Loading...
HomeMy WebLinkAbout03-4456 MARY C. CROUSE, Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.OJ... o/"ISl CIVIL TERM : IN DIVORCE DONALD M. CROUSE, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these 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 grounds for divorce is indignilies or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office al the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.A1_ tN,';" CIVIL TERM : IN DIVORCE MARY C. CROUSE, Plaintiff DONALD M CROUSE, Defendant COMPLAINT UNDER SECTION 3301(C ) OR (D) OF THE DIVORCE CODE Plaintiff, Mary C. Crouse, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Mary C. Crouse, is an adult individual residing at 235 Hunters Road, Newville, Pennsylvania 17241. 2 Defendant, Donald M. Crouse, is an adult individual sometimes residing at 235 Hunters Road. Newville, Pennsylvania 17241. 3 The parties were married on June 10, 1989, in Cumberland County, Pennsylvania. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301 (c ) of the Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. 54.. . r-- i/7.,,~ '(fidKJb'lL J(/. f-JUiL Lindsay(D Baird, Esquire \ . Attorney ~ the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 94904 relating to unsworn falsification to authorities. Ml!!f~us0Iai(!:C71A2J0 ~ ~,,~ ~, - -f '- ~ r ~ () o -tl _1\ ..r- ~\ ~' l' G' - (') C. 2";" 'A ~ .. '..J 'C' MARY C. CROUSE, Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DONALD M. CROUSE, Defendant : NO. 03-4456 : IN DIVORCE CIVIL TERM AMENDED COMPLAINT UNDER SECTION 3301(C I OR (O} OF THE DIVORCE CODE Plaintiff, Mary C. Crouse, by her attorney, Lindsay D. Baird, Esquire, amends the Complaint in Divorce to add a second count for alimony thus sets forth the following: COUNT 1 - DIVORCE 1 Plaintiff, Mary C. Crouse, is an adult individual residing at 235 Hunters Road, NeWVille, Pennsylvania 17241. 2 Defendant, Donald M. Crouse, is an adult individual sometimes residing at 235 Hunters Road, NeWVille, Pennsylvania 17241. 3 The parties were married on June 10, 1989, in Cumberland County, Pennsylvania. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301 (c) ofthe Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. COUNT II. - ALIMONY 9. Paragraphs 1 through 8 of the pleading are incorporated herein by reference as though set forth in full. 10. Plaintiff requires reasonable supporUalimony to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony. ~~~ Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS ~4904 relating to unsworn falsification to authorities. (1)0 T7~ {.'l _ (h()7~ Mary C. Cr se, Plaintiff ~ ~ ~ ~ ---... ....... -c: ~ ;l - ..J::. -t-I () ~ ~ r:; ~ ~ ~ ~ ;{?(" M 5!::n ;:::C' ~l~ co n1~ , -om ~ w i!5g ~ ;J; ((? \:> 51..,.. ~ ~... --:f:j >c: - !i?t;? "c> - 0 C- o- .. -I :.< 0 ~ ~ Co -< V> ---..f: ~ (' ~ 1 ' 5:l.. MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter alon~1 with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, November 17, 2003, by Certified Mail - Return Receipt Requested, restricted delivery, a copy of said return receipt evidencing delivery being attached hereto. Said service on November 17,2003. cr- Sworn and Subscribed to befwe me this 1:t,,1 day of +~...e'i ' 2004. (\ ~.UlhJ (<O~1- Notary Public Notarial Seal Niven J. Baird, Notary Public Carlisle Boro, Cumberland County My Commission Expires Noy. 2, 2006 Member, Pennsylvanra Assoclatlonot Notaries . Complete ~ems 1, 2, end 3. Also complete item 4 if Restricted Delivery is desired. . Print your 'Jams and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: 1'1 . 0 i~17':p) D. Is cMlivery address different from item 17 0 Yes If YES, enter delivery address below: 0 No 1 "PJ1\Jf1J.b 1Y7. r!J2D use... I c/o S /lrELLUj JeFF/2JbS SO,,~ ffwr. ~ G. ~ I TL C,(;J$8/ 3. ServIce Type Ita Certified Mail , D~egistered o Insured Mail o Express Mail o Retum Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (1'____1 PS Form 3811 , August 2001 7001 2510 0006 58~1 bOb1 Domestic Return Receipt 102595-02-M-1035 , J '\ ~ ) I o c:~ ....., = = -"" <- c:: z ".... ;.-,: " fi 1 <: (~ "^;C =< I N o -n ..... --c., rn r- -"m :.09 (JO ::::j~., c~o c;rn -, .". Z U) .. '-,-.~ ~~~ N co -'- MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 : IN DIVORCE CIVIL TERM DONALD M. CROUSE, Defendant MOTION FOR APPOINTMENT OF MASTER Mary C. Crouse, Plaintiff, moves the court to appoint a master with respect to the following claims: (X) Divorce ( ) Annulment (X) Alimony ( ) Alimony Pendente Lite (x) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Cost and Expenses and in support of the motion states: (1 ) (2) (3) (4) (5) (6) (7) Date: Discovery is complete as to the claim(s) for which the appointment of a master is requested. The defendant has appeared in the action by his attorney, Sean M. Shultz, Esq. The statutory ground for divorce is irretrievable breakdown. The marital home is sold and the proceeds in escrow with plaintiff's counsel. The parties have both moved out of state (Indiana and Louisiana). The action does not involve complex issues of law or fact. The hearing is expected to take less than half a day. Additional information, if any, relevant to thEl motion: None. fl~ /101 l . ',..vAr,(A.<-( ~;. \ Ylndsay Dare'Baird;Esq. ./ 37 South Hanover Street Carlisle, PA 17013 (7'17) 243-5732 Attorney for Plaintiff C~AJ!. /, ~,,</ , I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaeS ~4904 relating to unsworn falsification to authorities. MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 : IN DIVORCE CIVIL TERM DONALD M. CROUSE, Defendant CERTIFICATE OF SERVICE I hereby certify that on this /d day of June, 2004, I have caused a true copy of the foregoing to be delivered by first class mail to: Sean M. Shultz, Esquire 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 Attorney for the Defendant ~rL~.. ~ KfJi.'k2!ljA.,b)..{ , &'- n say D:are;naird, squire 37 South Hanover Street Carlisle, PA 17013 Attorney flJr the Plaintiff Cl ~~: ,. (" -::;. ~f -~ ....., = = -"'"' , c= _'0'" o " ..... :1: 11 nl;= -niTT :DO 9c) ;;~t :.rl ,"'}-- :0:." C) dcn -::-{ I N ~ -'-,..- -'.- 'f! ", OJ ,< MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE ORDER APPOINTING MASTER AND NOW, this .-3..J.. day of June, 2004, E. Robert Elicker, II, Esquire, is appointed master with respect to the following claims: Divorce, Distibution of Property, and Alimony. BY THE COURT: cc: kdsay Dare Baird, Esquire h~an M. Shultz, Esquire LZ:I l,/d S-lmnDDZ ,iI:3VLOi,nUOdd 31-11 ::10 301.:!:1Q-031I::l MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3301(C 1 OR (Dl OF THE DIVORCE CODE Plaintiff, Mary C. Crouse, by her attorney, Lindsay D. Baird, Esquire, amends the Complaint in Divorce to add a second count for alimony tlnus sets forth the following: COUNT 1 - DIVORCE 1 Plaintiff, Mary C. Crouse, is an adult individual residing at 235 Hunters Road, Newville, Pennsylvania 17241. 2 Defendant, Donald M. Crouse, is an adult individual sometimes residing at 235 Hunters Road, Newville, Pennsylvania 17241. 