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Home My WebLink About03-6348 J JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-~t'.fCIVIL TERM 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, 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 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant ; NO. 03- ~q CIVIL TERM COMPLAINT The plaintiff, Jennifer Gossert, by her attorneys, the Family Law Clinic, sets forth the following cause of action: DIVORCE UNDER 23 Pa,C.S, SECTION 330t(c) AND 23 Pa. C.S. SECTION 3301 (d) OF THE DIVORCE CODE I. Plaintiff is Jennifer Gossert, who currently resides at 445 East King Street, Shippensburg, Cumberland County, Pennsylvania. Plaintiff has resided there for approximately the last six months. 2. Defendant is Arthur Gossert, who currently resides at 6599 Upper Strasburg Road, Pleasant Hall, Franklin County, Pennsylvania. Defendant has resided there for approximately the last five years. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 26, 1993, in Roxbury, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since June 1996. 6. There have been no prior actions of divorce or for annulment between the parties. 7, The marriage 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, Plaintiff requests the court to enter a decree of divorce, Date loy8/03 C-OvJ..c"-';r 1'1, ~"" Carolyn M, Fenton Student Attorney ~4e~_1 THOMl" M. PLACE ~ ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 VERIFICATION I verify that the statements made in the foregoing are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa,C.S. ~4904, relating to unsworn falsification to authorities. Date: /~/glt3 tlvn/1Mlt/0 (;o,~ P~ntiff ~ ~ (") J;-; "1:'),-, C!)! -:--;:;- "'", , Cr" - [.-: .' ..,::: ,., j,>. :::~ " ,b - ,- .~ c) c.) .'J ""I -., I ():) (") "q ;.-] C; \-\ < i~.J c. "---[ .-~: :~~l "':'1 'i....':'" ~-~J -~ "D JENNIFER GOSSERT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO, 03- ~~CIVIL TERM ARTHUR GOSSERT, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Jennifer Gossert, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date /';)/8/03 C&~h'\ f'l. ~ Carolyn M, Fenton Certified Legal Intern ~A~~~-f ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 (") c' c~ C L} n ~ W "" 'J ;., 1'1 \..' -1'; n1 (,' c-; - , 7C:: c I I !l C. en :.::;) f~~ ~-::l ~" -r, ~: :::: ('j ~-. , -- j' n -, .0:"'_ j;: ::J .l) .....- -( JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-6348 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case, docket number 03- 6348, ~IT).~ Carolyn M. Fenton Certified L(:gal Intern Dated: April 12, 2004 ,..." c:.:> C:::) .c- (~ -' -il :J:i" r'i1r :;~? SQ ~~~~ --:>:l"n , , ~~:: :~:l i:'~"O :"J AJ N ~, -"''',"' ~, -=s t;,; <::) 0:> JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-6348 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case, docket number 03- 6348, //-1. ~~dd::s ~acht Certified Legal Intern ~u~# THO . PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Attorneys for Plaintiff Dated: June 7, 2004 u-; ", c..~) (.:::-:) ""- ( ~2 I --.J c') ., ::;:I J~-n .,;:::;:; .'r:Jln :;:..'1(-; (?,(~ ~T:: :r{ ~~ ~ ;:~1 ::s ::D -':;.: JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-6348 CIVIL TERM AFFIDAVIT OF SERVICE I, Anne MacDonald-Fox, hereby certify that on this date I served a true and correct copy of Plaintiffs Divorce Complaint filed December 8, 2003, and her Praecipes to Reinstate the Complaint filed April 8, 2004 and June 7, 2004, by hand delivering same to the Defendant at his place of employment at West End Service Center, 302 Lurgan Avenue, Shippensburg, PA. 17257. ---- Date: J(jM';(3. c200V I ~ <Id-F", Family Law Clinic 45 North Pitt Street Carlisle, P A. 17013 (717) 243-2968 o ,-- r-' "'" :? '- (_:~~ ."y ",r,'~' 1" 0' (-- ::2 () ---n .-\ Rl?;) -r;0' :;--~]~) .-,---, :.,:_:r:-) ;_~);r .~ .J ...;.",,,. r:~ o r...) JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-6348 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(C) of the Divorce Code was filed on December 8, 2003. 2. The complaint was reinstated on April 12, 2004 and again on June 7, 2004. 3. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have lapsed from the date of filing and service of the complaint. 4. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify 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. 94904 relating to unsworn falsification to authorities. Date: I / - / /J.. -OL/ ~fer C) ~:~:~ ,...." -(::;:::) c,::) .L:- c. eX> :::J (,) -" V~) co C) -'"\"1 ~T~ ?E \:J ::Ii -~-l \1".... C: " ~:t : ~.~~ ~:-(I )'''...) JENNIFER GOSSER T Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-6348 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.. C.S. ~ 404 relating to unsworn falsification to authorities. Date: / / - / J. -{}If trer . " ,,,' , :' ; ,_.... f" " C'.:' t,'" :i.~~: ' r,,' r--..:> ';"-',:') c:"t ~,'~ c ....~ ..: C'~ ,"' -"1 (~) ....0 JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO, 03-6348 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted, AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in June 1996 and have continued to live separate and apart for a period of at least two years, 2, The marriage is irretrievably broken, 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted. ! \'erify that the statements made in this affidavit are true and correct. I understand t,1J.at false statements herein are made subject to the penalties of 18 Pa.C,S. s4904, relating to unsworn falsification to authorities. Date J//7 IdS JENNIFER GOSSERT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO, 03-6348 CIVIL TERM CERTIFICATE OF SERVICE I, Rene M. Gomall, hereby certify that on this 23'd day of February, 2005, I am serving a true and correct copy of the Plaintiff's Affidavit under Section 3301(d) of the Divorce Code on Arthur Gossert by first class U.S, mail, addressed as follows: Mr. Arthur Gossert 6599 Upper Strasburg Road P,O. Box 57 Pleasant Hall, P A. 17246 Date:~ dfi:- Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, P A 17013 ~ . JENNIFER GOSSERT Plaintiff : IN THE COURT OF CO MON PLEAS OF : CUMBERLAND COUN Y, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO. 03-6348 CIV TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following inforrnatio ,to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S 3301(d) 0 the Divorce Code. 2. Date and manner of service of the complaint: June 23, 2004, b hand-delivery at Defendant's place of employment. 3. Date of execution of the Plaintiffs Affidavit required by g 3301 d) of the Divorce Code: February 23, 2005; Date of service of the Plaintiffs Affidavit upon he Defendant: February 23,2005. 4. Related claims pending: none. 5, Date and manner of service of the notice of intention to file raecipe to transmit record, a copy of which is attached: United States mail, first class, postage repaid on March 17, 2005. Date~ rtJ/}j( ( R~ER E. INS T MA . PLACE ANN CDONALD- OX LUCY JOHNSTON-W LSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 ,c.- ,--) C) ,-:::J. (,.::;.? -n C,.n ~.. -\:i -;:.;;~-~ \ C:) -"\"1 ,'0 CJ _l - ,. # JENNIFER GOSSERT Plaintiff : IN THE COURT OF CO MON PLEAS OF : CUMBERLAND COUN Y, PENNSYL VANIA Y. : CIVIL ACTION - LAW : DIVORCE F I L E ARTHUR GOSSERT Defendant : NO, 03-6348 CIVI TERM TO: ARTHUR GOSSERT You have been sued in an action for divorce, You have failed to swer the complaint or file a counter-affidavit to the S 3301(d) affidavit Therefore, on or after A ril6, 2005, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can nter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of t e court is attached to this notice, Unless you have already filed with the court a written claim for eco omic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief The filing of the form counter-affidavit alone does ot protect your economic claims, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT NCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO TELEPHONE THE OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT IRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS FFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCI S THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUC D FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with th Americans with Disabilities Act of 1990, For information about accessible facilities and reason ble accommodations available to disabled individuals having business before the curt, please contact our office, All arrangements must be made at least 72 hours prior to an hearing or business before the court, You must attend the scheduled conference or hearin . .-> '(~ <" ?o -;;0 \ cP ,...." ......------ q" ,,-;>;,...l. -<', "",, ..,"-;"--- < \"<:' ~(l (:1 )~\\ ~2, ..~',~Jj(, /, ":', .-<'. ~ " c.? -' ,,~>~ ':Z .~--,~., . JENNIFER GOSSERT Plaintiff : IN THE COURT OF CO MON PLEAS OF : CUMBERLAND COUN Y, PENNSYLVANIA v, : CIVIL ACTION - LAW : DIVORCE ARTHUR GOSSERT Defendant : NO, 03-6348 CIVIL TE CERTIFICATE OF SERVICE I, Rene M. Gornall, hereby certify that on this 8th day of April, 20 6, I am serving a true and correct copy of the Praecipe To Transmit Record and Divorce Info tion Sheet on Arthur Gossert by first class U.S. mail, addressed as follows: Arthur Gossert 6599 Upper Strasburg Road Pleasant Hall, P A 17246 Date:~ h {b5 ( en . Gornall Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, P A 17013 n ....' C.:.:'l C;:::.l cf' ?:j o"^v' Cl -n ---\ fFi p2 :st\!j )' Ie) '\f\ ~;:::: ;] C') N C) -, ..<. IN THE COURT OF CO MON PLEAS OF CUMBERLAND COUN ,PENNSYLVANIA CIVIL ACTION - LAW NO. 04-4393 ROBERT WARFIELD, Plaintiff vs. BONITA WARFIELD, Defendant IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION T ENTRY OF A DIVORCE DECREE UNDER !i 3301 ( d ) OF THE DIVORCE CODE 1, I consent to the entry of a final Decree of Divorce without notice, 2, I understand that I may lose rights concerning alimony, division of prop expenses if I do not claim them before a divorce is granted, CIVil TERM REQUE T I I I I I I rty, lawytr's fees or i 3, I understand that I will not be divorced until a Divorce Decree is entere by the C urt and that a copy of the Decree will be sent to me immediately after it is filed with th Prothon tary, I verify that the statements made in this Affidavit are true and correct to he best f my knowledge, information and belief. I understand that false statements herein are made ubject t the penalties of 18 Pa,C,S, 4904 relating to unsworn falsification to authorities, Date: 3//1 )05 bb/divorcestWarfield, Defendantwaiver 3.1,05 "'" c.:::. = "" ~ :xJ I ....J ~". ~ ~-r1 p'--'" :;g Fi1 ,-~ 'T ...J.() ~~~,~ ':::::t '~ ~c :...:..:: 8 u.:> -- - - ROBERT WARFIELD, Plaintiff IN THE COURT OF CUMBERLAND CO vs. NO, Oti- 'fJ1.3 OMMON PLEAS OF Y, PENNSYL VANIA IVIL TIJ!RM BONIT A WARFIELD, Defendant IN DIVORCE ACCEPT ANCE OF SERVICE ! ! I accept service of the Divorce Complaint on behalf of Bonita Warfi ld and c+rtify that I am authorized to do so, " i , ~(/ 9 ~ 5"- 0'-1 : ',-~,_ Date Joanne Harrison Clou ~~ 2331 Market Street Camp Hill, PA 1701 ------ C) (~ ~ '-'~;Jo 'Cn -~" "0 ~:J 1 ---' ,.-) "" -::?:Q r~, (;j -:?,q ik."\(~!, ':-'~'~~~1 ':~- fI' ;,'") -::::.-\ '<; :..,.~ -..: N .' '--" '--" - r , . , MARITAL SETTLEMENT AGREEME T THIS AGREEMENT, made this ~ ~y of March, 2 05, by arId between Bonita Warfield, (hereinafter "WIFE') and Robert W field, (hereinafter "HUSBAND"); WITNESSETH: WHEREAS, the parties hereto were married on June 28, 198f, in York County, Pennsylvania, and separated on November 20, 2002; an WHEREAS, the parties have two (2) children of this iagej Benjamin Warfield born on April 7, 1990, and Blaine Warfield born on Sept mber IS} 1992, i WHEREAS, difficulties have arisen between the parties and it ~ therefore their intention to live separate and apart for the rest of their live and the rarties are , desirous of settling completely the economic and other rig ts and bligations between each other, including, but not limited to: the equitabl distribu 'on of the marital property; past, present and future support; alimony, ali ony pe dente lite; and, in general, any and all other claims and possible claims by 0 e again I the other or against their respective estates. WHEREAS, Bonita and Robert and their respective cou el ente~ed into a Collaborative Law Participation Agreement dated August 13, 2 04, and ~ave used the Collaborative Law Process in negotiating this Agreement. NOW THEREFORE, in consideration of the coven ts and 'i promises hereinafter to be kept and performed by each party and inte ing to j:,e legally bound hereby, the parties do hereby agree as follows: 1, ADVICE OF COUNSEL. The provisions of this Agreement and their legal effec have J:1een fully explained to the parties by their respective counsel. WIFE s repre*nted by JOANNE HARRISON CLOUGH, Esquire. HUSBAND is repre ented by DAWN SUNDAY, Esquire. 