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Home My WebLink About04-0391IN THE "COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff ?y :No. Civil Term v. :INDIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOUHAVEBEEN SUED INCOURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, 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 Z Liberty Avenue Carlisle, PA 17013 (717);49-3166 {? (1 co RCi I t C u IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA VS. e? en R Brown Defendant No. 04- CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is 0 ? C C i Ct 13-,r who currently resides at Cumberland County, Pennsylvania. 2. Defendant is `T\r .le n ?- OW'n who currently resides at uqo curt e.S?rc? QA o.," O a o.l 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on rAQ ?,j 3 a oo CD at ?0(-C)<, I- ^)f one C'V)arch oc C"r rC: )cu-)-thcf5?ov ; 5. The marriage is irretrievably broken, and the parties separated on 0C\o ( \u ) 30(33 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. W cc ca Date Plaintiff, Pro Se 1, -? + ? GC Cl, -(?') C °l,vr) , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unworn falsification to authorities as provided in 18 Pa. C.S. §4904. y (-A-k" j a- B-c ? t- Date. Plaintiff, Pro Se Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 C7 c 0 o o r n im H ?? Y 'ta `q 1 t (t, l( 13'-01',3q Plaintiff V. ?LiltjA R.5r0u7?\ Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 (f- 3 21 a-t ? CIVIL ACTION - LAW IN DIVORCE PETITION TO PROCEED IN FORMA PAUPERIS The Petitioner, i1\? CC awl J (1 is the Plaintiff in this action. On the petitioner's behalf, MidPenn Legal Services does hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn Legal Services is assisting the Petitioner in filing a divorce case pro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests leave to proceed without payment of fees or costs. Jennifer Hoffman Pamela G. Smith Attorneys for Plaintiff MidPenn Legal Services Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 !t `o'c' Fi_ cc Iq IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. CIVIL TERM Defendant AFFIDAVIT IN SUPPORT OF PETITION TO PROCEED IN FORMA PAUPERIS 1. I am the ?\Q i 0 N 1 'C (= in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: ?-? \ C cA O, \? ? CW n (b) Address: \-4 1P) l'C ? UC ? ?-U ??bC1 (c) Social Security Number: I C601- U C& - D ? (?) LI If you are presently employed, state Employer: 1 -\0A C CLr \ v ? \ \a y' Address: c' nC-k rn? e C S A ? (- Salary or wages per month: Type of work: l .?" C\ i N c- e S S If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: +S • ° Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: -Vbb A `ivcx ro. ?p Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: (e) Property owned Cash: Checking Account: ? J Savings Account: Certificates of Deposit: Real Estate (including home): e4? a n Yea\ 1 Motor vehicle: MakeTb? A Cr Cost Amount owed 1UTI _ O Stocks; bonds: Other: (f) Debts and obligations Mortgage: ? Rent: y75o M O Loans: Monthly Expenses: c c?? C l'?.J? \ 2\ C- C r f L (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: (?(?np 00 t)Y1 n ( Age: rj 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances, which would permit me to pay the costs incurred herein. 5. 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. 4904, relating to unsworn falsification to authorities. Date: n1 <,o u o i? 41 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA \?lcc R_ ?c-bw ? Plaintiff Vs File No. IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one Uy marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of al c t (j 1_?tnc and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: Signature ?? - ?C 1M it?G G'1 Signature of name being resumed COMMONWE TH F P NNSYLVANIA ) COUNTY OF ) On the 1 ?'9 rn day of 200_, before me, the Prothonotary or the notary public, personally appeared the ove affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. I? NOTARIAL SEAL JCiDY S SMITH, NOTARY PUBLIC y Carl,sle B ic, Cumberland County Nar7 Public t?1v Cnmm?s;fon cxpfres April 4, 2005; oq a C7 } N . rl o, to W N n .