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HomeMy WebLinkAbout00-05965 , ~ _k, . r. . . . . . . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . STATE OF . . ,1lIDT'T'H W om ,r. Plaintiff VERSUS STEPHEN M. DELL . . Defendant . . AND NOW, DECREED THAT AND PENNA. NO. 2000 5965 CIVIL TERM DECREE IN DIVORCE J3;31~A, ?001 , IT IS ORDERED AND , PLAINTIFF, STEPHEN M. DELL DEFENDANT, ARE DIVOReED FROM THE BONDS OF MATRIMONY. THE. COURT RE'fAINS JURISDICTION OF THE FOLLOWING CLAIMS WHleH HAVE BEEN RAISED OF RECORD IN THIS AeTlON 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 certam Manta! Settlement Agreement between the parhes dated August 15, :WUU, and attached hereto, are incorporated in this Decree in Divorce by reference as fully as ifthe same werl..i ~vt fvtll11l\.ll\,l~.H at h."Hotll. S~J AOJ-l;;,;;uu;;;ul ;::.11a:11 UVllll~lot;; W~t11 "'uul ;'lllall :)Ul v~v~ t1~;) Decree in Divorce. . . . J. OTHONOTARY . . . . if. fl!ff. '" '" :Ii . -' ~ 1<1 oS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "~"_ 'p"" '''''i """-<V'~'~ ,.~,,~ ~'"= ',,- ..,.."~"-,,,,".,,..",,,>,,- i~ , k .. ~ .r'" '~! J' )S C7 I (}t-I C?;t /ua<JIJ/ z:' /b~ /,~: c'/ /b~~ I~~di/ k?qf ~cfr Ii Ii , ! ! ! , ! , >> !i i ~i .' ~ ~:I ~:i II II r ~ . ., .1J1il1.,. "'"7'" ~,.,- J1WJ "0,'" 'fl. . - ~~-1-!~ ,~ ""j ,.,&;li.fi:"", ~_~,.~ "j~^ ~,",!I!I!IlI!~_,,~,i:l;1,I~..., ".. ~,~ ~~ - -~ " MUUUTALSETTLEMENTAGREEMENT BY AND BETWEEN JUDITH W. DELL AND STEPHEN M. DELL - r . L < "" - "<" , , . , NUUUTALSETTLEMENTAGREEMENT THIS AGREEMENT is made this I t/:!.y of and between JUDITH W. DELL, of Cumberland County, Penns DELL, of Cumberland County, Pennsylvania; , 2000, by 'a, and STEPHENM. WITNESSETH: WHEREAS, Stephen M. Dell (hereinafter referred to as "Husband"), social security number 269-42-1893, was born on June 9,1947, and currently resides at 1006 Market Street, Apartment #1, Lemoyne, Cumberland County, Pennsylvania, 17043; WHEREAS, Judith W. Dell (hereinafter referred to as "Wife"), social security number 350-38-8657, was born on July 5,1946, and presently resides at 2104 Beacon Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055; WHEREAS, the parties hereto are husband and wife, having been lawfully married on July 12, 1969 in Michigan; WHEREAS, the parties have lived separate and apart since on or about July 22, 2000; WHEREAS, two children were born of the marriage between the parties, namely Brian Dell, born July 2, 1974 who is presently physically disabled and residing with Wife and, Mark Dell, born August 27, 1977 who is emancipated but attending his last year of college education at Eastern Michigan University; WHEREAS, the parties hereto are desirous of settling fully and fmally their respective fmancial 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, 1 c..'="'""' ~ ~ -- ~- . -. - -' ~. ~- .- <. .. the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of these premises, and of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, 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. The parties acknowledge that both have sought or have been advised of their right to seek independent legal counsel. The parties further acknowledge that Wife is represented by the firm ofHowett, Kissinger & Conley, P.C. and at no time has Husband been represented by this firm in connection with any divorce and claims arising therefrom. Husband acknowledges that he understands that he has every right to contact counsel of his choice, be advised by them and review in detail the contents ofthis Agreement before its execution. Each party fully understands the facts and hislher 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 acknowledges the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights ofthe parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or properties, 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 2 III ~.~",.~-"""~"",,,; , ,.'