3 The parties were married on June 10,1989, in Cumberland County, Pennsylvania. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301 (c) of the Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. COUNT II. - ALIMONY 9. Paragraphs 1 through 8 of the pleading are incorporated herein by reference as though set forth in full. 10. Plaintiff requires reasonable support/alimony to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony. COUNT III - EQUITABLE DISTRIIBUTION 11. Paragraphs 1 through 10 of the Complaint are incorporated herein by reference set forth in full. 12. Plaintiff and Defendant have acquired property, both real and personal during their marriage from September 17, 1977 until January 2002, the date of their separation. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. ~<tlJ4. ~ D. rd, Es uire v/ Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 24:1-5732 ,.." ~ ~ c) -~ W <;;:;:';) ~~ -lJ (::) :71 ~ ~ C) 0 -- ~ W ~ ~ ~ ~ ""'-1 ~ ----- v> ~ ~.,-,- '[l 'if' (II -. ~ MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE PRE-TRIAL STATEMENT OF PLAINTIFF. MARY C. CROUSE AND NOW, this i2Yi:,day of October, 2004, comes the Plaintiff, Mary C. Crouse, by and through her attorney, Lindsay Dare Baird, Esquire, and files her Pre-Trial Statement, and in support thereof states as follows: I. BACKGROUND The parties were married on June 10,1989, in Cumberland County, Pennsylvania. The couple separated November 17, 2003 and have been living separate and apart since that time. On September 10, 2003, Wife filed a Divorce Complaint and served husband by certified mail October 30, 2003 Wife filed an Amended Divorce Complaint on February 3, 2004, adding a count for reasonable support/alimony and on October 13, 2004 adding a count for Equitable Distribution. Master E. Robert Elicker, II, Esquire was appointed on June 3, 2004. II. PRESENT INFORMATION 1. ASSETS: A. Settlement of $38,771.49 received for sale of home/property at 235 Hunters Road, Newville, Pennsylvania, being held in escrow account with plaintiff's attorney. B. Personal Property: An Asset and Distribution Statement C. Retirement Funds: Wife has a premarital retirement plan from Essis and Sons valued at $25,606.07 December 2002. 2. EXPERTS: Wife does not anticipate calling any experts. However, if there is a question as to the value of property, Wife reserves the right to supplement this Statement. 3. WITNESSES: Wife would anticipate calling Wife and Husband. Wife reserves the right to supplement her list if necessary. 4. EXHIBITS: Wife has Income and Expense Statements and Asset and Distributions Statements attached. 5. INCOME INFORMATION: Wife is currently employed by Lowes Home Centers, Inc. Pay stubs are available for review. 6. COUNSEL FEES: Each party is paying counsel fees. 7. PROPOSED RESOLUTION: Wife respectfully requests her premarital money investment of $10,761.00 and her marital share of the remaining proceeds of settlement from the sale of the marital property currently held in escrow. Wife seeks one half of the $15,000.00 trade-in value of the marital property truck. Husband shall retain the new truck. Wife respectfully requests continued monthly supporUalimony from the Defendant in the amount of $1 ,021.00 so that she can continue to live in the manner to which she is accustomed. espectfully submitted, "af~ OA-q j6a~~ indsay Da~:~, Esquire 1.0. No. 72083 37 South Hanover Street Carlisle, PA 17013 (717) 243-5732 MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE ASSETS AND DISTRIBUTION ASSETS APPROXIMATE MR. CROUSE MS.CROUSE VALUE Sale of home $38,771.49 .. Less 10,761.00 100% Net sale proceeds $28,010.49 50% 50% Attorney's Fees, Each pay own Filing Fees and Court Costs Ms. Crouse's $25,606.07 100% Premarital Retirement Dec 02 1998 Freightliner $15,000.00 50% and keep new 50% truck trade-in value truck .. Premarital money of Ms. Crouse's paid in to home MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 : IN DIVORCE CIVIL TERM DONALD M. CROUSE, Defendant INCOME AND EXPENSE STATEMENT OF MARY C. CROUSE PART I. INCOME A. EMPLOYMENT INFORMATION: EMPLOYER: Lowe's Home Centers, Inc. ADDRESS: Louisiana POSITION: Sales clerk PAYROLL NUMBER: 436-62-3374 PAY PERIOD: Mary C. Crouse! Income and Expense Statement B.l EMPLOYMENT INCOME (BASED ON CURRENT P A YSTUB) GROSS PAY PER YEAR: $ l680.00/mo. $ 20,160.00/yr ITEMIZED DEDUCTIONS Itemized Business Deductions: Car Expense Office Expense Utilities Postage SUBTOTAL Pre-tax net TAXES SETAX $ FEDERAL TAX $ 230.00/mo. $ 2760.00/yr STATE TAX $ 46.00/mo. $ 552.00/yr LOCAL TAX $ TOTAL TAX DEDUCTIONS $ 276.00/mo. $ 33l2.00/yr TOTAL DEDUCTIONS $ 346.00/mo. $ 41 52.00/yr NET PAY PER PAY YEAR $16008.00 NET PAY PER MONTH $1334.00 Mary C. Crousel Income and Expense Statement B. OTHER INCOME: DESCRIPTION MONTHLY YEARLY INTEREST DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUND SUPPORT OR ALIMONY $1,021.00* COMMISSIONS TIPS OTHER (SPECIFY) TOTAL OTHER INCOME · This figure does not reflect arrears Mary C. Crouse/ Income and Expense Statement DESCRIPTION MONTHLY AMOUNT HOME EXPENSES: RENT $ 250.00 FIRST MORTGAGE SECOND MORTGAGE ON HOME EQUITY LOAN POOL GARDENING - FLOWER BEDS, ETC. MAINTENANCE AND REPAIRS ELECTRIC $ 120.00 GAS OIL TELEPHONE $77.00 home $32.00 cell WATER $ 20.00 SEWER TRASH OTHER UTILITIES/SPECIFY EMPLOYMENT: PUBLIC TRANSPORTATION LUNCHES OTHER EMPLOYMENT EXPENSES/SPECIFY TAXES: REAL ESTATE TAXES (COUNTY/SCHOOL) PERSONAL PROPERTY TAXES INCOME TAXES NOT WITHHELD PER CAPIT AlOCCUP A TION TAXES PART II. EXPENSES Mary C. Crouse! Income and Expense Statement DESCRIPTION MONTHLY AMOUNT INSURANCE: HOMEOWNERS INSURANCEfRENTERS INSURANCE $ 15.00 AUTOMOBILE INSURANCE $ 50.00 LIFE INSURANCE $ 50.00 ACCIDENT INSURANCE HEALTH INSURANCE $ 90.00 OTHER INSURANCE Dental $ 5.00 AUTOMOBILE EXPENSES: PAYMENTS FUEL $ 100.00 MAINTENANCE AND REPAIR $ 50.00 LICENSE AND REGISTRATION $ 6.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: DOCTOR $ 30.00 OPTICAL DENTAL ORTHODONTIC HOSPITAL MEDICINE $ 100.00 SPECIAL NEEDS/THERAPY ETC. EDUCATIONAL EXPENSES: PRIVATE SCHOOL Mary C. Crollse/ Income and Expense Statement DESCRIPTION MONTHLY AMOUNT PAROCHIAL SCHOOL COLLEGENOCA TlONAL RELIGIOUS TRAINING/EDUCATlON BOOKS/FEES AND SUPPLIES PERSONAL EXPENSES: CLOTHING work $ 100.00 FOOD $ 300.00 BARBER AND HAIR DRESSER $ 25.00 CREDIT CARDS $ 20.00 OTHER PERSONAL EXPENSES/SPECIFY LOANS: Borrowed $1000.00 from life insurance policy for move arld living $ 50.00 expenses until employed Borrowed $1500.00 from mother for same $ 50.00 MISCELLANEOUS EXPENSES: HOUSEHOLD HELP CHILD CARE NEWSP APERS/MAGAZINES/BOOKS ENTERTAINMENT PAY TV $ 41.00 VACATIONS GIFTS Mary C. Crollse/ Income and Expense Statement DESCRIPTION MONTHLY AMOUNT LEGAL FEES CHARlT ABLE CONTRIBUTIONS $ 20.00 OTHER CIDLD SUPPORT OTHER SPOUSAL SUPPORT/ALIMONY TOTAL EXPENSES: $1581.00 PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VALUE H W IT CHECKING Bank of Abbeville $ 95.00 X SAVINGS $ 25.00 X CREDIT UNION $ 37.00 X STOCKS/BONDS REAL ESTATE