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HomeMy WebLinkAbout00-00724 -' . -J'~' ,. ,;_'^-~ , ~ -,---'"" ~ _L ::'C,. ~:.<<():..::~;:-X.::(:::!>>::~,::XC{::,.::.::~;:: ):..:x :::~:'C~;::::~:'C:{:::!>>::~~;:)::.::.;::):'.X:,;~>>::~;:: :::~:..::~;:: XC<X.::(:::~::.X:::!::c~{ ):'<<~;~':"JXC~f~~:.c€,~>>~H'~::.>H~>>>t~::!::C~~:::::~at~;;::::~::~r:K"'A,::'!~ ~ r 1 ~ '",. ,<\ ~ ~ ~ , ~ ;.; ~ ~ !t.~ ~ ~ k'~ ~ ~.~ , ~ !".~ ~ ~.~ * ~ ~ ~'s * ~ ~.~ i4 ;i ~.~ ~ ~~~ ~ ".~ ~.; ~l . ~.~ ~~ ~ ~ ~~s , ;.~~ .. ~.~ ,~", ~ ~.~ 'v' ~ ~.~ ",.." ~ ~.~ il ~~ ~ ~.~ ~ ;..; ~ ~.; ~ tli ~ f-": ~ A .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF CAROLINE E. SAMPSON Plaintiff Versus nRAYMOND,.A. _SAMPSON""" Defendant PENNA, n...nn.. I .. II I N O. n.~Q.Q.Q...:::n}2 4...~;!:.Y.;u.19 DECREE IN DIVORCE .. .~.~.......... ,xk9. 2.0.QO, AND NOW, it is ordered and decreed that.. . . . .. . . . . .~~~9)l..I.I:\!~. ~.'. .1?N'l.~1i9~. . . . . . . . . .. .. . " plaintiff. and . . . . . .. . . . . . . .. . . R1Wl:19N.Q .~.. ..~l)J':1fp.Ql':l. . . . . . . . . . .. . . . . . " defendant. are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of resor5!.!n..!his action for which a final order has not yet been entered; ~ AND IT IS FURTHER ORDERED, that the terms, conditions and c:<?;:e?:il:r;t~:,. .E!e;~. .~C?~t!'. .~r;t. :t.~~. :":r.~ 1;.~~? .~~?)?e:~'!:Y. .~~~:t.l.~~~?t: .J?<,r:r.~~~~?t maue and entered 1nto by the parties on October 9, 2000, are incoLpora~ed.into.thi5.Decree.by.~efererrc ~ e~o,.hut.no~.merged into t is Decree. ; ~.~ ~ ~ ~ ~ I ;<aE(::,;.z.>.:::... ~ Prothonotary ~ .:.:,.::,:::>:,+::.,::::.::.:., ::--:::+::(::::.::+::,,:::::,:'.::.' _..':'+::." ,:.::.::< -":'.;". .,.::.::.;' ~ :.:..::~::: :,~:'.::..'- ':,.:.::.,~ ..':'.::'"," .:'.::., -'''::.:.'' ~ ~.~ ~ ~.~ ,'s ~ is * ,;, ~. ~ ~.~ ,'s ~ ~ ;.~ ~ ~.;: ~ $ ~ ~ ~'s * ~.s * ~~ ~.~ ~ ,~~.", ~ !".~ ~~~ ~ \.", W H i ".~ '". "~'l ~ ~.~ N ~ i !t."#. i ~.~ ~ ~.J ~ ".~ ,.s * ~ ~.l ~ ~.~ ~ ".~ ~ ~.~ ~ ~.~ J. ~ ~.~ ~ '.' ~ '.' ~ '.' ~ ... . IfC/m /f- 1 t:?pt '--!~- - ~ ~:p- . a/. ~ fl4dk --$ 4 ~ /1~ ~ 0 ~~ ... . , , ""'0'_............. ~~ _ ~~ ~""~., _ i ~ ~"'!.IlI J "~ ~r! ( .' . I fj 1C./;2. ~ Caroline E. Sampson Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW Ravmond A. Sampson Defendant NO. 2000 - 724 Civil Term DOMESTIC RELATIONS ORDER This Order is made pursuant to State domestic relations law and relates to the provision of marital property rights to the Alternate Payee who is or was the spouse of the Participant. This Order creates or recognizes the existence of the right of the Alternate Payee to receive a portion of the Participant's Deferred Compensation. 1. Definitions For the purposes ofthis Order, each term below has the meaning stated by this part. "Administrative Service Agency" means Copeland Associates, Inc. or the other person contracted by the Plan Administrator to provide services regarding the Plan. "Alternate Payee" means Caroline E. Sampson, 401 South College Street, Carlisle, PA 17013, who certificates that her Social Security Number is 202-36-5701. "Order" means this document when properly entered as an Order of a court having jurisdiction over both the Participant and the Alternate Payee. "Participant" means Raymond A. Sampson, 1473 Lutztown Road, Boiling Springs, PA 17007, who certifies that his Social Security Number is 199-34-8360. "Plan" means the Deferred Compensation Plan for Officers and Employees of the Commonwealth of Pennsylvania. "Plan Administrator" means the Pennsylvania State Employes' Retirement Board, an independent administrative board of the Commonwealth of Pennsylvania. "Separate Plan Account" means the sub-account of the Participant's Plan Account that the Plan Administrator causes to be maintained for the benefit ofthe Alternate Payee consistent with this Order. All other capitalized terms have the meaning provided by the Plan. j'- . -,' ~" -~ DRO Page 2 ~ , 2. Division of Deferred Compensation The Alternate Payee hereby is awarded an interest in the Participant's Plan Account. Upon the Plan Administrator's determination that this Order is a Plan-approved Domestic Relations Order, the Administrative Service Agency shall set apart 100% ofthe Participant's Plan Account as of the date that the Administrative Service Agency determines that the executed Order constitutes a Plan-approved Domestic Relations Order and direct that amount into a Separate Plan Account for the Alternate Payee. After the division provided by the preceding paragraph, the Plan's charge ($250.00) for the Plan Administrator's expense in processing this Order shall be charged against the Alternate Payee's Separate Plan