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Home My WebLink About00-02095 L~,," i '; " ".0. " . . . . ;Ii ;Ii :Ii;li;li;li ;Ii ;Ii ;Ii;li . . . . . ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii:li;li ;Ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PEN NA. STATE OF Dale R. Gross . 00- 2095 Civil Term No. . . VERSUS .' . Maureen M. Gross . DECREE IN DIVORCE . AND NOW, JunL 2.'1 bz..\ e. R... (,. ('0 S S , PLAINTIFF, , 2.00 I , IT IS ORDERED AND DECREED THAT AND~~Vre~4") VV1 '(,..ro!.~ , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . BEEN RAISED OF RECORD IN T CH A FINAL ORDER HAS NOT t is further ordered and decreed, pursuant to Pennsylvania Divorce ode, Section 23 Pa. C.S.A..S3101 et seq. and Pa. R.C.P. 1920.1 et seq. . . hat tl:lIll t...rrnii' aT'o ("nn(lit-inn.. nf " f"prt-"in Agreem'mt made between the . arties and dated /11 tJ--Y 2.- J;, z. ~ cJ ( , attached hereto and . ade a part hereof, in accordance with Paragraph 15, page 11, shall be ~ 'ncorporat:ea l.nt:o, out: shall nuL b", lU"'Ly",d wlLh, Cl D"''-'L'''''' .1.. Divorce ~ etween the parties. " ' J. ATT . . RY . ;Ii :Ii'" '" . . . . . .' ...... ~'-", . . . . . . . . . . . . . . . . . . . . . . . . . " ::1 ~', ;,t 1" Ii H: ~i' it 1-1 ii !'i . . . . . " i; !: ~~ . . . . ,: 'i i,; . . lJ i'f ~" 11 I' ii r~ [1 i, :~ . . . . . . . . . . . . . . . ~i. i,( I " r; '" ~ . . . . . . . . . . . . . . . . . . !!!!I"-",,;,) ".~nl21..HI_"" ,.....____Ir- ~ .. . ~ ~, ~, ~~~~~ "~ ~"lJ 1"" ~ ' . rz ~ ~lL, ~~'~ ~ "-- ""^""~ , h ~, ^ ., ~ ,;, ~ ~..~ ~1Iii " ~ ~" JO' i-:?'L /0' t' '/, .1 .- ~',' _.'C , ~"~ -';0" ,', '0, . , , MARIT AI. SETTLEMENT AGREEMENT THIS AGREEMENT, made this 1 J lJf;; of /""'I f). Y ,2001, by and between DALE R. GROSS, hereinafter referred to as "HUSBAND", and MAUREEN M. GROSS, hereinafter referred to as "WIFE". WITNESSETH, That: WHEREAS, the parties hereto are husband and wife, having been lawfully joined in marriage on September 17, 1999, in Camp Hill, Cumberland County, Pennsylvania; WHEREAS, no children were born of this marriage. WHEREAS, it is the intention of the parties to settle fully and finally their respective financial and property rights and obligations as between each other arising out of the marriage relationship or otherwise, including without limitation (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of HUSBAND and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles and interests, claims and possible claims in or against the estate of the other. NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed an essential part hereof in consideration of the foregoing recitals, the mutual promises, covenants and undertakings herein set forth, 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: Final 05/10/2001 ~- . .~. "~ ' .," , ,-' ~, " ~', ,. , !. I ~,' i I,~ ! i I i I 1. ADVICE 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. MAUREEN M. GROSS has been independently represented by Barbara Sump Ie-Sullivan, Esquire. DALE R. GROSS has been independently represented by Joel O. Sechrist, Esquire. Each party further declares that they are executing this Agreement freely and voluntarily, having obtained such knowledge and disclosure of their 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 as if she or he were unmarried, except as may be necessary to carry out the provisions of this Agreement. Each may reside at such place or places as she or he may select. 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 or WIFE of the lawfulness ofthe 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 Final 05/10/2001 2 r -- C' "' ~', , ",' , ",';' ."",.,," J '~' c;, "".~ ," ~_ -':, i" ',,~ ," 'kC,;, . ~I: f" i~ If I: !r " ii ii' !~ way interfere with the peaceful existence, separate from each other. I f~ , f~ 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 harmless from and against all future obligations of every kind incurred by them, including those for necessities. 