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: IN THE COURT OF COMMON PLEAS :
~ OF CUMBERLAND COUNTY 8
8 8
: STATE OF '* PENNA. :
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8 ANTHONY F 0 MISCAVIGE 11 N ll. ....~.7~.~.~.~~. c.~.~.~~...~El~ 8
" Plaintiff 'I III
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8 V~I'!;lIS ~
8 ANDREA LEE MISCAVIGE ..... -..-...... ii .
8 Defendant ii .
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: DECREE IN ~
DIVORCE .,
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: AND NOW, ".""" "M.~ "f... " .. 19 .f~". It Is ordered and 8
~ decreed that" . " .~~:.~~~:,,~ 0" ~.i.~~~:.i.~~"" "",," "".". plaintiff. ~
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~ and . . . . . . . . . . . . . . . ~.n.~:~~. .~7~. .~~~?a.~~?~. . . . . . . . . . . . . . . . . ., defendant, ~
8 are divorced from the bonds of matrimony. 8
8 ~
8 The court retains jurisdiction of the following claims which have ~
.... been raised of record in this action for which a final order has not yet -.
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" been entered; And it is further ORDERED, J\OJUDGED and DOCREED that the hmm,
" provisions and conditions of a certain Property Settlt!ll'lt!nt Agreerent between ~
. the parties, dated April 9, 1998, and attached hereto, are hereby incorporated ....
in' true Decree' and' ornili:" bi-' refilrenci:!' as' fully' as' 'thOugh' 'th'e' 'saiOO' were 's.tit' ..
8 fQrtl:l.l:leP;l:j.O. <It . length, . .5<1;1.0. Agrl!t5.1'tlnt. anall. npt. ll'*!rge. W.itil.. put ahall s.w:vive 8
8 this Dee nd Order 0
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. -'Prothonotary
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Ill.CAVIO., 1UI'2I0In' .., III D1I COIlllT 0' COIOIOIl PLIA. 0.
,laiDtUf CUIlIIIaLAIlD COUN'1'Y, PIIIlIlSY1.VAJlIA
.a. CIVIL ACT I 011 - LAW
III DIVO.C.
IlI.CAVIO., AIlDIlU 101.,
Defaadaat n-uu CIVIL '1'11I11
AND NOW, this
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AI.IMONY ORDER
day of r'\ ~
, 1998, it is ordered and directed thaI Husband
.hall pay the Wife alimony.. follows:
The Huaband haa been paying to the Wife the aum of $50.00 every two weeke aa
apouaal aupport. Effective upon the execution of thin Agreement, auch payment ahall
continue until a decree in divorce is issued. At such time as a divorce decree ia
granted, the payment ahall continue and ahall be deenled alimony. Payment of alimony
ahall continue, until auch time as the younger child compl~tes college or poat-high
achool vocational education, on June 1, 2001. Upon the death of the Wife, the
obligation to pay alimony shall terminate. Upon retirement or death of the Huaband,
the partiea' reapective righta in the retirement shall be aa set forth in Qualified
Domestics Relations Order entered in their divorce action filed in cumberland county
Court of Common Plea., Carlisle, PA. The payments made hereunder are intended by the
partiea to conatitute alimony under IRC 71, and as such, to be included in the income
of the Wife and deductible by the Husband.
Huaband and Wife further acknowledge that they have been advised of the
language contained in 5501(e) of the Divorce Coda, and it i. their specific
intention, request ~nd directive that 5501(e) not govern nor be applied to the terms
of this agr~.ment.
The alimony payments shall be made through the Domsstic Relations Office of
cumberland County, as per the Stip'\lation of the parties set forth a. Appendix "B",
which shall be promptly filed of record.
BY:~
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Domestics Relations Order entered in their divorce action filed in Cumberland County Court of
Common Pleas, Carlisle, PA, The payments made hereunder are intended by the parties to
constitute alimony under IRC 71, and as such, to be included in the income of the Wife and
deductible by the Husband.
Husband and Wife further acknowledge that they have been advised of the language
contained in ~SOJ(e) of the Divorce Code, and it is their specific intention, request and directive
that ~SOI(e) not govern nor be applied to the terms of this agreement.
The a1imonv payments shall be made through the Domestic Relations Office of
Cumberland County, as per the Stipulation of the parties set forth as Appendix "B", which shall
be promptly filed of record.
---~4-~7~
Andrea Lee Miscavige
~~ 'W"~4-
Ruby D. Weeks, Esquire
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and future eupport and or maintenance of the Children, the implementation of
ouatodY/vieitetion arrangemente for the minor Children/ and in generel, the
eettling of eny and all claima and poeeible claime by one againet the other or
againet their reepective eetatee.
MOW T....ro.., in conoideration of the promioee and of the mutual
premieee, covenante and undertakinge hereinafter aet forth and for other good and
valuable coneideration, receipt of which ia hereby acknowledged by each of the
partiee hereto, Wife and Hueband, each intending to be legally bound hereby,
covenant and agree a. followe,
1. &O..~ MOT A a.. TO Dlva.c. PROC..DIMOS
Thie A9reement ehall not be conaidered to affect or bar the right of Wife
or Hueband to a limited or absolute divorce on lawful grounde if euch grounde
now exiet or ehall hereafter exist or to such defense ao may be available to
either party. This Agrsement is not intended to condone and shall not be deemed
to be a condonation on the part of either party hereto of any act or acto on the
part of the other party which have occaeioned the dieputee or unhappy differences
which have occurred prior to or which may occur subsequent to the date hereof.
The parties intend to secure a mutual consent, no-fault divorce pursuant to the
terms of Section 3301(c) of the Divorce Code of 1980 as amended by Act No. 1990,
206 effective 3-19-91.
2. .PPBCT OP n.c.... NO MEROZR
It is specifically agreed, however, that a copy of this Agreement may be
incorporated, by reference, into a divorce judgment or decree.
