HomeMy WebLinkAbout03-4825LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003- 49,a CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for the 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 Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF
YOU DO NOT HAVE AN ATTORNEY 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
(717) 249-3166
LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003- y Bay CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(c)
AND 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Laura A. Roth, an adult individual who currently resides at 50
Winchester Gardens, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Kurt E. Roth, an adult individual who currently resides at 125
Partridge Circle, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on May 24, 1987 in Cedar
Knolls, New Jersey.
COUNT I - DIVORCE
5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above.
6. There have been no prior actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised of the availability of counseling and that
she may have the right to request that the court require the parties to participate in
Counseling.
9. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in
favor of the Plaintiff and against the Defendant.
COUNT II -EQUITABLE DISTRIBUTION
10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above.
11. The parties have acquired real estate, personal property, including
automobiles, bank accounts and other items of miscellaneous property during the
course of their marriage, some of which is marital property.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
decree which effects an equitable distribution of marital property.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Date: ?1• ld• 03
Michael A. Scherer, Esquire
I.D.# 61974
17 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff,
Laura A. Roth
m as.d i r/domestic/roth/com plai nt. pid
VERIFICATION
I verify that the statements made in this 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.
Laura A. Ro gh
Date: 9 ';? ? - 0 3
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LAURA A. ROTH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2003-4825 CIVIL TERM
VS. : CIVIL ACTION - LAW
KURT E. ROTH, IN DIVORCE
Defendant
ACCEPTANCE OF SERVICE,
I hereby accept service of the Complaint in Divorce on
September 19, 2003.
Witness:
Kurt E. Roth
CHRISTINA LYNN SEIBERT,
Plaintiff
V.
AARON MICHAEL McCAUSLIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-4925 CIVIL TERM
IN RE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 23rd day of September, 2003, Aaron
Michael McCauslin having appeared on a petition alleging
indirect criminal contempt of the prior PFA order, and the
Defendant having admitted violating that order, the Court
does find him to be in contempt of court.
Having so found, we sentence the Defendant to a
term of imprisonment in the Cumberland County Prison for not
less than 6 days nor more than 6 months. We give him credit
for 6 days previously served, and we now place him on parole
on the condition that he abide by the protection from abuse
order entered October 4, 2002, and that he have absolutely
no contact whatsoever with the victim in this case,
Christina Lynn Seibert. Any contact with Ms. Seibert in
regard to visitation with the parties' two children shall be
had solely through the Defendant's mother, Mary McCauslin.
The Defendant is also excluded from the residence
of the victim's mother which is located at R.D. 2, Box 1B,
Loysville, PA.
By the Court,
jGr*g-fe r , J.
,,Geoffrey S. McInroy, Esquire
Assistant District Attorney \\
For the Plaintiff ) L.tk 'l fl MOL' C 00X ?'r1
? illiam G. Braught, Esquire
Assistant Public Defender
For the Defendant
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LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003-4825 CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
PLANITIFF'S AFFIDAVIT OF CONSENT
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 12, 2003.
2. Defendant signed an Acceptance of Service form on September 23, 2003.
3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of the filing of the Complaint.
4. 1 consent to the entry of a final decree in divorce without notice.
5. 1 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.
6. 1 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.
7. 1 have been advised of the availability of marriage counseling and understand
that I may request that the court require counseling. 1 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 unsworn falsification to authorities,
Date: October a ]_, 2005 /4 A a=-- i?A
AURA A. RO
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LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003-4825 CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
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 12, 2003.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of a final decree in divorce without notice.
4. 1 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.
5. 1 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.
6. 1 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 unsworn falsification to authorities.
Date: /0-30 v /? uyt c? v?4 --64
Kurt E. Roth
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LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003-4825 CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
MOTION TO VACATE MASTER'S APPOINTMENT
1. Movant is Michael A. Scherer, Esquire, attorney for Plaintiff in the above-
captioned matter.
2. On or about June 7, 2004 , the Honorable George E. Hoffer appointed E. Robert
Elicker, II as Divorce Master.
3. Subsequent to Master's appointment, the parties negotiated a settlement.
WHEREFORE, Movant respectfully requests that the Master's appointment be vacated.
Respectfully submitted,
O'BRIIEN, BARIC & SCHERER
By Gl
Michael A. Scherer, Esquire
Attorney for Plaintiff
I. D. # 61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA
V. NO. 2003-4825 CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
MARITAL SETTLEMENT AGREEMENT
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THIS AGREEMENT, made this day of October, 2005 by and between
Laura A. Roth, of Long Valley, New Jersey, and Kurt E. Roth, of Carlisle, Cumberland
County, Pennsylvania.