4. WAIVER OF APPRAISAL AND INVENTORY The parties acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and inventory of same, and no statement or representation by either party as to value shall be deemed a misstatement or misrepresentation to the other or be deemed fraudulent. 5. MARITAL AND NON-MARITAL ASSETS Except as provided for herein, HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non-marital assets and marital assets including but without limitation, jewelry, clothes, furniture, and other assets wherever situated whether real, personal or mixed, tangible or intangible, and HUSBAND agrees that all assets in the possession of WIFE Final 05/1012001 3 0_",_ I --,.,'0>"'... ",''''', <"".'. , <: shall be the sole and separate property of WIFE; and, WIFE agrees that all assets in the possession of HUSBAND shall be the sole and separate property of HUSBAND. Each of the parties do hereby specifically 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 EST A TR The parties jointly own property at 1520 Inverness Drive, Mechanicsburg, Cumberland County, Pennsylvania. Said house is encumbered by a mortgage due and owing to National City Mortgage in the amount of ONE HUNDRED NINETY-FIVE THOUSAND SEVEN HUNDRED DOLLARS ($195,700.00). By agreement of the parties, the house is currently listed for a sales price of TWO HUNDRED THIRTY-FOUR THOUSAND FIVE HUNDRED DOLLARS ($234,500.00). This sum represents a reduction in the initial listing price of TWO HUNDRED THIRTY-NINE THOUSAND FIVE HUNDRED DOLLARS ($239,500.00). On or about April 13, 2001, the parties signed a sales contract for the home at a sales price of $230,000.00. In order to effectuate a sale at the price reduction of $4,500.00, HUSBAND has agreed to pay to WIFE one-half (1/2) of the difference or an additional TWO THOUSAND TWO HUNDRED FIFTY DOLLARS ($2,250.00). This sum shall be paid by HUSBAND at settlement. Settlement is scheduled for on Final 05/10/2001 4 ",~ '''' r'c.:: ,~ 'I'~ ' .' ,~ "._^ _o::'>,;,,~ ,--,.' ".,"_' ~_'-.' ~'_, . , I " , or about May 25,2001. Upon sale, all costs of closing, including real estate brokerage fees, etc. shall be shared equally by the parties. HUSBAND shall pay his one-half (1/2) of said costs to the Settlement Agent at the time of closing. Pending the settlement, HUSBAND agrees to actively sell WIFE's engagement ring, which is in his possession at the appraised or other agreed upon value. The proceeds of the ring sale shall be applied to reduce the real estate closing cost burden on each party. In the event the real estate should sell prior to the ring, Husband shall continue to have the ring marketed and will be obligated to give WIFE one-half (1/2) of the value upon its eventual sale. In such event, the ring will be placed on consignment or the sale handled by a third party who is in the business of selling jewelry. Said sale shall only be effectuated with prior approval of the listing price by WIFE. In the event the instant contract should not be consummated, the parties agree to immediately re-list the house and continue to be guided by the recommendation of the real estate professional who has listed the property for sale as to future sales prices. They agree to use their good faith efforts to effectuate a sale and to act responsibly in implementing suggestions which will achieve what is the best methods to effectuate the sale of the home. In the event that the house is not sold within six (6) months of the date ohhis Agreement, the parties agree to have the house appraised by an independent appraiser mutually agreed upon by them and set the listing price at the appraised value, ifless than the current listing price. The parties shall equally share in the cost of the appraisal. Final 05/10/2001 