This
incorporation, however, ohall not be regarded as a merger, it being the intent
of the partiee to permit thie Agrsement to survive any such judgment, unlese
otherwiee specifically provided herein, and for this Agreement to continue in
full force snd effect after euch time as a final decree in divorce may be
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entered with reepact to the partiee. The partiee agree that the terme of thie
Agreement ehall be incorporated into any divorce decree which may be entered
with reepact to them for purpoeee of enforcement only of any provieione therein,
but ehall eurvive euch decree.
]. DUTIIIIIIITIOJI DATIl
The tranefer of property, funde and/or documente provided for herein ehall
take place eimultaneouely with the execution of thie Agreement.
<I. MYla or COUNSEL
The provieione of thie Agreement and their legal effect have been ful~y
explained to the parties by their respective counsel, Joseph Barneko, Zequire,
for Hueband, and Ruby D. Weeks, Esquire, for IILte. The parths acknowledge that
they have received independent legal advice from counsel of their selection and
that they fully understand the facts and have been fully informed a. to their
legal right. and obligations and they acknowledge and accept that thi. Agreement
is, in the circumstances, fair and equitable and that it i. being entered into
freely and voluntarily, after having received euch advice and with euch knowledge
and that execution of thie Agreement ie not the reeult of any duree. or undue
influence and that it ie not the result of any collusion or improper or ill.gal
agreement or agreements.
5. PINANCIAL DISt!fnsURZ
The parties confirm that each has relied on the substantial accuracy of the
financial disclosure of the other as an inducement to the execution of thi.
Agreement, and that the partie. do not wi.h to exerci.e their right to have
apprai.ale by experte ae to the value of the varioue intereet. of the partie.o
The parties underetand that such appraisale would be neceesary to fix the fair
market value of the.e interests for purposes of equitable di.tribution.
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,. 011'1'.&1.1110 rlfPOa"&TIOIf ON PINANCa.
..ch p.rty .cknowledge. th.t they h.ve been informed they m.y h.v. the
right, .e provided by .t.tute .nd penn.ylv.ni. Rule. of Civil procedur., to
obt.in information reg.rding the p.rtie.' finance.. Such inform.tion would
includ., without limit.tion, their pre.ent and paat incom., .nd the identity and
v.lu. of ....t. both pre.ently owned .nd tr.n.ferred previou.ly. Such
inform.tion m.y be obtained by one or more of .ev.ral method. including
depo.ition. upon oral examination, written interrogatorie., production of
document. or .ntry upon prcperty for in9pection. The partiea agree to waive .ny
further di.cov.ry.
7. w&aa&1I'I'Y O. DIS"".nSURZ
The part i.. warrant and repreaent that they have made a full di.clo.ure of
all a..et. and their valuation prior to the execution of thi. Agreement. Thi.
di.clo.ur. wae in the form of an information exchange of information by the
partiee' attorneys and this Agreement between the parties is based upon this
discloaur. .
8. PK..nvaT RYORTS
Wife and Husband may and shall, at all times hereafter, live aeparate and
apart. They ehall be free from any control, restraint, interference or authority,
direct or indirect, by the other in all respects as fully as i.f they were
unmarried. They may reside at such place or places as they may select. Each may,
for hi. or her separate use or benefit, conduct, carryon and engage in any
businesa, occupation, profession or employment which to him or her may aeem
adviaable. However, each party shall make best efforte to maint.in employment
with comp.rable benefits and salary as they now hold or for which they are in
training.
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.. 1ftPI.'U.&L .WI' ......
Hu.b.nd .nd Wife ..ch do h.r.by mutu.lly r.mi.., r.l...., quitcl.im .nd
for.v.r di.charga the oth.r .nd the ..tat. of .uch oth.r, for all time to com.,
and for all purpa... what.o.v.r, of and from .ny .nd all right.,
title and
int.r..t, or claim. in or .gain.t the property (including incom. and g.in from
property h.r.aft.r accruing) of the oth.r or ag.in.t the ..tat. of .uch oth.r,
of what.v.r nature and wh.r..oav.r .itu.t., which h. or .h. now ha. or at any
time h.raaft.r may have again.t auch oth.r, the e.t.t. of auch oth.r or .ny p.rt
th.r.of, wh.th.r ari.inq out of any form.r act., contract., .ngaq.m.nt. or
liabiliti.. of .uch oth.r or by w.y of dow.r or curt..y, or claim. in the nature
of dower or curt..y or widow'. or widow.r'a riqht., f.mily .x.mption or aimilar
allowanca, or undar the int..tat. law., or the riqht to take .g.in.t the .pau..'.
Will, or. the right to tr.at . lif.tim. conv.yanc. by the oth.r aa t..tam.nt.ry,
or all oth.r right. of . .urviving .pou.. to particip.t. in . dec....d .pau....
..tat., wh.th.r ari.ing und.r the law. of (a) Penn.y,\vania, (b) any Stat.,
commonwe.lth or t.rritory of the United St.ta., or (c) any oth.r country, or .ny
riqht. which .ither party m.y have or at /tny tilRe h.r.aft.r have for put,
pr..ent or future .uppart or maintenance, alimony, alimony pend.nt. lit., coun..l
f..., equitable di.tribution, co.t. or .xpen.e., wh.th.r ari.ing a. a ra.ult of
tha marital r.lation or oth.rwhe, axcept, and only axcapt, .11 righte .nd
agr.ement. and oblig.tion. of wh.t.oever nature ari.ing or which may ari.. under
thi. Agreement or for the breach of any thereof. It i. the intention of Hu.b.nd
and Wife to qive to .ach ocher by the execution of thie Agr.....nt . full,
ccmpl.t. and g.n.ral r.l.... with r..pect to .ny .nd all property of any kind or
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nature, real, peraonal or milled, which the other now own. or may hereafter
acquire, except and only except all righte and agreement. and obligation. of
what~oever nature ari.ing or which may arile under thie Agreement or for the
breach of any thereof.