OTHER Mary C. Crouse/ Income and Expense Statement PART IV. INSURANCE INSURANCE COVERAGE TYPE COMPANY POLICY NO. H W C HOSPITAL Cigna 436623374 X MEDICAL " " X HEALTH ACCIDENT DISABILITY INCOME DENTAL " " X VISION " " X OTHER-SPECIFY . H=Husband; W=Wife; C=Child ,,' ""} , ~'i-. c:-) ( -'"1 (~~i -;'1 "'-f T j.; ,,: :> ..., I....CJ F: IUser FolderlFinn DocslGendocs2004\3367 -I.pretrial.statement. wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY C. CROUSE, Plaintiff No. 03-4456 CIVIL v. IN DIVORCE DONALD M. CROUSE, Defendant PRETRIAL STATEMENT OF DEFENDANT DONALD M. CROUSE PURSUANT TO Pa. R.C.P.1920.33(b) Statement of Facts Defendant (hereinafter "Husband") is Donald M. Crouse. He resides at 9371 East Highway 67, Bruceville, IN 47516. He is 56 years old (DOB 12/18/47). Plaintiff (hereinafter "Wife") is Mary C. Crouse. She resides in Louisiana. She is 60 years old (DOB 9/1/44). The Parties were married in Cumberland County, Pennsylvania, on June 10, 1989. The Parties have been living separate and apart since November 17,2003. The marital residence, which has been sold, was 235 Hunters Road, Newville, PA 17241 (hereinafter "Marital Residence"). There are no children of the marriage. Wife filed for divorce on September 10,2003, serving Husband by certified mail on October 30,2003. Wife added a count for Alimony by filing an Amended Complaint on February 3,2004. Master E. Robert Elicker, II, was appointed on June 3, 2004. On October 13, 2004, Wife filed another Amended Complaint, adding a count for Equitable Distribution. 1.(i) Marital Assets a. From the sale of the Marital Residence, $38, 771.49 is held in escrow with Wife's counsel. A mobile home (two bedroom, central air) given to Husband by his parents valued at approximately $6,000.00 was sold with the Marital Residence, and Wife put $10,761.00 of her pre- marital funds into the purchase of the Marital Residence. b. A 1998 Freightliner truck that was traded in for $15,000.00. c. A 1992 Chevrolet pickup truck with a trade-in value of $2,000.00, which is in Husband's possession. It is not encumbered. d. A dining room furniture set in Wife's possession purchased four years ago for approximately $1,200.00, and a roll top desk in Wife's possession with an approximate value of $375.00. e. One sixth of Wife's retirement plan from Essis and Sons valued at $25,606.07 in December, 2002. It is Husband's belief that Wife's retirement plan was funded during the twelve years she worked at Essis and Sons, two years of which were during the marriage. f. A 1993 GMC in Wife's possession worth approximately $1,000.00. t.fu) Nonmarital Assets a. Husband's home in Indiana purchased on September 1,2004. It is encumbered by mortgage. b. Husband's new Freightliner truck, purchased post-separation with the 1998 Freightliner truck listed above as a trade-in. It is encumbered by a loan with a remaining balance of approximately $33,000.00. c. Various tools and old farm machinery passed on to Husband from his father pre- marriage, which are worth approximately $2,000.00. 2. Expert Witnesses Husband does not anticipate the need to call any expert witnesses; however, Husband reserves the right to call expert witnesses as needed. 3. Witnesses Husband anticipates calling only Husband and Wife; however, he reserves the right to supplement his witness list. 4. Exhibits Husband anticipates using only the attached Income and Expense Statement and Assets and Distribution Statements as exhibits; however, he reserves the right to supplement his exhibit list. 5. Income See attached Income and Expense Statement. 6. Expenses See Attached Income and Expense Statement. 7. Pension or Retirement Benefit Wife has a retirement plan from Essis and Sons valued at $25,606.07 in December, 2002. Husband has no pension or retirement plan. 8. Counsel Fees Husband is not seeking counsel fees and does not believe that Wife is seeking counsel fees. 9. Personal Property Husband believes that thus far all household items have been distributed to the satisfaction of both parties. 10. Marital Debts There is $1,200.00 owed to Husband's parents, which was loaned to the Parties for the purchase of equipment for Wife's flower and landscaping business; the equipment is currently in Wife's possession. 11. Proposed Resolution Husband proposes that the Parties divide the proceeds from the Marital Residence equally after the $1,200.00. He further proposes that Wife's $7,500.00 equitable share from the 1998 Freightliner be awarded to Wife from Husband's share ofthe Marital Residence proceeds. Husband would retain his new Freightliner, and his pickup truck. Wife would retain her full pension plan, and the furniture, and the 1993 GMC. With Wife being awarded her portion of the Marital Residence proceeds and retaining the full amount of her retirement plan, Wife would have no need for alimony. Respectfully submitted, LC;; ~--- Sean M. Shultz, Esquire Attorney LD. No. 90946 11 Roadway Drive, Suite B Carlisle, PA 17013 (717) 249-5373 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY C. CROUSE, Plaintiff No. 03-4456 CIVIL v. IN DIVORCE DONALD M. CROUSE, Defendant ASSETS AND DISTRIBUTION Assets Approximate Value Husband Wife Marital Residence $38,771.49 Proceeds Less debt to ($1,200.00) Husband's Parents Net Proceeds $37,571.49 50% 50% Attorney's Fees, Filing Fees and Court Each Party pays own Costs Wife's Retirement $25,606.07 100% Furniture $1,575.00 100% 1998 Freightliner $15,000.00 50% and retain new 50% Trade-in Value Freightliner 1993 GMC $1,000.00 100% 1992 Chevrolet $2,000.00 100% Pickup Truck IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY C. CROUSE, Plaintiff No. 03-4456 CIVIL v. IN DIVORCE DONALD M. CROUSE, Defendant INCOME AND EXPENSE STATEMENT OF DONALD M. CROUSE I. INCOME A. EMPLOYMENT INFORMATION EMPLOYER: Self-Employed Contractor for Landstar Ranger, Inc. ADDRESS: 13410 Sutton Park Drive South Jacksonville, Florida (FL) 32224 POSITION: Contracted Truck Driver PAYROLL NUMBER: 304-54-1380 PAY PERIOD: Monthly B.1. EMPLOYMENT INCOME (BASED ON 2003 TAX) MONTHLY ANNUALLY Gross business receipts $12,520.58 $150,247.00 Business expenses ($10,344.00) ($124,128.00) Expense of business use of home ($104.83) ($1,258.00) Self-employed health insurance ($816.92) ($9,803.00) deduction Deduction for 50% of self- ($146.42) ($1,757.00) employment tax Itemized Deductions ($714.25) ($8,571.00) SUBTOTAL $394.17 $4,730.00 TAXES SE Tax $293.67 $3,524.00 Federal Tax $0.92 $11.00 State Tax $83.33 $1,000.00 Local Tax TOTAL TAX DEDUCTIONS $377.92 $4,535.00 TOTAL DEDUCTIONS $12,126.41 $145,517.00 NET PAY $16.25 $195.00 *NET PAY wi Truck $4,057.58 $48,691.00 depreciation and Truck insurance expense added back in *For purposes of spousal support the Parties previously averaged Husband's net income over the past three years, adding back the truck expenses and depreciation. The result was a gross annual income of $54.444.00 and a net monthly income $3,319.86 to which the Parties stipulated for support purposes. B.2. OTHER INCOME Not applicable. II. EXPENSES Description Approximate Monthly Amount HOME EXPENSES First Mortgage $714.21 Electric $75.00 Gas $65.00 Water $28.00 Telephone $60.00 Water/Sewer $28.00 EMPLOYMENT Fuel Meals Insurance for Freightliner TAXES Real Estate Taxes $432.00 Personal Property Taxes Income Taxes Not Withheld Per Capita/Occupation Taxes DESCRIPTION APPROXIMATE MONTHLY AMOUNT INSURANCE Homeowners Insurance $106.00 Automobile Insurance $54.00 Life Insurance $199.00 Health Insurance $281.00 AUTOMOBILE EXPENSES Payments Fuel $80.00 Maintenance and repair $25.00 License and registration $3.