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Home My WebLink About07-0923r~ Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C7 ~ ~ ~ TERM No. Q7 - 9~3 ~a~,f ~cr.~ 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 aze 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 by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for 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 Office at 1 Courthouse Square, Cazlisle PA 170013. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . G; ~ ~ ( TERM COMPLAINT IN DIVORCE COUNTI REQUEST FOR DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is CRAIG ALAN KRAMER, who currently resides at 4 CUMBERLAND ESTATES DRIVE, MECHANICSBURG, County of CUMBERLAND, Commonwealth of Pennsylvania. 2. Defendant is KATHRYN KAY K:RAMER, who currently resides at 7 LISMORE PLACE, MECHANICSBURG, County of CUMBERLAND, Commonweahh of Pennsylvania. 3. CRAIG ALAN KRAMER has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) month immediately preceding the filing of this Complaint. 4. The parties were married on the 2~ day of October , 1976 , at PALMYRA, COMMONWEALTH OF PENNSYLVANIA. Attached hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff not defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or for annulment between the Parties. 7. The defendant has been advised of the availability of counseling and the right to request that the Court require the parties to participate in Counseling. 8. The marriage of the parties is irretrievably broken. 9. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiffbelieves that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed from the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between Plaintiff and Defendant. COUNT II REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(B) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 are incorporated herein and made a part hereof by reference as though fully set forth. 11. Plaintiff and Defendant have reached an agreement on issues including division of property, custody, child support, spousal support, and alimony. WHEREFORE, Plaintiffrespectfully requests that this Court approve and incorporate the agreement reached between Plaintiff and Defendant into the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) ofthe Divorce Code. r.fe.~o~ ~r,~----- Plaintiff I verify that the statements made in this Complaint are true and convect. 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. Plaintiff Date: 2 p ~ X10 'z ~W a F--I i ~ ~ O 6 I z h-I CJ I F-I O x~ . H 1 W ~ -- ~~~-r~c~.~ior~ ~o~ ~~~r~i~~e ~ice~r~e Cornmonwovlth of PE:nnsylYan~o l SS 217 9._ 5 No. A . .. .... . County of Lebanon STATEMENT OF MALE STATEMENT OF FEMALE FULL NAME (Fketl (MiHir/ (LatH FULL NAME /fktt) ( 1/d(d (Ladl RESIDENCE (Sh Addran w RYnI h USUAL w to Nwmbed USUAL R DENCE ! ml Addrau w Rrnrl Jtert rrnbwJ ~ ' ~t _.,.~~lL. di>l.1Et-._tE~'._ ! •~.. L 1 F ~t~f aa dri CITY//''F~OR TOWN CDDOUN``TY~ STATE . . . CITY R TOWN COUNTT STAT~ USUAL OCCUP 10 USU L OCCUPATION ~ DATE OF 6{P~~1 IMon1 J (Day) tY 1 C.\TE OF lIR7M (Monthl (Day! (Year) lti~c PLACE OF RIRTH (S et w fweipn Cwatq) r- (LACE Of IIRTN (State w fanipn CwrregJ COLOR OR RACE fWh;te, Nero, Olhm, ac Sp NP) COLOR OR MCE (Whfh, Npn, OtMr, Specil ~E~~~r `` __ yy ANY /BLOB LIJ.RRIAGE) S H Y A 0 W ANY PRIO~t A~+ARRIAGE) - E O M NY) O 0 Q TES HOW MANYT 1) MOW AND WHEN WAS 4ATE5T MARRIAGE DISSOLVED) ~Ll NOW AND WHEN WAS LATEST MARRIAGE DISSOLVED) b 1-' lF DIVORCED STATE REASON IF DIVORCED STATE REASON E) GIVEN ANO SURNAME OF FATHER GIVEN ANp SURNAM Of FATHER ~ GIVEN AND SURNAME O MOTHER GIYEN AND SU'iN Of M THER ~ MAIDEN NAME OF MOTME l7 MAIDEN NAME Of MOTHER ~ 1f ~ - .,{~}, Arf~Gt)Ln~ RESIDENCE Of FATHER _ RESIDENCE OF FAT ER W RCSIDENCE Of MpTMER RESIDENCE MOTHER /~~ ~'~ ~ RACER RACE OF Fn FNER may,,, ~ ~ ~ RAGE OF MOTHER ~F ~~ r RACE Of MOTHER R~ OCCUPATIO"I~Of FGTHCR .. OCCUMTION Of FATHER ~ rr ~Q\ddd~t ~ OCCUPATION OF MOTHER __ OCCUPATION OF MGrHER a a 61RTNILACE OF FATHER 61RTHKACE Of fATMER .. ~ 11RTHPLACE Of MOTHER IIRTHPLACE OF MOTHER ~ ~~~~!!!! ~ypfd .r.,,,. t7n . ~ ~ .. _ O h appikenl elNicled rith ony trontmheible diteauy T^ h opplkant a11)klad Irilh any ftaatmhfible /uea T U_ ~ II aPPlicanl