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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF ~, PENNA.
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LARRY ROBERTSON,
Plaintiff
No. .
97-1584
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BARBARA ROBERTSON,
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Defendant
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DECREE IN
DIVORCE
AND NOW, . . MtM-t. .. f~.. .. . . .. .. 19.<1':1.. it is ordered and
decreed that. . . .. .. .. .. . . .. .LARRY .ROBERTSON.. .. .. .. .... .. ...., plaintiff.
and. . . . . . . . . . . . . . . . . . . . . . . . . BARBARA. ROBERTSON. . . . . . . . . . . .. . ., defendant,
are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered; None.
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It is further ORDERED, ADJUDGED and DECREED that the terms. provisions and
. conditions 'of 'a'certain NaritaI'SettIemerit'Agreemerit 'oetweeri'tHe'parties'dated
. .A.p'r.i.l. .2.9... .1.~9.~.. .ar:~ .i)\c;qr:p'qr:~~~<\ .:l,l\ .t.l1:l,fj .QElc;t:~e~.. .Q:l,~qr:c;El .Qy' .r:El~Elr:Ell\c;El .IlS
fully as if the same were sct forth herein at Ie h. Said Agreement shall
not mer e with but shall survive thi ecree i v ceo
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LARRY ROBERTSON,
Plaintiff
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CIVIL ACTION - LAW
IN DIVORCE
v.
NO. 97-1584 CIVIL TERM
BARBARA ROBERTSON,
Defendant
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following infomlUtion, to the court for entry of a divorce
decree:
I. Ground for divorce: Irrctrievable breakdown under ~3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Service accepted by Barbara Sumple-
Sullivan, Esquire on June 30,1998; Acceptance of Service filed on July I, 1998.
3. Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code:
by plaintiff, April 29, 1999; by defendant, April 30, 1999.
4. Related claims pending: All claims resolved by Marital Settlement Agreement dated
April 29, 1999.
5. Date plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the prothonotary:
contemporaneously herewith; date defendant's Waiver of Notice in ~330I(c) Divorce was
filed with the prothonotary: contemporaneously herewith.
Date:
s-AA;
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Donald T. Kissinger, Esq Ire
HOWETT, KISSINGER & MILES, P.C.
130 Walnut Street
P. O. Box 810
Harrisburg, PAl 7 I 08
Telephone: (717) 234-2616
Counsel for Plaintiff
Larry Robertson
------~
LARRY ROBERTSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
: PENNSYLVANIA
vs.
CIVIL ACTION /') '-r-:'
NO. q 1- /S'J'I'/ l:IUl'/ Ie r2../'Tj
: IN DIVORCE
BARBARA ROBERTSON,
Defendant
NOT ICE
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D E FEN D
You ~ave been sued in court. If you wish to defend against
the claimu 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:
Office of the Prothonotary
cumberland county court House
1 Courthouse square
Carlisle, PA 17013-3387
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 SE'J' FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
cumberland county Court House
Fourth Floor
1 Courthouse square
carlisle, PA 17013-3387
(717) 240-6200
LARRY ROBERTSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
,
BARBARA ROBERTSON,
Defendant
CIVIL ACTION /J. '--.-
NO. 97-Ir;p~ Crud fC'LivI
IN DIVORCE
'I
vs.
CONSOLIDATED COMPLAINT IN DIVORCE
1. Plaintiff is Larry Robertson, a citizen of Pennsylvania,
residing at 1022 Armstrong Road, Carlisle, Cumberland County,
Pennsylvailia.
2. Defendant is Barbara Robertson, a citizen of Pennsylvania,
residing at 252 Franklin street, Carlisle, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant are sui iuris and have been bonafide
residents of the Commonwealth of Pennsylvania for at least six
months immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on
December !O, 1989, in Cumberland County, Pennsylvania.
5. The 1.1arr iage is irretr ievably broken.
6. Neither Plaintiff nor Defendant is in the military or naval
service of the United states or its allies within the provisions
of the So:diers' & Sailors' civil Relief Act of the Congress of
1940 and its amendments.
7. There has been no prior action for divorce or annulment
instituted by either of the parties in this or any other
jurisdiction.
"
VERIFICATION
I, Larry RObertson, verify that the statements made in the
Complaint are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. 54904
relating to unsworn falsification.
IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LARRY ROBERTSON,
Plainti IT
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CIVIL ACTION - LAW
IN DIVORCE
v.
NO. 97-1584 CIVIL TERM
BARBARA ROBERTSON,
Defendant
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
I. A complaint in divorce under ~3301 (c) of the Divorce Code was filed on
March 27,1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety
days have elapsed from the date of filing and service of the complaint.
3. I consent to the entry ofa 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 statemcnts herein are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to
unsworn falsification to authorities.
Date:
'i/P-9/91
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LARRY ROBERTSON,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-1584
BARBARA ROBERTSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 27, 1997.
2. The marriage of the PlaintilTand 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 I do not claim them before a divorce is granted.
S. 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: ~::v/~
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BARBARA ROBERTSON
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
LARRY ROBERTSON,
Plaintiff
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CIVIL ACTION - LAW
IN DIVORCE
v.
