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HomeMy WebLinkAbout00-05183 . > ~v ~,;,. .' . . . . . " " .. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . STATE OF KATHERINE T. REMIG, . . NO. Plaintiff VERSUS BRADLEY E. REMIG, . Defendant . DECREE IN DIVORCE . ~~~7 AND NOW, . DECREED THAT KATHERINE T. REMIG AND BRADLEY E. REMIG ARE DIVORCED FROM THE BONDS OF MATRIMONY. . PENNA. )000-<;1 Ri rTVTT TFRM ~~: ;)~~P1. 2001 , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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. It is further ORDERED, ADJUDGED and DECREED that the terms, provisions and conditions of a certain Marital Settlement Agreement between the parties dated October 31, 2001, and attached hereto, are incorporated in this Decree in Divorce by reference as fully as If the same were set forth herein at length. Said Agreement shall no e with but shall survive this Decree' 'v ;Ii;li'" :Ii . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . t~ l ' ~':__w .., _~_'oo'd " ~. - > ~. ~.. ~~. i "' ,..,;, ,. ."'otlo , " //~2f~( M-~~ ~4~ /r-dl'9'z:J/ ~~ ~ IF 4' ~""'-L , , , .~c ~ ,~ ,~ _""I'm ~.. ~ ~ ~,~~ ,~9J. ~^ ~ w" .,,~~,1!_ i~ '..ill " " I,J.., .-._, " ~ r > ~ . . MARITAL SETTLEMENT AGREEMENT BY AND BETWEEN BRADLEY E. REMIG AND KATHERINE T. REMIG Donald T. Kissinger, Esquire HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, P A 17108 Telephone: (717) 234-2616 Counsel for Bradley E. Remig Keirsten W. Davidson, Esquire JOHNSON DUFFIE STEWART & WEIDNER 301 Market Street P.O. Box 109 Lemoyne, P A 17043-0109 Telephone: (717) 761-4540 Counsel for Katherine T. ReInig < -. - . , MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this 31 J~ay of Dc.. +D~fr ,2001, by and between BRADLEY E. REMIG, of Cumberland County, Pennsylvania, and KATHERINE T. REMIG, of Cumberland County, Pennsylvania; WITNESSETH: WHEREAS, Bradley E. Remig (hereinafter referred to as "Husband"), social security number 074-44-8487, was born on January 10, 1968, and currently resides at 1517-F High Pointe Drive, Harrisburg, Dauphin County, Pennsylvania 17110; WHEREAS, Katherine T. Remig (hereinafter referred to as "Wife"), social security number 171-42-9193, was born on July 7,1966, and currently resides at 955 South 29th Street, Camp Hill, Cumberland County, Pennsylvania 17011; WHEREAS, the parties hereto are husband and wife, having been lawfully married on May 20,1995 in York, Pennsylvania; WHEREAS, the parties have lived separate and apart since on or about March 18,2000; WHEREAS, one child was born of the marriage between the parties, namely Kyle B. Remig, born March 17,1997; WHEREAS, the parties hereto are desirous of settling fully and finally their respective [mancial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. 1 ( ), , L . NOW, THEREFORE, in consideration of these premises, and ofthe mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel of his or her selection (Donald T. Kissinger, Esquire for Husband and Keirsten W. Davidson, Esquire for Wife). Each party fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. In addition, each party understands the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleasof Cumberland County, or any other court of competent jurisdiction, make any determination or order affecting the respective parties' rights to alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs oflitigation. 2. DISCLOSURE OF ASSETS. Each ofthe parties hereto acknowledges that he or she is aware of his or her right to seek discovery, including but not limited to, written 2 < ~ ". , 'AA'. 1_ '~ , . . interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories, and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or she has had the opportunity to discuss with counsel the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this commonwealth or any other court of competent jurisdiction. The parties do hereby acknowledge that there has been full and fair disclosure to the other of his or her respective income, assets and liabilities, whether such are held jointly or in the name of one party alone. Each party agrees that any right to further disclosure, valuation, enumeration or statement thereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. Each party warrants that he or she is not aware of any maritalasset which is not identified in this Agreement. The parties hereby acknowledge and agree that the division of assets as set forth in this Agreement is fair, reasonable, equitable, and satisfactory to them. