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HomeMy WebLinkAbout00-06059 "";~,.;."...".~.."";.."~_.",...~~,.,.......""",,,,.,,*,,,'~""(C;""~->""'IeK~'''_''''~'''~,:"-::~"",.,,,:<Ci.''~'''f'''(:~'''.W~"""""'{C""""~""~-<<~"iB:~3I""w"::Ci"""'_""~~a;'1 i~r' ....,--,'..., ,..',.,,',.., ."--"." ,.~,,;,;.!.. ....".!"" ,.~,,,,!,,, ,.~..,A'", ';;:~' "".;'! . <. ;c,;'!'" ~~;""'" .',;"o!.., "~';:"" ,.~~,.!'" .M;';;'. 2,.;:".t.. ~";';;'!,,, ~'H'!'" ~,y..o;.... , "" i'.@'..., ~-;:."" "!-4",t.., ';#!,,'';t.. ,;;,,, .,:", . ":'J-' ~ - .~. . ~ ~ ~ '" .,' ~:~" I ' t ~ ~ x ~ ~ IN THE COURT OF COMMON PLEAS ~ ~ x ~ I ~ ~ ~ OF CUMBERLAND COUNTY ~ '1 ~ 2 ~ X ~ ~ I STATE OF PENNA. i ~~ ~ ~~ ~ ~l ~.~ ~ ~ ~.~ * N ~ ',.,' ~ ~.~ ~" ~ ! , ", ~ r:~ ~ a ~.~ i ~ ~ I ~_.'"..- .,_....~ . Y'...!"." "'1"" ,,#4r...... '_i'. . ~~~ ~ ~.~ ~ ;-0" ~ '.' ~ !O.~ ~ ~ a !O.~ '",' f..~ ~ N ~ ~ jlt~ ~ ~ ~.s ~ .<". ~ ~~ . :$ ::: . t} ~ k; I ", ~.f ~ C ~ !O.~ ;:; I ~.~ I ~ ~.~ a ;:;::+::()::+x ~!::.::.':' >::+::{ ::~~::.::{>::.;~:. ::--::.::.--: x.:{:::-::+::;,,: X.::~;' .'-\ ,~~- ,~, [, --- ... CYNTHIA L. DEGEORGE. Plaintiff N o. .....~.~:::.6.9.!3.~ ................. 2000 Versus I ANTHONY R. CRAYTON. H.._u...__._n__..._n_...u_...." ___'__..____u.,._ Defendant DECREE IN DIVORCE AND NOW, ......... .1~",4<y..... 1.~.., 20. 9!-.., it is ordered and decreed that.... .~Y!l.1::l].~:'l. .~:. P.~q~?.r.<;f~....................., plaintiff, and. .. ..~~~?o.~~. ~... . ?~.ax~?? .. .. .. .. . . .. .. .. .. .. .. .. . . .. ", defendant. are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; Tl1e terms of the part.i.e.E!:. ?~,?:p~.r.~:y. ?~~~~.e.II!~~.t. .~9~.e.E!I!l~p..l::..., ............................ . dated November 10. 2000. are incorporated herein but not _ .................. _................... ...... .'T..... ...... .................. herewith. C..o...u;;/L Attest: /1 -------_._._._------~_.~- ......n.... Prothonotary (':.::+:~;;: ':~*::.~: >>>::( ~:.::+:( )~()>>>;.: :;.::.;{ ::,~::.::{ :::.::+::~::. ..-.::.::( )::+::'.:.:::+::'::!... ~ ~" ~.~ I .", ~.~~ ~ ,.', ~.~ ~ ~ ~ ~.~ ~~; ~ k~ I i ~ ~1- V ~ .", ~~ I N a ~~ ~ ~ ~l ~ ~'s ~ ~.s ~ -..,; ~ ~.~ ~ ~ ~.~ ~ ~.~ .___,u J. ~ ~.~ ~ '.' ;i; ~.I ~ ~.~ ~ '.' <'.-_c;'-'--',,",:""~''''~ ,-"-,~.-,'",,,,,,,<,, ,_ ',c C',~,"<Co:" , . ,~---- I:\~lient DirectQfY\DeG~O~e-C\AgreementB\reviBed Property Settlement Agreement.wpd Y {-, .., OCTober 16, 2000 , PROPERTY SETTLEMENT AGREEMENT BETWEEN CYNTHIA L. DEGEORGE AND ANTHONY R. CRAYTON - ""'-~"~'<6"~""""""""""""~~''''''?'''''''''''~'''''''''''''''''''W;'''"",Nj,,,,,,oj<",,,,,,,,,,,,,,,--,,,,,~~- ~ ~=-"""U>>>;;':J>Jl'''''''''$'~''':l#'J'"""""~'~''''''<'l'"'~_~''''''''~''-~\J,'''-,,,, _~,=":;:;;::_=_____ __ __ _. _ _ ___ . _ .. ~,- . ~,l . " I;\~lient Dix:ectO.rY\DeGeO~glf-C\Agreements\revi8ed Property Settlement Agreement.wpd INDEX OF PROPERTY SETTLEMENT AGREEMENT BETWEEN CYNTHIA L. DEGEORGE AND ANTHONY R. CRAYTON . T October 16, 2000 , SUBJECT PAGE NUMBER 1. 2 . 3 . 4. 5 . 6 . 7. 8 . 9 . 10. 11. 12. 13 . 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. -- Separation Interference Agreement Not A Bar to Divorce Proceedings Subsequent Divorce . Incorporation in Divorce Decree Effective Date . Distribution Date Mutual Release . Advice of Counsel Warranty as to Existing Obligations Warrant as to Future Obligations Debt of the Parties Personal Property Division of Real Property Division of Bank Accounts Distribution of Individual Retirement Accounts Pensions, Annuities and/or Retirement Benefits Miscellaneous Assets . Motor Vehicles . After-Acquired Property Payment to Husband . Income Tax Prior Returns Applicability of Tax Law to Property Transfers Waiver of Alimony Effect of Divorce Decree Breach Waiver of Claims . Entire Agreement . Financial Disclosure Agreement Binding on Heirs Additional Instruments . Void Clauses . Independent Separate Covenants Modification and Waiver . Descriptive Headings Applicable Law . 