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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
"'t'
STATE OF ;~~~t PENNA,
roB ERr M. BRErn,
plaintiff
i\ (I, 97-6961
II)
VI'l','II->
MARILYN J. BREEN,
Defendant
DECREE IN
AND NOW .~ DI~{O R l~cfr~ o:.:.~~~ JA,
decreed that. , , ' . , . , , . roBEm' ,M. BREEN . , ' . , , ' . . " plaintiff,
and, ". .1:1!\!ULYN, J.. !l~.... " defendant,
are divorced from the bonds of matrimony.
~ 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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ROBERT M, BREEN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
MARILYN J. BREEN,
Defendant
No.97-t:.9"1 CIVIL TERM
IN DIVORCE
NQIICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
foregoing 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 in 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
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, L.AWYER'S
FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE
THE RIGHT TO CLAIM ANY OF THEM,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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Court Administrator, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
Telephone: (717) 240.6200
ROBERT M, BREEN,
Plalntlft'
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
CIVIL ACTION . LAW
NO, 91-6961 CIVIL TERM '
IN DIVORCE
MARll.YN J, BREEN,
Defendant
~CCEPTANC.E..OF SERVICE
I hereby enter my appearance on behalf of the Defendant, Marilyn J. Breen, and accept
service of the Complaint in divorce on his behalf and acknowledge receipt of a copy of the same.
DATE: 11ftl
uc<~~
Theresa Barrett Male
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ROBERT M. BREEN,
Plaintiff
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vs.
MARILYN J. BREEN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
NO. 97.6961 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on
December 18, 1997 and was served upon the Defendant on or about 14 January 1998 .
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice
of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand
that the Court maintains a list of marriage counselors and that I may request the Court to
require my spouse and I to participate in counseling and, being so advised, do not
request that the Court require that my spouse and I participate in counseling prior to the
divorce becoming final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
~l{M ~
R BERT . BREEN
June 4, 1998
DATE
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ROBERT M. BREEN,
Plaintiff
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vs.
MARILYN J. BREEN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
NO. 97.6961 CIVIL TERM
IN DIVORCE
AffIDAVIT OF CONSENT
1. A Complaint in Divorce unrler Section 330] (r.) of the Divorcf! Code was tiled on
December 18, 1997 and was served upon the Defendant on or about 14 January 1998
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice
of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand
that the Court maintains a list of marriage counselors and that I may request the Court to
I require my spouse and I to participate in counseling and, being so advised, do not
request that the Court require that my spouse and I participate in counseling prior to the
divorce becoming final.
I 'Jerify that the stat",ments mack, in this Affidavit arE' true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa, C.S.
Section 4904 relating to unsworn falsification to authorities,
{p - L/ - {0
DATE
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ROBERT M. BREEN,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
/'/Il,,\
NO. 97"'6:96-7 CIVIL TERM
IN DIVORCE
MARILYN J. BREEN,
Defendant
PLAINTIFF'S PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEru.NI
AND NOW comes the above-named Plaintiff, Robert M. Breen, by his
attorney, Samuel L. Andes, and petitions the Court to enforce the Property
Settlement Agreement of the parties In this matter, based upon the following:
1. The Petitioner herein Is the Plaintiff, Robert M. Breen, an adult Individual
who resides at 1041 Dogwood Lane in Enola, Cumberland County, Pennsylvania.
2. The Respondent herein Is the Defendant, fvlarllyn J. Breen, an adult
Individual who resides at 1101 Ridge Drive In Mechanlcsburg, Cumberland County,
Pennsylvania.
3. The parties were divorced by a final decree entered on 19 June 1998 in
this matter. Prior to the date of their divorce, the parties entered into a Property
Settlement Agreement to resolve the economic Issues between them in
contemplation of that divorce action. Attached hereto and marked as Exhibit A Is a
copy of the Property Settlement Agreement between the parties dated 17 December
1997.
4. Plaintiff has well and truly performed all of his obligations under the
Property Settlement Agreement.
5. Paragraph 3 of the Property Settlement Agreement obligated both parties
to share and pay equally the direct expenses incurred by the Defendant's daughter,
Kristl Schlott to complete her undergraduate college education and further obligated
the parties to share and pay equally the balance owed on Kristi Schlott's college
loans.
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6. Defendant has breached the Property Settlement Agreement between the
parties by failing and refusing to pay her share of the college loans and direct
expenses Incurred by Kristl Schlott, as required by Paragraph 3 of the Property
Settlement Agreement.
7. Defendant's share of the expenses and loan payments which Defendant Is
to pay pursuant to Paragraph 3 of the Property Settlement Agreement Is, at this
time, as follows:
A. Plaintiff paid $2,025.52 In room, board, and other direct
expenses for the child and the Defendant owes him reimbursement of
one half of that amount, or $1,012.76.
