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Home My WebLink About99-01771 (2) c ~i , b ..~ ...~ " '''( hi 'ii" " " ." " " '" I " ,I " " ". ',\ " ,'1' " "I' ;, , " ., " i: 'I ., I. " '/ " " " .. II II. ... ." I' , " ,. " " " , " ., " , " " " Ii. " " " " " i' ., , 'r!' ,. " " " " " '11 " ,. " " ", '!II'1 ~ '. I' 1\", ,i" ,It " ,~ ; ,I. ,; Ii ,. " I'" " ",-' " .j-, 'I"~ . ", '!.f " " ,,/. " .," .,j,' " ,. " Ii '.' , I,' ..' " " , " ,"-', ;..-, ';' '" " " >,';i '. L'I ,. 11-' " f! c...., >0. M l'" ~ M .. ~~'J'r. tJ;J.) (" ) ,~. C..Jtl} ~l:: ; "Ji~~ f!::'.1': 0.., .' ~(. ,')1;' ,)i:'~ 'Il". ~, nl. '\(;?- r~p: f:d r .:~;: rCblJ f (I~:) P-1 c:..'1 II.) P' ... 1, ~ \flJ 2, f.:l ,. . , . " , " " " Ii , .. !I n 1" .. " f\ .. " , 01' '-i' , .. ,. ". .' " f4q( " I, It " 'i t< 'I I' ,. " II I. I: " " ~ ' " I' " :I' " d II" 'I;, H " " l' " h , I, 'I " , I" @. In :>0, ~ I,., ~ .. .~ ' ~~ -- i'~I~' :r. @i A,; "I..l;~. In IJl;:' ~ :1' {!? @ ',I\!i 'b~ 'f'lre (- fl. t!5 , ~, I'j " \, I! " " " '-I' " 1-,; ""f I' " i.,!._ I, ;< I/;,A 1'f:.:1 7 t, .' "';; i\ iI' h it " '" " ,. .' "I, .' iI I!, I' ;, ,. "jl "I J! l' \: 'I' 'i' 'i j' I' " \' Ii ,. ", ,i' , . 1: II "I ;, " ',Ii I', "-", II '11, P,. I"" ,( "II " '. " . ~ I , . " ~:.~: :~'. :l+:: :,:~:': ':+~ ::~:',::+:'. ':1"', ::+!'. '~+:: :~', 'l+:: ::~:' .':.~'::!:'.~+:'.::~:'. ::+:' . ':~:::.:' ;': ':+:': ':+:':':;;":+::',' ::+:' .'~+::::+?':':f~::~ ~ ~ ~ : IN THE COURT OF COMMON PLEAS ~ : OF CUMSERL~ND COUNTY ~ ~ STATE OF I~~-':'~' ~ Pl=:NNA, ~ ", .~,,~ ~.I" I I;l ~ I!l ~ ~ BnOOK ~III1IJ;R I, $ , """ " No, "~nl...~,~~~l,,,,,,,,,,,,,,,, II) 99 ~ ...... II ~ ~ VOI'""11 $ ~ IITlilPlIMIIID I..ABIIEfI I!l .~ .. ...., ~ ~ ~; ,{I ~ $ " ~. ~ ~ Iii T'1 ~ 1\ ~ ~ ~. j iii ~ * ~ " ~ $ ~ $ ~ ~ DECREE IN DIVORCE S :: ~ ~ $ ~ ~ ".Ii ~ Ilv T 0 coW.:... ~'-/ . r1- . .~ , : ~ MIII.II c;i t1f... , ,(~ Xtly ~?...,;t.",.~ . , ~ ~ </1t(Itt:l' K >>!Yl, JJi~ ' . ~ ~ " 'l'olhnllnlol'V ~ ~.::"">>:'-~::'::+::-:i::'.>>:. .:.~;::.r-.,:.::-;:.:. '.~.::'::':;":i..::-::.:;' .:+:.-',:+:. .:+:. .:.:. .:.:- .~.:' .',:+:. .:.i. ',r.:: .:.~, ',:'.:. .:.:. .:+:. .:.1' .:.:. .:~:~ l!i (J l!I I, ~ ~ ~ til ~ ~ AND NOW, " " , " " ,,1wf-1, "r-.1:" " " 19, ~1... It Is ordered ann Ilroolt I,a/lhlJr I I Iff decroed that """,."."""""....,. t , , I , , t , , , . t , , I , , , , ! ' 'I f) a nt , and. , , , , t , , , , . , , , , ~~I~~~~~~~, ~~~l~7, , , , , , . , . . . , , , , , , , , , , , , . . t I defendant, are divorced from the bonds of matrimony. The court retains lurlsdlctlon of the following claims which have been raised of record In thlu action for which Q flnnl order has not yet been entered: . ~f1J€ " ,.",."".,.."...", """"""""""""", """""" 0' 0 0" .", 0 f ,oo,'!"" " 0"'" 100""'" """ 0" II I t ,..0""" ,.,.. ~ ~ " aROCI( I-AsHf.R, Plplntlff VB, IN THf. COURT Of COMMoN PI.f:AS CUMI3f.RI_ANP OOlJNTY, Pf.NNsYI.VANIA No, 00. 1771 ACTIoN IN OIVORC!:, smPHANIf. I.Af.lHf=R, Pefandanl MABBLMiUIHIl.eMIiNlAGBliliMliNI.lUilWGliN IUillClU.AlIIIGIi1INDJlIGP-IIANllUAlIl:lliB . 11116 AGRt:aM~NT mllCle thlsl::.(lI) ctay of (.J(J/,!, 1000 by I3ROOI< LA6Ht:R, an adultlnctlvlctual of Oumperlanct Oounty, Pennsylvania 1 anel STr:PHANIt: I,A6HaR, actultlnctlvlctual of O\lmperlanct Oounty, Pannsylvllnla, WITNa66r:nl: WHt:Rr:AS, the pmlles ware merrlect on January 23, 1000, In Oumperlanct Oounty, Pennsylvania, put they have since separated, anct; WHr:REA6, WIFE and HUSI3AND have reaohect agreement on financial anct property matlere arising out of a pandlng divorce aollon petween tllftlll: NOW THr:RaFORl=, Intending to be legally bOlmd hereby, the parties hereto Elgree as follows: 1. LIVING III:PARATl: AND APART, That tha parlleslntend to maintain eeparale anct permanent ctumlollea and to live apart from each other, Ills the Intention and purpose of this agreement to eet forth their respeollve rig hie Elnd dulles while they continue to live apart from eaoh other, Whereas a Oomplalntln Divorce wae flied, both parlles will agree to Il No..Fault Divorce after the eppllcable nlnaty (00) dey lime period hae run, " The parties have atlemptedto dlvlda tholr matrimonial proparty In a manner whloh conforms to a Just and right standard, wllh due reoarel to the rights of eaoh party, Ills the Intention of the parties that such dlvlelon shall be final and forever determine their respective rights, The division of exlslllng marital property Is not Intended Py the parties to conslllute In any way a sale or exchange of assots, Further, the partlee egree to continue living separately and apart from each other al any place or places thai he or ehe may select, Neither party ehall harrass, annoy, Injure, threaten, or Interfere with the other party In any manner whatsoever, Eaoh party may oerry on and engege In any employnllll1t, prOfeSSion, business or other eotlvlty as he or she may deell1lldvleable for his or her sole lIse and benefll, Neither party ehalllnterfere wllh the lIses, oWJ1llrahlp, enjoyment, or ctlsposltlon of any property now owned anct not epeolfled herein or property hereafter acquired by Ihe other, . .. 2. PROPERTY, Except as may otherwise be prOVided In Ihls Agreement, Wife agreea that all of the property of Husband or In his poeaeselon shall be the sole and separale property of Husband; and Husband agrees thel all of the properly of Wife or In her possession shall be the eo Ie and separate property of Wife, The partlea do hereby specifically Waiver, release, renounce, and forever abandon whelever claim, If any, he or sha may have wllh respect to the above lIems whloh shall become the sole and eeparate property of the olher, The parties agree Ihat their property Is tCl be dlvlcled ae followe: ~ A, MARITAl- RIl8IPIlNOI'!, The parllaa aollnoWlaqoe Ihat they ownoq, as 10nllntslJY Ihe ontlrlltlas, rOQI pr01lorty Imown as 110 MoaqowlJroo!1 RO,ad, Oarllslo, OumherlQnd Oounly, Ponnsvlvunll'! 170 3 (horelnaftar rofarralllo aa Iho IMrltal roalllonco), Wife has Irl'!nsfflrulI 10 huapanq, ell of hor rloht, tltIO, and Inloraat In Ihflmarltol raslelonco, sUPlaol tll Ilnv oUlsll'!ndlno doPI asaoola\~d willi Iho marllal rosldanea whloh allollllllhuatlOnel'a solo and oxolualva roaponallJIIIIV, Tllolollftor, hualJand shall 11Il Iho aolo and oxclualve ownor of Ihe marllal roslcjonoo froo Ilmi oloar of I'!I1V rlOhl, tltIo and Inloros\ or wlfo's, 1'1uallEmq slmllbo aolely reaponsllllo for oil ravmenla uf Illxaa, ulllltv ollaroos, morlOl.1llo pllYll1ents, aas08smanls, anll l11alnlonanoe OOS\s 0 the l11erlllll reslclenoe end shall Incjamnlfy wife Ilnd hold hor hmmless from alW responslhlllty Ihareof, 13, MOTOR VatilCl.1l8, Wllh respl.1ol 10 the motor vehlolus, ownell by one or IJOth or Ihe pmtleu, Ihey aorae ae follows: I. t:aoh party aorees to be solely responsl11lo for tile amounts presently due anel owlno aOlllnsl his or her rospeotlvo automobiles, II, Wife sllall rolaln possasulon of thn 1 000 ~X.2 !:scort, III, Husbanel shall retain poasosslon of tho 1006 Ford I~anoor, 0, PI'!RBONAI. PROPERTY, I. Wife shall obtain ous\ody of tlla coupla's d09, Samaon, on or ahoul July 17,1000, 0, MUTUAl. WAIVER OF IlMPl.oYMENT 13E!NliFIT8, Tile partlos aorea 10 walvo any and all rlghta Illey have In and to eaoh other's ell1ploymenlbel1eflts, Inolulllno butllolllll1llod 10 both partlaa pensions and retlrelTlont plans and Inr.enllve Savings Plans, The parlles a~ree never to a~sume any olalmto suoh benefits of the other al any tlmo Inlhe future, 3, OEaTB, Wife represents and warrants to Husband that slnoe tho seperallon she has not and In Ihe future sha wlll'1ot oontraot or Inoll[ any deht or liability for whloll Hl.Ishan(1 Of his estate mloht he responsible and shalllndllmnlfy and save harmless Husband from any and allololms or demands made aoalnst him by rsason of debts or oblloatlons Inourred by her, Husband represents and warrants to Wife that slnoe the separellon he has not and In the fulure he Will not oontraot or Inour any deht or liability for Wllloh Wlfa or her ostate might he responsible end shall Indemnify and save harmless Wife froll1 eny And all olalll1s or demands made aoalnst her by reason of dobts or obligations Inourrod by him, 'Wile agreee that tha followlno debts ara her own personal responslblllly and therefore agrees to complstely and finally pay on tile follOWing dehts and ohllOallons: Any and all debts In her Ilamo olone regardlsss of whenlnourrod, Husband aorees that tho follOWing debts are his own personal responsibility and thereforo agrees to completely and finally pay on Iho following debts and oblloatlons: Any and all dsbts In his name alone regardless of whonlnourred, " A, PRI:PIT OARPli. I, HlIab~nel will PIIY oH tllo Oornoralono Orodll oO[cl, whloh 11a8 II llalanoe of approKlrnaloly $400 IInllllhll oreelll oardla oomplelely paid ofl,Aflllr tlwl limo, Ihlallam! will oblaln a ore lilt oaret whlohlaln hla n~lm' III0n(:), II. Wife will pay Ihe Oorneralono Oroellt Oonaolldl1l1on loan, whloh hoa a ollrrllnlllalenoe of approKlmlllely $1600, Wllhln Iho nOKl60 dllVO, Wlfo ahnll ntlomPllo [Jol anolher loon In hor nrune alono Ilnel pny Ihlll jolnl dehl off Immediately, 4, ,INOOMI! TAX RaTUANB: All ourrant and /lituro Inoome tax returns sholllla flied sepr\[elely onel the rehmd8, If any, aholl be relalnm! IlY Ihe reopeollVIl partllls, 6, BJJOUBA~ BUPPORT ANP A~IMONY: Hoth parlllls horllby wnlvo onel forllgo all flnonolal and malerlal apollsalaupporl from Ilaoh olhor und ngroe nol 10 requesl or seoll 10 obtain olhnony or spouaal supporl hofore or oftllr any dlvoroe whlohmay be manted, Q, PIVORO!:: The partloo agree 10 oooperate wllh each olher In ohlalnlno a final Iflvoroe of Ihe marriage, n Is nmeedlhal al final aeltlemenllhe parllea will exeoule and file Ihe consento neoesaelY to ohlaln the divorce, Ilia furlher ooreed Ihellhe parties' marrlaoe 10 Irrelflevahly proken, '" BRI!AOl-tllf ollher porly breaohes any provisions of lhls ooreemanl, Ihe other parly shall hovs Ihs rloht, at his or her eleollon, 10 slle for damaoes fllr suoh breach, or seell olhsr remedies or relief aD may ho avollallle 10 him or hor, nnd the parly hreaohlno Ihls conlraot shollld ho responslhle for paymonl of logal foos and costs Inourrod Ily Ihe othor In enforolno Ihelr 1'10 hIs under Ihls aorsement, 0, APOITIONAL INIHRUMI!NT8: r=ach of Ihe porllos ahell, from lime 10 time, allhe request qf Ihe olher, exeouto, aoknoWledoe, and deliver to Ihe olher party I1IIY and all further Instruments that may be reasonebly required to give full foroe and effool to the provisions of Ihls agreement, II, VOLUNTARY I!XI!OIJTION: The provisions of this aoreemenl and their leoel effect heve besn fully Clxplalned to Ihe parties and lis provisions aro fully IInderstood, Husband's leoal oOlll1sells Jane Adamo, r=squlre, and wlfa hes no oouneal. Both parUos aoroo that they ere exeouUng this eoreemant freely and volunterlly, 10, I!NTIRI! AGRElMENl This aoreement oontalna Ihe entire underolandlno of the parties and Ihern are no representations, warnlllllee, covenants, or underlaldnos other than Ihoso expressly set forth herein, 11. APPLICA13LI! LAW: This eoreement shall bo oonstrued under 1111.1 law of Ihe Oommonweallh of Pennsylvania, 12, PRIOR AGHI!EMI!NTB: It Is understood and aoreodlhat any and all proporty solllemant agreemonts whloh mayor have UOAn exoouled or vorballl' ellscusoed prior 10 Ihe dala and tlmo of Ihls egreamant are null and void and or no effeot, 13, WAIVER OF OLAIMS AGAINST THI! EBTATI!8: r=xoopll1s herein otherwise provided, oaoh parly may dlsposA of his or her property In any way, and eaoh party hereby walvos end relinquishes any and all rlghls he or she may now hnve or hereaftor ecqulre, uncler Ihe presenl nr futuro lews of any jurlsdlollon, to shora Inlho properly or tl10 estalo of the olher as a resllll of tho marllal rolallonshlp, , ''I " " " f',:,. "". 111 N 4'h. \~i ," IIlh ;,;:'ir(.' '1..1 r.~' f..,lr'l ~t..: I.J =u. It- I c..'l., !")~l (,)1:: r'1'! In ~k \Y~ ,..\ \, ~ i\J(~ IT ",1 t,,1 ~\~~ p. "\' ~J I '1 1~'1 (1, C) (,1\ 'l " 1/'- :: " " " Ii II \j "-,! . . " i\ " , ,j " 'i. "j,' ,I, " ". 1(;, " " .' " Ji Ie 'J, 'j' 1\, " " "II " , .;7,:'- t~ TJi " .. 't' ..oJ' " ~ ~ B'" t_: I ~ " r::: f,i , 1.1"., , ~:t- ~J Q;, f'~I' , '0 8 ~ j'l II, , , I 0 ~ i:lt, In " (.., R fr)' ; 1",,/ , (,1 . , ':1:1 n.II' (." I I 'I \..f {~ ',f; ! '1.\. f'-. 1-1 (. ~, ~, I, tJ llJ (,n '- -~ (n Ll .~ rJ.. , 1\ ,Ii " , . ..... ~J ~ ~~~es' ~ ~~ ~ ~h~ \:; .... ! " I .. ~- -, I" (: \'-.1 :,1..1' ,,' f~,1I": ".( I \.,l [I:.' It. 'I fl.. (!l/, r'-l:'.; 1(' r'o, ',;i;:-j [/' I I. I ,1'1 fr-l} 0:: Iii [I i' (" 1!l1.; ..c I'i " m ::.'J () H ,,' " " ... , ~~h ~m~ ~ ~~~ ~.' ..... II ,\ ;' " ,......, iIC""'I ....... ..... " , ' . I' j I3ROCI~ 1-A13~II:R, Plaintiff VB. IN TI'II: CQURT or COMMON P~J:A8 CUMI3I:RLAND COUNTY, PJ:NNSY~VANIA No, 00 - 1771 ACTION IN DIVORCI: ST~PHANII: ~AS~II:R, Defendant AF..fJDM'lt..QE..Q.QNJmNI . 