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that there was a denial of any rights to full disclosure, or that there was any fraud, duress, undue influence or that there was a failure to have available full, proper and independent representation by legal counsel. 3. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect, by the other. Each may reside at such place or places as he or she may select. 3 , .' .,',' ,--j ,<' " , -' -~ . ,,--, ,-. >.- -\<-,' .y." d,.iJ--. " N" ~oo_ "' . ,- I~l:l, , .. , Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any mauner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the dissolution of their marriage and thus any divorce action with respect to these parties shall be limited to a claim for no-fault divorce only. The parties acknowledge that Wife filed a Complaint for Divorce in Cumberland County premised upon 93301 of the Divorce Code on or about July 19,2000. Contemporaneously with the execution of this Agreement, or no later than ten (10) days thereafter, each party agrees to execute an Affidavit of Consent to the Entry ofa Divorce Decree and a Waiver of Notice of Intention to Request Entry of Divorce Decree. Thereafter, Husband shall take all other necessary steps, and file all appropriate documents, to obtain a no-fault divorce based upon 93301(c) of the Divorce Code before December 31, 2001. 5. EOUlTABLE DISTRIBUTION. (a) Marital Residence. The parties acknowledge that on August 21, 2000, they sold that certain house and lot and all improvements thereupon situated at 30 Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania (hereinafter referred to as the "Marital Residence"). The parties agree that the proceeds from the sale were distributed between the parties with Wife receiving Ten Thousand Dollars ($10,000) therefrom and Husband receiving the remainder, approximately Six Thousand Five Hundred Dollars ($6,500). 4 ~' "-- -" "~-- , .. '" " '"",,"-;-.;;, ,,', .~,.~ ,-, >'.', " ,-" ',ODe,,, .. . (b) Furnishinl!:s and Personalty. (1) The parties agree that they have divided by agreement between themselves all furnishings and personalty accumulated during the marriage, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment. (2) Except as otherwise set forth herein, Husband shall retain, as his sole and separate property, free of any and all right, title, claim or interest of Wife, all of the personalty and furnishings currently in his possession. (3) Except as otherwise set forth herein, Wife shall retain, as her sole and separate property, free of any and all right, title, claim or interest of Husband, all of the personalty and furnishings currently in her possession. (c) Motor Vehicles. (1) Husband agrees that Wife shall retain possession of and receive as her sole and separate property the 1992 Toyota Canrry XLE automobile currently titled in the joint names of the parties, along with all rights under any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon, free of any and all right, title, claim or interest of Husband. Wife shall indemnify and hold Husband and his property harmless from any and all liability, cost or expense, including actual attorney's fees, incurred in connection with any vehicle belonging to Wife by virtue of this subparagraph. (2) Wife agrees that Husband shall retain possession of and receive as his sole and separate property the 1996 Audi A4 automobile, currently titled in the joint names of the parties, along with all rights under any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance 5 ~ I! o~ ''"' "~" " -" --.'.10.'"' ~. . '~";;;i.:. :0 thereon, free of any and all right, title, claim or interest of Wife. Husband shall indemnify and hold Wife and her property harmless from any and all liability, cost or expense, including actual attorney's fees, incurred in connection with any vehicles belonging to Husband by virtue ofthis subparagraph. (3) The parties agree that they will cooperate in effectuating the transfer oftitles and insurance to accomplish the purposes of this subparagraph. (d) Life Insurance. The parties acknowledge and agree that each shall retain as his/her sole and separate property, any and all life insurance policies in his/her name, free of any right, title and interest of the other