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE Doctor $20.00 Optical $30.00 Dental $25.00 Orthodontic Hospital Medicine $40.00 Special needs/Therapy Etc. EDUCATIONAL EXPENSES: None Description Approximate Monthly Amount PERSONAL EXPENSES Clothing $40.00 Food $330.00 Barber and Hair Dresser $5.00 Credit Cards $175.00 LOANS: The Parties borrowed $1,200.00 from Husband's parents for expenses related to Wife's former business. MISCELLANEOUS EXPENSES: Household Help Childcare NewspaperslMagazines/Books Entertainment $173.00 Cable TV $77.00 Legal Fees $125.00 Charitable Contributions $40.00 Other Child Support Other Spousal Support! Alimony TOTAL EXPENSES: Ill. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VALUE H W JT Checking Union Planners $650.00 X Savings Union Planners $225.00 X Credit Union StockslBonds Real Estate Recently purchased, loan was $90,000.00 X $82,000-non-marital asset Other IV. INSURANCE INSURANCE COVERAGE TYPE COMPANY POLICY NO. H W C Hospital Anthem BCIBS YRP304541380 X Medical " " X Health Accident " " X Disability Sears Unknown Income Dental NONE Vision NONE Other-[Specify ] 0 l') ~ c:.::> \,..- :;; -,- '" :r z 0 i'n;;g , ....:: ~'Y 1''' "'Om - 1~6 ij> .' \D 1<::, :~-\ 5~.. -0 :c...H '\.:Ci :J:: ~:?O j; ~-~ (~) rn --1 ~ ? +"' ~ MARY C. CROUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 03 - 4456 CIVIL DONALD M. CROUSE, Defendant IN DIVORCE ORDER OF COURT 2005, the )(7 . l' . d' th d' / h . economlC calms ralse In e procee lngs aVlng AND NOW, this .".0 / I' day of been resolved in accordance with a marriage settlement agreement and stipulation dated May 2, 2005, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, J. cc: Lindsay Dare Baird Attorney for Plaintiff Sean M. Shultz Attorney for Defendant . ',"-) I' ! ,)~, \ \ \'",',\\ S7J~'~ <,' .11 '1..5 \ . ~ ',.,' ,~~.ul' J,'~.} .J ." \ . ,~- j,,-:"ii.: '~.,_..' I ','-., .------ - 'Hi;tl;'j'( Cf,;"r,ftv';:,/.IY- . IS/" tliUli NiO '" """~'''j'fiN ~'Il.ED<:-'-' CCPvOFTHE f:\U$cr follkr\Finn Doxs.\Gend0cs2005'336T-I.MSA.""JIl!; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ',t?6T' MARY C. CROUSE, Plaintiff No. 03-4456 CIVIL v. IN DIVORCE DONALD M. CROUSE, Defendant MARRIAGE SETTLEMENT AGREEMENT AND STIPULATION THIS AGREEMENT, made this . ;::Vi day of I) )/,. I, ,2005, by and between DONALD M. CROUSE,of9371 East State Road 67, B~iana47516,partyofthe first part, hereinafter referred to as "Husband" and MARY C. CROUSE of 805 Espasie Road, Y oungsville, Louisiana 70592,party of the second part, hereinafter referred to as 'fWife." WITNESSETH: WHEREAS, Husband and Wife were married on June 10, 1989, in Cumberland County, Pennsylvania; and WHEREAS, Husband and Wife have been living separate and apart from each other since November 17, 2003; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six (6) months; and WHEREAS, certain diverse, unhappy differences have arisen between the parties hereto which have made them desirous ofliving separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other and to settle all financial and property rights between them; and WHEREAS, the parties hereto have mutually entered into agreement for the division of their jointly owned assets, the provisions for the liabilities they owe, and provisions for the resollltion of their mutual differences, after both have had full and ample opportunity to consult with their respective attorneys, and the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to be legally bound and to legally bind heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: ARTICLE I: SEPARATION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall deem fit free from any control, restrain, or interference, direct or indirect, by each other. Neitherparty shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II: DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the parties hereto and each of the said parties does warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or action for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has be~n, may, or shall be instituted by the other party, or for making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing Husband and Wife to execllte this Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims if this Agreement is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant and agree that, in any possible event he and she are and ever shall be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, county, or jurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be effected in any way by any such separation or divorce; and that 1I1othing in any such decree, judgment, order or further modification or revision thereof shall ~lter, amend or vary any term of this Agreement, whether or not either or both of the parties Should remany, it being understood by and between the parties that this Agreement shall survive and shall not be merged into any decree, judgment or order of divorce or separation. It is understood by the parties that this Agreement is being entered into pursuant to an oral agreement reached while in conference with the Cumberland County Divorce Master. 2.3 It is specifically agreed that a copy of this Agreement may be incorporated by r~ference into any divorce judgment or decree if or whenever sought by any of the parties hereto. It is understood by the parties that a Divorce Complaint has been filed in the Court of Common Pleas of Cumberland County at Docket Number 03-4456 Civil Term. Such incorporation, however, shall not be regarded a merger, it being the intent of the parties to permit this Agreement to survive any such agreements. ARTICLE III: EQUITABLE DISTRIBUTION OF MARITAL PROPERTY 3.1 The parties have attempted to divide their marital property in a manner which c@nforms to the criteria set forth in Section 3502 of the Pennsylvania Domestic Relations Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities, and need for each of the parties; the contribution of one party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisition of capital assets and income; the sources of income of both parties, including, but not limited to medical, retirement, insurance or other benefits; the contribution of dissipation of each party in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during their marriage. 3.2 The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribution of the parties. 