10. .OUt~a.T. DrSTarBUTION or PROPKRTY
It i. .p.cifically underltood and agre.d that thil Agreement conetitute.
an equitable diltribution of property, both real and perlonal, which wae legally
and beneficially acquired br HUlband and Wife or either of them during the
marriage, a. contemplated by The Act of April 2, 1980 (P.L. 63, No. 26) known
a. "The Divorce Code,. 23 P.S. 3101 et. eeq. of the Commonwealth of
Penn.ylvania.
And further, that the partie. have attempted to divide their marital
property in a manner which conforme to the criteria Bet forth in 3502 of the
PennMylvani~ Divorce COde, and taking into account the fOllowing coneiderationel
the length of the marriage, the prior marriagee of the partiee, the age, health,
etation, amount and Mourcee of income, vocational ekille, employability, eetate,
liabilitiee and neede of each of the partie., the contribution of one party to
the education, training, or increaeed earning power of the other party, the
opportunity of each party for future acquieition of capital aeeete and income,
the sources of income of both parties, including but not limited to medical,
retirement, insurance or other benefite, the contribution or dieeipation of each
party in the acquieition, preservation, depreciation, or appreciation of marital
property, including the contribution of a party ae a homemaker, the value of the
property let apart to each party, the standard of living of the partie.
e.tabliehed during the m.rriage, and the economic circumstancee of each party at
the time the divieion of property ie to become effective.
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11. ..aT pao...TY
The partiea acknowledge they have .old the marital re.idence which wa.
formerly located at 329 Ea.t Meadow Driv., Mechanicsburg, Pennsylvania, on which
the Mortgagy wa. .atiafi.d and they have already divided the proceeda between
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th.m in a manner agr..able to each of them, with the Wife receiving 60\ of the
n.t proc..d. and the Huaband 40\. There i. no other marital real property.
12. ni.~ribu~ioD of ..r.DDal PrDD.~Y.
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Huaband and Wife do hereby acknowledge that they have previoualy divided
their tangible per.onal property including, but without limitation, jewelry,
clothea, furniture, furnishings, rugs, carpets, household equipmsnt and
appliances, pictures, books, works of art and ather personal property, and
hereafter Wife agree. that all of the property in the passession of Husband shall
be the .ole and separate property of Husband, and Husband agrees that all of the
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property in the possession of Wife shall be the sale and separate property of
Wife. The partiea do hereby apecifically waive, releaee, renounce and forever
abandon whatever claims, if any, he or she may have with respect to the above
items which shall became the sale and separate property of the other. This
Agreement shall have the effect of an assignment or bill of sale from each party
to the ather far such property as may be in the individual pas sees ions of each
of the partiee hereto.
ll. GaDeral.
(1) Husband hereby wai~es all interest in Wife's property including
but not limited to all accounts, certificates of deposit and securitiea.
(2) Wife hereby waives all interest in Husband's property
including but not limited to all accounte, certificatea of deposit, and
..curitie..
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PI Huab.nd .nd WU. al/r.. th.t Huab.nd .h.ll p.y .U coat.,
includinl/ .ttorn.y f..a, of tun.f.rdnl/ .ny property n.c...ary to b.
titled from joint own.nhip to th.t of .ith.r p6rty .nd 111& .ttorn.y ah.ll
pr.par. the docum.nta n.c....ry for auch tran.f.ra.
(4) TII. p.rti.a al/r.. the WU. .h.ll receiv. the proc.ed. trom the
a.l. of th. p.nn.ylv.nia N.tion.l S.nk Stock .nd th.t Hu.b.nd .h.ll b..r
.11 t.x cona.qu.nc.a r.aulting from the ..1. of thi. atock.
1.. MD~ar V.hiat.al
With r.ap.ct to the motor vehicl.a owned by on. or both of the p.rti..,
th.y agr.. .. followa.
(.) The 1993 Honda Accord on >1hich th.r. 1& no debt owed, titled
Andr.a L. Hi.cavige, "to Wife", ahall become .nd remain the aol. and
axclu.ive property of the Wif..
(b) The 1994 Honda Accord, on which there ia no debt owed, titled
Anthony r. Hi.cavige,"to Huaband", ahall become and r.mai~ the aole .nd
.xcluaiv. property of the Huaband.
15. PILIMO IUVDtTORIB8 JUm APPRAIS.....N'T'
The partie. further acknowledge their understanding that they each have the
right to file lnventories and Apprai.ement with the Court and to require the
oth.r p.rty to do ao. such Inventories .nd Appraieement require a party to
indicat., und.r oath, information regarding .11 marital property in which either
party haa an int.reat a. of the date the .ction waa commenced. Fully knowing the
aamg, each party nonethele.. waivee their re.pective righta to requ.at addition.l
diacov.ry be conducted, to file lnventorie. and Appraia.m.nt with the Court, or
to require the other p.rty to do ao.
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Hu.b.nd .qr... to provide Wife with copie. of any and all joint tax
1'. IVt.I"I....-.a. TO .. rtmJI'l..RDI
return. filed by the partie..
11. ......_&l!Ouy..n ....n.....t~ .Ro...n
lach of the partie. .hall h.reaft.r own and enjoy, indep.ndently of any
claim or ri9ht of the other, all it.m. of peuonal property, tan9ible and
intan9ible, .ub.equently acquir.d by the other party.
II. D..Tal
Marital Debte, There are no marital d.bt., excapt.
A. of 4/~/98. Loan #1 - $16049.~5
Loan #2 - $7317.00
Loan #3 - $10106.00
All of which Hueband ha. agr.ed to a..ume in full. He further agr.e. to
indemnify Wife from any and all claims or demand. for payment of the.e debt..