wok-minded, ineon., of eorowd miol or YMer Ptmtdromhlp of . Pones o It applkant weok•m;adpd, Meane, el Ynurnd mind w Ynder yYardianfhip at Y Psnw of O Ymwnd mind) antornd mind) Hot apPlkanl, vtlbin S yeort, bten an Inmate of any Ntlitullon Iw fnlipent -enont, week- Hos opplicont, ritbin S yeas, Jaen an inmate e! any bttitntioa IN indigent penens, weoh- ~ m;nded, inwne, or Penent ei astound mmdl mindd, Lease, w panwre 0< an/Wad mind) O h epplv;a; nor wader the Inlluence sl ony inteeketinp liquor or t: ncotk dnyT C? _ h applicant nor Ynder the lailaenct of euy MfpnkaiLR ligew w narcotic drYp) ~ _ ~ Rnlotiontbip el pad;n nekinp tbb aPplicoUon, fl any. O Cy h.,,. . Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM . No. ~ ~ - 9 ~` 3 u' ~ ~C -~ ~~K COUNSELING NOTICE The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301 (a) (6) -Indignities Section 3301 (c) -Irretrievable breakdown- Mutual Consent Section 3301 (d) -Irretrievable breakdown -Two/Three year separation A list of qualified professionals is available for inspection in Prothonotary Office 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM No. Q ~ - ~a3 c3Jr r ~et~,. AFFIDAVIT OF NON-MILITARY SERVICE Craig Alan Kramer, being duly sworn according to Law, deposes and says that he knows by his own personal knowledge and therefore avers that defendant, Kathryn Kay Kramer, is 50 years of age; that she is employed by Silver Spring Township, 6475 Cazlisle Pike, Mechanicsburg, PA 17050; and that she is not in the military service of the United States or its allies, or otherwise within the provision of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. Sworn to and subscribed before e t '~_~day of ~ 2007 ,.-- Notary Public CommortweaNh of Pennsylvania NOTARtAE. SEAL SHIRLEIf A. BFARDSt.EY, E.'-wry Palk Sliver Sing Tip., C~sm~~ ia~ad C~. My Commissbn Er~ires (~. 23, 2~i38 Q s ~-r.i .,,,,,_ ~ z S~.? ~ ~ ~ ~5 r t / ^~ ` .. ~ `~k~ ""~ :~ ,, Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717)691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg Pa. 17050 (717} 756-7077 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C'.v ~ t TERM No. O7-q2 3 c~ uc l -fern, AFFIDAVIT AS TO SIGNATURE Craig Alan Kramer, being duly sworn according to law, deposes and says that he/she is the Plaintiff in the above-captioned divorce action; that he/she is familiar with the signature of the Defendant; and that the signature on the return receipt attached hereto as Exhibit "A" is the signature of the Defendant. Fe ap , 2007 Sworn and subscribed befo thi~Q~day of _ ~~ , 2007 otary Public !} 4 Cum rland Estates Drive Mechanicsburg, PA 17050 to~t~t~nsvesldr o~ ~~~;~~~d~!~i~ I~OT~~,~? ~'~""L ~' SHIRLEYA. ~" r~.: ~~ r 4~~.. ~ ,a:~ ~~ ~~~~~~~~i~ii~ i'?r.sFV°ti.Fi: ~.~~i.3.rlii Lrti,.,y °~ F~iy Ca~r-missio~ Ex~€~~s ~4 ~~; 2Q~3 Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C ~ U ~ l TERM No. O-7 - ~ 23 C ~ ~; l -Fcrn~ ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce filed in the above-captioned matter. ' a~ , 2007 7 Lismore Place Mechanicsburg, PA 17050 Sworn and subscribed befor this ~_day of , 2007 Notary Public Commonareelth of Pe~r~{van~e ,~;.-mss . tdOTAIII~".! ~~~~- SHIRLEY A. B~fa~~~e ~1; F~~er}° ~s~{l~ Silver Spr{ng ~~~,, O;smberi~n~ C~. ty4yy Comm{ss{on Exp'sres Ck~. 23, 208 ~. -'r+ ~ i , ~ r, ~ r ) ~ ;''` ~~ E vy, { ~ Y ., V. k""'~~. ~ ~ ~l" if C ; ~,~ N ..~, tp" AGREEMENT BETWEEN CRAIG ALAN KRAMER and KATHRYN KAY KRAMER KATHRYN KAY KRAMER Pro Se CRAIG ALAN K;RAMER Pro Se Agreement made this l S day of ~~ ~ mar ~, 2007, by and between KATHRYN KAY KRAMER (hereinafter known as "Wife), currently residing at 7 Lismore Place, Mechanicsburg, Cumberland County, Pennsylvania, and CRAIG ALAN KRAMER (hereinafter known as Husband"), currently residing at 4 Cumberland Estates Drive, Mechanicsburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on October 2nd, 1976, in Palmyra, Lebanon County, Pennsylvania. There were four children born of this marriage, said children being Benjamin, a boy born July 31, 1979; Jennifer, a girl born March 17, 1982; Matthew, a boy born November 20, 1990; and Kristina, a girl born, November 20, 1990. WHEREAS, the marriage has been irretrievably broken and it is the intention PAGE 1 OF 18 of Wife and