3.3 The parties sha1l retain sole and exclusive right, title and possession of all personal property currently in their possession. Except as provided for herein, Husband sha1l make no claim whatsoever for any personal property in Wife's possession. Additionally, except as provided for herein, Wife shall make no claim whatsoever for any personal property in Husband's possession. Should it be necessary for either party to execute any documents to convey title to any such personal property in the other party's possession, they shall do so within thirty (30) days ofthe execution of this Agreement or within thirty (30) days of the request from the opposing party. 3.4 Except as provided herein, Wife waives any right or interest she may have in Husband's employment benefits, including any pension benefits, retirement plan, stock option purchase plan, profit sharing plan or related matters. Except as provided herein, Iiusband waives any right or interest he may have in Wife's employment benefits, including any pension benefits, retirement plan, stock option purchase plan, profit sharing plan or related matters. 3.5 Husband and Wife agree to waive and relinquish any and a1l rights that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other party. Husband and Wife specifica1ly agree to waive and relinquish any right jnsuch property that may arise as a result of the marriage relationship. Wife specifically waives and relinquishes any and all rights or interests that she may have in the real property Husband purchased after the separation of the parties, located at 9371 East State Road 67, Bruceville, Indiana 47516. 3.6 The Parties agree that from the proceeds in the amount of Thirty-Eight Thousand Seven Hundred Seventy-One Dollars and Forty-Nine Cents ($38,771.49) from the sale of their marital residence located at 235 Hunters Road, Newville, Pennsylvania, Husband shall receive Thirteen Thousand Five Hundred Dollars ($13,500.00), and Wife shall receive Twenty-Five Thousand Two Hundred Seventy-One Dollars and Forty-Nine Cents ($25,271.49). Said monies are being held in escrow with Lindsay Dare Baird, Esquire. Upon execution of this agreement by both parties, said monies may be distributed to the parties; Husband's portion of the proceeds shall be forwarded to Husband's counsel, Knight & Associates, P.C. ARTICLE IV: RELEASE OF SUPPORT FOR HUSBAND AND WIFE 4.1 The parties herein acknowledge that by this Agreement they have respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient resources to provide for their comfort, maintenance, and support in the station of life in which they are accustomed. Except as provided herein, Husband and Wife do hereby waive, nelease and give up any rights they may respectively have against the other for alimony pendente lite, spousal support, or maintenance. a. Husband agrees to pay Wife the amount of Five Hundred Dollars ($500.00) in monthly alimony payments due on or before the final day of each month. Husband's Obligation to make said payments shall commence with the first full month after the Court has issued a Divorce Decree dissolving the Partes' marriage, and shall cease with the last full month before Wife's Sixty-Sixth birthday, which makes the final alimony payment dlle in August, 2010. Said payments shall be directly wired to Wife's bank account (Bank of hbbeville & Trust Company, Account no. 65105-2, Routing no. 065203729) from Husband's Mcount. Wife shall notify Husband in writing ifher account or bank changes, and she shall pnovide all information necessary to effectuate any necessary change by Husband at his bank; Husband shall make any such necessary changes as soon as reasonably possible. b. In lieu of greater or further alimony payments, Husband shall maintain Wife on a life insurance policy, payable upon Husband's death, that has a benefit of$50,OOO.00 payable to Wife. Said life insurance coverage may be maintained by Husband by having Wife as a whole or partial beneficiary, so long as the death benefit payable to Wife is $50,000.00. Husband's obligation under this paragraph shall cease upon Wife's Sixty-Sixth birthday on September 1,2010. 4.2 Except as provided in this Agreement, Husband and Wife specifically waive, release and give up any additional rights for alimony that they may be entitled to pursuant to Chapter 37 of the Pennsylvania Domestic Relations Code, except that the Parties may petition the Court to modify alimony if for any medical reason either one of them are unable to continue working. Upon the filing to modify or terminate alimony by either party Husband's obligation under Paragraph 4. 1 (b) to maintain life insurance with Wife as the beneficiary shall cease. ARTICLE V: DEBTS OF THE PARTIES 5.1 Each party represents to the other that except as otherwise specificallysct forth herein, there are no outstanding obligations of the parties, that since the separation neither party has contracted for any debts for which the other will be responsible and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. In the event either party contracted for or incurred any debts since the date of separation, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged. Husband and Wife acknowledge and agree that they have no outstanding debts or obligations of the Husband and Wife incurred prior to the signing of this Agreement. 5.2 The Parties agree that all marital debts have been paid in fuIl from the proceeds of the sale of their marital residence. 5.3 Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in the possession of the other party. Within thirty (30) days of the date of execution of this document, each party shall execute the necessary documents to have said vehicles property registered in the other party's name with the PermsylvaniaDepartrnent of Transportation. ARTICLE VI: MISCELLANEOUS PROVISIONS ; 6.1 The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counselor the parties have waived their right to have legal advice regarding the meaning and implication of this Agreement. The parties acknowledge and accept that this Agreement is, in the circumstances, fair and equitable, that it is being entered into freely and voluntarily, after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 6.2 Husband and Wife do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of the other, for all times to come and for all purposes whatsoever, of and from any and all legal right, title and interest, or claims in or against the property of the other or against the estate of the other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of( a) Pennsylvania, (b) any state, commonwealth, or territory of the United States, or ( c) any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, source fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 6.3 Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, e~cept as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless from and against any and all such debts, liabilities or obligations of each of them, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent and agree that each will, noW and at all times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided herein. 