The Hu.band ha. al.o provid.d living expenses for the Wife and children from date
of .ep.ration throu9h January 1998.
19. PUTURI DIBTS.
Hu.band and Wife hereby mutually agree that subsequent to the execution of
this A9reement neither party ehall incur any dsbts which will obligate the other
to make payment for sarne. Hu.band and Wife hsrsby acknowledge that there are no
out.tandin9 bill. or other indebtedness which have been incurred by either for
the liabil \ty of the other, and both parties hereby covenant and a9ree that
neither .hall have any financial obligation to pay any financial obli9ations
which are .olely the tinancial obligation of the other and which have been
contracted by either party solely for their own bensfit and without the knowledge
or con.ent of the other party. Husband and Wife further a9ree that they will
indemnify the other from any and all claima or demande made a9ain.t the othar by
rea.on of any debts or obli9atione contract.d in violation of thie Agreemento
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20. V....II'I'Y a. TO _11.TINa ORIOATIOII..
Bach party repreaenta that they have not heretofore incurred or contracted
for ~y debt or liability or obliqation for whlch the eatate of the other party
may be reaponalble or 11able excapt aa may be provlded for ln thie Aqreement.
Bach party aqrees to lndemnlfy or hold the other party harmlesa from and aqalnst
any and all such debts, 11abilltlss or obllqatlons of every klnd whlch may have
heretofore been lncurred by them, lncludlnq those for necessltiee, except for
the obliqations arislnq out of thls Aqreement.
21. I.......... ..AI .RIOR RZT'UJUII
The partle. have heretofore fl1ed jolnt federal, state and local income tax
returns. Husband aqrees that ln the event any deflclency ln federal, state, or
local income, real estate or personal tax ls proposed, or any aseessment of any
such tax is made aqainst Husband or Wite by reason of Husband or Wife havlnq
joined in tha fl1lnq of sald jolnt returns or by reason of Husband's prlor
omlssion to filII returns or pay such, Husband wlll lndemnlfy and hold Wite
harmless from snd aqalnst any loss or 11abl1lty for any such tax deficlency or
assessment and any lnterest, penalty, and expense lncurred ln connectlon
therewith, and such tax, lnterest, penalty or expense shall be pald eolely and
entlrely by Husband, unless sald tax, interest, penalty or expense i~ finally
determined to be attrlbutable to W1fe' s mlsrepresentations or failures to
dlsclose the nature and extsnt of Wlfe's ssparate lncome on the aforesald joint
return..
22. IIIC~ TAl RZTURH
Hueband and Wlfe agrse that they shall fl1e lndivldually and separately for
rederal, state and Local Income Tax Returns for the year 1997, and each party
Ihall aqree to assume responslbl1lty for the payment of any tax due, includinq
any interest or penalty, for the year 1997, on their individual tax return.
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Hu.band and Wit. .hall indemnity and hold .ach other harmle.. trom .ame. The
partie. acknowledge that the Tax Retorm Act. ot 1984 and 1986, and all amendment.
thereto, created dramatic change. in the tax l.w a. it attect. the di..olution
ot marriages, including but not limited to the tax consequence. ot .upport
payments end all taxe. a.sociated with the divi.ion ot property. Ruby D. Week.,
attorney tor the Plaintitt, doee not hold her.elt out ae being an expert in tax
related matters snd, theretore, has recommended that the partiee obtain competent
tax advice trom an independent eource. By execution hereot, the parties have
scknowledged .uch recommendation and, it they so desire, have sought and obtained
advice with regard to matters ot concern to them, as contemplated herein.
2]. SUPPORT
The partie. are the parents ot one child who is in college, Josoph Aaron
Miscavige, born April 19, 1979. the partieD agree that in accordance with
Pennsylvania Law, based upon the respective earning capacities ot the parties and
needs ot the child, as long as the child resides in the mother's home and is a
tull time student, the Husband agrees to pay the mother child support ot $27S.00
every two weeke during such times as Joseph is not in college, ie during eummer
and echool breaks, provided Joseph resides with the mother during such times.
These payments shall continue until Joseph graduates trom college.
All tinancial obligations undertaken by husband in this paragraph shall be
binding upon husband'. heirs, executors, administrators, succeeeors and assigns,
and shall constitute a charge against husband's estate.
The parties expressly understand and agree that the payments made to Andrea
L. Miseavige under this paragraph are tor support and maintenance ot the child
only and are not, nor are they intended to be, periodic payments and are not ,
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nor are th.y int.nd.d to b. d.bta which are att.cted by diacharll. in bankruptcy.
Such paymenta are to be tax tr.. to Andr.. L. Hiac.ville, .nd Anthony r. Hi.c.vill.
cov.n.nta and .Ilr..a not to ....rt .ny poaition .a would .tt.mpt to cr..t.
li.bility tor wit. tor the p.yment ot .ny income t.x ther.on.
2.. ..a'~ ........ AWD ~'TR IN.lm.Me. cov...oz.
Huaband ia to p.y tor medic.l inaur.nce, dent.l and optical cov.r.ll. tor
the child ao lonll .a he ia .ble to be covered on huab.nd'a policy. Th. huab.nd
will pay the premium tor d.nt.l .nd h.alth inauranc. cover aile tor the younll.r aon
on the wit.'a medical inaurance coveralle throullh her employ.r'. benetita a. lonll
.a auch b.n.tita exiat.
Howev.r, it the preaent medical inauranc. policy ot .ither party will not
permit him or her to continue medical, dental, or optical inaurance coveralle on
the child, tor any reason, or it one parent can no lonller obtain, through the
pl.ce ot employment, medical coveralle that is generously subsidized by the
employ.r, then it either parties spouse (in the event ot remarri.lle) can obtain
similar medical inaurance coveralle tor the children, at no cost to them, the
parent ahould arranlle to obtain such medical coveralle at hi. or her own expenae.