party. (e) Pension and Retirement Benefits. Except as specifically set forth below, Wife and Husband each hereby specifically releases and waives any and all right, title, claim or interest that he or she may have in and to any and all retirement benefits (including but not limited to pension or profit sharing benefits, deferred compensation plans, 40 1 (k) plans, employee savings and thrift plans, individual retirement accounts or other similar benefits) of the other party, specifically to include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. The parties agree that they shall execute any documents pursuant to the Retirement Equity Act or any similar act that may be required from time to time to accomplish the purposes of this subparagraph. Notwithstanding the above, the parties agree that Wife shall receive the entire amount of Husband's Traditional Individual Retirement Account, the approximate balance of which is Fifteen Thousand Dollars ($15,000) and is comprised of Delaware -Technology and Innovation 6 j}' ~ ," _.', Co _ i . :__'-;.; "< -w_', - f'ii (, ,..., and AIM Weingarten stock. Husband shall take all steps necessary to prepare a Qualified Domestic Relations Order to accomplish the rollover from Husband to Wife. (I) Investments. The parties acknowledge that both before and during the marriage Husband acquired several investments and securities. The parties agree that Wife shall receive a portion of Husband's investments and securities totaling Twenty Thousand Dollars ($20,000), compromised of Five Thousand Dollars ($5,000) each from the following mutual funds of Husband: (1) AIM-Charter; (2) AIM-Value; (3) Putnam-New Opportunity; (4) Oppenheimer-MSIG. The remainder of said investments and securities shall remain Husband's sole and separate ' property. (g) 2001 Tax Retnrns. The parties agree that they will sign and file separate federal, state and local income tax returns for tax year 2001. The parties agree that Wife reserves the right to claim their child as a dependent on the 2001 and future tax returns. (h) Miscellaneous Property. As of the execution date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled; and if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. (i) Pronerty to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of Husband, the property awarded to her by the terms of this 7 , > ,..-' , " . ~.~' .'-, "".'''- ( , '~... Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. G) Assumntion of Encumbrances. (1) Commencing on the execution date of this Agreement, Husband shall be solely responsible for any and all liabilities he has incurred in his name alone, specifically to include any obligations to issuers of credit cards in his name. (2) Commencing on the execution date of this Agreement, Wife shall be solely responsible for any and all liabilities she has incurred in her name alone, specifically to include any obligations to issuers of credit cards in her name. Wife shall immediately delivcr to Husband any and all credit cards in her possession which provide for joint liability, and Husband shall take all necessary steps to close all accounts on which the parties are jointly liable. If Wife has incurred any liabilities on any credit card account or any other account on which Husband is jointly liable, Wife shall be solely responsible for payment of any such liabilities she has incurred and she shall indemnify and hold Husband and his property harmless from any liability, cost or expense associated therewith. (3) Unless otherwise provided herein, each party hereby assumes the debts, encumbrances, taxes and liens on all the property each will hold subsequent to the effective date of this Agreement. Each party agrees to indenmify and hold harmless the other party and his or her property from any claim or liability that the other part will suffer or may be 8 (I ',);. required to pay because of the debts, encumbrances or lines assumed by the other pursuant to this Agreement. (k) Property to Husband. The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. (I) Liability Not Listed. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, on which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter .incur it, and such party agrees to pay it as the same shall become. due,. and to indemnify and hold the other party and his or her property harmless from any and all such debts, obligations and liabilities. (m) Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indenmify her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Wife in connection therewith. 