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been lawfully
married on May 24, 1987; and,
WHEREAS, a divorce complaint was filed on September 12, 2003; and,
WHEREAS, no children were born of the marriage; and,
WHEREAS, the parties hereto are desirous of settling fully and finally their
respective marital and property rights and obligations as between each other, including,
without limitation, the settling of all matters between them relating to the ownership of
real and personal property, the support and maintenance of one another and, in
general, the settling of any and all claims and possible claims by one against the other
or against their respective estates.
1
NOW THEREFORE, in consideration of these premises, and of the mutual
promises, covenants and undertakings hereinafter set forth, and for other good and
valuable consideration, the receipt and sufficiency of which is hereby acknowledged by
each of the parties hereto, Husband and Wife, each intending to be legally bound
hereby, covenant and agree as follows:
1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live
separate and apart at such places as they may desire, free from all control, restraint,
interference and authority, direct or indirect, by the other. Neither party will interfere with
the use, ownership, enjoyment or disposition of any property now owned by or hereafter
acquired by the other.
2. ADVICE OF COUNSEL. Each party acknowledges that he or she has
had the opportunity to receive independent legal advice from counsel of his or her
selection. Wife has secured legal advice from Michael A. Scherer, Esquire, her counsel,
and Husband had previously been represented by Dale Shughart, Esquire, but
Husband is now unrepresented by counsel. Husband understands that he may consult
with counsel in this matter at any time and that Michael A. Scherer, Esquire, represents
the interests of Wife in this matter. Each party fully understands the facts and his or her
legal rights and obligations, and each party acknowledges and accepts that this
Agreement is, in the circumstances, fair and equitable, and that it is being entered into
freely and voluntarily, and that the execution of this Agreement is not the result of any
duress or undue influence, and that it is not the result of any improper or illegal
agreement or agreements.
2
3. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges
that he or she is aware of his or her right to seek discovery permitted under the
Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. The parties
do hereby acknowledge that there has been full and fair disclosure to the other of his or
her respective income, assets and liabilities, whether such are held jointly, in the name
of one party alone or in the name of one of the parties and another individual or
individuals. Each of the parties hereto further covenants and agrees for himself and
herself and his or her heirs, executors, administrators or assigns, that he or she will
never at any time hereafter sue the other party or his or her heirs, executors,
administrators or assigns in any action of contention, direct or indirect, and allege
therein that there was a denial of any rights to full disclosure, or that there was any
fraud, duress, undue influence or that there was a failure to have available full, proper
and independent representation by legal counsel.
4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the
parties agree, that by this Agreement they have resolved all ancillary economic issues
related to the dissolution of their marriage and thus any divorce action with respect to
these parties shall be limited to a claim for divorce only. The parties agree that they will
each execute an Affidavit of Consent and Waiver of Notice of Intention to Request
Entry of Divorce Decree in order that counsel may finalize the divorce action in a timely
fashion.
3
5. EQUITABLE DISTRIBUTION.
A. Real Estate. The parties are the owners as tenants by the
entireties of real estate located at 125 Partridge Circle, Carlisle, Pennsylvania. The
parties agree that the fair market value of this real estate is approximately $119,000.00,
and the mortgage payoff is $77,535.00, leaving $41,465.00 worth of equity in the
property. Husband shall become the sole owner of the marital residence and shall
refinance the existing mortgage on the property within 120 days of the date of this
agreement. Concurrent with the refinance, Wife shall execute a deed transferring all
right, title and interest to the aforementioned residence to Husband individually. In the
event Husband fails to remove Wife's name from the mortgage within 120 days from
the date of this Agreement either by refinancing, mortgage modification or other means,
the property shall be listed for sale at a price agreed upon by the parties or determined
by the Court and Husband shall retain the proceeds of the sale. The said deed
referenced above shall be held in escrow by counsel for Wife to be supplied to
Husband at the time of the refinancing or sale of the real estate more particularly set
forth above.
The parties also owned investment real estate at 153 Chester Street, Carlisle,
Pennsylvania. That real estate was sold on June 30, 2004 and the proceeds of the sale
were $36,761.00. The parties each received $5,000.00 at the time of settlement, and
the sum of $26,761.63 was placed into escrow thereafter. After the parties each
received and additional $5,000.00 on February 24, 2005, the sum of approximately
$17,335.79 remains in escrow. When this agreement has been signed by both parties,
4
Michael A. Scherer, escrow holder, shall write a check to Husband for one-half of the
balance in escrow and he shall write Wife a check for the remaining one-half of the
balance in escrow.