It, at .ny time, a parent's spouse (in the event ot remarrialle \( is able to
obtain medical insurance coveralle for the child that is better than the medical
inauranc. cover aile in force at that time for the child and, it auch cover aile ia
available to a parent or parent's spouse at no exponse to them, the paren~ ahall
.rrang. to obtain auch medical coveralle, thu. relieving the parent of the
reaponaibility to provide such coveralle. In the event th.t auch coverall. is not
.vailable to the parent or the parent's spouse at no additional expena. to thsm
and it . par.nt cannot obtain, throullh ths place of employment, medic.l insurance
coverall. tor the child that is totally subsidized by the employer aa it ia
currently, appropriate medic.l insurance coveralls shall then be obt.ined for the
12
chl1d and both par.nta ah.ll then ..ch be r..ponelbl. for payment of the premlume
for euoh medlo.1 lneuranc. for the chl1d ln the a&me r.tlo ae thalr 9ro.a lncomee
bear to aach othar'e ,
Tha partl.e a9r.. to be raaponalbl. for tha chl1d'a unlneur.d medlcal,
dental, optlcal, pra.crlptlon or ho.plt.l ..pen.e. ln tha earn. ratlo aa th.lr
gro.a lncome. b..r to ..ch oth.r'a.
In r.gard to ..ch p.rty'. r..pon.lbillty to p.y for uncov.rad m.dical,
d.nt.l, opticel, pr.ecriptlon, or ho.pitel ..pen... .. epeciflc.lly e.t forth ln
the pr.cadlng par.gr.ph, ..ch party eh.ll h.v. cert.ln obligatlone to ...ur. that
the .xpen... for which the oth." .hall b. li.bl. .hall b. n.c....ry .nd
.pproprl.t.. SpaclHcally, e..ch party .h..ll u.. ..11 medical, dental and
hoaplt.lh.tion ineur..nc. th..t le ln eff.ct ..t the time th..t any of the
axpendituree ar. incurred. E.ch p..rty eh..ll ..1.0 chooee phyeici..n., dentiata or
oth.r prof.eaion.la who partlclp..te in the medlc~l In.ur..nce program th..t i. then
in eff.ct, wh.n.v.r poealbl.. For ...mple, if Dlue Cro../Dlu. Shleld cov.r.gft
1. ln .ff.ct at the tlme th..t .. p..rtlcul.r medlc..l .ervlc. la n.c.ae..ry, ..ch
party .hall choo.e .. phyelcl.n, dentl.t or other profe..lon..l who will .ccept
Dlu. Croe./Dlue Shi.ld paymente ..e p..yment in full lf .uch phyelclan., d.nti.t
or oth.r prof...ion.l. .re .v.l1..ble ..nd eultable. N.lth.r p.rty .h.ll incur .ny
medic.l, dental, optic..l, preecrlptlon, or hoepit..l expenee for the child unl..a
.uch .xpen.. 1. deemed to be nec.e...ry. Except ln c..... of emergency, each p.rty
.h.ll .ttempt to coneult wlth the other p.rty before .ny medlcal. dental,
optlcal, pre.crlptlon or ho.plt.l expen..e .re lncurred, except in the ca.. of
ongoing tre.tment. of which the oth.r p.rty h.d prior knowledg.. In ord.r to
v.rify tho.. .xpen... for which e..ch p..rty .h..ll be re.pon.lbla, pur.uant to the
r
13
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preceding paragraph, each party ehall aubmit appropriate document a including
billa or receipt a or canceled checka, etc. in order to verify the amount of
medical, dental, optical, preacription, or hoapital expenaea that have been
incurred for the child, auch coata not having been covered by medical inaurance.
2!1. ALllIOlIY
The Huaband ha. been paying to the Wife the aum of $50.00 every two weeka
aa apouaal aupport. Iffective upon the execution of thia Agreement, auch payment
ahall continue until a decree in divorce La iaaued. At auch time aa a divorce
decree ia granted, the payment ahall continue and ahall be deemed alimony.
payment of alimony
ahall continue, until auch time aa the younger child
completea college or post-high school vocational education, on June 1, 2001. Upon
the death of the Wife, the obligation to pay alimony shall terminate. upon
retirement or death of the Husband, the parties' respective right a in the
retir~nt ahall be a. set forth in Qualified Domestics Relations order entersd
in their divorce action filsd in Cumbsrland County Court of COlNllon Pleas,
Carliele, PA.
The payments made hereunder are intendsd by the partie. to
con.titute alimony under IRC 71, end as such, to be included in the income of the
Wife and deductible by the Husband.
Hu.band and Wife further acknowledge that they have besn advised of the
language contained in 5501(e) of the Divorce Code, and it is their specific
intention, request and directive that 5501(e) not govern nor be applied to the
terma of thi. agreement.
The alimony payment. shall be made through the Dome.tic Relationa Office
of cumberland county, as per the Stipulation of the parties set forth aa Appendix
"a", which ahall be promptly filed of record.
14
2'. ..-.o.~""""'1
The partiea hereby agr..e that all of the provi.ion. cont.ined in thi.
Agreement, including both direct and indirect contribution to .upport, euch a.
payment of health and/or life in.urance, and the provi.ion. regarding alimony,
may be enforceable by an action in accordance with the provieione of the
penn.ylvania Divorce Code, a. am..nded, 23 P.SA. 101 et .eq.
21. IRa. .-TJa~ PUNDI 5 tOllk\ PLANS
A. The Hu.band, who ha. b.en employed by Brown, Schultz, Snyd.r, Hutz..l 5
Ple.ic, Worml.yaburg, P.nn.ylvanie, a...rts h. ha. no r..tir.m..nt b..nefit..
