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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA,
STEPHEN P. BRANDT
No, 98 - 2529
__.P.l.lln.t.i.ll______~___.
VERSUS
MAUREEN S. BRANDT
Defendant
DECREE IN
DIVORCE
AND NOW,__-!=:>_l" I
,~P-S, IT IS ORDERED AND
DECREED THAT
Stephen P. Brandt
, PLAI NTI FF,
ANO
Maureeen S. Brandt
_' DEFEN DANT,
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 BEEN ENTERED; None
~~tached Property Settle~ent Agreement dated November 29,
2004 i~ hereby incorporated, but not merged, into this Decree in
By THE COURT: // j)L
___ ~~J.~ __
PROTHONOTARY
.
PROPERTY SETTLEMENT A_GREEMENT
l' v: t<
b j. YHIS AGREEMENT, Made this ,) day of
,A.. ,Vt( IJ,(j(~ , 2004, by and between STEPHEN p, BRANDT, hereinafter
referred to as "Husband", and MAUREEN S, BRANDT, hereinafter referred to as "Wife",
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on November 11,
1978; and
WHEREAS, ono child was born of this marriage, namely, Katherine Brandt,
born December 29,1990; and
WHEREAS, certain differences have arisen between the parties as a result
of which they have separated and now live separate and apart from one another, and are
desirous of settling fully and finally their respective financial and property rights and
obligations as between each other, including, without limitation by specification: the
settling of all matters between them relating to the past, present and fuiUre support and/or
maintenance of Wife by Husband or of Husband by Wife; and in general the settling of
any and all claims and possible claims by one against the olher or against their respective
estates for equitable distribution of all marital property; and a resolution of all mutual
responsibilities and rights growing out of the marriage relationship; and
WHEREAS, the parties hereto, after being properly advised by their
respective counsel, Husband by his altorney, John J. Connelly, Jr., and Wife by her
attorney, Sandra L, Meilton, have come to the following agreement.
NOW THEREFORE, in consideration of the above recitals and the following
covenants and promises mutually made and mutually to be kept, the parties heretofore,
intendin9 to be legally bound and to legally bind their heirs, successors and assigns
thereby, covenant, promise and agree as follows:
1, S~PARI\TION:
It shall be lawful for eact. party at all times hereafter to live separate
and apart from the other at such place or places as he or she may from time to time
choose or deem fit.
2, PERSQNAl RIGHTS:
Eaoh party shall be free from Interferenoe, authority and contaot by
the other, as fully as If he or she were single and unmarried, except as may be neoessary
to carry oul the provisions of this Agreement. Neither party shall molest the other nor
attempt to endeavor to molest the other, nor compel the other 10 cohabit with Ihe other,
nor 111 any way harass or malign the olher, nor In any way Inlerfere with the peaceful
existence, separate and apart from the other In all respects as If he or she were single
and unmarried,
3, WifE'S DEBTS:
Wife represents and warrants 10 Husband that since their separation
on May 1, '1998, she has not, and In the future she will not, conlract or incur any debt or
liability for which Husband or his eslate might be responsible and shall Indemnify and
save Husband harmless from any and all claims or demands made against him by reason
of debts or obligations Incurred by her,
Husband and Wife agree Ihat Wife has been using a joint credit card
and that she does not, at Ihe time of the signing of Ihis Agreement, have a credit card In
her own name, Wife agrees to promptly apply for a credit card in her own name and the
parties agree Ihat until she is able to obtain a credil card in her own name, she shall be
entitled to continue to use the joint credit card, Wife shall be solely responsible for any
oharges incurred by her on the joint card and shall hold Husband and/or his eslate
harmless from any and all claim or demands made against him by reason of her use of
the )olnl credit card, Upon obtaining a credit card in her own name, Wife shall promptly
pay the balance outstanding on Ihe joinl credit card and have that card closed,
4, HUSBAND'S DEBTS:
Husband represents and warrants to Wife thaI since their separation
on May 1, 1998, he has not, and in the fulure he will not, contract or incur any debt or
liability for which Wife or her estate might be responsible and shall indemnify and save
Wife harmless from any and all claims or demands made against her by reason of debts
or obligations Incurred by him,
From the date of execution of this Agreement, Husband shall use
only those credit cards and accounls for which he Is individuallY liable and the parties
agree to cooperate In oloslng any remaining accounts which provide for joint liability,
.2-
5, OUTSTANDING MARITAL DEBTS:
Husband and Wife acknowledge and agree that they have no
outstanding debts and obligations of the Husband and Wife Incurred prior to the signing
of this Agreement.
6, MUTUAL RELEASE:
Subject to the provisions of this Agreement, each party waives his or
her right to alimony and any further distribution of property inasmuch as the parties hereto
agree that this Agreement provides for an equitable distribution of their marital property in
accordance with Ihe Divorce Code of 1980, Subject 10 the provisions of Ihis Agreement,
each party has released and discharged, and by this Agreement does for himself or
herself, and his or her heirs, legal representatives, executors, administrators and assigns,
release and discharge the other of and from all causes of action, claims, rights or
demands whatsoever arising out of their marriage, excepl any or all cause or causes of
acllon for divorce and except in any or all causes of aclion for breach of any provisions of
this Agreement. Each party also waives his or her right to request marital counseling
pursuanl to 23 Pa,C,SA Section 3302,
7, gaulTABLE DISTRIBUTION OF MARITAL PROPERTY:
The parties have attempted to distrlbule their marilal property In a
manner which conforms to Ihe criteria set forth in 23 Pa,C,S,A. Section 3501 et. seQ" and
taking Into account the fOllowing considerations: the length of Ihe marriage; Ihe fact that It
is the first marriage for b':llh Husband and Wife, the age, health, station, amount and
sources of income, vocational skills, employability, estale, Iiabililies and needs of each of
the parties; the contribution of each party to the education, training or Increased earning
power of the other party; the opportunity of each party for future acquisitions of capital
assels and income; the sources of income of both parties, including but not limited to
medical, retirement, insurance or other benefits; the contribution or dissipation of each
party In Ihe acquisition, preservation, depreciation or appreciation of the marital property,
Including the contribution of each spouse as a homemaker; Ihe value of the property set
apart to each party; the standard of living of the parties established during Ihe marriage;
and the economic circumstances of each party at Ihe lime the division of property Is to
become effective,
The division of existing marital property is not intended by the parties
to constitute In any way a sale or exchange of assets, and Ihe division is being effeoted
wlthoul the Introduction of oulslde funds or olher property nol conslltullng marital
property, The division of property under this Agreement shall be In full satisfaction of all
marital rights of the parties,
- 3 -
A, DISTRIBUTION OF PERSONAL PROPERTY:,
Except as may be otherwise provided herein, the parties hereto
mutually agree that they have effected a satisfactory division of the furniture, household
furnishings, appliances, and other household personal property between Ihem, and they
mutually agree that each party shall from and after the date hereof be the sole and
separate owner of all such tangible personal property presently in his or her possession,
and this Agreement shall have Ihe effect of an assignment or bill of sale from each party
to the other for such property as may be in the individual possession of each of the
parties hereto,
The parties hereto have divided between themselves, to their mutual
satisfaction, all items of tangible and intangible marital property, Neither party shall make
any claim to any such items of marital property, or of Ihe separate personal property of
either party, which are now in Ihe possession and/or under the control of the other,
Should II become necessary, the parties each agree 10 sign, upon request, any titles or
documents necessary to give effect to this paragraph, Property shall be deemed to be in
the possession or under the control of either party if, in the case of tangible personal
property, the Item Is physically In Ihe possession or control of the party allhe time of the
signing of this Agreement and, in the case of intangible personal property, if any physical
or written evidence of ownership, such as passbook, checkbook, policy or certificate of
insurance or other similar writing Is in the possession or control of the party, Except as
may be otherwise provided herein, Husband and Wife shall each be deemed to be in the
possession and control of his or her own individual pension or other employee benefit
plans or retirement benefits of any nature with Ihe exception of Social Security benefits to
which either party may have a vesled or contingent right or interesl at the time of the
signing of this Agreement, and neither will make any claim againsl the other for any
Interest In such benefits,
From and after the date of the signing of this Agreement, both
parties shall have complete freedom of disposition as to his/her separate property and
any property which is in their possession or control pursuant to this Agreement and may
mortgage, sell, grant, convey, or olherwise encumber or dispose of such property,
whether real or personal, whether such property was acquired before, during or after
marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any
deed, mortgage, or other instrument of Ihe other pertaining to such disposition of
property,
- 4 -
B, DISTRIBUTION OF REAL EST~TE:
The parties agree thaI Ihey presenlly own a residence localed al 2
Accent Circle, Camp Hili, Cumberland County, Pennsylvania, and both parties agree that
they believe Ills In Katherine's best interests if she Is afforded an opportunity to continue
to reside In the residence for a period of lime, Consequently, Ihe parties agree as follows:
(1) Husband shall, at the time of the execution of Ihis
Agreement, transfer all of his right, title and interest 10 the marital residence to Wife,
(2) Wife shall have the exclusive use and possession of
the residence until such time as she chooses to no longer reside in Ihe real eslate until
Katherine reaohes age 22 or graduates from college, whichever shall firsl occur, Allhat
time, Wife, at her discretion, may eilher sell the house or buy oul Husband's 45%
Interest. In Ihe event that Wife decides to remain in the marital residenoe, buyout
Husband's Inlerest and oblaln a mortgage on the marital residence In order 10 purchase
Husband's interest, the appraisal done for the purposes of obtaining the mortgage shall
control the value of the house for Ihe purpose of determining Husband's 45% Interest. In
the evenl thaI Wife decides to purchase Husband's Interest but does not choose to
mortgage the residence, then and in thaI event, the parties shall mutually agree upon an
appraiser to set the fair market value for the purposes of determining Husband's 45%
interest.