~~~ , - - . ( equitable to each of the parties, and waives his/her respective right to have the Court of Common Pleas of Cumberland County, or any other Court of competent jurisdiction, make any determination or order affecting the respective parties' right to alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs of litigation. 2. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she is aware of his or her right to seek discovery, including but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories, and all other means of discovery permitted under the Peunsylvania 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 marital asset 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 and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other party or his or her heirs, executors, 3 ";'~" -"'~~ - ~"~ '"~ II' ._" """"",, , , 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. 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 manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acqnired 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 divorce only. Wife shall, as soon as practicable, after execution of this Agreement, commence a divorce action under ~3301(c) of the divorce code. When the ninety (90) day waiting period has expired, both parties shall execute Affidavits of Consent after January 1,2001 and Waivers of Notice of Intent to Request Entry of Divorce Decree and forward same to counsel for Wife who shall file said documents of record along with any and all other documents necessary to precipitate the prompt entry of a divorce decree. Moreover, the parties 4 have agreed that Wife can and shall bring the divorce action in the Cumberland County Court of Common Pleas. 5. EOUlTABLE DISTRIBUTION. (a) Marital Residence. The parties acknowledge that they are the titled owners, as tenants by the entireties ofthat certain house and lot and all improvements thereupon situated at 2104 Beacon Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055 (hereinafter referred to as the "Marital Residence"), subject to a mortgage with a current outstanding balance' of approximately Sixty Nine Thousand Nine Hundred Dollars ($69,900). The parties further agree that the value of the home as of the date of execution of this Agreement is One Hundred Sixty Five Thousand Dollars ($165,000). The parties also agree that if the house were to be listed for sale, the sales costs involved in selling the house would be approximately Thirteen Thousand Two Hundred Dollars ($13,200) (7% real estate commission and 1% transfer tax) leaving net equity in the Marital Residence as of the date of execution of this Agreement to be Eighty One Thousand Nine Hundred Dollars ($81,900). The parties agree as follows with respect to the Marital Residence: (1) Wife shall become the sole and exclusive owner of the Marital Residence and shall be permitted to take any action with respect thereto that she deems appropriate. Except as provided below, Husband hereby waives, relinquishes and releases any and all past, present or future right, title, claim and interest he may have in and to the Marital Residence. Husband shall, at Wife's request, execute a deed transferring all of his right, title and interest in the Marital Residence to Wife. (2) Husband agrees that as the date of execution of this agreement, any and all title policies and any other policies of insurance with respect to the 5 Marital Residence shall be endorsed to reflect Wife as sole owner thereof and further agrees that Wife shall be entitled to receive any payments now or hereafter due under any such insurance policies. (3) Commencing on the execution date of this Agreement, Wife shall be solely responsible for all costs, expenses and liabilities associated with or attributable to the Marital Residence, including, but not limited to, any mortgages, any and all home equity loans or lines of credit, taxes, insurance premiums, utilities, maintenance