He ha., however, accumulated a 401(k) savinga plan. Wife agree. to waive
any intere.t ahe may hav.. had in eaid 401(k) .avings plan which the Hu.band hae
ae a re.ult of his .mployment.
B. The Wife, who was .mployed at Woolworth Corporation, H..chaniceburg,
P..nnsylvania, and i. now employ.d at penn.ylvania National In.urance, Harrieburg,
p.nn.ylvania, al.o has r.tir.m.nt and oth.r .mploy.e benefits. It is agreed by
the partie. that the Husband shall waive any int..reat he may have in any of th..
benefit., including retirement, which the Wife may have as a result of her prior
..mployment.
c. Th.. parties agree that each shall rstain the IRA accounts presently in
th.ir name.
21. DIVORCB
Huaband and Wife agree that Husband has fil.d a Complaint in divorc..
....king a divorce on the basis of mutual consent. Husband and Wife both agre..
that ninety (90) daya tollowing the tiling ot a Divorce Complaint by Wite that
both part i.. will ex..cute the required Aftidavits of Consent to be tiled with the
Court to allow the Court to grant a divorce on the ba.i. ot mutual con.ent.
15
Hu.band agree. to pay all coun.el fee., co.t., and expen.e. incident to
obtaining the efore.eid divorce.
AND the partie. hereto .tate and agree that this Agreement .hall not in any
way be con.trued a. a collu.ive agreemant.
21. A~."Y ..... ~O.T. , ..PKN...
The Hu.band agree. to pay co.t. of Wife'. attorney fee., court co.t. and
expan.e. in connection with the negotiation and preparation of this Agreement and
the granting of a divorce decree. He agree. to make such payment in full within
five IS) day. of the entry of a decree in divorce.
]0. B..a~. 01' AO.K~
If either party fail. in the due performance of obligation. under this
Agreement at their election, the non-breaching party .hall have the right to .ue
for damage. for breach of this Agr.ement or to reecind .ame and .eek .uch legal
r.medie. a. may be available to them. The brwaching party will be reepon.ible
for actual legal fee. and co.t. incurred by the non-breaching party nece..ary to
the enforcement of thie Agreement.
] 1. LAW 01' PtnlVlYLVAJlIA APPLI,.a.RT.W:
Thi. Agreement shall be con.trued in accordance with the law. of the
COmmonwealth of Pennsylvania which are in effect as of the date of execution of
this Agreement.
32. AGRR~ BINDING ON BEIRS
Thie Agreement ehall be binding and shall inure to the benefit of the
partie. hereto and their respective heir., executor., admini.trators, succe.sor.
and anigne.
16
3]. 5WVW...ILITY
If any term, condit lon, clauae or provlaion of thia Aqreement ahall be
determin~ or declar~ to ba void or invalid in law or otherwiae, then only that
term, condition, clauae or proviaion ahall be atricken from thia Aqreement and
in all other rea~cta thia Aqre~nt ahall ba valid and continue in full force,
effect and o~ration. Likewi.e, the failure of any party to meet her or hi.
obliqation. under anyone or more of the paragraphe herein, with the exception
of the .ati.faction of the condition. precedent, .hall in no WkY avoid or alter
the remaininq obliqation. of the partie..
]t. IIITI:O."'l'ION
Thi. Aqreement con.titute. the entire under.tandinq of the partie. and
.u~re~e. any and all prior aqreement. and neqotiatione between them. There are
no repre.entatione or warrantie. other than tho.e expre..ly .et forth herein.
35. NO WAIVER OF DB FAULT
Thi. Aqreement .hall remain in full force and effect unleaa and until
terminated under and purauant to the terms of thia Aqreement. The failure of
either party to in.iat upon .trict performance of any of the provisiona of thi.
Aqreement .hall in no way affect the riqht of such party hereafter to enforce
the eame, nor ahall the waiver of any breach of any providon hereof be
constru~ a. a waiver of any aubaequent default of the aame or .imilar nature,
nor ahall it be construed as a waiver of any subsequent default of the sarne or
.imilar nature, nor ahall it be construed aa a waiver of atrict ~rformance of
any other obliqationa herein.
17
J6. "AIIIIIS os MnDI"I~"'IOU TO .11 IU N11ITIUq
No modltlcatlon Or w.lver ot any ot the terma hereot .hall be v.lld unle..
ln wrltlng and .1gned by both partle. and no waiver ot .ny breach hereot Or
detault her.under .h.ll be d.emed a w.iver ot .ny .ub..qu.nt detault ot the .am.
or .imllar nature.
37. au...oumr. Drvo.f!'
Wit..
It 1. cont.mpl.t.d that HU.band ha. tlled a Complalnt ln Dlvorc. again.t
HU.band and Wlt. .ach .gree to .1gn an Att1dav1t ot Con..nt .nd .n
Attldavlt waivlng Coun.eling to be tiled in .aid divorc. actlon. In the eVent
.uch divorc. actlon 1. concluded, Husband shall be entitled to receive a copy ot
the D.cr.e ln Divorce tor the normal t.e charged by the Prothonot.ry and .hall
not be .......d any co.ts ot the proceeding, except as previouRly agreed to
h.r.ln in P.r.graph 34 regarding attorney fees and Coets. In the event euch
divorce .ction 1. concluded, the partie. shall be bound by all the terms ot thi.
Agreement, which .hall not be lncorporated by reference into the Divorce Decree,
.nd thl. Agreement shall not be merged in such Decree, but shall in all re.pect.
.urvive the .ame and be forever binding and conclusive upon the partles.
38.. 1ft"""."'. r...nnPRR.a'l'IQjf
E.ch p.rty .hall, at any time and from time to time hereafter, take any and
all .tep. .nd .xecut., acknowledge and deliver to the other party any and all
turth.r in.trument. and/or documents that the other party may reasonably require
for the purpo.e ot giving tull force and eftect to the provhione ot this
Agreement.