(3) At the time of sale, Ihe parties shall divide the net
proceeds 55% by Wife and 45% by Husband, Net proceeds shall be defined as the
balance remaining of the sale price, less any capital gains or tax consequences Incident
to the s..~: "I '~,d residence, any liens or mortgages on the residence agreed to by the
parties, taxes, realtor's commissions and costs incidenl to sale, Wife cannot further lien
or encumber the property without Ihe consent of Husband in writing,
(4) While Wife resides at the marital residence, the parties
shall share the costs of major maintenance and repairs to the residence equally between
them, Ills the Inlent of the parties that in addition to major maintenance and repairs, they
shall also share real estale taxes, homeowner's insurance and repairs required by Camp
Hili Borough, Major maintenance shall be defined as Including, but not limited to, repair
and replacement of the heating and cooling system, necessary plumbing, electrical and
roofing repairs and all repairs, but shall not include Interior painting and general interior
face lifting,
(5) In the event that either party dies prior to Ihe sale of
the marital residence, the deceased party's inlerest In Ihe marital residence shall pass to
the parties' daughter, Katherine,
- 5 -.
(a) the 2004 Volvo S60 shall become Ihe sole and
exclusive property of Wife free and clear of all liens and encumbrances;
(b) the 2001 Lexus LS430 shall become the sole and
exclusive property of Husband free and clear of all liens and encumbrances; and
(c) the titles 10 the said motor vehicles shall be executed
by the parties, if appropriate for effecting transfer as herein provided, on the date of
execution of this Agreement and the said execuled title shall be delivered to the proper
parties on the distribution date,
9, LIFE INSURANCE:
Husband agrees to continue to maintain in full force and effect the
present two (2) Insurance policies on his life Issued by Jefferson Pilot Financial Life
Insurance Company having a combined face value of $600,000, As noted In this
Agreement, Ihe existing loans on Husband's insurance policies shail be paid in full
through the liquidation of Boston Scientific 5tocl(, Husband shall make Wife the owner of
said Insurarlce policy and same shall be subject to the following conditions:
(a) Except as specifically provided herein, he shall
maintain Ihe Insurance In full force and effect, paying all premiums due thereon and shall
not borrow against, assign, pledge, or otherwise encumber the insurance, nor surrender il
10 obtain Its cash value;
(b) He shall Immediately designate Maureen S, Brandt, his
wife, as irrevocable beneficiary of Insurance in the face amount of $500,000 until his
alimony obligation ends and until all of his obligations under this Agreement are fulfilled
and also designate Katherine Brandt, the parties' daughter, as Irrevocable beneficiary of
Insurance in the face amount of $300,000 until the earlier of Katherine's gradualion from
college 01' reaching the age of 23 years; and
(c) Within thirty (30) days after the execution of this
Agreement, Husband shall deliver 10 Wife or his attorney satisfactory proof that said
Irrevocable beneficiary designations have been properly endorsed on each insurance
policy and that the Insurer has received notice of restrictions placed upon the ownership
of the insurance by Ihe terms of this Agreement. Husband shall also request that
duplicate premium statements and receipts be mailed by the insurer to Wife,
- 8 -
10, CUSTODY AN!?_8UPPORT:
The parties agree that they will share legal custody of their minor
daughter, Katherine, with Wife having primary custody subject to Husband's partial
oustody rights to be mutually agreed upon, Husband agrees to pay to Wife the sum of
$1,500 per month for the support of their daughter and further to oontlnue to maintain
medical insurance as provided by Husband's employer on the said child, The support
payments of $1,500 per month are based upon Husband having an annual income of
$175,000, To the extent that Husband shall earn more than $175,000 annually, he shall
provide Wife with 15,5% of any net income over a gross Income of $175,000 per year,
Tothe extent that Ihose amounts over the $175,000 are paid to Husband as a resull of a
bonus, Wife shail receive her 15,5% within ten (10) days of Husband's receipt of the
bonus,
Husband shail pay child support directly to Wife in the sum of $1,500
per month (or increased amount as noted above) commencing on the first day of the first
month following the signing of this Agreement. Payments shall thereafter be paid on or
before the first day of each month,
The parties herein acknowledge that support Is modifiable pursuant
to the Pennsylvania Family Support Guidelines, and Ihat Wife may petition the Court of
Common Pleas of Cumberland County, or any other court having appropriate jurisdiction,
to establish a court order of support pursuant to such guidelines,
11. ALIMONY:
Husband agrees to pay Wife the sum of $2,500,00 per month for the
support and maintenance of Wife, Such obligation for support to Wife shall commence
with the first day of the first month after the signing of this Agreement and continue for a
five (5) year period,
Beginning with the first day of the first month after the expiration of
the five (5) year period, Husband shail pay Wife the sum of $2,200,00 per month and
continue until Wife dies, remarries or enters into cohabitation with an adult individual who
Is not a member of the Wife's immediate family within the degrees of consanguinity
subsequent to the signing of this Agreement. The alimony payments may be modified
based upon proof of an involuntary substantial change of Husband's economic
circumstances, Husband further agrees to provide medical and hospitalization coverage
for Wife until the entry of a final Decree in Divorce between the parties,
Wife acknowledges and agrees that the provisions of this Agreement
providing for the payment of alimony to her by her Husband are fair, adequate, and
- 9 -
satiflfactory 10 her and are based upon her actual need, her Husband's ability to pay, the
duration of the parties' marriage and other relevant factors which have been taken into
consideration by the parties, Although the approval of this Agreement by a court of
competent jurisdicllon in connection wllh an action In divorce or annulment filed by
HUflband or Wife shall be deemed an order of the court and may be enforced as provided
In 23 Pa,C,SA Section 3701, as amended, this Agreement, insofar as it pertains only to
SUppolt for Wife or Husband and Ihe paymenl of alimony following the entry of a final
Decree In Divorce between Ihe parties, may not be modified, suspended, termlnaled, or
reinstated al the instance or request of the Wife or Husband, or subject to further order of
any court upon changed circumstances of the Wife or Husband of a substantial 01'
continuing nalure, or for any reason claimed by Wife or Husband whatsoever. Upon that
condition, Wife hereby accepls the provisions of this Agreement In lieu of and In full and
final settlement and satisfaction 01 all claims and demands thaI she may now or hereafter
have against Husband for her support and maintenance of herself and for alimony,
Except as specifically provided herein, Husband and Wife further voluntarliy and
intelligently waive and relinquish any right to seek a modification, suspension, termination,
reinstllution, or other couli order wllh respect to the terms of this Agreement pertaining to
the payment of support to Wife or to Husband or the payment of alimony by Husband or
the payment of alimony by Wife,
12, ALIMONY PENDENTE LITE, COUNSEL FEES, AND EXPENSES:
Husband and Wife acknowledge and agree that the provisions of this
Agreement providing for the equitable distribution of marital property of the parties are
fair, adequale and satisfactory to them, Both parties agree to accept the provisions set
forth In this Agreement in lieu of and in fuli and final settlement and satisfaction of all
claims and demands Ihat either may now or hereafter have against the other for alimony
pendente lile, counsel fees or expenses or any other provision for their support and
maintenance before, during and after the commencement of any proceedings for divorce
or annulment between the parties,
13. INCOME TAX PRIOR RETURNS:
The parties have heretofore filed joint federal and state tax returns,
Both parties agree that In the event any deficiency in federal, state or local Income tax Is
proposed, or any assessment of any such tax is made against either of them, each will