and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors and administrators indemnified and held harmless from any liability, cost or expense, including actual attorneys fees, which may be incurred in connection with such liabilities and expenses or resulting from Husband'sownership interest in the Marital Residence. Upon Wife's sale of the Marital Residence, Wife shall pay to Husband from the proceeds of sale, the sum of Forty Thousand Nine Hundred Fifty Dollars ($40,950) representing one-half of the estimated equity in the Marital Residence as of the date of execution of this Agreement. (b) Furnishinl!s and Personalty. (1) The parties agree that they have divided by agreement between themselves all furnishings and personalty located in the Marital Residence, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment. (2) 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 remaining in the Marital Residence. 6 - - - ~" "'- - ~ "' " .1 ,,"~',. , "-11n~' ( (3) 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. (c) Motor Vehicles. (1) Husband agrees that Wife shall from the date of execution of this agreement through May 31, 2001, retain possession the leased Honda automobile currently titled in the joint names ofthe parties, during which period Wife shall be responsible for the monthly payments on any outstanding indebtedness pertaining thereto and insurance thereon. Wife shall indemnify and hold Husband and his property hannless from any and all liability, cost or expense, including actual attorney's fees, incurred in connection with this vehicle accruing during the period of time Wife is in possession of said vehicle pursuant to the terms of this subparagraph. The Parties further agree that on June 1, 2001 possession of the leased Honda automobile shall transfer from Wife to Husband which shall thereafter be his sole and separate property along with all rights under 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 Wife and Husband shall indemnify and hold Wife and her property harmless from and all liability, cost, or expense, including attorneys fees, incurred in connection with this vehicle on or after June 1,2001. (2) The parties acknowledge that during the marriage Wife was gifted a Camry automobile which is currently titled in her name but which is in Husband's possession and being utilized by Husband on a daily basis. The parties agree that Husband shall be entitled to continue to utilize said vehicle from the date of execution of this Agreement through June 1,2001 at which point Husband shall transfer possession of said vehicle to Wife. 7 ",fr~. , ~ ~~,~ ~_n. _"'~ ,......- ~ Moreover, until Husband transfers possession of said vehicle to Wife, Husband shall, pay to Wife for the use of said vehicle, the sum of Two Hundred Dollars ($200) per month payable to Wife on or before the 15th day of each and every month. Should Husband fail to make any of said payments in a timely fashion, Wife shall be entitled to immediate possession of the Camry automobile. (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. Specifically, Wife shall become the sole and exclusive owner of, free and clear of any right, title, claim and/or interest of Husband her Luthem Brotherhood Life Insurance Policy, including the cash value thereto. Likewise, Husband shall become the sole and exclusive owner of, free and clear of any right, title, claim or interest of Wife, his Luthem Brotherhood Insurance Policy including the cash value thereto. (e) Pension and R.etirement Benefits. 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 I (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. 8 - -~ L . ,~-~r ~~ ~-, .~-_.