '_714 DOMESTIC RETURN RlCElPT n' ~ j~'1 .- '" ~ ~ al ~ '~-\. In 1-- " 12 ~~ r Q~ * ..., ~ Ll<t I O....'j .~- '1 (') ~'... n ..:'I~ co H;ii5 w fl.IU. u.. ~ 15 r- ei' 't ~j J I " .~ " z I ~ ; ;fi1 ~ ~ ~ I . g . . ~ p .., Q I z " ~ z . Ii m ~ ~ q ~ Q OIl ; 8 I . '. it . CffD - 3;1. q3 ~ T..vv..- MARRIAGE SETTLEMENT AGREEMENT THIS MARITAL SETTLEMENT AGREEMENT made this ). 2. day of ~ 1996, by and between DIANE J. LEREW ("WIFE") of Derry ~nJhiP: Dauphin County, Pennsylvania and d'",W:.-.,~ , (9-4~,- -I.v C1-f?"'-'''s.. "'~ ,..Q..J "'-,, . --r.:A.~ .>>t.. d.. J- LONNIE D. LEREW ("HUSBAND") of the Borough Cumberland County, Pennsylvania WITNESSETH, WHEREAS, HUSBAND and WIFE are lawfully married; and WHEREAS, differences have arisen between HUSBAND and WIFE, as a consaquence of which they have separated and intend to live separate and apart from each other; and WHEREAS, HUSBAND and WIFE desire to settle and determine for all time their rights and obligations one to the other,. NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree as follows: 1. It shall be lawful for each party at all SEPARATION: times hereafter to continue to live separate and apart from each other in such place as he or she may from time to time choose or deem fit. 2. DIVISION OF CERTAIN PROPERTY: A. Personal Effects. Vehicles. Household Goods and Furnishina: The parties have divided between them to their mutual satisfaction, all personal effects, household goods, - 1 - furnishings, and all other items of personal property inoluding bank accounts which have heretofore been used in common by them, h :t i: , . , , , and neither party shall make any claim to any such items which are now in the possession of or undsr the control of the other. B. Pension. Profit SharinQ and EmDlovee Benefits: All psnsion, profit sharing and employee benefits and retirement accounts, if any, in WIFE's name or provided by WIFE's employer shall be and remain the sole and separate property of WIFE. All pension, profit sharing and employee benefits and individual retirement accounts, if any, in HUSBAND's name or provided by HUSBAND's employer shall be and remain the sole and separate property of HUSBAND. C. Life Insurance Policies: Any policy insuring the life of a party shall be the sole and separate property of the insured and the insured may name such beneficiary for each such policy as he or she desires. :! J ,. !' i: I. i' J ~ ~ I . D. Debts: Each party represents to the other that neither will incur any indebtedness which obligates the other party and that all joint credit cards have been cancelled. It is agreed HUSBAND assumed the obligation to pay the following accounts following separation: Boscov credit card, First Card, First of America credit card, First USA credit card, Montgomery Ward charge card, Wanamaker charge card, Mellon Bank line of credit, Holy Spirit Hospital medical bills, B. Lerew personal loan and F. Lerew personal loan. WIFE agrees to pay the Choice credit card account and Gensbigler dental bills related to Jessica zidik. It - 2 - is agreed the personal loan made by F. Hickey has been cancelled. 3. ALIMONY: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. HUSBAND and WIFE further voluntarily waive and relinquioh any right to seek from the other any payment for alimony. 4. CUSTODY. VISITATION AND SUPPORT OF CHILDREN: A. The parties are parents of ZACHARY LEREW, born June 5, 1989, and HANNAH LEREW, born Marcr. 22, 1991. It is agreed the parties shall have shared custody of the children. During the school years they shall live with WIFE and during the summer they shall live with HUSBAND. B. The parties shall make, execute, acknowledge and deliver all documents necessary to have a consent support order entered by the Cumberland County court in the form attached hereto ae Exhibit A. C. Each party shall have liberal visitation privileges during the period the children reside with the other party which shall be agreed upon from time to time. If the parties cannot agree, either party may seek court intervention and the subsequent Cumberland County conciliation procedure. - 3 - D. The parties shall confer with each other and cooperate in making decisions which relate to the physical and emotional well being of the children. Each party shall be kept informed as to all matters pertaining to the condition of the children. Each party shall encourage the children to honor the other party and shall not alienate the child from the other party. 5. INCOME TAX RETURNS: The parties shall file a joint state and federal income tax return for 1995. It is agreed the HUSBAND is entitled to the refund, if any, and WIFE agrees to execute the tax returns and refund checks when requested to do so by HUSBAND. starting in 1996 and in each subsequent year that HUSBAND pays support for his daughter, Hannah Lerew, he shall be entitled to claim her as a dependent for income tax purposes and WIFE agrees on request, to make, execute, acknowledge and deliver all documents required by the Internal Revenue Service to permit HUSBAND to claim an exemption for sa~d child. 