5 ,"e:V'h"" . " , < '. -~". .,,;,;c. ., --., '- " " ","', --,,:~,--,,', ,,: '--, - <-_,c;-, ..';;,,";~ , 'w, i !' , Upon sale of the real estate, the net proceeds, after satisfaction of all closing costs which shall be shared as set forth above, shall be the sole property of WIFE and paid to her. Pending sale, both parties shall be equally responsible for payment of the mortgage, utilities, repairs and maintenance of the home. A) Mortgage: HUSBAND shall mail his check for one half (l/2) of the monthly mortgage payment to WIFE by the twentieth (20th) day of each month. Said check shall be mailed to WIFE at 55 Old Pioneer Road, Camp Hill, Pennsylvania. Said check shall be made payable to WIFE. WIFE shall then forward the mortgage payment to the bank. WIFE shall immediately notify HUSBAND of any address change for the forwarding of said check. HUSBAND shall also immediately pay any outstanding portions of the November and December, 2000 mortgage payments, as well as any late fees associated with the payments for these months. Husband warrants that these have been paid and Husband agrees to be solely responsible for any such obligation and to indemnify and hold Wife harmless from said debt. If any debt is due, it shall be paid prior to or at the real estate settlement. Husband warrants that all payments for January, February, March and April have been made in a timely manner. B) Utilities, Maintenance and Repairs: If either party resides in the home, he or Final 05/10/2001 6 ',,0:',"__,,""" ~~, ~ __ '='x ~, "i __'j- -- --~-"60.w,' . , . she shall be solely responsible for all utilities, maintenance and repair. If the house remains unoccupied by either party, both parties shall equally share all costs of utilities, maintenance and repair. HUSBAND had disconnected the utilities without notice to and approval of WIFE. HUSBAND shall be solely responsible for said costs. All other utilities, maintenance and repair costs shall by shared equally between them. HUSBAND agrees to forward to WIFE copies of the actual utility bills upon receipt from the providers. WIFE agrees to pay HUSBAND one-half (l/2)ofthese expenses within seven (7) days of her receipt of same from HUSBAND. In order to minimize these costs, HUSBAND agrees to notify Hampden Township in writing that the home is vacant so that the trash portion of the sewer/trash bill can be credited and eliminated. C) Status Quo During Marketing of the Property: The parties agree that the utilities and condition of the home shall be maintained until settlement to enhance the marketability of the home. The parties agree that the temperature of the home will be kept as low as reasonably possible in order to reduce the heating expenses. There currently exist certain black marks on the carpeting which did not exist when WIFE relocated from the marital home. In the event the black spots on the carpet become an issue during any negotiations concerning sale ofthe real estate, HUSBAND agrees to be solely responsible for the costs of remedying the Final 05/10/2001 7 I ',',' '.'t.-Y'". " ., ,,,, ,~>-, '<- ' .,' "'":",'--,,'" '. """-~'->"~ . ,~ !~ ~~ i~ II .il.' ~f,; '& If t,( !~ :l~ :~ " , I~ ff ,r;- ! , I! ~ !&, IS i~ ;t If: It It I~ I~,. 't , I t problem. Regarding preparing the home for settlement, HUSBAND shall remove all of his personalty remaining in the home prior to the settlement and the occurrence of final inspection incident to said settlement. 7. MOTOR VEHICLES WIFE shall have sole title and ownership of her pre-maritall995 Mazda MX6. HUSBAND had a Grand Cherokee at the time of marriage and now has a Mountaineer. HUSBAND shall be solely responsible for the lease of his vehicle and agrees to indemnify and hold WIFE harmless for any such debt. 8. PENSION Each party hereby waives any and all claims that he or she may have against the other to any pension, employee saving or other stock benefit program of the other, if applicable. 