Account. During the period after the Alternate Payee's Separate Plan Account is established and before a distribution is payable, the Alternate Payee may direct the investment of her Separate Plan Account according to the Plan's provisions and procedures. The Alternate Payee's Separate Plan Account shall not receive an allocation of any contributions or credits made by the Participant or any employer. Upon the Participant's death or Separation-from-Service, the Alternate Payee shall become entitled to a distribution of her Separate Plan Account. The Alternate Payee may elect any distribution and Payout Option that meets all requirements of the Plan. Not later than 60 days after the date that the Alternate Payee has notice of the Participant's death or Separation-from- Service, the Alternate Payee shall file with the Administrative Service Agency a written claim that includes the Alternate Payee's irrevocable election of her Distribution Commencement Date. Not later than 15 days before the Distribution Commencement Date, the Alternate Payee shall file with the Administrative Service Agency her irrevocable election of her Payout Option. The Participant is ordered to furnish to the Alternate Payee a written notice of the fact of his Separation-from-Service not later than 5 days after the date of the Participant's Separation-from- Service. The Participant is ordered to keep a copy of this Order together with those personal papers that he sets aside for his personal representative or family to find upon his death. The Participant's personal representative is ordered to furnish to the Alternate Payee a written notice of the fact of the Participant's death not later than 5 days after the date that the personal representative has knowledge of the Participant's death. Any rights not paid before the Alternate Payee's death shall be payable to the duly appointed and then-currently serving Personal Representative of the Alternate Payee's estate. On and after the date of establishment of the Alternate Payee's Separate Plan Account, the Participant shall have no further right or interest in the portion of Participant's Plan Account that is properly directed to the Alternate Payee's Separate Plan Account; and the Alternate Payee shall have no right or interest in the portion of the Participant's Plan Account that is not directed to the Alternate Payee's Separate Plan Account. . ~~." -,j -~ ,~ ;'! 'DRD Page 3 f Nothing in this Order shall restrict the Participant's rights to obtain a distribution under the Plan or to designate a Beneficiary under the Plan with respect to the portion of his Plan Account other than the Alternate Payee's Separate Plan Account. 3. Tax Treatment Nothing in this Order shall have any effect concerning any party's tax treatment, and nothing in the Order shall direct any person's tax reporting or withholding. 4. General Provisions and Restrictions The Plan Administrator and the Administrative Service Agency and any person subject to the direction of either of them shall not apply any provisions that would require the Plan Administrator or the Administrative Service Agency to calculate the amount to be directed to the Alternate Payee's separate sub-Account in a manner not readily calculable by the Administrative Service Agency according to its currently available records and without regard to any records for any accounting period that is an account stated or otherwise settled by the application of the Plan. When establishing the Alternate Payee's Separate Plan Account, the Plan Administrator shall first redeem amounts pro rata from all investment options other than life insurance held for the Participant's Plan Account, and shall redeem amounts from a life insurance policy only if necessary to obtain the amount that this Order provides for the Alternate Payee. If the Alternate Payee receives a Confirmation or Account statement that shows the amount of the Participant's Plan Account directed to the Alternate Payee's Separate Plan Account and the Alternate Payee does not object within the time specified by the Plan for objections to an Account, the amount provided is an account stated as to the Alternate Payee to the fullest extent provided by the Plan and further shall be deemed a correct division consistent with this Order. If the Participant receives a Confirmation or Account statement that shows the amount of the Participant's Plan Account directed to the Alternate Payee's Separate Plan Account and the Participant does not object within the time specified by the Plan for objections to an Account, the amount directed is an account stated as to the Participant to