1, A oomplalnt In etlvorca uneler aacllon 3301 (c) of the Dlvcrce Code waa flied on March 26, 1009, 2, The marrlaoe of Plalnllff ancl Dafendant Is Irretrlflvaply hrol<en anel ninety dllya have elapaed from the dllte of the filing of the Oomplalnt, . 3, I conaent to the entry of a tlnal dllcree of divorce, 4, luncleratand that I may IrJse my rights concerning alimony, etlvlalon of properly, Illwyer'a feea, or expenaea, If 1 do not olalrp Ihem hefom a divorce Is granted, lunderstllnd thllt the atatemel1ts made In this Ilffldavlt Ilre Irue end correcl, I Illso understElI1d that falne atlltementa theraln Ilre made sUbJeot to the penallles of 10 PIl,O,S, 4004, relallng to unsworn falslflcallon to Iluthorltlea, 'L- Pale: "I1,';l, ~)I'\ ~ ~~ 0Ilt((/~2/n<<!JiC?~ . lep n e l.a~!l!!r..o..Jlf&neiailt ,/'~.-/ (.-~- WAIVBIU1E..NOIIQJlQEJNIeNIlQl\I TO RBCU,ellJJ;litBY..QI'.AD.l\lQBQJiQIIDBIia. UNDJ;B.Aaa.o1{IlUJf_1:I:I~Ill'iQROB CODe 1, I consent 10 entry of a IInal deoree of dlvoroe wllhout nollce, 2, I understand that I may loae rights conoernlng Illlmony, division of property, lawyer's fees or expensen If I do not olelm them before a cllvorce Is grantecJ, 3, lunderslllnd lhat I will nol be ellvorced until a dlvoroe decree In entered Py Ihe Oourl end that a oopy of the decree will he sant to me Immediately after It Is flied Wllh the Prothonotary, I verify Ihat Ihe atatemants mada In this affidavit are true IlIlCI correot. I underslancJ that false alalemenlB herein are mede sUbject to the penaltleB of 10 Pa,O,S, 64004 rei Ung t unsworn falalllcatlon to authorities, r:? . .L / l lie ~::9i1filndan t.-,~ Pate: 'I \ d,d,) '\ 9 /!, " 'I' I, /, i, " " ;1' Ii \: i\ .;.. ,,' I ,~ '\' ,I' " .. ic , ii " II q i' I' " '" " " \' " " 1'2 cq ~' ;, I; In . ~~ " j':.. H (11 -, ,:'~"'S ,j' ~".. :' r t:., ).ic, ',-,- C).t!, .. /,"0 .,,~, .~~ " ... 'r' ".. '::)1.:,1 " (l'l.. ". J'r" " [j- c\') '! .;r' l) I" I /'" C'J I"' I (I. (Jl~ " f~11 t 1:..1 " " " If i'," ;;:.t ih1.: I.. i ui ' p, en " ..j ,'r\ I ~) 'Iii i\ " i' " ,f 'i I. " i< I; II 0; \1\ .. H ';, " " ""I '. 1< .1 " " , " , " .- + , '-11 " 13ROOI< I.ASHF.:R, rl~lntlff VB, IN 1l11= OOUIU OF OOMMoN PI,I=Aa OUMaf:I~I.ANP OOUNTY, rf:NNSYI.VANIA No, 00. '17'11 AOTloN IN lJIVOI~or: STf:PHANIf: I.ASHf:R, lJefendnnt l\EEllll\ VILClE. 0 ONlll:NI 'I. A (lompl~lnlln cllvorolJ IInder seollon 3:\01(0) of 1I1ll Dlvorco Oocto wos fIIOlf on fI1oroh ,!6, 1000, ~, The marrl~oa of Plnlntlff uml Pefen(l~nt Is Irrolrlovullly Inolcen un<t ninety duys hove elapsad ff(Jmlhe date of Ihe filing of the Domplalnl, :\, I oonsent 10 1I1ll enlry of a IInal (Ieoroo of (IIvuroD, 4, IlInderstand IIml Imay losa my rlohls oonoornlno nlhnony, division of property, lawyer's fees, or eKpenses, If I do nol olalm them before a cllvorce Is omnlecl, IlInderslan<t thaI 1110 alulamenls modo In Ihla nffldavll me trllB and oorreol, I also IInderBland Ihat falBe slolemonls Ihereln are made BlIbjeol to Ihe pe@llIes of 10 PRC,S, 4004, relallno to unBWOrn folalfloallon 10 alllhorlllos, Polo: 7/~ a/0 'j I 1.1 d / !,) ,((>-;";-" (/ ,Loftl. ,.' aroolc I.aaher, Plaintiff WAOlell.QE..NO.ILQ.J;.QEJtiTetiTIQN .IOJleColUllllI.etiTIlY...QE..l\.lll\!.O.RQlU2I;Q.llee. llNI2IiB,!lUII1(gLQE_tt1F.J!lV..QRQ,fi.QQDC 1. I oonsent to enlry of a IInal deoree 0' dlvoroo wllholll nollr.o, ~, IlInderstand Ihal I may lose rlohts ooncernlng olhnony, division of properly, lawyer's feas or eKpenses If I do not ol~lm Ihem before a diva roe Is omnlelj, 3, IlImlerBtand thaI I will not be dlvoroed IIntll a divorce demee Is enterod by tho CalirI end Ihal a oopy of the deoree will be Bont to me hnmodlatoly after Ills flied wllh Iho Prolhonotery, Date: I verify Ihal the Blatemonls made In this affidavit ow Irlle and oorreot, I understand 11101 fBlse stololllents horoln aremado Bubjeol to the penalties of 10 Pa,C,S, 94004 rolollng 10 uneworn folBllloollonlo OlllllOrllles, :" /,.4,"'" J ';G/.tt"?1" t(, /"_'fk_/ arook LOBhel', Plolnllff 7 I;), ~/i) " " " " 1", " j' ". ; " " ,,' " " " " " " d I' '\' I,! " ;, ;. " 'il H I {,f " , , '11 " ",. " I' ;, " 'j. " .. " " " " , , JI' (!,,' " " "1, " " " I: .,' " " .' Ii IIIUlCI~ LI\lilllq~, I'lnlnllmH~~llflncl~nl v, , IN TIII~ COIJHT UF COMMON I'LI~AS I ClJMllImli/\Nn COlJNTY, 111~NNSYI.v ANIA , , , NO, O!H771 I , I I CIYIL ACTION. LAW , IN U1YOIWI'; STIWllANlIC H, 1l0JJSI~, 1'11I'11101'1)' IIIlII\Vll n~ SI~llhn"l~ l,n~h~l', n\ll'~llll n'II/I'~llllflll ~I' I'I':TI'I'IONTO I~NElliWI~ MAlU'I'A" HID"I'L1':lVlICN'I' MlImICMI~N'I' C()MI~S NOW, pctltlonol', Htophlllllo 1~, IloIISO, fonnol'ly knOwIIlIs Stophlllllo 1"IIShol', hy IIlId throllgh hol' IIltnnlPYs, ,III1110S, Hlllllh, 11101l0rlok &. COllllolly, hy ,fohll .I, Connolly, .JI'" Ilsllull'o, IInd filos Iho Ihl!mvlng POlltlon 10 Ilnlhroo I'roporty Sol\lol11ont Agl'oonlOntllnd 111 SlIppol'lthol'cof 1'0HlHiotlillly ropl'csonts liS lhllows: I, I'ollllonol' Is 8tophllnlo It 1101IHO, 110folldllnlln tho IIhovo,cllplloncd 1I01l0n, cnrrontly I'osldlng lit 12(\ Sccond Strcot, WcsI FlIll'vlow, CliIllhorllllld County, 1'0nl1sylvllnlll 17025, 2, Rospolldcnt Is Brook LIIShol', 1'IIIInll 1'1' In tho IIhOVO'CllpllollOd 1I0llon, ollll'ontly rosldlllg 111110 MCllllowhl'ool( ROlld, ClIl'lIslo, Cnl1lhol'llInd Connly, I'cllllsylvllnlll17013, 3. On or IIlmul July 13, II)()I), lho pllrllos olltcl'cd Inlo II MlIl'ltlll Soltlcl11onl Agl'conlont, II oopy ofwhloh Is IIttllohod hOl'olo 111\(1 nllu'kod Exhlhll "A", 4, Undol' I'lIrngl'lIph 2A of tho MlIl'ltlll Sottlemonl Agl'oolllont, tho 1'01l1l0l\(lI' trnnslbl'l'cd 1111 righI, tltlo IInd Inlol'ost 10 tho 1'0111 osllllo 100lltOll lit 110. Momlowhl'ook Roml, Cmllslo, CUl11hol'hmd County. I'cnnsylvllnlll, tho Ihl'11101' 1lllll'Itllllosldonoo of tho PlIl'lIos to tho Rospondont. 5, I'msullnt to I'lIrngl'llph 2A, tho ROSpOllllont WIIS rosponslhlo fill' 1111 pllymonls of tllXoS, utility ohlll'gos, mlll'lglIgo pllymonls, IISS0SSIllonts IInd WIIS to Indoll1l1i1y IInd hold I'ollllonol' hlll'lllloss on tho sllld ohllgllllons, l\lsollln'Rulllltlo 1'II1'IIgl'llph 2A oflho Agrcol11olll,lho Rospondont WIIS 11661111111111 601~ Illlil l,xol116lvu r06pol1sIhlllty Ihr III1Y nlllsllllllllilll llohts 116soollllull wllh t1w roslll~I1\l~, 6, Al Iho t1111~ Iho pllrllos slllllell Iho AlllWl1l1ll1l, Ihoy hili I II 1110rlllllllo with Cml11lrywlllollol11o I,OIlI1S, 1100il\1I11110, 18737St), 7, Sll100 llio 111110 01' tho pllnlos' Agroollllll1l, Iho l{ospolI\l0111 hils hl1011 1l011sls1011t1y IlIto with Iho morlllllgo PllYI1111l1ls cIIU6111g 1I11011lllivu ol'lbol 011 tho Poll1l0110r's crollil rcport. 8, I'lIl'slIlInllolho MIII'IIIII Soltloll1onl Agrool1111I1I, Iho l{ospondcl1l hils I\llIclllo hold Ihll 1'011t10l1el' 1\1I1'111loss IIl1dor tho tlll'l116 01' I'lIrllgrllph 2A 111111 hils olll1sod Iho 1'01l1l0110l"s ol'olllt I'lIlil1g 10 dotol'lOI'lIlo, Tho Rcspomlolll mllst, 111 ol'dol' 10 1'01110dy tho pl'Ohl0111, rol1l1l1l1co Iho snlll PI'Oporly 111 hla 11111110 1I1111vldulllly 01' solllho l'oslll011011 h11l11odlllloly, 110 Illllst IIlso provido tho 1'0111101101' with C0I1I11111l1tloll 1\'0111 tho 11101'lgllgo COlllplll1Y thlllllho WIIS 1101l'llHpol1slhlo 1'01' III1Y 11110 PIlY1110111s thlll . hl\ve ocoul'rcd slllco tho .dlllo 01' tho pllrllcs' Agrooll10111 111 1999, 110 lI1ust III so SOlid II 101\01' 01' oxpllll1l1l1011lollny ol'cdlt ropol'llng IIgOll0Y who hll6 roporlcd 11011111lvoly 011 1'0tltl01l0l"S ol'cdlt, 9, I'lIrsullnl to I'mllgrllph 7 01' tho AIJrooll1olll, IIwllrd to Iho I'ollllonor 1I111011llllbos IInd cosl6 IIssocllllcd with lho onlbrcoll1ont 01'1h161'0tltlon, WllmmFOlm, your P01l1l0nor, 810phllnlo R, lIollso, rospccll\llIy rcqllests thllt Iho Court dlrcct tho Rospondonl, Brock Lllshor, to h11ll1cdllltoly soli 01' rol11lllllCO tho prClpol'ly loclltod lit 110 MOlldowhl'ook ROIIII, ClIl'lIslo, ClIll1hcrllllld COllnly, PonnsylvllllllI, Ihorohy rOll1ovlng Iho Potitlonor's nlll110 Ihlll1 tho 1110rtgllgo ohllgllllon to COllnlrywldo 1101110 LOllns 1\1111, IlIrlhor, dlrcct Iho pclltlollel' to sccuro II 101101' 01' explllnll1l0n fhllll Counll'ywlde 1101110 LOllns Iwllllowledglng tltllt 1111 pllYl11ellts 11110 01' otlwrwlso 10 thc 1110rtgllgo C0111PllllY werll I11l1do hy the Rllspolldelll, dll'eel tho Rcspomlcllt to tllke whlllovel' stcps me llecesslIl'Y to clellr III1Y Ileglltlve cOllllllUllts Oil the Petltlollor's credit roport ellused by the Respolldent's Ihllurolol11l1ko (hlloly pllYl11enls olllhol11orlgllgo, A Iso, " d' /" " !I ".. ':1' ., " " " " " " '.n. " " ,I' I', " " Ii Ii ,,' " Ill{ I' '/; , , , , , 'i r! " " " II " " ',',11 j ~ l! "-j! " " " f't, "Ii ," .'i ;-1. !! i' " r: " " \, . EXHIBIT" A" 'I " ,I; " "" j' ,'i ," ,,'I "~'I I' "" ", ,I ~ ;, " I3ROCI< ~ASI'II~R, Pll'llntlff IN TH~ COLJRT OF COMMoN P~J:AS ClJMI3J:I~I.ANP COUN1Y, P~NNSYI-VANIA No, 90 - 1771 ACTION IN r)IVORo~ VB, STJ:PHANIJ: I-ASHJ:R, Pe(enQl'lnl MAam8G~~l1gM~NIAaBaaMe~La[ONaaN BBOilltWlifiltANCJiIafHANllu.AHB TI-1I8 A<3RggMgNT macte Ihla/3f/1 (lay of Ju/'( ,1000 tly I3ROO/~ [.A8HSR ,an ad~lIlndlvlct~al of O~milerilmct Oo~nly, Penney/van In, an(l 8TGJ'I-IANIS I.ASHt:R, a(hllllnctlvlct~al of O~milerland oounlY, Penneylvenln, WITNSBSSlll: WI'lgR!.:AS, the parllea were married an JElI1uary 23, 1000, In O~mberland Oaunty, Penneylvanla, ilutthey have alnae eeperated, and; WI'lSm.:AS, W/PS end HUBI3ANP heve reaohed aoreement on flnenolal Emd property mailers arlalng aUI of a pending dlvoroo aollon belween them; NOW THERSPORr:, Intencllng 10 tle legelly bound hereby, the part lee hereto agrae aa follows: 1, l..IVING SEPARATE ANP APART. Thallhe partlea Intend 10 malnlaln separale and permanent domlollea and 10 live apart from eaoh olher, ilia Ihe Inlenllon and purpose of this agresmentto aet forlh Ihelr reapeollVe rights and dullea while they oonllnue to live apert from eaoh olher, Whereaa a Oomplalnt In Dlvoroe waa flied, both parllea will agree to a No-Feull Divorce after the applloaille ninety (00) day lima period haa run, The parllua hava allempled 10 divide Ihelr malrlmonlal property In a manner whloh coqfalmslo a J~stand right slandard, wllh due regard 10 Ihe rlghla of eaoh parly, Ills the Intenllon of Ihe parllea that suoh dlv/olan ahall be final and forever determine tholr reapeotlve rights, The division of eX/oiling marllal property la not Intondod by the parties to constlMe In any way a aale or 6xohange of aoaels, Further, tho palilea agree to conllnue IIvlno aepmetely !1f1d aperl from eaoh other at eny pleoe or pieces Ihat he or she msy select. Neither party ahsll harrsaa, annoy, Injure, threaten, or Interfere with the othllr party In any manner whatsoever, Eaoh party may carryon and engaga In any employment, pmfeaslon, buolneaa or olher acllvlty aa he or ahe may deem advisable for his or her aole use and benaflt, Nellher parly ahalllntol rem with the uses, ownerahlp, enJoymenl, or dlapoalllon of sny proparty now owned and not apeclflsd heloln or propllrty horearter eoqulred hy the other, .. 