B. The balance owed on the girl's student loans, after she
completed her course of study In the summer of 1998, was $20,794.65
and those loans bear Interest at the rate of 8.25%. Defendant owes one
half of those loans, or $10,397.32, plus Interest on the unpaid balance
of 8.25% per annum.
C. Plaintiff has made four payments on the student loans, as of
the date of this Petition, of $259.96 each, for a total of $1,039.84, and
the Defendant owes the Plaintiff one half of those payments of $519.92,
plus one half of all future monthly payments until such time as
Defendant meets all of her obligations under the agreement by paying
her full share of the girl's direct expenses and student loans.
At the present time, based upon the above, the Defendant owes directly to the
Plaintiff the sum of $1,532.68, plus owes payment to the student loan servicing
center In the amount of $$10,397.32, plus Interest on that balance at the rate of
I 8.25%. Despite repeated demands by Plaintiff, Defendant has failed and refused to
make payment of those amounts, to the loan servicing center or to Plaintiff.
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II 8. Paragraph 12 of the Property Settlement Agreement requires Defendant
to pay Plaintiff's attorneys fees and other expenses Incurred In enforcing the terms
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PRQPf.RTYSETTI.J;lVItNT AGRf.f,;Mf.NT
THIS AGREEMENT, Illude this rll h day 01 (JQ(lQnlbu, 1997, IS by and
between:
ROBERT M. BREEN, of 1041 Dogwood l.ane, Enola, Ponnsylvania, party of the first
part, hereinafter referred to as "Husband"; and
MARILYN J. BREEN, of 1003-13 Nanroc Road, Mechanicsburg, Pennsylvania, party
of the second part, hereinafter referred to as "Wife."
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been married on 27
September 1989 and no children were born of this marriage;
WHEREAS, certain difficulties have arisen between the parties hereto which have
made them desirous of living separate and apart from one another and Husband has
initiated or plans to shortly initiate an action in divorce against Wife; and
WHEREAS, the parties hereto, Wife being represented by Theresa Barrett Male,
Esquire, and Husband by Samuel L. Andes, Esquire, have each exchanged full and complete
information as to the property, assets, and liabilities owned and owed by each and have
disclosed to each other and to their respective attorneys full information as to the financial
status of both parties hereto; and
WHEREAS, the parties hereto have mutually entered into an agreement for the
division of their assets, the provision for the liabilities they owe, and provision for the
resolution of their mutual differences, after both parties have had full and ample
opportunity to consult with t11P.ir respective attorneys, and the partios now wish to have
that agreement reduced to writing.
NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the
lT1uluallv made and to be kept promises set forth hereinafter, and for other good and
villuullle considerations, and intending to be legally bound and to legally bind their hoirs,
successors, assigns, and personal represent<ltives, do heroby covunant, promise, and agree
as follows:
1, Wife covenants and agrees to convey to Husband, ns his sole and separate
property, the real estate prcsently owned by the parties hereto as tonants by the entireties
and being known as 1041 Dogwood Lane, Enola, East Pennsboro Township, Cumberland
County, Pennsylvania, subject, however, to all liens, encumbrances, easements, and
restrictions presently existing thereon. Wife acknowledges that she has executed a deed to
make that conveyance and that will deliver that to Husband, or cause it to be delivered to
his attorney at the time that settlement is held on the refinancing of the debts in
accordance with Paragraph 2 heroof or immediately upon her receipt of proof from Husband
that the debts provided in Paragraph 2 hereof have been satisfied. In the event that the
property remains in joint names after the final decree in divorce between the parties and
any liens are entered against Wife's interest in the property, she will satisfy such liens, or
arrange to have them removed from the property, prior to or contemporaneously with the
delivery of the deed in accordance with this paragraph.
2. The parties acknowledge that the residence to be conveyed to Husband is
encumbered by a first mortgage owed to Homeside Lendinu Mortgage Company, on which
there is a balance of approximately $65,000.00 at this time, and a home equity loan owed
to the Pennsylvania State Employecs' Credit Union which has a principal balance of
approximatcly $14,000.00, Husband agrecs that he shall pay and satisfy those
obligations, in accordance with their terms, and agrees to indemnify and save Wife
harmless from any loss, cost, or expense caused to her by his failure to do so. Further,
Husband agrees to use diligent effort to refinance those obligations so that the present
debts, on which Wife is liable, are paid and satisfied and she is released from any
obligation, Husband will use due diligence to obtain the refinancing of those obligations
within six months of the date of this agreement or sooner.