6.4 No waiver or modification of any of the terms of this Agreement shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 6.5 This Agreement shall be construed in accordance with the laws ofthe Commonwealth of Pennsylvania which are in effect as ofthe date of this Agreement. 6.6 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 6.7 This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 6.8 If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligation under anyone or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.9 It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by the Domestic Relations Code of the Commonwealth of Pennsylvania. 6.10 The parties warrant and represent that they have made full disclosure of all assets prior to the execution of this Agreement. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her personal property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each further warrants, represents, and declares that each is and has been fully and completely informed of and is familiar with and is cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure tot he other of his and her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns (including supporting documentation) filed by or on behalf of either or both Parties during marriage. 6.11 In the event either party to this Agreement shall breach any term, covenant or other obligation herein, the non-breaching party shall be entitled, in addition to all other remedies available at law or in equity, to recover from the breaching party all costs which the non- breaching party may incur, including but not limited to filing fees and attorney's fees, in any action or proceeding to enforce the terms of this Agreement. 6.12 This Agreement shall survive any action for divorce and decree of divorce and shall Eorever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of this Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this Agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 6.13 The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the C<1>sts and legal fees of the party who is seeking the divorce. 6.14 The Parties shall submit their annual Federal Income Tax Returns to each other upon written demand for each year requested subsequent to the final entry of divorce of the Parties. Said obligation shall continue until Tax Year 2010. --- ~ IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first above written. WITNESSED BY: ~---. .~ L..-O' Donald M. Crouse, Jr. k:;{i&l~'s----- ma~ t (]{]2~ Mary C. ouse Swor. to _lid -brIcrWed ~ -.e 08 Ulb: 0 '1- . da, or '-1E~ 'f;, .~- . Ut ,~1 " ^-t-Ck-J -.,....... MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, 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. Ground for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: November 17, 2003 Certified mail, restricted delivery, return receipt. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 4/14/05; by Defendant: 5/3/05. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: May 6, 2005. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: May 6, 2005. r~,:' is C...f' o 'TI :? r=;oi:.o ~:. ~:,; ........ o w ~') -:::b C") n1 (.~ S-'~ ~ F: \U$cr Foldcr\Finn Qocs\Gendocs200S\3367 -I ,MSA wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MARY C. CROUSE, Plaintiff No. 03-4456 CIVIL v. IN DIVORCE DONALD M. CROUSE, Defendant MARRIAGE SETTLEMENT AGREEMENT AND STIPULATION THIS AGREEMENT, made this ~d day of IJ!.a/ v ,2005, by and between DONALD M. CROUSE, of937l East State Road 67, Brucevil1e, Indiana 47516, party ofthe first part, hereinafter referred to as "Husband" and MARY C. CROUSE of 805 Espasie Road, Y oungsvilJe, Louisiana 70592,party of the second part, hereinafter referred to as "Wife." WITNESSETH: WHEREAS, Husband and Wife were married on June 10, 1989, in Cumberland County, Pennsylvania; and WHEREAS, Husband and Wife have been living separate and apart from each other since November 17,2003; and WHEREAS, Husband and Wife are residents ofthe Commonwealth of Pennsylvania and have been so for at least the past six (6) months; and WHEREAS, certain diverse, unhappy differences have arisen between the parties hereto which have made them desirous of living separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other and to settle all financial and property rights between them; and WHEREAS, the parties hereto have mutually entered into agreement for the division of their jointly owned assets, the provisions for the liabilities they owe, and provisions for the resolution of their mutual differences, after both have had full and ample opportunity to consult with their respective attorneys, and the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to be legally bound and to legally bind heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: ARTICLE I: SEPARATION I.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall deem fit free from any control, restrain, or interference, direct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II: DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the parties hereto and each of the said parties does warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either ofthe parties hereto from commencing, instituting or prosecuting any action or action for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or for making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenanl, and representation is made for the specific purpose of inducing Husband and Wife to execute this Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims if this Agreement is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant and agree that, in any possible event he and she are and ever shall be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, county, or jurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be effected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties should remarry, it being understood by and between the parties that this Agreement shall survive and shall not be merged into any decree, judgment or order of divorce or separation. It is understood by the parties that this Agreement is being entered into pursuant to an oral agreement reached while in conference with the Cumberland County Divorce Master. 2.3 It is specifically agreed that a copy of this Agreement may be incorporated by reference into any divorce judgment or decree if or whenever sought by any of the parties hereto. It is understood by the parties that a Divorce Complaint has been filed in the Court of Common Pleas of Cumberland County at Docket Number 03-4456 Civil Term. Such incorporation, however, shall not be regarded a merger, it being the intent of the parties to permit this Agreement to survive any such agreements. ARTICLE III: EQUITABLE DISTRIBUTION OF MARITAL PROPERTY 3.1 The parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Domestic Relations Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities, and need for each of the parties; the contribution of one party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisition of capital assets and income; the sOllrces of income of both parties, including, but not limited to medical, retirement, insurance or other benefits; the contribulion of dissipation of each party in lhe acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard ofliving of the parties established during their marriage. 