the fullest extent provided by the Plan and further shall be deemed a correct division consistent with this Order. The Alternate Payee's Separate Plan Account shall bear all fees and expenses as though the Alternate Payee were a Participant. This Order shall not require this Plan to provide increased Deferred Compensation. Any Distribution to the Alternate Payee becomes payable only after the Participant's death or Separation-from-Service and only upon the Alternate Payee's written claim made to the Plan Administrator or the Administrative Service Agency. This Order shall not require this Plan to provide any type or form of benefit or any option not otherwise provided under this Plan. ,( ..' , 'DRO . . Page 4 , Any provision of this order that would have the effect or requiring any Distribution to or Separate Plan Account for an Alternate Payee of Deferred Compensation that is required to be paid or payable to another person under any other court order is void. Any provision in this Order that relates to any employee benefit plan other than the Plan is void. Without limiting the comprehensive effect of the preceding sentence, any provision relating to any pension plan, retirement plan, deferred compensation plan, health plan, welfare benefit plan, or employee benefit plan other than this Plan is void. The Plan Administrator may assume that the Alternate Payee named by the Order is a proper payee and need not inquire into whether the person named is a spouse or former spouse of the Participant. 5. Giving Effect To This Order The attorney for the Alternate Payee shall furnish this Order to the Administrative Service Agency. EXECUTED this il4--day of ~ ,7MP PLAINTIFF/ALTERNATE PAYEE DEFENDANT/P CONSENT TO ORDER: tl::~!~ f)(fJjt<U) ~ r>>#) Date ----ACUJ-1<<Md A. ~r4t~A1 Signatur r Date 10) l (...17J'YYJ I ATIO&NEY FOR PLAINTIFF/ALTERNATE PAYEE J~Af A~//~~ ~ignature ATIORNEY FOR DEFENDANT/ PARTICIPANT siB.. Q1212 /~/t P!) Date 2."'- Ddrir/ 2.0.~ Date ~ . I~ ,-""'. , . . "".,~ FLED~OfrlCE 01' TI'~ ,,","'" ''''I",-!^ny , ,:i-: l' :"',); rl,);\U hfI 00 HOV - 8 PM 3: I.. 9 CUM''''R'' "., ~OUNTf K" , ':'\llJ " . , t,..;,," ,,-1,1 v 1 PENNS'(LVANIA rt .qf)O ~~ . -"~, .~ "__ _ ,~"~~Il'flffl!!ll!ll'~~_, _~r::mr~JIm. )~,'~.........,....."~ ,u",... ,,~.-~=- .~ >--.~'-',- '-.,',,, ". . -~ ,-.' ",,' --~- - ,~-_ -'-,-_<<- ','_> ," _"''',_ _~',",'J_~.~_~,"""_ ._ >' <' CAROLINE E. SAMPSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - 724 CIVIL TERM RAYMOND A. SAMPSON, Defendant : CIVIL ACTION - LAW : IN DIVORCE PROPERTY SETTLEMENT AGREEMENT T~~ , .. I, \ " PROPERTY SETTLEMENT AGREEMENT fHL day of a~) 2000, by and between RAYMOND A. SAMPSON, hereinafter referred to as "Husband", and CAROLINE E. SAMPSON, hereinafter referred to as "Wife". . .- THIS AGREEMENT, Made this WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 4, 1970; and WHEREAS, the parties have two children; Joseph A., born March 1, 1966 and Raymond Jonathan, born December 14, 1979; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which will provide for support, distribute their marital property, and will provide for their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband by his attorney, Samuel L. Andes, and Wife by her attorney, Sandra L. Meilton, have come to the following agreement. NOW THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single ahd unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way -, ' ~_ ,I \ " interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since their separation on January 4, 2000, 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 shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since their separation on January 4, 2000, 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 shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTSTANDING MARITAL DEBTS: Husband and Wife acknowledge and agree that they have no outstanding debts and obligations of the Husband, Wife or Husband and Wife incurred prior to the signing of this Agreement. In the event that either party contracted or incurred any debts prior to the parties' separation, the party incurring such debt shall pay the outstanding obligation and further agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations. 6. MUTUAL RELEASE: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Subject to the provisions of this Agreement each party waives his or her right to alimony and - 2 - '-"ld . - - , - ~'. " equitable distribution of property notwithstanding the Pennsylvania "Divorce Code" known as Act No. 26-1980 and as amended by Act No. 13-1988. Each party also waives his/her right to request marital counseling pursuant to 23 Pa.C.S.A. Section 3302. 7. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY: The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. Section 3501 m;. seq., and taking into account the following considerations: the length of the marriage; the fact that it is the first marriage for both Husband and Wife, the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. A. DISTRIBUTION OF PERSONAL PROPERTY: Except as may be otherwise provided herein, the parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and aher the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession, except as set forth in Exhibit "A" attached hereto, which items shall be distributed in accordance with Exhibit "A", and this Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto and as set forth in Exhibit "A". . - 3 - I ~- '~ ~. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other, or which property will be distributed in accordance with Exhibit "A" attached hereto. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Except as may be otherwise provided herein, Husband and Wife shall each be deemed to be in the possession and control of his or her own individual pension or other employee benefit plans or retirement benefits of any nature with the exception of Social Security benefits to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. B. DISTRIBUTION OF REAL ESTATE: Wife agrees to transfer to Husband immediately upon the signing of this Agreement, all of her interest in and title to their jointly-owned real estate at 1473 Lutztown Road, Boiling Springs, Cumberland County, Pennsylvania, in exchange for which Husband agrees to be solely responsible for the payment of all future liens on said real estate, taxes, insurance and utility bills relative to said real estate. C. TAX LIABILITY: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, - 4 - . ".", ,I" the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of the said Act. 8. PENSION AND RETIREMENT PLAN: The parties agree that Husband is currently employed by PHEAA and has a pension with the State Employes' Retirement System (SERSI and has a Copeland Deferred Compensation Plan and that Wife is currently employed on a part- time basis by the Cumberland VaHey School District and has no pension benefits as a result of that part-time employment and have exchanged information about those assets and their values. The parties agree that Husband shall receive his entire SERS pension and Wife hereby waives any right, title and interest she may have thereto, and in return for Wife's waiver of her interest in the SERS pension, Husband shall transfer his entire Copeland Deferred Compensation Account to Wife as set forth in Paragraph 9 below and Husband, in addition to transferring the Copeland Fund to Wife shall also pay to Wife $22,000. The $22,000 payment shall be paid by Husband to Wife upon the settlement on his loan to refinance the home as provided herein below, but in any event, shall not be paid to Wife later than 120 days from the date of the signing of this Agreement. (See Paragraph 14 below.) 9. COPELAND DEFERRED COMPENSATION ACCOUNT: Husband is the owner of a Copeland Deferred Compensation Account valued in excess of $100,000. The full and entire value of this account shall be transferred to Wife through a Domestic Relations Order. The Domestic Relations Order shall be prepared by Harry M. Leister, Jr., F.S.A. of Conrad M. Siegel, Inc. The expense incident to the preparation of the Domestic Relations Order shall be paid by Husband. Wife's agreement to accept the full value of the Copeland Deferred Compensation Account and to waive her interest in Husband's SERS Account is contingent upon a number of factors including, but not limited to, the following: (al That Wife receives the entire Copeland Deferred Compensation Account; - 5 - , . (b) That the Plan permits the Copeland Deferred Compensation Account to be transferred to Wife through the use of a Domestic Relations Order and permits her to control the account once it is transferred, to the same extent that Husband can control the account prior to the transfer; (c) That the transfer is made without tax consequences to either party; (d) That the Plan will pay any funds in the alternate payee's account to the estate of the alternate payee upon the alternate payee's death; and (e) Wife shall have full rights as alternate payee to the Plan and Husband waives all of his right, title and interest to said Plan. 10. INDIVIDUAL RETIREMENT ACCOUNTS: The parties also each own a Roth Conversion Individual Retirement Account (IRA), Husband's account number is HG 7764-4157 