9. BANK ACCOUNTS AND INVESTMENTS Each party shall have sole possession of the bank accounts and investments in their own names. Final 05/10/2001 8 .~ ....l.. . , "~ " ,'~,~ . 10. LIFE INSURANCE Each party shall retain ownership of any life insurance policy in his or her name. 11. CASH PAYMENT TO WIFE Immediately upon execution of this agreement, HUSBAND agrees to pay to WIFE the sum of FIVE THOUSAND DOLLARS ($5,000.00) in reimbursement to her of her pre-marital cash used by HUSBAND. 12. PERSONAL PROPERTY All personal property in the possession of either party shall become that parties' sole property. Specifically, it is noted that WIFE shall have: (a) King size bed; (b) Kitchen table and hutch; ( c) Tables in living room; (d) Living room furniture; (e) Pyrex dish in Husband's possession; and (e) Dining room glass Bombay table. Also, the parties shall share personal property as indicated on Exhibit "A" which is attached hereto and made a part of this Agreement. The parties acknowledge that in the move from the marital residence some personalty which did not belong to them was inadvertently removed by the wrong party. The parties agree that all such personalty has been returned prior to the execution of this Agreement. FinaI05/l0/2001 9 ~",' ,,'io, ',:'," , T.: J ( :1 I;; I"~ ~"',,- , r . ',,'~ ''', -- ",'.- -, "'.~"" , ~" ",~ 13. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CLAIMS CONFERRED BY THE PENNSYLVANIA DIVORCE ACT OF 1980, AS AMENDED HUSBAND and WIFE acknowledge and agree that the provisions of this Agreement 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 equitable distribution, alimony, alimony pendente lite, counsel fees, costs and expenses or other provisions for their support and maintenance before, during and after the commencement of any proceeding for divorce or annulment between the parties. 14. 2000 TAX RETURN The parties have filed a joint federal income tax return for 2000 and expect a refund in excess of FOUR THOUSAND DOLLARS ($4,000.00). Said refund shall be divided equally. The parties shall equally share the cost of the tax preparation. Should there be any subsequent audit of the taxes for any year or years for which the parties filed jointly, the party who was responsible, either through neglect or intentional action, for any additional tax assessment, penalty or interest shall be responsible for payment of same and shall hold the other party harmless. Final 05/10/2001 10 " , ~,_,;"n,' ;~" < . !)i ii: i!- I.: ,. Ii !'( )' i' I' .. ,0''--' ,,"_,~,'\,".' '~" ~<__;~~~i;:__:~"',~;"",,i~::;':~'__':"__ ,'~' ,,;/__ .' o;,o;'~, "': -- " ""., ~ I. 1:-- 15. SUBSEQUENT DIVORCE A decree in divorce, entered by a court of competent jurisdiction to either party, shall not suspend, supersede or affect the terms of this Agreement. Both parties agree to enter a Consent Decree concerning the provisions of this Agreement in the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court of competent jurisdiction, as a part of a resolution of any divorce action filed. This Agreement, and the terms and conditions contained herein, as well as the enforcement of said terms and conditions, shall not be contingent upon the granting of a Divorce Decree to either party by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. Furthermore, both parties hereto agree to timely execute the appropriate affidavits and consents to secure a No-Fault Divorce as may be required by the Divorce Code of 1980, as amended. Both parties hereto agree that this Agreement may be incorporated for purposes of enforcement into a separate Court Order but shall not merge in such order in the Court of Common Pleas of Cumberland County, Pennsylvania. 