6. MUTUAL RELEASE: HUSBAND releases his inchoate intestate rights in the estate of WIFE, including the right to take against her will, and WIFE releases her inchoate intestate rights in thR estate of HUSBAND, including the right to take against his will, and each of the parties hereto by these presents for himself or or herself, his or her heirs, executors, administrators, or assigns, does remise, release, quitclaim and forever discharge the other party hereto, his or or her heirs, executors, administrators, or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits of - 4 - law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to be done by such other party prior to the date hereof; except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement and shall in no way affect any cause of action in absolute divorce which either party may have against the other. 7. DISCLOSURE OF PROPERTY: HUSBAND and WIFE acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the parties and, further, that the HUSBAND and WIFE voluntarily and intelligently agree to waive any rights which they may have to receive an inventory and appraisement of all property owned or possessed by them either jointly or individually, at the tim~ of delivery of this Agreement or of the commencement of any action in divorce. e. FUTURE ACOUISITION OF PROPERTY: Each party may acquire property subsequent to the date of this Agreement in his or her name and it shall be the sole and separate property of such party free and clear of any claim by the other that it constitutes marital property. Each agrees to execute releases which may be required to waive his or her claim to all after acquired property by the other party. 9. VOLUNTARY EXECUTION: The provisions of this Agreement are fully understood by both parties and each party acknowledges - 5 - LONNIB D. LEREW, ) IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . ) '1"-:3;L q '3 Ovv<.t /991 v. . NO. . ) DIANB J. LEREW, I CIVIL ACTION - LAW Defendant ) IN DIVORCE PINAL ORDER OF COURT .-~- AND NOW, l1. ordered that the Defendant Payor pay 0 e D mest 0 Relations Section, Court 01' Common Pleas, Eight Hundred ($400.00) Dollars a month payable semi-monthly on the first and sixteenth day of eaoh month oommenoing HtltllZ'... I , 199~.; for the support 01' Zaohary Lerew, born June 5, 1989 and Hannah Lerew, born Maroh 22, 1991; a oredit is granted the Payor 01' Eight Hundred ($800.00) Dollars a month for the period from June 15 through August 15th of eaoh year that the children reside with him. Said money to be turned over by the Domestic Relations Seotion to Diane J. Lerew. Payments may be made by cash, oheok or money order. All oheoks and money orders must be made payable to Cumberland County Domestio Relations Office and mailed to that office at P. O. Box 320, CarliSle, PA 17013. Each payment must bear your Domestio Relations (DR) number in order. to be processed. Do not send oash by mail. Unreimbursed medical expenses are to be paid 50% by Defendant and 50% by Plaintiff. Defendant to provide medical insuranoe coverage. Within 30 days after the entry of this order, the Defendant shall submit to the person having oustody of the children written proof that medioal insuranoe ooverage has been obtained or that applioation for ooverage has been made. Proof of ooverage shall oonsist, at a minimum, of: 1) the name of the health oare coverage provider(s); 2) any applioable identification numbers; 3) any cards evidenoing ooverage; 4) the address to whioh olaims should be made; 5) a description of any restriotions on usage, such as prior approval for hospital admissions, and the manner of Obtaining approval; 6) a oopy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE - 1 - Exhibit A ADMINISTRATION OF TilE SUPPORT ORDER, INCLUDING, OUT NOT LIMITED TO, LOSS OR CIIANGE OF INCOME OR EMPLOYMENT AND CIIANGE OF PERSONAL ADDRESS OR CIIANGE OF ADDRESS OF ANY CIIILD RECEIVING SUPPOR'r. A PARTY WIIO WILLFULI,Y FAILS 'J'O REPOR'!' A MA'l'ERIAL CIIANGE IN CIRCUMS'l'ANCE MAY DE ADJUDGED IN COtlTEMP'l' OF COUR'l', AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THA'r ALL SUI'PORT ORDERS SIIALL BE REVIEWED AT LEAS'r ONCE EVERY 'l'IIREE (3) YEARS IF SUCII A REVIEW IS REQUESTED BY ONE OF TilE l'AU'rIES. IF YOU WISII TO REQUEST A REVIEW AND ADJUS'l'MEN'l' OF YOUR ommn, YOU Mus'r VO TilE FOLLOWING I AN UNREPRESENTED PERSON WIIO WAN'rs TO MODIFY (ADJUS'l') A SUPPORT ORDER SHOULD A MANDA'l'ORY INCOME A'l"l'ACIIMENT WILL ISSUE UNLESS TilE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTII'S UUPPORT OBLIGATION AND (1) TilE COURT FINDS TIIAT TIIERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITlUIOLDINGi OR (2) A WRITTEN AGREEMENT IS REACIIED BETWEEN TilE PARTIES WHICH PROVIDES FOU AN ALTERNATE ARRANGEMENT. DELINQUENT ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER TilE DATE IT IS DUE, EACII UNPAID SUPPORT PAYMENT SHALL CONSTITUTE A JUDGMENT AGAINST YOU. IT IS FUR~IER ORDERED that, upon Payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing to $ a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Copies delivered to parties /3 t--:e b '17 t ~ ff ~~'.tf) ~ Defendant j){tti/[ Defendant's Attornay / / BY \IIE COU (/ . J ~)/ / ~ lA/\ J. - 2 - Exhibit A