1 . '. The parties further declare that each is executing the greement freely and voluntarily having either obtained sufficient knowledge an disclosure of their respective legal rights and obligations, or if counsel has ot beetj. consulted, expressly waiving the right to obtain such knowledge. The parties each acknowledge that this Agreement is fair and equitable and is ot the result of any fraud, coercion, duress, undue influence or collusion. 2. DIVORCEACfION. , The parties acknowledge that their marriage is irretriev bly bro~en and that HUSBAND shall secure a no fault divorce pursuant to !l 33 l(d) of the Divorce Code. A divorce action was filed by HUSBAND with the Court of Co~on Pleas of Cumberland County, Pennsylvania at Civil Action No. 04-4393 on Au~t 30, 2004, seeking a divorce under section 3301 (c) or (d) of the Pennsylv 'a DivorJe Code. This Agreement shall remain in full force and effect afte such tirfe as a final decree in divorce may be entered with respect to the parties. e partiej; agree that the terms of this Agreement shall be incorporated into any D vorce ~ee which may be entered with respect to them and specifically refere ced in *e Divorce Decree. Ibis Agreement shall not merge with the divorce decr , but s~ continue to have independent contractual significance. 3. DATE OF EXECUTION. , The "date of execution" and "execution date" of this greernept shall be defined as the date upon which it is executed by the parti if they I have each executed the Agreement on the same date. Otherwise, the "d te of eXf:ution" or "execution date" of this Agreement shall be defined as the date of execu~on by the party last executing this Agreement I 4. MUTUAL RELEASES. Each party absolutely and unconditionally release the ot er and t~e estate of the other from any and all rights and obligations which either may hat for past, present, or future obligations, arising out of the marital relatio hip or lotherwise, including all rights and benefits under the Pennsylvania Divorc Code o~ 1980, and amendments except as described herein. 2 Each party absolutely and unconditionally releases the ther and his or her heirs, executors, and estate from any claims arising by v' e of the marital relationship of the parties. The above release shall be effective hether liUch claims arise by way of widow's or widower's rights, family exem tion, or under the intestate laws, or the right to take against the spouse's will, 0 the right to treat a lifetime conveyance by the other as testamentary or all other 'ghts of II surviving spouse to participate in a deceased spouse's estate, whether ari ing under the laws of Pennsylvania, any state, Commonwealth, or territory of the nited St~tes, or any other country. , I Except for any cause of action for divorce which either party mhy have or , claim to have, each party gives to the other by the execution 0 this A~eement an absolute and unconditional release from all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSUR The parties confirm that each has relied on the accur y of th~ financial I disclosure of the other as an inducement to the execution of thi Agreerrlent. Each I party understands that he! she had the right to obtain from the oth4r party a complete inventory or list of all property that either or both p rties owred at the I time of separation or currently and that each party had the rig t to havt all such property valued by means of appraisals or otherwise. Both p es unde$tand that they have right to have a court hold hearings and make decisi ns on t~e matters covered by this Agreement. Both parties hereby acknowledge th this Agteement is fair and equitable, and that the terms adequately provide for his her int~rests, and that this Agreement is not a result of fraud, duress or undue infl ence ex4rcised by either party upon the other or by any person or persons upon eith r party, i 6. SEPARATION{NON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafte live seprrate and apart. They shall be free from any interference, direct or indirect, by the o~her in all respects as fully as if they were unmarried. Each may, for his or er separ~te use or benefit, conduct, carry on and engage in any business, occupa on, proff.'ssion or employment which to him or her may seem advisable. WIFE an HUSBAND shall not harass, disturb, or malign each other or the respective families f each o~her. 3 7. REAL PROPERTY. The parties are the joint owners of real property 10c locations: a. marital residence: The parties agree the value of t e mariW residence located at 1481 Jacobs Mill Road, Hanover, York County, P ylvar1ia, 17331 is $152,000.00. HUSBAND and WIFE specifically agree that in consideration of the other property transfers set forth in this Agreement, HUSBA D agreeS to transfer any and all right, title, claim or interest he has in the real pro erty loc4ted at 1481 Jacobs Mill Road, Hanover, PA to WIFE. Said real property hall be t~e sole and exclusive property of WIFE. WIFE agrees to indemnify d hold \HUSBAND harmless on any taxes, liens, utilities or other obligations asso iated wAh said real property. HUSBAND and WIFE agree to execute a deed trans erring KuSBAND's interest in said real property to WIFE contemporaneously with e exec~tion of this Agreement Said deed shall be prepared by WIFE's counsel. agr+ to tender to HUSBAND the sum of THIRTY-TWO THOUSAND FIVE REDIOOLLARS I (32,500.00) within seven (7) days of HUSBAND executing sai deed. fIUSBAND must use these monies to pay in full and satisfy the business line of credit!loan that is a lien against the townhouse property identified in paragraph cere belot. , I b. 830 Sunnyside Road, York, PA 17404: HU BAND rnd WIFE acknowledge that HUSBAND purchased real estate located at 0 Sunnxside Road, York, P A on or about December 20, 2002, in his sole name. The p~es further , acknowledge that there is a mortgage in HUSBAND's s Ie nam~ with an approximate balance of $92,000.00. HUSBAND and W agr,* that in consideration of the other property transfers set forth in thi Agree ent WIFE agrees to transfer and/or waive any and all right, title, claim r intere t she may have in said real property to HUSBAND. HUSBAND agrees to be soleI liable for, and indemnify and hold WIFE harmless on any/and all mo gage, t xes, liens, utilities, or other obligations associated with this real propert. WIFE agrees to execute a Quit Oaim Deed prepared by HUSBAND's couns I transf rring any I interest she has in this property to HUSBAND contempor eously I, with the " , execution of this Agreement. : c. 82 Conewa 0 Drive Hanover Adams Count PAt wnhouse: HUSBAND and WIFE own a townhouse located at 82 Conewa 0 Drive,: Hanover, Pennsylvania, HUSBAND and WIFE agree to list this real pro rty for ~ale at fair 4 market value. The parties further acknowledge that they will ' cur a capital gains tax obligation as a result of the sale of this property and each grees to be equally liable for said capital gains obligation. Each party shall pay his r her portion of the capital gains tax within thirty days of settlement. HUSBAND d WIFE agree that HUSBAND shall receive the net proceeds from the sale of the ownhou$e after the lien is satisfied and all commissions, real estate and transfer t xes and bther costs associated with the property are paid in fulL The parties a that HUSBAND shall receive the net proceeds from the sale of the townhouse. e partie~ shall then calculate the townhouse net proceeds plus the $152,000.00 v lue of ~he marital , residence to determine if HUSBAND is due any additional m nies frof WIFE so that he receives 50% of the combined values of the marital resid nce and townhouse assets, . 8. DEBTS. If a party has acquired debt, the parties agree that each s II assurhe full and I complete responsibility for his or her own debts. HUSBAND represents and warrants to WIFE that since t e separahon he has I not, and in the future he will not, contract or incur any debt 0 Iiabilit}j for which WIFE or her estate might be responsible, and he shall inde 'fy and ~ave WIFE harmless from any and all claims or demands made against he by reaspn of such debts or obligations incurred by him since the date of said s parationj except as otherwise set forth herein. I I I WIFE represents and warrants to HUSBAND that since the sepJration she I has not, and in the future she will not, contract or incur any ebt or lIability for which HUSBAND or his estate might be responsible, and she all inde\mnify and save HUSBAND harmless from any and all claims or demands de agai~st him by reason of such debts or obligations incurred by her since the dat of said feparation, except as otherwise set forth herein. ' HUSBAND agrees to be solely responsible and inde fy and Th.old WIFE I harmless on the following obligations: : 1. Capital One Account No. 4802132249367759: ap roxima~e balance $3,942.65 as of August, 2004, , 2. MBNA America Account No. 5490990148063702: a proximalte balance , $7,512,99. 5 " 3. Waypoint, now Sovereign Bank: loan for H BAND's business. Approximate balance $24,000.00 that is secured by a lien on t e townhouse. This debt will be paid from HUSBAND's share of settlement proceeds from the townhouse. HUSBAND and WIFE acknowledge the Waypoint Bank oan is ~ured by a lien on the townhouse and this lien shall be paid in full by USBAND with the monies he receives from WIFE under paragraph 7a of this Agree 9. RETIREMENT BENEFITS. i HUSBAND is the owner of certain IRA accounts. W is th, owner of certain IRA accounts and retirement plans through her empl yment ~ a public school teacher. Husband has the following IRAs: a. Franklin Templeton Roth IRA: r; 976-1~6254. The approximate balance for this account as of Jun 2004 is 1,787.00. h Seligman Roth IRA: account number; 0070015 59. The approximate balance of this account as of June, 2004 is $ ,415.00. c. Lincoln Fund: account balance; 98113-24 85-106 46. The approximate balance for this account as of Jun 2004 is 7,851.00, I Wife has the following IRAs: I a. Seligman Roth IRA: account number 070015~' The approximate balance for this account as of June 2004 is 3,905.00. b. Lincoln 403 (b) Plan: account number 73923 31407-2 03B. The approximate balance for this account as of June 2004 is $11,167.00. , c. Franklin Templeton Roth IRA: account nurn r 976-1 6278. The approximate balance for this account as of June 2004 is 3,317.00. d. American Funds IRA: account number 732333. The approximate balance for this account as of June 2004 is$ 6,853.00. e. PSERS Account: participants contributions ough Ju , e 30, 2003 are $34,042.00 (no independent valuation p rsuant to parties' agreement). 