NO. 97-1584 CIVIL TERM
BARBARA ROBERTSON,
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
63301 (e) OF TilE DIVORCE CODE
I. I consent to thc cntry 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 daim 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 arc 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:
LjJf}.9/9i
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LARRY ROBERTSON,
PlaintilT
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 97-1584 - CIVIL TERM
BARBARA ROBERTSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICA TE OF SERVICE
I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certifY that on this date, I
served a true and correct copy of the Acceptance of Service, in the above-captioned mailer upon the
following individual(s), by United States first-class mail, postage prepaid, addressed as follows:
Michael Rentschler, Esquire
28 North 32nd Street'
Camp Hill, PA 17 II
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, P A 17070- I 931
(717) 774-1445
Supreme Court J.D. 32317
Allorney for Defendant
DATE:~J"
v.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LARRY ROBERTSON,
Plaintiff
NO. 97-1584 CIVIL TERM
BARBARA ROBERTSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE WITHDRAWING ANCILLARY CLAIMS
TO THE PROTHONOTARY:
Please withdraw all ancillary claims filed by the Plaintiff, Larry Robertson, in his
Complaint in Divorce docketed to the above term and number inasmuch as the parties have
reached an agreement resolving all issues.
Respectfully submitted,
Date:
5"" /'1 ~
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Donald T. Kissinger, Esquire
HOWETT, KISSINGER & MILES, P.C.
130 Walnut Street
P. O. Box 810
Harrisburg, P A 17108
Telephone: (717) 234-2616
Counsel for PlaintilT
Larry Robertson
LAW OrUrls Of
1I0WETT. KISSINGEU & MILES, P.C.
110 WALNUT STIlEET
IIOST OffiCI: nox MIO
IIARRlsllURU, l'I:NNS\'LVANIA 1710M
JOliN C. 1I0WETT, JR.
lJONALll T. KISSINGER
PA TRlCIA A. MIEES
ClNIlY S. CONLEY
(717111+-2616
April 30, 1999
FAX 17171 2l4.1401
IlEDIlA M. SIIIMP,
Lelal Auhlanl
E. Robert Elicker, III, Esquire
Divorce Master
9 North Hanover Street
Carlisle, PA 17013
~
Re: Larry Robertsoll v. Barbara Robertsoll
No. 97-/584/ Divorce
Dear Mr. Elicker:
Enclosed please find a copy of the Marital Settlement Agreement entered
into between the above-referenced parties. Would you please return the file to the
courthouse so that I may finaliz~ !"'is divorce action.
Thank you for your assistance with this matter.
Sincerely,
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Enclosure
ee: Barbara Sump Ie-Sullivan, Esquire
Larry S. Robertson
.
'*
OFFICE OF DIVORCE MASTER
CUM8ERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Streel
Carlisle. PA 17013
(717) 240.6535
E. Robert Elicker, II
Divorce ~aster
Tracl .10 Colver
Office Manager/Reporter
West Shore
697-0371 Exl. 6535
July 13, 199B
Michael D. Rentschler, Esquire
28 North 32nd street
Camp Hill, PA 17011
Barbara Sumple-Sullivan
Attorney at Law
549 Bridge street
New Cumberland, PA 17070
RE: Larry Robertson vs. Barbara Robertson
No. 97 - 1584 civil
In Divorce
Dear Mr. Rentschler and Ms. Sumple-sullivan:
By order of Court of President Judge George E. Hoffer
dated July 2, 199B, the full-time Master has been appointed in
the above referenced divorce proceedings.
A divorce complaint was filed on March 27, 1997, raising
grounds for divorce of irretrievable breakdown of the marriage
and the economic claim of equitable distribution. No claims
have been raised for alimony or counsel fees and expenses,
although the motion for appointment of Master indicates those
issues are before the Master. If no pleadings are filed raising
additional claims, I will deal only with the claim raised of
equitable distribution in the complaint.
I am going to proceed on the assumption that grounds for
divorce are not an issue. I am not able to tell from the
pleadings as to whether or not the parties will consent or have
been separated for a period in excess of two years. However,
based on my assumption that we will not be dealing with grounds
for divorce issues, I am directing each counsel to file a
pre-trial statement in accordance with P.R.C.P. 1920.33(b) on or
before Monday, August 3, 1998. Upon receipt of the pre-trial
statements, I will immediately schedule a pre-hearing conference
Mr. Rentschler and Ms. Sumple-Sullivan, Attorneys at Law
13 July 1998
Page 2
with counsel to discuss the issues and, if necessary, schedule a
hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
LARRY ROBERTSON,
PlaintilT
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CIVIL ACTION . LAW
IN DIVORCE
v.
NO. 97-1584 CIVIL TERM
BARBARA ROBERTSON,
Defendant
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the appearance of Michael Rentschler, Esquire, on behalf of Larry
Robertson, PlaintilT in the above-captioned divorce action, and enter the appearance of
Donald T. Kissinger, Esquire.
Date:
r;/~r
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Respectfully submilled,
':--~~ ~
Donald T. Kissinger, ESqUi~
HOWETT, KISSINGER & MILES, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, P A 17108
Telephone: 717-234-2616
Date:
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Michael Rentschler, Esquire
28 North 32nd Street
Camp Hill, PA 17011
Telephone: 717-975-9129
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-1584 - CIVIL TERM
LARRY ROBERTSON,
PlaintilT
BARBARA ROBERTSON.