2, PROPERTY, Except ea may otherwlae be proVided Inthla Agreement, Wife agreea that all of the property of Huabsnd or In his poaausa/on shall bo the aole end Deparate propDl1y of Husband; and HuaIJand agreea thut all 0' tha property or Wire or In hor posae8alon ahall be the aole ondsoporate property 0' Wire, The palt/ea do hereby spaclrloallv waiver, rOlooae, renounoe, and forever ebandon whatever olalm, " any, he or ahe may havll with roapeclla the ebove Iloms whloh ahall beoomo the aole and separate property or the other, Tho parlloa egrea thetthelr property la to be divided aa followa: A, MARITAL Rr=alPJ:Nct:!, The pmllea aoknowlorloo 1I1111lhoy oWnoq, l1a lananta Py Ihe llnllrelllla, relll property known oa 110 MnarfuwlJrook Rund, Omllala, Dumperlanrt County, Pllnnaylvanla17013 (haralnaftor roforrerlto 11a Iha marlllll realrlence), Wlfll hlla Iranaferelj to .hllapand, all of her rloht, IlIle, and Inlereal In 11m rnmllal realrlence, allbJaotto any oulalonr1lno rlapl asaClollllart with Ihlll11arllal raaldenca Whloh almlllla hllapond'a aolo anrl axclllalvo reaponallllllly, Thoreafter, huahand al101I1Ie 1110 aole andaxolllOlva owner of the morllol realdonco free and clallr of any right. IIl1e anri Intoreal of wlla'a, Hushonrlshall ha SolelY rosponallllo for 111111aymontR olla)(oa, I'tlllly olmroos, 1110110000 paYments, aSllassmenls, ondl11alnlannnoa cosls 0 ilia morllal raslrlenoe I1nd shell Indemnify wile I1nd hol\l Iler 11I1rmlesalrom ArlY rosponelhllllY Ihemof, 13, MOTOR Vl3fiIOJ.,J:S, Wllh rospeutlo 1I1e motor Vflllloles, ownerlllY one or IlOtll or 1110 parlles, tlley flaree as follows: I, r:lloll parly agrees to he aolely rllsponslhlll for Ilia amounls presenlly rlUll anrt owlno aOolnsl his or her resflecllve llutomohlles, II, Wife sl1l111 rolllln posseoslon of fha 1 000 ~X.2 I:soorl, III, HuellOnrl shall rotaln posaasalon of 1110 1000 I'orrl Ranoer, o. raASoNAL PROP13RTY, I. Wllo sllall olltaln ollslody or the oouple's doO, Samson, on or abollt July 17, 1000, p. MUTUAL WAIVER Of' l:MPI..OYMaNT f:lF.Nl:f'ITS, The parlles aoree to wlllveany and 1111 rlghls they have In anri to euoh other's employment penoms, Inoludlno but not IImlled to poth parties pensions and retirement plana and Inoentlve Savlnos Plans, The pertllla aoree navar to assuma anI' olalm to suoh benefits of the other al Imy time In tha future, 3, OaaTs, Wile represents and Warranls to Husbanri thai slnoe tho separation she hes not anr1 In Ihe futuro she will not oontraot ar Inoul' any debt or lIablll\y for which Husbend or hla ostala mloht pa responalblo and ahalllnclemnlly and save hormleas Husband from any and all olallno or demllnds made aoalnst him by reason of debts or ohlloatlons Inourred by her, Huabond represents amI warrants to Wile Ihat slnco the Reparlltlon he haa not and In the fulure hD will not oontraol or Inour eny deht ur lIeblllly for Wllloh Wlfo or her estate might bo responalhlll and shell Indemnify and savo harmlosa Wife frolll any alld 1111 ololll1S or demunds ",ede agalnat her by rea san al debts or obligations IlIourrer! by him, Wile aoreos Ihallhelollowlno debts are her own personal responslblllly end tller,llfore agraea 10 completelY and filially pay on the followlno dobts and obligations: AllY alld ell debls In har nBllle alone regerrlloes of whenlnourrarl, Husband agrees tlml the follOWing dabls fUO his OWII personal reaponslblllly and therefore aorees to oompletely and finally pay all the followlno debts and obllgntlonsi AllY and all debls In his name alone regardlaea al Whenlnourrari, ,r." Cfil!PIT CARPa, I, HlIsbund will puy nfr Ille Oorneralilf1o Oreelll omel, Wll/olllma II balllnoa of llpproxlmaloly $400 unlll Iha orertll OElrdla oomplelely paid off, Afler Illalllme, l'lusballd will olllaln 11 ormlil carel whloh I~ III hla nlllnelllollP, II, Wlfo will pay tile Oorlleratolle areelll OonaQlldatlon 1011n, wllloll hils 11 Ollfrent Illllllnoe of approximately $1600, Within tile nexlOo cloys, Wife ahlllt atlompllo oelllnolher loell In her nllme 1l10n8 llnef pey thla Jolnl debl off ImmoeHlllelY, 4, !NCOMI! TAX RETURNIl: All ollfrenlllnd flllllre Incomelllx relllrna ahalt be filed aeperately IlIlCl the refllnels, I( eny, almll pe retalneel py 1110 roapsollve parl(ea, 8, SPOUSAl. SUPPORT AND AI.IMONY:!301l1 pmlloa horehy wolve and foreoo all finonolal alld malerlol epollslll Bupporl from elloll other llncllloree not 10 reqUest or seek 10 ohlaln alimony or spousal suppor! hefore nr llfler Ilny eHvoroe whloh mllY Ile omnleel. 8, DlVOROIl: The pllrHes agree 10 oooperale with elloh olher In ohllllnlno B final divorce of the f11arrlllOa, Ills lloresd thai 01 flnal selllemonllhe penloa will oxoollte and fila tho oonoonla noooaaory to ohtllln tile dlvoroe, ilia fllrlher Iloreedlhlll the pllrllea' merrlsoo Is Irrotrlovably broken, 7, aRJ:AOHllf ellller parly hre<lohea any provlalona of thla IlOfeel110nt, Ihe olher party ahell hllVO tho rloht, llt his or Iler eleotlon, 10 sue for elll/naoes for auoh hreaoh, or soek olhor remodlos or relief as msy ho avallllhle to him or her, llnd tile Pll/ty broachlno Ihls con!mol should be responslhlo for peymenl of leoal fees and oosts Inourrod by the otller In enforolno tholr rlollts IInder Ihls lloreoment, . 0, ADDITIONAl. INSTRUMENTS: Each of tile psrtles shell, from time 10 time, al the request of tho olher, exeoute, soknowlsdoll, and dellVl1f to Ihe othor party any and 1111 further Inslruments Ihal may bo resaonably required 10 olve full forae and effeo! to the provisions of this aoreement, 0, VOLUNTARY eXECUTION: The provisions of Ihls agreament and tllelr legal effecl heve been fully explained to ths pertles end lis provisions are fully understollel, HlIsband's laoel oounsella Jsne Aderna, Esquire, anel wife hes no counsel. Cloth pertles aorao that Ihey are exeoutlnO this aoresmanl freely and voluntarily, 10. ENTIRIl AGREEMENT: This llgreemenl con Ie Ins Ihe entire unclerslendlno of Ihe Pllfllso and Ihere me no representations, warranties, covonents, or Undeneklnos othor than those expressly sel forth herein, 11, ^f>PL!OAal.e I.AW: This agreement shall be oonslruedunder the law of the Comll1onweallh or Pennsylvanle, 12, PI~IOR AGReeMENTS: It Ie understood and agroed that ony and all properly settloment Ilgroemento whlc!l mayor heve been exeoutad or vorhally dlsoussed prior to the dala and time or this "oraoment ara null and Void and or no effeot. 13, WAIVER 01' CI.AIMS AGAINST Tim ESTATeS: Except as herein olherwlse provldod, eaoh parly may dispose of his or har property In allY way, and each party horsby waives and rellnqulahes any and all rlohts he or she may now have or hereafler acquire, IInder Ihe present or future laws of any Jurlsdlcllon, to share In the properlY or Iho ostalo or the 0111111' oS a resull of tho marllal rolallol1shlp, ....~ 11' " i''; HI ;' (!el II i" ,), I (11'1: I' " iLi\! j... I'. .~) . . :\ '''1 ..""" ,- I', III ., ...-"-t .;t' "r- i',;": :) i ~ " I ~ i I Ill" Iii ,j J;J.. In ....~ 'i" L;) ; ~:~:: '" IT,. ILl \"-1 "'\ c) I, ,ji ;I ;." Ii !! ,I ,. .j' " , ".j' 'I " " " it ii' " " ,I' ", ;1 " ,. Ii; " I, " " '" I;, ..' " 'J' " iI; " .,' I' 01) ~ ' I" 1'.- q. " ',', i' if " " , , )! " I' " " 't, " {1 , " " " " d?( Sr.? "~ f' 'i, " " '", " " ';', " , ii' " "," .. I,r"'l ~'.. ,.;'., '"'J T' I ',:! ;, " I ~ <~I " ~ ,,, , I: II,; " , , , t.L. Ii.. I ! ::1'11, \,-:,) , , -',1'1'. ",'- 1'1" (!;) '\'1 III '.'; ;'- I. L~~I " '''' ..'1' , I ('.1 j,t (,} t';' p...j " H ,,' " " " , ;, 'I " jo -, H " " " !\ i' 11" Ii_ it ;, "i.. 01 " " '~ j " ,'i' " I" 1: ,I' .. q ji, "[" I' ;, I, jl /, '" Ii " " ,. ',' " I;' " " '" " ii', 0< " " " H ,..1 " ;, " h /. 6, Thu I~UHpllllllulll wnH IlIHIl Ulvull Ihu nptioll nl' npplylll!! thl' rutll1lllwl111l or IINNlllnllllon nfllw 101l0,mlllilllu him Hnluly'reNpllllHlhllllhr Ihe Il1l1Ht1l1ld11l1l hllhllleu olllhu mnrlun!!u, It wnN rellulrCll, pUlldlll!! npprnvnl nl' rutllllllllJlllU, Ihnl thu hnmu I'llllHllo IIHtClllhr Hnle 1II1111hlll hI! Wnllhllllku 1111 netion Ihnt wOllhl PIWUllllhu Hlllu oflhu homu, 7, AN pllrt Ill' Ihu Htiplllntioll, Ihu !{UHplllldunlllgreed In pny eO\lllHIll tiloH III thu 11l1111llnt 1l1'$600,OO 10 ellunHollhr Ihu I'elltlonel' nllhu timu lll'tlnnl HettlulllOllllll' rotlnnlleln!!, H, 11 IIIIH ellmu tll thu IIttentillll Ill' Yllnr Petitioner tI\IIl tlw RUHpOllllull1 rUlllllved Ihu pl'nllUrty tl'llmlhllmnrkut ill .Jllly Ill' 200S, PrillI' to n rUUUIlI pnYIlHlnl, the Illortgllllu wnH dlllhlllnulll Ih!' thll 1l1lllllhH nl' .Inly, An!!nHl, SllptUlHI1OI', Oelllhur nnd Nnvumhur, continning tn el\\IHO Ihu Petitillnur Nlunl nCllnl credit prllhloll1H, Tho nlllrtllllgo IH nnw dollllqnunt Illr Octoher nml Novomhor, I), Tho hiHlory of Iho pllynlOnlH nrn Ihnt ti10 ReHpolHhlllt did nol mlll\o tho Mnroh pnyn10nt until April I H, 200S nnd the April, MIlY nlld .Innu pllymentH were not mndu unttl.Jnnu 6, 200S. 10, ConUHel thr thu pelllloner wrotu tll RUHpondent'H eonnHel nn MIlY 27, 200S nnd .Iuly 12, 200S I'lIIHlnglhe IHHUUS of dullnquont pUYlllunlH uud the proporly lllJlnllremovud fh1l11lhu mnrkut in vlolnllon ofthu slIpullltlon, SlIld lutturN IIru IIttuehed hurutollnd I1lllrked IIH Exhlhit "e" IInd "I)", II, PnlllloUlll' hUH uxpemled ndditlonlll SIIIllS In eounsul tees In Ihu IInlOllnlof $467,SO slneu Ihu Order of April 21, 200S 10 unthreu Ihu termH or thu Stlpullltion Inehullng telephonu elllls, elllTuspondunee IInd Ihu prepllrntion Ill' Ihls l'ull1l0n, In IIlldltlon to IIl1ornoY'H leOH Hot Ihl1h In pllrllgrnph 7 horeof; Ihu 1'01l1l0nur 11'111 Incur ongoing eounsul feeH In enlbrelng tho tUl'lm Ill' Ihe Agreclllenl lilr which Ihu ReHpondenl is nlHo reHponHlbhl. Hnhllees 10 hc provided tolhc COUl'l III the 1Ime ofheuriog In thiN millieI', lInnCl~ l,ASmCll, l'lnlllllffml\~IHIlHI~111 v, I IN TIIlC COunT OF COMMON 1'l.lCAS I CIJMllICHLANIl COUNTY, l'ICNI'/IlYl.V ANI" I , , No. !JU-1771 S'I'lCl'IIANm n. 11OIJST~, fm'Il11Il'I)' 'mowlI liS SI~J1hlllllo l.nshor, Il~ f~III' n II I I Pol I I Inn or I I I CIVIl. ACTIoN - LAW I IN 11IVOlWIC f"l "'" p .' .' I 11 .1" "\ ;c,\ ,1,'11 \ ~ I' ' .., ~ .,,\'\ 1)\ ' I , 'rJ 1,\ . ' ~, , ' , , , ". J rl1 , , ..' .,.! .. , " " .< -' I'WI'ITION TO rr.NF()I!f.rl~ MAIUTi\l, HWI"I'l,lCMICN'I' i\nm~ICMEN'I' :) COMICS NOW, Polltlol1cl', Slcphllnlc R, HOIIHU. fhnncrly IwownllH Stcphlll1lo l~lIshor, hy lllllllhrollgh hor llUO\'11CYS, .1l1ll1eH, Smith. Diollurlek &. Connolly, hy .1olm.1, Connolly, .11'" llsl)uiro, llndl1lcs tho fhllowing Pcllllon to El1fon:e PropcrlY SclllcnlOnt Agrocmcnt llnd in H1lpport thcroof I'cspcetfnlly rcproHontR liS follows: I, Petltionor Is Slephlll1lo R, HOIISO, DOrOlllhmt In Iho IIhOVO-Ollplloncdllelion, cmrcnliy rcsidlng lit 126 Second Slreet. WORt FlllrvIcw. ClIl\1herlllnd COllllty, PonnHylvllnlo 17025, 2, RCHpondcllt iH Brock LlIshor, PllIllIlirr in Ihc IIhove-ollpllonml lIetion, onrrcntly residing lit 110 MOlldowhrook ROlld, Cllrllsle, Cnl\1horlllnd COllnty, Pcnnsylvllnlll 17013, :1, On or IIhOll1 ,hlly l::l, 1999, tho pnrtlcs cnlcrcdlntoll Mllrlllll Soltlomcnt Agrcomcnt, II copy ofwhioh Is nUnchcd hcrelo 1I1ll1l11l11'Iwd Exhlhll "A", 1\, Undor PlI1'lIgl'llph 2^ of'tho Mllrltlll SoUlol11onl Agreol\1onl, Iho Polltlonor tl'llnsfcll'cd , oil righi, litle nnd Inlerest 10 the relll esllllo locntcd III 110 MClldowhrnak ROlld, CnrllHlo, ClImhorlllnd COllnly,l'cnnHylvllnln, tho fonner I\1l1rltlll resldencc oflha pllrllcs tolhe Respondcnt. 5, Pursnnnl 10 PlIl'IIgrnph 2A, thc Rcspondenl WIIS respol1Hlhle fhr 1111 pllYll1cnls or tllxcS, ullllly chllrgcH, 1110rlgnge PIlYl11cl1ls, IIHHosslllonlH IIIllI WIIS to Indomnlfy lIlul hold l'ot It I lInOl' hnl'lnlcss on tho /I/Ild obllglll!ol1s, Also IJlllHlI/lnlln Pnl'llgl'llph 2A llflho Agroemcnt, thJ ROHpondenl wlla IISBIlInhlll sole IIncl IlXolllslve responslhlllty for IIIlY olllstll\llllng dehls IIssoe\!I\Ocl wl!h Iho rlla\llelloe, (i, AI Iho limo Iho Pllrtlos signed tho AgroonlOnt, they hml II mnrtgllg\l with COlln\rywldo Homo LOllns, IICOClllnt no, 1873789, 7, Slnoo Iho clllle of Ihe pllrllos' Agl'oenlllnl, Ihc Ronpollllont hils Imon oOllslslontly 11110 with tlw ll1orlgllgo pllymontn ollllslnllll noglltlvo offoul olllho \,ollllonol"lI crcllIIl'cporl, ll, P\lI'Sllllnl 10 Iho MIII'I1111 Sottlolllcnl Agl'comonl, Iho RoupolHlonl hils fullod to hold Iho \'cllllonol' hll111110ss IIndcl' Iho 10l'ms of Pili'll Ill'll ph 2A IInd hils UlI\lsod tho Potl1lonOI"8 cl'cdlt I'IItlng 10 clcterlol'l\te, Thc ROllponclcnl mUlll, in ordol' 10 rCl\1cdy Iho prohlom, I'ofinllnco Ihllllllld propully In his nllnlC Indlvldulllly (JI' 801llho rosldcncc hlllllcdillloly. 1'10 l\1uslnlllO pl'ovldc Iho Pelltlonol' with oonfinlllltlon frolll Ihc morlgllgo cCllllpllny Ihllt shc WIIS noll'csponslblo for IIny Inle pnymcnts tllllt huvc ocoulTcd sinoo Iho dlllo of tho Plll'lios' Agl'ccmout In 1999, Hc lllUS\ IIlso scnd II lellul' of ('>:plllnllllon 10 IIny ol'cdlt 1'0POl'IInll IIgenoY who hils I'opnrlmlnoglllivoly on I'cll11oncl"8 cl'cdlt, 9, PlII'sullnt to Pllrngl'llph 7 of thc Agl'ccl\1cnl, IIwlII'd 10 Ihe Petitloncl' ullleglll fCCB IInd oosts IInsoollllcd wl1h Ihe enfol'eol11cnl of thin Pelilion, WIII~RIWOlm, yonI' PctitioUOl', Slcphnnlo It Housc, I'espcctfully I'cqucsls thnt the Comt dll'cet Ihe Respondent, Brook LIIShol', 10 il\1111odllllely sell 01' l'el1nllnoc thc proporly loolltcd III 110 MOllllowhroo\c Roml, Cill'lIslc, ClIIllhel'llIncl County, PcnnsylvllullI, Ihcl'ehy rOllloving tho Petltiouel"s nlllllC fj'OI1l tho lllol'lgllgo ohllgnllon to Counllywide HOl11e LOllns 1I11c1, fmthol', direot Ihe Petl1ioncl' to SCClll'C II lellcl' of oxplllnllllon 1'1'0111 Connll'ywidc HOl11e LOllns 1I0knowlcdglng thllt 1111 pllYlllcnts IlIlc 01' othol'wisc to the 1Il01'lgllgc cOlllpllny welc mlldo hy thc Responllcnt, dll'ccl the Respondcnt to tllkc whnlcvcl' Hteps III'C nccesHllry to olcllr IIny nogllllve commcnts on the Pelltloncr's credit roport clIlIHed hy thc Rospondcnt's fhihlnllo IIInkc limcly pllYl11cnts on the lIlorlgnge, AIHo, Dol~1 _lL)Jl' fI~:L' OHioI' I.h~ 1~~spom\~11IIo PIIY ~o\1118~1 r~~811\l\1 posla fplllthl11lulhls Pplllion. 1~~8po~I~Iny 8\Ihml1l011, , . JAtv\llS, SMITII, P1l1'I'rUlll~~NNIlLI,y UYI' . ) @-wvl~\f'\ "Jt( oh "I. Co \Pity, ,11'.. 1l8fllllrll . f.t.U]O fOf Potitionor "- I'usl 0 -Oil Ilox 650 .-.,-.... rlllfshllY, PA 17033 (717) S33.32RO M \.P. No, 15615 ,0' " " " " ,. " ,. I " " " ;, 1 ., '1' '\ '" " " d" ", " " , I " " " ", " ,. , .,' \ " q. " I' " " " ,I' . " I' '" "I' '" " " " "I' " !i " I' 'f " " " ", " " , " " , , ,j H " H " ,!', " " ,.., ij. " .'