Loading...
HomeMy WebLinkAbout07-4034LARRY STRAWSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION LAURA STRAWSER, NO. 0'J- ~{0,3~ C;vit Terrr+ Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013- 3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4'h Floor Carlisle, PA 17013-3387 (717) 240-6200 NOTICIA Le han demandado a usted en la Corte. Si usted quiere defenderse de estats demandas expuestas en las pagirias siquientes, usted tiene, veinte (20) dial de plazo al partir de lag fecha de las demanda y la notification. Usted debe presenter una apariencia escrita o en persona o Page 1 of 2 por abogado y azchival en la Corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomaza medidas y puede entraz una Orden contra usted sin previo aviso o notificacion y por cualquier quej a o alivio que es pedido en la peticion de demanda. usted puede perder dinero o sus propiedades o otros derechos importantes paza usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse 1 Courthouse Squaze, 4`~ Floor Cazlisle, PA 17013-3387 (717) 240-6200 '~~ Michael D. Rentschler, Esquire Attorney for Plaintiff Page 2 of 2 LARRY STRAWSER, Plaintiff vs. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. b~- uo3y IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling, please advise in writing promptly by replying to: Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013-3387. Prothonotary LARRY STRAWSER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION LAURA STRAWSER, : NO. d ~ - Yo 3 y Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is LARRY STRAWSER, an adult individual who currently resides at 131 East Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is LAURA STRAWSER, an adult individual who currently resides at 444 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui juris and both have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties aze husband and wife and were lawfully married on Apri13,1971 in Chicago, Illinois. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction, with regard to this marriage. 8. The Plaintiff has been advised of the availability of counseling and of the right to request 1 that the Court require the parties to participate in counseling. COUNTI Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 9. The prior paragraphs of this Complaint aze incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 13. The prior pazagraphs of this Complaint are incorporate herein by reference thereto. 14. The marriage of the parties is irretrievably broken. 15. The parties have been living sepazate and apart from each other since June 1, 2007. After two (2) years have elapsed from the date of final sepazation, Plaintiff intends to file his 2 affidavit of having lived separate and apart, provided a divorce decree has not already been granted pursuant to Section 3301 C of the Divorce Code. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, it is respectfully requested that this Court enter a Decree in Divorce, pursuant to Section 3301(d) of the Divorce Code. Respectfully submitted, LAW OFFICE OF MICHAEL D. RENTSCHLER, P.C. Gj ~' _~~ Michael D. Rentschler, Esquire Attorney for Plaintiff Supreme Court I.D. #45836 28 North 32nd Street Camp Hill, PA 17011 (717) 975-9129 VERIFICATION I, Michael D. Rentschler, Esquire, do hereby swear and affirm that the statements contained in the foregoing document are true and correct based upon representations made to me by my client, the Plaintiff herein. I further certify that I am authorized to sign this verification. I understand that any false statement may be prosecuted under Pa CSA Section 4904 which relates to unsworn falsification to authorities. -'~ l'~----~_ Date: y~'~-~ - `- MICHAEL D. RENTSCHLER, ESQ. CERTIFICATE OF SERVICE I, MICHAEL D. RENTSCHLER, ESQUIRE, do hereby certify that on this date I served a copy of the foregoing Complaint in Divorce by Certified Mail, restricted delivery, return receipt requested to the following: Laura Strawser 444 West Main Street Walnut Bottom, PA 17266 Date: MICHAEL D. RENTSCHLER, ESQUIRE Attorney for Plaintiff c-? ~ o ~ <~_ ~ -~ -~ M W J_ - _ r'j.y i ~ J 3. -p J7 ~ + ~~ ? O ~ _ ' i ' "L7 .. ,`tom; ,_ r ~ .~ Z p ~ r.~ . _C L~ LARRY STRAWSER, Plaintiff vs. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION N0.07-4034 CIVIL IN DIVORCE MOTION FOR APPOINTMENT OF DIVORCE MASTER And now, comes Larry Strawser, through his attorney, Michael D. Rentschler, Esquire, who files the within Motion as follows: 1). Plaintiff filed a Complaint in Divorce against Defendant. Contemporaneously with the filing of this Motion, Plaintiff filed an amended complaint requesting equitable distribution. The parties have not been able to resolve property issues nor have they been able to obtain a divorce from each other. Consequently, it is requested that a Divorce Master be appointed to decide property issues and to grant a divorce. Plaintiff will file his Inventory and Appraisement form in accordance with the local rules. WHEREFORE, it is respectfully requested that a Divorce Master be appointed. Respectfully submitted, ,~ ~""~ ~~,r..,.