3.2 The division of existing marital property is not intended by the parties to conslitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribution of the parties. 3.3 The parties shall retain sole and exclusive right, title and possession of all personal property currently in their possession. Except as provided for herein, Husband shall make no claim whatsoever for any personal property in Wife's possession. Additionally, except as provided for herein, Wife shall make no claim whatsoever for any personal property in Husband's possession. Should it be necessary for either party to execute any documents to convey title to any such personal property in the other party's possession, they shall do so within thirty (30) days of the execution ofthis Agreement or within thirty (30) days of the request from the opposing party. 3.4 Except as provided herein, Wife waives any right or interest she may have in Husband's employment benefits, including any pension benefits, retirement plan, stock option purchase plan, profit sharing plan or related matters. Except as provided herein, Husband waives any right or interest he may have in Wife's employment benefits, including any pension benefits, retirement plan, stock option purchase plan, profit sharing plan or related matters. 3.5 Husband and Wife agree to waive and relinquish any and all rights that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other party. Husband and Wife specifically agree to waive and relinquish any right in sllch property that may arise as a result of the marriage relationship. Wife specifically waives and relinquishes any and all rights or interests that she may have in the real property Husband purchased after the separation of the parties, located at 9371 East State Road 67, Bruceville, Indiana 47516. 3.6 The Parties agree that from the proceeds in the amount of Thirty-Eight Thousand Seven Hundred Seventy-One Dollars and Forty-Nine Cents ($38,771.49) from the sale of their marital residence located at 235 Hunters Road, Newville, Pennsylvania, Husband shall receive Thirteen Thousand Five Hundred Dollars ($13,500.00), and Wife shall receive Twenty-Five Thousand Two Hundred Seventy-One Dollars and Forty-Nine Cents ($25,271.49). Said monies are being held in escrow with Lindsay Dare Baird, Esquire. Upon execution of this agreement by both parties, said monies may be distributed to the parties; Husband's portion of the proceeds shall be forwarded to Husband's counsel, Knight & Associates, P.C. ARTICLE IV: RELEASE OF SUPPORT FOR HUSBAND AND WIFE 4.1 The parties herein acknowledge that by this Agreement they have respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient resources to provide for their comfort, maintenance, and support in the station of life in which they are accustomed. Except as provided herein, Husband and Wife do hereby waive, release and give up any rights they may respectively have against the other for alimony pendente lite, spousal support, or maintenance. a. Husband agrees to pay Wife the amount of Five Hundred Dollars ($500.00) in monthly alimony payments due on or before the final day of each month. Husband's obligation to make said payments shall commence with the first full month after the Court has issued a Divorce Decree dissolving the Partes' marriage, and shall cease with the last full month before Wife's Sixty-Sixth birthday, which makes the final alimony payment due in August, 2010. Said payments shall be directly wired to Wife's bank account (Bank of Abbeville & Trust Company, Account no. 65105-2, Routing no. 065203729) from Husband's account. Wife shall notify Husband in writing ifher account or bank changes, and she shall provide all information necessary to effectuate any necessary change by Husband at his bank; Husband shall make any such necessary changes as soon as reasonably possible. b. In lieu of greater or further alimony payments, Husband shall maintain Wife on a life insurance policy, payable upon Husband's death, that has a benefit of$50,000.00 payable to Wife. Said life insurance coverage may be maintained by Husband by having Wife as a whole or partial beneficiary, so long as the death benefit payable to Wife is $50,000.00. Husband's obligation under this paragraph shall cease upon Wife's Sixty-Sixth birthday on September 1,2010. 4.2 Except as provided in this Agreement, Husband and Wife specifically waive, release and give up any additional rights for alimony that they may be entitled to pursuant to Chapter 37 of the Pennsylvania Domestic Relations Code, except that the Parties may petition the Court to modify alimony if for any medical reason either one of them are unable to continue working. Upon the filing to modify or terminate alimony by either party Husband's obligation under Paragraph 4.1(b) to maintain life insurance with Wife as the beneficiary shall cease. ARTICLE V: DEBTS OF THE PARTIES 5.1 Each party represents to the other that except as otherwise specifically set forth herein, there are no outstanding obligations ofthe parties, that since the separation neither party has contracted for any debts for which the other will be responsible and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. In the event either party contracted for or incurred any debts since the date of separation, the party who incurred said debt shall be responsible for the payment thereof regardless ofthe name in which the account may have been charged. Husband and Wife acknowledge and agree that they have no outstanding debts or obligations of the Husband and Wife incurred prior to the signing of this Agreement. 5.2 The Parties agree that all marital debts have been paid in full from the proceeds of the sale of their marital residence. 5.3 Each party relinquishes any right, title and interest he or she may have to any and aU motor vehicles currently in the possession of the other party. Within thirty (30) days of the date of execution of this document, each party shall execute the necessary documents to have said vehicles property registered in the other party's name with the Pennsylvania Department of Transportation. ARTICLE VI: MISCELLANEOUS PROVISIONS : 6.1 The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counselor the parties have waived their right to have legal advice regarding the meaning and implication of this Agreement. The parties acknowledge and accept that this Agreement is, in the circumstances, fair and equitable, that it is being entered into freely and voluntarily, after having received such advice and with such knowledge that execution of this Agreement is notthe result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 6.2 Husband and Wife do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of the other, for all times to come and for all purposes whatsoever, of and from any and all legal right, title and interest, or claims in or against the property of the other or against the estate of the other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of( a) Pennsylvania, (b) any state, commonwealth, or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, source fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations ofwhatsoevernature arising or which may arise under this Agreement or for the breach of any thereof. 