and Wife's account number is HG 7765-5268. These accounts are listed on Exhibit "B" and shall be distributed to each party as set forth on this schedule. The parties acknowledge and agree that he or she waives any right, title and interest in the IRA accounts, except as set forth on Exhibit "B" 11. FINANCIAL ACCOUNTS. STOCK ACCOUNTS AND OTHER INVESTMENT ACCOUNTS: The parties acknowledge and agree that they own various financial accounts, stock interests and other financial accounts, some of which are titled in joint names, some of which are titled in separate names and some of which have been liquidated after the date of separation. Exhibit "B" lists the distribution of all such accounts and investments of the parties. To the extent that Exhibit "B" assigns an asset to either party, the other party hereby waives all right, title and interest to that asset. - 6 - ,_ J -~ I~ ",,", 12. MOTOR VEHICLES: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (a) the 1997 Dodge Caravan shall become the sole and exclusive property of Wife free and clear of all liens and encumbran~e;;' (b) the 1991 Dodge Dynasty shall become the sole and exclusive property of Husband free and clear of all liens and encumbrances; and (c) the 1996 Ford Taurus, which is titled in Husband's name, but driven by the parties' son, Raymond Jonathan, shall become the sole and exclusive property of Husband free and clear of all liens and encumbrances. It is the intent of the parties that this vehicle shall be transferred to Raymond Jonathan at a time deemed appropriate by both parties; and (d) the titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the dllte of execution of this Agreement and the said executed title shall be delivered to the proper parties on the distribution date. 13. CASH PAYMENT: In consideration for the covenants and promises set forth in this Agreement and in consideration for the distribution set forth on Exhibit "8" of this Agreement, Husband shall pay to Wife $99,695.51. (i.e. $77,695.51 determined from Exhibit 8, $22,000.00 for the pension differential set forth in Paragraph 8 above). Husband shall pay said sum to Wife upon his refinancing of the mortgage against the marital residence but in no event later than 120 days from the date of the signing of this Agreement. 14. ALIMONY: Husband agrees to pay to Wife the sum of $10,800.00 simultaneous with the signing of this Agreement in return for which Wife agrees to waive all of her right, title and interest to alimony. The amount paid to Wife shall not be deemed alimony and shall not be taxable to Wife nor deductible to Husband. Further, 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 - 7 - . '" ~~ " 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 and intelligently waive and relinquish any right to seek from the other any payment for support or alimony. 15. ALIMONY PENDENTE LITE. COUNSEL FEES. AND EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. 16. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense incurred by one party as a result of incomplete, inaccurate or otherwise deficient reporting of income or deductions by the other party shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. As a result of the liquidation of marital assets in 1999, the parties incurred a capital gains tax of $3,600.00. Husband has paid the capital gains tax and Wife agrees to pay him $1,800.00, which amount represents fifty /50%) percent of the capital gain tax incurred by the parties. This $1,800.00 amount owed from Wife to Husband has been subtracted from the cash payment provision set forth in Paragraph 14 above and the amount owed by Husband to Wife has been reduced by $1,800.00. - B - " -- ..4 17. COLLEGE EDUCATION: The parties agree that they shall share the cost of their son, Raymond Jonathan Sampson's, college education in an amount up to but not exceeding Twelve Thousand ($12,000) Dollars per year, for a four year period, pro rata based on their incomes. The total combined parental obligatlon..is $12,000.00 per year and is not to be interpreted as $12,000.00 per year, per parent. Unless agreed to otherwise by the parties, the four-year period shall run consecutively following their son's graduation from high school. 18. BOOK ROYALTIES: During the course of the marriage, Wife began to write a book but gave up the endeavor during the marriage. At the time of the signing of this Agreement, Wife has no completed projects and has not attempted to contact any publishers with regard to the book which she had been writing. 