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Defendant, moves the court to appoint a master with respect to the following claims:
i
f
( ) Divorce
( ) Annulment
(X) Alimony
(X) Alimony Pendente Lite
(X) Distribution of Property
( ) Support
(X) Counsel Fees
(X) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims for which the appointment of a master is requested.
(2) Plaintiff has appeared personally in this action by his attorney, Michael Rentschler,
Esquire.
(3) The Statutory grounds for divorce are irreeoncilabIe differences.
(4) The action is contested with respect to the following claims: equitable distribution,
alimony, alimony pendente lite, eounsel fees and eosts.
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take one day.
Barbara Sumple-SuIlivan, Esquire
Attorney for Defendant
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court J.D. No. 32317
(7) Additional information, if any, relevant to the
Dated: ~/Jf!fr
LARRY ROBERTSON,
PlaintilT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-1584 - CIVIL TERM
BARBARA ROBERTSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER APPOINTING MASTER
AND NOW W I9!li [" kl ~ Esquire, is appointed master with respect
to the following claims: equitable distribution, alimony, alimony pendente Ute, counsel fees and
eosts.
By the Court:
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LARRY ROBERTSON,
PlaintilT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-1584 - CIVIL TERM
BARBARA ROBERTSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and
correct copy of the foregoing MOTION FOR APPOINTMENT OF MASTER, in the above-
captioned mailer upon the following individual(s) by first class mail, postage prepaid, addressed as
follows:
Michael Rentschler, Esquire
28 North 32nd Street
CampHilI,PA 17011
Bar ara Sumple-Sullivan, Esquire
Attorney for Defendant
549 Bridge Street
New Cumberland, P A 17070-1931
(717) 774.1445
Supreme Court 1.0. No. 32317
DATED: 0,9/7 f
LARRY ROBERTSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1584 CIVIL
BARBARA ROBERTSON,
Defendant
IN DIVORCE
ORD~~OURT
AND NOW, this:> day of
1999, the economic claims raised in
aving been
resolved in accordance with a marital settlement agreement dated
April 29, 1999, the appointment of the Master is vacated and
counsel can file a praecipe transmitting the record to the Court
requesting a final decree in divorce.
P.J.
co:
Donald T. Kissinger
Attorney for Plaintiff
Barbara Sumple-Sullivan
Attorney for Defendant
~.... n~:.c.cL 4"/99.
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MARITAL SETTLEMENT AGREEMENT
TillS AGREEMENT is made thiS~-:y of ~ . 1999. by
and between LARRY S. ROBERTSON, of Cumberland County, Pennsylvania, and BARBARA
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F. ROBERTSON, of Cumberland County, Pennsylvania;
WITNESSETH:
WIIEREAS, Larry S. Robertson (hereinafter referred to as "Husband"), social security
number 486-46-3794, was born on February 4, 1942, and presently resides at I 022 Armstrong
Road, Carlisle, Cumberland County, Pennsylvania, 17013.
WHEREAS, Barbara F. Robertson (hereinafter referred to as "Wife"), social security
number 192-30-1831, was born on March 26, 1939, and presently resides at 252 Franklin Street,
Carlisle, Cumberland County, Pennsylvania, 17013.
WHEREAS, the parties hereto are husband and wife, having been lawfully married on
December 30, 1989;
WHEREAS,the parties have lived separate and apart since on or about August 19, 1996;
WHEREAS, no children were born of the marriage between the parties;
WHEREAS, the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other, including, without limitation,
the settling of all matters between them relating to the ownership of real and personal property,
the support and maintenance of one another and, in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW, THEREFORE, in consideration of these premises, and of the mutual promises,
covenants and undertakings hereinafter set forth, and for other good and valuable consideration,
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the receipt and sufficiency of which is hereby acknowledged by each of the parties herelo,
Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows:
1. ADVICE OF COUNSEL. Each party acknowledges that he or she has
had the opportunity to receive independent legal advice from counsel of his or her selection
(Donald T. Kissinger, Esquire for Husband and Barbara Sump Ie-Sullivan, Esquire for Wife).
Each party fully understands the facts and his or her legal rights and obligations, and each party
acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable, and
that it is being entered into freely and voluntarily, and that the execution of this Agreement is not
the result of any duress or undue influence, and that it is not the result of any improper or illegal
agreement or agreements. In addition, each party understands the impact of the Pennsylvania
Divorce Code, whereby the court has the right and duty to determine aU marital rights of the
parties including divorce, alimony, alimony pendente lite, equitable distribution of aU marital
property or property owned or possessed individually by the other, counsel fees and costs of
litigation and, fuUy knowing the same, each party hereto stilI desires to execute this Agreement,
acknowledging that the terms and conditions set forth herein are fair, just and equitable to each
of the parties, and waives his and her respective right to have the Court of Common Pleas of
Cumberland County, or any other court of competent jurisdiction, rnake any determination or
order aITeeting the respective parties' rights to alimony, alirnony pendente lite, support and
maintenance, equitable distribution, counsel fees and costs of litigation.
2. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges
that he or she is aware of his or her right to seek discovery, including but not limited to, written
interrogatories, motions for production of documents, the taking of oral depositions, the filing of
inventories, and all other means of discovery permitted under the Pennsylvania Divorce Code or
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the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or
she has had the opportunity to discuss with counsel the concept ofrnarital property under
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Pennsylvania law and each is aware of his or her right to have the real and/or personal property,
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estate and assets, earnings and income of the other assessed or evaluated by the courts of this
commonwealth or any other court of competent jurisdiction. The parties do hereby acknowledge
that there has been full and fair disclosure to the other of his or her respective income, assets and
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liabilities, whether such are held jointly or in the name of one party alone. Each party agrees that
any right to further disclosure, valuation, enumeration or statement thereof in this Agreement is
hereby specifically waived, and the parties co not wish to make or append hereto any further
enumeration or statement. Each party warrants that he or she is not aware of any marital asset
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which is not identified in this Agreernenl. The parties hereby acknowledge and agree that the
division of assets as set forth in this Agreement is satisfactory to them. Each of the parties hereto
further covenants and agrees for himself and herself and his or her heirs, executors,
administrators or assigns, that he or she will never at any time hereafter sue the other party or his
or her heirs, executors, administrators or assigns in any action of contention, direct or indirect,
and allege therein that there was a denial of any rights to full disclosure, or that there was any
fraud, duress, undue influence or that there was a failure to have available full, proper and
independent representation by legal counsel.
3. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter,
live separate and apart. Each shall be free frorn all control, restraint, interference and authority,
direct or indirect, by the other. Each may reside at such place or places as he or she may select.
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Each may, for his or her separate use or benefit, conduct, carry on or engage in any business,
occupation, profession or employment which to him or her may seem advisable. Husband and
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Wife shall not molest, harass, disturb or malign each other or the respective families of each
other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any
manner whatsoever with him or her. Neither party will interfere with the use, ownership,
enjoyrnent or disposition of any property now owned by or hereafter acquired by the other.
4. SETTLEMENT UPON SALE OF ARMSTRONG ROAD
RESIDENCE CONDITION PRECEDENT TO AGREEMENT. The parties acknowledge
and agree that completion of settlement with respect to the sale of the real property located at
1022 Armstrong Road, Carlisle, Cumberland County, Pennsylvania, 17013 as referenced in
paragraph 6(a) hereinafter shall constitute a condition precedent to the parties' respective rights
and responsibilities created and/or saved by this Marital Settlement Agreement. In the event that
selllement with regard to the sale of said real property is not conducted for any reason, the terms
and provisions of this Marital Selllement Agreement shall be deemed null and void.
Accordingly, counsel for Husband shall hold the fully-executed Marital Selllement Agreement
documents, fully-executed documents surrounding the transfer of GMElEDS stock and dividends
as required hereinafter, and the professionally-taken photograph referenced hereinafter in his
possession pending confirmation that settlernent with regard to the real property has been
completed pursuant to the terms of sales agreement dated April 8, 1999. Upon such
confirmation, counsel for Husband shall deliver executed copies of the Marital Selllement
Agreement and the professionally-taken photograph to counsel for Wife, and counsel for
Husband shall be permilled to release to Husband any and all documents surrounding transfer of
the aforementioned stock and dividends.
5. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and
the parties agree, that by this Agreement they have resolved all ancillary economic issues related
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to the dissolution of their marriage and thus any divorce action with respect to these parties shall
be limited to a claim for divorce only. The parties acknowledge that on March 27, 1997,
Husband initiated a divorce action under the no.fault provisions of the Divorce Code by filing a
complaint docketed at number 97-1584 in the Cumberland County Court of Common Pleas. The
parties acknowledge that the ninety (90) day waiting period provided for under ~330I(c) of the
Divorce Code has expired. Therefore, contemporaneously with the execution of this Agreement,
each party will sign an Affidavit of Consent to Divorce and Waiver of Notice ofIntention to
Request Entry of Divorce Decree and deliver same to counsel for Husband, who shall prornptly
submit said affidavits and waivers to the court, along with a Praecipe to Transmit Record, Vital
Statistics Form and any and all other documents necessary to precipitate the prompt entry ofa
divorce decree.
6. EOUlTADLE DISTRIBUTION.
(a) Armstrone Road Resldenee. The parties acknowledge that they
are the owners, as tenants by the entirety, of real property located at 1022 Armstrong Road,
Carlisle, Cumberland County, Pennsylvania, 17013 (hereinafter referred to as the "Armstrong
Road Residence"), subject to a mortgage, which residence is subject to a sales agreement dated
April 8, 1999 and requiring selllementto be conducted on or before April 30, 1999. The parties
agree as follows with respect to the Armstrong Road Residence:
(I) Each party shall execute any and all documents and
perform such acts necessary to permit selllementto occur as per the sales agreement. The net
proceeds of sale of the Armstrong Road Residence shall be divided with Wife receiving the first
Forty-Nine Thousand Seven Hundred Fifty Dollars ($49,750) of said proceeds and Husband
receiving the remainder of said proceeds. The parties acknowledge and agree that they shall
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jointly instruct the settlement agent to issue two FornI I099s, one to each party, evidencing equal
amounts of sales proceeds to each party.
(2) Pending sale of the residence, Husband shall be entitled to
continue to reside in the Armstrong Road Residence and shall have exclusive possession thereof.
At the time of sale of the property, any pro rata refunds of real estate taxes, homeowner's
insurance or any other prepaid expenses shall be paid directly to Husband and shall be his sole
and separate property. Husband agrees to keep and maintain the residence in good repair
pending its sale. Husband further agrees to pay, until such time as the premises shall be sold,
utilities with respect to the Armstrong Road Residence.