3, The parties agree that Wife's daughter, Kristi Schlott, is a student at the Indiana
Univorslty of Punnsylvania, whoro she is scheduled to complete hcr studies in Mny of
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1998. Husband and Wife ogree that they will silarc cqually the direct expenses (meaning
tuition, room, boord, and other expenscs paid directly to the University) of Kristi Schlott's
education at said school from now througil May of 1998, with each of them paying one-
half of those expenses either to Kristi Schlott or directly to the University. The obligation
of each of them to contribute to the educational expenses of Kristi Schlott shall cease and
terminate absolutely after the term completed in May of 1998. In addition, the parties
agree that they will pay the presently-existing loans incurred for the college education of
Kri8ti Schlott, in accordance with tile terms of such student loans, wit!;lHu band and Wife
parties agree W, rA
each paying one-half of the paymcnts on those loans. ^ . tl59aRd that the
current balance owed on those loans does not exceed $l~,OOO.oo. ~ fO,"
4. The parties acknowledge that Husband currently provides health insurance for
Wife and her daughter, Kristi Schlott. Husband agrees that he will pay to continue that
insurance through 30 May 1998 on the condition, however. that Wife will cooperate to
continue such coverage under the COBRA provisions of the group insurance plan foplowin
Husband shan pay the COBRA premiums directly to the COBRA provider
the divorce between the parties. to maintain Wife', medical coverage through May 30,1998. r{!;
5. Husband covenants and agrees to transfer and assign to Wife. all of his right,
title, and interest in and to a certain 1994 Toyota Camry automobile; said automobile to be
tile sole and separate property of Wifc. The partics acknowledge that Husband has already
completed such transfcr,
6. With the exception of the items listed on Schedule A, which shall be and remain
the sole and separate property of Wife hereafter, the parties hereto mutually agree that
they have effected a satisfactory division of the furniture, household furnishings,
appliances, and other household and personal property between them and they mutually
agree that each party shull, from and after the date hereof, be the sole and separate owner
of all such tangible personal property presently in his or her possession, whether said
propClty was heretofore owned jointly or individually by the parties hereto, and this
agreement shall have the effect of un assignment or receipt from each party to the other
for such property as may be in tile individual possessions of each of the parties hereto, the
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effective date of said bill of sale to bo contemporaneous with the date of the execution of
this Agrooment. Wife sholl remove the items listed on Schedule A from tho residonce
within thirty (30) days of the date of thi€ ilgreement. 'olllumenl on her new re.idence. ~l)t{\
7, Tho parties acknowlodge that they are aware of tho incolTlo, education, income
potential, and assets and holdings of tho other or have had full and ample opportunity to
become familiar with such items, Both parties acknowledge that they are ablo to support
and maintain themselves comfortably, without contribution from the other bllyond that as
provided for in this Property Settlement Agreement, upon the incomo and assets owned by
each of them. Tho parties hereby accept the mutual covenants and terms of this
Agreement and the benofits and properties passed to them hereunder in liou of any and all
furthor rights to support or alimony for themself, counsel fees, and alimony pendente lite at
this timo and during any and all further or future actions of divorce brought by either of the
parties hereto and the parties do hereby remise, release, quit claim, and relinquish forever
any and all right to support, alimony, alimony pendente lite, counsel fees and expenses
beyond those provided for herein, during the pendency of or as a result of any such
actions, as provided by the Divorce Code of Pennsylvania or any othor applicable statute, at
this time and at any time in the future.
8. The parties acknowledge that each of them have had a full and ample
opportunity to consult with counsel of their e;hoice regarding their claims arising out of the
marriage and divorce and that they have specifically reviewed their rights to the equitable
distribution of lTIarital property, including rights of discovery, the right to compel a filing of
an Inventory and Appraisement, and the right to have the court review the assets and
claims of the parties and decide them as part of the divorce action. Boing aware of tho!ie
rights, and being aware of the marital property owned by each of the parties, the parties
hereto, in consideration of the other torms and provisions of this agreement, do hereby
waive, reloase and qUitclaim any furthor right to have this court or any other tribunal
equitably distribute or divide their marital property and do hereby further waive, relllase and
quitclaim any and all claim a(Jainst or intorest in assets now currently in the possession or
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held in the name 01 the other, it being their intention to accept the Wrms nnd provisions of
this agreement Ifl full satisfaction of ull of lheir cluims to the maritnl propcrty of the parties
and the equitable distribution of the same.