~ .. Specifically, the parties agree that Wife shall retain sole and exclusive ownership of her T-Rowe Price Roth Individual Retirement Account, her Vanguard Roth Individual Retirement Account, her AETNA T.S.A. Account, and her Public School Employees Retirement Benefits. Husband hereby waives any and all right, title, claim and interest he may have in and to said retirement benefits. Likewise, Husband shall retain sole and exclusive ownership of his REIT SEP Lincoln Trust Individual Retirement Account free and clear of any and all right, title, claim and interest Wife, may have in and to said retirement benefits. (f) Dreyfus Account. The parties acknowledge that at the time of separation they owned a Dreyfus Account with an approximate balance of Eighteen Hundred Dollars($1,800) dollars. The parties agree that they shall take all steps necessary to withdraw the funds from said account and distribute said funds between themselves on an equal basis. (g) Other Accounts. Husband shall become the sole and exclusive owner of the following accounts titled in his name alone, free and clear of any and all right, title, claim and interest of Wife: (I) Merrill Lynch Account; (2) Citi Group Account. The parties further agree that Wife shall retain sole and exclusive ownership of the following accounts titled in her name alone, free and clear of any right, title, claim and interest of Husband: (I) Merrill Lynch Account; (2) T. Rowe Price Mutual Funds Account; (3) Vanguard Balanced Equity Indexed Account; 9 - , -""'-- - (4) Pennsylvania State Employees Credit Union Savings and Checking Account. Moreover, the parties specifically acknowledge that Wife's Merrill Lynch Account, Vanguard Account and T. Rowe Price Account were funded by gifts from her parents. (h) Husband's Commissions on Listinl!:s. The parties acknowledge that Husband is employed as a commercial real estate agent and thus, is entitled to commissions on his listings and that said commissions may constitute marital property. Notwithstanding the above, the parties agree that Husband shall be the sole and exclusive owner of said commissions free and clear of any and all right, title, claim and interest of Wife. (i) Miscellaneous ProDertv. 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. (j) ProDeJjv to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of Husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns 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. 10 ,""_...."""'. ~. .~" - ~~ -- ..~~~ .~ i~; ,.. (k) Pronertv 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 ill 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 hannless 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 indemnifY her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Wife in connection therewith. (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, 11 <~,<;tt"""^'~'-~~ ~ ~ .,"~ '~- ~,,~."'~ ~~..,..- :-';'."'_M'" ~_~ W~ ~~h'_"""_~..!;:' . 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. WAIVER OF ALIMONY. ALIMONY PENDENTELITE. SPOUSAL SUPPORT. Husband and Wife hereby expressly waive, discharge and release any and all rights and claims which he or she may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite, spousal support and/or maintenance or other like benefits resulting from the parties' status as husband and wife. The parties further release and waive any rights they may have to seek modification of the terms of this paragraph in a court of law or equity, it being understood that the foregoing constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. 7. COLLEGE EXPENSES. The parties acknowledge that their son, Mark, is currently enrolled and will commence his last year of college at Eastern Michigan University in the fall of2000. The parties further acknowledge that Mark's tuition expense for the fall, 12 '- ~~~~~ ~= "",,,,,,,,,,--_.,, " ~. .., ~,.~ '---. . 