(3) The parties acknowledge and agree that completion of
settlement with regard to the sale of the Armstrong Road Residence pursuant to said sales
agreernent dated April 8, 1999 shall constitute a condition precedent to the parties' respective
responsibilities and rights created by this Marital Settlement Agreement as more fully set forth in
paragraph 4 hereinabove.
(b) Wife's Pre-Marital Real Estate. The parties acknowledge that, at
the time of marriage, Wife owned II residence known and numbered as 252 Franklin Street,
Carlisle, Cumberland County, Pennsylvania and an interest in fifteen (IS) acres ofunirnproved
land on Pipeline Road in Newville, Pennsylvania (hereinafter referred to as "Wife's pre-marital
real estate"). Husband hereby waives any right, title and interest he may have in said pre-marital
real estate, specifically including any increase in value thereof during the marriage.
(e) Furnlshlnl!s and Personaltv.
(I) The parties agree that they have divided by agreement
between themselves all furnishings and personalty located in the Armstrong Road Residence,
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including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and
equipment.
(2) Except as otherwise set forth herein, Husband shall retain,
as his sole and separate property, free of any and all right, title, claim or interest of Wife, all of
the personalty and furnishings remaining in the Armstrong Road Residence, in his possession
elsewhere, and those iterns listed on Exhibit "B".
(3) Except as otherwise set forth herein, Wife shall retain, as
her sole and separate property, free of any and all right, title, claim or interest of Husband, all of
the personalty and furnishings at her current residence and those items listed on Exhibit "A",
(4) Husband's counsel shall deliver the professionally-taken
nude photograph of Wife to counsel for Wife upon completion of the settlement on the sale of
the Armstrong Road Residence as referenced hereinabove.
(d) Motor Vehicles.
(I) Husband agrees that Wife shall retain possession of and
receive as her sole and separate property the 1996 Subaru Outback automobile, along with all
rights under any insurance policies thereon and wiih all responsibility for payment of any
outstanding indebtedness pertaining thereto and insurance thereon, free of any and all right, title,
elairn or interest of Husband. Wife shall indemnify and hold Husband and his property harmless
from any and all liability, cost or expense, including actual attorney's fees, incurred in
connection with any vehicle belonging to Wife by virtue of this subparagraph.
(2) Wife agrees that Husband shall retain possession of and
receive as his sole and separate property the 1993 Pontiac Grand Am SE automobile, along with
all rights under any insurance policies thereon and with all responsibility for payment of any
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outstanding indebtedness pertaining thereto and insurance thercon, free of any and all righi, title,
claim or interest of Wife. Husband shall indemnify and hold Wife and her property harmless
from any and all liability, cost or expense, including actual attorney's fees, incurred in
connection with any vehicle belonging to Husband by virtue of this subparagraph.
(e) Life Insurance. Wife and Husband each hereby specifically
releases and waives any and all right, title, claim or interest that he or she may have in and to any
and all policies ofinsurance owned by or insuring the life of the other, including cash surrender
value, if any, and also specifically to include a waiver of any beneficiary designation thereunder.
Accordingly, it is specifically agreed and acknowledged that, pursuant to this subparagraph, Wife
shall retain sole and exclusive ownership oflhe Prudential whole life policy #63-018-735.
(I) Pension and Retirement Benefits. Wife and Husband each
hereby specifically releases and waives any and all right, title, c1airn or interest that he or she
, may have in and to any and all retirernent benefits (including but not limited to pension or profit
sharing benefits, deferred compensation plans, 401(k) plans, employee savings and thrift plans,
individual retirement accounts or other similar benefits) of the other party. specifically to include
a waiver of any spousal annuity benefits and/or beneficiary designations thereunder.
Accordingly, pursuant to this subparagraph, Husband specifically waives any right, title and
interest he may have in Wife's Pennsylvania Public School Employes' Retirement Systern
Pension and Wife specifically waives any right, title and interest she rnay have in Husband's
EDS Defined Benefit Plan and Husband's EDS Deferred Compensation Plan. Each party shall,
within five (5) days from presentation by the other, any and all documents required by the
employer of the other to eITectuate the terms of this subparagraph.
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(g) Cosh Aecounts, Stocks and Investments.
(I) lIusbond's EDS Federal Credit Union
Cheeklnl!/Sovlnl!s Aecouni 110011332009. Husband shall retain sole and exclusive ownership
of these accounls and Wife hereby waives any right, title and interest she may have in said
accounts.
(2) Husband's Demond Deposit AecounUGMAC Aeeount
119011513511. Husband shall retain sole and exclusive ownership of this account and Wife
hereby waives any right, title and interest she may have in said account.
(3) York Federal Joint Cheeklnl! Aeeount 1109-653809. The
parties have divided the proceeds of this account, and each hereby waives any right, title and
interest he or she may have in the funds received by the other.
(4) Wife's Members First Credit Union Sovlnl!s/Cheeklnll
Aeeount 1167955RO. Wife shall retain sole and exclusive ownership of these accounts and
Husband hereby waives any right, title and interest he may have in said accounts.
(5) Wife's United States Sovlnl!s Bonds. Wife shall retain
sole and exclusive ownership of these bonds and Husband hereby waives any right, title and
interest he may have in said bonds.