2 3 3 3 5 5 5 6 7 8 8 9 9 10 11 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 19 19 19 19 20 20 ~~;~~ ~~,;.-~,-_. -"=--..; !\l!l:l''''~~olj;"':i'-''~''!'l!milM:"1/!!Jt-'iil~!;;!>Ifu-;''~-''JlID;!;...~;W~''=''-#N!ie;;~-=""'''. ~ , ",Ol"",'.:!. '~'~"_':'"'" "~""o,~'~:.''''',-,'~ " I: \~lient Directo::y\DeGeorge~C\A9reements\revisea Property Settlement Agreement.wpd , , . October 16, 2000 , PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this -10+h IJO\)e.tn'wYL. day of Oeteaer 2000, by and between Cynthia L. DeGeorge, of Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "WIFE") and Anthony R. Crayton, of Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "HUSBAND"): WITNESSETH: WHEREAS, the parties were married on July 8, 1991, in Rockville, Maryland and; WHEREAS, no children have been born of this marriage. WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of WIFE and HUSBAND to live separate and apart, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to the - I ~'.",,,",;;b,,,,,,,,,,~,b""~'.~~ ~ "- " .-'",;:';'.'.__'c_'-" ,'"0" ".,,~",,"__L,"i , I: \t:<lient Direoto~\DeGeorge'~C\Agreements\revised Property Settlement Agreement_wpd . , , Ootober Hi, 2000 V' , past, present, and future support, alimony, and/or, maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt 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. SEPARATION: HUSBAND and WIFE shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint or interference whatsoever by the other. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions shall not be taken to be an admission on the part of either HUSBAND or WIFE of the lawfulness or unlawfulness of the causes leading to their living apart. -2- ,"'% '~':'''cc'.,;\',,~, --,,'~,\1;" '-'. '!"'~7 ~l:"'" ,,,",,,, -',. '''~~~' ~ ",""_~."--'<''''c"",'>~,L"",,,~,:"''\',,,,,L'''--.l..__,, . _,,_J,', "__~":,,,,,".J,,~'.L,,""" it,""","" ~' ""'.'f,," "",'_' / , ~ ~ 4 I,\Client DirectOFY\DeGeor,ge'-C\Agreements\revised Property Settlement Agreement.wpd Oc;ober 16, 2000 2. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agreement shall not be considered to affect or bar the right of HUSBAND or WIFE to a divorce on lawful grounds as such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 4. SUBSEOUENT DIVORCE: The parties hereby acknowledge that WIFE has filed a Complaint in Divorce in Cumberland County, claiming that the marriage is irretrievably broken under Section -3- -~ --'--'-- -- _.0. -- 00'- - -. ~" ,'^"~-'--",-,,, ~~",~_',~'~,~,J:"-"_' ',,--,- ____''~'__'__'_.',,+.""_' ,co,~,_,,'__i , ~ ,. I, \).:lient DirectOfY\DeGeo~ge~C\Agreements\revised Property Settlement Agreement.wpd , Oc;ober 16, 2000 3301(c)of the Pennsylvania Divorce Code. HUSBAND hereby expresses his agreement that the marriage is irretrievably broken and expresses his intent to execute any and all Affidavits, Waivers, or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code when the requisite time frame has expired. The parties hereby waive all rights to request court ordered counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions of this Agreement as to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. should a decree, judgment, or order of divorce be obtained by either of the parties in this or any other state, country, or jurisdiction, each of the parties hereby consents and agrees this Agreement and all of its covenants shall not be affected in any way by such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. -4- '."_""."""""''''''''':,Ofr'''d'' ..'cj,<':.oo_'--' I,~Client Director.Y\DeGeo~e~C\Agreements\reVised Property Settlement Agreement.wpd , . . OC;ober 16, 2000 5. INCORPORATION IN DIVORCE DECREE: It is further agreed, covenanted, and stipulated that this Agreement, or the essential parts hereof, shall be incorporated in any decree hereinafter entered by any court of competent jurisdiction in any divorce proceedings that have been or may be instituted by the parties for the purpose of enforcing the contractual obligations of the parties. This Agreement shall not be merged in any such decree but shall in all respects survive the same and be forever binding and conclusive upon the parties. 