16. OTHER DOCUMENT A TION HUSBAND and WIFE covenant and agree that upon request of the other party, they will forthwith execute and deliver to the other party, any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. Final 05/10/2001 11 .' ^,__ ~o, ,__ 0,'__.. I - , < <-'",_< -':>i'-C'6,',<i' < ~ ~'. ' .. . .~~, ;'.." ~,,~ c,.';',...,. "~'. '.~_ -- "'~,..., ~___ 17. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CLAIMS IN ESTATE Each party hereby releases, waives and relinquishes any and all rights which he or she may now have, or may hereafter have, against the other party under the present or future laws of any jurisdiction (a) to share in the estate of the other party upon the other party's death and (b) to act as executor/rix or administrator/rix of the other party's estate. 18. MUTUAL RELEASE HUSBAND and WIFE each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of equitable distribution, dower or curtesy, or claims in the nature of dower or curtesy 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, Final 05/10/2001 12 > .........1 '",;"":_ ',( -.c C;,', ''':~' :"""""-"",, _ ~ -y'~' " / "1, ',-,:.'-" :', '" '.,,"; " ic~',;' '= ",j,;,,'., ',_.'n ~;"k, ,"~, ,,~' ~,\,,:' . . 'd Ii 'I II I I II il " jl ,I " II Ii , 1 I I ,[ 'I I ! 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 party or his 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 permit 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 the 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. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Marital Settlement Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, 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 Final 05/10/200 I 13 --~ "~'"'H ",', "~~" _~' I' ^",.' " , ",,,.W=,' '<'. ..'." , -"-"E:'- 'C.';:o'--;'J thereof. :'i I,: I:: " 19. SUCCESSOR'S RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 20. SEVERABILITY If any provision in this Agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired or invalidated in any way. 21. ENTIRE AGREEMENT f: Ii HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all of the representations, promises and Agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto. Final 05/10/2001 14 [:- ,," ','"c, '~~', ,_~;~ -- , :;, :: -,;,:;~:',',:J~--' ",'1"~-"'~';_ - ~ ~ ' ~ ;~ ~-- 22. BINDING EFFECT OF AGREEMENTIW AIVER This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, nor shall such failure be construed as a waiver of any other term, condition, clause or provision of this Agreement. 23. BREACH 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 contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 24. CONTROLLING LAW This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. Final 05/10/2001 15 "" "','- ",' '",- '-""'-"'" -- ~'," ~ ' f ~; ~. ~; ~: f. t. ij: h t " I , i t t, ,. , I , I I I i I I ~i I. 1: I, ;. i I !; .~=,~, 'I,' "', ^'-";', "-"',,' '- ' "=,--,, ~,," '^"'- -, " '"' ',,~ ,,~,,'~" , "i' ,. .; ~", ,'","',. ','"' i' '" , !j " "'"t'j {I II I I I , I ,I .' 25. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS i,i I I I I I ,I Ii Ii ,I ! 1 1 The parties acknowledge that this Agreement shall become effective when actually signed by both parties. "",02/4L~~ DALE R. GROSS " k! 11 II " I ;, [I i ,I ,1 I :i :,1 :i WITNESS ~ 11A-~ / MA REEN M. GROSS ,I 'I :', i 'I :1 'I II 'I I! ,I Final 05/10/200 I 16 , J , .. ...1.... , '--"'7""<c"~,,i','''__'''-"' ",''', .. , '.,_ ,'",,, ',;;~ "i,J,'"..S,.o ;"""J.- ~ '~\ " . .' COMMONWEALTH OF PENNSYL VANIA COUNTY OF VOAA ) ) SS. ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared DALE R. GROSS, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of his knowledge, information and belief. Ii I 1 I~ Ii ; Affirmed and subscribed to before me this ~5T1.l day of (rUN ,2001. @;dW~ NOTAAY; LIC COMMONWEALTH OF PENNSYLV ~;2 COUNTYOF ~~,---.,,~ ) ) SS. ) . 