(6) 1600 Shares of GME/EDS Stoek and DIvidends.
Husband shall retain sole and exclusive ownership of these shares ofsloek and any dividends
received and Wife hereby waives any right, title and interest she may have in said stock and
dividends. Wife hereby agrees to execute any and all documents required to transfer said stock
and dividends to Husband individually contemporaneously with execution h::reof. Such
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documents shall be held by counsel for Husband pending completion of the settlement on the
sale of the Armstrong Road Residence at which time they shall be released to Husband.
(7) Wife's (403 B) Fldelltv Mutual Fund Aecount
IITl00276830. Wife shall retain sole and exclusive ownership of this account and Husband
hereby waives any right, title and interest he may have in this account.
(8) Wife's IRAs. Wife shall retain sole and exclusive
ownership of all IRAs titled in her name and Husband hereby waives any right, title and interest
he may have in said IRAs.
(h) Mlseellaneous Property. As of the execution date of this
Agreement, any and all property not specifically addressed herein shall be owned by the party to
whom the property is titled; and ifuntitIed, the party in possession. This Agreement shall
constitute a sufficient biIl of sale to evidence the transfer of any and all rights in such property
from each to the other.
(I) Pronertv to Wife. The parties agree that Wife shall own, possess,
and enjoy, free from any claim of Husband, the property awarded to her by the terms of this
Agreement. Husband hereby quitclaims, assigns artd conveys to Wife all such property, and
waives and relinquishes any and all rights thereto, together with any insurance policies covering
that property, and any escrow accounts relating to that property. This Agreement shall constitute
a sufficient bill of sale to evidence the transfer of any and all rights in such property from
Husband to Wife.
OJ Property to Husband. The parties agree that Husband shaIl own,
possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this
Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property, and
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waives and relinquishes any and all rights thereto, together with any insurance policies covering
that property, and any escrow accounts relating to that property. This Agreement shall constitute
a sufficient bill of sale to evidence the transfer of any and all rights in such property frorn Wife to
Husband.
(k) Assumption of Eneumbranees.
(I) Husband shall be solely responsible for any and all
liabilities he has incurred in his name alone, specifically to include any obligations to issuers of
credit cards in his name.
(2) Wife shall be solely responsible for any and all liabilities
she has incurred in her name alone, specifically to include any obligations to issuers of credit
cards in her name.
(3) Unless otherwise provided herein, each party hereby
assumes the debts, encumbrances, taxes and liens on all the property each will hold subsequent to
the eITective date of this Agreement. Each party agrees to indemnify and hold harmless the other
party and his or her property from any claim or liability that the other party will suITer or may be
required to pay because of the debts, encumbrances or liens assumed by the other pursuant to this
Agreement.
(I) Llabilitv Not Listed. Each party represents and warrants to the
other that he or she has not incurred any debt, obligation or other liability, other than those
described in this Agreement, on which the other party is or may be liable. A liability not
disclosed in this Agreernent will be the sole responsibility of the party who has incurred or may
hereafter incur it, and such party agrees to pay it as the same shall becorne due, and to indemnify
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and hold the other party and his or her property harmless from any and all such debts, obligations
and liabilities.
(m) Indemnification of Wife, If any claim, action or proceeding is
hereafter initiated seeking to hold Wife liable for the debts or obligations assurned by Husband
under this Agreement, Husband will, at his sole expense, defend Wife against any such claim,
action or proceeding, whether or not well.founded, and indemnify her and her property against
any damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Wife in connection therewith.
(0) Indemnlfieatlon of Husband. Ifany claim, action or proceeding
is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife
under this Agreement, Wife will, at her sole expense, defend Husband against any such claim,
action or proceeding, whether or not well-founded, and indemnify him and his property against
any damages or loss resulting therefrorn, including, but not Iirnited to, costs of court and actual
attorney's fees incurred by Husband in connection therewith.
(0) Warranty as to Future Oblhmtlons. Husband and Wife each
represents and warrants to the other that he or she will not at any tirne in the future incur or
contract any debt, charge or liability for which the other, the other's legal representatives,
property or estate rnay be responsible. From the date of execution of this Agreement, each party
shall use only those credit cards and accounts for which that party is individually liable and the
parties agree to cooperate in closing any remaining accounts which provide for joint liability.
Each party hereby agrees to indemnify, save and hold the other and his or her property harmless
from any liability, loss, cost or expense whatsoever, including actual attorneys fees, incurred in
the event of breach hereof.
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7. WAIVER OF ALIMONY. Husband and Wife hereby expressly waive,
discharge and release any and all rights and claims which he or she may have now or hereafter by
reason of the parties' marriage to alirnony, alimony pelldellte lite, support and/or maintenance or
other like benefits resulting from the parties' status as husband and wife. The parties further
release and waive any rights they may have to seek modification of the terms of this paragraph in
a court oflaw or equity, it being understood that the foregoing constitutes a final determination
for all time of either party's obligation to contribute to the support and maintenance of the other.
8. COUNSEL FEES. COSTS AND EXPENSES, Each party shall be
solely responsible for his or her own legal fees, costs and expenses incurred in connection with
their separation and/or the dissolution of their marriage, and the preparation and execution of this
Agreement.