Indemnify and hold harmless the other from and against any loss or Iiablllty for any such
tax defiCiency or assessment and any interest, penalty and expense incurred In
connection therewith, Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who Is finally determined to be the cause of the
- J.O -
mlsrepresenlalions or failures 10 disclose Ihe nalure and exlent of his or her separate
Income on the aforesaid Joint returns,
14, WmERS OF CLA.IMS AGAINST ESTATES:
Except as herein otherwise provided, each party may dispose of his
or her property In any way, and each party hereby waives and relinquishes any and all
rlghls he or she may now have or hereafter acquire, under Ihe present or fulure laws of
any Jurisdiction, 10 share in the property or the aslate of the olher as a result of the marital
relationship, including without limitation, dower, curtesy, stalutory allowance, widow's
allowance, righllo take in Inteslacy, righl to take agalnsllhe will of Ihe other, and right 10
act as administrator or execulor of Ihe other's estate, Each will, al Ihe requesl of the
other, execule, acknowledge and deliver any and all inslruments which may be necessary
or advisable to carry inlo effect Ihls mutuaf waiver and relinquishment of all such inlerests,
rights and claims,
15, MUTUAL CONSENT DIVORCE:
The parties agree and acknowledge thaI Ihelr marriage Is
Irretrievably broken, Ihat they do not desire marital counseling, and Ihatlhey both consenl
to the entry of a decree In divorce pursuant to 23 Pa,C,SA Section 3301 (c),
Accordingly, both parties agree to execule such consents, affidav/ls, or other documenls
and to direcl Ihelr respecllve attorneys to file such consenls, affidavits, or other
documenls as may be necessary 10 proceed 10 obtain a divorce pursuant to said 23
Pa,C,SA Section 3301(c) immedialely after January 1, 2005. Upon requesl, 10 tile
extent permitted by law and Ihe applicable Rules of Civil Procedure, the named defendanl
In such divorce action shall execule any waivers of nolice or other walvors necessary to
expedite SUch divorce,
It is the Inlenlion of the parties that the Agreement shall survive any
action for divorce which lTlay be Instltuled or proseculed by either party and no order,
judgmenl or decree of divorce, lemporary, final or permanent, shall affect or modify tha
financ/allerms of this Agreement. This Agreernenl shall be Incorporated In bul shall not
merge into any such jUdgmenl or decree of final divorce, but shall be incorporated for the
purposes of enforcement only,
- 11 -
21, VOLUNTARY EXECUTION:.
The provisions of Ihis Agreement and their legal affecl have been
fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, that it is being entered into voluntarily, wilh full
knowledge of Ihe assels of both parties, and Ihat it Is not the result of any duress or
undue influence, The parties acknowledge that they have been furnished with all
information relating to the financial affairs of the other which has been requesled by each
of them or by Iheir respective counsel,
22, f~Jl!3E AGREEMENT:
This Agreemenl contains the entire understanding of the parties and
Ihere are no representations, warranties, covenants or undertakings olher than those
expressly set forth herein, Husband and Wife acknowledge and agree that the provisions
of this Agreement with respecl to the distribution and division of marital and separate
property are fall', equilable and salisfactory 10 them based on the length of their marriage
and other relevant factors which have been laken inlo consideration by the parties, Both
parties hereby accept the provisions of this Agreement with respect to the division of
property in lieu of and in full and final settlemenl and satisfaction of all claims and
demands that they may now have or hereafter have against the other for equilable
dislrlbution of their property by any court of competent jurisdiction pursuant to 23
Pa,C,SA Section 3501 ~, sea, or any other laws, Husband and Wife each voluntarily
and intelligently waive and relinquish any righlto seek a court ordered determination and
distribution of marital property, but nolhing herein contained shall constitute a waiver by
either party of any rights to seek the relief of any court for the purpose of enforcing the
provisions of this Agreement.
23, DISCLOSURE:
The parties confirm Ihatlhey have relied on the completeness and
substantial accuracy of the financial disclosure of the other as an Inducement to the
execulion of this Agreement. The parties acknowledge that Ihere has been no formal
discovery conducted in Ihelr pending divorce aclion and Ihal neither party has filed an
inventory and appraisemenl as required by Seclion 3505(b) of the Pennsylvania Divorce
Code, Notwilhstanding the foregoing, the rig hIs of eilher party 10 pursue a claim for
equitable distribution, pursuant 10 the Pennsyivanla Divorce Code, of any interest owned
by the other party in an asset of any nature at any time prior to the date of execution of
this Agreement thaI was nol disclosed 10 the other party or his or her counsel prior to the
date of Ihe within Agreemenlls expressly reserved, In the event that either party, al any
,. 13 -
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STEPHEN P. BRANDT,
Plaintiff
:IM THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2529 CIVIL TERM /99P
I
:CIVIL ACTION - LAW
I IN DIVORCE
v.
MAUREEN S. BRANDT,
Defendant
~OF OF SERVI~
I, paige Maodonald-Matthes, Esquire, do hereby certify
that a true and correct copy of the Complaint in Divorce in
the above captioned matter was served on Defendant, Maureen S.
Brandt, by First Class, certified Delivery Mail, postage
prepaid, on May 6, 1998. The receipt card is attached hereto.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: May B, 199B
By: '..---;:.~ "." '''kJ~,('d'~)"v..''Lj-J.. '1
P tge Macdonald-Matthes, Esquire
1.0. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 23B-6570
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STEPHEN P. BRANDT,
Plailltlff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v,
NO, 2529
MAUREEN S, BRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
~SWER ANQ...COUNTIlliC.LAIM TO COMPLAllSliN....uIVORCE
AND NOW, comes the Defendant, Maureen S, Brandt, by lInd througb her attomey,
Joseph J. Dixon, Esquire, and nles this Answer and Counterclaim to the Complaint in Divorce In
the above-captioned matter as followf~:
1. Admitted,
2. Admitted,
3, Admitted,
4, Admitted,
5, Admitted,
6, Admitted,
7, Admitted,
R, (a) Admitted,
(b) Denied, Tlw Defendant denies that she has offered such indignities to the
person of the Plaintiff, as to render his condition intolerable and life burdensome, and further
denies that be the innocent and injured spousc, To the contrary, it is averred that the Defendant
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'WI HI"U'I' CERTII"Y T~AT THI WITt'UN It
r A 'I'"uE AND COH'U1CT COPY 01" THI!
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STEPHEN P. BRANDT,
Plaintiff
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
MAUREEN S. BRANDT,
Defendant
· NO. 98-2529
· CIVIL ACTION .- LAW
· IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on May 4, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce.
4. I understand that I may lose rights conceming alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted·
5. I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
{}4904 relating to unsworn falsification to authorities.
Date: 11/29/04
' I~I~ILU reen-S.' ~ra n/dt, Defendant
STEPHEN P. BRANDT,
Plaintiff
Vo
MAUREEN S. BRANDT,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 98-2529
: CIVIL ACTION .- LAW
:IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that l may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is
entered by the Court and that a copy of the decree will be se~nt to me immediately after it is
filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Date: 11/29/04
73050.1
Ma~een S. 8~'a~d{, Defendant
STEPHEN P. BRANDT,
PLAINTIFF
Vo
MAUREEN S. BRANDT,
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98 - 2529
· CIVIL ACTION -. LAW " ~
DEFENDANT INDWORCE , Np-, ~
AFFIDAVIT OF CONSENT ~
1. A Complaint in Divorce under Section 3301(c) of the Divorce Cod ~
May4, 1998. ~-, ~
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both 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·
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry ora final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made above are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom
falsification to authorities.