- ~ -~ Michael D. Rentschler, Esquire 28 N. 32°d Street Camp Hill, PA 1701 l 717-975-9129 Supreme Court ID 45836 Attorney for Defendant CERTIFICATE OF SERVICE I, MICHAEL D. RENTSCHLER, ESQUIRE, do hereby certify that on this date I served a copy of the foregoing Motion for Appointment of Divorce Master by LISPS first class mail, postage prepaid and addressed to Defendant's legal counsel, as follows: Marcus A. McKnight, III, Esquire 60 West Pomfret Street Cazlisle, PA 17013-3222 Date: ~-~ /'~~ ~~ c MICHAEL D. TSCHLER, ESQUIRE Attorney for Plaintiff N , ~;, ~._ , J, rc;, <- -~ . ~~.° ~:_.. 4 N + ~'", h o/ LARRY STRAWSER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION LAURA STRAWSER, NO. p~- ~D~~1 Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013- 3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4"' Floor Carlisle, PA 17013-3387 (717) 240-6200 NOTICIA Le han demandado a usted en la torte. Si usted quiere defenderse de estats demandas expuestas en las paginas siquientes, usted tiene, veinte (20) dias de plazo al partir de lag fecha de las demanda y la notification. Usted debe presentax una apariencia escrita o en persona o Page 1 of 2 por abogado y archival en la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4th Floor Carlisle, PA 17013-3387 (717) 240-6200 --' ~~~ Michael D. Rentschler, Esquire Attorney for Plaintiff Page 2 of 2 LARRY STRAWSER, Plaintiff vs. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling, please advise in writing promptly by replying to: Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013-3387. Prothonotary LARRY STRAWSER, Plaintiff vs. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION NO. IN DIVORCE AMENDED COMPLAINT IN DIVORCE 1. Plaintiff is LARRY STRAWSER, an adult individual who currently resides at 131 East Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is LAURA STRAWSER, an adult individual who currently resides at 444 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui 1uriS and both have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties aze husband and wife and were lawfully married on April 3,1971 in Chicago, Illinois. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction, with regard to this marriage. 8. The Plaintiff has been advised of the availability of counseling and of the right to request 1 that the Court require the parties to participate in counseling. COUNTI Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 14. The marriage of the parties is irretrievably broken. 15. The parties have been living separate and apart from each other since Tune 1, 2007. After two (2) years have elapsed from the date of final separation, Plaintiff intends to file his 2 affidavit of having lived separate and apart, provided a divorce decree has not already been granted pursuant to Section 3301C of the Divorce Code. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, it is respectfully requested that this Court enter a Decree in Divorce, pursuant to Section 3301(d) of the Divorce Code. COUNT III Equitable Distribution 17. The prior paragraphs of this Amended Complaint are herein incorporated by reference. 18. Plaintiff requests that the Court equitably divide, distribute, or assign marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Cade. Respectfully submitted, LAW OFFICE OF MICHAEL D. RENTSCHLER, P.C -- Michael D. Rentschler, Esquire Attorney for Plaintiff Supreme Court I.D. #45836 28 Narth 32nd Street Camp Hill, PA 17011 (717) 975-9129 3 VERIFICATION I, LARRY STRAW SER, verify that the statements made in the Amended Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. LARRY S SER, Plaintiff CERTIFICATE OF SERVICE I, MICHAEL D. RENTSCHLER, ESQUIRE, do hereby certify that on this date I served a copy of the foregoing Amended Complaint by USPS first class mail, postage prepaid and addressed to Defendant's legal counsel, as follows: Marcus A. McKnight, III, Esquire 60 West Pomfret Street Carlisle, PA 17013-3222 ~' ._.- ~~f ~~ ._-- Date: ~ ~- ~~ -" MICHAEL D. RENTSCHLER, ESQUIRE Attorney for Plaintiff (~1 ~t.~ , 'Tl ~. ~ .. .~1 f..-. OQ ~ ~ ",~. ` VV~~r ~j ~ ..... JUN 0 ~ 200 ~~ LARRY STRAWSER, Plaintiff vs. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION N0.07-4034 CIVIL IN DIVORCE ORDER AND NOW, this ~~ day of June, 2008, upon consideration of Plaintiff's Motion for Appointment of Divorce Master, ~• ~~~-~ C~~~~ ~, Esquire, is hereby appointed as Divorce Master. BY C RT: ,. ~ Gv~ istribution: ichael D. Rentschler, Esquire ~arcus A. McKnight, III, Esquire G~s'~o8 ~•r~ N C ~_ > c;p cc ~'~ 4 ~ -~ 7-~ ~~ .~ [~~ ~ C7 ~ C..) c.t Larry Strawser, IN THE COURT OF COMMON PLEAS Plaintiff OF PENNSYLVANIA vs. CUMBERLAND COUNTY BRANCH Laura Strawser, ~ CIVIL ACTION Defendant ~ N0. 