1 I I I I i I i I I I I i: Nolllrial Seal Linda J. McDaniel, Notary Public SEAL) Falrvtew Twp., York County My Commission Expires Feb. 23, 2003 Member, Pennsylvania Assoclatlcn ot NotarieS My commission expires: Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared MAUREEN M. GROSS, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of her knowledge, information and belief. X f" day of I. ~~-,~,-" ~OTARY PUBLIC ( ~~ commission expires: (SEAL) 8, f'~C<t,i.;2j S~'aJ 'I~ ~rbc2ra Sump!o-SUmV2~, Notary p. ""'~. ',.M J:nbOrhlrlB C . U~'..~ My Com~iss'."-' E .>~ro, umber/and Cow. Ion xplres November 15, 2C: ~'-'~~~--'_.""-~"'.~~"_.. Final 05/10/2001 17 "_ . ~, "'M> C' "~"~" ~ -;., ." , 1....1 . . - (~ .0 Dale's Item List Griddle Wedding toasting glasses Crystal candle sticks Engmved invitation picture fiame Candle garden Black stemware Pilsner gJasses Mikasa platter tray Crystal brandy deeanter Throw blanket Te-fa1 pots and pans Desktop photo cube Main bath towels and accessories , Tupperware and silverware Will be split Blender Meatloaf pan and cookie sheets Mixer Potpourri/candle holder Brass ivy basket Powder room ivy pot and leaf candle Curved picture frame Split kitchen tool and gadget set Small crystal clock ~~ Maureen Gross Dale Gross !~ lLI,2OOD Date n (~ d ~, '"....".k=', " "", ~' - , ~~- <OJ . - Maureen's Item List Crystal clock Crystal vase Covered box Pitcher and glasses Napkins and tablecloth Potpourri dish Waterford glasses Yankee Candle Throw blanket Irish clock Bowl and plate set Coasters Lenox candle holders Tall crystal vase Engraved picture frame Mikasa wedding picture frame Tuppenvare and silverware will be split Cetamic wine cooler Kitchen tool and gadget set will be split Master bath towels and all accessories Master bedroomJbath curtains!rods Mikasa serving set Mikasadishes Year 2000 toasting glasses Framed invitation Vase with flowers Mikasa bowl Toaster oven Pyzex portable Hand mixer Waffle maker Set of three candle holders Candle tree Powder room bath accessories and waIl decoration Two floor candleslholders Bzass ivy basket Hand towels Cutting boanl Wedding basket i~~ Maureen Gross d1:.J /4\ dr9iJD Date Dale Gross Date ~ (0 " ~" ~, !iJj;' ~,I '< -... ,,11tJ:'~. " - , -"'--- "",~",,:- Dale R. Gross IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION Maureen M. Gross NO. 00-2095 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under ~3301(c) -aae1-(tlX+}-ef-lRe-eive~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service by Barbara Sumple-Sullivan, Attorney for Defendant 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: by plaintiff (p I " 10 I ; by defendant (., / '110 I (b) (1) Date of execution of the affidavit required by ~3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: I: I" I' i L, I: I' " , /" " l" i ~ F1 , I'" "J i:: " 'i 4. Related claims pending: all claims settled by Agreement dated 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's waive;;f N7 in ~3301 (c) Divorce was filed with the Prothonotary: ~ / ~ IJ / Date defendant's Waiver 0 Notic in ~3301 (c) Divorce was filed with the Prothonotary: ( (~ fJ -# fT{'t1P ~m;SrL,;,.;.."J""'\~Jj;I~_I~iililiiililri~~'ESilMiii:f.iiI:t<ili;>~,-.J";'II1if.i:i! C' ,~r =~"' [L 'V~~' ,^"" ~ _ ^ -'.", ",,-,',~~, . ..,~,~ -,~~.' 1:llltU( ",,-, ,"' _ "~ ~> _0 1IIilI' . ..c..... .~_< ~ .'~'O" ,'" (") c:) 0 C TI <- '- -of:T'1 n~tf~-::, '-- " -,. z:i~ -- .~~ zr :Qf~ U;) kC) ;r::"" -'- --,--, ~o "'"';'1" ~j~~ 5>8 z i') );! =< r0 :cn -< ,_..., .~ L__ ~, ~.~ ,~ i,,'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA 'I "I NonCE TO DEFEND AND CLAIM RIGHTS MANDATED BY R.C.P. 1920.71 DALE R. GROSS Civil Action - Law i i 1 ,I :"1 'i 'I :! :i 'I I 11 'I iJ !j VS. No. (}-() _ ;lo '1!