Date:
Stephe ~'-'-Z:n ~~Plain ti~ff~~'''''''''''
II
STEPHEN P. BRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. ;)'5J.1
CIVIL TERM
MAUREEN S. BRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTrCE TO DEFEND AND CLArK RrGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
take prompt action. You 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 Dauphin County
Courthouse, Harrisburg, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY COURT ADMINISTRATOR
Cumberland County Courthouse, 4th Floor
1 Courthouse Square
CarliSle, PA 17013-3387
Telephone: (717) 240-6200
CUNNINGHAM & CHERNICOFF, P.C.
BY~, ~ j'.'~N-,,~""''''o:J~ m,..~'\.D/)
Paige Mcdonald-Matthes, Esquire
1.D. #66266
2320 North Second Street
P. O. Box 1855
Harrisburg, PA 17105-1855
Date: ~ \ \<\'\.t'
(\ I
II
3. The Plaintiff has been a bona fide resident in the
Commonwealth of Pennsylvania for at least the last six (6)
months immediately previous to the filing of this Complaint.
4. The Defendant has been a bona fide resident in the
Commonwealth of Pennsylvania for at least the last six (6)
months immediately previous to the filing of this Complaint.
5. The Plaintiff and Defendant were married on November
11, 1978, in Camp Hill, Cumberland County, Pennsylvania.
6.
1998.
The Plaintiff and the Defendant separated on May 1,
7. The parties are the parents of one (1) minor child,
Katherine Brandt, date of birth, December 29, 1990.
8. The Plaintiff avers as the grounds on which this
action is based that:
(a) The marriage is irretrievably broken; and
2
II
(b) The Defendant has offered such indignities to
the person of the plaintiff, the injured and innocent spouse,
as to render his condition intolerable and life burdensome.
9. There has been no prior action for divorce or
annulment of marriage between the parties in this or any other
jurisdiction.
~o. The Plaintiff has been advised of the availability
of counseling and that the Defendant may have the right to
request that the Court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff prays your Honorable Court to
enter a Decree in Divorce from the bonds of matrimony.
COUNT II
9. The averments in paragraphs ~ through 8, inclusive,
are incorporated herein by reference thereto.
~o. During the course of the marriage, the parties
acquired marital property.
3
II
VERXFXCATXON
I, Stephen P. Brandt, verify that the statements made in
the foregoing Complaint in Divorce are true and correct to the
best of my knowledge, information and belief.
I understand
that false statements herein are made subject to the penalties
of 18 Pa. C.S. ~4904, relating to unsworn falsification to
authorities.
5:----- ////. . )'
( 6t7' ,/// ~~4e-~
Stephen P. Brandt
Date:
p;1/ f'ff'
,
II
Ij
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
55;
COUNTY
OF
DAUPHIN
I, Stephen P. Brandt, being duly sworn according to law,
depose and say:
(I), I have been advised of the availability
of marr~age 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 Domestic
Relations 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 court.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 94904 relating to
unsworn falsification to authorities.
,d ~,//
~ /;/~
("',.. '/.,(' "~
Stephe P. Brandt
SWORN and Subscribed to
Before me this /.s.i day
M ~~' m,.
& ,1 tvu/Jvr-
/ - NOTARY PUBLIC '-'
Bla h Notarial Seal
nc e A. Morrison N ta .
HarriSburg Daup'h' Oc ry Public
My Co ..' In ounty
mmlsSlon Expires Nov. S, 2001
em fir. !1nnsy van a ssoc a on 0 0 a es
II
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
55;
COUNTY
OF
DAUPHIN
The Plaintiff, being duly sworn according to law, deposes
and says that he is the Plaintiff in the above captioned
matter and that he personally knows that the Defendant is over
the age of eighteen (18) years.
The Plaintiff further avers that the Defendant is not in
the Military Service or in any branch of the Armed Forces of
the United States of America or its Allies or otherwise within
the provisions of the Soldiers' and Sailors' civil Relief Act
of Congress of 1940 and its Amendments.
~c~ /~~/
ste~en P. Brandt
SWORN and Subscribed to
/If
this day
of , 1998.
tJ//
~ /1 vIA-
Notarial Seal
BlanChe: A. Morrison, Notary PUblic
Ham~bu.rg. Dauphin Count
My CommIssIOn ExpIres Nov. a,Y2001
em r, ennsy vama ssoc a on 0 0 ar es
PROPERTY SETTLEMENT AGREEMENT
1 r.J t\
/; J THIS AGREEMENT, Made this;A day of
./J' V'{ IA~ , 2004, by and between STEPHEN P. BRANDT, hereinafter
referred to as "Husband", and MAUREEN S. BRANDT, hereinafter referred to as "Wife".
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on November 11,
1978; and
WHEREAS, one child was born of this marriage, namely, Katherine Brandt,
born December 29, 1990; and
WHEREAS, certain differences have arisen between the parties as a result
of which they have separated and now live separate and apart from one another, and are
desirous of settling fully and finally their respective financial and property rights and
obligations as between each other, including, without limitation by specification: the
settling of all matters between them relating to the past, present and future support and/or
maintenance of Wife by Husband or of Husband by Wife; and in general the settling of
any and all claims and possible claims by one against the other or against their respective
estates for equitable distribution of all marital property; and a resolution of all mutual
responsibilities and rights growing out of the marriage relationship; and
WHEREAS, the parties hereto, after being properly advised by their
respective counsel, Husband by his attorney, John J. Connelly, Jr., and Wife by her
attorney, Sandra L. Meilton, have come to the following agreement.
NOW THEREFORE, in consideration of the above recitals and the following
covenants and promises mutually made and mutually to be kept, the parties heretofore,
intending to be legally bound and to legally bind their heirs, successors and assigns
thereby, covenant, promise and agree as follows:
1. SEPARATION:
It shall be lawful for each party at all times hereafter to live separate
and apart from the other at such place or places as he or she may from time to time
choose or deem fit.
2. PERSONAL RIGHTS:
Each party shall be free from interference, authority and contact by
the other, as fully as if he or she were single and unmarried, except as may be necessary
to carry out the provisions of this Agreement. Neither party shall molest the other nor
attempt to endeavor to molest the other, nor compel the other to cohabit with the other,
nor in any way harass or malign the other, nor in any way interfere with the peaceful
existence, separate and apart from the other in all respects as if he or she were single
and unmarried.
3. WIFE'S DEBTS:
Wife represents and warrants to Husband that since their separation
on May 1, 1998, she has not, and in the future she will not, contract or incur any debt or
liability for which Husband or his estate might be responsible and shall indemnify and
save Husband harmless from any and all claims or demands made against him by reason
of debts or obligations incurred by her.
Husband and Wife agree that Wife has been using a joint credit card
and that she does not, at the time of the signing of this Agreement, have a credit card in
her own name. Wife agrees to promptly apply for a credit card in her own name and the
parties agree that until she is able to obtain a credit card in her own name, she shall be
entitled to continue to use the joint credit card. Wife shall be solely responsible for any
charges incurred by her on the joint card and shall hold Husband and/or his estate
harmless from any and all claim or demands made against him by reason of her use of
the joint credit card. Upon obtaining a credit card in her own name, Wife shall promptly
pay the balance outstanding on the joint credit card and have that card closed.
4. HUSBAND'S DEBTS:
Husband represents and warrants to Wife that since their separation
on May 1, 1998, he has not, and in the future he will not, contract or incur any debt or
liability for which Wife or her estate might be responsible and shall indemnify and save
Wife harmless from any and all claims or demands made against her by reason of debts
or obligations incurred by him.
From the date of execution of this Agreement, Husband shall use
only those credit cards and accounts for which he is individually liable and the parties
agree to cooperate in closing any remaining accounts which provide for joint liability.