07-4034 IN DIVORCE PRAECIPE TO WITHDRAW ~pEARANCE ITo the Prothonotary: At the request of the Plaintiff, Larry Strawser, please withdraw my appearance as counsel of record. .. L~ Michael D. Rentschler Attorney for Plaintiff Co the Prothonotary: At the request of the Plaintiff, Larry Strawser, please enter ny appearance as counsel of record. ,. _ ., A . `' Mary ter Dissinger 1 Supreme+ Court ~ID-27736 28 N. 32nd Street Camp Hill, PA 17011 (717)975-2840 (717} 975-;1924 - fax c: Michael Rentschler, Esq. Marcus McKnight, Esq. f F :G. _: rTi "T7 ~. ST /_- . _~ r~C^ ., ~ r .A W + J ~t ""fi ~ e I wR ~~ ~SSt'~G~R & ~~`" ~"R D G ~ ~ Larry Strawser, IN THE COURT CF COMMON PLEAS Plaintiff OF PENNSYLVANIA vs. CUMBERLAND COUNTY BRANCH CIVIL ACTION Laura Strawser, NO. 07-4034 Defendant IN DIVORCE AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss .. Mary A. Etter Dissinger, attorney for Plaintiff, being duly sworn according to law, says that Michael Rentschler, Esq., former counsel for Plaintiff, mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Complaint in Divorce in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt dated July 5, 2007, attached hereto as Exhibit "A". Mary A. fitter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed before me this ~'`L day of iV ovrrnbe•- 2008 . r Notary P blic NOTARIAL 9E/1L ANNETIE PERKINS Notary PubNc CAMpiRLL 80R000N, CtMVIBERW~ COUMY A+ly CommWbn Expires Jt~l 22, 2t~9 ,i ~ ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse • so thinre can return the card to you. ^ Attach~t~is card to the back of the mailpiece, or orb the front if space permits. 1. Rrticla ed to: S~~4GJs, .• ~j tic-C±~,~ ~~~~~~~` A. Signature X ~it~/ ^ Agent B ~ R~-ive (Printed Name) C.,~te~of D D/.. Is delivery address different from item 1? ^ No If YES, enter delivery address below: 3. Service Type ~$'Certifled Mail ^ Express Mail ~ R~igtered ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. ResMcted Delivery? (Extra Fee) Yes 2. Article Number 7007 0220 0002 2527 8622 (Transfer from serve label) DOmeStiC Return Receipt 102595-02-M-1540 PS Form 3811, February 2004 EXHIBIT "A" _+. ~ `x ~., ~~ Larry Strawser, : IN THE COURT OF COMMON PLEAS Plaintiff : OF PENNSYLVANIA vs. : CUMBERLAND COUNTY BRANCH CIVIL ACTION Laura Strawser, : N0. 07-4034 Defendant : IN DIVORCE INVENTORY AND APPRAISEI~NT OF LARRY STRAWSER, PLAINTIFF Plaintiff files the following Inventory and Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three (3) years. I, Larry Strawser, verify that the statements made in this Inventory and Appraisement are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. ~ ,1 arry Strawser, Plain iff INVENTORY AND APPRAISEMENT UNDER RULE 1920.33 Updated 8/29/08 ITEM # A. 8. C. D. MARITAL PROPERTY IN IS PROPERTY BASIS FOR PERSON OR WHICH EITHER SPOUSE EXCLUDED FROM CLAIMED ENTITY WITH HAS LEGAL OR MARITAL EXCLUSION WHOM INTEREST EQUITABLE INTEREST PROPERTY IS HELD ON DATE OF SEP. 1. Marital residence J 2. '02 Dodge Dakota J Pick-up 3. W's '07 Honda J Odessy 4. '07 Harley 1200c H 5. '04 Freedom 250 H scooter 6. Orrstown chkg acct J ..381 7. Orrstown ckg acct J ..2917 8. Orrstown svgs acct J ..0050 9. Orrstown svgs acct J ..1592 10. W's life insurance- W Wholelife 11. H's Wachovia 401(k) H 12. W's Smith Barney ya Roth IRA 13. Smith Barney Fund? ,7 14. Oppenheimer Rite H Aid Stock -H cashed out 1000shares on 4/30 & kept cash for himself 15. Household goods ,7 16. Antique table Y gift from W W's -mother 17. Antique mantle clock Y from H's g- father's estate sale H 18. 2 antique guns Y heirloom gifts H 19. H's wood shop tools H 20. lawn tractor W 21. snow blower W 22, plow blade to Dixon tractor W 23. 2 burial plots J 24. computer system J 25. * water pitcher/glass set Y from H's parent's estate H 26. Sony flatscreen TV J 27. ** H's childhood pictures/albums Y W 28. Son owes parents 29. W's Member's First Sav acct #3773 30. W's Member's First CD 40-11 J 31. J/T Member's First CD 41-11 J 32. W's M & T Check Acct #4381 J 33. J/T CD @ Member's First J 34. W's M & T Sav Acct 35. 2 Cemetery Lots 36. Cabin Proceeds 37. M & T Checking Acct #2917 3$. W's M & T Checking Acct #4457 * H wants but in W's possession. ** H wants but in W's possession. INVENTORY AND APPRAISEMENT UNDER RULE 1920.33 Updated on 8/29/08 ITEM L. F. G. H. I. J. K. # DATE COST OR VALUE ON AMT OF NATURE DATE LIEN ACQUIRED ACQUIRED DATE OF LIEN ON OF LIEN OF HOLDER VALUE SEPARATION DATE OF LIEN SEPARATIO N 1. 95000.00 199000.00 on 39661.44 mtg for Orrstown 7/9/08 per son Bank w's appraisal 2. 24000.00 4360.00 on 8/25/08 3. 22000.00 19525.00 on Honda 8/25/08 4. 5840.00 on 8/25/08 5. 600.00 6. 6407.14 7. 910.56 8. 383.21 9. 747.46 10. 11. 99534.53 on 6/2/07 12. 9145.47 on 6/30/08 13. 9354.49 on 6/30/08 14. 6019.90- H w/d on 4/30/07 & kept cash 15. c 25000.00 16. 550Q.00 17. 125.00 250.00 18. 19. 8000.00 20. 4200.00 3000.00 21. 1200.00 900.00 22. 300.00 300.00 23. 1800.00 24. 1200.00 800.00 25. 100.00 26. 2000.00 1500.00 27. 28. 29. 101.14 30. 5024.13 31. 1575.21 32. 6407.14 33. 2000.00 34. 35. 1880.00 36. 30000.00 (W has recd 10000.00) 37. 950-1250/ mo 38. 29.02 39. 2746.12 Larry Strawser, IN THE COURT OF COMMON PLEAS Plaintiff OF PENNSYLVANIA vs. CUMBERLAND COUNTY BRANCH CIVIL ACTION Laura Strawser, N0. 