.; /" I' , " ,1I " " /, " " II. " I' I' " " " 'L' " II " i\ , "il " ,j' " " " " " EXHIBIT "A" P"OOI< ~ASI-lf.H, fJlalntlff VB, IN TI-II: OOUHT of cOMMoN P~I=AS OUMI3I:r~l.ANP COUNTY, PENNsYI.VANIA No, 00 - 'l77 '1 AOTloN IN PIVorwl: srr:PI'IANII: l..A81-lI:R, pefenclanl MABnIACiIi.JleUb(;MeUI.Al3Bs~MIiNLaa.tWIiIiN fiIlQnll1.811lJ~llANlilJIel~L1AUILl.l.Al;lUIiB / ':l'l/l .,- /. " THII'l AGHl:EMI:NT maclo Ihlu~:) dnyof vtJ '( ,1000 lly 11ROOI< ~ASI'Ir=R I Illl adultlnlllvlclllal of Clllllhorlnnd Oounty, Pl.lnnuylvnnln, ollll STF-F'I'IANlg I.ASHI=H, aelUIt Inrltvldual of Oumharland Oounty, Ponnuylvnnla, WITNF-E10ETH: WHgRr:AS, Iho pmlloB wora marrloll on Jamll1ry 23, 1000, In Oumhorland Oounty, Pennsylvania, but thoy Imvo slnoe Bopnratod, allll: WHEREAS, WIFE anlt HUSBAND have roaohed agreement on IInanolal and properly molters arising oul of a pondlno dlvoma 1I01l0n hotweon tholn: I' NOW THEREFOR!:, Intondlnu to be legally hound herohy, the parlles herelo agrl10 OB foltllWS: 1, 1.IVING S13PARATE AND APART, That the parlles Inlend to 1I10lntaln soparale and permenenl domlollas and to Itvo apart frolll uuoh olher, Ills tho Intenllon and purposa of Ihls agreel\1ent 10 set forth Iholr rsspeallve rlohts and dulles while Ihuy conllnue to Itvo apar1 froll1 eaah olhar, Whereas a OomplOllnlln Divorce was OIod, bath purlles will agree to !1 No-Fault Dlvoroe after the appllcahle ninety (00) day lima period has run, . The parlles have altompled 10 divide Ihelr matrlmonlul property In a manner whloh conforms 10 a Just pnd right slandard, wllh duo rooard 10 Iho rlohts of euoh parly, It 10 Iho Intonllon of tho pmlleD that auch division shalllla finul pnd forover dotormlno Ihelr raspectlvo rlohts, The division ofaxleltlno marllal propurty IS.nollntonded by the perlles 10 oonslllute In any way a sola or axohange of aesels, Furlher, the parllos agree 10 continuo living eoparnlelY and Elpart from OEloh other pt any place or plaoos that hI! or she may saloo!. Nollher party shall harress, annoy, Injure, throolon, or Inlorforo wllh tha other parly In any marll10r wllatsoever, I:aoh party may carry on ancl an{lage In any ernployrnonl, , profosalon, business or othar aotlvlly ae he or sho may deem advlsflhla for his or her solo lIse enel haneflt, Nollhar parly shalllnlerfaro Wllh the usos, ownership, enjoyment, or dlaposltlon of any propsrly now ownod and not speolJlod heroin or propurly herellftor ucqulrod hy tho olher, 2. PROf'IiRTY, Excepl os may olhorwlse he prOVided In this Aoroomanl, Wlfa agfolls that all of tho property of Husband 01 In his possusulon sholl bo IIle sale and oeparete proporty of Husband: and Husband agmes Ihat all of tho proporly of Wile 01 In her posseoslon sh!lll be thfl oole and sopamle property of Wife, The PUltlos do hereby Ilpeolllcally waiver, rnlease, I'OnoU/1oe, and forevor ollalldo/1 whatever ala 1m, II any, ho or sl1!ll/1ay hllva with respuctlo lho above Items whloh shall bocome Iho sole and soperale proporty of tho olher, Tho parllos a[Jrne 1I11l1lhelr property Is 10 be divided as follows: A, MARITAl. Rl>BIPllNog, rho Porlloll Ilnknowlocl[lo IIml Ihoy owneel, IW lanl1nlo 11Y "'" ul111rolll1s, ronl f1rnpollY knpwn ns 110 Monclowhrpok HOOII, OnrllslfJ, Ollll1llOrllln,l GPlInly, Penl1aYlWIIlln17D13 (huroll1l1nor rofurrocl 10 liB Iho mmltol rool,lol1no), Wlfa hnB Irpnoforael to hllSIHlnel, 1111 of hnr rl[lhl, lilia, I'lnlllnlorfJollfl IhfJ ml1l1l111 roslelonoo, 81111)00110 UI1Y Olilstnncllnn ,Ialll n8SDolnlall wllh the nmrllllll'llslllol1oo whlnh ohallllfl hllsl1nnll'H 00111 IHlCI oxnhlUlvo raoponolhllllY, ThalPofler, hllolluml shnll110 IIw oola I1nel oxnllllllve OWIUlI of Iha mnrlllll roolclanoo frao IInel olonr of Ilny rlolll, 11110 unlllntfJrost pf wlfo'o, Ihlalllln,l ollnlllJO sOlaly reoponolhlo for 1l1l/IIlYlllonls of tllxeo, 1I11l1ly 011llro08, mor1[1aoo pllYlllanto, 088aB8nlOnlo, llnelllllllnlonllnOO OOslo 0 Iho IllBrllnl roslclonoe 11M ohalllnelomnlfy wife Ilnll holrl har harmlaoR frolllfll1Y reapc1l1811111llY Iharoof, p, MOTOR Va~"Qhl:fl, Wllh rospoollo Ihalllolor vehlnlaH, ownoel hy Ollll or IlOlh of Iho portlee, they o[JrOl! on followa: I, r:lldh /lIHly u[Jraos 10 ha uololy ro~pnnulhle for Iho omullnlo pluuen\ly Iluu and owlno ll[Jolnnll1lu or har respeotlvo alllolTlullll08, II. Wlfo al1l111 lolnln posaoualon of II1u100n 2>\.2 [20nml, III, Huub'1Ill1 ahnll roll1ln poesl1llelon of Ihe '1000 Forel Ronoar, 0, PI3RSONAI. PROf'SfHY, I. Wife allllll obluln ouotody Ilf the oouplo's cloO, Smllson, on or aboul ,July 17,1000, p, MUTUAL WAIVI:R OF EMPLoYM/lNT IlSNI:FITS, The parlllls aorelB 10 Waive uny and nil rlol11e Ihey hllvo In IInel 10 aooh olher's ol1lploymonl benofits, Inolllltlno bllt nolllmllo(1 10 both purtlau ponolonn und retlrel1l13nt plona andlnoonllve 8nvlnos Plans, Tho pertles lIurOO never 10 aaBllme any ololmlo suoh llonaflln of tho olhol' 01 any lima In Iho fulllre, 3, pgaTB, Wife roprosento oncl wmlOnlB to Husband lhat alnoe Ihe BOflurutlon sho has not onel In Ihe future Bhll will nol OOl1lraol or Inollr nl1Y debl or IIl1blllly for whloh HlIaband or hlo eutule mloht bo resflonelble ul1d Bhollll1[larnnlfy IIl1d uavo hUlll1leaa HlIohaml from any ond nil olalma or damands Illuclo eoalnat hllll DY raoaon of clabla or ohll[Jutlol1o Inourracl hy har, HlIahond roflrnsonlo nncl warrantH 10 Wlfo thnt sllloa 1110 Oapnrlltlon he hila nolund In Iho future ho will nol uonlraol or II10ur OilY dehl or IInhlllly fur whlnl! Wlfo or har aalola mlnhlllo 10sflonalbln IIl1d Hhall Inelamnlfy ond aovo hUllnleoa Wllu frolll OilY UIIII oil nlnlins m clal1lnndo moelo aoall1al hor hy rS8S0n of dobts or ohllootlonH liwurrod hy him, Wife aorooa Ihot tho folloWlllo dehts oro hor OWII porsol1nl lCluflonslblllly amllhoroforo aorous 10 OOlTlplolaly oml flnnlly flllY Cll11ho followlno dohla n/lll ohllOlltlol1a: Any nlld 011 dobla In her nllmo II10no reonrcllass of when Inellrroc!. Hlluhandll(Jroos Ihollho fOllowln(J dohlu 11I0 hla OWn paIBonal renflonslhllllY and Iharolora anmoa 10 oOl11platoly and finally !lIlY on Ihe fullowlno (labIa and obllgllllonn: Any nnd 011 dabla In hlu noma olono raonrelleoa (If wl!onlnourrac!, A. ORI:1PIT CARPs, I, Huspand will pay oft the Cornerstone Creelll card, which Im~ n IJalslIPe pf aflproxlmataly $400 un\lllha credl1 o~mlls cPl11plaloly pnld of[, Allor Ihallll11o, Huspancl will ohtoln a proell\ par,1 Whloh Is In his nl1l11e alone, II, Wife will pay Ihe Cornerstone Cre'lll Consollelallon loan, Which hus s ourrent halanoe of approximately $1600, Wllhln tha nexl 00 elnYd, Wile shellllllel11pl 10 001 nnolhor loon In her nal110 alone anet pny Ihls jolnl clebl off Il11l11eellnlely, II. INl10MI:1 TAX RI:1TURNS: All ollrrent anel fulure Incol118ln~ ralurns slmll ho iliaci sapornlsly und tho refunds, If eny, shall lIe relall1ad by Ihe rnspoollvo pmlles, 6, arOUSAl. uurrorn AND AI-IMoNY: Onlh partlos horohy walvo anel forago all flnenclal and l11alerlal spollaal support Irom elloh other end aoree nol 10 roqueal or seok to ohlaln alimony or spousal support hafon~ or after any ellvorori whloh n1flY ho Olanlecl, 6, DIVORce: The perlles agren to cooperele wllh eeoh olher In oblalnlno a final ellvoroe of Ihe l11arrlaoe, Ills aoresd that at final selllement the parllEls will oxeollle and file the oonsenls neceasary 10 obtsln the dlvproe, Ills furthor aoreed thai the par Ilea' l11arrlaoo la Irrelrlevably hroken, 7, BRI3AOIIlIr ellher party hreaohea IIny provisions of Ihls egreel11onl, the other pnrty shall haw the rloht, al hla or her oleollon, 10 s~la for damaoes for slloh hreaoh, or seak olhsr remodlau or relief au may be avnllable 10 him or her, !1IlC11ha POlly braaohlno this contraol ahould he responslhlu for paymanl of leoal feas ami oosts Inourred hy the other In enfprolng Ihelr rights under this agreemenl, 6, ADDITIONAl- INBTRlIMgNTS: I:ach of Ihe parlles sholl, frol11 lime 10 III11B, al tho raqueal of tho olhar, oxeoute, aoknowleclge, and delivaI' 10 Ihe olher party any and all furlher Inslruments IImt may be reoaonahly required 10 give full fprc\!! end effeol to tho prOVisions pf Ihl8 aoreemenl' 0, VOI-UNTARY I:XECUTlON: The prOVisions of Ihls ogroemont ondlhalr legal effecl have hool1 fully explolnedlo the parties and lis prOVisions aro fully underslollCt. Husbund's leoul oOllnsolls .Jano Adams, I:squlre, and wile lias no counsal. 80th pnrlles agreo thatlhey are oxooullno Ihla lIorsemonl freoly ami voluntarily, 10, I:NTIRI:1 AGRF.I:Mr:NT: This ogroement contains tho enllre underalendlng of Iho parlles ond there fue no roprosenlallons, Wnrrnnlles, OovElnanls, or underlaklrl0s oilier Ihan Ihose oxprossly sol lorth horeln, 11. APf'LICABI-1: I-AW: This ogroemonloholl he cOI1Rtruodundol tho Inw of the Commonwoallh 01 Ponnaylvanlu, 12. PRIOR AGRI:I:MI:1NTB: It Is ~lI1dOISlood nnd agroocllllalllllY oncl all proporly solllemollt I1groemsnta wllloh mny or hnve boon oxeoutocl or verbally cllsouoRecl prior to tllo cloto and lime of Ihls agreoment are null and void ancl of no of loci, 13. WAIVI:R or CLAIMS 'GAINST THr: I:BTAmB: Excopl UB herein othOlwlso IJlovldocl. eaoh pafly may dispose of his or liar properly 111 any way, ond ench purty IIelohy wulvos oncl relinquishes any and all rlohls he or she may now hovo or horonllor ncqlllre, undor the prosenl or Iuturo lawn of any jurlscllollon, to 811mo In Iho propeliy 01 Il1e estato of Iho olllOr os n rosult of Iho mnrltal rOlallonshlp, .. ~ " III~oq( Li\IlIII\/{, 1'11111111 nm CSpOlldllll1 : IN '1'111\ CUI Jln OF COMMON PLHi\H, : C1JMl1lHtl,i\Nf) CYllJNTY, PI\NNHYINi\NIi\ , , v, : NO, lJl) - 1 'I'll Civil Tel'/Il STI!PIIi\Nm 1(, IfO\JSH, lill'/lIul'ly klloWlllIS Sluphlllllu LIIShul', f)e tUI 11 11111 1/1'11 II I lillieI' : CIVil, ACTION. LAW : DIVOIWH n 1:" r..1 ('I IiI ,i,ll :,(1 1.;li.: lHr. ,-J \I dyu ;;'(1 " "I) ~~:I ,1/ l:;l , . I. :c I.\{l, :',: :,1'/, I"/! " " ~.I:' ( , , t~ ) , ...... i;.i11n , .. .;'j 'I c,n :I~ "'f ,:,.... ';, H'I'IJIIJIJA'I'ION III'jLtIT!.yti) TO Tim PIC'I'I'I'Iill':l Tn 1'~NII'nHf:',li' M.1JIJ'J'..U, .'W'lT: ,1':M1CN':' Mm~:ICI\tICr:iI " la horohy allpllllllud h,y lI11d hulwuUlllhu PIIIIIIIIO; Ill'Oul, Lllllhul', IIl1d hla Atlol'lloy, .Jill''' Adllllla, Euqllll'u, IIl1d Iho Dolulldlllll/l'llllilollllr Hlephlllllll it, 1101lSU, IIl1d hul' Altol'lloy, .Iohn .I, COllllolly, Jr., IlHIIIIII'U IIH fhlloWII; I, Brock LIIHhol' ahllll kuuJl Iho IlIlHIf.lIlIlO ohlllllllloll 011 Ihu hlllllO 10UllluII 11\ 110 Mondowhl'ook ROlld Ollrl'OIl! IIlld IIh II II 111 II Iw 1I111111111'U 11IIYllloII11I 11111 1I111OIy IIl1n1l101', 2, Thu hnlllO 111110 MUlldowhmok 1{lllld II' Olll'l'Ulllly 1I1110d fill' 111110, Brook Lllllhul' IIhllll ooupurlllu with lho I'UIlItOI' III ordul' lhlll lho hOlllU 01111 ho 1I0hllll II Illlwly Iilahioll, 110 will 111110 provldo Rlephlllllo It, IloIIIIU wllh tho lllllllU IIlld lelephollu IIl1lllhur of the I'ellltor 111111 IIhlllllllllll IIIlY IIppl'llprllllo eOllllolltll In ordol' III II110w Htephlllllu II.. Ilollllu l\1\d/ol' hol' IIltnl'l1uy In OOl11l11l1nlolllo oponly wllh tho 1'Ill1ltol', J, Brook Lllllhol' IIhllll he pOl'lnlilcd III IIpply iiII' rofinlllllllllll 01' 1I11111alllllllpllon Ill' Iho elllTUllllolln whloh wOllhllholohy Illllko Brock I..lIl1hol' Holely rOHplllllllhlo In lho h)(lIlll(ll11Jll1ny fill' uny nlllull1lldlnlllllllnllllla 01)('/'01111>, llwod nil Iho, nllll'lglIgo nhllgl1tlllll, IlowoVOI', pondlng I1nl1l uppl'Ovlll ol'l'otinlll1oll1ll. Iho hOlllo IIhulll'01l1ll111 UlIled Illl' 11111011I111 I1l'nek LlIshol' wlllnolluko UIlY uollon which wnl1ld prevenl 81110 (Jftho hllnlll, .. . " " I. " " Jj' " 1\' I' " 'i , , " j, ' H " " " " I' I'" 1-/' " ,. " " " , " .. I' " I" U I" " , " I 'I I' ,I " it "" 'I " EXHIBtr "c" " , ,. ,; 1,,, " " ;l I' " II 'I Ui I' H' .' I , " ",. " I'"~ " '" " ,. " " I' :, .. Ii " ii.. 'I " '" " ". " " ~ I' " " I, " I' !-,. L " ,. ;.'." I' .' " ,. 'I' " " I 'f' " I' " " '-\ d' , , " 'I' '-I " " , " I, " I . "h I' Ii I, " I.' , I I' " " " " >,Ii " I H 'I " " " , , " " " " " e' I, "',; 'I' ,I' I , 'i I' 1'1 ., 'ff' " " ;! " I, " , , H I I' 'i' d' " ':: , I' ,. , H 'I I~ , I 'I " " " " I I' EXHIBIT "D'~' ~ Ii ", m t?~ j~;' rlJ1 t;:,,) "j (.') t;)"t ..'1 1-I1J,,' l,"i ( 1-, :.q, )::1' I'!~h! (.\~ )"'J 'ff;"., "'} ,,:' IiJI::~ \' ''''I CJLIJ t.,~, "1:1 t;r~l' p I;,~ t';J -i'''! !.ld. ,~ :,-~ p. 1m ~} .~ q " I' , " Ii ';", ,j' ..' '.... , ' " " " !.~ " " Ji j' "ll " j,- " .' " , " 'j " " , " JiI IIi " " 'i! " " " H ' H " Ii ,j; I' il" " " ,,'I " it; " " I' .' Ii: I' I: 'It " j".' " II " ; ,; .' .. , " I,,, " ,ii' ,. d., " ,I " ImOl2K/,A/:HlIm, PlnlnllfIYf\paplll1clpl1t .. IN '1'/111, (:.'