6 In consideration of the property transfers in this A eement, HUSBAND hereby waives his right, title and interest to any of WIFE's 's, pension and/or retirement and any and all other retirement benefits, othe se disclqsed. WIFE hereby waives her right, title and interest to any of HUSBA 's IRA's, pension and/ or retirement and any and all other retirement benefits, 0 rwise djsclosed. The parties specifically waive any and all other retirem nt bene~its obtained by the parties pre-marriage, during marriage, and post-separa 'on. Th~ individual who holds said benefits shall own the property solely and indi 'dually.! Each party waives their right to title and interest to the other party's benefi , 10. BANK ACCOUNTS. , The parties acknowledge that they have divided the 'tal bapk accounts and investment accounts to their satisfaction. The bank acc unts held solely in individual names shall become the sole and separate property f the projry in whose name it is registered. Each party does hereby specifically waiv and rel1ase his/her right, title and interest in the other party's respective accounts. i 11. LIFE INSURANCE. , HUSBAND hereby waives any right, title, claim or int rest he rPay have in , any life insurance policy of WIFE. WIFE hereby waives any right, ti~le, claim or interest she may have in any life insurance policy of HUSBAND 12. PERSONAL PROPERTY, Except as set forth here below, the parties hereto mu ally agr~ that they have divided all furniture, household furnishings and person I propetty between i them in a manner agreeable to both parties. The parties mu ally agr~ that each party shall from and after the date of this Agreement be the sol and sepfrrate owner of all tangible personal property in his or her possession. b shall I remove his property from Jacobs Mill Road by September 1, 2005, Bob sha 1 prepcut a list to be reviewed and approved by Bonnie of the items he intends to eep as ~is personal , property. ! 13. VEHICLES. The parties own a 2000 Honda Ovic, a 1996 Mercury Vi ager, a 1~85 Yamaha motorcycle and HUSBAND owns a 1978 Mazda. HUSBAND a ees to tansfer any 7 right, title, claim or interest he may have in the 2000 Honda 0 'c to WIFE, and said vehicle shall be WIFE's sole and exclusive property. WIFE agrees to waive or transfer any right, title, claim or interest she may have in the 1 6 Mercury Villager, 1985 Yamaha motorcycle and in the 1978 Mazda and sai vehicles shall be HUSBAND's sole and exclusive property. 14. TOWNHOUSE BANK ACCOUNTS: The parties have two (2) bank accounts they use in onnection with the townhouse. The parties agree to divide the proceeds equally i these aCFounts after the sale of the townhouse and refund or transfer of rent security deposit Iinonies. 15. HUSBAND'S BUSINESS. HUSBAND and WIFE agree that WIFE shall waive or transfer iany and all right, title, claim, or interest she may have in HUSBAND's bus' ess, Bobfs Brass and Woodwind Repair to HUSBAND and said business shall be t e sole mid exclusive property of HUSBAND. HUSBAND agrees to be solely liable d responsible for an indemnify and hold WIFE harmless on any business obligations 16. CUSTODYjPARENTING PLAN. The parties specifically agree that WIFE shall have pri of Benjamin and Blaine Warfield and HUSBAND shall have p at certain times as the parties may agree. HUSBAND and legal custody of the minor children and shall each participate ' decisions affecting the health, education, safety, and welfare of physical custody 'al physkal custody shall have shared all major parenting e children. HUSBAND and WIFE agree that they will share in arenting their sons, Benjamin and Blaine. All major decisions regarding Benjami and Blaine shall be made by the parents jointly, after discussion and consulta ' n with each other. HUSBAND and WIFE shall notify each other of any activity or event' concerning Benjamin and Blaine that could reasonably be expected to be of concern to the other. HUSBAND and WIFE shall each be entitled to complete d full information regarding Benjamin and Blaine from any doctor, dentist, teac er, professional, etc., and to receive copies of any reports or information given to either of them as a parent 8 " HUSBAND and WIFE understand that they can alter th parenting schedule by their mutual agreement In the event one or the other pare t wishes to modify this schedule, and the parents are unable to reach an agree nt, HUSBAND and WIFE agree to return to the Collaborative Law Process prior to' 'tiating litigation, 17. CHILDREN'S EXPENSES AND COLLEGE EDU nON COSTS HUSBAND and WIFE agree that the parties shall coope ate with each other to jointly share equally expenses regarding the daily care and maintenance of the children and both shall contribute equally in any extra or ' expenses for the children. Bonnie and Bob agree to each contribute to th children's college education costs if each is finandally able and such contributio will not cause the parent financial hardship. Each party will pay, if able, up to 25% of college education costs to include room, board, and tuition of said c' equivalent to the Pennsylvania State School Tuition/Room Board costs at the' said monies shall be contributed, if parent is able, provided the child is enrolled time in a college or trade school approved by said parent and said child is not on academic or sodal probation. Each parent may use any educational funds he 0 she maintains, or college savings monies towards his or her contribution obligation HUSBAND and WIFE agree that neither shall seek suppo from the other for Benjamin or Blaine. Instead, the parents agree to share expe es related to their sons, depending upon their needs. In the event either parent is ssatisfied with this sharing of expenses, HUSBAND and WIFE agree to return to the Collaborative Law Process to re-address this issue prior to initiating support litig 'on. Both parties acknowledge their agreement to forego child support is unenforce ble by law. 18. CLAIMING MINOR CHILDREN ON TAXES. The parties specifically acknowledge that WIFE shall cla the children as dependents for income tax filing purposes. 19. BANKRUPTCY OR REORGANIZATION PROCE DINGS. In the event that either party becomes a debtor in any b ptcy or financial reorganization proceedings of any kind while any obligatio remain to be performed by that party for the benefit of the other party pursuan to the provisions of this Agreement, the debtor spouse hereby waives, releases an relinquishes any right to claim any exemption (whether granted under State or F derallaw) to any 9 " property remaining in the debtor as a defense to any claim mad pursuant hereto by the creditor-spouse as set forth herein, including all attorney f and costs incurred in the enforcement of this paragraph or any other provision of his Agreement. No obligation created by this Agreement shall be discharge or dischargeable, regardless of Federal or State law to the contrary, and each p waives any and all right to assert that obligation hereunder is discharged or dischar eable. The parties mutually agree that in the event of b ptcy or finandal reorganization proceedings by either party in the future, any onies to be paid to the other party, or to a third party, pursuant to the terms of t 's Agreement shall constitute support and maintenance and shall not be discharged' bankruptcy. 20. ALIMONY, SPOUSAL SUPPORT, AND ALl ONY PENDENTE LITE, The parties hereby expressly waive, release, discharge d give up any and all rights or claims which either may now or hereafter have f r spousal support, alimony pendente lite, alimony, or maintenance. The parties further release any rights that they may have to seek modification of the terms of's Agreement in a court of law or equity, with the understanding that this Ag:t' ment constitutes a final determination for all time of either party's obligations t contribute to the support or maintenance of the other. 21. ATTORNEY FEES, COURT COSTS. Each party hereby agrees to be solely responsible for his r her own counsel fees, costs and expenses. Neither shall seek any contribution th eto from the other except as otherwise expressly provided herein. 22. 2004 INCOME TAXES HUSBAND and WIFE agree to cooperate and file a joint federal income tax return for the 2004 tax year and to equally divide any refund. I the event any tax liability is owed, then the party whose income caused the tax liabi ity due and owing shall pay said liability in full and indemnify and hold the other party harmless on said obligation. 10 '. I \ 23. ENFORCEMENT of AGREEMENT. If either party believes that the other party has breached y provision of this Agreement, the parties agree to return to the Collaborative La Process to resolve the issue. If the parties are unable to resolve the issues throu the Collaborative Law Process, a party shall have the right at his or her election to ue for damages for such breach or seek such other remedies or relief as may be av 'able to him or her. The party breaching this contract shall be responsible for pay ent of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 24, WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a.) The right to obtain an inventory and the a praisement of all marital and non-marital property; (b.) The right to obtain an income and expense s party; (c.) The right to have all property identified and a praised; (d.) The right to discovery as provided by the Pe ylvania Rules of Civil Procedure; and (e,) The right to have the court make all dete tions regarding marital and non-marital property, equita Ie distribution, spousal support, alimony pendente lite, alim y, COUIJl;el fees and costs and expenses, 25. MUTUAL COOPERATION. WIFE and HUSBAND shall mutually cooperate with each 0 er in order to carry through the terms of this Agreement, including but not limite to, the signing of documents. 26, VOID CLAUSES. If any term, condition, clause or provIsIOn of this Agree ent sh</-ll be determined or declared to be void or invalid in law or otherwise, en only that term, condition, clause or provision shall be stricken from this Agr ent, and in all other respects this Agreement shall be valid and continue in full fo ce, effec~ and operation. It , " \ I \ 27. APPLICABLE lAW, This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 28. ENTIRE AGREEMENT, This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 29. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpos in resolving any ambiguity herein, the parties agree that this Agreement was prep ed jointly by the parties. IN WITNESS WHEREOF, the parties hereto have set their h ds and seals of the day first above written. This Agreement is executed in duplicate, and in caunterp s. WIFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. (()~ Q(J~ Witness /' (~/JLd Robert Warfiel~' 12 ~ COMMONWEALTH OF PENNSYLV ANlA COUNTYOF CumDl"dcr>J On the _II day of mUfch Notary Public in and for the Commonwealth of Pennsylvani officer, personally appeared -B,l\fl, \c" 10{,( t; e Id . known to proven) to be one of the parties executing the foregoing ins acknowledges the foregoing instrument to be her free act and dee :55. 005, before me, a the undersigned e (or satisfactory ent, and she IN WTINESS WHEREOF, I have hereunto set my hand an notarial seal the day and year first above written. NOTARIAL SEAL Mt S. RUDY. NcllIfy PubIc . I!aIl~J' ~~=- MrC- I ' __ ... S Notary Public My Commission COMMONWEALTH OF PENNSYLV ANlA :55. COUNTYOF C",,,,,be( I""J On the I \ day of March, 2005, before me, a Notary ublic in and for {t Commonwealth of Pennsylvania, the undersigned officer, pers nally appeared \nl (MG,-t,t> I~ known to me (or satisfactory proven) t be on ,of the parties executing the foregoing instrument, and he acknowledge the forl'!going instrument to be his free act and deed. IN WI1NESS WHEREOF, I have hereunto set my hand and otarial ~al the day and year first above written. Notary Public My Commission Exp res: "- NOTARIAl. SEAl. J "-' PAM S. RIJOY, t>lolaIy ~ r.~..u 1; ., ~ attea.I...w..I~q 14,~ -,~- - ,~ 13 \ '1'; ;:,' .' ,~ t;:; ~:~:?, ~7} -;:.;;:s -<- \ -l o "" ::t."fJ r"\r:-\ ;:-\\.? (_-;Cl -'-~ :;) '~~~:~A -~ :."" 8 :-.:.\ ':--<. c~,; ji,;" 2 - ROBERT WARFIELD, Plaintiff IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW vs, NO, 04-4393 C VIL TERM BONIT A WARFIELD, Defendant IN DIVORCE I PRAECIPE TO TRANSMIT RECORD " I i \ To the Prothonotary: \ , Please transmit the record, together with the following information to t e court f~r entry of a divorce decree: : ! 