{~ -r.L<-- MAUREEN M. GROSS Action in Divorce NOTICE TO DEFEND AND CLAIM RIGHTS ;'j You have been sued in court. If you wish to defend against the claims set forth in the following pages, you musttake 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. ,'I ,I 1 1 i I 1 I ;'1 1 ,I I 1 'I i , i I I ,1 i 1 i 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 P A 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 TIDS PAPER TO YOUR LA WYERAT 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. i i I i j I j I i Cumberland County Bar Association Lawyer Referral Service Carlisle, P A (717)249-3166 (800)990-9108 ~ .. . ,-'- ~' ~,!J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NonCE TO DEFEND AND CLAIM RIGHTS MANDATED BY R.C.P. 1920.71 DALE R. GROSS Civil Action - Law VS. No. MAUREEN M. GROSS Action in Divorce A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA smo DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en 1as paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambi6n ser emitida en su contra por cualquier otra queja 0 compensacion reclamados por e1 demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para e1 divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponib1e en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEV AR ESTE P APEL A UN ABOGADO DE INMEDIA TO. SI NO TIENE 0 NO PUEDE P AGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association Lawyer Referral Service Carlisle, P A (717)249-3166 (800)990-9108 ~,- ~~. , <" ,", , '. "~"""'~<'l~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DALE R. GROSS Civil Action - Law VS. No. 0-0 - .2-0 qS' ~ ., ~ MAUREEN M. GROSS Action in Divorce COMPLAINT 1. Plaintiff is Dale R. Gross, an adult individual, who currently resides at at1520 Inverness Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Maureen M. Gross, an adult individual, who currently resides at1520 Inverness Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The Parties have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and the defendant were married on September 17, 1999 at Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. tJ- O. Sechrist, Esquire upreme Court LD. #15609 568 Old York Road Etters PA 17319 717 938-3396 f.:'" ~- ~'"~ . ~'~,;" .~ . ' 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. DATE: f(101) ....QL -I't/ /~ Plaintiff ,~~,~ ~ ., '" ~'~' ~" - . " 'I , u - ~--.'l!t.mrj,;;, ~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DALE R. GROSS VS. MAUREEN M. GROSS Civil Action - Law , ~, , , i , if I; I' t I',: i; r i~ t,; Ii i',' I;; l' i~' i,c, I~ H ;~: ,,; No. 00-2095 Civil Term Action in Divorce ACCEPTANCE OF SERVICE I, BARBARA SUMPLE-SULLIV AN, am the attorney of record for Maureen M. Gross, Defendant in the within action in divorce. I hereby accept servic fthe Divorce Complaint in this action. I certifY that I am authorized to accept service on e f of ureen M. Gross. DATE: y;;//~tJo f~ f: , I if: :" I' ~; ,,' Ii' ~:, Barbara Sumple-Sullivan Attorney at Law 549 Bridge Street New Cumberland P A 17070 Attorney for Maureen M. Gross #3!Bf7 l'~ 11, [ L ~:' '--~,',o "," "";. ,";..,;..- : , J- -.:; ;~, . Barbara Sump1e-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 DALE R. GROSS, Plaintiff Ii 1 I' if , Ii :L " : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ", , , ~! t I v. : NO: 00-2095 MAUREEN M. GROSS, Defendant CIVIL ACTION - LAW IN DIVORCE i ~: f f AFFIDAVIT OF CONSENT c , , 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on April 6, 2000. 1 I; [, !: 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. DATE: "'/4 boo I ,())~4L/~ DALE R. GROSS I I I I I' Ii l: l' Ii !! Ij I:! I! I 1 I I ~ j 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. ", ,~, _"";;~""~C~~'''~.; ~ i "e,-, ',,;; ~,~~";"C .~~' "',,' " . ;~c. ~;~i.~ ,,~,,;; ,,,,,'''''''''N'''''~' ~~ ~ ;";,""~"'''k"",'j".,,,C''';,",',,'C;';'';:,,;;'~:ei"CC..c;, ',C" ... _ . ,_ . 0 0 0 C ---,'1 ~ '- -', '"OW c: t:!)m :';-i.:: -<'--<..) Zc;:.: cD (j).. -<2 ~C) ~ Pc :Z~ , " Z" 0 ~- C5 ,.:t:;'C ~ Z N =< :D r'0 -< ,',., "- '"", ,",', ",~,~, ." ~ ' , I "-," g,,; - -"" ',^ ;,!:,':"",': ',' l' ",,' c '~ .,." ' ~ " '", . 