(}\Jln of COMMoN PI.BM1PF . CIIMHlll{l,ANP CO(JNTY, PBNNHYI.v ANIA CIVil, ACTION -lAW .: NO, 00.1771 CIVil, VR, STIWI"I\Nm R, 1I0USIl, flll'l1wly Iq1l1\V11 na Htpl1hnnlp I,llalwr, f)p 1\JllIlnl11/PPll t IIlIWI' PIVOIWIl li'l Rill 1'1l'ITlJillLl.1)J.UiEllCIAL RIILlliE ruU2.!lli ANI) NOW, thla 10' dny Ill' JIUHmr)', 2006, honrhlB Inlho nhllyO onptlllnod militoI' aol fl1l' Fohnmry 17,2006, nt 91~0 n,m, la tl'lllwl\Jl'l'od 10 Tho Ilollol'llhlo M, I" IIhol't, ,II'" In " COlll'troom NlIl11h,II' ~, CUll1horlnnd Coullty Cll\ll'lho\lao, Cnl'lIRlo, 11A, BY Tim COURT, Tho HOl1ornhlo M, t, Ehol'l, ,II', v.MO Adnll1R, Eligulrll For lho Phlllltlff/RoHpondonl 1. 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Tho PllIll1l1ff/ltoHpnIHlol1\ hllN l\1rlhor IIgl'oed Ihlll ho will 11111111111111 II uOl1l1nunUH IIHlh'lll nf Iho proporl)' UIIIII Hold, f\llly Ilnnpol'lIlu with Iho rOllllnl' 1'0lllll'dll11llho slllo of Ihu propurl)' 111111 provide n oopy of Iho 01'1101' In Ihls 111l1t1el' In Iho 1'01111(11' who shllll hllYO dll'ool 001111101 wllh Iho Dofondllnl!Pollllnnol' rogllrdll111 tho sllllus of Iho slllo, 5. Tho PllllnllWRospondol11 shl1l1 PIlY IIl1mnrlgllllo pllymOl1ls 11111 Ihlloly fllshlon. 6. AI Iho dnlll of sctllomulIl In IhlH I11I1t1UI', Iho Pllllnlll'fYRllspnl1donl shull PIlY III tho Dofondllnl!l'ollllol1ul' hCI' oUlstlllldlll1l 1It10l'llcy's filcs IIl1d unHtH In Ihls l11otlol' nol tn oKoccd $1,500.00, Tho Hllld 1It101'l\0)"H fCCH Inoludo Iho $600,00 proYlouHly ordored 10 ho pllld by Iho PllIlnllff/Rospolldonllnlhc SlIpnlllllnnIn IhlH 11111t101' dlltod AI1I'1I21, 2005, 7, UpOI1 Hohcdullnll II sotllomont of tho HII\O of tho 1'011\ OHlllto hoth Iho Plalnllff/Respolldent IInd Ihe 1'01111(11' 8hllll oonlllot Iho ()ofcndlllll/Putlllonol' In ol'dol' tn rcoelyo doolll11ol1lntlon of hol' 1It10l'llOY'H fcos hili re{crol1ood IIhovo whloh shllll ho pllld Oil tho Hotllol11ont shoot to Iho DoflllldllnllPotltlonol' III tho time of oIosll1gln thlH mllllol', 2 BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : IN DIVORCE PETITION TO ENFORCE MARITAL SETTLEl\-IENT AGREEMENT COMES NOW, Petitioner, Stephanie R. House, formerly known as Stephanie Lasher, by and through her attorneys, James, Smith, Dietterick & Connelly, by John 1. Connelly, Jr., Esquire, and files the following Petition to Enforce Property Settlement Agreement and in support thereof respectfully represents as follows: 1. Petitioner is Stephanie R. House, Defendant in the above-captioned action, currently residing at 126 Second Street, West Fairview, Cumberland County, Pennsylvania 17025. 2. Respondent is Brock Lasher, Plaintiff in the above-captioned action, currently residing at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about July 13, 1999, the parties entered into a Marital Settlement Agreement, a copy of which is attached hereto and marked Exhibit "A". 4. Under Paragraph 2A of the Marital Settlement Agreement, the Petitioner transferred all right, title and interest to the real estate located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania, the former marital residence of the parties to the Respondent. 5. Pursuant to Paragraph 2A, the Respondent was responsible for all payments of taxes, utility charges, mortgage payments, assessments and was to indemnify and hold Petitioner harmless on the said obligations. Also pursuant to Paragraph 2A of the Agreement, the Respondent was assuming sole and exclusive responsibility for any outstanding debts associated with the residence. 6. At the time the parties signed the Agreement, they had a mortgage with Countrywide Home Loans, account no. 1873789. 7. Since the date of the parties' Agreement, the Respondent has been consistently late with the mortgage payments causing a negative effect on the Petitioner's credit report. 8. Pursuant to the Marital Settlement Agreement, the: Respondent has failed to hold the Petitioner harmless under the terms of Paragraph 2A and has caused the Petitioner's credit rating to deteriorate. The Respondent must, in order to remedy the problem, refinance the said property in his name individually or sell the residence immediately. He must also provide the Petitioner with confirmation from the mortgage company that she was not responsible for any late payments that have occurred since the date of the parties' Agreement in 1999. He must also send a letter of explanation to any credit reporting agency who has reported negatively on Petitioner's credit. 9. Pursuant to Paragraph 7 of the Agreement, award to the Petitioner all legal fees and costs associated with the enforcement oftms Petition. WHEREFORE, your Petitioner, Stephanie R. House, n:spectfully requests that the Court direct the Respondent, Brock Lasher, to immediately sell or refinance the property located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania, thereby removing the Petitioner's name from the mortgage obligation to Countrywide Home Loans and , further, direct the Petitioner to secure a letter of explanation from Countrywide Home Loans acknowledging that all payments late or otherwise to the mortgage company were made by the Respondent, direct the Respondent to take whatever steps are necessary to clear any negative comments on the Petitioner's credit report caused by the Respondent's failure to make timely payments on the mortgage. Also, order the Respondent to pay counsel fees and costs relating to this Petition. Respectfully submitted, JAMES, SMITH, DIETTERICK Date:~ By: VERIFICA TION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: I J - /1- /) L/ ~IU>' {? /I{U[L Stephanie R. House, Petitioner EXHIBIT "A" BROCK LASHER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 99 - 1771 STEPHANIE LASHER, Defendant ACTION IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT BETWEEN BROCK LASHER AND STEPHANIE LA:~ THIS AGREEMENT made this/3 ft1 day of Ju /.j ,1999 by BROCK LASHER, an adult individual of Cumberland County, Pennsylvania, and STEPRANIE: LASHER, adult individual of Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties were married on January 23, 1998, in Cumberland County, Pennsylvania, but they have since separated, and; WHEREAS, WIFE and HUSBAND have reached agreement on financial and property matters arising out of a pending divorce action between them; NOW THEREFORE, intending to be legally bound hereby, the parties hereto agree as follows: 1. LIVING SEPARATE AND APART. That the parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apc:lrt from each other. Whereas a Complaint in Divorce was filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and forever determine their respective rights. The division of exisiting marital property is not intended by the parties to constitute in any way a sale or l~xchange of assets. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall harrass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 2. PROPERTY. Except as may otherwise be provided in this A~)reement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waiver, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. The parties agree that their property is to be divided as follows: A. MARITAL RESIDENCE. The parties acknowledge that they owned, as tenants by the entireties, real property known as 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania 17013 (hereinafter referred to as the marital residence). Wife has transfered to husband, all of her right, title, and interest in the marital residence, subject to any outstanding debt associated with the marital residence which shall be husband's sole and exclusive responsibility. Thereafter, husband shall be the sole and exclusive owner of the marital residence free and clear of any right, title and interest of wife's. Husband shall be solely responsible for all payments of taxes, utility charges, mortgage payments, assessments, and maintenance costs of the marital residence and shall indemnify wife and hold her harmless from any responsibility thereof. B. MOTOR VEHICLES. With respect to the motor vehicIE~S, owned by one or both of the parties, they agree as follows: i. Each party agrees to be solely responsible for thl3 amounts presently due and owing against his or her respective automobiles. ii. Wife shall retain possession of the 1998 ZX-2 Escort. iii. Husband shall retain possession of the 1996 Ford Ranger. c. PERSONAL PROPERTY. i. Wife shall obtain custody of the couple's dog, Samson, on or about July 17, 1999. D. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 3. DEBTS. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her 13state might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all debts in her name alone regardless of when incurred. Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all debts in his name alone regardless of when incurred. A. CREDIT CARDS. i. Husband will payoff the Cornerstone Credit card, which has a balance of approximately $400 until the credit card is completely paid off. After that time, Husband will obtain a credit card which is in his name alone. ii. Wife will pay the Cornerstone Credit Consolidation loan, which has a current balance of approximately $1500. Within the next 60 days, Wife shall attempt to get another loan in her name alone and pay this joint debt off immediately. 4. INCOME TAX RETURNS: All current and future income tax returns shall be filed separately and the refunds, if any, shall be retained by the respective parties. 5. SPOUSAL SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be granted. 6. DIVORCE: The parties agree to cooperate with each othl~r in obtaining a final divorce of the marriage. It is agreed that at final settlement the parties will execute and file the consents necessary to obtain the divorce. It is further agreed that the parties' marriage is irretrievably broken. 7. BREACH: If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights uncler this agreement. 8. ADDITIONAL INSTRUMENTS: Each of the parties shall, from time to time, at the request of the other, execute, acknowledge. and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. 9. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect have been fully explained to the parties and its provisions are fully understood. Husband's legal counsel is Jane Adams, Esquire, and wife has no counsel. Both parties agree that thl~y are executing this agreement freely and voluntarily. 10. ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants, or undertakings lother than those expressly set forth herein. 11. APPLICABLE LAW: This agreement shall be construed under the law of the Commonwealth of Pennsylvania. 12. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which mayor have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship. including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. IN WITNESS WHEREOF, the parties have hereunto set th,eir hands and seals the day and year first above written: WITNESS: I,VaAJ U(j :'L~ Witness v 15~tllL BROCK LASHER Date: 1/11/ r9 Address: WITNESS: -Jl!:{/&)C ~~~ Itness Dat& COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Address: } }:ss } On this, the /3 day of :t~ ' 1999, before me, the undersigned officer, personally appeared STEPHANIE LASHER known to me, .(or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledg1ed that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and officicil seal. ..~ ~.:.... . .e ._. . COMMONWEALTH OF PENNSYLVANIA' } ):ss COUNTY OF CUMBERLAND ) On this, the 13 day of ~ ,1999, before me, the undersigned officer, personally appeared BROCK LASRER kn'own to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand,and official seal. BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantJPetitioner : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVIC~ I, John J. Connelly, Jr., Esquire, of James, Smith, Diett(:rick & Connelly, attorney for the Petitioner, Stephanie R. House, hereby certify that I have served a copy of the foregoing Petition to Enforce Property Settlement Agreement on the following on the date and in the manner indicated below: U.S MAIL. FIRST CLASS. PRE-])AID Brock Lasher 110 Meadowbrook Road Carlisle, PA 17013 JAMES, SMITH, DIETTERICK & CONNELLY DATE: \ \ \~ol1 C) r-~ 0 C. ,) '" -n j,- -1 -1 T\ ..,:.: [;1 r::: : 1'. " h r' C., " , C) , , , -', ,1 ) '> n .- r 1 '-;::.. - 'j C1 :~ -, -<.. ~ BROCK LASHER, PlaintiffIRespondent NOY r 2004 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantJPetitioner : CIVIL ACTION - LAW : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this .Il}l dayof JJ~ ,2004, upon consideration of the foregoing Petition to Enforce Marital Settlement Agreement, a Rule is hereby entered against the Respondent, Brock Lasher, to show cause why the relief requested in the attached Petition should not be granted. Rule returnable in writing Z- 0 days from the date of service. BY THE COURT:: / /1 ,6/~ J. f~ IX '-~O~ ~'?O '\I ff\\fi'~\}\S>: \\:;j,.j A.lNn(Y~; ('l ..', '-:}"~:O 9tt :9 H"\1 at: ;,011 I]Gul }.Hv'lO:\JHj.C(~d 3\41 :10 :;:)~:\=.Cl-Q:ri;:\ ~ DEe 1 7 2004 f. BROCK LASHER, Plaintiff /Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil n:rm STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, : CIVIL ACTION - LA W Defendant/Petitioner : DIVORCE ORDER AND NOW, this ~::;J7d day of ~i2e._.e/Jnf.