Husband to live separate and apart, and the parties desire to settle their respective financial and property rights and obligations, including the equitable distribution of marital property, spousal support and alimony, child support, child custody and child visitation and all other claims that one party might bring against the other or the other's estate, now or in the future. NOW, THEREFORE, the parties agree to be legally bound as follows: I. AGREEMENT WILL NOT PREVENT DIVORCE PROCEEDINGS This agreement shall not affect the right of the Wife or the Husband to a divorce on lawful grounds. The parties intend to secure a mutual consent no-fault divorce pursuant to the provisions of Section 3301(c) of the Divorce Code of 1980, as amended. II. EFFECT OF DIVORCE DECREE The parties agree that the provisions of this agreement, unless otherwise stated, will continue after a Decree of Divorce is entered. III. AGREEMENT SHALL BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of the agreement shall be incorporated into PAGE 2 OF 18 any divorce decree that may be entered with respect to them, and this Agreement will be independent of any Decree in Divorce. The parties agree that all the provisions of this Agreement constitute a binding contract for the purposes of any enforcement action or proceedings. IV. DATE OF EXECUTION The date of execution of the Agreement is the day on which the Agreement is signed by both parties. V. DATE OF DISTRIBUTION Any transfer of property, funds and/or documents pursuant to the Agreement shall be made on the date of execution of this agreement, unless otherwise specified in this Agreement. VI. TERMINATION OF AGREEMENT If a final Decree of Divorce is not entered within one year of the date of execution of this Agreement, the Agreement shall automatically become null and void and the Agreement shall not be binding on the parties. Any property or funds distributed pursuant to the Agreement shall be returned to the party holding the property or funds before the date of execution. PAGE 3 OF 18 VII. PRO SE REPRESENTATION Both parties are aware of their respective rights to seek advice of counsel, and the parties have chosen to reach this Agreement by themselves. The parties each acknowledge that they have made full and complete disclosures of all information relevant to a distribution of their property and to a determination of their respective marital rights and responsibilities. Each party understands the terms, conditions and provisions of this Agreement and believes them to be fair and reasonable. Each party is entering into the Agreement freely and voluntarily and the execution of this Agreement is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. VIII. EFFECT OF BANKRUPTCY In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while this Agreement is in effect, that party waives any and all rights to any property held by the debtor and sought by the creditor-spouse in fulfillment of this agreement. The debtor will convey to the spouse any and all property necessary to fulfill this agreement. No obligations pursuant to this Agreement are dischargeable under any state or federal law. PAGE 4 OF 18 IX. CHILD SUPPORT Husband agrees to pay to Wife $1200 per month for the support of the children until the children become emancipated. These payments commenced on January 1, 2007. These payments will continue for each child until each child is emancipated. Each child will be emancipated on (1) reaching age eighteen or (2) graduation from high school, whichever is later, or (3) entry into the armed services, or (4) marriage, or (5) on becoming self-supporting. Husband agrees to cover the following child related expenses: allowance, cell phones, life insurance policies, and Matthew's Scout related expenses. Wife agrees to cover the following child related expenses: hair cuts, clothing/shoes, school lunches, and Kristina's ice skating expenses. Other child related expenses will be paid as mutually agreed by Husband and Wife. X. COLLEGE COSTS Husband agrees to pay for one-half of reasonable undergraduate college costs of the children as long as each child is enrolled and is diligently seeking a degree. Children will be responsible for the other half of reasonable