- 2 -
5. OUTSTANDING MARITAL DEBTS:
Husband and Wife acknowledge and agree that they have no
outstanding debts and obligations of the Husband and Wife incurred prior to the signing
of this Agreement.
6. MUTUAL RELEASE:
Subject to the provisions of this Agreement, each party waives his or
her right to alimony and any further distribution of property inasmuch as the parties hereto
agree that this Agreement provides for an equitable distribution of their marital property in
accordance with the Divorce Code of 1980. Subject to the provisions of this Agreement,
each party has released and discharged, and by this Agreement does for himself or
herself, and his or her heirs, legal representatives, executors, administrators and assigns,
release and discharge the other of and from all causes of action, claims, rights or
demands whatsoever arising out of their marriage, except any or all cause or causes of
action for divorce and except in any or all causes of action for breach of any provisions of
this Agreement. Each party also waives his or her right to request marital counseling
pursuant to 23 Pa.C.S.A. Section 3302.
7. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY:
The parties have attempted to distribute their marital property in a
manner which conforms to the criteria set forth in 23 Pa.C.SA Section 3501 et. seq., and
taking into account the following considerations: the length of the marriage; the faCt that it
is the first marriage for both Husband and Wife, the age, health, station, amount and
sources of income, vocational skills, employability, estate, liabilities and needs of each of
the parties; the contribution of each party to the education, training or increased earning
power of the other party; the opportunity of each party for future acquisitions of capital
assets and income; the sources of income of both parties, including but not limited to
medical, retirement, insurance or other benefits; the contribution or dissipation of each
party in the acquisition, preservation, depreciation or appreciation of the marital property,
including the contribution of each spouse as a homemaker; the value of the property set
apart to each party; the standard of living of the parties established during the marriage;
and the economic circumstances of each party at the time the division of property is to
become effective.
The division of existing marital property is not intended by the parties
to constitute in any way a sale or exchange of assets, and the division is being effected
without the introduction of outside funds or other property not constituting marital
property. The division of property under this Agreement shall be in full satisfaction of all
marital rights of the parties.
- 3 -
A. DISTRIBUTION OF PERSONAL PROPERTY:
Except as may be otherwise provided herein, the parties hereto
mutually agree that they have effected a satisfactory division of the furniture, household
furnishings, appliances, and other household personal property between them, and they
mutually agree that each party shall from and after the date hereof be the sole and
separate owner of all such tangible personal property presently in his or her possession,
and this Agreement shall have the effect of an assignment or bill of sale from each party
to the other for such property as may be in the individual possession of each of the
parties hereto.
The parties hereto have divided between themselves, to their mutual
satisfaction, all items of tangible and intangible marital property. Neither party shall make
any claim to any such items of marital property, or of the separate personal property of
either party, which are now in the possession and/or under the control of the other.
Should it become necessary, the parties each agree to sign, upon request, any titles or
documents necessary to give effect to this paragraph. Property shall be deemed to be in
the possession or under the control of either party if, in the case of tangible personal
property, the item is physically in the possession or control of the party at the time of the
signing of this Agreement and, in the case of intangible personal property, if any physical
or written evidence of ownership, such as passbook, checkbook, policy or certificate of
insurance or other similar writing is in the possession or control of the party. Except as
may be otherwise provided herein, Husband and Wife shall each be deemed to be in the
possession and control of his or her own individual pension or other employee benefit
plans or retirement benefits of any nature with the exception of Social Security benefits to
which either party may have a vested or contingent right or interest at the time of the
signing of this Agreement, and neither will make any claim against the other for any
interest in such benefits.
From and after the date of the signing of this Agreement, both
parties shall have complete freedom of disposition as to his/her separate property and
any property which is in their possession or control pursuant to this Agreement and may
mortgage, sell, grant, convey, or otherwise encumber or dispose of such property,
whether real or personal, whether such property was acquired before, during or after
marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any
deed, mortgage, or other instrument of the other pertaining to such disposition of
property.
- 4 -
B. DISTRIBUTION OF REAL ESTATE:
The parties agree that they presently own a residence located at 2
Accent Circle, Camp Hill, Cumberland County, Pennsylvania, and both parties agree that
they believe it is in Katherine's best interests if she is afforded an opportunity to continue
to reside in the residence for a period of time. Consequently, the parties agree as follows:
(1) Husband shall, at the time of the execution of this
Agreement, transfer all of his right, title and interest to the marital residence to Wife.
(2) Wife shall have the exclusive use and possession of
the residence until such time as she chooses to no longer reside in the real estate until
Katherine reaches age 22 or graduates from college, whichever shall first occur. At that
time, Wife, at her discretion, may either sell the house or buyout Husband's 45%
interest. In the event that Wife decides to remain in the marital residence, buyout
Husband's interest and obtain a mortgage on the marital residence in order to purchase
Husband's interest, the appraisal done for the purposes of obtaining the mortgage shall
control the value of the house for the purpose of determining Husband's 45% interest. In
the event that Wife decides to purchase Husband's interest but does not choose to
mortgage the residence, then and in that event, the parties shall mutually agree upon an
appraiser to set the fair market value for the purposes of determining Husband's 45%
interest.
(3) At the time of sale, the parties shall divide the net
proceeds 55% by Wife and 45% by Husband. Net proceeds shall be defined as the
balance remaining of the sale price, less any capital gains or tax consequences incident
to the sale of the residence, any liens or mortgages on the residence agreed to by the
parties, taxes, realtor's commissions and costs incident to sale. Wife cannot further lien
or encumber the property without the consent of Husband in writing.
(4) While Wife resides at the marital residence, the parties
shall share the costs of major maintenance and repairs to the residence equally between
them. It is the intent of the parties that in addition to major maintenance and repairs, they
shall also share real estate taxes, homeowner's insurance and repairs required by Camp
Hill Borough. Major maintenance shall be defined as including, but not limited to, repair
and replacement of the heating and cooling system, necessary plumbing, electrical and
roofing repairs and all repairs, but shall not include interior painting and general interior
face lifting.
(5) In the event that either party dies prior to the sale of
the marital residence, the deceased party's interest in the marital residence shall pass to
the parties' daughter, Katherine.
- 5 -
In the event that there are any tax consequences suffered by Wife
as a result of the sale of the residence, the parties shall share said tax consequences
equally.
C. TAX LIABILITY:
The parties believe and agree that the division of property heretofore
made by this Agreement is a non-taxable division of property between co-owners rather
than a taxable sale or exchange of such property. Each party promises not to take any
position with respect to the adjusted basis of the property assigned to him or her or with
respect to any other issue which is inconsistent with the position set forth in the preceding
sentence on his or her Federal or State income tax returns.
D. INVESTMENTS:
The parties acquired during their marriage, either individually or
jointly, shares of Boston Scientific stock. A portion of the stocks have been liquidated to
satisfy two Jefferson Pilot Financial Life Insurance Company loans and the mortgage on
the marital residence. The balance of these stocks has been divided between the parties
with Wife receiving 55% of the remaining shares and Husband receiving 45% of
remaining shares. Husband and Wife shall from the time of the signing of this Agreement
forward be deemed to be in possession of and the owners of the stocks which have been
transferred to their individual name and each waives all right, title and interest to the
other's shares of stock.
E. BANK ACCOUNTS:
Any bank accounts held by the parties individually or joint accounts
owned by the parties used solely by one party, shall remain the sole and separate
property of the party in the possession of the bank records.
F. IRAsfPENSION AND RETIREMENT BENEFITS:
During the marriage, the parties have contributed to IRAs which are
currently with Matrix Asset Allocation (Schwab) and Salomon, Smith Barney. The
Salomon, Smith Barney IRA is a rollover from Husband's Vanguard 401(k) from a prior
employer. The parties agree that all of the retirement assets referred to above will be
divided fifty-five (55%) percent to Wife and forty-five (45%) percent to Husband. Husband
and Wife have created an IRA account in Wife's name with Salomon, Smith Barney
- 6 -
which has not yet been funded. Husband will roll over from his IRA at Salomon, Smith
Barney an amount to Wife's Salomon, Smith Barney IRA which will complete the
55%/45% distribution of the retirement assets. The parties will cooperate fully in
accomplishing this rollover within thirty (30) days of the date of this Agreement. It is the
clear intent of the parties that the exchange of monies under this paragraph will have no
tax consequence.