6. EFFECTIVE DATE: The effective date of this Agreement shall be the "date of execution" or "execution date," defined as the date upon which it is executed by the parties if they have each executed this Agreement an the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7. DISTRIBUTION DATE: The transfer of property, funds, and/or, documents provided for herein, shall only take place on the "distribution date," which shall be defined as the date of execution of this Agreement unless otherwise specified herein. However, the support and/or alimony payments, if any, provided -5- "~"~' ";"',",~,~"",, ,'" ,'~', -'..',d..:,<o'.\' ",,;.. I_.i.'.do..'"..^" ~'JL'"~''' , '. .-, I: \Client Directory\DeGeo:rge-C\Agreements\revised Property Settlement Agreement.wpd , . oc~Ober 16, 2000 for in this Agreement shall take effect as set forth in this Agreement. 8. MUTUAL RELEASE: HUSBAND and WIFE each do hereby mutually remise, release, quit-claim, and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situated, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or 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 a testamentary gift, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth, or territory of the united states, or (c) any country or any rights which either party may have or at any time hereafter shall have for past, -6- < ''",----'--'0' ,;,>",jo-""--',~_-"~"~ ,~'i,>"C"'-""'\__"-"~';;"" ,--id':','~'d,__,,'e-- ,..__c'-""_,'"',, ,'c,'.____.-__'-:'n . .'. I:\Client Directooy\DeGeorge-C\Agreements\revised Property Settlement Agreement.wpd . .' Oc~ober 16, 2000 present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, division of property, costs or expenses, whether arising as a result of the marital relationship or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE to give each other by the execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed this Agreement shall be and shall constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite, or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 9. ADVICE OF COUNSEL: The provisions of this Agreement and its legal effect have been fully explained to the parties by their respective counsel, MARIA P. COGNETTI, Esquire, for WIFE, and MURREL R. WALTERS, III, Esquire, for HUSBAND. HUSBAND and -7- '..... , ';--,' .'''_"-'-'---'"---'-,,-''c', _""','~"""-""-,--",,,, '.,~_",--,-=""',3""'_,;,;-""",~" ."~--,,,',.' "-",--,,_1.,0' ,--,,-.',...,L --,,-,,_'n_ ,. ""c,. ,""-",,.-,,__','" '"-1,-''' _ , .~,'__ , . .', I, \Client Directory\DeGeOrge-C\Agreements\revised Property Settlement Agreement .wpd . .' . OCtober 16, 2000 WIFE acknowledge this Agreement is not the result of any duress or undue influence and it is not the result of any collusion or improper or illegal agreement or agreements. 10. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities, or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 11. WARRANTY AS TO FUTURE OBLIGATIONS: HUSBAND and WIFE covenant, warrant, represent, and agree that, with the exception of the obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. -8- ,i,,' _ _'C~, "~,'-,~__"~;.,..' .'<=_~,b, cd ",",,~,L=, ',';''''0',,"-' " ,,', J~:'..""' ,-".~',',c,' "' ,., 't~,-,'-" _--'--.. ",' I, . , . " I,\Cli~nt Directcry\DeGeo~ge-C\Agreementa\reviaed ~roperty Settlement Agreement.wpd . OCtober 16, 2000 12. DEBT OF THE PARTIES: WIFE agrees to pay and to be solely responsible for the debt owed on Visa Account No. 4118 1601 5512 0341. WIFE agrees to indemnify and hold HUSBAND harmless from any and all liability associated with said debt. 13. PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, and neither party will make any claim to any such items which are now in the possession or under the control of the other. should it become necessary, the parties each agree, upon request, to sign any titles or documents necessary to give effect to this paragraph. By these presents, each of the parties hereby specifically waives, releases, renounces, and forever abandons whatever claims he or she may have with respect to any personal property which is in the possession of the other, and which shall become the sole and separate property of the other from the date of execution hereof. -9- ,,','_,"--'-'-~~" c";-"~.J."",~"_~,"'.;h',,-,--~,,,,.