undergraduate college costs. These costs include but are not limited to such items as room and board, tuition, books, and transportation. This obligation will cease on graduation PAGE 5 OF 18 or withdrawal from college. XI. CHILDREN'S HEALTH INSURANCE Wife agrees to provide health-care insurance coverage for the children. Husband and Wife will each be responsible to pay one-half of any reasonable medical expense not covered by such insurance including deductibles. Husband and Wife will continue to pay for reasonable medical expenses of each child until that child is emancipated, as described in Paragraph IX. In the event that Wife's Employer no longer covers children's insurance at no cost to Wife, Wife and Husband will pay one-half of Health Insurance costs of each child until children that child is emancipated, as described in Paragraph IX. XII. SUPPORT In consideration for the provision contained herein for the respective benefits of the parties and other good and valuable considerations, the parties hereto mutually waive any and all claim or right to temporary or permanent maintenance or support, whether past, present or future. Thus, each of the parties give up any right to spousal support that they may have from the other. XIII. ALIMONY PAGE 6 OF 18 In consideration for the provision contained herein for the respective benefits of the parties and other good and valuable considerations, the parties hereto mutually waive any and all claim or right to temporary or permanent alimony, whether past, present or future. Thus, each of the parties give up any right to spousal alimony that they may have from the other. XIV. CUSTODY OF CHILDREN The parties agree that Husband and Wife shall share legal custody and Husband and Wife will share primary physical custody of the children. Wife or Husband shall also have the right to speak on the phone with the children during reasonable hours and for reasonable amounts of time. Wife and Husband shall have visitation and custody rights according to the following schedule: Matthew and Kristina will alternate weeks between Husband and Wife. Exchange will be made on Friday's at 6:00 p.m. unless mutually agreed by both parents. During summer break, Matthew and Kristina will spend approximately 6 weeks (one-half time) with each parent. Matthew and Kristina will spend Christmas and Easter with Wife on the first year of this agreement is in effect. They will spend Christmas and with Husband the following year and will alternate in the following years. Matthew and Kristina will spend Thanksgiving with Husband the first year of PAGE 7 OF 18 this agreement is in effect and will spend the next Thanksgiving with Wife and will alternate in following years. Matthew and Kristina will spend other holidays as the parties agree. XV. CHANGE OF RESIDENCE If either party desires to change residence, that party shall give the other party at least 90 days' prior written notice in order to allow both parties to make new custody and visitation agreements if necessary. If the parties are unable to make such an agreement, both parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania, shall have jurisdiction to issue a custody and visitation order. XVI. HEALTH AND MEDICAL INSURANCE Wife agrees to provide the children health and medical insurance during the period beginning with the date of execution of this Agreement until the final decree in divorce between the parties is entered. In the event that Wife's employer no longer covers children's costs, Husband and Wife will share cost of insurance equally. PAGE 8 OF 18 XVII. PERSONAL PROPERTY Longenberger Baskets, Carnival Glass, wall hangings, personal childhood mementos in attic, and tanning table located at Husband's residence remain the property of Wife-and will be delivered to Wife when the final decree in divorce between parties is entered or later if mutually agreed to by Husband and Wife. Photographs, Negatives, Scrap Books and Photo Albums located at Wife's residence will be divided equitably with husband's share delivered to Husband when the final decree in divorce between parties is entered or later if mutually agreed to by Husband and Wife. Wife agrees that all other personal property not otherwise