1, Ground for divorce: irretrievable breakdown under e Divor e Code and I two year separation, I 2, Date and manner of service ofthe complaint: Acce tance of ervice si ned b defendant's counsel on September 5. 2004, 3. Date of execution of the affidavit required by S 330l(d) of the Di orce Co e: March L 2005; Date of filing and service of the plaintiffs affida it upon t e respondent: March L 2005; March 11,2005, 4, Related claims pending: None, All claims resolved b Marital ettleme eement silWed by the parties on March 1 L 2005. 5. Defendant's Waiver of Notice in 93301(d): Si ned on March 11 005 and ttached for filing, ~(~ Attorney for Plaintiff Dawn S. Sunday, Esquire ID # 41954 39 W, Main Street - Suite 1 Mechanicsburg, P A 17055-62 0 (717) 766-9622 ((~- <-' C',-:'? <:::,,? (',.fl .....:'" -:.-(:; /.,) I ~.::..c. {~ .-\ ::C--;'J Ci:lr:: -d~\ ,),...,.' ;:>~('-) "! -,. ;;':~~~, ~<-\ N ("oj 'P ,~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E, HALL Plaintiff : NO. 05-1120 v. : CIVIL ACTION - LAW WENDY L. HALL, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(d) OF THE DIVORCE CODE , I consent to the entry of a final decree of divorce without not ce, I I understand that I may lose rights concerning alimony, divis'on ofprdperty, lawyer's fees or expenses if! do not claim them before a div rce is fi~alized. , I understand that I will not be divorced until a divorce decre is enter~d by the Court and that a copy of the decree will be sent to me imme iately aftfr it is filed with the prothonotary, I , , I I I verify that the statements made in this Affidavit are true and corre 1. I und~rstand that false statements herein are made subject to the penalties of 18 Pa.C's, 949 4 relatin~ to unsworn falsification to authorities, j 1. 2, 3. IW~ Robert E. Hall Dated: 3/.3<J/br F\IIOM!i\CAZ\(j.I\IIALLKOB\DlVORCE\AfFCONW A_WPD '..-;,-; r;:; S~?l <;:;:, <-" - -;{:.'i -;,:) -- -- "'i"'-" -;;:-.> ..~' . .- -~~ !"J 0'':0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E, HALL Plaintiff : NO,: 05-1120 v. : CIVIL ACTION - LAW WENDY L. HALL, Defendant : IN DIVORCE WAIVE OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRE UNDER 3301 c and 3301 d OF THE DIVORCE C DE 1. I consent to the entry of a final decree of divorce without no 'ce. , I understand that I may lose rights concerning alimony, divi ion ofPrJperty, I 2, lawyer's fees or expenses if! do not claim them before a divorce is granted 3, I understand that I will not be divorced until a divorce decre is enter~d by the I filed Wijh the , i Court and that a copy of the decree will be sent to me immediately after it i prothonotary, , I verify that the statements made in this affidavit are true and corre t. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. S 4904 lating tolunswom I i I i falsification to authorities. Dated: ,'5 h rJ /0 ;;- I I j{j jf ~ Wen~all Defendant .....> c'"' c? <f' ;:;; /\.) c-' -0 ,-\ :1:-.' fi,'f';:; -nCr\ -~,( , Y T \~),(-- -,,,:::;.:, ('j:;~~ ;.~!\\{\ ~~~;: r;J - c": .Jh !') Cf' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E, HALL Plaintiff : NO.: 05-1120 v, ; CIVIL ACTION - LAW WENDY L HALL, Defendant ; IN DIVORCE ACCEPTANCE OF SERVICE I, John J. Connelly, Jr., Esquire, Attorney at Law, hereby accept ser ice ofa ~rtified copy of the Divorce Complaint and Plaintiffs Affidavit under Section 3301 d) ofthelDivorce Code filed on March 3, 2005, to the above term and number on behalf ofth Defendtnt, Wendy * I L. Hall, on this X day of March, 2005. Respectfully submitted, I I I I , I (') c r---> = =' <J' ~ ';:0 --"- !_-" '!:';.': o --n ~-n fn--::::: r-r; -D}.-,,: -,'~~~\ is,F?, ~~ - - N 0-' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E, HALL Plaintiff : NO,: 05-1120 : CIVIL ACTION - LAW v, WENDY L. HALL, Defendant : IN DIVORCE COVNTER-AFFIDA VIT UNDER & 330Hd) OF THE DIVORCE CODE 1. Check either (a) or (b): .iL(a): I do not oppose the entry of a divorce decree. , I i I I i _ (b): I oppose the entry ofa divorce decree because (Che k (I), (ii)lor both): (I) The parties to this action have not lived sepa ate and ,art for a period of at least two years. I _(ii) The marriage is not irretrievably broken. \ Check either (a) or (b): I X (a): I do not wish to make any claim for economi relief. tunderstand that I may lose rights concerning alimony, di ision of roperty, lawyer's fees or expenses if! do not claim th m befor a divorce is granted. ' _ (b): I wish to claim economic relief which may i c1ude alitony, division of property, lawyer's fees or expens s or othe important rights, I 2, ! under stand that in addition to checking (b) above, I must also file all of m1economiC claims with the prothonotary in writing and serve them on the other party. f I fail t do so before the date set forth on the Notice oflntentio to Request Divorce Decr e, the di rce decree may be entered without further notice to me, and I shall be unable thereaft to file a y economic , claims, I 'I I verify that the statements made in this affidavit are true and corre . I unde~stand that false statements herein are made subject to penalties of 18 Pa.C,S. S 4904 r lating tolunsworn falsification to authorities, Dated: ~ ) ~o /;1 S I I /~~ /~ iL Wendy L. H I Defendant {~) ,- ,..., C'~? ~ ;0 :;:::t - - CA __-4 -r..-r, f"\....-r'- -','1P:':\ l~~<C, ,,^ v'~,~ Y' -,...,- -",' .:~~';;; - --- ('..) 0''1. ":c; '-<'- - MARITAL SETTLEMENT AGREEMENT BY AND BETWEEN ROBERT E. HALL AND WENDY L HALL Jordan D. Cunningham, Es uire Cunningham & Chernicoff, P.C. 2320 North Second Street P. O. Box 60457 Harrisburg, P A 17106-045 (Attorney for Robert E, Ha I) John J. Connelly, Jr., Esqui e . James, Smith, Dietterick & Connelly! 134 Sipe Avenue ' Hummelstown, PA 17036 (Attorney for Wendy L Ha I) MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made by and between ROBERT E, HA of Cumberland County, Pennsylvania (hereinafter referred to as "HUSBAND"), and W NDY L. HALL of Cumberland County, Pennsylvania (hereinafter referred to as "WIFE"), WITNESSETH: WHEREAS, WIFE was born on November 24, 1954, and curren Iy reside~ at 2880 Ford Farm Road, Mechanicsburg, Cumberland County, Pennsylvania; WHEREAS, HUSBAND was born on November 17, 1945, and Ford Farm Road, Mechanicsburg, Cumberland County, Pennsylvania; I urrently ~esides at 2880 WHEREAS, the parties hereto are husband and wife, having bee married I on May 7, 1983, in Harrisburg, Dauphin County, Pennsylvania; WHEREAS, the parties are the parents of the following minor c ildren: Name Sex Date ofBirt R. Jarek Hall M 12/27/85 Skyler E, Hall M 8/12/88 Chesse S.B. Hall F 1/ 16/92 WHEREAS, the parties hereto are desirous of settling fully and nally their respective financial and property rights and obligations as between each other, incl ding, wi1hout limitation, the settling of all matters between them relating to the owner hip of re41 and personal property, the support and maintenance of one another, and in general, th settling pf any and all claims and possible claims by one against the other or against their resp ctive est*es. WHEREAS, the parties previously entered into prior to their ma iage a c~rtain Ante- Nuptial Agreement dated April 26, 1983, the terms of which are incorpo ated intol this Agreement. 1 NOW, THEREFORE, in consideration of these premises, and of he mutual promises, covenants, and undertakings hereinafter set forth, and for other good an valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the arties hereto, HUSBAND and WIFE, each intending to be legally bound hereby, cove ant and algree as follows; I. ADVICE OF COUNSEL: The provisions ofthis Agree ent and tlleir legal effect have been fully explained to HUSBAND by his counsel, Jordan D. Cun ingham, Esquire, and to WIFE by her counsel, John J. Connelly, Jr., Esquire. Each party ackno ledges that he or she has had the opportunity to receive independent legal counsel of his or her se ection, aIitd that each fully understands the facts and his or her legal rights and obligations, an each patty acknowledges and accepts that this Agreement is, in the circumstances, air and equitable, and that it is being entered into freely and voluntarily, and that execution of his Agre~ment is not the result of any duress or undue influence, and that it is not the result of an improper or illegal agreement or agreements. In addition, each party hereby acknowledges hat he 011 she is aware of the impact ofthe Pennsylvania Divorce Code, 23 Pa, C.S.A. S3 IO I, et ., whereby the Court has the right and duty to determine all martial rights of the parties inclu ing divorbe, alimony, alimony pendente lite, equitable distribution of all marital property or p perty ol1Tned or possessed individually by the other, counsel fees and costs oflitigation nd, fully Iknowing the same, and being fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions s forth herein are fair, just and equitable to each of the parties, and waives his and her respecti e right t~ have the Court of Common Pleas of Cumberland County, or any other court of compet nt jurisdiction, make any determination or order affecting the respective parties' rights to alimony alimony ipendente lite, , equitable distribution of all marital property, counsel fees and costs ofli igation, or any other right arising from the parties' marriage. 2 2. DISCLOSURE OF ASSETS: Each of the parties hereto cknowledges that he or she is aware of his or her right to engage in discovery, including but not imited to, written interrogatories, motions for production of documents, the taking of oral epositiOllLs, the filing of inventories, and all other means of discovery permitted under the Penns lvania Divorce Code or the Pennsylvania Rules of Civil Procedure and each ofthe parties speci cally waiives his or her right to engage in any further discovery, Each of the parties further ac owl edges that he or she is aware of his or her right to have the real and/or personal property, est te and aS$ets, earnings and income of the other assessed or evaluated by the Courts of this Co onweal~h or any other Court or competent jurisdiction. The respective parties do hereby warra t that thdre has been I full and fair disclosure to the other of his or her income, assets and liabil' ties, and leach party agrees that any right to further disclosure, valuation, enumeration or stat ment thereof in this i Agreement is hereby specifically waives, and the parties do not wish to ake or afpend hereto any further enumeration or statement The parties hereby acknowledge nd agree Ithat, based I upon the warrants of disclosure, the division of the marital assets as set rth in this Agreement is I considered fair, reasonable and equitable, and is satisfactory to them. E ch ofthe Iparties hereto further covenant and agree for himself and herself and his or her heirs, e ecutors, ~dministrators I or assigns, that he or she will never at any time hereafter sue the other p rty or hisl or her heirs, executors, administrators or assigns in any action of contention, direct 0 indirect, land allege therein that there was any duress, undue influence, or that there was a fa lure to have available I full, proper and independent representation by legal counsel. I The parties acknowledge that prior to their marriage, they execut d a vali~ and binding , Antenuptial Agreement which, in part, contained an anti-transmutation ause proyiding that each party's property was to remain their own property regardless of the manner i~ which the property became titled during the marriage unless the parties executed a express written , agreement to the contrary, Each party warrants to the other that they ne er entered into either an 3 expressed or implied oral or written agreement altering the ownership 0 each party's property during the marriage. 