~ ,2004, upon consideration of the Petition to Enforce Property Settlement Agreement and Response, a hearing is hereby scheduled for the / V0 Day of :P? &1# a7ft-' , 20~ at '/ /' 30 /}. M. in Courtroom No. Y , of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: cc: ~ohn Connelly, Jr., Esquire ....-Jane Adams, Esquire /4J "" ~ / 2 ~ 22-0 ~( . ~, ','- .-' .,,+- t ~ - , ,.. ,,~...J. ~ ~ ~J ./ " J ..~) _~ }l~DZ BROCK LASHER, PlaintifElRespondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil T(~rm STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, : CIVIL ACTION - LA W Defendant/Petitioner : DIVORCE ORDER AND NOW, this day of , 2004, upon consideration of the Petition to Enforce Property Settlement Agreement and Response, Petitioner's request is DENIED and the petition is DISMISSED. BY THE COURT: J. cc: John Connelly, Jr., Esquire Jane Adams, Esquire BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Tema STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, : CIVIL ACTION - LA W Defendant/Petitioner : DIVORCE RESPONSE TO DEFENDANT'S PETITION TO ENFORCE MARITAL SETTLEMENT AGREEl\lENT AND NOW COMES, Brock Lasher, by and through her attorney, Jane Adams, Esquire, and files the following response to Defendant's petition: I. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. Respondent has occasionally but not consistently made late mortgage payments. Respondent has no knowledge as to what effect this has had on Petitioner's credit report. 8. Denied. Respondent has made all payments relating to the marital home and Petitioner has not paid anything towards the marital home since the agreement. Respondent currently has two mortgages, totaling $790 a month, the second of which was obtained to satisfy over $10,000.00 in credit card bills that Plaintiff incurred during the marriage. Respondent previously attempted to refinance the mortgage obligation on the property and was denied. Paragraph 2A of the parties' agreement does not require Respondent to refinance to mortgage obligation on the marital home. Nevertheless, Respondent is willing to attempt to refinance this obligation or sell the residence promptly in order to remedy this situation. Respondent is also willing to provide Petitioner with any documents he can obtain from the mortgage company which might show that she is not responsible for late payments. He will also agree to send a letter of explanation to any credit reporting agency who has reported negatively on Petitioner's credit. 9. Denied. Respondent should not have to pay Petitioner's legal fees. Respondent denies that he breached the agreement since the agreement does not require him to sell or refinance and further notes that Petitioner chose to take formal legal action before writing to Respondent to notify him of the alleged breach. Petitioner should be required to pay her own legal fees since she voluntarily and unnecessarily incurred those fees when the matter might have been resolved without legal action. WHEREFORE, Respondent, Brock Lasher, respectfully r1equests this Honorable Court to enter an Order that either denies Petitioner's Motion or sets a hearing regarding this matter. Date: ld-l/b~Lj VERIFICATION I verify that the statements made in this Response are tlUe and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: /Z/I{;! 01 ~~_/ Brock Lasher, Respondent CERTIFICATE OF SERVICE AND NOW, this December 16,2004 I, Jane Adams, Attorney for Respondent, Brock Lasher, hereby certify that a copy of this response has been duly served upon the following party, by placing such in the custody of the United States Postal Servic(~, via certified mail, postage pre- paid addressed to: John J. Connelly, Jr, Esquire Attorney for Petitioner P.O. Box 650 Hershey, Pa. 17033 (717) 533-3280 ( ) ",) (: , r f' -', \., ~ .....-' -I I r:") :--1 ! ; 1 ( -'J r I"j , r, C'\ , -;--; , , r' ) I i -. ; r-,) ..... . BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantlPetitioner : CNIL ACTION - LAW : DIVORCE STIPULATION RELATIVE TO THE PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT It is hereby stipulated by and between the Plaintiff, Brock Lasher, and his Attorney, Jane Adams, Esquire, and the Defendant/Petitioner Stephanie R. House, and her Attorney, John J. Connelly, Jr., Esquire as follows: i. Brock Lasher shaH keep the mortgage obligation on the home located at 110 Meadowbrook Road current and shaH make all future payments in a timely manner. 2. The home at 110 Meadowbrook Road is currently listed for sale. Brock Lasher shaH cooperate with the realtor in order that the home can be sold in a timely fashion. He wiH also provide Stephanie R. House with the name and telephone number of the realtor and shaH sign any appropriate consents in order to aHow Stephanie R. House and/or her attorney to communicate openly with the realtor. 3. Brock Lasher shaH be permitted to apply for refinancing or fuH assumption of the current loan which would thereby make Brock Lasher solely responsible to the loan company for any outstanding amounts currently owed on the mortgage obligation. However, pending final approval ofrefinancing, the home shaH remain listed for sale and Brock Lasher wiH not take any action which would prevent sale of the home. . 4. Upon the final date of settlement or refinancing, Brock Lasher shall pay John J. Connelly, Jr. Six Hundred ($600.00) Dollars which represents Stephanie R. House's outstanding Attorney's fees. 5. DefendantlPetitioner Stephanie R. House reserves the right to have a hearing rescheduled in this matter in the event Brock Lasher fails to comply with this stipulation. Respectfully Submitted, an :A.dams, EsqUlre 6 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Brock Lasher By: ;.-i ..,.' ;- ....~ ~.i; ~, '>h .-j ~".."' C) ~"~~ -..- (n r<: BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE ORDER AND NOW, this '2-/~' day of /7"".,i , , 2005, upon consideration of the foregoing Stipulation relative to the Petition to Enforce Marital Settlement Agreement, it is hereby ORDERED and DECREED that the attached Stipulation of the Parties, which was filed on AI''' 'I Zf) . , 2005 is hereby incorporated into this Order of Court. The hearing in this matter originally scheduled for February 14, 2005 at 9:30 a.m. is hereby continued generally. BY THE COURT: ,44 J. cc: Z I ::, lid 17 \1 .Pf 1'[.'7 ,~u'~~ -,-,;,.I.... :iHl :JC ::;~J~:>!C.{)3lU BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil TeJm STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE PETITION FOR CONTEMPT AND TO ENFORCE TERMS OF MARITAL SETTLEMENT AGREEMENl: AND NOW, comes the Petitioner, Stephanie R. House, by and through her attorneys, James, Smith, Dietterrick & Connelly LLP, and avers as follows: 1. The Petitioner is Stephanie R. House, Defendant in the above-captioned action. 2. The Respondent is Brock Lasher, Plaintiffin the above-captioned action. 3. On November 16, 2004, your Petitioner filed a Petition to Enforce Marital Settlement Agreement alleging that the Respondent had violated the terms of the agreement by not timely paying the mortgage on the former marital residence located at I 10 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania. A copy of the said Petition is attached and marked as Exhibit "A". 4. After negotiations between counsel for the parties, a Stipulation was entered of record on April 21, 2005. A copy of said Stipulation is attached and marked as Exhibit "B". 5. The Stipulation provided in part that the Meadowbrook Road property was listed for sale and that the Respondent was to cooperate with the realtor in order that the home could be sold in a timely fashion. 6. The Respondent was also gIven the option of applying for refinancing or assumption of the loan, making him solely responsible for the outstanding balance on the mortgage. It was required, pending approval of refinancing, that the home remain listed for sale and that he would take no action that would prevent the sale of the home. 7. As part of the Stipulation, the Respondent agreed to pay counsel fees in the amount of$600.00 to counsel for the Petitioner at the time of final settlement or refinancing. 8. It has come to the attention of your Petitioner that the Respondent removed the property from the market in July of2005. Prior to a recent payment, the mortgage was delinquent for the months of July, August, September, October and November, continuing to cause the Petitioner significant credit problems. The mortgage is now delinquent fix October and November. 9. The history of the payments are that the Respondent did not make the March payment until April 18, 2005 and the April, May and June payments were not made until June 6, 2005. 10. Counsel for the Petitioner wrote to Respondent's counsel on May 27, 2005 and July 12, 2005 raising the issues of delinquent payments and the property being removed from the market in violation of the stipulation. Said letters are attached hereto and marked as Exhibit "C" and "D". 1 i. Petitioner has expended additional sums in counsel fees in the amount of $467.50 since the Order of April 21, 2005 to enforce the tenns of the Stipulation including telephone calls, correspondence and the preparation of this Petition. In addition to attorney's fees set forth in paragraph 7 hereof, the Petitioner will incur ongoing counsel fees in enforcing the tenns of the Agreement for which the Respondent is also responsible. Said fees to be provided to the Court at the time of hearing in this matter. WHEREFORE, the Petitioner requests that the Respondent be held in contempt for violation of the Court's Order attached to the Stipulation dated April 21, 2005 due to the failure of the Respondent to maintain the property on the market or to timely make the mortgage payments. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY Date: \ \ \ A?Y \ t ~ By: JohnV. Cpnne~, Jr., Esquire AttoIj1ey\t?.rP\ltitioner \ Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA LD. No. 15615 VERIFICATION I verifY that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date:~ I -,),3 . 05' BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Telm STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP, attorney for the Defendant/Petitioner, Stephanie R. House, hereby certifY that I have served a copy of the foregoing Petition for Contempt and to Enforce Terms of Marital Settlement Agreement on the following on the date and in the manner indicated below: V.S MAIL. FIRST CLASS. PRE-PAID Jane Adams, Esquire 36 South Pitt Street Carlisle, P A 17013-3225 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: ~ By: EXHIBIT" A" NOV 1 ~ 2004 BROCK LASHER, PlaintiffIRespondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this 19 tltday of DO\le~~Q ,2004, upon consideration ofthe " foregoing Petition to Enforce Marital Settlement Agreement, a Rule is hereby entered against the Respondent, Brock Lasher, to show cause why the relief requested in the attached Petition should not be granted. Rule retumable in writing J.[) days from the date of service. BY THE COURT: J. TRUE COpy FR.OM R\:CORD In Testi~ony whereof, I here unto set my hand an the sea! of s id Court at Carlisle, pa. i '. i m30:". i~~:;,J~ BROCK LASHER, PlaintifflRespondent : IN THE COURT OJ. COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantlPetitioner CIVIL ACTION - LAW : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2004, upon consideration of the within Petition to Enforce Property Settlement Agreement, a hearing is hereby scheduled for the day of , 2004, at o'clock .m. in Court Room No. of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: J. BROCK LASHER, PlaintifURespondent : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner f'") r<' ',"'-, , () ~il .--\ - ~ . <, __I f\ CIVIL ACTION - LAW IN DIVORCE \,' (" PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT .; ) l\ -:'i COMES NOW, Petitioner, Stepharrie R. House, formerly Imown as Stepharrie Lasher, by and tlrrough her attorneys, James, Smith, Dietterick & Connelly, by John J. Connelly, Jr., Esquire, and files the following Petition to Enforce Property Settlement Agreement and in support thereof respectfully represents as follows: I. Petitioner is Stepharrie R. House, Defendant in the above-captioned action, currently residing at 126 Second Street, West F airview, Cumberland County, Pennsylvarria 17025. 