G. JEFFERSON PILOT FINANCIAL LIFE INSURANCE
COMPANY:
The parties have agreed that the cash surrender values on the
Jefferson Pilot Financial Life Insurance Company policies shall be used for Katherine's
educational expenses. Should the funds not be needed for her educational purposes, the
cash surrender values of the policies shall be divided between the parties with Wife
receiving fifty-five (55%) percent of said cash surrender values and Husband receiving
forty-five (45%) percent of cash surrender values.
If the cash surrender value is utilized for Katherine's advanced
education, any tax consequences of the cash surrender of the above-referenced policy
shall be paid from the actual cash surrender value.
'~
H. MATRIX ASSET ACCOUNTS:
The parties acknowledge and agree that during the marriage, a
Matrix Asset Allocation account No. 17878959 was established. This fund shall be
utilized for the purposes of satisfying Katherine's advanced education expenses.
I. HOUSEHOLD GOODS AND FURNISHINGS:
The parties agree that household goods and furnishings shall remain
in the marital residence for Katherine's use and shall be divided between the parties as
they mutually agree.
8. MOTOR VEHICLES:
With respect to the motor vehicles owned by one or both of the
parties, they agree as follows:
- 7 -
(a) the 2004 Volvo S80 shall become the sole and
exclusive property of Wife free and clear of all liens and encumbrances;
(b) the 2001 Lexus LS430 shall become the sole and
exclusive property of Husband free and clear of all liens and encumbrances; and
(c) the titles to the said motor vehicles shall be executed
by the parties, if appropriate for effecting transfer as herein provided, on the date of
execution of this Agreement and the said executed title shall be delivered to the proper
parties on the distribution date.
9. LIFE INSURANCE:
Husband agrees to continue to maintain in full force and effect the
present two (2) insurance policies on his life issued by Jefferson Pilot Financial Life
Insurance Company having a combined face value of $800,000. As noted in this
Agreement, the existing loans on Husband's insurance policies shall be paid in full
through the liquidation of Boston Scientific stock. Husband shall make Wife the owner of
said insurance policy and same shall be subject to the following conditions:
(a) Except as specifically provided herein, he shall
maintain the insurance in full force and effect, paying all premiums due thereon and shall
not borrow against, assign, pledge, or otherwise encumber the insurance, nor surrender it
to obtain its cash value;
(b) He shall immediately designate Maureen S. Brandt, his
wife, as irrevocable beneficiary of insurance in the face amount of $500,000 until his
alimony obligation ends and until all of his obligations under this Agreement are fulfilled
and also designate Katherine Brandt, the parties' daughter, as irrevocable beneficiary of
insurance in the face amount of $300,000 until the earlier of Katherine's graduation from
college or reaching the age of 23 years; and
(c) Within thirty (30) days after the execution of this
Agreement, Husband shall deliver to Wife or his attorney satisfactory proof that said
irrevocable beneficiary designations have been properly endorsed on each insurance
policy and that the insurer has received notice of restrictions placed upon the ownership
of the insurance by the terms of this Agreement. Husband shall also request that
duplicate premium statements and receipts be mailed by the insurer to Wife.
- 8 -
10. CUSTODY AND SUPPORT:
The parties agree that they will share legal custody of their minor
daughter, Katherine, with Wife having primary custody subject to Husband's partial
custody rights to be mutually agreed upon. Husband agrees to pay to Wife the sum of
$1,500 per month for the support of their daughter and further to continue to maintain
medical insurance as provided by Husband's employer on the said child. The support
payments of $1,500 per month are based upon Husband having an annual income of
$175,000. To the extent that Husband shall earn more than $175,000 annually, he shall
provide Wife with 15.5% of any net income over a gross income of $175,000 per year.
To the extent that those amounts over the $175,000 are paid to Husband as a result of a
bonus, Wife shall receive her 15.5% within ten (10) days of Husband's receipt of the
bonus.
Husband shall pay child support directly to Wife in the sum of $1,500
per month (or increased amount as noted above) commencing on the first day of the first
month following the signing of this Agreement. Payments shall thereafter be paid on or
before the first day of each month.
The parties herein acknowledge that support is modifiable pursuant
to the Pennsylvania Family Support Guidelines, and that Wife may petition the Court of
Common Pleas of Cumberland County, or any other court having appropriate jurisdiction,
to establish a court order of support pursuant to such guidelines.
11. ALIMONY:
Husband agrees to pay Wife the sum of $2,500.00 per month for the
support and maintenance of Wife. Such obligation for support to Wife shall commence
with the first day of the first month after the signing of this Agreement and continue for a
five (5) year period.
Beginning with the first day of the first month after the expiration of
the five (5) year period, Husband shall pay Wife the sum of $2,200.00 per month and
continue until Wife dies, remarries or enters into cohabitation with an adult individual who
is not a member of the Wife's immediate family within the degrees of consanguinity
subsequent to the signing of this Agreement. The alimony payments may be modified
based upon proof of an involuntary substantial change of Husband's economic
circumstances. Husband further agrees to provide medical and hospitalization coverage
for Wife until the entry of a final Decree in Divorce between the parties.
Wife acknowledges and agrees that the provisions of this Agreement
providing for the payment of alimony to her by her Husband are fair, adequate, and
- 9 -
satisfactory to her and are based upon her actual need, her Husband's ability to pay, the
duration of the parties' marriage and other relevant factors which have been taken into
consideration by the parties. Although the approval of this Agreement by a court of
competent jurisdiction in connection with an action in divorce or annulment filed by
Husband or Wife shall be deemed an order of the court and may be enforced as provided
in 23 Pa.C.SA Section 3701, as amended, this Agreement, insofar as it pertains only to
support for Wife or Husband and the payment of alimony following the entry of a final
Decree in Divorce between the parties, may not be modified, suspended, terminated, or
reinstated at the instance or request of the Wife or Husband, or subject to further order of
any court upon changed circumstances of the Wife or Husband of a substantial or
continuing nature, or for any reason claimed by Wife or Husband whatsoever. Upon that
condition, Wife hereby accepts the provisions of this Agreement in lieu of and in full and
final settlement and satisfaction of all claims and demands that she may now or hereafter
have against Husband for her support and maintenance of herself and for alimony.
Except as specifically provided herein, Husband and Wife further voluntarily and
intelligently waive and relinquish any right to seek a modification, suspension, termination,
reinstitution, or other court order with respect to the terms of this Agreement pertaining to
the payment of support to Wife or to Husband or the payment of alimony by Husband or
the payment of alimony by Wife.
12. ALIMONY PENDENTE LITE. COUNSEL FEES. AND EXPENSES:
Husband and Wife acknowledge and agree that the provisions of this
Agreement providing for the equitable distribution of marital property of the parties are
fair, adequate and satisfactory to them. Both parties agree to accept the provisions set
forth in this Agreement in lieu of and in full and final settlement and satisfaction of all
claims and demands that either may now or hereafter have against the other for alimony
pendente lite, counsel fees or expenses or any other provision for their support and
maintenance before, during and after the commencement of any proceedings for divorce
or annulment between the parties.
13. INCOME TAX PRIOR RETURNS:
The parties have heretofore filed joint federal and state tax returns.
Both parties agree that in the event any deficiency in federal, state or local income tax is
proposed, or any assessment of any such tax is made against either of them, each will
indemnify and hold harmless the other from and against any loss or liability for any such
tax deficiency or assessment and any interest, penalty and expense incurred in
connection therewith. Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who is finally determined to be the cause of the
- 10 -
misrepresentations or failures to disclose the nature and extent of his or her separate
income on the aforesaid joint returns.
14. WAIVERS OF CLAIMS AGAINST ESTATES:
Except as herein otherwise provided, each party may dispose of his
or her property in any way, and each party hereby waives and relinquishes any and all
rights he or she may now have or hereafter acquire, under the present or future laws of
any jurisdiction, to share in the property or the estate of the other as a result of the marital
relationship, including without limitation, dower, curtesy, 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. 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.