-'-.,", k~,,- ",1 .. ". I I \Client Directoiy\DeGeocgeMC\Agreements\revised Property Settlement Agreement. wpd , , ,. Oc.tober 16, 2000 14. DIVISION OF REAL PROPERTY: HUSBAND agrees to transfer all his right, title, and interest in and to the real estate situated at 711 Charles Street, Mechanicsburg, Cumberland County, pennsylvania, now titled in the name of HUSBAND and WIFE as tenants by the entireties, to WIFE and agrees to immediately execute now and in the future any and all deeds, documents or papers necessary to effect such transfer of title upon request. HUSBAND further acknowledges that he has no claim, right, interest or title whatsoever in said property and further agrees never to assert any claim to said property in the future. HUSBAND agrees to execute a deed conveying his interest to WIFE, said deed to be delivered to WIFE's attorney pursuant to the provisions of paragraph 21 herein. WIFE hereby covenants and agrees to assume and to pay in full the remaining balance of the mortgage now existing and presently constituting a lien upon and encumbering the same premises, such mortgage being owed and payable to Chase Manhatten Bank, and further covenants and agrees that she will indemnify and save HUSBAND harmless from any and all liability, expense, cost, or loss whatsoever as a result of her non-payment of or non-performance of said mortgage and said mortgage conditions. -10- ~ .'" \d -., ~, ., , . _i "_"""'^'_c"---"-,_"c:.~"'"""'-''''.'"""-"--,-,,,~d;,,,,,,. ~'...u,-"~,..,j,, ,~',~",_.~~,~ ,~",,',,"i ., ",'L" . '. I: \Client Directo-ry\DeGeOLge-C\Agreements\revised Property Settlement Agreement. wpd . O~to~er ~6, 2000 15. DIVISION OF BANK ACCOUNTS: The parties agree that the Price Waterhouse Account No. 43802168 presently held jointly by the parties, shall become the sole and exclusive property of HUSBAND, and the GIT Account No.50360-4 held in the name of WIFE, shall become the sole and exclusive property of the WIFE upon the entry of a final Decree in Divorce. The parties acknowledge they have no further claim or interest in said accounts of the other and agree that each will not assert any such claim in the future. 16. DISTRIBUTION OF INDIVIDUAL RETIREMENT ACCOUNTS: WIFE hereby acknowledges and agrees that HUSBAND shall receive, as his separate property, free and clear from any claim, right, title, or interest on the part of WIFE, her Individual Retirement Account with Ameritrade, Account No. 17907709. WIFE hereby acknowledges that she has no further claim, right, title or interest whatsoever in said Individual Retirement Account, and further agrees never to assert any claim to this asset in the future. 17. PENSIONS. ANNUITIES AND/OR RETIREMENT BENEFITS: WIFE agrees that any monies which HUSBAND has acquired through his interests in either pensions, profit sharing, savings and thrift plans, annuities, and/or, retirement benefits through his present -11- - "',"---'""'.''''.'~, "",,-,__,-,,=.n="~' "~Ir"~";''-''''''''''d"'''''--'-'';'~'''''.::'..'~'~ "",,,,,;;":,,~',i '," ,.,:"","""""",,,;"'_",,: ,~-'-~'i=__ ; --"C_',,,"',.,',- . ,. I:\Client Directozy\DeGeo~e-C\A9reements\revised Property Settlement Agreement.wpd . October 16, 2000 . . or past employers shall remain his sole and exclusive property. WlFE waives any interest she may have in such property and further agrees that she will not assert any such claim in the future. HUSBAND agrees that any monies which WIFE has acquired through her interests in either pensions, profit sharing, savings and thrift plans, annuities, and/or, retirement benefits through her present or past employer shall remain her sole and exclusive property. HUSBAND waives any interest he may have in such property and further agrees that he will not assert any such claim in the future. 