3. EOUlTABLE DISTRIBUTION: The parties acknowledge that the terms of the Ante-Nuptial Agr ement control the ownership of property owned by each party prior to the marriage which greemen:t is not intended to be superceded or merged into this Agreement. In order to cl rify the dontinuing ownership of certain non-marital property and the division of marital pr perty the! parties acknowledge the following: (a) Real Pro\)ertv: The parties acknowledge that HU BAND is the owner of five (5) parcels of real property which are as follows: (i) #2, 100th Street, Stone Harbor, New Jerse (ii) 2880 Ford Farm Road, Upper Allen Town hip, Me~hanicsburg, Cumberland County, Pennsylvania; (iii) Four (4) undeveloped lots located in Low r Paxton lrownship owned by Hall Development Corporation; (iv) 2841 North Front Street, Harrisburg, Dau hin Coudty, I Pennsylvania; (v) 18 acres of undeveloped real estate locate in WestlHanover Township, Dauphin County, Pennsylvania. The parties agree as follows with respect to each of the p rcels of ~eal property set forth above that: (i) HUSBAND shall be and remain the sole ner ofl1is interest in each of the above described parcels of real estate and WI E hereb]' waives and , releases any right, title, claim or interest she may have in and to HVSBAND'S interest in each of the above described parcels of real est te; 4 (ii) WIFE agrees that as of the effective date 0 this Agreement, any and all title policies, and any other policy of insurance wi h respect to HUSBAND'S interest in any of the above described polic'es shall he endorsed to reflect HUSBAND as sole owner thereof and WIFE furth r agrees that HUSBAND shall be entitled to receive any payments no or hereafter due under any such insurance policies. (iii) Commencing on the effective date ofthis greeme1)t, HUSBAND shall be solely responsible for all costs, expenses and lia ilities asspciated with or attributable to his interest in the above described parcels f real est~te, including but not limited to any mortgages, taxes, insurance premi maintenance and repairs. (iv) WIFE shall execute deeds transferring an and all itl1terest to and releasing any right, title, or claim she may have in the ab ve real e~tate set forth in paragraph 5(a)(i)-(v) above when presented to her by USBANp. (b) Business Interests: The parties acknowledge that HUSBM,m is an owner of all the shares of the following various business concerns: (i) Hall Development Corporation-one hund ed percedt (100%) of the , common stock; The parties agree that HUSBAND shall retain and receiv as his s61e and separate property any and all interest he has in and to the shares of the above list d corportte entities and WIFE hereby waives and releases any and all right, title, claim or intere t she mat have in and to I HUSBAND'S interest in the above listed corporate entities, including b t not lim*ed to, fixed assets and accounts receivable. (c) Furnishings and Personal Property: (i) Each of the parties recognize that each of hem at tHe date of their marriage separately owned certain furnishings and perso al propeIity. Each of the 5 parties recognize that the furnishings and personal prope owned by them prior to their marriage is non-marital property as that term is d fined in the Divorce Code and ownership of that property is controlled by the erms of the Ante- Nuptial Agreement. In light of the non-marital nature of uch prop1erty, effective the date of this Agreement, HUSBAND and WIFE each s ts over ~nd transfers to the other, all of their right, title, claim and interest in and 0 all of each other's non-marital furnishings and personal property, including ut not liI/nited to, furniture, furnishings, rugs, antiques, collectibles, househ Id appli~nces and I equipment, clothes,jewelry, coin collection, memorabili ,movie c~ls, cereal premiers collection, personalty, and other items of tangib e propero/ of whatever nature. , (ii) As of the effective date of this Agreement HUSBAND sets over, , transfers and assigns to WIFE all of his right, title, claim nd inter~st in and to I the furnishings of the marital residence identified on Exh bit "I." Any and all items not set forth in Exhibit "I" shall become solely the roperty of HUSBAND, (d) Motor Vehicles: (i) HUSBAND agrees that he shall pay WIF the NAqA loan value of the 1999 Ford Explorer equaling $8,350.00 and in exc ange H~SBAND shall retain possession of and receive as his sole and separate roperty a~ong with all I rights under any insurance policy thereon, free of any rig t, title, cjaim or interest ! of WIFE. HUSBAND shall pay the sum of$8,350.00 to IFE fo~ her interest in the vehicle. (ii) WIFE agrees that HUSBAND shall retain possessiqn of and I receive as his sole and separate property all other motor ehicles npt set forth in I subparagraph 3(d)(i) regardless of the name or names in hich the:vehicle are 6 titled along with all rights under any insurance policy the eon, free of any right, title, claim or interest of WIFE; (iii) HUSBAND and WIFE agree to execute, a knowledge and deliver, within thirty (30) days of WIFE'S request, any and all ins ruments \Jr documents necessary to effectuate the transfer of the vehicle pursuan to the tel:ms of this subparagraph. (iv) The parties agree to indemnity and hold e ch other .nd their property harmless from any liability, cost or expense, inc uding attbrney's fees, , incurred in connection with the vehicle awarded to them y the te~s of this subparagraph. (e) Pension/Retirement Funds: (i) The parties agree that HUSBAND shall b and rem~in the sole owner ofthe following IRA accounts: (a) Morgan Stanley Traditional IRA (b) Morgan Stanley Roth IRA Accoun ; (ii) The parties agree that WIFE shall be and r main the sole owner of the following IRA accounts: (a) Morgan Stanley Roth IRA Accoun . (f) Cash Accounts and Investments: (i) WIFE agrees that HUSBAND shall receiv ,as his sble and separate property, free from any right, title, claim or inte st of WIFE in HUSBAND'S investment in the following: (a) Morgan Stanley Stock Brokerage ccount; (b) Smith Barney Stock Brokerage Ac ount; (c) Fidelity Mutual Fund Account; 7 (d) PNC Bank: 1. Robert Hall Business Acco nt; ii. Robert Hall Savings Accou t; (e) Commerce Bank: 1. Robert Hall Account; ii. Hall Development Account (ii) HUSBAND agrees that WIFE shall receiv ,as her sble and I separate property free from any right, title, claim or inter st ofHU~mAND, , WIFE'S investment in the following: (a) (b) Morgan Stanley Brokerage Accou t. PNC Bank: 1. , Robert and Wendy Hall Ac ount. WIFE shall take , , all steps necessary to remo e HUSB~ND'S name from the account. i (g) Intended Tax Result and Indemnification: By thi Agreem~nt, the parties , have intended to effectuate and by this Agreement have identified their on-mari*l assets and have equitably divided their marital assets. The identification of non-m rital assets and the division of existing marital assets is not, except as otherwise may be ex ressly prq.vided herein, intended by the parties to constitute in any way a sale or exchange of as ets. As ~art of the , ! division of marital assets and the marital settlement herein contained, th parties ~gree to save and hold each other harmless from all income taxes assessed against the other res*lting from the division of the property as herein provided. (h) Life Insurance: (i) The parties agree that HUSBAND will ret in as his [sole and I separate property, free from any and all right, title, claim or interes[t of WIFE in the following life insurance policies reflecting the curren owner as the Robert 8 Hall Living Trust: (I) Prudential Financial, $1,000,000.0 term lifi: policy; and (2) Prudential Financial $500,000.00 Universal Life Poli . The parties minor children are the beneficiaries of the Robert Hall Living T st and the provisions of the aforesaid trust contains provisions that Trust assets are to be used to provide for the minor children's health, welfare and educ tion. (ii) HUSBAND shall obtain and pay for a sev n year level premium term life insurance policy with WIFE designated as an i vocable beneficiary until HUSBAND'S obligation to pay alimony ceases pur uant to t~is Agreement , with a minimum death benefit equal to the aggregate prin ipal amdunt of alimony , due to WIFE at the time of HUSBAND'S death, if anythi g, pursu~nt to Paragraph 6 of this Agreement HUSBAND shall provid to wrFI): a copy of the insurance policy or binder to WIFE upon his receipt oft same. $.USBAND shall provide the premium notices to WIFE as they are re eived fo1' the policies which are in effect WIFE shall have the option to either pay the premium and receive reimbursement from HUSBAND or have HUSB ND pay (he premium due. This clause is specifically provided to protect WIF 'S interesls under this Agreement In the event of a default of premiums of ins rance pollicies by HUSBAND of any amount due on account of any policy f insurance required to be maintained by virtue of this subparagraph, such paym nt may bb made by WIFE, who shall be reimbursed by HUSBAND for the II amounl of such payments, plus any interest, penalties and costs, incurred by WIFE; in securing repayment HUSBAND may reduce the amount of the d ath benefit from time to time as the principal of amount due to WIFE pursuant to aragrap~ 3 of this Agreement is reduced. (i) Miscellaneous Prooertv: All property not specifi ally addr~ssed herein shall be hereafter owned by the party to whom the property is titled; an if untitled, the party in 9 possessIOn. This Agreement shall constitute a sufficient bill of sale to e idence the transfer of any and all rights in such property from each to the other. G) Property to Wife: The parties agree that WIFE sh II own, I1ossess, and enjoy, free from any claim of HUSBAND, the property awarded to her the ternlS of this Agreement. HUSBAND hereby quitclaims, assigns and conveys to WI E all such property, together with any insurance policies covering that property, and any esc ow accounts relating to , that property, This Agreement shall constitute a sufficient bill of sale to evidencelthe transfer of I any and all rights in such property from HUSBAND to WIFE. (k) Propertv to Husband: The parties agree that HUS AND sHall own, possess, and enjoy, free from any claim of WIFE, the property awarded 0 her by the terms of I this Agreement. WIFE hereby quitclaims, assigns and conveys to HUS AND alii such property, together with any insurance policies covering that property, and any esc ow acc04nts relating to I that property. This Agreement shall constitute a sufficient bill of sale to evidence! the transfer of any and all rights in such property from WIFE to HUSBAND, (I) Assumption of Liabilities: (i) HUSBAND shall be solely responsible fo all debt ~e has incurred in his name alone, including, but not limited to, obligatio s to issu~rs of credit i cards in his name, and HUSBAND further agrees that he will inde1nnify and hold i WIFE and her property harmless from any liability, cost r expens~, including attorney's fees, associated with these obligations. HUSB ND shall also be I responsible for the debt associated with the vehicle bein assigned/to WIFE, I pursuant to this Agreement. HUSBAND shall make all ayments ~ue for the , assigned vehicle pursuant to the terms of the loan agree ent and/9r financing agreement signed by HUSBAND. HUSBAND shall als be solel~ responsible for the obligation owed to Sun Trust Consumer Loan. 10 (ii) HUSBAND shall be responsible for and p y for on behalf of WIFE a sum not to exceed $3,700.00 for WIFE'S obligation ow d on a VISA credit card issued to her by Bank of America, card number 4356-002 -0148-9'[06. Such payment to be made by HUSBAND by November 1, 200 . (iii) WIFE agrees that she shall be solely respo sible for: all debt she has incurred in her name alone, including, but not limited to, oblig~tions to issuers , of credit cards in her name and WIFE further agrees that he will i~demnifY and , hold HUSBAND and his property harmless from any lia ility, cos~ or expense, including attorney's fees, associated with these obligatio s. , ! (iv) Unless otherwise provided herein, each p y herebt assumes the I debts, encumbrances, taxes (past and future) and liens on all the prpperty each i will hold subsequent to the date of this Agreement, and e ch party lagrees to , indemnifY and hold harmless the other party and his or h r property from any claim or liability, cost