identified in this Agreement now in Husband's possession is the sole property of Husband, and Husband agrees that all personal property not otherwise identified in this Agreement now in possession of Wife is the sole property of Wife. XVIII. MOTOR VEHICLES A. The 2002 Dodge Caravan, VIN number xxxxxxxxxxxx85041, shall be the sole property of Wife, free of liens and encumbrances. Husband agrees to sign and deliver any and all documents necessary to transfer title of this motor vehicle on the date of execution of this Agreement. PAGE 9 OF 18 B. The 1999 Ford Explorer, VIN number xxxxxxxxxxxx65001, shall be the sole property of Husband, free of liens and encumbrances. Wife agrees to sign and deliver any and all documents necessary to transfer title of this motor vehicle on the date of execution of this Agreement. C. The 1979 Honda motorcycle, VIN number xxxxxxxx2420, shall be the sole property of Husband (for Son Benjamin), free of liens and encumbrances. D. The 1999 Nissan Stanza, VIN number xxxxxxxxxxxx04479, shall be the sole property of Husband (for Daughter Jennifer), free of liens and encumbrances. XIX. BANK ACCOUNTS The parties agree that all funds in the bank accounts numbered xxxxxx0106, xxxxxx0717 and xxxxxx8286 at the Sovereign Bank are the sole property of Husband, and Wife now waives any and all future claims to those funds. The parties also agree that all funds in the bank account numbered xxxxxx6366 at the Sovereign Bank is the sole property of Wife, and Husband now waives any and all future claims to those funds. Sovereign Bank Account xxxxxx2006 will remain property of Husband held in Trust for daughter Kristina Kramer and Sovereign Bank Account xxxxxx1990 PAGE 10 OF 18 will remain property of Husband held in Trust for son Matthew Kramer. XX. REAL ESTATE TRANSFER Wife shall sign and deliver to Husband all documents necessary to transfer title to Husband in the real estate known as 4 Cumberland Estates Drive and situated at 4 Cumberland Estates Drive, Mechanicsburg Pennsylvania and property owned on leased land known as 44 Woodrow Road and situated at 44 Woodrow Road, Gardners in Cooke Township Pennsylvania. These titles shall be free of liens and encumbrances, except for the existing mortgage, which Husband assumes. Husband agrees to indemnify and hold harmless Wife and for any mortgage payments, taxes, liability and expense incurred in connection with these properties. Wife waives any and all rights or claims he may have to any insurance policies held in connection with said real estate, or the proceeds from any such insurance policies. The documents necessary to carry out the provisions in this paragraph shall be delivered to Husband no later than July 1, 2007. In consideration, Husband agrees to pay Wife $40,000 no later than July 1, 2007. If mutually agreed to by Husband and Wife, payment or partial payment can be postponed at which time 4% interest compounded annually will be added to unpaid amount. PAGE 11 OF 18 XXI. Stocks and Bonds Husband will retain ownership of all remaining EDS stock and EDS stock options in his name. Wife relinquishes any/all rights to ownership of said EDS stock and EDS stock options. Any/All AT&T, AlcateULucent, and Avaya stock owned jointly by both Husband and Wife will be sold and proceeds will be split equally between Husband and Wife. Any/All U.S. Savings Bonds in Husband's name will be sold at appropriate times to be used by Husband for Children College expenses. XXII. RETIREMENT BENEFITS Husband agrees that Wife shall retain the following retirement assets/benefits and Husband relinquishes all rights to ownership of the following: A. Sovereign Bank IRA - #xxxxxx6674 B. Ameriprise Financial Mutual Funds - #Group xxxx-xxxx-x-1001, Client # xxxx-xxxx-3-001 C. Prudential Permanent Life Insurance - #xxxxx0395 D. Prudential Term Life Insurance - #xxxxx070 PAGE 12 OF 18 Wife agrees that Husband shall retain the following assets/retirement benefits and Wife relinquishes all rights to ownership of the following: A. Sovereign Bank IRA - #xxxxxx6666 B. EDS 401(K) Savings Plan C. EDS Pension D. Prudential Variable Interest Sensitive Life - #xxxx763 E. Prudential Life - #xxxxx959 XXIII. DEBTS, LIABILITIES AND OTHER OBLIGATIONS The parties