9 < -'.'0' " . """"-~ ., --" -'''0 O. ~'"'... "", ., _'_- _,CO, ." I', /" .1 .ll (n) Indemnification of Husband. If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Husband in connection therewith. (0) Warranty as to Future Oblil!:ations. Husband and Wife each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability, Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever, including actual attorneys fees; incurred in the event of breach hereof. 6. WIFE'S NEW RESIDENCE. The parties acknowledge that Wife used the Ten Thousand Dollars ($10,000) she received from the sale of the Marital Residence to purchase property and that certain house and improvements thereupon situated at 955 South 29th Street, Camp Hill, Cumberland County, PA 17011.. The parties further acknowledge that Husband agreed to place his name on the mortgage in order to allow Wife to get a better interest rate and has paid Twenty Seven Thousand Eight Hundred Twenty Five Dollars ($27,825.00) to Wife for various expenses on the new property. The parties agree that Wife must refinance the mortgage on or before September 1, 2003 so as to remove Husband's name from the mortgage. 10 , -. .~-~" ,~ ;; i,1 ,,', <;0.'. --0'." "^'* ,-_''',J , ~ ~ii' . .. Wife acknowledges that Seven Hundred Three Dollars and Twenty Two Cents ($703.22) of the One Thousand Five Hundred Dollars ($1,500) in alimony that Husband has agreed to pay Wife per month (see Paragraph Seven infra) will be utilized for payment ofthe monthly mortgage obligation. In the event Wife defaults on her mortgage, she must notify Husband of said default. Wife further agrees to indemnify Husband and his property, for any and all liability he may incur on the mortgage in the event of Wife's default. Additionally, all alimony to Wife will immediately terminate upon Wife's default on the mortgage, and Husband will thereafter be responsible only for child support, which shall be determined under the state guidelines. Husband's obligation on the mortgage is further conditioned upon Wife not remarrying or cohabiting with a member of the opposite sex. In the event Wife cohabits or remarries within the time period outlined above, she must immediately refinance the mortgage so as to remove Husband's name from the mortgage. Wife agrees that she will not further encumber the property without the express written consent of Husband while Husband's name is on the mortgage. It is understood by the parties that Husband obtains no ownership interest in the property and has no responsibility for its maintenance. 7. ALIMONY. AND SUPPORT. Commencing February 1,2001, the parties agree that Husband shall pay to Wife the sum of One Thousand Five Hundred ($1,500) cash per month as and for alimony. Said One Thousand Five Hundred Dollar ($1,500) monthly payment shall consist of Seven Hundred Three Dollars and Twenty Two Cents ($703.22) per month paid directly to Wife for payment of her monthly mortgage obligation and Seven Hundred Ninety-Six Dollars and Seventy Eight Cents ($796.78) per month to be used for support purposes. In addition to the above, Husband agrees to pay Wife an additional Two Thousand 11 . '''~~,' '. ". ,," :"".-'--~".. -, ' '" . ,~ , ,-. , --, .. .. Five Hundred Dollars ($2,500) payment on February 1, 2002 and February 1, 2003 as and for alimony. Husband's obligation to provide Wife with alimony shall terminate on September 1, 2003. Husband's alimony obligation shall be non-modifiable in duration or amount, it being understood by the parties that they waive any right to modify the terms of the alimony in a court oflaw or equity. Said alimony payments shall terminate before September 1, 2003 only upon the fust to occur of one of the following: (i) Death of Wife; (ii) Death of Husband; (iii) Wife's remarriage; or (iv) Wife's cohabitation with a member of the opposite sex, other than a member of her family within the degrees of consanguinity set forth in 23 Pa.C.S,A. gg3706 & 1304(a). 8. CHILD SUPPORT. The parties agree that Husband's child support obligation shall be handled through the Cumberland County Domestic Relations Office and calculated pursuant to Pennsylvania Support Law and the Child Support Guidelines promulgated by the Pennsylvania Supreme Court. Wife shall file a petition for child support with the Cumberland County Domestic Relations Office to permit the entry of a child support order. 