or expense, including actual attorn y's fees, !that the other party will suffer or may be required to pay because of su h debts, ~ncumbrances i i ! D shalllpay for i furniture to be placed in the two (2) minor children's bedrooms in WIF 's new hbme provided, however, the cost of such bedroom suites shall not exceed $6,000.00. eceipts rJf1ecting the monies spent by WIFE for each bedroom suite shall be given by WIFE 0 HUSB1ND who shall , i or liens. (m) Purchase of Children's Bedroom Suites. HUSB reimburse WIFE for the expenditure within ten (10) days of the receipt hereof i (n) Liabilitv Not Listed: Each party represents and arrants tq the other that ! he or she has not incurred any debt, obligation or other liability, other t an those ~iescribed in I this Agreement, on which the other party is or may be liable. A liabilit not disclbsed in this I Agreement will be the sole responsibility of the party who has incurred r may hereafter incur it, , and each party agrees to pay it as the same shall become due, and to ind mnifY and hold the , I 11 other party and his or her property harmless from any and all such debts, obligations and liabilities. (0) Indemnification of Wife: If any claim, action or oceedinS: is hereafter initiated seeking to hold WIFE liable for the marital and business debts r obligations assumed by HUSBAND under this Agreement as a result of his default in the pay ent oftli1e said marital or business debts, HUSBAND shall, at his sole expense, defend WIFE a ainst any such claim, I action or proceeding, whether or not well-founded, and indemnify her a d her property against any damages or loss resulting therefrom, including, but not limited to, c sts of coJrt and actual i , attorney's fees incurred by WIFE in connection therewith, (P) Indemnification of Husband: If any claim, action or procedding is hereafter initiated seeking to hold HUSBAND liable for the debts or obI gations a~sumed by , WIFE under this Agreement, WIFE shall, at her sole expense, defend H SBANQ against any , such claim, action or proceeding, whether or not well-founded, and inde ify hiJ and his ! property against any damages or loss resulting therefrom, including, but not limit,d to, costs of court and actual attorney's fees incurred by HUSBAND in connection t rewith. I (q) Warrantv as to Future Obligations: HUSBAND d WIFE shall take all steps necessary to assure that no credit cards or similar accounts or obli ations ex' st which I provide for joint liability. Prom the date of execution of this Agreemen each pao/Y shall use only those credit cards and accounts for which that party is individually iable an1 the parties agree to cooperate in closing any and all accounts on which joint liabilit may be lincurred, , HUSBAND and WIFE each represents and warrants to the other that he or she Wi~1 not at any time in the future incur or contract any debt, charge or liability for whic the other. the other's legal representatives, property or estate may be responsible. Each party hereby a~rees to indemnify, save and hold the other and his or her property harmless fro any liablility, loss, cost I , or expense whatsoever, including attorney's fees, incurred in the event 0 breach ijereof. 12 4, USE OF #2 100 STREET STONE HARBOR BEACH OUSE: HUSBAND shall allow WIFE, in his discretion, which shall not be unreasonably wi eld, to use the improved real property known and numbered as #2 100 Street, Stone H rbor, New Jersey, but only when it is otherwise unoccupied by himself, renters, or other third arties. llhis privilege shall terminate either August 31, 20 I 0, or until HUSBAND sells or tran fers the real estate to a third party, whichever event first occurs, provided, however, such use s all be lirnlited to WIFE and the minor children, WIFE shall be liable to HUSBAND for any da caused by herself. 5, CUSTODY OF MINOR CHILDREN: HUSBAND and IFE agrbe that , HUSBAND and WIFE shall have shared legal and physical custody oft e partiesl minor children, "Legal custody" as used herein shall mean the legal right to ke majot decisions , affecting the best interest of a minor child, including major medical, reli ious an~ educational , decisions; educational decisions shall be defined as those decisions dire t1y relate~ to or affecting the academic performance of a minor child in the classroom. , HUSBAND and WIFE shall have equally shared physical custo y of said minor children, i "Physical custody" as used herein shall mean actual physical possession and conttol of a child, HUSBAND and WIFE shall have the following rights of custody with s id minor!children at the other's dwelling on an alternating week to week basis from Sunday to t e follow1ng Sunday together with the following periods of physical custody which are to be njoyed ahd exercised by HUSBAND and WIFE: ( a) Summer Vacation: HUSBAND and WIFE shall ach have!a continuous , period of time each year during the summer vacation of the children, sai length 9ftime to be determined by HUSBAND and WIFE with the children having input an their wi$hes being , given consideration as to dates of the vacation. Provided however, that f any of tbe times of , summer visitation exceed two (2) continuous weeks, the a out of cu tod shal be afforded a period of partial custody of two (2) davs. HUSBAND and WIFE shall ovide W~FE and 13 HUSBAND with at least sixty (60) days prior written notice of the peri d he will so exercise his summer vacation period of custody. The total vacation period shall not exceed four weeks unless otherwise requested by the children, (b) Holidays: The parties shall alternate custody of t e minor ,children on the following holidays, with Mother having the first of such days - New Ye r's Day, President's Day, Easter, Memorial Day, July Fourth, Labor Day, and Veteran's Day, Th parties shall share custody on Thanksgiving as they may from time to time agree upon. F ther shall! have the children on Father's Day and Mother shall have the children on Mother' Day, In! the event the parties have rights of physical custody of the minor children on a week nd and t* party also has rights of physical custody on a holiday which falls on a Monday after t e weekeQd, his or her period of physical custody shall extend over to the holiday and end at 900 p.m. ; (c) Christmas: In odd-numbered years, from 9:00 a, ,from dIsmissal from I school until 12:00 p,m, noon on Christmas Day, In even-numbered yea s, from 1!2:00 p,m, noon on Christmas Day until 6:00 p,m, on December 28th, or as the parties ay othervhse mutually I agree as long as HUSBAND and WIFE are provided with at least fifty ercent (5b%) of the , children's holiday vacation. (d) Other: Such other times as the parties may herei after agr~e. , (e) Transoortation: In all cases HUSBAND and WI E shall b~ responsible for the pickup of the minor children at their place of domicile and HUS AND anp WIFE shall be responsible for the redelivery of the children to the children's place domicil~ at the end of each party's period of custody. (f) Harassment or Interference: The parties further gree that they will not , utilize the right of custody or visitation in order to harass or interfere w' h the ot~r's right to live I and remain separate and apart from each other, In the event that either arty uti likes custody or visitation rights to harass or interfere as hereinabove described, the part es expreSsly agree that, in addition to all other legal and equitable remedies available to them, t ey may make immediate 14 application with a court of appropriate jurisdiction to pursue appropriate 'udicial remedies for said harassment or said interference. (g) Entrv of Court Order: HUSBAND and WIFE agr e to the entry of a Court Order of Custody in accordance with the terms and provisions of this A eement Uy a court of competent jurisdiction. (h) Other Custody Rights: In addition to any provisi s which :may be y shall h~ve the contained herein regarding custody rights set forth hereinabove, each pa I following rights with respect to the children: reasonable telephone callin privileg~s until 9:00 i p.m, on school nights and 9:30 p.m. on non-school nights, provided that ach partt may exercise I his or her telephone calling privileges a maximum oftwo (2) nights per eek, proyiding nothing herein is to be construed to limit the children from calling either parent they de~ire; access to I report cards and other relevant information concerning the progress of t childre~ in school; ! approval of extraordinary medical and/or dental treatment except in the ase of an I emergency ! and provided that such approval shall not be unreasonably withheld. Ea h ofthe ~arties agree to provide the other with their address and telephone numbers, and to advis of any ~hange thereof within ten (10) days. HUSBAND and WIFE agree that either one of the will hate the right to refuse a child's request to have any body part pierced or tattooed. (i) Illness of Child: In the event of any serious ilInes children at any time, the party then having physical custody of the said c of eithe~ of the I ild shalllimmediately I communicate with the other party by telephone or any other means, info ing the lother party of I the nature of the illness. During such illness, each party shall have the ri ht to visIt the child as ! often as he or she desires, consistent with the proper medical care of the hild. 15 6. CHILD SUPPORT INCOME TAX DEPENDENCY EX MPTION FOR MINOR CHILDREN AND MEDICAL INSURANCE: (a) HUSBAND shall enter into an Agreement of Sale for the purchase of a parcel of improved real estate acceptable to WIFE for a purchase price n t to exceed Two Hundred Thousand and 00/100 Dollars ($200,000.00). HUSBAND shat obtain adequate financing for the acquisition of the aforesaid property. HUSBAND shal transfer jjtle to the aforesaid property to WIFE at the closing of the property. HUSBAND s all have Ino further claim to the property, This Agreement assumes the real property to be a quired i~ the property known and numbered as Round Top Road, Mechanicsburg, Pennsylvani . If the ~foresaid property is acquired, HUSBAND shall pay for and have installed in the roperty: r powder room on the first floor consisting of a toilet, sink and shower; completion of op ceiling and drywall installation on the first floor; a utility sink on the first floor; constructio of a closet; "screen-in" I an existing porch and install a base cabinet and extend the kitchen count r, the co~t of said renovations not to exceed $7,500. Additionally, HUSBAND shall provi e to WI~E a washer, I dryer and lawn mower. HUSBAND shall also pay for all reasonable co ts to mov~ WIFE'S i personalty from the current marital residence to the Round Top Road, echanics~urg, Pennsylvania property. The purpose of this paragraph is to provide the WIFE an minor c~ildren a property in which to reside that otherwise is not provided for in this Agr ement o~ contemplated I under the Antenuptial Agreement and the fair rental value of such housi g is cont~mplated as part of HUSBAND'S child support obligation and in lieu of payment of monthlr support payment. i (b) HUSBAND shall be entitled to claim R. Jarek Ha I and Skyler E. Hall as I dependency exemptions for Federal, State and Local Income Tax purpo es for 20@5 and all , I future years. HUSBAND and WIFE shall alternate the right to claim C esse S.B.I Hall as a , I dependency exemption for Federal, State and Local income tax purpose for 20051 and all future 16 years with WIFE having the right to claim Chesse S.B. Hall as an exem ion in 2005 and HUSBAND having the right to claim Chesse S.B. Hall as an exemption n 2006, and alternate thereafter, provided, however, HUSBAND shall have the right to claim hesse SJ3. Hall for all tax years when he is not eligible to claim R. Jarek Hall and/or Skylar Ha I as dependence exemptions on Federal, State or Local income tax returns. WIFE and H SBAND hereby agree to execute any forms or acknowledgment required by the tax authority t provide HUSBAND I and/or WIFE with said dependency exemptions for