18
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Wife .nd Hu.b.nd cov.n.nt .nd .gr.. th.t th.y will forthwith (.nd within
.t l...t t.n (10) d.y. .ft.r d.m.nd th.r.for.) .x.cut. .ny .nd .11 wl'itt.n
in.trument., ...ignm.nt., r.l....., ..ti.f.ction., d..d., not.., or .uch oth.r
v
writinga .. m.y b. n.c....ry or de.ir.bl. for the prop.r .ff.ctu.tion of this
.~
Agre.m.nt, .nd .a th.ir r..pective coun..l .h.ll mutu.lly .gre. .hould b. .0
.x.cuted in ord.r to c.rry out fully .nd .ff.ctiv.ly the t.rm. of thi. Agr..m.nt.
.0. ..anyMQ. .~ P..~ OP a.aRB~
,
Any h..ding. pr.c.ding the t.xt of tha aav.r.l par.gr.ph. and aubpar.graph.
hereof .r. in..rt.d .olely for convenience of r.f.rence and .h.ll not con.titut.
.ff.ct.
. p.rt of this Agreement nor ehall they affect it. m.aninq, con.truction or
IN WITNZSS WHEREOF, the partie. h.reto have .et their h.nd. and ...1.
the
day .nd y..r fir.t above written.
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19
ANTHONY F, MISCA VlGE,
IN TIlE COURT OF COMMON PLEAS
Plaintiff
OF CUMBERLAND COUNTY
VS,
CIVIL ACTION - LAW
Defendant
IN DIVORCE
q7- /Rtf;'! ~~v1u",
ANDREA LEE MISCA VlGE,
NO,
NOTICE
You have been sued In Coon, lfyou wish to defend againsl the claims set forth in the folllming pages,
you must take prompt action. You arc \\lImed thnt if you fail to do so, dlC ClUC nUlY proceed against you and a Decree of
Divorce or Annulment may be entered ogainsl )'ou by IIIC Coun. A Judgment nUlY also be enlered against you for ony
other elnim or relicfreq\lestcd in these papers by Ihe Plaintiff. Yl'UllUIY lose money or property or other righls important
to you, including custody or visiL1tion of)'our children.
When the ground for divorce is indignities or irretrievable bn:llkdo\\n of tile nUlrriage, you nlllY request
marrillge counseling, A list of marriage counselors is available in the Office of Ihe Prothonolnry at the Cwnbcrland
County Counhouse, Cnrlisle, Pennsylvanil\, 17013.
IF YOU DO NaT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYERS' FEES
OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRAI'ITED, YOU MAY LOSE THE R1GI-IT TO
CLAIM ANY OF THEM,
IF YOU DO NaT HAVE A LAWYER OR CANNaT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OlJf WHERE YOU CAN GET LEGAL HELP,
COURT ADMINISTRATOR
Founh Floor. Cumberland County Coun House
Carlisle. Pennsy!\'anin 17013
(717) 2-10-6200
8. The marriage is irretrievably broken,
9, The PlaintifTrequests your Honorable Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce
pursuant to Section 3301(c) or 3301(d) of the Divorce Code, divorcing Plaintiff from the bonds of
matrimony existing between the parties.
COUNT II. EOUITABLE DISTRIBUTION OF PROPERTY
10, Paragraphs I through 9 inclusive are incorporated herein as though set forth at length,
14, The Plaintiff and Defendant OWl! substantial marital property as defined under the Divorce
Code,
15. In order to effectuate economic justice between the parties, the Plaintiff requests your
Honorable Court to enter a fair and just detennination and settlement of the parties' property rights,
WHEREFORE, the Plaintiff requests your Honorable Court to equitably divide and distribute
the marital property of the pariies in accordance with the Div rce Code.
I t./'L '
Joseph ~ ranko, Jr., Esquire
A~mw for Plaintiff
M'vI,OTIE, DAVID & FITLPA TR K
67 North Church Street
IHjlileton, Pennsylvania 18201
I (117) 454-5575
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ANDREA LI. NISCAVIGE,
Plaintiff
IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY, PENNsYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
ANTHONY r. NISCAVIGE,
Defendant
197- '-49~
CIVIL TERN
AFFIDAVIT OF MARRIAGE COUNSELIHQ
I, ANDREA LEE HISCAVIGE, being duly sworn according to law, depose and say.
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 that my spouse
and I participate in counseling prior to a divorce decree being handed
down by the COUl't.
I understand that false statements hsrein are made subject to the penalties
of 18 Pa. C.S. 54904 relating to unsworn falsification to authoritiss.
natodl J.;...J).. '17
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ANDREA LEE HISCAVIGE, Plaintiff
Sworn and subncribed i~
before me this ~
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IN mE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
IN DIVORCE
NO. 97.6494 CIVIL TERM
ANTHONY F, MlSCA VIGE,
Plaintiff
vs,
ANDREA LEE MlSCA VIGE,
AFFlDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November
21,1997.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint
3, I consent to the entry of a final Decree of Divorce,
4, I understand that if a claim for alimony, alimony pendente lite, marital property or collnsel
fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the
right to claim any of them will be lost
I verifY that the statements made in this Affidavit are true and correct I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S,. Section 4904 relating to unswom
falsification to authorities.
DATE:
v/1/trl
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ANDREA LEE MISCA VIGE
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ANTHONY F. MlSCA VlOE,
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
IN DIVORCE
NO, 97~94 CIVIL TERM
Plaintiff
VS.