15. MUTUAL CONSENT DIVORCE:
The parties agree and acknowledge that their marriage is
irretrievably broken, that they do not desire marital counseling, and that they both consent
to the entry of a decree in divorce pursuant to 23 Pa.C.SA Section 3301 (c).
Accordingly, both parties agree to execute such consents, affidavits, or other documents
and to direct their respective attorneys to file such consents, affidavits, or other
documents as may be necessary to proceed to obtain a divorce pursuant to said 23
Pa.C.SA Section 3301 (c) immediately after January 1, 2005. Upon request, to the
extent permitted by law and the applicable Rules of Civil Procedure, the named defendant
in such divorce action shall execute any waivers of notice or other waivers necessary to
expedite such divorce.
It is the intention of the parties that the Agreement shall survive any
action for divorce which may be instituted or prosecuted by either party and no order,
judgment or decree of divorce, temporary, final or permanent, shall affect or modify the
financial terms of this Agreement. This Agreement shall be incorporated in but shall not
merge into any such judgment or decree of final divorce, but shall be incorporated for the
purposes of enforcement only.
- 11 -
16. EFFECT OF RECONCILIATION OR COHABITATION:
This Agreement shall remain in full force and effect and shall not be
abrogated even if the parties effect reconciliation, cohabit as husband and wife or attempt
to effect reconciliation.
17. BREACH AND ENFORCEMENT:
If either party breaches any provision of this Agreement, the other
party shall have the right, at his or her election, to sue for damages for such breach, or
seek such other remedies or relief as may be available to him or her, and the party
breaching this Agreement shall be responsible for payment of legal fees and costs
incurred by the other in enforcing his or her rights under this Agreement.
18. THIRD PARTY BENEFICIARIES:
Husband and Wife agree that it is not their intention in this
Agreement that any other individuals, including their minor child, be third party
beneficiaries of this Agreement at this time or at any time in the future.
19. ADDITIONAL INSTRUMENTS:
Each of the parties shall from time to time, at the request of the
other, execute, acknowledge and deliver to the other party any and all further instruments
that may be reasonably required to give full force and effect to the provisions of this
Agreement.
20. TAX ADVICE:
Both parties hereto hereby acknowledge and agree that they have
had the opportunity to retain their own accountants, certified public accountants, tax
advisor, or tax attorney with reference to the tax implications of this Agreement. Further,
neither party has been given any tax advice whatsoever by their respective attorneys.
Further both parties hereby acknowledge that they have been advised, by their respective
attorneys, to seek their own independent tax advice by retaining an accountant, certified
public accountant, tax attorney, or tax advisor with reference to the tax implications
involved in this Agreement. Further, the parties acknowledge and agree that their
signatures to this Agreement serve as their acknowledgment that they have read this
particular paragraph and have had the opportunity to seek independent tax advice.
- 12 -
21. VOLUNTARY EXECUTION:
The provisions of this Agreement and their legal effect have been
fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, that it is being entered into voluntarily, with full
knowledge of the assets of both parties, and that it is not the result of any duress or
undue influence. The parties acknowledge that they have been furnished with all
information relating to the financial affairs of the other which has been requested by each
of them or by their respective counsel.
22. ENTIRE AGREEMENT:
This Agreement contains the entire understanding of the parties and
there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein. Husband and Wife acknowledge and agree that the provisions
of this Agreement with respect to the distribution and division of marital and separate
property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the parties. Both
parties hereby accept the provisions of this Agreement with respect to the division of
property in lieu of and in full and final settlement and satisfaction of all claims and
demands that they may now have or hereafter have against the other for equitable
distribution of their property by any court of competent jurisdiction pursuant to 23
Pa.C.S.A. Section 3501 et. sea. or any other laws. Husband and Wife each voluntarily
and intelligently waive and relinquish any right to seek a court ordered determination and
distribution of marital property, but nothing herein contained shall constitute a waiver by
either party of any rights to seek the relief of any court for the purpose of enforcing the
provisions of this Agreement.
23. DISCLOSURE:
The parties confirm that they have relied on the completeness and
substantial accuracy of the financial disclosure of the other as an inducement to the
execution of this Agreement. The parties acknowledge that there has been no formal
discovery conducted in their pending divorce action and that neither party has filed an
inventory and appraisement as required by Section 3505(b) of the Pennsylvania Divorce
Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for
equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owned
by the other party in an asset of any nature at any time prior to the date of execution of
this Agreement that was not disclosed to the other party or his or her counsel prior to the
date of the within Agreement is expressly reserved. In the event that either party, at any
- 13 -
time hereafter, discovers such an undisclosed asset, the party shall have the right to
petition the Court of Common Pleas of Cumberland County to make equitable distribution
of said asset.
The non-disclosing party shall be responsible for payment of counsel
fees, costs or expenses incurred by the other party in seeking equitable distribution of
said asset.
Notwithstanding the foregoing, the Agreement shall in all other
respects remain in full force and effect.
24. MODIFICATION AND WAIVER:
A modification or waiver of any of the provisions of this Agreement
shall be effective only if made in writing and executed with the same formality as this
Agreement. The failure of either party to insist upon strict performance of any of the
provisions of this Agreement shall not be construed as a waiver of any subsequent
default of the same or similar nature.
25. PRIOR AGREEMENT:
It is understood and agreed that any and all property settlement
agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
26. DESCRIPTIVE HEADINGS:
The descriptive headings used herein are for convenience only.
They shall have no effect whatsoever in determining the rights or obligations of the
parties.
27. APPLICABLE LAW:
This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
- 14 -
28. AGREEMENT BINDING ON HEIRS:
This Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors, administrators, successors, and
assigns.
29. CONSTRUCTION:
No provisions of this Agreement shall be interpreted for or against
any party because that party or that party's representative drafted this Agreement in
whole or in part.
IN WITNESS WHEREOF, the parties hereto have set their Hands and
Seals the day and year first above written.
/"'~/~
Step~r;ndt (SEAL)
I
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(SEAL)
- 15 -
COMMONWEAL TH OF PENNSYLVANIA
COUNTY OF fft..{J..upIUjj<-/
On this, the (~5M day of /.,IJ))U/);~ , 2004, before
me, a Notary Public, the undersigned officer, personally appeared Stephen P. Brandt,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the
foregoing Property Settlement Agreement and acknowledged that he executed the same
for the purposes therein contained.
)
(
)
SS:
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
J~'
~)~ . MUJ>
N ry Public
COMMONWEALTH OF PEi'i%YLVANIA
Notarial Seal
Jean L Kosier, Notary Public
Derry Twp.. Dauphin County
My Commission Expires Mar. 3, 2008
Member. pennsylvarua ASSQC\3tlo!1 of Notanes
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Da+'h,(I.
.
. ~ II h
On this, the J, r day of /V~/lpI;'JA ,2004, before
me, a Notary Public, the undersigned officer, personally appeared Maureen S. Brandt,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the
foregoing Property Settlement Agreement and acknowledged that she executed the same
for the purposes therein contained.
)
(
)
SS:
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
tfONW.lfAI.
GlOIIlo\ M. IllNE
NoIarv NlIc
CIlY OF ~, IWlI'IlN COUNIY
My ColnmIalon ExJlIrw Nov 5. 2007
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Notary Public
57195.1
v.
:IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2529 CIVIL TERM /991>
STEPHEN P. BRANDT,
Plaintiff
MAUREEN S. BRANDT,
Defendant
:CIVIL ACTION - LAW
:IN DIVORCE
PROOF OF SERVICE
I, Paige Macdonald-Matthes, Esquire, do hereby certify
that a true and correct copy of the Complaint in Divorce in
the above captioned matter was served on Defendant, Maureen S.
Brandt, by First Class, certified Delivery Mail, postage
prepaid, on May 6, 1998. The receipt card is attached hereto.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: May 8, 1998
By: ,~~~~~-~
P ge Macdonald-Matthes, Esquire
1.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
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STEPHEN P. BRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 98-2529
: CIVIL ACTION - LAW
1-..)
;:~1
MAUREEN S. BRANDT,
Defendant
: IN DIVORCE
r'
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on May 4, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce.
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.
5. I verify that the statements made in this affidavit are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~4904 relating to unsworn falsification to authorities.