R. Jarek Hall, Skyle E Hall, ~nd Chesse S,B, Hall, (c) HUSBAND agrees to continue to provide such he Ith insur~nce for the I three (3) minor children as is currently provided to HUSBAND. WIFE grees to provide such , health insurance for the children which may be available to her through ny futur~ employer as ! long as there is no cost to her. The requirement of HUSBAND and WI E to mai~tain adequate health insurance as provided in this Agreement continues until the child en reach ~he age of I eighteen (18) or; ifin college, so long as eligible. HUSBAND and WIF further ~gree to split i and equally pay any medical, dental and eye expenses for the children hich are 40t covered by , msurance coverage. I (d) (i) In the event WIFE files a Petition for Chil SUPP01 and the parties continue to exercise physical custody in accordance with this Agreeme ,the pa~ies agree the , Office of Domestic Relations shall first calculate the amount owed by t e respectlve parties I based upon their net incomes including a reduction of HUSBAND'S in orne for ~limony paid to WIFE and including the alimony paid in WIFE'S income, Anyamount wed by fUSBAND to WIFE shall be reduced by the fair rental value of the property referred t in para~aph 6(a) and any support greater than the fair rental value of the property shall be pai by HU$BAND, I provided, however, HUSBAND shall be entitled to adjust the alimony e to WI~'E provided in i paragraph 7 of this Agreement by the same amount of the child support USBA11lD is required to pay to WIFE In the event the monthly child support awarded to WI E is great.er than the 17 monthly alimony owed to WIFE, HUSBAND shall have the right to offs t the difference prospectively against any future amounts of alimony due to WIFE. By ay of illustration, if the monthly amount of child support equaled the sum of $1 ,500.00 per mon ,HUSBJ\ND would have the right to reduce the monthly payment by not only $1,000.00 but Iso the right to reduce the next future alimony payment by $500.00, thus reducing his overall a imony olJligation prospectively. (ii) In the event WIFE files a Petition for Chi! Support!and a change , in the custody arrangement of the minor children has occurred (i.e., WI E has primary custody of some or all of the minor children) the parties agree the Office of Do stic Rel~tions shall first , calculate the amount owed by the respective parties based upon their ne income ibcluding a I reduction of HUSBAND'S income for alimony paid to WIFE and inclu ing the ajimony paid in , WIFE'S income. Any amount owed by HUSBAND to WIFE shall be r duced bylthe fair rental I value ofthe property referred to in paragraph 6( a) and any support great r than th~ fair rental , value ofthe property shall be paid by HUSBAND provided, however, USBAN~ shall be entitled to adiust alimony due to WIFE as set forth in paragraph 70fthi Agreemfnt in accordance with the following formula: (1) calculate the support owed y HUSBtND to WIFE due to a change in the custodial arrangement; (2) calculate the support t at wouldl have been owed by HUSBAND to WIFE if the joint shared physical custody as en isioned ~y the Agreement; (3) calculate the difference between the first two calculatio s; (4) cal~ulate the then I fair rental value of the property referred to in paragraph 6(a); (5) apply e then ftir rental value to the support owed in step (I) above as a credit; any amount left due a owing tfter the completion of step (5) shall be paid by HUSBAND to WIFE as child su port, prolvided, however, HUSBAND shall be reimbursed by WIFE for each dollar HU BAND ~ays to WIFE in an amount equal to the difference between the then fair rental value of t e prope~y and the I amount HUSBAND would have paid to WIFE if custody of the minor c ildren h~d not been I modified as calculated by step (2) above. By way of illustration, if a ch nge in t~e custody 18 arrangement of the minor children were to occur and at the time of the c ange the fair rental value of the property equaled $1,000.00, the calculation of child support based upon the change of custody equaled $1,500.00 and the calculation of child support based pon shared physical custody as provided by this Agreement equaled $1,200.00 then in that e ent the calculation would be as follows; $],500.00 - $1,000.00 = $500,00 which HUSBAN would pay to WIFE for child support and HUSBAND would have a right to receive as reimb rsementas a credit , against alimony the sum of$200.00 and would have the right to adiust t e monthljy alimony payment of$],OOO,OO by $200,00 leaving a payment of$800.00. (iii) In the event HUSBAND files a petition fo child suwport and a change in the custody arrangement of the minor children has occurred (i e" husbaUd has primary custody of some or all of the minor children) the parties agree the Offic of Domelstic Relations shall lirst calculate the amount owed by the respective parties based upo their nel incomes including a reduction of HUSBAND'S income for alimony paid to WIF and including the alimony paid in WIFE'S income. Additionally, the Office of Domestic elationsishall include as income to WIFE the then fair rental value ofthe property referred to' paragraph 6(a) ofthis Agreement. The Office of Domestic Relations shall then calculate the r spective ~upport due and owing by each of the parties. (iv) The fair rental value of property credit pr vided fori in this I paragraph 6(d)(i), (ii), and (iii) shall survive even if the property acquir d for WIIFE in paragraph 6(a) is no longer owned or solely owned by WIFE. , 7. ALIMONY: HUSBAND shall pay to WIFE the sum of ne Thousand and 00/100 I Dollars ($],000.00) per month as alimony, commencing on the first mo th follovvling the effective date of this Agreement and terminating on June 1,2010, with e last pa~ment to be , made on June 30, 2010, with no modification of amount or duration, ex ept as sei forth herein or as set forth in the provisions of paragraph 6(d)(i)-(iv). HUSBAND'S 0 ligation 110 pay alimony 19 provided in this paragraph shall terminate, however, upon WIFE'S rem 'age; WIFE'S cohabitation with either a person of the opposite sex or same sex who is ot a member of WIFE'S family within the degrees of consanguinity; WIFE'S death; or USBAND'S death. 8. 2004 FEDERAL INCOME TAX RETURN: HUSBAND nd WIn shall file a joint 2004 Federal Income Tax Return claiming "Married Filing Jointly' status, A.ny refund shall be divided equally by the parties. I I 9. COUNSEL FEES: HUSBAND and WIFE shall each be oldy responsible for I their respective counsel fees, costs and expenses which each of the parti s may infur in connection with the negotiation and execution of this Agreement and th dissolutipn of their mamage, 10. WIFE'S HEALTH INSURANCE: HUSBAND shall pay or COB~ benefits for I WIFE if needed for a period of thirty-six (36) months from the date ofa entry o~a Decree of Divorce. WIFE agrees she shall attempt to secure employment which p ovides f~r health I insurance benefits. In the event WIFE secures employment with health enefits, l-IUSBAND I shall have the following rights: (I) if such health insurance coverage is t no cost Ito WIFE and is I comparable to the coverage supplied by HUSBAND under COBRA, he hall hav~ the right to i require WIFE to accept the health insurance benefits and to terminate IFE'S Cq>BRA benefits; I (2) if such health insurance coverage is paid for by WIFE and is compa ble to thb coverage I supplied by HUSBAND under COBRA, he shall have the right to requi e WIFE tp accept the , benefits; terminate WIFE'S COBRA benefits and reimburse WIFE the ost ofthd benefits until the end of the thirty-six (36) month period he was liable to pay for WIF 'S COB~ benefits pursuant to this Agreement HUSBAND shall retain similar rights as s forth abbve if WIFE 20 remarries and is afforded health insurance benefits through her spouse's mployer's health insurance benefit plan or through the new spouse's health insurance pIa . 11. WAIVER OF BENEFICIARY DESIGNATIONS. Unles otherw* specifically set forth in this Agreement, each party hereto specifically waives any an all benelficiary rights in and to any asset, benefit or like program carrying a beneficiary designati n which;belongs to the other party under the terms of this Agreement, including, but not limited to, pensj~ms and I retirement plans of any sort or nature, deferred compensation plans, life nsuranceipolicies, I annuities, stock accounts, bank accounts, final paychecks or any other p ,t-death ~istribution I scheme, and each party expressly states that it is his and her intention to 10voke bt the terms of , this Agreement any beneficiary designations naming the other which ar . n cffect Jas of the date of execution of this Agreement If and in the event the other party conti lues to bf names as a beneficiary and no alternate beneficiary is otherwise designated, the ben 'ficiary s~all be deemed I to be the estate of the deceased party. Notwithstanding the foregoing, h )wcver, in the event that either party hereto specifically designates the other party as a beneficiar of any a/sset after the date of execution of this Agreement, then this waiver provision shall no bar that warty from qualifying as such beneficiary. 12. RELEASE OF CLAIMS: (a) HUSBAND and WIFE acknowledge and agree t t the property I eir asset~ and liabilities , dispositions provided for herein constitute an equitable distribution oft pursuant to Section 3502 of the Divorce Code and HUSBAND and WI E hereby/waive any right to division of their property except as otherwise provided for in this Ag eement Furthermore, , except as otherwise provided for in this Agreement, each of the parties ereby sp~cifically I waives, releases, renounces and forever abandons any claim, right, title r interesJ; whatsoever he or she may have in or to property transferred to the other party pursuant to this A~reement or 21 identified in this Agreement as belonging to the other party, and each pa y agrees never to assert any claim to said property or proceeds in the future, However, neither p rty is rekased or discharged from any obligation under this Agreement or any instrument r document executed pursuant to this Agreement HUSBAND and WIFE shall hereafter own nd enjoY' independently of any claim or right of the other, acquired by him or her from the date 0 execution of this Agreement with full power in him or her to dispose of the same fully an effectiv~:ly for all purpose. (b) Each party hereby absolutely and unconditionally releases 4nd forever i discharges the other and the estate ofthe other for all purposes from any and all ri~hts and obligations which either party may have or at any time hereafter has for ast, pres~nt or future support or maintenance, alimony pendente lite, alimony, equitable distri ution, c9unsel fees, costs, expenses and any other right or obligation, economic or otherwise whetherlarising out of ! the marital relationship or otherwise, including all rights and benefits un er the Nnnsylvania I , Divorce Code of 1980 its supplements and amendments, as well as any ther law pf any other jurisdiction, except and only except all rights and obligations arising un the breach of any of its provisions. (c) Except as otherwise provided herein, each party unconditionally releases and forever discharges the other and his or her i er this A~reement or for ! i I reby ab~olutely and eirs, exe~utors, administrators, assigns, property and estate from any and all rights, clai s, demar}ds or obligations arising out of or by virtue of the marital relationship of the p rties wh~ther now I existing or hereafter arising. The above release shall be effective regar ess of w~ether such , I claims arise out of any former or future acts, contracts, engagements or iabilities Iof the other or by way of dower, curtesy, widow's or widower's rights, family exempti or simi1ar allowance, I or under the intestate laws or the right to take against the spouse's will, r the rig* to treat a lifetime conveyance by the other as testamentary or all other rights of a urviving:spouse to 22 participate in a deceased spouse's estate, whether arising under the laws f Pennsylvania, any state, commonwealth or territory of the United States, or any other count . 