2000 semester will be Four Thousand Dollars ($4,000) and for the spring 2001 semester will be Four Thousand Dollars ($4,000) for a total of Eight Thousand Dollars ($8,000) in tuition payments less any [mancial aid he receives. Moreover, the parties acknowledge that Mark has an apartment rental expense of Two Hundred Eighty Dollars ($280) per month. The parties agree that they shall each pay one-half of Mark's tuition and fees expense after deducting all amounts he receives in financial aide for each of the fall and spring semesters. Said payments shall be made directly to Eastern Michigan University within ten (10) days of the date of execution of this Agreement. Moreover, the parties further agree that each shall be responsible for one-half of Mark' s ongoing apartment expense for the months, August 2000 through June 2001. Each party shall pay to Mark, on or before the first day of each and every month that they are obligated pursuant to this paragraph, the sum of One Hundred Forty Dollars ($140) per month. 8. BRIAN'S MEDICAL EXPENSES/NURSING CARE EXPENSES. The parties acknowledge that their son, Brian is currently physically disabled due to a debilitating physical condition requiring ongoing medical treatment. The parties further acknowledge that Brian is currently residing with Wife in the Marital Residence and will continue to do so until such time as his physical condition improves to the point were he is no longer disabled, or deteriorates to the point where he requires nursing home care. The parties agree that for so long as Brian continues to be disabled, that each party shall be responsible for one-half of the costs of Brian's uninsured medical expenses which specifically include but are not limited to the cost of his chemotherapy treatments, doctor's appointments and in-home nursing care. Moreover, the parties agree that should Brian enter a nursing home or other type of assisted living facility that each shall be responsible for one-half of the uninsured cost of said 13 "',,,,,"..."''''~~''''' ~~ ""~ ", .,_,~........L" """""',_~. = ~~ ..~w~~~, &' '_~~.....;" care. In the event parties advance said costs prior to insurance reimbursement each party shall be entitled to one-half of the insurance reimbursement when received. 9. MEDICAL INSURANCE COVERAGE FOR HUSBAND. The parties acknowledge that Wife is currently providing medical insurance for Husband through her place of employment. Wife agrees to continue to provide said coverage until such time as a Divorce Decree is entered at which time her obligation to provide said coverage shall terminate. 10. COUNSEL FEES. COSTS AND EXPENSES. Husband shall within thirty (30) days of the date of entry of a Divorce Decree in this matter reimburse Wife for one- half of the legal fees, costs and expenses she has incurred in connection with their separation and/or the dissolution of their marriage, and the preparation and execution ofthis Agreement. Accordingly, with ten (10) days of the date of entry of the Divorce Decree in this matter, Wife will provide Husband with copies of invoices evidencing the total legal fees, costs, and expenses she has incurred. 11. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each waives all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 12. 2000 TAX RETURNS. The parties agree that they shall file joint Federal, State and local tax returns for the 2000 tax year. Iftaxes are due each party, shall be 14 ,""-~' "~ ,~ .'-. ~------..........-. - ~L ~ ~~ "-~_-.l'j responsible for the taxes due that are attributable to his/her income. If taxes are due to be refunded each party shall receive that portion of said refund attributable to his/her overpayment of taxes. 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, [mal 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 ofthe 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 ~3502 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, 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 15 ... "" lV'~ 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 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, 16 "~~ - '- .~' - = -, -,- ~ >~"'~ .~ .= ..' ~~Jccl"'~3" . 