6.3 Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless from and against any and all such debts, liabilities or obligations of each of them, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent and agree that each will, now and at all times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided herein. 6.4 No waiver or modification of any ofthe terms ofthis Agreement shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 6.5 This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of this Agreement. 6.6 This Agreement shall be binding and shall inure to the benefit ofthe parties hereto and their respective heirs, executors, administrators, successors and assigns. 6.7 This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 6.8 If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligation under anyone or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.9 It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by the Domestic Relations Code of the Commonwealth of Pennsylvania. 6.l0 The parties warrant and represent that they have made full disclosure of all assets prior to the execution of this Agreement. Each party represents and warrants that he or she has made a full and fair disclosure to the other of aU of his or her personal property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration ofMarital Property without the prior consent of the other. Each further warrants, represents, and declares that each is and has been fully and completely informed of and is familiar with and is cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure tot he other of his and her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns (including supporting documentation) filed by or on behalf of either or both Parties during marriage. 6.11 In the event either party to this Agreement shall breach any term, covenant or other obligation herein, the non-breaching party shall be entitled, in addition to all other remedies available at law or in equity, to recover from the breaching party all costs which the non- breaching party may incur, including but not limited to filing fees and attorney's fees, in any action or proceeding to enforce the terms of this Agreement. 6.12 This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of this Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this Agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 6.13 The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 6.14 The Parties shall submit their annual Federal Income Tax Returns to each other upon written demand for each year requested subsequent to the final entry of divorce of the Parties. Said obligation shall continue until Tax Year 2010. . , IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first above written. WITNESSED BY: , Donald M. Crouse, Jr. ,yflNJJS;-- M~7:0Ur: (JdlMY- Swor. to Ind s.blcdtkd before 1M on t.is " 'L day or~~.~~ -, ..... .If ...... UJ . fIClUICIO _ _ARYI'UaIC tW,*AYE1"II.~ ',. , ", ~ ',': ' ,,~l' .~ .~-- .., MM.''t'M't' .-M '!D-UU ~ --OUUlVAA_ JT13v.W~ .".'11110.1 . , (") '" C:';::I 0 e- X! -n ~'l\ ~ I,".'. " "'.", -'- ::ry ", t~;::: r ~ -~.P i, () ~:~ N?' - _....~ : ',\-; - ) . -'-1 "- , .. c, -.-( 1'0 .'" l, F 1 MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (C) ofthe Divorce Code was filed on September 10, 2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on November 17, 2003 3. An amended complaint in divorce under Section 3301(C) of the Divorce Code was filed on February 3, 2004. 4. Attomey for the Defendant acknowledged receipt and accepted service of the Complaint on behalf of the Defendant, on February 9, 2004. 5. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the original Complaint. 6. I consent to the entry of a final decree in divorce without notice. 7. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 8. 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. 9. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: 1.///'1/05" 1Y2Clf!tt ~ tJt~ Mary C. Crouse, Plaintiff (-- -' ~:: '" = = <On :-:7; --1 ~~ ?: -".~ I C"> _::. '" N - MARY C. CROUSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4456 CIVIL TERM DONALD M. CROUSE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on September 10,2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on November 17, 2003 3. An amended complaint in divorce under Section 3301 (C) of the Divorce Code was filed on February 3, 2004. 4. Attorney for the Defendant acknowledged receipt and accepted service of the Complaint on behalf of the Defendant, on February 9, 2004. 5. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the original Complaint. 6. I consent to the entry of a final decree in divorce without notice. 7. 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. 8. 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. 9. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~.~c;ion 49~4 relating to unsworn falsifiD.n to authorities. Date: .}/~/()<; . ~a~~. Donald M. Crouse, Defendant 7 ~ ...'-..... . '-\',"" :r,,) ~>: 1-',., ~ ~,~-. o ( ,..., c? s; ~~c:, :..~ ' ~ ~(::. i " (') :':'11 -1 ~~\~~} - .. ('.., c....) L . . . . . . . . . ;1;:'::+:'" ;t;~ ~ ~ if. :+:~:+: if.",;t;", if.:+:;t;",;+::+::+::+::+::+::+::+::+:;+:if. :+::+:if.;f.if.:f.++++++*.++ +:+:++:+:+++++++++~ . . IN THE COURT OF COMMON PLEAS ~ . . OFCUMBERLANDCOUNTY . . . STATE OF PENNA. . . . . . . . . . . . . . . . . . . . . MARY C. CRooSE No. 03-4456 Plaintiff VERSUS IJC.W\LDM.CRooSE Defendant DECREE IN . . . . . . . . DIVORCE . AND NOW,~ {'\ , IT IS ORDERED AND , 2005 . . . . . MARY C. CRooSE , PLAINTIFF, DECREED THAT . . . roqALD M. CRooSE , DEFENDANT, . . . . . . . . . . AND ARE DIVORCED FROM THE BONDS OF MATRIMONY, FOLLOWING CLAIMS WHICH HAVE WH ICH A FI NAL ORDER HAS NOT THE COURT RETAINS JURISDICTION OF THE BEEN RAISED OF RECO~~~.T.HIS ACTION FOR YET BEEN ENTERED; "'~ . . . i ,. . . . . . . . . . . . . . . . . . . . . . . . . ++++++++++;t;++++~ . . . . . . The Marriaqe Settlement Aqreernent and Stipulation dated MUV 2, Z005 is incorporated by reference. . . . . . . . . . . 'f.+++!'f. :f.'f. + +++++++ +++++++ " BY T;4 , .' . . . " . . . ROTHONOTARY . . . " . ++:+;+:f. + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. ~/p~., 7-7 .t? ~;W ~'!< ~.z:r:r _J? ~7- ~ 4w '-J-~il? . ".'. R7 U 5' 50-!j?