9. INDEMNIFICATION UPON TAX DEFICIENCY. The parties agree
that ifin the future any taxes, penalties or interest are irnposed for joint filing years related to
failure to declare income received by Wife pursuant to a property settlement as a result of a prior
marriage, such taxes, penalties or interest shall be solely allributable to and paid by Wife, and
Wife shall indemnify and hold Husband harmless for any such taxes, penalties and interest
assessed by the taxing authority. Responsibility for any other taxes, penalties or interest assessed
after execution hereof related to joint filing years shall be the equal responsibility of the parties,
and each shall contribute equally to any such assessments.
10. ALLOCATION OF DEDUCTIONS FOR ARMSTRONG ROAD
RESIDENCE. The parties acknowledge and agree that Husband made all rnortgage and tax
payments associated with the Armstrong Road Residence during 1998 and in 1999 through the
date of execution hereof, and Husband shall be entitled to claim all deductions associated with
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such residence on his 1998 and 1999 individual income tax returns. Husband's right to claim all
deductions associated with said residence continues through the sale of said property.
II. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically
provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each
waives all rights of inheritance in the estate of the other, any right to elect to take against the will
or any trust of the other or in which the other has an interest, and each of the parties waives any
additional rights which said party has or may have by reason of their marriage, except the rights
saved or created by the terms of this Agreement. This waiver shall be construed generally and
shall include, but not be limited to, a waiver of all rights provided under the laws of
Pennsylvania, or any other jurisdiction.
12. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise
specifically set forth in this Agreement, each party hereto specifically waives any and all
beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like
program carrying a beneficiary designation which belongs to the other party under the terms of
this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature,
deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts,
final pay checks or any other post-death distribution scheme, and each party expressly states that
it is his and her intention to revoke by the terms of this Agreement any beneficiary designations
naming the other which are in effect as of the date of execution of this Agreement. Ifand in the
event the other party continues to be named as beneficiary and no alternate beneficiary is
otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party.
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13. RELEASE OF CLAIMS.
(a) Wife and Husband acknowledge and agree that the property
dispositions provided for herein constitute a distribution of their assets and liabilities pursuant to
93502 of the Divorce Code, and Wife and Husband hereby waive any right to division ofthcir
property except as provided for in this Agreement. Furthermore, except as otherwise provided
for in this Agreement, each of the parties hereby specifically waives, releases, renounces and
forever abandons any claim, right, title or interest whatsoever he or she may have in property
transferred to the other party pursuant to this Agreement or identified in this Agreement as
belonging to the other party, and each party agrees never to assert any claim to said property or
proceeds in the future. However, neither party is released or discharged from any obligation
under this Agreement or any instrurnent or document executed pursuant to this Agreement.
Husband and Wife shall hereafter own and enjoy independently of any clairn or right of the other,
all items of personal property, tangible or intangible, acquired by hirn or her from the execution
date of this Agreement with full power in him or her to dispose of the same fully and effectively
for all purposes.
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(b) Each party hereby absolutely and unconditionally releases and
forever discharges the other and the estate ofthe other for all purposes frorn any and all rights
and obligations which either party may have or at any time hereafter has for past, present or
future support or maintenance, alimony pendellle lite, alimony, equitable distribution, counsel
fees, costs, expenses, and any other right or obligation, economic or otherwise, whether arising
out of the marital relationship or otherwise, including all rights and benefits under the
Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any
other law of any other jurisdiction, except and only except all rights and obligations arising under
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this Agreement or for the breach of any of its provisions. Neither party shall have any obligation
to the other not expressly set forth herein.
(c) Except as set forth in this Agreement, each party hereby absolutely
and unconditionally releases and forever discharges the other and his or her heirs, executors,
administrators, assigns, property and estate from any and all rights, claims, demands or
obligations arising out of or by virtue of the marital relationship of the parties whether now
existing or hereafter arising. The above release shall be effecti ve regardless of whether such
claims arise out of any former or future acts, contracts, engagements or liabilities of the other or
by way of dower, curtesy, 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 Pennsylvania, any
state, commonwealth or territory of the United States, or any other country.
(d) Except for the obligations of the parties contained in this
Agreement and such rights as are expressly reserved herein, each party gives to the other by the
execution of this Agreernent an absolute and unconditional release and discharge from all causes
of action, claims, rights or demands whatsoever in law or in equity, which either party ever had
or now has against the other.
14. PRESERVATION OF RECORDS. Each party will keep and preserve
for a period of four (4) years from the date of their divorce decree all financial records relating to
the marital estate, and each party will allow the other party access to those records in the event of
tax audits.
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IS. MODIFICATION. No modification, rescission, or arnendmentto this
Agreernent shall be eITective unless in writing signed by each of the parties hereto.
16. SEVERAHILlTY. Ifany provision of this Agreement is held by a court
of cornpetent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof
shall nevertheless survive and continue in full force and effect without being impaired or
invalidated in any way.
17. BREACH. If either party hereto breaches any provision hereof, the other
party shall have the right, at his or her election, to sue for damages for such breach, or seek such
other rernedies or relief as may be available to him or her. The non-breaching party shall be
entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in
the enforeernent of the rights of the non-breaching party.
18. WAIVER OF BREACH. The waiver by one party of any breach of this
Agreernent by the other party will not be deemed a waiver of any other breach or any provision
of this Agreement.