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 ofthis 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. 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 17 ~,,~~ ""^'~ -_ -"'1""\11I> _.~ , ~...~. ~""~"'''~''~-'''~ .. entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 19. WAIVER 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 oftbis 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: Stephen M. Dell 1006 Market Street, Apartment # 1 Lemoyne, PA 17043 and to Wife, if made or addressed to the following: Judith W. Dell 2104 Beacon Circle Mechanicsburg, Pennsylvania 17055 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 --',~ '~-- ~-,~ "" "- """" -- lI;jJll~ . 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 ofthe terms hereof unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 25. Hf:ADINGS 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 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 ,,~.:.l!IJll ~ -," ~.~.~ ~~- ~""~"""""'i . . 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. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. , I , *DJd'~ 20 ,m-~llII : ~~/~nc~; 1/ "__,,"," Ilti . / tv, ITH W. DELL 21 . " 'i:' ,'H~"''''''- ~ ~~, ~~_A_~ -~~- _OJ," -"1 ----, . . COMMONWE ) ) ) COUNTY OF , BEFORE ME, the undersigned authority, on this day personally appeared STEPHEN M. DELL 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. IVEN UNDER MY HAND AND SEAL OF OFFICE this I LfJ~day of ,2000. e:, .~~ /" N ublic in and for ( Commonwealth ofPennsyl~ TYIled or printed name of Notary: h:haz. fYI. ;Lj~I'j~q 'cJ l!.,"" (.- \ My commission expires: ,j)3',. '-. 22 'ff~"" - h ~, ~~ ~.....'~ ~ Ib\<,,'" " .~ - ....~=.~ " Iii.. ~' ~ "". . . COUNTY OF , IlL. ) ) ) BEFORE ME, the undersigned authority, on this day personally appeared JUDITH W. DELL known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and considerations therein expressed. jJ'l ~ UNDER MY HAND AND SEAL OF OFFICE tlm 6 obyor ~t!!/\+-- ,2000. No lie in and for Commonwealth ofPenns vania Typed or printed name of 0 : ~ wi ?5tilUf My commission expires: e-;::s.(){) 23 ~_~~Mj~~A~fig~4Gti>~~t~~~~B~i~~;~~": ll~~~~~mll1linlt "' ~. H !ME' ,'. tJ~ih;~,>>1li!.i MI!'~:i&.t~1~1!J!rr_!:f!;@:~r~:j1 n,., . . . () 0 0 C -'1 <:'" t__ ::;:l ~!TI ],11I :':i~ fi~2{ , N ~g.9 Cf)..~ N r:~ rl S,'\') '< -- ~TJ -.Jfi ~(J _J....." 6?-'1 :Ji: ~1(i ;<--C ~ .(',)rn ~ .:~ 0 ~ N ,,"'-- :~- ~ ~ ~ ~ - "0'- r,~_,'-i;,,,,-c . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDITH W. DELL, Plaintiff ) ) ) ) ) ) ) NO. 2000-5965 CNIL TERM v. STEPHEN M. DELL, Defendant CIVIL 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 9330I(c) ofthe Divorce Code. 2. Date and marmer of service of the complaint: Service by certified mail on September 1, 2000; Affidavit of Service filed September 7, 2000. 3. Date of execution of the affidavit of consent required by 9330I(c) of the Divorce Code: by plaintiff, January 6,2001; by defendant, January 13, 2001. 4. Related, claims pending: All claims resolved by Marital Settlement Agreement of August 15,2000. 5. Date plaintiff's Waiver of Notice in 9330I(c) Divorce was filed with the prothonotary: contemporaneously herewith; date defendant's Waiver of Notice in 9330I(c) Divorce was filed with the prothonotary: contemporaneously herewith. Date: JC! JO/vL. 0 I Cindy S. Con , Esquire HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P. O. Box 810 Harrisburg, P A 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Judith W. Dell -l ; "" "~~Uiltiia.~ ~---- .''''" i:. ~~:r~--- - "^ '~', "~,' ~ '. e,,_, ", '''tl J.ll~" "L.c~ __,. ~.. ~;,"- " '-""" ~~ - " (") 0 0 ~ -n r.... ,,-\ "0 OJ l:>o :r:::rJ ~9:l z ,ilL N :g~ Zs::; ,'-' CQ-c:;;.., ~~( ~L. ~CI V -r=H :5 ~8 :J: ~C) 5>C N cyn .. );! ~ 0 ::0 N -< ~, _ n , L '~~"""";"<.."",,,,,,,,.....,,,,,, ~ ~,~ ~ "- ~ lliIl, '"',' '~~I~...!/ilIAIiilIPl'IJ "..~,..r~~""." , . IN THE CO'URT O'F CO'MMO'N PLEAS O'F CUMBERLAND CO'UNTY, PENNSYLVANIA JUDITH W. DELL, Plaintiff ) ) ) ) ) ) ) NO'. 