19. COBRA: Husband shall take all steps necessary to assure that Wife receives a Cobra notification so that she can continue to receive health insurance on the parties' current plan which is provided by Husband's employer. All notices incident to Cobra shall be mailed to Wife at the following address: P.O. Box 95 Boiling Springs, PA 17007-0095 20. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. - 9 - "'" ., ~"~ 21. MUTUAL CONSENT DIVORCE: The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section 3301 (c). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301 (c). Upon request, to the extent permitted by law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. 22. BREACH AND ENFORCEMENT: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 23. THIRD PARTY BENEFICIARIES: Husband and Wife agree that it is not their intention in this Agreement that any other individuals, including their children, be third party beneficiaries of this Agreement at this time or at any time in the future. 24. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. - 10 - " ';' , ~~- ,-C-" -L 25. TAX ADVICE: Both parties hereto hereby acknowledge and agree that they have had the opportunity to retain their own accountants, certified public accountants, tax advisor, or tax attorney with reference to the tax implications of thiS Agreement. Further, neither party has been given any tax advice whatsoever by their respective attorneys. Further both parties hereby acknowledge that they have been advised, by their respective attorneys, to seek their own independent tax advice by retaining an accountant, certified public accountant, tax attorney, or tax advisor with reference to the tax implications involved in this Agreement. Further, the parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent tax advice. 26. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 27. 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. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to 23 Pa.C.S.A. Section 3501 ~. seq. or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but - 11 - . "- '. nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 28. DISCLOSURE: The parties confirm that they have relied on the completeness and substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no formal discovery conducted in their pending divorce action and neither party has filed an inventory and appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code, but the assets set forth in this document and on the attached Exhibits represent a complete disclosure of their assets. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owned by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. In the event that either party, at any time hereafter, discovers such an undisclosed asset, the party shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of said asset. The non-disclosing party shall be responsible for payment of counsel fees, costs or expenses incurred by the other party in seeking equitable distribution of said asset. Notwithstanding the foregoing, the Agreement shall in all other respects remain in full force and effect. 29. MODIFICATION AND WAIVER: A modification or waiver of any of the provIsions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. - 12 - I _._ ;.u > ~ -, 30. PRIOR AGREEMENT: It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 31. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 32. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 33. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. IN WITNESS WHEREOF, the parties hereto have set their Hands and Seals the day and year first above written. ~~4 R~ ~ ,to :S1'~t'iJy{. (SEAL) Ray ond A. Sampso /~-Z'7JjJ~ ~1k~J (SEALI - 13 - . - , '~" ___'.c._I,,__ ~"~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF~a..nd..- On this, the tG{oth day of cQ.~ ,2000, before me, a Notary Public, the undersigned officer, personally appeared RAYMOND A. SAMPSON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. SS: IN WITNESS WHEREOF, I hereunto set my hand and official seal. "'11_ \Ii~~ilr!~c~i~~~~'M ~c.. '.l!."