-i T .? C?Z -nay C7 ? z? U? i1 t Cc k 61- c "? q : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. Q L? - 3 C1 CIVIL ACTION -- LAW C- ?- b s?( ?l u 1 1?. of t) : IN DIVORCE „'. Defendant C3 r , PETITION TO PROCEED IN FORMA PAUPERIS ' The Petitioner, ?\\ N CA, Ci is the Plaintiff in this action. On the petitioner's behalf, MidPenn Legal Services does hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn Legal Services is assisting the Petitioner in filing a divorce case pro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests leave to proceed without payment of fees or costs. Attorneys for Plaintiff MidPenn Legal Services Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 0 pi? m -kip n23 x Pamela G. Smith ('((yz /31'0Lt1q Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. `?, NO. 00-391 CIVIL TERM Defendant AFFIDAVIT IN SUPPORT OF PETITION TO PROCEED IN FORMA PAUPERIS 1. I am thee[) A t E° ' in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: 1 \ CU'a ?) ? UW rl C (b) Address: \? ! ( RUC ? '?)h e ?? a J 7 (c) Social Security Number: 1 O` L4 9) L If you are presently employed, state Employer: -L-,C-V? CLr1 y ? Address: 1CL(- Salary or wages per month: J ?2S . S/ Type of work: ?y C\ (? c e S`S If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession:, Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: yS • ° 0 (W Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: 7-Cbr# S t c1 rr? n Other: (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: (e) Property owned Cash: Checking Account: ;ia Savings Account: Certificates of Deposit: _ b Real Estate (including home): el \o V-c r G n Motor vehicle: MakelbyA Year k 1-l ,? ' D Cost Amount owed u Stocks; bonds: Other: (fl Debts and obligations Mortgage: on Rent: Loans: Monthly Expenses:_ r? C-C 0 \ -c (? i CC, F r` ? c (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: \,?&)Cs (IL)O A n r Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances, which would permit me to pay the costs incurred herein. 5. 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. 4904, relating to unworn falsification to authorities. Date: 10 1 `i C?. UC. C-L-C, -F? C', LJ n hJ <-, C7 __ rS ,? r ? -t ..,. ?_:_ ^? -o ?.> <? C J ? __? y _ C '-r?? "° ? h.7 K C? J? YO I^j'rl f-U cc cl 0, Plaintiff VS. Ac O'cn a BY a i"1? Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. V y - _3I / CIVIL TERM IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Submitted, Plaintiff, Pro Se C'ap'.-', O T A' [? C. •-? _ ??? P?'J '?l '1 I ? ?.? ?' _ n ?, `? -„ J 3 0 2004 #licie k, Grown vs. -6-6veti A. crown IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Oq-391 NO. CIVIL TERM ORDER OF COURT AND NOW this G ` day of _ 2004, upon consideration of the attached Petition and Affidavit, the petitioner is allowed to proceed in forma pauperis. BY THE COURT, Distribution Plaintiff: fil;b { RChnl',' ,yr S M Name P4 Address Defendant: 5feb'eK, ik 6'/own ,? ?euc M Pic s ! ?Crw:... ? Q d rru? % ? Wh R{l f Addres 01'4 eesiorn P?- ?7-101 Plaintiff Defendants 06-0Y L?- WWM Ismori. I C =ZI Nd 9- inp wi A "IONOHIOW 3Nt jO :??)la ?L?-(731L 0 Alicia R. Brown IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA No. 04-391 CIVIL TERM V. Steven R. Brown Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Steven R. Brown, accepted service of a true and correct copy of the complaint in Divorce under section 3301 (c) of the Divorce (`,ode on the date written below. I understand that false statements herein are made subject to Oe penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 7 1 ?f? Date Steven R. Brown, Defendant a'a Cn . : CL ttJ . ,f ,..,• Ltj O o° N DRS# ALICIA R. RININGER, IN THE COURT' OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant : IN DIVORCE NOTICE TO PLEAD You are hereby notified to file a written response to the within New Matter within twenty days (20) days from service hereof or a judgment may be entered against you. ALICIA R. RININGER, Plaintiff V. STEVEN R. BROWN, Defendant DRS# IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.04-391 CIVIL TERM IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW comes Petitioner, Alicia R. Rininger, by and through her counsel of record, Hannah Herman-Snyder, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above named Plaintiff, Alicia R. Rininger, an adult individual currently residing at 154 SME, Shippensburg, Cumberland County, Pennsylvania. 