07-4034 Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the Inventory and Appraisement upon the attorney for Defendant, by First Class United States mail addressed as follows: Marcus A. Mcknight, III, Esquire 60 West Pomfret Street Carlisle, PA 17013 Date : ~ ~a~ (.~(' Mary A. E ter Dissinger v~ w~ _.,. :- r ~ ~, r-r-~ ~- ~ c~:; _,. == ~) f~ LARRY STRAWSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. LAURA STRAWSER, Defendant . CIVIL ACTION -LAW . 2007 - 4034 CIVIL TERM . IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 3, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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: - LARRY STRAWSER Plaintiff ~lj..t L,f ..'t f ~~~r ~ ! ~~~,. ~~l~l~~' Cu,,;_._ LARRY STRAWSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. LAURA STRAWSER, Defendant CIVIL ACTION -LAW . 2007 - 4034 CIVIL TERM . IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: '~~ - O L Y W R Plainti J~P~.1 ~~tir~,; , , °. ,,, . _ I E `.~ ~ I:~ .> LARRY STRAWSER, Plaintiff v. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 4034 CIVIL TERM IN DIVORCE DEFENDANT' S AFFIDAVIT OF CONSENT 2007. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 3, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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: H L URA STRAWSER Defendant r'lrlr °iLC_'wr ~ ~ i!J~ ~" ~ _. _ ~k. LARRY STRAWSER, Plaintiff v. LAURA STRAWSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007 - 4034 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I . I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ ~ d 9 LAURA STRAWSER Defendant f'.? (s"~ `) 'i $ E ~ 1 _ +3 '?"F ~+ 1 _ F_ .ze - t ,~ _ "_ ~ . , ~ ~~~ ~~ GJ J' LARRY STRAWSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0. 07 - 4034 CIVIL LAURA STRAWSER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this day of , 2009, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on March 31, 2009, following a de novo hearing before the Support Master, the agreement and stipulation having been transcribed, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. cc: ~ Mary A. Etter Dissinger Attorney for Plaintiff / Marcus A. McKnight, III Attorney for Defendant t~s ma~~ ~~1~41' ~~ BY T OU , ., 1 p,~ Edgar B. Bayley, P.J. a ~~~ ~w ~~ou ~ LARRY STRAWSER, Plaintiff vs. LAURA STRAWSER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 07 - 4034 CIVIL IN DIVORCE THE MASTER: Today is Tuesday, March 31, 2009. The parties and counsel were at a de novo hearing before Mr. Rundle this morning and in the process of meeting, they apparently have reached an agreement with respect to the divorce issues. The Master notes that a conference has been scheduled for April 28, 2009, with counsel. Obviously, if we have an agreement today with the parties and with counsel present, we will not need to have the conference on April 28, 2009. Counsel were also directed to file pre-trial statements by April 17 and the agreement will obviate the need for having the pretrial statements filed. This action was commenced by the filing of a complaint in divorce on July 3, 2007, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. An amended complaint was filed on June 2, 2008, raising the economic issue of equitable distribution. No claims have been raised by either party for alimony or counsel fees and costs. Present in the hearing room are the 1 Plaintiff, Larry Strawser, and his counsel Mary A. Etter Dissinger and the Defendant, Laura Strawser, and her counsel Marcus A. McKnight, III. Both counsel and the parties have agreed to return tomorrow morning to sign affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce be concluded under Section 3301 (c) of the Domestic Relations Code. At that time the parties and counsel will also review the draft of the agreement. An agreement is going to be placed on the record in the presence of the parties. The agreement will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when the parties and counsel return to review the draft of the agreement, they will not be able to make substantive changes but can make typographical corrections, if necessary. The parties will be asked to affix their signatures to the agreement affirming the terms of settlement as stated an the record. Upon receipt by the Master of the completed agreement, the Master will prepare an order vacating his appointment and counsel can then filed a praecipe transmitting the record to the Court requesting a final decree in divorce. The parties were married on April 3, 1971, 2 and separated June 1, 2007. The parties have two children of the marriage, both of whom are emancipated. Ms. Dissinger. MS. DISSINGER: 1. The parties own various items of property, real estate and personal. They are itemized on Plaintiff's inventory and appraisement filed February 24, 2009. Without going through and enumerating all of the items listed on the inventory and appraisement, the agreement of the parties is that the marital residence, which is jointly owned, will become the sole and exclusive property of wife. The transfer of the deed will take place on or before April 15, 2009. The deed will be prepared by wife's counsel and provided to husband's counsel and he will promptly execute it and return it to wife's counsel. 