'I . . " . Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 DALE R. GROSS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO: 00-2095 MAUREEN M. GROSS, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !!3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the prothonotary . I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATE: ~IL} 1 dEOf ~QlL d ~ DALE R. GROSS [t,;., ...S""liiit"'"'' """";'fli"""''';'';' _,"u ;:",,;',." '",,",.,",,;;,,,,,.,,,,;.,,,,,,,., ," ";c",, """,, " '. 0 (--'. C) ~. C "Tl s: <- UG] c:: 111 fT: ;~ - 2:t) "'""1 ~5c: \.0 , ;::J , -<..:':.~ - () C::CJ ::t;:::", " ;;E;c -,"" ...,~) --1', -'~. C) ZC; 6rn Pc s1 Z !'0 =< r" ~ ,,~~ _;o",,~ ~ 'w" .,SO.,. ;" ""',I ~ I ;1 II Ii Ii II , Ii ii " ii " il . . ~ .. .. 01 . Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DALE R. GROSS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO: 00-2095 MAUREEN M. GROSS, 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 April 6, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: {f I '-( I O(){)( 11J;I;wM"pA/(~ 111-~ MAUREEN M. GROSS "i, }\ri iL"" . '" - ""'Jiii~;i,,,..~,y.:..,,~.;;.;'c '-""iir'>~"" """', '~'" u . < "" ~- ~,~'" " ~ ,.~r,~ ,'",+i ", ~,,~,,'=,'" /l- 'ii'%"""i~M'""i",iih"", , ,i~!i ,,!iF','," "'" '_~i,,,,,,;"",'i,,i"",' """"" ""i'..,,' .. . .. '. (') C) 'j c: ::)"j' ~ ''- '" ", -ocu ,- "-,- mrTi i,_ ;~~; ~T~ ;~ "'1-'::: :z: :Ti ~i~ ~S: CD -<.c ~C; ;:'1'<> P_, ~~'<>' ~:?ji 2" -'-''''- ;:8 c" ~ ''\.:l :;;! :0 r", -< ..,- I ',:) ':,'i,';':,;,'-' '"', ',' ,,'- : ;;', .~~ --, >--j.' , -'" ~-.,",,' "",' f . t . r lJ .. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 DALE R. GROSS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO: 00-2095 MAUREEN M. GROSS, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 1l3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary . I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATE: i( J ~ !JeD I ~ ru1~~ MAUREEN M. GROSS iIIil"'"" ;,,0"'""'1'" ",.~:,{,,, ;~,';',,"'" ." ~ .. ..... ,"'", '"' " ,~ .'~' ,~, ~~ ";;;"~""",;v"';";";~~" 'C'.".' ,,';', ,c;I~'/ ,'" "V;,,,,h';'""~""" "-h; . . 0 C) 0 C 'n ;;: C-.. "~ uU:, 5~; , nlr;-: Z:J:J ",---ii_ "i'::':': 4.<;"" ~In: cD , j S!<2:: :~J;'~~ r::: C.i ~": )>" - -on zc~ -''''' "" c) n"1 5> ." v c:: c-I z: ,,:> :t> ~ :D r'.) -< <. ' '''i I " ! i II ~ Barbara Sump1e-Sul1ivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 DALE R. GROSS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 00-2095 MAUREEN M. GROSS, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME B I r. , , ~ Ii , , I ! , I ! I I I NOTICE is hereby given that Plaintiff in the above-captioned matter, having been granted a final decree in divorce on the 29th day of June ,2001, hereby intends to resume and hereafter use the previous name of Maureen M. Peters and gives this written notice avowing her intention in accordance with the provisions of the Act of 54 Pa. C.S. ~704. 1k0.~ 11'(. ~~ Maureen M. Gross TO BE KNOWN AS: 11iCUW-OM 111 - ~ Maureen M. Peters COMMONWEALTH OF PE~SYLVJN~ /t I' A_~ Lf,LU tfL-. : SS. COUNTYOF ~fi . On this, the t9o: day of ,2001, before me, a Notary Public, the undersigned officer, personal ppear Maureen M. Gross, known to me (or satisfactorily proven) to be the person whose n e is subscribed to the within instrument, and acknowledged that she executed the foregoing Notice ofIntention to Resume Prior Name for the purposes contained therein. WHEREOF, I hereunto set my hand and official seal. My Commission Expires: (SEAL) J;:;i,~,:~,;J--"i~"," :~"': ." ,u , Fcc'" ""-,,-,,' ,~~~, ':"Ii"'> .,,,j-;~:" c'.',c .,.c'" . . , ".;;",.;,'":"",;,,,,,,, ;;i;";,:iJ;'~\~._:;'-' ,:;j~,,~,:{, r' ,,:;:; ~~ojiq, ~~~ CIt () ~~ J .,,,,,..dl"""'l'''..;'';';,,,, .... 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