2000- K9I..S CIVIL TERM v. STEPHEN M. DELL, Defendant CIVIL ACTIO'N - LAW IN DIVO'RCE 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 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the O'ffice of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. IF YO'U DO' NO'T FILE A CLAIM FO'R ALIMO'NY, DIVISIO'N O'F PRO'PERTY, LAWYER'S FEES O'R EXPENSES BEFO'RE A DIVO'RCE O'R ANNULMENT IS GRANTED, YOU MAY LO'SE THE RIGHT TO' CLAIM ANY O'F THEM. YO'U SHO'ULD TAKE TillS PAPER TO' YO'UR LAWYER AT O'NCE. IF YO'U DO' NO'T HAVE A LAWYER O'R CANNO'T AFFO'RD O'NE, GO' TO' O'R TELEPHO'NE THE O'FFICE SET FO'RTH BELO'W TO' FIND O'UT WHERE YO'U CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 Telephone: (717) 240-6200 AMERICANS WITH DISABILITIES ACT O'F 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ,i'''''""''._.....,,~- .l.l"'~ . -~ '-~.. ..~~~~=, """""~-_.. .~~~ 0.. "..i.l:'" f ~ r. a' .'; . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDITH W. DELL, Plaintiff ) ) ) ) ) ) ) NO. 2000- 5'1(, s" CNIL TERM v. STEPHEN M. DELL, Defendant CNIL ACTION - LAW IN DNORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Judith W. Dell, by and through her counsel, Howett, Kissinger & Conley, P.C., who states the following in support of the within Complaint: I. Plaintiff is Judith W. Dell, an adult individual who currently resides at 2104 Beacon Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Stephen M. Dell, an adult individual who currently resides at 1006 Market Street, Apartment #1, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. Both the Plaintiff and the Defendant have been bona fide residents in the Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding the filing ofthis Complaint. 4. Plaintiff and Defendant were married on July 12, 1969 in Michigan. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States of its allies within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or annulment of the marriage instituted by either of the parties in this or any other jurisdiction. c~~ . . ,lli&,,,,,,,,,~,,,,,,,,",,,,,__,"'~~' ~'~w_' . .~'.'i" . . . 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage of the parties is irretrievably broken. 9. The parties have lived separate and apart since in or about July 22, 2000. 10. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Date: /}r ~,wa}(X) ,~*'~!~,-~'~ ""I'~""'~""'"""'-~ I. " . VERIFICATION I, Judith W. Dell, hereby swear and affirm that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: rtS /).E '60 tl~ti- w. [).dL Pdith W. Dell "-~~~". - ~18;>;l;~," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JUDITH W. DELL, Plaintiff ) ) ) ) ) ) ) NO. 2000-5965 CNIL TERM v. STEPHEN M. DELL, Defendant CNIL ACTION - LAW IN DNORCE AFFIDAVIT OF SERVICE Cindy S. Conley, being dilly sworn according to law, deposes and says that she is an attorney at law authorized to practice in the Commonwealth of Pennsylvania, and that on the 30th day of August, 2000, she sent the original ofthe attached letter, with which was enclosed a certified, time-stamped copy of the Complaint in Divorce in the above-captioned matter, properly endorsed, to the Defendant, Stephen M. Dell, by certified mail, postage prepaid, return receipt requested, restricted delivery, pursuant to PaRC.P. 1930.4, to 1006 Market Street, Apartment #1, Lemoyne, PA, 17043, the Defendant's last known address, and that the return receipt card which was signed by Stephen M. Dell, marked as having been delivered to him on September 1, 2000, is attached hereto and made a part hereof. Cindy S. Coni ,Esquire HOWETT, SSINGER & CO 130 Walnut Street / P. O. Box 8 Harrisburg, P A 171.08 Telephone: (717) 234-2616 Counsel for Plaintiff Judith W. Dell SWORN TO AND SUBSCRIBED be re me this 5th day of September, 2000. ^,l~"~'~'~< ~- JOHN C. HOWETT. JR. DONALD T. KISSINGER CINDY S. CONLEY DARREN J. HOLST DEBRA M. SHIMP Legal Assistant ~~ ..'