2. With regard to the motor vehicles, each party has in their possession the vehicle they wish to retain. To the extent that it is necessary to remove the other spouse's name from the title to the vehicle in possession of the other spouse, they agree that they shall accomplish removal of their name from the title and sign it over to the other spouse on or before April 15, 2009. Any vehicle that is encumbered, the spouse receiving that vehicle will assume the encumbrance and hold harmless the other party. Wife's vehicle, the 2007 Honda Odessy, is the only one that is encumbered. When that title becomes available, husband will execute the title transferring it to wife. In the meantime, she will maintain and insure that vehicle such that husband is not identified as owning an uninsured vehicle. If she fails to do so, she will hold him harmless for her failure to keep the motor vehicle insured. In light of the Master's suggestion, wife's counsel will prepare a power of attorney which husband will sign authorizing wife to execute the title on his behalf once the encumbrance is lifted on her motor vehicle. Husband will sign that within five (5) days of receipt of the power of attorney from wife's counsel. 3. With regard to the financial accounts of the parties, wife shall receive all accounts at Orrstown Bank. Husband will receive his 401(k) which has been transferred to a Wachovia IRA. Wife relinquishes all of her 3 right, title, and interest in and to that account. The parties are the owners of a Smith Barney account, which is titled jointly. That shall become the property of husband henceforth. Wife hereby relinquishes all of her right, title, and interest in and to the joint Smith Barney account. Husband relinquishes all of his right, title and interest in and to wife's Roth IRA account at Smith Barney. It shall henceforth be her sole and exclusive property. The parties will cooperate in signing any documents necessary to effectuate the transfer of these accounts to the party who is to receive ownership of the account. 4. With regard to the household goods, all of the household goods in the marital residence shall become the sole and exclusive property of wife with the exception of some pre-marital items which husband is to receive on or about April 15, 2009. Those items that husband is to receive are his grandfather's antique mantle clock, his photo albums in the attic that are pictures of husband when he was a child, and his grandmother's water pitcher and glass set. All personal property remaining in the marital home will remain wife's and all personal property in possession of husband will remain his. 5. Husband shall receive the two burial plots that are owned jointly by the parties. Husband will arrange for the plots to be transferred to his name. When the cemetery association has prepared the appropriate documentation, it will be provided to wife who will, within ten (10) days of receipt of the document, sign transferring ownership to husband. 6. Wife is the owner of various accounts at Member's lst, some owned individually by her and some titled jointly to husband. All of the Member's lst accounts shall become the sole and exclusive property of wife. Wife's M&T accounts shall become her sole and exclusive property. The joint certificates of deposit at Member's lst shall become wife's sole and exclusive property as well. 7. The parties, during the marriage, sold a cabin in another county. The agreement for sale required three payments to be made in three different years. The first 4 payment has already been received by the parties and distributed. The second payment has been received by husband and is currently in an account. Upon execution of this agreement, husband shall divide that account equally with wife and pay her $1,000.00 on account of the cemetery plots. Upon receipt by husband of the last payment of the cabin, he will promptly, within two weeks of receipt, disburse to wife one-half the proceeds from that last payment. 8. The parties further agree that whatever order is entered by the Support Master today will expire and terminate on May 1, 2009. In the event that the Support Master indicates that there is no support due and owing to wife, then that is not an issue. In the event the Support Master orders some amount of support through May 1, 2009, the order will terminate automatically on May 1, 2009, by agreement of the parties. If it is spousal support, it will convert to alimony pendente lite through May 1, 2009, if a decree in divorce is entered before May 1, 2009, and terminate on May 1, 2009. If there is an arrearage due and owing to wife under the support order entered in this county to their support docket number, this agreement does not waive or relinquish the right of wife to collect those arrearages. 