B. Furnishings and Personalty. Wife shall be permitted to retrieve
and keep as her separate property from the marital residence her grandmother's china
and some other collectibles belonging to wife. Aside from the foregoing, the parties
have divided by agreement between themselves all furnishings and personalty located
in the marital residence and Husband shall retain sole and exclusive ownership of all
furnishings and personalty currently in his possession, free and clear of any right, title,
claim and/or interest of Wife and Wife shall retain all items of furnishings and personal
property currently in her possession as her sole and separate property free and clear of
any right, title, claim and/or interest of Husband.
C. Motor Vehicles. Each party shall retain as their separate property
the motor vehicle currently in their possession, and if the vehicle is titled jointly with the
other spouse, that spouse agrees to release his or her interest in the vehicle by signing
the title over to the other spouse within 30 days of the date of this agreement.
D. Intangible Personal Property Wife is the owner of certain Roth
IRA investments which totaled approximately $13,450.00 at the time of separation.
Certain of the accounts no longer exist or have been used by Wife for living expenses.
Wife shall become the sole owner of the Roth IRA accounts in her name and Husband
releases any interest he has in these accounts or the funds that had been in those
accounts.
5
E. Retirement Benefits. The parties each have retirement
accounts. Wife accrued a 401 k with her former employer, M & T Bank, and the value of
Wife's 401 k is approximately $24,947.00. Wife shall keep as her separate property her
401k and Husband hereby releases any interest he has in Wife's 401 k.
Husband accrued a retirement in the nature of a thrift saving plan in connection
with his former employment with the United States government. The total value of
Husband's thrift savings plan is approximately $121,070.00, and the marital portion of
Husband's thrift savings plan is $108,098.00, because Husband had been employed
with the United States government prior to the marriage. Husband shall transfer to Wife
through the use of a Qualified Domestic Relations Order, the sum of $42,250.00, plus
investment gain or loss as determined by the plan administrator.
F. M & T Bank Stock. Wife is in possession of 37 shares of M & T
Bank stock with a current share price of approximately $108.00 per share. Wife shall
keep as her separate property the M & T Bank stock and Husband hereby releases any
interest he may have in the M & T Bank stock in Wife's possession.
G. Note from Laura Roth and Scott G. Chapman. The parties hold
a note in the amount of $40,000.00 from Laura Roth and Scott G. Chapman dated May
28, 2003. Wife shall become the sole owner of this note by virtue of this agreement
and Husband hereby releases any interest he has in the note to Wife.
6
H. Miscellaneous Property. As of the execution date of this
Agreement, any and all property not specifically addressed herein shall be owned by
the party to whom the property is titled; and if untitled, the party in possession. This
Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all
rights in such property from each to together.
F. Marital Debt. The parties acknowledge and agree that there are
no outstanding joint obligations aside from the mortgage on 125 Partridge Circle,
Carlisle, PA. In the event there are any other debts in the name of either party, that
party shall be solely responsible for those debts and shall hold the other harmless on
the obligations. Husband shall be solely liable for his post-separation debts to the IRS
and various medical care providers, and Husband shall indemnify and hold Wife
harmless on those obligations.
6. SUPPORT. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL
SUPPORT. Neither party shall pay the other spousal support, alimony pendente lite or
alimony in connection with this separation and divorce.
7. RELEASE OF CLAIMS.
Wife and Husband acknowledge and agree that the property
dispositions provided for herein constitute an equitable distribution of their assets and
liabilities pursuant to §3502 of the Divorce Code, and Wife and Husband hereby waive
any right to division of their property except as provided for in this Agreement.
8. MODIFICATION. No modification, rescission, or amendment to this
Agreement shall be effective unless in writing signed by each of the parties hereto.
7
9. BREACH. If either party hereto breaches any provision hereof, the other
party shall have the right, at his or her election, to sue for damages for such breach, or
seek such other remedies or relief as may be available to him or her. The non-
breaching party shall be entitled to recover from the breaching party all costs, expenses
and legal fees actually incurred in the enforcement of the rights of the non-breaching
party.
10. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement
shall bind the parties hereto and their respective heirs, executors, administrators, legal
representatives, assigns, and successors in any interest of the parties.
11. AGREEMENT NOT TO BE MERGED. This Agreement may be
incorporated into a decree of divorce for purposes of enforcement only, but otherwise
shall not be merged into said decree. The parties shall have the right to enforce this
Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain
any remedies in law or in equity under this Agreement as an independent contract.
Such remedies in law or equity are specifically not waived or released.
IN WITNESS WHEREOF, the parties hereto set their hands and seals on the
dates of their acknowledgments.
WITNESS:
D
Laura A. Roth
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LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003-4825 CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this 4 day of November, 2005, upon review of the attached Motion
filed by Michael A. Scherer, Esquire, Attorney for Plaintiff in the above-captioned action the
appointment of E. Robert Elicker, II as Divorce Master is hereby VACATED.