9. MEDICAL INSURANCE COVERAGE FOR WIFE. The parties acknowledge that Husband is currently providing medical insurance for Wife and the parties' child. Husband agrees to continue to provide Wife with said medical coverage until such time as a Divorce Decree is entered at which time his obligation to provide said coverage shall terminate. 12 .---,' ,''''''>-- .,'<' ';' J' ""'-, "'",; ,.",', >';,,' ~' ,~., -', .. .. Husband's obligation to provide child with medical coverage shall continue until the child reaches the age of eighteen (18). 10. CUSTODY. Husband and Wife agree to the following with respect to custody oftheir child, Kyle B. Remig, born March 17, 1997: (a) Husband and Wife shall share legal custody of Kyle. Legal custody is defined as the right to make major decisions affecting the best interest of the child, including, but not limited to, decisions regarding medical treatment and healthcare, religion, moral, educational and standards of conduct. Mother and Father shall discuss and consult with one another on these decisions with a view of adopting a harmonious policy calculated to promote the child's best interest. Father and Mother shall have the right to be kept informed of the child's educational, social, moral and medical development. Each parent shall be entitled to full and complete records and information concerning the child from any doctor, dentist, teacher and to receive copies of any reports, notices of other communication given to a parent. Each parent shall notify the other of any matter relating to the child which could reasonably be expected of significant concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. The parent having physical custody of the child at the time of any emergency shall have a right to make any inrmediate decisions necessitated thereby, but shall inform the other parent ofthe emergency and consult with him or her as soon as possible. (b) Wife shall have primary physical custody of Kyle with partial custody to Husband as follows: (i) alternating weekends from Friday at 6:00 p.m. until Monday at 9:00 a.m.; 13 '., .~' .. ... (ii) up to two weeknight overnights per week to be agreed upon by the parties; (c) Custody during holidays, unless otherwise indicated, shall be upon agreement of the parties. Notwithstanding, the parties agree as follows: (i) Husband and Wife shall alternate the Thanksgiving and Easter holiday, with Husband having the child on Thanksgiving in 2001 and all odd-numbered years thereafter, and Wife having the child on Easter in 2001 and all odd-numbered years thereafter. In all even-numbered years, Wife shall have the child on Thanksgiving and Husband shall have the child on Easter. The Thanksgiving and Easter holiday shall run from 10:00 a.m. until 7:00 p.m. of the day of the holiday and shall take precedence over the regular schedule; (ii) for Christmas 2001, and all odd-numbered years thereafter, Wife will have the child from December 24tl1 (Christmas Eve) at 12:00 noon until December 25tl1 (Christmas Day) at 12:00 noon and Husband will have the child from December 25tl1 at 12:00 noon until December 26th at 12:00 noon. For Christmas 2002, and all even-numbered years thereafter, Husband shall have the child from December 24tl1 at 12:00 noon until December 25tl1at 12:00 noon and Wife shall have the child from December 25tl1 at 12:00 noon until December 26th at 12:00 noon. The Christmas holiday schedule shall take precedence over the regular schedule. 11. COUNSEL FEES. COSTS AND EXPENSES. Each party shall be solely responsible for his or her own legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their marriage, and the preparation and execution of this Agreement. 12. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as ofthe execution date ofthis Agreement, Husband and Wife each 14 - '''" ,-' ,-J w-,-'" """-' ~~ ~'~, -;i",-_r.~.",t,:o _;-i;!,'.__""i."~-~;.: ~ > . ,_,' " i",-;c:,i,j .. .. waives all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason oftheir marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 13. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay checks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. 