18. MISCELLANEOUS ASSETS: All other assets not specifically enumerated herein shall remain the sole and exclusive property of the party currently in possession of same. The non-custodial party waives all right, title and interest in the property in the possession of the other party. 19. MOTOR VEHICLES: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (al The 1998 VW Passat shall be and remain the sole and exclusive property of WIFE; -12- "',,=,,,'''''''''''",,- - '''.~n''''"' "h". "~O,,",~,,.,..,,",",-,,,Jo-,,,,,__ "="""_<'",1.,~"=",,,,,,,-,~,,,,, ,-"',",,,"__'<,"' >" "'''''',-,l-Wc..",~\'i,~ , "','-'-'.'."_ . " I:\Client Directory\DeGeovge-C\Agreements\revised Property Settlement Agreement.wpd Oc,tober 16, 2000 (b) The 1991 Jaguar XJS shall be and remain the sole and exclusive property of HUSBAND. The titles to the said motor vehicles shall be executed by the parties, if appropriate for affecting transfer as herein provided, on the date of execution of this Agreement, and said executed title shall be delivered to the proper party on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobile. 20. AFTER-ACOUIRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 21. PAYMENT TO HUSBAND: In consideration of the above transfers WIFE hereby agrees to pay HUSBAND the sum of $200,000.00 on or before ninety (90) days from the execution date of this Agreement. HUSBAND shall provide WIFE a fully executed deed to the real estate referred to in paragraph 14 herein in -13- .. '- '.' ,c,.--"""",,,-,, C' ,,,~,,",';~''-'', ;,i,,,o.,,..1.~"_',,,~:",-,;o",,,,, ,,' ",oJ"""" .".. . ,;~__,.;,,,,-,.._ ',;, '_' . . I,\Clien: DirectorY\DeGeorge~C\Agreements\revised Property Settlement Agreement.wpd . . Oc,tober ~6, 2000 exchange for receiving said $200,000.00 payment from WIFE. HUSBAND's counsel agrees to prepare the deed to the said real estate. 22. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint Federal and state tax returns. Both parties agree that in the event any deficiency in Federal, state, or local income tax is proposed, or any assessment of any such tax is made against either of them, each party will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 23. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed -14- "0;; ,,' e,"---"~""c',,,w. ~....:t.-.j.",.--,-,-",,--,"":,',",,",,~k",e.,,-='",~ !", ,,__Ie .L " ^' -,,', ",<I' "'"''-'-:''':' '. I; \Clie~t Dirscto:ty\DeGaorge-C\Agreements\revised Property Settlement Agreement .wpd O'itober 16, 2000 any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of the said Act. 24. WAIVER OF ALIMONY: HUSBAND and WIFE recognize and acknowledge that the foregoing provisions for their individual benefit are satisfactory with regard to their support and maintenance, past, present, and future. The parties release and discharge the other absolutely and forever for the rest of their lives from all claims and demands, past, present, or future, for alimony, alimony pendente lite, or for any provision for support or maintenance, except as specifically provided for herein. The parties further acknowledge that in consideration of the transfers made herein each completely waives and relinquishes any and all claims, and/or, demands they may now have or hereafter have against the other for alimony, alimony pendente lite, spousal support, and counsel fees, except as specifically provided for herein. 25. EFFECT OF DIVORCE DECREE: The parties agree that except as otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. -15- ~, ~""-~" """"-";" ,"c1,,~o,~' ",,;,j"__~'''''~~'='''',';,.;~'''''-'i.dc~ ,,', . .,''''bn__'-<,'-t,""-',"_' '0' .~",',"_,=,'~;"'__, ~'" ":""~~"'''' , " . I'\Clien~ Direct~iy\DeGeOrge-C\Agreements\reviBed Property Settlement Agreement.wpd OrJtober 16, 2000 26. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 27. WAIVER OF CLAIMS: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she shall now have or hereafter acquire, under the present and future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, widower's allowance, right to take in intestacy, right to take against the Will of the other, and the right to act as administrator or executor of the other's estate. Each party will, at the request of the other party, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. -16- ,,'_',' ,-,,-""",', ";,~~"c.~",,,--,,~,,- ,,,,,-,--2~'J' " ""'"C,C'",,,,,,,c'.". , I,\clie~t Di~ect~~\DeGeorge-C\Agreements\revised property Settlement Agreement.wpd . Ol!tober 16, 2000 28. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. 29. FINANCIAL DISCLOSURE: Each of the parties hereto acknowledges that he or she is aware of his or her right to engage in discovery, including, but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories and appraisements, and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of civil Procedure and each of the parties specifically waives his or her right to engage in any further discovery than has heretofore been conducted. Each of the parties further acknowledges that he or she is aware of, and specifically waives, his or her right to have the real, and/or, personal property, estate and assets, earnings and income of the other party assessed or evaluated by the courts of this Commonwealth or any other court of competent jurisdiction. The respective parties do hereby acknowledge, recognize and accept that there has been disclosure to the other party of his or her assets and liabilities, and each party agrees that any right to further disclosure, valuation, enumeration or statement thereof in this Agreement is hereby specifically -17- '","",,' ...."-=--~""'*"'....~;,'<,"" <~ '."" ~"'~", ,~~ ,> ,.~.__' ,,"--~,",',,' ,-e",__ ";~"",,, ,,- I;\Clie~t D~rect~~\DeGeOrge-C\Agreement8\revised Property Settlement Agreement.wpd {, . . 06tober J.6, 2000 waived, and the parties do not wish to make or append hereto any further enumeration or statement. The parties hereby acknowledge and agree that the division of the marital assets as set forth in this agreement is considered fair, reasonable, and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself or herself and his or her heirs, executors, administrators and 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 duress, or undue influence, or that there was a failure to have available full, proper, and independent representation by legal counsel. Each party does hereby waive any right that he or she might have under the Pennsylvania Divorce Code to seek to impose a trust on any asset not disclosed or because the other party failed to file an inventory and appraisement with the exception of disclosure that may have been fraudulently withheld. 30. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. -18- "l"".c;:~ '""_'('",:-"'''' ".-'" .",.' ,,,__,,,;'~,,,-,-",",,,,,,,, ",,' ",k,.,;-~"-;;>",,,<,L",,",", -- ,"" ~.",'_""'c,.,-"~'--_"----c,' I:\Clien} D~~cto.~\DeGeorge~C\A9reementS\reViaed Property Settlement Agreement.wpd ,', . . O~ober 16, 2000 31. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other party, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 32. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. 33. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent Agreement. 34. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not -19- :M; ..- ""w.-\; " "~-'<<,", ~ " "I ,,'-',',~= "~,~,.~~ _d"-'"''''''',~'~J,'' .'to ,~.,,~,,~. ~'o: ,I, '.., L,,',~:J,'c~," ~,,'J " ",~-'-'~ -' __'J-<-'-'-~' I, \ClienJ; DJ,:t"~ct'i:~~DeGeo:rge-C\Ag:reement8\reViSed Property Settlement Agreement.wpd . , .' O~tober 16. 2000 be construed as a waiver of any subsequent defaults of the same or similar nature. 35. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no affect whatsoever in determining the rights or obligations of the parties. 36. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980 and any amendments thereto. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. WITNESS ~~rf.or CY HIA DEGEORG (SEAL) (SEAL) -20- .,'J'~:' "'4:;" ,~". ~""'~~'" -<""" ,'~" .. ~''."'" -~'=>ai,,' ='''0 .'"""~=,,-,,,_,,"'-' ,""',"'-.0,,,"'" ~ ' ., 'lI! I, \Clie~ D:i<rEct~\DeGeorge-C\Agreements\revised Property Settlement Agreement.wpd .. ~;:~. O~tohe.r ~€, :wnn COMMONWEALTH OF PENNSYLVANIA COUNTY OF (!'().tn~/ o.fl.J ) ) SS: ) .~ h^_ On this, the ~ day of NO{f(;(})UJUL ,2000, before me, a Notary Public, the undersigned officer, personally appeared Cynthia L. DeGeorge, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. N Notarial Saal Karan A. Sheriff, Notary Public Harrisburg, Dauphin County My Commission Expires March 9, 2002 Member, PennsyNania As5CCla\\on.! Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cu.m~ ) )SS: ) On this, the fo'f+-. day of !UoIJunUer ,2000, before me, a Notary Public, the undersigned officer, personally appeared Anthony R. Crayton, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. D~M.~ Notary Public Notarial Seal Diane M. Smith, Notary Public Mechanlcsbu'\l Boro, Cumberland County My Commission Expires June 22, 2004 -21- .;",_hr."""'" "".- " _""', i,,,-"Ol,'",,,,, ,,' ':"",-'~C.,O-"JI",'~,'," ,',,,",' ~",", ",v'..;,., ',,;, ~",,_L ~,,~.i. , ~ MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview A venue, Suite 102 Camp Hill, P A 17011 Telephone No. (717) 909-4060 Attomeys for Plaintiff CYNTHIA 1. DEGEORGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6059 CIVIL ANTHONYR. CRAYTON, 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 ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant's attorney, MURRELL R. WALTERS, III, on the 18TH day of September, 2000. 3. Date of execution of the AffidavitofConsent required by ~ 3301(c) of the Divorce Code: by Cynthia 1. DeGeorge, Plaintiff, on January 2, 2001; and by Anthony R. Crayton, Defendant, on January 2, 2001. 4. Related claims pending: Settled by Agreement dated November 10, 2000. .W .",. ~, ,> >.1' ..'::o"">0I!-,__, _, "c_''':'':" ,', "."'"~''' ..Y'-'i 5. (Complete either (a) or (b).) (a) Date and manner of service of the Notice ofIntention to File Praecipe to Transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in 9 3301(c) Divorce was filed with the Prothonotary: Filed simultaneously herewith. Date Defendant's Waiver of Notice in 9 3301(c) Divorce was filed with the Prothonotary: Filed simultaneously herewith. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: January 3, 2001 By: MARIA P. COG TI, ESQUIRE Attorney LD. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff .",'''"' ',. ~,",__l,', '."",,,' ,",'". ',.",,"----< '" ' .' "' <".~- ,~ ' !i*i.,; <&. .~~, ,. CYNTHIA 1. DEGEORGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. fJ1J ~ h 0.j1 ~ ANTHONY R. CRAYTON, Defendant CIVIL ACTION - LAW IN DIVORCE 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. 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 office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 .' '~ ~ .. ..- ,- REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717)763-1383 Attornevs for Plaintiff CYNTHIA 1. DEGEORGE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. tnJ .t-.OJ-9 (!..;;J ~ ANTHONY R. CRAYTON, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Cynthia 1. DeGeorge, who has resided at 711 Charles Street, Mechanicsburg, Cumberland County, Pennsylvania, for the last eight years. 2. Defendant is Anthony R. Crayton, who has resided at 255 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, for the last three months. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 8, 1991 in Rockville, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. .. ~ '",._,--~~~ " " - " :at.