2. Respondent is Brock Lasher, Plaintiff in the above-captioned action, currently residing at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvarria 17013. 3. On or about July 13, 1999, the parties entered into a Marital Settlement Agreement, a copy of which is attached hereto and marked Exhibit "A". 4. Under Paragraph 2A of the Marital Settlement Agreement, the Petitioner transferred all right, title and interest to the real estate located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvarria, the former marital residence of the parties to the Respondent. 5. Pursuant to Paragraph 2A, the Respondent was responsible for all payments of taxes, utility charges, mortgage payments, assessments and was to indemnity and hold Petitioner hannless on the said obligations. Also pursuant to Paragraph 2A of the Agreement, the Respondent was assummg sole and exclusive responsibility for any outstanding debts associated with the residence. 6. At the time the parties signed the Agreement, they had a mortgage with Countrywide Home Loans, account no. 1873789. 7. Since the date of the parties' Agreement, the Respondent has been consistently late with the mortgage payments causing a negative effect on the Petitioner's credit report. 8. Pursuant to the Marital Settlement Agreement, the Respondent has failed to hold the Petitioner harmless under the terms of Paragraph 2A and has caused the Petitioner's credit rating to deteriorate. The Respondent must, in order to remedy the problem, refinance the said property in his name individually or sell the residence immediately. He must also provide the Petitioner with confirmation from the mortgage company that she was not responsible for any late payments that have occurred since the date of the parties' Agreement in 1999. He must also send a letter of explanation to any credit reporting agency who has reported negatively on Petitioner's credit. 9. Pursuant to Paragraph 7 of the Agreement, award to the Petitioner all legal fees and costs associated with the enforcement ofthis Petition. WHEREFORE, your Petitioner, Stephanie R. House, respectfully requests that the Court direct the Respondent, Brock Lasher, to immediately sell or refinance the property located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania, thereby removing the Petitioner's name from the mortgage obligation to Countrywide Home Loans and , further, direct the Petitioner to secure a letter of explanation from Countrywide Home Loans acknowledging that all payments late or otherwise to the mortgage company were made by the Respondent, direct the Respondent to take whatever steps are necessary to clear any negative comments on the Petitioner's credit report caused by the Respondent's failure to malce timely payments on the mortgage. Also, order the Respondent to pay counsel fees and costs relating to this Petition. Respectfully submitted, Date:~ By: VERIFICATION I verifY that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: if - 11-(; L/ \i. / /) l-,/ /(. ~VJ/)(llu..J2 /1 / I(l&...~ . Stephanie R. House, Petitioner EXHIBIT "An BROCK LASHER, Pia i ntiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 99 - 1771 STEPHANIE LASHER, Defendant ACTION IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT BETWEEN BROCK LASHER AND STEPHANIE LASHER THIS AGREEMENT made this! 3 ft. day of Ju / '-j , 1999 by BROCK LASHER. an adult individual of Cumberland County, Pennsylvania, and STEPAANIE LASHER, adult individual of Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties were married on January 23, 1998, in Cumberland County. Pennsylvania, but they have since separated, and; WHEREAS. WIFE and HUSBAND have reached agreement on financial and property matters arising out of a pending divorce action between them; NOW THEREFORE, intending to be legally bound hereby, the parties hereto agree as follows: 1. LIVING SEPARATE AND APART. That the parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and forever determine their respective rights. The division of exisiting marital property is not intended by the parties to constitute in any way a sale or exchange of assets. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall harrass, annoy, injure. threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 2. PROPERTY. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waiver, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. The parties agree that their property is to be divided as follows: A. MARITAL RESIDENCE. The parties acknowledge that they owned, as tenants by the entireties, real property known as 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania 17013 (hereinafter referred to as the marital residence). Wife has transfered to husband, all of her right, title, and interest in the marital residence, subject to any outstanding debt associated with the marital residence which shall be husband's sole and exclusive responsibility. Thereafter, husband shall be the sole and exclusive owner of the marital residence free and clear of any right, tille and interest of wife's. Husband shall be solely responsible for all payments of taxes, utility charges. mortgage payments, assessments, and maintenance costs of the marital residence and shall indemnify wife and hold her harmless from any responsibility thereof. B. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: i. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. ii. Wife shall retain possession of the 199B ZX-2 Escort. Iii. Husband shall retain possession of the 1996 Ford Ranger. C. PERSONAL PROPERTY. i. Wife shall obtain custody of the couple's dog, Samson, on or about July 17, 1999. D. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the iuture. 3. DEBTS. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incu r any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason oi debts or obligations incurred by him. Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all debts in her name alone regardless of when incurred. Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all debts in his name alone regardless of when incurred. A. CREDIT CARDS. i. Husband will payoff the Cornerstone Credit card, which has a balance of approximately $400 until the credit card is completely paid off. After that time, Husband will obtain a credit card which is in his name alone. ii. Wife will pay the Cornerstone Credit Consolidation loan, which has a current balance of approximately $1500. Within the next 60 days, Wife shall attempt to get another loan in her name alone and pay this joint debt off immediately. 4. INCOME TAX RETURNS: All current and future income tax returns shall be filed separately and the refunds, if any, shall be retained by the respective parties. 5. SPOUSAL SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be granted. 6. DIVORCE: The parties agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that at final settlement the parties will execute and file the consents necessary to obtain the divorce. It is further agreed that the parties' marriage is irretrievably broken. 7. BREACH: If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 8. ADDITIONAL INSTRUMENTS: Each of the parties shall. from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. 9. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect have been fully explained to the parties and its provisions are fully understood. Husband's legal counsel is Jane Adams, Esquire. and wife has no counsel. Both parties agree that they are executing this agreement freely and voluntarily. 10. 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. 11. APPLICABLE LAW: This agreement shall be construed under the law of the Commonwealth of Pennsylvania. 12. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which mayor have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as herein othelWise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any Jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take intestacy, right to take against the Will of the other, and right to act as administrator or executor of the others estate, and each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: C: j ~ ~ 1 ^ ) () A (/ Ii. . WuA.../ Witness v f3df!Y-- BROCK LASHER Date flll/ '19 Address: WITNESS: -v;k//uX' ~ Itness Dat& , COMMONWEALTH OF PENNSYLVANIA Address: COUNTY OF CUMBERLAND ) ):ss ) On this, the /3 day of :r~ ' 1999, before me. the undersigned officer, personally appeared STEPHANIE LASHER known to me,(or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. d~L __)U NOt8.nr.tl Sas! M co~m~(t,>0~~W"~!ti~1~% ~u~~ty ...My Cor,-,rn~~~I~t~.f::';'f'!.~EH, gtt..,!~' ~~~o S ffi. Qt, PIlflHWIYsille ""soolli j,," of Notalies COMMONWEAL TH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the 13 day of ~ ,1999, before me, the undersigned officer, personally appeared BROCK LASRER kn'own to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL Notaiial Seal aollnie L. Sholl.BY, Notary Public My cO'nllWlllilQlblQ:f(plrellarland County . My CommIssion EFires Oct. 19,2000 SE IffI II, P.nn,YW.lii~ A9S91li9tion 01 Notaries BROCK LASHER, Plain tiffi'Respon den t : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 99-1771 STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, John 1. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, attorney for the Petitioner, Stephanie R. House, hereby certify that I have served a copy of the foregoing Petition to Enforce Property Settlement Agreement on the following on the date and in the manner indicated below: U.S MAIL, FIRST CLASS, PRE-PAID Brock Lasher 110 Meadowbrook Road Carlisle, PA 17013 JAMES, SMITH. DIETTERlCK & CONNELLY DATE: \\ \ ~ 0 4 B.'- y. , John 1. Connelly Jr., Esquire {/ I A, Y f1 ltioner \ Post Office Box 650 Hershey, P A 17033 (717) 533-3280 P A I.D. No. 15615 EXHIBIT "B" RECEIVED APR 21 ZOOS:}< BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE ORDER AN\) NOW. "" 1}sf d'y of ~p.u1 the foregoing Stipulation relative to the Petition to Enforce Marital Settlement Agreement, it is ,2005, upon consideration of h"'ij:DEIlliD md OlieREEO "", ili, ,"'w',d "'po''''o, ofili, Pert,,,. whi,' w,; fil'" on ~11 20~ ,2005 is hereby incorporated into this Order of Court. The hearing in this matter originally scheduled for February 14, 2005 at 9:30 a.m. is hereby continued generally. J. cc: John Connelly, Jr., Esquire Jane Adams, Esquire BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, fonnerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE (:-) '" C~;:; c::::J G'l ::~ :::i.J r-~) C.J c) ~n ::;c! f~l~ n-, Q ~-~: .. i::,i STIPULATION RELATIVE TO THE PETITION TO~.NFOHCE ~~A!l!:r:'ll s!:r!'TLE-~1EI'tr AGr~El't1El",T ,-rl U1 <.~) It is hereby stipulated by and between the Plaintiff, Brock Lasher, and his Attorney, Jar" Adams, Esquire, and the DefendantlPetitioner Stephanie R. House, and her Attorney, John J. COlmelly, Jr., Esquire as follows: I. Brock Lasher shall keep the mortgage obligation on the home located at 110 Meadowbrook Road current and shall make all future payments in a timely mmmer. 2. The home at 110 Meadowbrook Road is currently listed for sale. Brock Lasher shall cooperate with the realtor in order that the home can be sold in a timely fashion. He will also provide Stephanie R. House with the name and telephone number of the realtor and shall sign any appropriate consents in order to allow Stephanie R. House and/or her attorney to communicate openly with the realtor. 3. Brock Lasher shall be permitted to apply for refinancing or full assumption of the current loan which would thereby make Brock Lasher solely responsible to the loan company for any outstanding amounts currently owed on the mortgage obligation. However, pending final approval of refinancing, the home shall remain listed for sale and Brock Lasher will not take any action which would prevent sale of the home. 4. Upon the final date of settlement or refinancing, Brock Lasher shall pay John J. Connelly, Jr. Six Hundred ($600.00) Dollars which represents Stephanie R. House's outstanding Attorney's fees. 5. Defendant/Petitioner Stephanie R. House reserves the right to have a hearing rescheduled in this matter in the event Brock Lasher fails to comply with this stipulation. Respectfull y Submitted, an 1\.dams, EsqUIre 6 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Brock Lasher By: EXHIBIT "C" JAMES SMITH DIrrrERICK & CONNELLY UP John J. Connelly, Jr. iic{@isdc.com FAX 7175337771 May 27, 2005 VIA FACSIMILE 243-9200 Jane Adams, Esquire 36 South Pitt Street Carlisle, P A 17013-3225 Re: House/Lasher Dear Jane: Your client is in violation of the existing Court Order in this matter because he has not made mortgage payments on a timely basis. He made the March I, 2005 payment on April 18, 2005 and the April and May payments are still outstanding. This is causing my client significant problems on her credit report and unless your client brings the mortgage current for April and May by June I, 2005 and the June payment made no later than June 15, 2005, we will file a Petition for Contempt and request counsel fees. It seems apparent to me that he has no interest whatsoever in complying with the terms of the Court's Order. Please give me a call after you have spoken to him. Very truly yours, C~g ~q,,-~'t John J. Connelly, Jr. JJC/mbl cc: Stephanie House Dictated but not read. I .