9. Except as herein otherwise provided, each party hereto may dispose of his or her
property in any way, and each party heroby oxpressly waives and relinquishes any and all
rights he or she may now have or hereaftor acquiro, under the prosent or future laws of any
jurisdiction, to share in tho property or the ostate of the other as a result of the marital
relationship, including, without limitation, the right to equitable division of marital property,
alimony, alimony pendente lite, and counsel fees, exccpt as provided for otherwise in this
Agreement, dower, courtesy, statutory allowance, widow's allowance, right to take in
intestacy, right to take against the will of the other, and right to act as administrator or
executor of the other's estate, and each will, at the request of the other, execute,
acknowledge, and deliver any and all instruments which may be necessary or advisable to
carry into effect this mutual waiver and relinquishment of all such interests, rights, and
claims,
10. Husband releases his inchoate intestato rights in tho estate of Wife and Wife
releases her inchoate intestate rights in the estate of Husband, and each of the parties
hereto by these presents for himself or herself, his or her heirs, executors, administrators,
or assigns, does remise, release, quit clnim, and forever discharge the other party hereto,
his or her heirs, executors, administrators, or assigns, or any of them, of any and all claims,
demands, damages, actions, causes of action or suits of law or in equity, of whatsoever
kind or nature, lor or becauso of any matter or thing done, omitted, or suffered to be done
by such other party prior to the dale hereof; excopt that this release shall in no way
exonerate or discharge either party hereto from the obligations and promises made and
imposed by reason of this agreoment and slwll in no way affect any cause of action In
absolute divorce which oither party may have against the other.
11, The parties hereto mutually represent to the other than neither of them has
incurred any debts In the name of Hw othnr nol previously disclosed or provided for In this
b
ilgreomont. Each of the partllls hurllhy rllpresllnls to the othor thot noither one of thom
hovo incurred or contractocl for dohts in the IHlIllll of tho othor or for which the othor is or
would bo legillly liable from ilnd ofter tho dute of the parties' separotion. Both parties
hereto mutuolly ogree ond promise that neithor will controct or otherwise incur debts in the
other's or Joint names without the prior permission and consent of the other party hereto.
Both parties heroto roprosont and worront to the othor party that thoy have not so
contracted any debts unbeknownst to the othor up to the timo end date of this Agreement.
12. In the evont that uny of the provisions of this agrooment aro breached or
violated by eithor of the parties, the othor party shall be entitled to enforce this agreemont
by an appropriate action in law or in oquity or to take any other action to which they are
lawfully entitled to enforce this agreement or otherwise protect their rights. In the event
that such action is commenced by one of tho parties and the other party is found to have
breached or violated any of the terms and provisions of this agroement, the party having so
violated or breached the agreement, shall be responsible for and shall promptly pay upon
demand tho reasonable attorney's fees incurred by the other party to enforce their rights
hereunder.
13. The parties enter into this agreement in the contemplation of the dissolution of
their marriage by a final decree in divorce to be entered in the action to be filed by
Husband. The parties agree that they shall, promptly upon the request of Husband's
attorney, make, execute, acknowledge, and deliver unto said attorney, consents and
waivers pursuant to Section 3301 (c) of the Pennsylvania Divorce Code and any and all
other documents reosonably necessary to conclude a divorce action. The parties agree that
they shall take any and all action necessary to conclude a divorce pursuant to Section
3301 (e) promptly after the execution of this agreement.
14. This Agreement shull be interpreted and construed in accordance with the laws
of the Commonwoalth or Penn3ylvania,
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15. If for any reason whatsoevor any part of this Agreement sholl bo declared void
or Invalid, only such port shall be deollled void i1nd in all other respocts this Agroement
shall remain valid and fully enforceable.
16. The waiver of any term, condition, clause, 9r provision of this Agreement shall
in no way be deerTled or considered a waiver of any other term, condition, clause or
provision of this Agreement,
IN WITNESS WHEREOF, the partios hereto havo set their hands and seals the day
and year first above written.
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SCHED.U.LE.A
White Iron daybed;
Desk from the basament office;
Treadmill;
White shelving units;
Gold mirror;
Square oak cocktail teble;
Oblong oek table;
Green chair;
Queen mattress, box spring and frame; and
Verious Items of personal property, including photo albums, seasonal
decorations, and antique sewing machine in a cherry cabinet, and other
assorted momentos presently located In the attic of the marltel residence,
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ROBERT M. BREEN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
MARILYN J. BREEN,
Defendant
97-6961 CIVIL TERM
ORDER OF COURT
AND NOW, this 22nd day of April, 1999, upon the
agreement of the parties, it is ordered and decreed as follows:
1. The Defendant, Marilyn J. Breen, shall pay
directly to the student loan servicing center no later than May
15, 1999, the sum of $2,687.50 to be applied to the loans owed
on behalf of her daughter, Kristi Schlott.
2. This payment is in full satisfaction of the claims
raised in the Petition To Enforce Property settlement Agreement
filed by the Plaintiff, Robert M. Breen, and the payment is in
full and final satisfaction of the Defendant's obligations under
Paragraph 3 of the parties' settlement agreement which was
executed on December 17th, 1997.
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By the court,
Samuel L. Andes, Esquire
525 North 12th Street
Lemoyne, PA 17043
For the Plaintiff
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Theresa Barrett Male, Esquire
115 Pine Street
HarriSburg, PA 17101
For the Defendant
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