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LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2003-4825 CIVIL TERM
KURT E. ROTH, CIVIL ACTION-LAW
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: Defendant signed an
Acceptance of Service form on September 19, 2003.
3. (complete either paragraph (a) or (b).)
A. Date of execution of the affidavit of consent required by Section
3301(c) of the Divorce Code: by Plaintiff on October 21, 2005; and Defendant on
October 30, 2005.
B. (1) date of execution of the Plaintiffs Affidavit required by Section
3301(d) of the Divorce Code: N/A
(2) date of service of the Plaintiffs Affidavit upon the Defendant:
N/A
4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe
to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the
Divorce Code: None.
Respectfully submitted,
Michaelherer, Esquire
',
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
LAURA A. ROTH
Plaintiff,
VERSUS
KURT E. ROTH
Defendant.
AND NOW,
DIVORCE
DECREED THAT
AND
No. 2003 - 4825 CIVIL
DECREE IN
LAURA A.
3o
KURT E. ROTH
ZOOS- , IT IS ORDERED AND
PLAINTIFF,
,DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The parties, Marital Settlement Agreement dated October 21
2005, is incorporated but not merged, herein as a final
order of Court. BY THErOURT: /
Y. <? ?I /. //j 4
ATTES-Y: _ J.
?T // PROTHONOTARY
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KURT E. ROTH, CIVIL ACTION-LAW
Defendant IN DIVORCE
LAURA A. ROTH, IN THE COURT OF COMMON PLEAS OF
V. NO. 2003-4825 CIVIL TERM
STIPULATION FOR ENTRY OF RETIREMENT BENEFITS ORDER
WHEREAS, the parties are formerly husband and wife, having been divorced by
this Honorable Court on November 30, 2005; and
WHEREAS, the parties entered into a marital settlement agreement dated
October 21, 2005, wherein husband agreed to transfer to wife the sum of $42,250.00
plus investment gain or loss from his Thrift Savings Plan; and,
WHEREAS, the parties had contemplated that this transfer would have occurred
in or about December, 2005; and,
WHEREAS, the October 21, 2005 agreement provides that wife is to receive
investment gain or loss from the date of the agreement; and,
WHEREAS, at husband's suggestion, the parties are agreeable to the transfer of
$50,000.00 to satisfy the terms of the agreement in order to alleviate the calculation of
investment gain.
NOW, THEREFORE, the parties wish to implement this provision of their marital
settlement agreement and request that this Honorable Court execute the attached
Retirement Benefits Court Order and the parties have signed this Stipulation to
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
evidence their consent to such Order.
Laura A.
Co.
-' Kurt E. Roth R6fh
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Mi ae A. Scherer, Esquire
ID # 61974
Attorney For Laura A. Roth
N or*Oaal ina
STATE OF MAR' b#(N& )
SS.
COUNTY OF Wak e, )
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On this, the A day of _, Wfr; before me, the
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undersigned officer, personally appeared La ra A. 82-h known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
?Dl `1C`NQXXlsCC?xa? (seal)
sr. aco 9
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND )
On this, th*m-day of , 20 , before me, the
undersigned officer, personally appeared rt oth known to me (or satisfactorily
proven) to be the person whose name is bscrl ed to the within instrument, and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
(seal)
L.,001 OU 1
COMMONWEALTH OF PENNSYLVANIA
Notarial Sear
Jennifer S. Lindsay, Notary Public
Carlisle Boro, Cumberland County
My Cornntmion E)ires Nov. 28, 2011
Member, Pennsylvania Association of Notaries
FILED-DH
2009 AUG -7 Fir : t4 9
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LAURA A. ROTH,
V.
KURT E. ROTH,
Plaintiff
Defendant
AUG i p 2009 (,.7
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2003-4825 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
RETIREMENT BENEFITS COURT ORDER
AND NOW, this /Z day of src? , 2009, upon agreement of the
parties and pursuant to a Marital Settlement Agreement dated October 21, 2005, it is
hereby
ORDERED, that Laura A. Roth, S.S. # xxx-xx-xx41, 926 Brook Arbor Drive, Cary,
North Carolina, 27519 is awarded Fifty Thousand Dollars ($50,000.00) plus interest and
earnings at a rate equal to the "Government Securities Investment Fund" ("G Fund")
from the valuation date of July 1, 2008 until two business days before payment is
processed, from the Thrift Savings Plan account of Kurt E. Roth, S.S. # xxx-xx-xx08,
125 Partridge Circle, Carlisle, Pennsylvania 17013.
ichael A. Scherer, Esquire
19 West South Street
Carlisle, Pennsylvania 17013
Attorney for Laura A. Roth
urt E. Roth
125 Partridge Circle
Carlisle, Pennsylvania 17013
BY THE COURT,
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