13. PRESERVATION OF RECORDS: Each party will keep and preserve for a period of four (4) years from the date of divorce all financial records reI ting to thi~ marital estate, and each party will allow the other party access to those records i the eve* of tax audit. 14. MODIFICATION: No modification, rescission, or amen ment to lhis Agreement ! shall be effective unless in writing signed by each of the parties hereto, I I I , 15, SEVERABILITY: If any provisions of this Agreement i held by . court of competent jurisdiction to be void, invalid or unenforceable, the remaini g provisi~ns hereof shall I nevertheless survive and continue in full force effect without being imp ired or in]validated in I any way. i 17 . WAIVER OF BREACH: The waiver by one party of an breach <if this Agreement by the other party will not be deemed a waiver of any other reach or lany provision of this Agreement. 23 18, NOTICE: Any notice to be given under this Agreement either party to the other shall be in writing and may be effective by registered or certified ail, return receipt requested. Notice to WIFE, will be sufficient if made or addressed to th following: Wendy L Hall 3A Round Top Road Mechanicsburg, P A 17055 and to HUSBAND, ifmade or addressed to the following: Robert E. Hall 2841 North Front Street Harrisburg, PA 17110 I Each party may change the address for notice to him or her by giving no ice ofth~t change in I accordance with the provisions of this paragraph. 19. APPLICABLE LAW: All acts contemplated by this Agr ement s~ll be I construed and enforced under the laws of the Commonwealth of Pennsy vania in ~ffect as of the date of execution of this Agreement 20. AGREEMENT BINDING OR PARTIES AND HEIRS: his Agr~ement, except as otherwise expressly provided herein, shall bind the parties hereto and their res~ective heirs, executors, administrators, legal representatives, assigns, and successors n any int~rest of the parties. , I 21. ENTIRE AGREEMENT: Each party acknowledges that e or she/has carefully I read this Agreement, including all other documents to which it refers; th t he or slle has had the I opportunity to discuss its provisions with an attorney of his or her own hoice, an~ has executed I it voluntarily; and that this instrument expresses the entire agreement be ween th~ parties 24 concerning the subjects it purports to cover. This Agreement should be i terpreted fairly and simply, and not strictly for or against either of the parties. 22, PRIOR AGREEMENTS: The parties specifically agree t at this Agreement shall supersede and any and all prior agreements between the parties with the xception of the Ante- Nuptial Agreement executed on April 26, 1983, the terms of which shall survive t11is Agreement I except where specifically modified by the terms of this Agreement. I 23, INCORPORATION OF DOCUMENTS: All documents i nd otherl instruments I pletely ,S if they were I I i referred to in this Agreement are incorporated into this Agreement as co copied verbatim in the body of it. i i i i 24. MUTUAL COOPERATION: Each party shall on deman execute) and deliver to the other any deeds, bills of sale, assignments, consents to change of be eficiarie~ of insurance i policies or other benefits or assets, tax returns, and other documents, an shall do lor cause to be i done every other act or thing that may be necessary or desirable to effec ate the ~rovisions and i purposes of this Agreement. If either party unreasonably fails on dema d to comWly with these I provisions, that party shall pay to the other party all attorney's fees, cost , and othFr expenses ! actually incurred as a result of such failure, i , I I 25, DATE OF EXECUTION: The "date of execution" or "e ecution qate" of this I Agreement shall be defined as the date upon which it is executed by the parties iflthey each have ! executed the Agreement on the same date. Otherwise, the "date of exec tion" or I'execution i date" of this Agreement shall be defined as the date of execution by the arty lastlexecuting this I Agreement. 25 26. EFFECTIVE DA IE: This Agreement is effective and bi ing upon both parties as of November I, 2004. , 27. AGREEMENT NOT TO BE MERGED: This Agreemen and the A~nte-Nuptial Agreement executed by the parties on April 26, 1983, shall not be merge into the!parties' divorce decree. The parties shall have the right to enforce this Agreeme t under die Divorce Code of 1980, as amended, and in addition, shall retain any remedies in aw or in fquity under this Agreement as an independent contract Such remedies in law or eq ity speci1cally are not I I I waived or released. 28. EFFECT OF RECONCILIATION OR RECONCILIA TI N A TT MPT: This Agreement shall remain in full force and effect and shall not be abrogat even if he parties effect a reconciliation, cohabit as husband and wife or attempt to effect reconcil ation, This Agreement shall continue in full force and effect and there shall be no any of the tenns hereof unless the parties in writing execute a statement eclaring this Agreement or any tenn ofthis Agreement to be null and void. I 29. HEADINGS NOT PART OF AGREEMENT: Any head ngs prec~ding the text of the several paragraphs and subparagraphs hereof are inserted solely for onveniejce of reference and shall not constitute a part of this Agreement nor shall they affect its eaning, construction or I I I I COUNTERPARTS: This Agreement may be executed i count~~arts, each of which will be an original and which together shall constitute one and th same m~trument. I I effect 30. 26 IN WITNESS WHEREOF, the parties hereto have set their hand and seals on the dates of their acknowledgements. WITNEr': I ~ ') .~.m/J2f1~~ 'di~/> / /; t ,// !/l~1 1;1/J;>Iy;/;tl, Y Zti}(; ,j F:IJIOME\CAZ\G-N-1ALLROBISETI026,WPD 27 COMMONWEALTH OF PENNSYLVANIA COUNTY OF D~~{ph'n On this, the J!!!!day of ~ 2004, before me, a Notary ublic, th~: undersigned officer, personally appeared ROBERT E. HALL known to me (or satisfa torily p~JVen) to be the person whose name is subscribed to the foregoing Marital Settlement A reement alnd acknowledged that he executed the same for the purposes therein contai ed. ss IN WITNESS WHEREOF, I hereunto set my hand and official s at NSYL VANIA COMMONWEALTH OF PENNSYLVANIA COUNTYOF (jUU.()(i1r\ On this, the a:r~y of (}u,0-e( 2004, before me, a Notary ublic, t~'e undersigned officer, personally appeared WENDY L HALL known to me (or satisfi torily pr ven) to be the person whose name is subscribed to the foregoing Marital Settlement A reement nd acknowledged that she executed the same for the purposes therein cont ned. i I i , ss IN WITNESS WHEREOF, I hereunto set my hand and official s at COMMONWEALTH OF PENN YLVANIA Notarial Seal Christine A. Zaring, Notary ublic CIty or Harrisburg, Dauphin nty My Commission Expires Mar. 5, 2008 Member. Pennsylvania Associatio Of Notaries 28 EXHIBIT "1" (Property to Wife) L All of the furniture located in the dining room, including e carpet land chandelier situated at 2880 Ford Farm Road, Mechanicsburg, PA wi the exc~)ption of the wood serving cart and crystal decanter stored on the servi g cart, I 2. All ofthe china and crystal together with gold and silver atware sJored in the dining room with the exception of crystal decanters store on the ~ood serving cart located 2880 Ford Farm Road, Mechanicsburg, PA. : 3. All of the furniture located in the living room including t e mirror all hanging situated at 2880 Ford Farm Road, Mechanicsburg, PA wi h the exc ption of the Venetian red glassware and wine decanter; the statues dis layed in the display cabinet, and the other art and pictures hanging on the wal s, 4. Porch and/or lawn furniture 5. Vase from Arizona 6. Electronic Eauipment: A. Large screen television situated at 2841 North Fr nt Street, Harrisburg, Pennsylvania, provided, however, WIFE's posses ion ofte evision and HUSBAND'S obligation to transfer the televisio to WIFE shall not occur until HUSBAND sells the real property situated a 2841 N rth Front Street, Harrisburg, Pennsylvania; B. Computer located in the library situated at 2880 Mechanicsburg, Pennsylvania; i ord Farml Road, I oad, MeFhanicsburg, I I I I i I I i C. Grey vacuum cleaner located at 2880 Ford Farm Pennsylvania. CERTIFICATE OF SERVICE I do hereby state that on the 8th day of April 2005, I served a tru and com:ct copy of the foregoing in the captioned matter, by placing the same in the United Stat s mail, ~rst-c]ass, postage prepaid, in Harrisburg, Pennsylvania, addressed to: John 1. Connelly, Jr., Esquire James Smith Dietterick & Connelly 134 Sipe Avenue Hummelstown, PA 17036 ^ Angela L Hewitt Legal Secretary (:-'" c-' , 1 .",:- :.1 .-"" --- 9" #.....\ -<1 c ':.q -, ., .-'.',. -' ..,~"\ ..>"--) \;'i1 -- ~ ').'~ ~ {''''1 0' , ;' ROBERT E. HALL, Plaintiff IN THE COURT OF OMMON PLEAS CUMBERLAND CO TY, PENNSYL VANIA v. NO. 05-1120 WENDY L. HALL, Defendant CIVIL ACTION - AC ION IN DIVORCE PRAECIPE TO TRANSMIT REC RD TO THE PROTHONOTARY: I j I I ation, t1 the Court for I Transmit the record, together with the following info entry of a Divorce Decree: L Ground for divorce: irretrievable breakdown unde 3301(<-) or 3301(d)(I) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: De Com laint on March 7 2005 b service on her Counsel Jo as evidenced b the Proof of Service filed to the within num er. 3. (Complete either Paragraph (a) or (b)). I (a) Date of execution of the Affidavit of Consent req ired by J3301(C) of the Divorce Code: by Plaintiff: N/A; Defendant: N/A. I (b)(1) Date of execution of the Affidavit required by 93301 (d)1 of the Divorce Code: January 3 L 2005. I i (2) Date ofming and service of the Plaintiffs Affi avit upo the respondent: Affidavit filed March 7 2005' the Affidavit was served on t e Defend nt b service u on her Counsel John J. Connell Jr. Es uire. A Counter Affi vit exec ted b Defendant on March 30 2005 refIectin no 0 osition to the ent of a ivorce d cree and no claims for economic relief and was filed with the Prothonota on ril 8 20 5. 4. Related claims pending: All economic and e uita Ie istri ution claims were addressed and have been settled. I I I I I I (a) Date and manner of service of the Notice ofInte tion to FlIe Praecipe to Transmit Record, a copy of which is attached: N/A : I I . (b) Date Plaintiffs Waiver of Notice in (i330I(c) Di orce was filed wIth the I Prothonotary: April 8. 2005 I I I I I I I I 5. (Complete either Paragraph (a) or (b)). , ,i Date Defendant's Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: April 8. 2005 Date: ~- -j- I in ham, Esquire I I Street i P. O. Box 60457 I Harrisburg, PA I 106-045p (Attorneys for PI . ntiff) I I I I I I I I I i I I I I I I I I I I I I I I I I I F:IHOMEICAZIG-IIHALLROBIDIYORCEIPRACTRAN.WPD 2 c:::- .- C) C. ~ C:~} en .......~ ;:.0 ;r-. ."," c:) 'TI -1 :1: -1, I'ilr=.. -r11:r1 :.lili} :~~~i~ :~}f~ .J :-::.;:! I......) --: .J ., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + + . + . + + + + + + + + + + . + + + + + + + + . + . + . + + + + + . + . + . + . . + + + + + + + . + + + . . + + . . ;+:+>+''i' +u + :+: >+' O+'+: + ~'+::+::+: +. '+:+++.:+::+: '+: ~:+:+~++ :+:+~ +~~+;+++:+:+;+++.+.++ +++ ++++.+++. + . . + + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY . + PENNA. . STATE OF JENNIFER GOSSERT, PLAINTIFF No. 03-6348 VERSUS ARTHUR GOSSERT, DEFENDANT DECREE IN DIVORCE AND NOW, A~ Z.so.( IT IS ORDERED AND I S- DECREED THAT JENNIFER GOSSERT , PLAINTIFF, AND ARTHUR GOSSERT , 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; NONE. By THE COURT: ATTEST: J. + + + + + + + PROTHONOTARY + + + . +++++;+ +'+;++++'i''i'+++~? ++ ++ ++ ++++'1'+'1';++;++;+;+:++:++ ++ 'to;+ :f'++'+'++ ;+:;+:+'+'++;+:+'+'i'+ + +. ++. + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + J~/ .~ /"iT-P'-J/ 7 -/ /;' "OI7?-'7.'?/ /r';-/} . r-,-..-ry' r~_ . ?lP;;; ~. /' _~-v~L--') ./),,,"j /";./ ;:;;/ // ./7 ..11) b j/r