14. RELEASE OF CLAIMS. (a) Wife and Husband acknowledge and agree that the property dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to 93502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. Furthermore, except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, 15 ',. '.,' ,-,-/' "'-,<, "-'-,."-,- ..,"' . ~;"""" 'i.' ,.",; ,;.;",;:,j~ '.'~d_-' ;'~"-~l'-L~,;~...;,__'''' ",,'->,_--' \i " .. releases, renounces and forever abandons any claim, right, title or interest whatsoever he or she may have in property transferred to the other party pursuant to this Agreement or identified in this Agreement as belonging to the other party, and each party agrees never to assert any claim to said property or proceeds in the future. However, neither party is released or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her from the execution date ofthis Agreement with full power in him or her to dispose ofthe same fully and effectively for all purposes. (b) Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either party may have or at any time hereafter has for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. Neither party shall have any obligation to the other not expressly set forth herein. (c) Except as set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now 16 "~-- ,-' '," >'-,""" . . ~-,,"'.-- >',-,-, ',,;;~.;, '~"" . ',".' " '-',: t, "", ,',,' ";',"'~_''''''''' .---"'_'-"'4;, .. ... existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory ofthe United States, or any other country. (d) Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 15. PRESERVATION OF RECORDS. Each party will keep and preserve for a period offour (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 16. MODIFICATION. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 17. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 17 - ~- ,~=" '~r n "",:',~""",,: ";;"f:"_~- ".e_, . -,_' "'_',- "',-{'; ",--- " ~-"h--"" '!'"~'"""; .... 18. BREACH. If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement ofthe rights of the non-breaching party. 19. W AlVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other breach or any provision of this Agreement. 20. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or certified mail, return receipt requested. Notice to Husband will be sufficient if made or addressed to the following: Bradley E. Remig 1517-F High Pointe Drive Harrisburg, Pennsylvania 17110 and to Wife, if made or addressed to the following: Katherine T. Remig 955 South 29th Street Camp Hill, P A 17011 Notice shall be deemed to have occurred upon the date received by the recipient. Each party may change the address for notice to him or her by giving notice of that change in accordance with the provisions of this paragraph. 21. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to the conflict oflaw rules applicable in Pennsylvania) in effect as of the date of execution of this Agreement. 18 ,=,---",-,,,". ---'.'-'-" _',", ~~ ',,~ "., . c,. ,--"'C'. . 0: ':^~'.' _"-"" ,':'. ',__ ,; ,._:",.., .'-, " .'00,_"" ,;.:,,'_,__ - .,y, ~, " .. , , 22. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. 23. EFFECTIVE DATE. This Agreement shall become effective and binding upon both parties on the execution date. 24. EFFECT OF RECONCILIATION. COHABITATION OR DIVORCE. This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term ofthis Agreement to be null and void. 25. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 26. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal i representatives, assigns, and successors in any interest of the parties. 27. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully read this Agreement; that he or she has discussed its provisions with an attorney of his or her own choice, and has executed it voluntarily and in reliance upon his or her own attorney; 19 ,.,-,;0-' " ... and that this instrument expresses the entire agreement between the parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 28. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorney's fees, costs, and other expenses actually incurred as a result of such failure. 29. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. 20 ',",' ~,>, " O~,~ . .., .. " . '" ~".- ,- -,~-,____~-",_~,~ '''.''',00' '__"_,,,,_'-',," ';,~,i ,_<, .-c_",,~'~,- ."J--""'''~''-,..."' -'S_"j ,,''.. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. C~/1lc;JhdW WITNESS . .1' , .