ANDREA LEE MlSCA VlGE,
Defendant
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 330Hd OF THE DIVORCE CODE
1. J consent to the entry of a final Decree of Divorce without notice.
2, J understand that J may lose rights concerning alimony, division of property, lawyers' fees or
expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and
that a copy of the Decree will be sent to me immediately after it is filed with the Protilonotary,
J verifY that the statements made in this Affidavit are true and correct J understand that false
II statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn
falsification to authorities.
I
I DATE:
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ANDREA LEE MISCA VaGI
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
ANDRZA L. MISCAVIGB ) DlX:kel Number 97-6Ut
Plainuff )
VS. ) PACSES Case Number 870100083
ANTIIONY F, MISCAVIGB )
Defenda11l ) Other Slale ID Number 0-27452
Order
AND NOW 10 wit, this
JUNK 23, 1998
it is hereby Ordered
thai:
THB PBTITION FOR ALIMONY PBNDBNTB LITB, PILBD ON DBCBMBBR 31, 1997, IS
DISMISSBD, WITHOUT PRBJUDICB, AS THE MATTBR HAS NOT SBBN PURSUED THROUGH THB
DOMESTIC RBLATIONS SBCTION SINCB THB PILING DATB.
BY THE COURT:
ORO: R.J. Shadday _.
ee: defendant and plaInt Lff}
ee: R~by O. Weeks, Esq. )~
1I,'tJ-u
eel J~seph R. Barank~, Esq. 1~-~
JUDGE
Service Type M
FomlOE-001
Worker ID ~1005
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AMTIONY P. NI.CAVIO.,
,laiatUf
IN TIIJ: COURT or COMMON PLEAS or
CUMBBRLAND COUNTY, PI!llIISYLVAHIA
"1.
CIVIL ACTION - LAW
IN DIVORCB
ANDRIA La. NI.CAVIO.,
Defeadaat
91-6494 CIVIL TBRM
NI..'. PRTITION peR AWARD DP ALIMONY. ALIMONY PENDENTK LITE.
COURT COSTS. COUNSEL PEES. EOUITABLE DISTRIBUTION.
AND INSURANC~ RELI~F
TO n. .01f0lABLll, TBB Jl1IIQU OF SAID COURT.
CON8. NOW, Defendant, Andrea Lee Hiscavige, by hsr attorney, Ruby D. Weeke,
.Iquire, and ahe reepectfully repreasnts that.
1. Plaintiff is Anthony F. Hiscavige, an adult individual residing at 2108
Cedar Run Drive, Number 301, Camp Hill, Cumberland County, Pennsylvania,
17011.
2. Defendant ie Andrea Lee Hiscavige, an adult individual reeiding at2808
Suneet Court, P.O. Box 191, Grantham, Cumberland County, pennsylvania,
11027.
3. Plaintiff and Defendant are husband and wifs, having besn marrisd on April
30, 1918. Plaintiff filed a complaint in Divorce on November 21, 1997.
COUNSEL F~~S. COSTS. EIPENSES
4. Defendant, Andrsa Lee Hiscavig.., has retained the services of Ruby D.
Week., Esquire, and the counsel fees, costs, and expen... for
repreeentation in this action will be substantial and continuing.
5. Defendant is without sufficient funds, income, or assets to pay such
counsel fees, costs, and expenses.
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6. Defendsnt msy need to retsin the services of an appraiaer and other
experts with regard to this action.
7.
Plaintiff is financially able to provide for these expenses of Defendant.
(O.('
ALIMONY AND ALIMONY P~ND~HT~ LIT~
8. Defendant lacks sufficient meane of support at pressnt to fully provide
for her reasonable needs. In that she makes $9.32 a hour and has been
,
sdvised that she will be laid off March 31, 1998 from her employment
through Woolworth Corporation.
9. Defendant requests an award of alimony pendente lite.
10.
Defendant requires reasonable support to adequately maintain herself in
~\
accordance with the standard of living established during the marriage.
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11.
PlaintHf is financially able to provide for the reasonable needs of
Defendant.
WR~REFORE, Plaintiff prays that Your Honorable Court enter an award for,
counsel fees, costs and expenses, alimony and alimony pendente lite.
Respectfully eubmitted,
Dated. \.:1.- ~ .1;7
~VO"I'A--
Ruby D. Weeks, Esquire
Attorney for Defendant
10 West High Street
Carlisle, PA 17013
(717) 243-1294
ee: Joseph R. Bacanko,Jr., Esquire. Plaintiff
CIlNMONWU.IoTII or PEIIJIIYLVAHIA
..
COUIITY or CUMBIRLIUfD
per.onally appeared before me, a Notary Public in and for the Commonwealth
and COunty afore.aid, the under.iqned, beinq duly .worn accordinq to law, depo.ea
and eay. that the fact. .et forth in the foreqoinq Petition are true and correct.
?t1,tlf.ta- jM4~/;~
Sworn to and .ub.cri~~ to
bef~ me thta a...':/fll.l day ti'"
of Dl'om LD.l , 19.L.l.
CAl~~~
Notary Public
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TELEPHONE 717'2U" 284
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d?uG!J ~. <WUk1
ATTORNEY AT LAW
TEN WE8T HIGH 8TRUT
CARLISLE, PENNSYLVANIA 17013-21155
March 31, 1998
Cum6erland County Domestic Relations Office
13 Nonh Hanover Street
Carlisle, Pa, 17013
Re: Miscavige V Miscavige APL
Dear Sirs:
1 am again enclosing a copy of your DRS Attachment for APL Proceedings which wu
sent to me in the above matter, The parties have reached an agreement for apl and alimony
following tho divorce, At the present timo we are merely waiting to obtain all needed signatures
on tho stipulation so that it can bo entered as an order of court, I will be forwarding that to you
as soon u I have all signatures,
Sincerely,
~~o..~-t.
Ruby D. Weeks. Esquire
cc Andrea Miscavigo
Joseph R. Baranko, Jr., Attorney for Husband
rdw/c
enclosure as noted above
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