~_..,_ . ". ---. - .,..,..,_.,~-- COMMONWEALTH OF PENNSYLVANIA ) ~. _,I (SS: COUNTYOF_~hl^ ) On this, the C4..... day of ~ ' 2000, before me, a Notary Public, the undersigned officer, personally appeared CAROLINE E. SAMPSON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. '-~~c o blic Notarial Seal Pauline Patti Thomas, Notary Public Harrisburg, Dauphin County My Commission Expires Mar. 24, 2003 Member, PennsylVama ASSocIatIon of Notarres - 14 - .' I ., EXHIBIT"A" Wife shall retain the following items, including but not limited to: Wife's family's corner cupboard Franciscan apple pattern, earthenware dishes Button and bows punch bowl and glasses as well as goblets Wife's father's family cradle Wife's mother's and father's family Bibles Books Photographs Caroline's jewelry The parties agree that these items may remain in the marital residence and Wife may retrieve them at her convenience with reasonable notice to Husband. If Husband wishes Wife's items to be removed, he shall provide Wife with sixty days' written notice to remove said items and Wife shall remove the items within that time frame. Husband shall retain the following items: All other items in the residence at 1473 Lutztown Road or otherwise in Husband's position on the date of this Agreement. - 15 - ,'~ ' EXHIBIT "B" SAMPSON MARITAL ASSETS Asset 1473 Lutztown Road, Boiling Springs Household Goods PSECU account, Acct. 0199348360 Roth Conversion IRA, Acct. HG 7765-5268 Roth Conversion IRA, Acct. HG 7764-4157 Savings Bonds AFL Stock Plan First Bank of Chicago Bank One Corp Clayton Homes, Inc. Diebold, Inc. Intel Johnson Controls, Inc. McDonald's Motorola Newell Rubbermaid Schwab TOTAL , ~ , , Value $134,000.00 $ 10,000.00 $ 8,330.34 $ 6,513.32 $ 8,994.71 $ 12,290.72 $ 8,460.58 $ 6,917.90 $ 11 7.49 $ 680.73 $ 3,915.34 $ 7,727.18 $ 7,554.28 $ 2,195.04 $ 4,000.57 $ 2,344.18 $ 10.950.32 $234,992.70 Husband's Copeland Deferred Compensation Account valued in excess of $ 1 00,000 and Husband's SERS pension valued in excess of $144,000 shall be divided between the parties as set forth in Paragraphs 8 and 9 of this Agreement. - 16 - . . -"~ - ^ ASSETS DISTRIBUTED TO WIFE: Roth Conversion IRA, Acct. HG 7765-5268 Savings Bonds Diebold, Inc. Intel Johnson Controls, Inc. SUBTOTAL Plus Husband's Copeland Deferred Compensation account $ 6,513.32 $ 12,290.72 $ 3,915.34 $ 7,727.18 $ 7.554.28 $ 38,000.84 ASSETS DISTRIBUTED TO HUSBAND: 1473 Lutztown Road, Boiling Springs Household Goods PSECU account, Acct. 0199348360 Roth Conversion IRA, Acct. HG 7764-4157 AFL Stock Plan First Bank of Chicago Bank One Corp Clayton Homes, Inc. McDonald's Motorola Newell Rubbermaid Schwab SUBTOTAL Plus Husband's SERS Pension $134,000.00 $ 10,000.00 $ 8,330.34 $ 8,994.71 $ 8,460.58 $ 6,917.90 $ 11 7.49 $ 680.73 $ 2,195.04 $ 4,000.57 $ 2,344.18 $ 10.950.32 $196,991.86 CALCULATION FOR CASH PAYMENT - PARAGRAPH 14: Marital assets excluding Copeland and SERS pension $234,992.70 X 50% $117,496.35 $117,496.35 38.000.84 $ 79,495.51 -1 .800.00 $ 77,695.51 22.000.00 $ 99,695.51 (Wife's distribution listed above) (Capital gain - see paragraph 17) pension differential - paragraph 8) (Amount due to Wife from Husband) - 17 - ~. ,'" --"" "--'" ',-.,':: ". .. 29698.1 >: ,1I ~ G;o w- z f': ~:l ::;:'s l?'~?;~, ',:)2 "--,-~ ".,)...( , .. " L__ 03 [:-. ?:>:: c--) S~ I {i:z :':')'1' uJuJ C wa.. r',c ;;I: "S ~- LI_ e? :::> () L_' Q N !2 &1 ~'" ~ CI).~ ;:: ~~ ~ 0",,,,;:1_ ~~gg~~ ~op<p1' ~",o",;1; "llI<al~~ Z:I:o'"~ ~~P;ic ~- '" ~::: ~ g :a Eo< f , >, , () fO{giVi4 ( c' , -,~ - ~ ~ ~! .. ~~~ ~ ~'" '-;';"~- "' L .. ~'- CAROLINE E. SAMPSON, Plaintiff IN THE COURT OF COMMON PLEAS OF .cmfBERLAND COUNTY, PENNSYLVANIA NO, 2000-724 CIVIL 19 vs. RAYl-lOND A. SAMPSON, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 3301 (c) 1. Ground for divorce: irretrievable breakdown under Section~) ~ of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: Acceptance of' Service by Sa:r.tUel L. Andes, Esquire, counsel for Defendant 3. (Complete either paragraph (a) or (b) .) and waiver (a) Date of execution of the affidavit of consent/req;,Jired by Section 3301 (c) ~) of the Divorce Code: by the plaintiff 10/9/00 by defendant 10/26/00 (b) (1) Date of execution of the plaintiff's affidavit required by Section 20l(d) of the Divorce Code: (2) date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None. .,~~ Attorney for (PIa tiff) ~) if...." ~ l__~;;-., . '~"I~~-~"'<Ij~""~ ,< " (') c: "'l'Jg; !l!~ 6i !:/ ;::$< ~D .:so Sfo ~ -J U7 "" \;0 o o >- o --= I W o -'["I i.;C;:JJ ,~',~~ t~ ":l(? ~"-t _J "co~4i 50 (3rn .'i:' :::0 -<: :y -it: is> iii' __''''' "f ~ " -~ ,I, ~.- ~-O"-'f CAROLINE E. SAMPSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ..tOOa _ ~H CL,i c l~ CIVIL ACTION - LAW IN DIVORCE v. RAYMOND A. SAMPSON, 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 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 in the Office of the Prothonotary at the Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 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 GET LEGAL HELP. The Cumberland County Lawyer Referral Service 1 Courthouse Square Carlisle, PA 17013 TUCKER ARENS BERG & SWARTZ BY:~~ /' Sandra L. Meil on Attorney I.D. #32551 111 North Front Street P. O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Dated :~ Y J bO I ATTORNEYS FOR PLAINTIFF " ~ ^ .. >>"..