~~ :J, (3v4 t: -Lt-r WIT. SS 21 '.,.,' , ,,,.'-,,,-~,,~ . '" .", ,,', " ~c -"'~ ~-, ", ";-''','_:;-),. :,., ;'"__""~',',"7,:',,-':..~,'__ __, -_C'.O";,, ,'~",--,,;, ,'>, . _~:i.i~',',__" .. If' .. .. , COMMONWEALTHOFPENNSYLVANlA i COUNTY OF t!-d-Nl,~ ) ) ) BEFORE ME, the undersigned authority, on this day personally appeared BRADLEY E. REMIG known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this .3 (-1' ~ay of @Vf ,2001. t~cL ( Not Public in and for Commonwealth of Pennsylvania Typed or printed name of Not IJ' arARlAL SEAL F::. Bickhart, NoW')' Publk Hill Bore.. Cwn\>elWtdCoun\'Y My'~mmission expir..l'<b. 19. 2004 My commission expires: 22 JJitIb" 'OJ > .-, ,., ~ 'b' ,~,.,~,-' --'"~,~-". " ""'~. ,,,-',,--.',,,-,,;. "C-.-_:' ,_,~,,_"; ~' " ""'""ii'" ~_ ~''''', .,. , ~, -", . .,' - ;V';:";~-l,"," '-,--,~ '- ., .., -< c " - " -"' , .. ... ." ~ ... ~ COMMONWEALTH OF PENNSYLVANIA COUNTYOF ~L ~ ) ) ) BEFORE ME, the undersigned authority, on this day personally appeared KATHERINE T. REMIG known to me to be the person who executed the foregoing instmment, and who acknowledged to me that she executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this 3 ( '2.J day of &c-f, ,2001. ~. f5 '-c-C 1.. f Not Public in and for Commonwealth of Pennsylvania Typed or printed name of Notary: NOTARIAL SEAL 1. Bickhart, Notary Public Camp Hill BolO., Cumberland County' Myoommi..ioo expires Feb. 19.2004 My commission expires: 23 ,""W&'''''''''''' _~~~l\f~M~~~~iS\iIri. c ~ , .bt:A:idlllilllllol "" ~ ~ .-. - (') C "'" ~~i co .I> --<' .~' ~o """ ~t5 c z =< . ~~- i . co o q ~.)lli' :5 ",--<' -"- ,_ ~TI . f" ~ ,nn r'0 cr', v -c -~ ~~) , -~'1 (-) t~) nl 55 -< ""0 f;i;: ,"". I ~_" C',; . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A KATHERINE T. REMIG, Plaintiff v, ) ) ) ) ) ) NO. 2000-5183 CIVIL TERM BRADLEY E. REMIG, Defendant CIVIL ACTION - LAW IN DIVORCE 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 g3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service accepted by Donald T. Kissinger, Esquire on behalf of Defendant Bradley E. Remig on or about August 1,2001; Acceptance of Service filed with the court on August 1, 2001. 3. Date of execution of the affidavit of consent required by g3301(c) of the Divorce Code: by plaintiff, November 14, 2001; by defendant, November 5, 2001. 4. Relatedclaims pending: All claims resolved by Marital Settlement Agreement of October 31, 2001. 5. Date plaintiff's Waiver of Notice in g3301(c) Divorce was filed with the prothonotary: contemporaneously herewith; date defendant's Waiver of Notice in g3301(c) Divorce was filed with the prothonotary: November 6, 2001. Date: / / I'Ll /6 ! ~~~"l~ HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P. O. Box 810 Harrisburg, P A 17108 Telephone: (717) 234-2616 Counsel for Defendant Bradley E. Remig iIi'""" r rl( '., ..l!l!ltIiltl5bil!tl'i'JtjK~~--~d!l~'!i~~!!~'ll\i;lj!;'U~~liil]i!l'k~ .. -. , _;..;.-,Jl1WlIi~ , ~ B. ""'" "' . "'" "'~ (') 0 ." c: \1 :g;: ::l: ;:go::' C;) fTi -,- ,.c Z-T": zs:: N , ,'T': en", 0"> '---' <::: ~f '",; r~" ;.::: -' .." '~ -r, )>0 -.,.,~ ~d -----,-" Zo .,.to. ('5 Pc: C) m Z N ~ =< :n -( ",-,' '} \ I , " I I I I . ~_"M_ " , , "',_'~~"-_'r~'. "",~,_,~ ,~'"J<', "-_,-.r.<J ,.. Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff KATHERINE T. REMIG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000- 5/~ 3 CIVIL TERM v. CIVIL ACTION - LAW BRADLEY E. REMIG, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You 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 pages 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 the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 '-~', .~ ,- ~^I-' ,'. ^ ,__ ,-_ , ,- ~ , -.~ '~""Ol-.g. .. . Johnson, Duffie, Stewart & Weidner By: Keirsttln W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHERINE T. REMIG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000- S/f'3 CIVIL TERM v. CIVIL ACTION - LAW BRADLEY E. REMIG, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(cl OR 3301(dl OF THE DIVORCE CODE AND NOW; comes the Plaintiff, Katherine T. Remig, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Bradley E. Remig: 1. The Plaintiff is Katherine T. Remig, an adult individual, residing at 121 November Drive, Apt. 6, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Bradley E. Remig, an adult individual, residing at 30 Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant were married on May 20, 1995 in York County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. ",,',.