\ II (l I I I ( I ~ JS.}( PO BOX 650 HERSHEY. PA 17033 GaUlle' Address 134 SIPE AVENUE HUMMELSTOWN, PA 17036 TEL. 717,5333280 VVWW,JSDC,COM GARY L. JAMES MAX J. SMITH, JR. JOHN J. CONNELLY, JA Scan A. DIETTERICK JAMES F. SPADE MATTHEW CHABAL, III GREGORY K. RICHARDS SUSAN M. KADEL JARAD W. HANDELMAN DONNA M. MULLIN EDWARD P. SEEBER NEil W. YAHN COURTNEY L KISHEL KIMBERLY A. DEWITT OF COUNSEL: BERNARD A. RYAN, JR. HERSHEY, PA EXHIBIT "D" ]AMEs SMITH DIITTERICK & CONNELLY UP John J. Connelly, Jr. licuuisdc.com FAX 7]7533.7771 July 12, 2005 Jane Adams, Esquire 36 South Pitt Street Carlisle, P A 17013-3225 Re: House/Lasher Dear Ms. Adams: It has come to my client's attention that Mr. Lasher has removed the house from the market and although the mortgage is now current as of today's date, it has been late three times. The March 5, 2005 payment was not made until April 18, 2005. The April, May and June payments were not made until June 6, 2005. As of today, the July payment is currently outstanding. My client has grown weary of dealing with this issue and we must resolve it promptly. Please call my office upon receipt of this correspondence to discuss a prompt remedy or we will find ourselves before the Court in short order. I will await your call. Very truly yours, \f~~ ~ C~,vl~9c !"YIJ;Z John J. Connelly, Jr. JJC/mbl cc: Stephanie House Dictated but not read. I..\\\' (lllll I.., JS).C PO BOX 650 HERSHEY. PA 17033 Courier Address 134 SIPE AVENUE HUMMELSTOWN. PA 17036 TEL. 7175333280 WWW JSOC-COM GARY L JAMES . MAX J. SMITH. JR JOHN J. CONNELLY, JR SCOTT A D1ETTERICK JAMES F, SPADE MATl"HEW CHABAL, III GREGORY K. RICHARDS SUSAN M. KADEL JARAD W HANDELMAN DONNA M. MULLIN EDWARD P SEEBER NEIL W. YAHN COURTNEY L KISHEL KIMBERLY A DEWITr OF COUNSEL' BERNARD A. RYAN, JR. HERSHEY, PA Co .~") -jl ::;-3 :1-1 I'.) \...:,.) {.; (-, ~ DEe 0 1 2005tJr'-- BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE RULE TO SHOW CAUSE AND NOW, this I III day of 1:>". (<,.r- ,2005, upon consideration of the foregoing Petition for Contempt and to Enforce Terms of Marital Settlement Agreement, a Rule is hereby entered against the Plaintiff /Respondent, Brock Lasher, to show cause why he should not be held in contempt. Rule returnable in writing 20 days from the date of service. By the Court, 44 J. /) - 1. -lj ') ~j ~ fl' ~, ,. Jl..l ! _ r', BROCK LASHER, Plaintiff /Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantlPetitioner : CIVIL ACTION - LAW : DIVORCE RESPONSE TO DEFENDANT'S PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT AND NOW COMES, Brock Lasher, by and through her attorney, Jane Adams, Esquire, and files the following response to Defendant's petition: I. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied; Respondent did cooperate with the Realtor and there were three sales agreements on the home, all of which were terminated due to no fault of Respondent. Respondent attempted to sell the home, but when he was unable to sell the home or pay the mortgage payment, after six months, he secured renters for the home which would cover the mortgage payment and thereby prevent foreclosure. 6. Denied; Respondent was give the option of applying for refinancing, but could not qualiry. Respondent took no action to prevent sale of the home during the listing. Respondent was not responsible for the home not selling. He rented the home to prevent foreclosure and further consequences to Petitioner. 7. Admitted, that Respondent agreed to pay legal fees up to a limit of $600. Denied that Respondent agreed to, or should be required to pay additional fees. 8. Admitted in part, denied in part. It is admitted that Respondent removed the property from the market in July of 2005 and that the mortgage was delinquent from July through November. However, the mortgage is now current through November 2005. j 9. Admitted. 10. Admitted. 11. Respondent does not have any independent knowledge regarding Petitioner's legal fees but admits that Petitioner may have incurred additional fees. These fees are due to circumstances in part beyond Respondent's control. Respondent has made his best efforts to sell the property, and when that was no possible, took actions to make sure that the mortgage would be paid, thereby protecting Petitioner's credit rating. WHEREFORE, Respondent, Brock Lasher, respectfully requests this Honorable Court to enter an Order that sets a hearing regarding this matter. ])0'.. l~ \'1 \J '> Respectfully submitted, (' () \ ? '. .'-..-/~/ i'.j~ (/ Jane dams, Esquire !.D. N . 79465 64 S. itt Street Car 'sle, Pa. 17013 17) 245-8508 ATTORNEY FOR BROCK LASHER I VERlFICATON I verifY that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: n~t\'b // /ft~~/r;</(;;;L Brock Lasher, Respondent i ~ . CERTIFICATE OF SERVICE AND NOW, this December 19,2005 I, Jane Adams, Attorney for Respondent, Brock Lasher, hereby certiry that a copy of this response has been duly served upon the following party, by placing such in the custody of the United States Postal Service, via certified mail, postage pre- paid addressed to: John 1. Connelly, Jr, Esquire Attorney for Petitioner P.O. Box 650 Hershey, Pa. 17033 (717) 533-3280 (-'>~ (c-\ ----~~- .. /Jane dams, Esquire / ( LD. o. 79465 \ 64 .s'~uth Pitt Street . -carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT BROCK LASHER () ~ ~~;l:i' - ! (l C' ~ ....., = = C.M o Pl n o .." :r rn:D ,-- -om ?::3? ?~J~ c' C ":~I~ ::::1 :D -<: \.D -0 3;. VI , q DEe 2 1 200tl,J ! BROCK LASHER, Plaintiff /Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantlPetitioner : CIVIL ACTION - LAW : DIVORCE ORDER AND NOW, this eM nd day of ~/ , 2005, upon consideration of the Response filed regarding the Petition for Special Relief, a hearing is hereby scheduled for the 17~ Dayof 5'~~ ,200~,at 9:30 A. M. in Courtroom No. i ,of the Cumberland County Courthouse,. One Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: cc: John Connelly, Jr., Esquire ,4i Jane Adams, Esquire /J- ).-7-cJ:J C~w '~L fl ~,{~, '.'-;"- (:,,) ',:- ),,'.;- 'q'''- -_:;'~\.U U- ':C- r-" Lt_ o ("., c0 c;., ~,~- 0- N N .:,.) 1..-i,.J o ~S? c::::.' C;;;> C.... C,) '() BROCK LASHER, Plaintiff/Respondent vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-1771 CIVIL STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner DIVORCE IN RE: PETITION FOR SPECIAL RELIEF AND NOW, this ORDER 10' day of January, 2006, hearing in the above captioned matter set for February 17,2006, at 9:30 a.m. is transferred to The Honorable M. L. Ebert, Jr., in Courtroom Number 5, Cumberland County Courthouse, Carlisle, PA. The Honorable M. L. Ebert, Jr. ~e Adams, Esquire For the Plaintiff/Respondent .)1lhn Connelly, Jr., Esquire For the Defendant/Petitioner :rlm BY THE COURT, /lJ, ~ ("I", GS:Olt:':) OJ :-:\T ,1 :~D ~; BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, Defendant/Petitioner : CIVIL ACTION - LAW : DIVORCE ORDER OF COURT S1' f 1\ day of .eo \f\l()"'~ Stipulation of the parties and their counsel, it is hereby ORDERED and DECREED as follows: AND NOW, this , 2006, based on the attached 1. The Plaintiff/Respondent shall continuously list for sale the property located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania until sold. The property is currently listed with Les Welsh ofB-H Realtors, 163 North Hanover Street, Carlisle, Pennsylvania. 2. The Plaintiff/Respondent will fully cooperate with the realtor regarding the sale of the property and will provide a copy of this Order to the realtor who shall have direct contact with the DefendantlPetitioner regarding the status of the sale. 3. The Plaintiff/Respondent shall make all mortgage payments in a timely fashion keeping the mortgage current throughout the sale process. 4. At the time of settlement, the Plaintiff/Respondent shall pay to the DefendantlPetitioner from his proceeds of the sale her outstanding attorney's fees and costs in this matter not to exceed $1,500.00. 5. Upon scheduling a settlement on the sale ofthe real estate both the Plaintiff/Respondent and the realtor shall contact the Defendant/Petitioner in order to receive -, documentation of her attorney's fees as referenced above. The said fees shall be placed on the settlement sheet and paid to the DefendantlPetitioner at the time of the settlement. 6. The hearing in this matter originally scheduled for February 17, 2006 at 9:30 a.m. is hereby canceled. BY THE COURT: '--L ~/ J. Distribution: John J. Connelly, Jr., Esquire Jane Adams, Esquire ) ,) 1_ () '" "I._:"\i I ,"" .t' ..... ." ~,. '^. At;-",,__ , 'I :,I~ ,...., I') OJ ',L -, .. BROCK LASHER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99 - 1771 Civil Term STEPHANIE R. HOUSE, formerly known as Stephanie Lasher, DefendantlPetitioner : CIVIL ACTION - LAW : DIVORCE STIPULATION RELATIVE TO THE PETITION FOR CONTEMPT AND TO ENFORCE MARITAL SETTLEMENT AGREEMENT AND NOW, this 16th day of February, 2006, it is hereby stipulated by and between the Plaintiff/Respondent, Brock Lasher, and his counsel, Jane Adams, Esquire, and the DefendantlPetitioner, Stephanie R. House, and her counsel, John J. Connelly, Jr., Esquire as follows: WHEREAS, the parties entered into a Stipulation on April 21, 2005 related to the parties' former marital residence located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania; and WHEREAS, since the date of the entry of the Order the Defendant/Petitioner filed a Petition for Contempt of the prior Stipulation and enforcement of the Marital Settlement Agreement; and WHEREAS, the Court has scheduled a hearing on this matter for Friday, February 17, 2006 at 9:30 a.m.; and WHEREAS, it is the intent of the parties to enter into a Stipulation for Court Order finalizing this matter and eliminating the necessity for a hearing. , 1. On November 29, 2005, the Defendant/Petitioner filed a Petition for Contempt and to Enforce Terms of Marital Settlement Agreement. 2. Plaintiff/Respondent's counsel has contacted counsel for the DefendantlPetitioner advising that the Plaintiff/Respondent would agree to enter a Stipulation eliminating the necessity for a hearing. 3. The Plaintiff/Respondent confirms that he has listed for sale the property located at 110 Meadowbrook Road, Carlisle, Cumberland County, Pennsylvania with Les Welsh of B-H Realtors, 163 North Hanover Street, Carlisle, Pennsylvania. 4. The Plaintiff /Respondent has further agreed that he will maintain a continuous listing of the property until sold, fully cooperate with the realtor regarding the sale of the property and provide a copy of the Order in this matter to the realtor who shall have direct contact with the DefendantlPetitioner regarding the status of the sale. 5. The Plaintiff /Respondent shall pay all mortgage payments in a timely fashion. 6. At the date of settlement in this matter, the Plaintiff/Respondent shall pay to the Defendant/Petitioner her outstanding attorney's fees and costs in this matter not to exceed $1,500.00. The said attorney's fees include the $600.00 previously ordered to be paid by the Plaintiff/Respondent in the Stipulation in this matter dated April 21, 2005. 7. Upon scheduling a settlement of the sale of the real estate both the Plaintiff /Respondent and the realtor shall contact the DefendantlPetitioner in order to receive documentation of her attorney's fees bill referenced above which shall be paid on the settlement sheet to the Defendant/Petitioner at the time of closing in this matter. 2 , . 8. The limit for attorney's fees as set forth above is only subject to modification in the event there is a further breach ofthis Stipulation and Order. 9. It is agreed by the parties that the hearing scheduled in this matter for Friday, February 17,2006 at 9:30 a.m. shall be canceled. ~UU-.OJj#WL e Adams, Esquire Attorney for Plaintiff /Respondent f~(:lhk/ Brock Lasher Plaintiff/Respondent "c (c.. -- -- JOhn'l Co elly, Jr., ESqUIre Attorn~.J9r efendant:lPetiti .c- .~ ie . House Defendant/Petitioner :iL l. r}L 3