Date: 11/29/04
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-2529
: CIVIL ACTION - LAW
STEPHEN P. BRANDT,
Plaintiff
MAUREEN S. BRANDT,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is
entered by the Court and that a copy of the decree will be sent to me immediately after it is
filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Date: 11/29/04
73050.1
STEPHEN P. BRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 2529 ci;2 / '11( <1
MAUREEN S. BRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
TO STEPHEN P. BRANDT:
You are hereby notified to plead to the enclosed Answer ad Counterclaim within twenty
(20) days from service thereof or judgment by default may be entered against you.
STEPHEN P. BRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 2529
MAUREEN S. BRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE
AND NOW, comes the Defendant, Maureen S. Brandt, by and through her attorney,
Joseph J. Dixon, Esquire, and files this Answer and Counterclaim to the Complaint in Divorce in
the above-captioned matter as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. (a) Admitted.
(b) Denied. The Defendant denies that she has offered such indignities to the
person of the Plaintiff, as to render his condition intolerable and life burdensome, and further
denies that he the innocent and injured spouse. To the contrary, it is averred that the Defendant
is the innocent and injured spouse and the Plaintiff has rendered her condition intolerable and
life burdensome.
9. Admitted.
10. Admitted in part and denied in part. After reasonable investigation, the
Defendant is unable to ascertain what the Plaintiff has been advised concerning the availability
of marriage counseling. It is admitted however, that the Defendant has the right to require the
parties to participate in marriage counseling.
WHEREFORE, the Defendant prays your Honorable Court to enter a Decree in
Divorce from the bonds of matrimony.
COUNT II
9. No response required.
10. Admitted.
COUNTERCLAIM
COUNT III
CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE
II. The Defendant has no adequate means of support for herself except as
provided by the Plaintiff.
12. The Plaintiff has substantial income to provide for the Defendant who is a
full-time homemaker and custodial parent ofthe parties' minor child.
2
COUNT IV
CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES UNDER
SECTION 3702 OF THE DIVORCE CODE
13. The Defendant does not have sufficient funds to support herself or
pay counsel fees and expenses incidental to this action.
14. The Plaintiff is full well and able to pay Defendant Alimony, Alimony
Pendente Lite, counsel fees and expenses incidental to this divorce action.
WHEREFORE, Petitioner prays this Honorable Court to:
a. Enter a Decree in Divorce.
b. Direct the Plaintiff to pay Alimony Pendente Lite, counsel fees and costs
to the Defendant.
c. Direct the Plaintiff to pay Alimony.
d. Order a fair and equitable distribution of martial property.
Respectfully submitted,
By:
Jos h J. Dixon, Esquire
Attorney No. 28290
126 State Street
Harrisburg, P A 17101
(717) 236-8515
Date: rt-~ / q?,
Attorney for Defendant
3
'.
VERIFICATION
I verify that the statements made in this Answer nnn
G<?untpr"'1~;m
are true and correct.
I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
S4904, relating to unsworn falsification to authorities.
DATED: 1/3;jqf
~hlU~u1l"
Ma een s. Bandt
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing
document by depositing the same in the United States mail, First
Class, postage prepaid, at the following address (es) :
Paige Macdonald-Matthes, Esquire
CUNNINGHAM & CHERNICOFF, P.C.
2320 North Second Street
P.O. Box 1855
Harrisburg, PA 17105-1855
Date:
7/3/ I q f
I I
By
~
/ Jos h J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Attorney for Defendant
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-
STEPHEN P. BRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 98-2529 CIVIL
MAUREEN S. BRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance as counsel for the Plaintiff, Stephen P. Brandt, in the
above-captioned action.
Date: ,1i(l\-. ~, wVl
BY:~~.l.\..''''''~~'~ .
Paige Macdonald Matthes, Esquire
2 North Second Street
Harrisburg, P A 17101
(717) 238-7675
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of John J. Connelly, Jr., Esquire on behalf of the Plaintiff,
Stephen P. Brandt, in the above-captioned action.
Date:
u
',".
STEPHEN P. BRANDT,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-2529
: CIVIL ACTION - LAW
MAUREEN S. BRANDT,
Defendant
: IN DIVORCE
PRAECIPE
PROTHONOTARY:
Please withdraw the appearance of Joseph J. Dixon, Esquire, as counsel for the
Defendant in the above matter.
Dated:
r /)}Jf!
~/7~~
J s h J. Dixon, Esquire
6 State Street
Harrisburg, PA 17101
(717) 236-8515
Please enter the appearance of Sandra L. Meilton, Esquire, as counsel for the
Defendant in the above matter.
Dated: #,
:J4~~ ~~LtiH<-/
~andra L. Meilton (No. 2551)
TUCKER ARENS BERG & SWARTZ
111 N. Front Street, P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
43481.1
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(;')
STEPHEN P. BRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
MAUREEN S. BRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
98-2529 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of October, 2001, in the case
of Brandt versus Brandt at No. 98-2529 Civil Term, and an
objection to dismissal having been filed by the Defendant, and no
appearance having been made at this time by the Plaintiff in
opposition to that action, the case is stricken from the purge
list and shall remain active.
By the Court,
011
Jr., J.
John J. Connelly,
P.O. Box 650.
Hershey, PA 17033
For the plaintiff
Jr. ,
ESqUire,r~~
JI.o'21,.OJ V
P-.'f\ 5
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Sandra L. Meilton, Esquire
III N. Front St.
Harrisburg, PA 17108-0889
For the Defendant
pcb
J
III The Court of Common Pleas of
Cumberland County, Pennsylvania
File No.
1998-02529
BRANDT STEPHEN P
vs
BRANDT MAUREEN S
STATEMENT OF INTENTION TO PROCEED
To the Court:
Maureen S. Brandt
intends to proceed with the above captioned matter.
Date:
9/13/04
A'!:'~~
Maureen ~. Brandt
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111 The Court of Common Pleas of
Cumberland County, Pennsylvania
FileNo.
1998-02529
BRANDT STEPHEN P
vs
BRANDT MAUREEN S
STATEMENT OF INTENTION TO PROCEED
To the Court:
Stephen P. Brandt
intends to proceed with the above captioned matter.
Date: 9/16/04
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STEPHEN P. BRANDT,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 98 - 2529
MAUREEN S. BRANDT,
DEFENDANT
: CNIL ACTION - LAW
: IN DNORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a
Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section (XX) 3301 (c) ()
330l(d) of the Divorce Code.
2. Date and manner of service of the Complaint: May 6, 1998 by certified mail no.
Z360840736.
3. Complete either paragraph (a) or (b).
(a) Date of execution ofthe Affidavit of Consent and Waiver of Counseling
required by Section 3301( c) of the Divorce Code: by Plaintiff: December 23, 2004; Defendant:
November 29, 2004.
(b) (1) Date of execution of the Plaintiffs Affidavit required by Section 330l(d) of
the Divorce Code:
(2) Date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: All claims of record have been settled pursuant to a Property
Settlement Agreement dated November 29,2004.
5. Date and manner of service of Notice of Intention to file Praecipe to
Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d)
of the Divorce Code:
or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree
under Section 330 I (c) of the Divorce Code: by Plaintiff: December 23, 2004; by Defendant:
November 29,2004.
and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce
Decree: Both the Plaintiffs and Defendant's Waivers were filed on December 27,2004.
JAMES, SMITH, DIETTERRIC
,..---
Date:
/ - /'-1 -oS
,
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-
.
.
.
'" :Ii:+: ;!i:f.:f.:f.;t;
..
.
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
.
STEPHEN P. BRANDT
.
.
No.
98 - 2529
.
Plaintiff
.
.
VERSUS
MAUREEN S. BRANDT
.
.
Defendant
.
DECREE IN
DIVORCE
.
.
.
.
F"L,. I
_, 7..ot>5, IT IS ORDERED AND
.
AND NOW,
DECREED THAT
Stephen P. Brandt
, PLAINTIFF,
.
.
AND
Maureeen S. Brandt
, 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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The attached Property Settlement Aqreement dated November 29,
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2004 is hereby incorporated, but not merged, into this Decree in
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BY THE COURT:
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PROTHONOTARY
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'f.:f. ;+':f.:f.
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