~ ,- .... " 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. COUNT I - DIVORCE 9. The Plaintiff avers that the grounds on which the action is based are as follows: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court enter a decree in divorce. Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date: August 29,2000 By: - 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for Plaintiff ~ ' "' ' ,., ,,', ".- liiil1:i!k,l ;;;i. '. REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attornevs for Plaintiff CYNTIDA 1. DEGEORGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6059 CIVIL ANTHONY R. CRAYTON, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, MURRELL R. WALTERS, III, ESQUIRE, do hereby accept service of a true L copy of the Complaint in Divorce directed to my client, above-captioned matter, pursuant to Pennsylvania Murrell R. Walters, III, Esquire DATE: C((t.uO I:\Client Directory\DeGeorge-C\Pleadings\Affidavit of Acceptance ofService.wpd I, ~ __ ,',~",____CJ ,,/ ..,' ", ,;,^ U',<--,""<< ilii r '. MARIA P. COGNETTI & ASSOCIATES H. ALLISON WRIGHT, ESQUIRE Attorney LD. No. 60311 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff CYNTHIA 1. DeGEORGE, Plaintiff, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-6059 ANTHONY R. CRAYTON, Defendant. : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 1,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify 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. S4904 relating to unsworn falsification to authorities. Date: / -':;-6/ ~~9 C TRIA 1. DeGEOR - . -'".2:' .. ~ ',,> , "', ".,,,,~,,",,-,", ",""".~~",,,,,,"=,,,-~i""',,...,,,.,,;,,"'____,",:,,,-,,""; ,~H'",~,,,, "',' ;, ''''--'-___<0_ . ....... -- MARIA P. COGNETTI & ASSOCIATES H. ALLISON WRIGHT, ESQUIRE Attorney J.D. No. 60311 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff CYNTHIA L. DeGEORGE, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 00-6059 ANTHONY R. CRAYTON, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330HC) OF THE DIVORCE CODE 1. I consentto 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 of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. ~~o CYN A 1. DeGEORGE y Dated: /- J-O / .' ,~,'''''''''.,rr;"r'~ ,"-',Mt"%->-"='''"' ,,'v. .,,,,,",,"""-':J,"'"'''''' ",,~~,_'" "'''''' ,; "~ '0 .' '->>l; _ -." ~,.,,",,--, ','i&;"'.r"~>"",,,,,,,,_:,,,,~,,-,"'---'w--~';""'-''',])~o_~''''o.h,,,,,-;,,'=;,"'<,.;," ""'0_-'-"'" \,' ' *- .- >- CYNTHIA 1. DEGEORGE, Plaintiff, v. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-6059 ANTHONY R. CRAYTON, Defendant. . : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 1, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to Date: / -,}- D/ unsworn falsification to authorities. ANT .",,.. ,'~ ,- _ _ """''''' ",,_. ,""'''''''', ,-,,,,...,,",, '~>7''',' ".~,~ , . .'_' ,-,0-""',-. ,,,,, "'",~" -~, '~"<-d;,"';-'l'-"~""~"-",,,,,,"-'H!.','^ " --',~'._~-',.'~'---~ . . '"'t " .- "- CYNTHIA 1. DeGEORGE, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 00-6059 : CIVIL ACTION - LAW : IN DIVORCE ANTHONY R. CRAYTON, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301((;) OF THE DIVORCE CODE I. I consent to the entry of a fmal 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 of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 to authorities. Dated: I -qJ - (j / ..,- .'#,." ," ,.",...,.~,.~O""".. '''~~'='-''I< -, "",,, < _A,_ ~~'''',' .,'"., A".", ',""< ,", ~.-",-,'C,.s-,'" o,:.c,,-,~ ~'-'"J_ ,',' "~""'-''''"~,,,,,,,e,,,,;Lc';-,! ,;~,.-:, . ....... MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 210 Grandview Avenue, Suite 102 CampHiIl, PA 17011 Telephone No. (717)909-4060 Attorneys for Plaintiff CYNTHIA 1. DEGEORGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-6059 CIVIL ANTHONYR. CRAYTON, Defendant CIVIL ACTION - LAW IN DIVORCE PARTIES' SOCIAL SECURITY NUMBERS CYNTHIA L. DEGEORGE, Plaintiff SS# 218-74-1626 ANTHONY R. CRAYTON, Defendant SS# 577-92-3741 ~,~,m-g -'. _~,_~,~"~",~""~,~,,,,,~,>,,,,,w,,,,_,,,,,,,,,,,'~'~,".,~,,,,""""w.W'''''''C_''.'~'''-''''~' .~. '-~#.~=..."'~-"'~~ ~,-,,,~,...,,,,.,'.