--, .. 7. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301 (c) of the Divorce Code. JOHNSON, DUFFIE, STEWART & WEIDNER By:~lJ.~ Keirsten W. Davidson :136511 ,,',,_.'---'-<', VERIFICA TION I, Katherine T. Remig, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A ~4904, relating to unsworn falsification to authorities. Date: 1-/9-M . . , J . , Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attomeys for Plaintiff KATHERINE T. REMIG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000- CIVIL TERM v. CIVIL ACTION - LAW BRADLEY E. REMIG, IN DIVORCE Defendant AFFIDA VIT KATHERINE T. REMIG, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. ~904, relating to unswom falsification to authorities. Date: 7-/9--- orJ . .:dlIiIJ~ ,,~ ~~ 'ii!iiW-~ . .","""''''''"'' -.-'-' ~~I\B~"'""'''''''';''"lill'jl~:li''''' !~Mlij!llii~'''~ ~~ ~~ ~ ~ ~ ~ ~ ~L!il'r'" ~ ~. V\ ),(j, \ , Jt . ;" "'-. ~~ \~ '\ , ~ ..... o C 7' l:JG' JTlfT: Z::}I LC, S2~:;: ~C-=- :?C ;?; C<\ )>~ ~. ::< '.""" ,^ -~ ~ c: c,;; (-:: r- r',.) .i. ~1::; ::h: r',' =) .0 C,_,) < .~ ~ r ..... .7-;--'.,-"", ':,,,, .,'.'. ,. . , KATHERINE T. REMIG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-5183 CIVIL TERM Plaintiff v. CIVIL ACTION - LAW BRADLEY E. REMIG, IN DIVORCE Defendant ACCEPTANCE OF SERVICE I, Donald T. Kissinger, Esquire, attorney for Defendant, Bradley E. Remig, hereby accept service and acknowledge receipt of the Complaint in Divorce under Sections 3301 (c) or 3301 (d) of the Divorce Code filed by the Plaintiff in the above-captioned matter on behalf of my client, Bradley E. Remig. H Donald T. Kissinger Attorney I.D. No. 130 Walnut Street Harrisburg, PA 17101 :136511-7Z .~Mfll' 0" " o . .",,"" . '~"1I&~'l'ili[jM-- '~llfllliiI "~ ~ "~~ "" . " (') ~ -oC'~ IT1q.', Z__c, ~~' ~~; j;;C c -"-! -< -.,. ,-'. c:> a ",. .- r;) I (:~ . , ~- u , ~~) ,~~~ "'-j fv :"b -< J'~"=' ~- ," . ',;:., Johnson, Dnffie-, Stewart & Weidner By: Keirsten W: Davidson LD. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 . . Attorneys for Plaintiff KATHERINE T. REMIG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ,j.O()O C;(g3 CIVIL TERM v. CIVIL ACTION - LAW BRADLEY E. REMIG, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 19, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not r'3quest 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. I understand that false statements herein are made subject to. the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: I' /1 !.-if 200 , Katherine T. laintiff :151791-1 " ~~ . .~ -~. - (") c <^ -orE rnh~ Z.J...' 65 S;~ C-<.-: ~C) >0 Zo rc ~ - " "' . c=, C) -n z f'" :;~: N G'"'; , ) ,.L :-f'-..) -~-" ~5 om ';:;! SJ c-< ;:? N C', . . ',-" ';0', '~ , , co-, ".- ""i.ii,';;; Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 " . Attorneys for Plaintiff KATHERINE T. REMIG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ,J-bbD c ~ I g 3 CIVIL TERM v. CIVIL ACTION - LAW BRADLEY E. REMIG, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 1 B Pa.C.S. !l4904 relating to unsworn falsification to authorities. Date: If 11..d2.0P, f , :151791.2 -~ ,.....-.... =, ~ ~ -, ~"' "~ ~-lii\liIitIiI . " "'- ^-- .. ,~-~. '~ I" (') (- ~ rl1,f/:; ;?'n' _.,. J' Cf5\-c .",< f2e; ~(') 55f-8 <: =< ,=.,,-- . ." '- -r,; :J:: - C;:; -- ,13 'c;;:;:: f'0 0'-1 ,"-~- , J '",' -- \1 .5i.~t 2? I' .I . ~- ,',-,;., .' ___0 _,_ i.,.'-, _'__il, , ,,-~, -- " . r'" V ... ..,. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KATHERINE T. REMIG, Plaintiff v. ) ) ) ) ) ) NO. 2000-5183 CIVIL TERM BRADLEY E. REMIG, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under S3301(c) of the Divorce Code was filed on July 19,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF TIlE DIVORCE CODE I. 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! 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 ofthe decree will be sent to me inrmediately 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. S4904 relating to unsworn falsification to authorities. Date: lI/si2Yrll I ~l~liJ;i!iWhiJ.%~"1$-jl~B~~~>i!~~~~ti!!1llNi~~'-i w .. .n. -- ~ ,H c_., -.-, -'.- , -~ " 1"",...... "--' "". ~i, : "OJ .. (') C) C) C '" s: Z 'Or'-" I:=J :}~ [11[1" j,-;:: Z:::C Z r.-- (D ~t:: 0" -< ~c, '..' r:;;:-':'::J " ---1'. ~C~ -;" ," :(i C) 5~: r:-? en ::::: ~...-.,) j;! -< f0 ~ "