agree to divide the responsibilities for paying their debts according to the list below. Each party further agrees to pay these debts in full and on time. Each party releases the other party from those debts not assigned to that party and releases that party from any penalties resulting in connection with these debts and liabilities. Each party agrees that no debts shall be incurred for which the other may be liable except as stated in this Agreement. PAGE 13 OF 18 DEBT PAYOR Equity Loan on 4 Cumberland Estates Dr, Mechanicsburg, PA Husband MasterCard Account (Bank America) - #xxxx xxxx xxxx 1461 Husband MasterCard Account (GM Card) - #xxxx xxxx xxxx 5070 American Express Account (Costco) - #xxxx xxxxxx x 2002 CitiFinancial -Harris TV & Appl. - #xxxx-xxxx-xxxx-1158 Care Credit Account- #xxxx xxxx xxxx 5495 Care Credit Account - #xxxx xxxx xxxx 6247 Kohl's Account - #xxx-xxxx-355 Pier 1 Account - #xxx-xxx-957-0 Husband Husband Husband Wife Wife Wife Wife XXIV. PROPERTY ACQUIRED AFTER SIGNING AGREEMENT Any property acquired by either party after this Agreement is executed is the sole owner of that property, and any and all claims by the other party to that property are waived. XXV. LIFE INSURANCE Husband agrees to purchase alife-insurance policy naming the other party as beneficiary. Said policy will be for an amount sufficient to meet all obligations pursuant to this agreement in the event of the death of the obligated party. PAGE 14 OF 18 Husband agrees not to encumber policy. XXVI. TAXES The parties agree that they will file a joint Federal Income Tax return for the 2006 tax year. Husband will pay state, federal and local income taxes for the 2006 Tax year. Any refunds will be the property of Husband. The parties agree that they will file a joint Federal Income Tax return for the 2007 tax year unless mutually agreed. If Husband and Wife File Joint for the 2007 Tax year, Husband will pay state, federal and local income taxes. Any refunds will be the property of Husband. Husband shall claim children on yearly Income Tax Returns until children are emancipated or upon completion of college degrees. XXVII. METHOD OF PAYMENT All periodic payments to Wife, unless specified otherwise, shall be mailed or delivered to Wife at her residence at 7 Lismore Place, Mechanicsburg, Pennsylvania, or at her current residence if she moves. XXVIII. CONSOLIDATION The agreement constitutes the entire and full agreement between the parties. PAGE 15 OF 18 No other agreements have been made between the parties. XXIX. SEVERABILITY If any clause is held unenforceable or found to be in any way unexecutable, or if a court alters or holds unenforceable any clause in this contract, this shall in no way affect or alter the other clauses in the agreement, which shall remain in full force. Each party has carefully read and fully understands all clauses, statements, provisions and conditions in this Agreement. IN WITNESS THEREOF, intending to be legally bound hereby, the parties have set their hands and seals the day and year first written above. WITNES WIFE ~----(SEAL) WITNESS HCTSBAND c~ hu°l~ ~n~~ i r<.(SEAL) ~ ~xrt~rnr~cc ~xnc~ PAGE 16 OF 18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the /,S"~ day of , 2007, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the City of Mechanicsburg and County of Cumberland, personally appeared Craig Alan Kramer, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS THEREOF, I have hereunto set my hand and official seal. NOTARY PUBLIC Commonwealth ol` s'ennsyhrania NOTARIAL SEAL SHIRLEY A. BEf1Ri?SLEI(, Notary Pubilc Silver Sprinngq Twp., Cumberland Co. My Commission Expires Od.13, 2008 PAGE 17 OF 1$ a COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the ~-' da of ~~~ X , 2007, before me, a Notary Y Public of the Commonwealth of Pennsylvania, residing in the Mechanicsburg and County of Cumberland, personally appeared Kathryn Kay Kramer, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS THEREOF, I have hereunto set my hand and official seal. ~i G'~~~ NOTARY PUBLIC Commonweaith of Pennsylvania NOTARIAL SEAL SHIRLEY A. BEARDSL~'!, P~9otary P~!~iic Silver Spring 14~p., Cunbe~iand Co. My Commission Explrns Oct. 23, 2008 PAGE 18 OF 18 r ' t._y ~--, = in ...._ ~. S .. .. _ i r,.