9. With regard to marital debt, there is only the debt owed on wife's car. There is an obligation due and owing to the parties by their adult son. It is in the nature of a mortgage on the residence wife is to receive. The parties, during the marriage, permitted their son to use their residence as collateral for him to obtain a mobile home. It has been the agreement of the parties and continues to be that the son will pay that mortgage. By this agreement, the parties agree that the payments are due and owing from the son to wife exclusively and that it shall be wife's responsibility to collect that debt for her sole benefit. Husband does not have any right hereafter to seek to enforce the payment agreement between him and their son. That shall be only wife's privilege and responsibility. Wife has assumed the obligation to pay the mortgage in the event that their son does not repay her. Husband will release his lien on the title of the mobile home when the debt has been been paid in full to wife. Inasmuch as wife is receiving the payment from the son for the lien against the real estate, she will indemnify and save husband harmless on account of any claims which may be made by the lien holder against husband. 5 10. Husband will maintain ownership of his life insurance policies and wife will maintain ownership of her life insurance policies and each party can designate whomever they wish as a beneficiary of those policies. 11. 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, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MS. DISSINGER: Mr. Strawser, have you heard the agreement that I dictated and the supplements that Mr. McKnight made to the record in terms of your agreement with your wife? MR. STRAWSER: Yes. MS. DISSINGER: Do you understand everything that we have said today? MR. STRAWSER: Yes. MS. DISSINGER: And the agreement that we have represented to the Court as being your agreement with your wife, is that your agreement? MR. STRAWSER: Yes. MS. DISSINGER: Do you have any questions about anything that has transpired in this room today? 6 MR. STRAWSER: No. MS. DISSINGER: And you are satisfied that this agreement should become an order of Court and you will forever be bound by its terms? MR. STRAWSER: Yes. MS. DISSINGER: Tomorrow you cannot Monday-morning quarterback it, you understand that? MR. STRASWER: Yes. MR. McKNIGHT: Laura, did you hear all of the provisions of the agreement that we reached today? MS. STRAWSER: Yes. MR. McKNIGHT: And are you willing to make that your agreement to resolve all issues in this case? MS. STRAWSER: Yes. MR. McKNIGHT: Are you satisfied with the way I have represented you throughout this process? MS. STRAWSER: Yes. MR. McKNIGHT: And you are willing to enter into this agreement and forever waive any other rights you have to the marital assets? MS. STRAWSER: Yes. THE MASTER: Thank you very much. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of 7 settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: ary A. ter iss' ger Attorney/for Pl,raintiff Marcus A. McKn~g , III Attorn y fen nt DATE: Larr Stra ser Q! 6 ~ ~ er-- aura Strawser 8 LARRY STRAWSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0. 07 ~ 4034 CIVIL LAURA STRAWSER, IN DIVORCE THE MASTER: Today is Tuesday, March 31, 2009. The parties and counsel were at a de novo hearing before Mr. Rundle this morning and in the process of meeting, they apparently have reached an agreement with respect to the divorce issues. The Master notes that a conference has been scheduled for April 28, 2009, with counsel. Obviously, if we have an agreement today with the parties and with counsel present, we will not need to have the conference on April 28, 2009. Counsel were also directed to file pre-trial statements by April 17 and the agreement will obviate the need for having the pretrial statements filed. This action was commenced by the filing of a complaint in divorce on July 3, 2007, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. An amended complaint was filed on June 2, 2008, raising the economic issue of equitable distribution. No claims have been raised by either party for alimony or counsel fees and costs. Present in the hearing room are the 1 Plaintiff, Larry Strawser, and his counsel Mary A. Etter Dissinger and the Defendant, Laura Strawser, and her counsel Marcus A. McKnight, III. Both counsel and the parties have agreed to return tomorrow morning to sign affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce be concluded under Section 3301(c) of the Domestic Relations Code. At that time the parties and counsel will also review the draft of the agreement. An agreement is going to be placed on the record in the presence of the parties. The agreement will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when the parties and counsel return to review the draft of the agreement, they will not be able to make substantive changes but can make typographical corrections, if necessary. The parties will be asked to affix their signatures to the agreement affirming the terms of settlement as stated on the record. Upon receipt by the Master of the completed agreement, the Master will