~"\;~'''' " CAROLINE E. SAMPSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. RAYMOND A. SAMPSON, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Caroline E. Sampson, an adult individual who is sui juris and resides at 1473 Lutztown Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. 2. Defendant is Raymond A. Sampson, an adult individual who is sui juris and resides at 1473 Lutztown Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. The present whereabouts of the Defendant, Raymond A. Sampson, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents 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 April 4, 1970, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. ~-~.~-'" 1 ::' " 8. The Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between plaintiff and Defendant; and b. For such further relief as the Court may determine equitable and just. TUCKER ARENSBERG & SWARTZ L~2r~ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF 24534.1 ,', '~ii~ ~~. ~' . - .- j~'ilI:ful . VERIFICATION I, Caroline Sampson, acknowledge that the facts stated in the within document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: /5/c{~/fJ 647,1 , .' '~ ~ ~ ~ -~ ~ ::::::0 ~ ~~ 3~~~~ ~ztc~\,I) t~~~~ ~~gg--3~ -~"''''O ~ ~Iil' :5 ~C/) i ~ N 0 c::,. C ~, ~,., -" ,.! "1V r:J 6c:J "\)CU "'1 ~ nl('ll G:J ~ Z::U I It:. ~ Zc.- ...... Cl' .J.-.~ -_1 ~ "'-J -<:.;,~ h r:::C: . h ~>() ~"'fJ ~ B "'v- i --) -:- ~ Zc' ':'-:;';'f.. ) ...Q 8 Cr Pc :",~J ~3~'T; ~ () ~ z :n ~, D- :< :0 I .... -< c; v ~ F iI 1- , .... CAROLINE E. SAMPSON, Plaintiff ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-724 CIVIL TERM RAYMOND A. SAMPSON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 7 February 2000 and served upon the Defendant on or about 7 February 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the I Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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. i 2b O~.21:n--> ! Date ~~~d 1[, ~~'ltI'M- RAY OND A. SAMPS N II d'" ,~, - ~'- "":',"o-i:'" aiitilOOu.il " -- . " ,,""',' , ~ ~ -"~ ,V" -<: (') L":> C~ C <::> 'T! <"" ;;;e "tJf.a a !;2rp '<l;:: -.:J:j I -.pt') 2:1;' (J)e: (.) ~':; 'T :<~. ~:.:~ (~) !S::Cl --0 ~~;~ ~8 ::Jl: f\j CSrC1 ~ ;;-; '-J'1 5; =< ......, -< ~ '. ;' ,'~, , .' _,.c~_ __' __''' ":.- '" -- _,__ ",,;.'_ " I ' CAROLINE E. SAMPSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 724 CIVIL TERM RAYMOND A. SAMPSON, Defendant CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 7, 2000. 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 in divorce after service of notice of intention to request entry of the decree. 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. Section 4904 relating to unswom falsification to authorities. Date: {D_q-OO Ilii'""" ""'" ,", ~, ',) "~, "'.;iC ',,,,,,,,," CC.h'L' "",~, . III . . .', -, "^ ,- ,~,' ,"""^' 0 <:..-:> 0 C 0 -n ~ Z ~,:j -o'c;o 0 ::i1---:: rnm <: c 2::c I ""--.I~ Zr;.- ~~ (f)_.. W . -'~ ~C=j "'D :<:: ~O 3: ~_J(., :l>f3 ~ ~m '-' ~ Ul ~ -..J -< ~ ,,;, CAROLINE E. SAMPSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-724 CIVIL TERM RAYMOND A. SAMPSON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 2h ~'b/ 2olO Date ~iW1YlJ A, sor--- RAY OND A. SAMPS II _Illl .-' ~.~l--"""'~ '" C4'>~' "., ," ., '. , 0 0 C) C Cl .""1"'1 $; Z --~ 'Ll(,O 0 , '."-" mrT! "t:: " ~ ') ;::;i ~:n I ~~;:tS W;t;: <...' ,") L ;::>6 'C.U :<:: - 'V ~5~ ~o ,:::E::" ~ L:-n >8 0" ~ U1 :.;;! ::0 0:> -< L - ". ';;;.' , ,,- ,." . '-j-, ' ~ " J ;.,.' , CAROLINE E. SAMPSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 724 CIVIL TERM RAYMOND A. SAMPSON, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (e) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 10 -'1 ~OD 0 <::> () f 0 hI) :?: -Om :::> -' '~':;~]J !P!B "'= "r- e551.;:: I -'-,in W -5Cl <-::: ':;1(~ :-<~:.. :;;:C """V ;~~~ PC) ~ -~ ~O 'Y C~ril ~ Ul >' 0;> !? ~" .~ I _,j...,,, '.. ,,-,'...- . . " ~,# " CAROLINE E. SAMPSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~MO 1.!t4 RAYMOND A. SAMPSON, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Samuel L. Andes, do hereby accept service of the Complaint for Divorce filed by the Plaintiff in the above matter on February 7, 2000. sa&fjfJD{J DATED: I. b ~ '$ 2DDo iilO'''('" .~~~. 'c-"'-'" ~, ~~~ ',-,- llM~~~~>\liili~~........_.lijll!i'''~ ,~'t, ~. ,,, ., '.~' - < ~ - ..""" '~i " . A _.!~ (') 0 0 ,- c:> '1' ::-:::;: .',-. -'- :OJ -rJ (''::-; ::;:'" '1" rn C,-': :;;::J ,11 f= ~ ...;_,1 I 1_'.1 rn /::. , \J (~~; 0) :0 9 C, .--, -r1 ,.,--; ~ , un :.::5 (S .. - :;< 1Ti 1,,- :::;:7 ~z: :J1 -I <-) -< en :<: I~