~ LAw On-ICfS OF HOWETT, KISSINGER & CONLEY, P.c. . 130 WALNUT STREET POST OFFICE BOX 810 HAJUUSauao. PENNSYlVAMA 17103 August 30, 2000 CERTIFIED MAIL NO. 70993400001475844403 RESTRICTED DELIVERY RETURN RECEIPT REOUESTED Mr. Stephen M. Dell 1006 Market Street Apartment #1 Lemoyne, P A 17043 Dear Mr. Dell: Re: Dell v. Dell Enclosed for service upon you please find a certified copy of a Complaint in Divorce filed on behalf of your wife in the Cumberland County Court of Common Pleas. Very truly yours, J(:. CSC/dms Enclosure cc: Judith W. Dell (w/encl) -'-'= ~~<-"'''''"~""''' (717) 234.2616 FAX (717) 234.5402 0- J ", IJ,Complete items 1 and/or 2 for additional services. = Complete-items 3, 4a, and 4b. ... 0 Print your name and address on the reverse of this form so that we can return this t card to you. ~ 0 Attach.this form 10 the front of the mailpiece, or on the back if space does Rot GI permit. . -S 0 Write. "Return Receipt Requested" on the mailpiece below the article number. C 0 The Return Receipt will show to whom the article was delivered and the date o delivered. i 3. Article Addressed to: 1D Q. E o u Ul Ul III 0: '0 o <( z S+~hULn1. ~/( t OD~ rn~Z-8red- f+ptU-1Jm Wru -1J= I UIKA e..- 'P)4- / '7 D 1f:3::> ~''''lOi"~'''"~- f<<*": ~ ".~ ~" m CJ e>- e>- e>- <0 U1 l'- _._~ 'w ',. e>- M CJ CJ 'Re: {Endors Aestrlc (Endors U.S. POSTAGE : ,. CJ CJ e>- m Totall .~:c;p~ Name (~'ea~01~~,~~:t:lfJZ completed by mailer) -'-- .i.~~~.Srrd:~:::/i;;~: L- 71t /71J13. 0- 0- CJ l'- I also wish to receive ~he fmi_~ ing services (for an extra fee): 1. 0 Addressee's Address 2*estricted Delivery a '3 " ODI415g~4'1fJ3 E ~ ~ertified ! o Express Mail 0 Insured .; ~Retum Receipt '"'-- u...-Io.~mIi8e-- 0 COD ::::II .2 7. Date of Delivery ::::II /;1' ODD g, .. c .. .. .. 102595-99-8-0223 Domestic Return Receipt jj ~ "'--'k ,- ~ , .Ii i: al ~~iVjj~~:;1!t1!ii!lr~:t]in~"<.-l~;~'ilii" L"'''-~jttt~~'[Th..i'~'o ,'0 ,'", "'-"',.~'"L''''' J" ~' -= li'!!!ii!I,iIlli1ilJiio"'ml (1[,:"':' n1rl ~f2 s;?;c.. ~..~ \~. ~;'-'- ~j~~; :=~ :< (J c.:' . - ,.,...., ,"'1 '"'0 .~ ~~,J ~-,._, ,en 2J -~ t '-"-',,,,~,,,;-.--,,,,",,,__, ~"(" h I:J ~~. ~.;~.. --,""'~""_"_-""'- "'Y''''''~,"''' . '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDITH W. DELL, Plaintiff ) ) ) ) ) ) ) NO. 2000-5965 CIVIL TERM v. STEPHEN M. DELL, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under 93301(c) of the Divorce Code was filed on August 29, 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 THE 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 in 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. 94904 relating to unsworn falsification to authorities. Date: Jd.nLLarv 6) 200/ / i..4jliu.l&lllk!.~~=" lllt_~jmrl!Ml!gj~~!lld{l"lJi(*,l~4~Ci,1jj)i:);.-ItJ-'#.i!:~"liiA . =- ,~ ~.~,'-. R11r'~1filit 'i1lf1~'"'-"~'~~~~-.~..iI-~lf-!.>~" ~. " ~ <. ".C1 'un:" . . C) '.:::' c= t-J'f'i::: c_ ::C~;, ~t~_! """~ tr'l -- ::'<: ~'~~'::, v ;> C-' C' '-'~- 7...'; :.....:; -'-.,. :< Jj f0 -<': , '~"'_'~_J _ - "~"~~~ " J'" ""'-" - . . )11 ~ ";';"\_ .. . . . <>' " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDITH W. DELL, Plaintiff ) ) ) ) ) ) ) NO. 2000-5965 CIVIL TERM v. STEPHEN M. DELL, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT L A complaint in divorce under g3301(c) of the Divorce Code was filed on August 29, 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 fmal 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 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 ifI 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. g4904 relating to unsworn falsification to authorities. Date: Ijro/l)j ~~""n' J/lN II R ?nOO '__t\i'l~ki.j'~-.1~i0c.h~.'ifu!~y'-\,'i;;*~~~~i!!i I:' ,~ , ""'~~~:JiiH'~<! r u'~~~~ ~'~~~~'C" ,,' <" '..' """".' JAN 1 6 200\ (') C> 0 ~ -n '- ~::j ~m ". ;i;;;g :z: z::O N '"'t',rn ~~ N --.,0 6~ 1:'0 ::::f" . ~(') -0 . , :0:: ?3';!J r.;",...') -0 N orn >c ~ ., -'-I 0 ~ f'V ,