prepare an order vacating his appointment and counsel can then filed a praecipe transmitting the record to the Court requesting a final decree in divorce. The parties were married on April 3, 1971, 2 and separated June 1, 2007. The parties have two children of the marriage, both of whom are emancipated. Ms. Dissinger. MS. DISSINGER: 1. The parties own various items of property, real estate and personal. They are itemized on Plaintiff's inventory and appraisement filed February 24, 2009. Without going through and enumerating all of the items listed on the inventory and appraisement, the agreement of the parties is that the marital residence, which is jointly owned, will become the sole and exclusive property of wife. The transfer of the deed will take place on or before April 15, 2009. The deed will be prepared by wife's counsel and provided to husband's counsel and he will promptly execute it and return it to wife's counsel. 2. With regard to the motor vehicles, each party has in their possession the vehicle they wish to retain. To the extent that it is necessary to remove the other spouse's name from the title to the vehicle in possession of the other spouse, they agree that they shall accomplish removal of their name from the title and sign it over to the other spouse on or before April 15, 2009. Any vehicle that is encumbered, the spouse receiving that vehicle will assume the encumbrance and hold harmless the other party. Wife's vehicle, the 2007 Honda Odessy, is the only one that is encumbered. When that title becomes available, husband will execute the title transferring it to wife. In the meantime, she will maintain and insure that vehicle such that husband is not identified as owning an uninsured vehicle. If she fails to do so, she will hold him harmless for her failure to keep the motor vehicle insured. In light of the Master's suggestion, wife's counsel will prepare a power of attorney which husband will sign authorizing wife to execute the title on his behalf once the encumbrance is lifted on her motor vehicle. Husband will sign that within five (5) days of receipt of the power of attorney from wife's counsel. 3. With regard to the financial accounts of the parties, wife shall receive all accounts at Orrstown Bank. Husband will receive his 401(k) which has been transferred to a Wachovia IRA. Wife relinquishes all of her 3 right, title, and interest in and to that account. The parties are the owners of a Smith Barney account, which is titled jointly. That shall become the property of husband henceforth. Wife hereby relinquishes all of her right, title, and interest in and to the joint Smith Barney account. Husband relinquishes all of his right, title and interest in and to wife's Roth IRA account at Smith Barney. It shall henceforth be her sole and exclusive property. The parties will cooperate in signing any documents necessary to effectuate the transfer of these accounts to the party who is to receive ownership of the account. 4. With regard to the household goods, all of the household goods in the marital residence shall become the sole and exclusive property of wife with the exception of some pre-marital items which husband is to receive on or about April 15, 2009. Those items that husband is to receive are his grandfather's antique mantle clock, his photo albums in the attic that are pictures of husband when he was a child, and his grandmother's water pitcher and glass set. All personal property remaining in the marital home will remain wife's and all personal property in possession of husband will remain his. 5. Husband shall receive the two burial plots that are owned jointly by the parties. Husband will arrange for the plots to be transferred to his name. When the cemetery association has prepared the appropriate documentation, it will be provided to wife who will, within ten (10) days of receipt of the document, sign transferring ownership to husband. 6. Wife is the owner of various accounts at Member's 1st, some owned individually by her and some titled jointly to husband. All of the Member's lst accounts shall become the sole and exclusive property of wife. Wife's M&T accounts shall become her sole and exclusive property. The joint certificates of deposit at Member's 1st shall become wife's sole and exclusive property as well. 7. The parties, during the marriage, sold a cabin in another county. The agreement for sale required three payments to be made in three different years. The first 4 payment has already been received by the parties and distributed. The second payment has been received by husband and is currently in an account. Upon execution of this agreement, husband shall divide that account equally with wife and pay her $1,000.00 on account of the cemetery plots. Upon receipt by husband of the last payment of the cabin, he will promptly, within two weeks of receipt, disburse to wife one-half the proceeds from that last payment. 