~ G:i r, ~ __ .. ' ~ ) z . :=t. _ C...- Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 No. 07-923 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 20, 2007. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. ( of dan 1. ~ , 2007 C% ~ ~~ {~ .---' .~.t ~~ _ -~r; r-. ~a; .~~. _:~, ~,_ ~*,? ~ C'r`-~~; ~,,.~ .~ _ --. -V„~ r^^ ~w. ~'l Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v. CIVIL DIVISION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-923 CIVIL TERM Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 Decree in Divorce 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. 4. 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. (Def ant ~, o~ , 2007 Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717) 691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF .COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION No. 07-923 CIVIL TERM DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit aze true and correct. I understand that false statements herein made aze subject to penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. (D t) o~~ , 2007 °' C~ ~~~ ~,.., °r~ "C T, ~ C"` ~~ ~~ =i _~ C': -.' ~~ ~r Craig Alan Kramer IN THE COURT OF COMMON PLEAS 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 :CUMBERLAND COUNTY, PENNSYLVANIA (717) 691-9457 CIVIL DIVISION v. No. 07-923 CIVIL TERM Kathryn Kay Krarner 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 20, 2007. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. l ~~~.~..~--- (Plamtif~ (L1 A~ 02 _~ , 2007 r"- `--~ -,-r ~_ 7 T1 t"'+7 ~-7 ~.' t,.,.~ __ ( i.:.. _ _ ~~~ ~~+i ,.. ~i .. ~ Craig Alan Kramer IN THE COURT OF COMMON PLEAS 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 :CUMBERLAND COUNTY, PENNSYLVANIA (717) 691-9457 CIVIL DIVISION v. No. 07-923 CIVIL TERM Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 Decree in Divorce is entered by the Court and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this affiidavit 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. (Plaintiff (tilC~ ( , 2007 r.._ , ~ ~a1 _ .,.{ .1= --rs ~ ~ ~ '- 'i"~ ~ C .'S _ _~_'. t"'~ ~~ . Craig Alan Kramer 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 (717)691-9457 v. Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717) 756-7077 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No. 07-923 CIVIL TERM PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this afFidavit are true and correct. I understand that false statements herein made are subject to penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. (Plaintiff day ~3 , 2007 r.-a C':= c: a t~ .- - ~ - -~`t .~" ---i nay _ C.+.- ~y_ , - _- - G.: ,. ,a _ L`7 ,., _...., - ~, ^y. ~--, 7 Craig Alan Kramer IN THE COURT OF COMMON PLEAS 4 Cumberland Estates Dr. Mechanicsburg, Pa. 17050 :CUMBERLAND COUNTY, PENNSYLVANIA (717) 691-9457 CIVIL DIVISION v. No. 07-923 CIVIL TERM Kathryn Kay Kramer 7 Lismore Place Mechanicsburg, Pa. 17050 (717)756-7077 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Februar~20 2007, by acceptance of service. 3. Complete either paragraph (a) or (b) (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintii~: 2007 By Defendant: ~, ~ ~,, 2007 (b) (1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: , 2007 (2) Date and Filing and service of the plaintiff s affidavit upon the respondent: 4. Related claims pending: Incorporation of the attached Agreement. 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 Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: o Date defendant's Waiv of Notice in 3301 (c) Divorce was filled with the Prothonotary: ~4 a ~ a.o a '~ Plaintiff k ~, 2007 :`~ a ~`~ ) rm '3 ~,a :_ --: • ._t °r' tiz-- 3"^,% ~J ~~~ .. ~ -' I N THE COURT OF COMMON PLEAS Cca;~ Ptlcw. Kc c~ec ~~~~~~~ VERSUS Ka-~~«,n KQ~, K~GM~ DECREE IN DIVORCE AND NOW, ~~/ ~~, IT IS ORDERED AND DECREED THAT G~A~_Ato~. \_\Ca.M2~' PLAINTIFF, AND KQ~Y1Cy f~ K0.4 KS~GIheC ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. n THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD~N T~ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ~~ BY THE COURT: A ST: ~ J. . M0/l ~n,nnnrnt~ ~~l_ OF CUMBERLAND COUNTY STATE OF PENNA. ~;; PRbTHbN~TARY ~~-~»„ ~'~°'`~ ~ '~°~ ,~ J ~~ .s.~ Q • ,Sf ~