19. NOTICE. Any notice to be given under this Agreement by either party to
the other shall be in writing and may be effected by registered or certified mail, return receipt
requested. Notice to Husband will be sufficient ifmade or addressed to the following:
Larry S. Robertson
1022 Armstrong Road
Carlisle, PA 17013
and to Wife, if made or addressed to the following:
Barbara F. Robertson
252 Franklin Street
Carlisle, PA 17013
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Notice shall be deemed to have occurred upon the date received by the recipient. Each party may
change the address for notice to him or her by giving notice of that change in accordance with the
provisions of this paragraph.
20. APPLICABLE LA W. All acts contemplated by this Agreement shall be
construed and enforced under the substantive laws of the Commonwealth of Pennsylvania
(without regard to the conflict of law rules applicable in Pennsylvania) in effect as of the date of
execution of this Agreement.
21. DATE OF EXECUTION, The "date of execution" or "execution date" of
this Agreement shall be defined as the date upon which the parties signed the Agreement if they
do so on the same date, or jfnot on the same date,then the date on which the Agreement was
signed by the last party to execute this Agreement.
22. EFFECTIVE DATE. This Agreement shall become effective and
binding upon both parties on the execution date.
23. EFFECT OF RECONCILIATION, COHABITATION OR
DIVORCE. This Agreement shall remain in full force and eITect and shall not be abrogated
even if the parties eITect a reconciliation, cohabit as husband and wife or attempt to eITect a
reconciliation. This Agreement also shall continue in full force and eITeet in the event of the
parties'divorce. There shall be no modification or waiver of any of the terms hereof unless the
parties in writing execute a statement declaring this Agreement or any term of this Agreement to
be null and void.
24. HEADINGS NOT PART OF AGREEMENT. Any headings preceding
the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of
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reference and shall not constitute a part of this Agreement nor shall they affect its meaning,
construction or effect.
25. AGREEMENT 8INDING ON PARTIES AND IIEIRS. This
Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal
representatives, assigns, and successors in any interest of the parties.
26. ENTIRE AGREEMENT. Each party acknowledges that he or she has
carefully read this Agreement; that he or she has discussed its provisions with an allorney of his
or her own choice, and has executed it voluntarily and in reliance upon his or her own allorney;
and that this instrument expresses the entire agreement between the parties concerning the
subjects it purports to cover and supersedes any and all prior agreem~nts between the parties.
This Agreement should be interpreted fairly and simply, and not strictly for or against either of
the parties.
27. MUTUAL COOPERATION. Each party shall, on demand, execute and
deliver to the other any deeds, bills of sale, assigrunents, consents to change of beneficiary
designations, tax returns, and other documents, and shall do or cause to be done every other act
or thing that may be necessary or desirable to eITectuate the provisions and purposes of this
Agreement. If either party unreasonably fails on demand to comply with these provisions, that
party shall pay to the other party all attorney's fees, costs, and other expenses actually incurred as
a result of such failure.
28. AGREEMENT NOT TO BE MERGED. This Agreement may be
incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not
be merged into said decree. The parties shall have the right to enforce this Agreernent under the
Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity
19
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under this Agreement as an independent contract. Such remedies in law or equity are specifically
not waived or released.
IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of
their acknowledgments.
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WITNESS .
Y.J; ./
~ S. ROBERTSON
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BARBARA F. ROBERTSON
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COMMONWEALTH OF PENNSYL V A~IA
COUNTY OF (~ //:/;~Y 1(/. { ( \..
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BEFORE ME, the undersigned authority, on this day personally appeared BARBARA F.
ROBERTSON known to me to be the person who executed the foregoing instrument, and who
acknowledged to me that she executed same for the purposes and considerations therein
expressed. . ~ ~.
GIVEN UNDf;R MY HAND AND SEAL OF OFFICE thiS,$ d~ of
tftJt.~ ,1999.
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Notary Public in and for
Commonwealth of Pennsylvania
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My commission expires: . ~
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LARRY ROBERTSON,
Plaintifi'
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-1584
BARBARA ROBERTSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF INTENTION TO RESUME PRIOR NAME
NOTICE is hereby given that PlaintilT in the above-captioned maller, having been granted
a final decree in divorce on the J EfH'day of ~' 1999, hereby intends to resume and
hereafter use the previous name of Barbara F. Weary and gives this wrillen notice avowing her
intention in accordance with the provisions of the Act of 54 Pa. C.S. ~704.
~JLLLtL 1 e{J~~
Barbara F. Robertson
TO BE KNOWN AS:
/f3nuJ~~ (j 1J-L~
Barbara F. Weary
COMMONWEALTH OF PENNSYLVANIA
: SS.
COUNTY OF CUMBERLAND
On this, the ~ day of , 1999, before me, a Notary Public,
the undersigned officer, personally appear Darbara F. Robertson known to me (or satisfactorily
proven) to be the person whose name is su cribed to the within instrument, and acknowledged that
she executed the foregoing Notice of Intention to Resume Prior Name for the purposes contained
therein.
/' J 'l'ffN~SS WIIEREOF, I ,,,,"'10 ,,' my 'om! ,,' offici,1 ,,,I
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I NOTARY PUBLIC NOIARW.SEAl
My Commission Expires: (SEAL) ~o..::~lII't:o.=
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