8. The parties further agree that whatever order is entered by the Support Master today will expire and terminate on May 1, 2009. In the event that the Support Master indicates that there is no support due and owing to wife, then that is not an issue. In the event the Support Master orders some amount of support through May 1, 2009, the order will terminate automatically on May 1, 2009, by agreement of the parties. If it is spousal support, it will convert to alimony pendente lite through May 1, 2009, if a decree in divorce is entered before May 1, 2009, and terminate on May 1, 2009. If there is an arrearage due and owing to wife under the support order entered in this county to their support docket number, this agreement does not waive or relinquish the right of wife to collect those arrearages. 9. With regard to marital debt, there is only the debt owed on wife's car. There is an obligation due and owing to the parties by their adult son. It is in the nature of a mortgage on the residence wife is to receive. The parties, during the marriage, permitted their son to use their residence as collateral for him to obtain a mobile home. It has been the agreement of the parties and continues to be that the son will pay that mortgage. By this agreement, the parties agree that the payments are due and owing from the son to wife exclusively and that it shall be wife's responsibility to collect that debt for her sole benefit. Husband does not have any right hereafter to seek to enforce the payment agreement between him and their son. That shall be only wife's privilege and responsibility. Wife has assumed the obligation to pay the mortgage in the event that their son does not repay her. Husband will release his lien on the title of the mobile home when the debt has been been paid in full to wife. Inasmuch as wife is receiving the payment from the son for the lien against the real estate, she will indemnify and save husband harmless on account of any claims which may be made by the lien holder against husband. 5 10. Husband will maintain ownership of his life insurance policies and wife will maintain ownership of her life insurance policies and each party can designate whomever they wish as a beneficiary of those policies. 11. 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, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MS. DISSINGER: Mr. Strawser, have you heard the agreement that I dictated and the supplements that Mr. McKnight made to the record in terms of your agreement with your wife? MR. STRAWSER: Yes. MS. DISSINGER: Do you understand everything that we have said today? MR. STRAWSER: Yes. MS. DISSINGER: And the agreement that we have represented to the Court as being your agreement with your wife, is that your agreement? MR. STRAWSER: Yes. MS. DISSINGER: Do you have any questions about anything that has transpired in this room today? 6 MR. STRAWSER: No. MS. DISSINGER: And you are satisfied that this agreement should become an order of Court and you will forever be bound by its terms? MR. STRAWSER: Yes. MS. DISSINGER: Tomorrow you cannot Monday-morning quarterback it, you understand that? MR. STRASWER: Yes. MR. McKNIGHT: Laura, did you hear all of the provisions of the agreement that we reached today? MS. STRAWSER: Yes. MR. McKNIGHT: And are you willing to make that your agreement to resolve all issues in this case? MS. STRAWSER: Yes. MR. McKNIGHT: Are you satisfied with the way I have represented you throughout this process? MS. STRAWSER: Yes. MR. McKNIGHT: And you are willing to enter into this agreement and forever waive any other rights you have to the marital assets? MS. STRAWSER: Yes. THE MASTER: Thank you very much. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of 7 settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: y Mary A. Etter Dissinger Attorne for Plaintiff l Marcus A. McKni t, III Attorne~'Defe ant DATE: ` ~ Larr r wse ~ oY Laura Strawser 8 ~~Q9 A~ ~ { 6 ~. 1 ~ ~ 5 i ~4 Larry Strawser, IN THE COURT OF COMMON PLEAS Plaintiff OF PENNSYLVANIA vs. CUMBERLAND COUNTY BRANCH CIVIL ACTION Laura Strawser, N0. 07-4034 Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: November 5, 2008, by United States Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce Code: By Plaintiff April 1, 2009; by Defendant April 1, 2009. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce filed with the Prothonotary: April 1, 2009. Date Defendant's Waiver of Notice in § 3301(c) Divorce filed with the Prothonotary: April 1, 2009. Respectfully submitted, Date : y~~.~l a °t. DISSINGER AND DISSINGER Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID # 27736 28 North Thirty-Second Street Camp Hill, PA 17011 717-975-2840 cc: Marcus A. McKnight, Esquire F~L~t~~i~t~~i 20~~ ~+PR I ~ ~ 1 f ~ 58 •~; r; ~n' i71~~ '`~ tthR~ t(;i L ~ ~4~.~.5 i _ 4'r`4 V LARRY STRAWSER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. LAURA STRAWSER No. 07-4034 DIVORCE DECREE AND NOW, ~ ~1 oZ d~ , it is ordered and decreed that LARRY STRAWSER ,plaintiff, and LAURA STRAWSER ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, Attest: J. Prothonotary ~_ '`/ ~ as - ~~ ~1~~r~c~ ~ ~ ~~ !~~~~~'~c''~f ~ '~,~ ~,. 1