2. Your Respondent is the above named Defendant, Steven R. Brown, an adult individual currently residing at 7001 Old Scotland Road, Shippensburg, Franklin County, Pennsylvania. 3. The divorce action filed to the above docketed number in the Court of Common Pleas of Cumberland County, Pennsylvania, requests a divorce be entered based upon §3301(c) or (d) of the Divorce Code of 1980 as amended. 4. Petitioner has employed counsel and will incur certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support herself and pay for attorney's fees or pay for the costs and expenses associated with this action. 5. Respondent is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, WHEREFORE, Plaintiff requests your Honorable Court to enter an Order for alimony pendente lite in this matter. Respectfully submitted, nnah ''1 A AR - Hannah Herman-Snyder, Esq ire Attorney for Plaint ff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4404, relating to unworn falsifications to authorities. Q,? C? C 0? li n DATE: ALICIA R. RININGER ALICIA R. RININGER, Plaintiff V. STEVEN R. BROWN, Defendant DRS# IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-391 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the I day o 2005, cause a copy of Plaintiffs Petition for Alimony Pendente Lite to be served upon Defendant's counsel of record by first-class mail, postage prepaid at the following addresses: Mark F. Bayley, Esquire 155 South Hanover Street Carlisle, PA 17013 DATE: -A-1 ) bS °l Hannah Herman-Snyder, Esc ire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 ALICIA R. RININGER, Plaintiff V. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-391 CIVIL TERM IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Alicia R. Rininger ADDRESS 154 SME Shi ensbur , PA 17257 BIRTH DATE August 3, 1977 SOCIAL SECURITY NUMBER 180-68-2184 HOME PHONE 717-530-1403 WORK PHONE N/A EMPLOYER NAME N/A EMPLOYER ADDRESS N/A JOB TITLE/POSITION N/A DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY N/A OTHER INCOME Child support: $467.00/month (child 1) Child support: ;$45.00/week child 2 ATTORNEY'S NAME Hannah Herman-Snyder, Esquire ATTORNEY'S ADDRESS 200 North Hanover Street Carlisle, PA 17013 ATTORNEY'S PHONE NUMBER 717-243-5551 RESPONDENT NAME Steven R. Brown ADDRESS 7001 Old Scotland Road Shi ensbur , PA 17257 BIRTH DATE April 3, 1971 SOCIAL SECURITY NUMBER 204-56-2823 HOME PHONE 7117-977-1690 WORK PHONE EMPLOYER NAME EMPLOYER ADDRESS JOB TITLE/POSITION DATE EMPLOYMENT COMMENCED GROSS PAY $13.00/hr. NET PAY OTHER INCOME ATTORNEY'S NAME Mark F. Bayley, Esquire ATTORNEY'S ADDRESS 155 South Hanover Street Carlisle, PA 17013 ATTORNEY'S PHONE NUMBER 717-241-6070 MARRIAGE INFORMATION DATE OF MARRIAGE November 3, 2000 PLACE OF MARRIAGE Chambersburg, Pennsylvania DATE OF SEPARATION October 16, 2003 ADDRESS OF LAST MARITAL HOME 12 Airport Road Shippensburg, PA 17257 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Petition DATE APL DOCUMENT FILED ^? 3 ?I 1 Q. D t0 L1 A LIAR 0 9 2005re DRS# ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant : IN DIVORCE ORDER OF COURT AND NOW this lb ` day of mo,,,A , 2005, upon presentation and consideration of the within Petition, the issued of Alimony Pendente Lite is hereby referred to the Domestic Relations Office for scheduling of an appropriate conference or hearing. BY THE COURT, cc: ci'"`mah Herman-Snyder, Esquire Attorney for Plaintiff/Petitioner ddark F. Bayley, Esquire Attorney for Defendant/Respondent J p op?"? 03 ? ? . ? ? _? DRS# ALIC[A R. RININGER, IN THE COURT OF COMMO PLEAS OF Plaintiff CUMBERLAND COUNTY, P NNSYLVANIA VS. STEVEN R. BROWN, Defendant NO. 04-391 CIVIL TERM IN DIVORCE PRAECIPE TO THE DOMESTIC RELATIONS OFFICE: Please withdraw Plaintiff s request for the scheduling of an Respectfully Attorneyfor Plaint GRIFFIE & ASSO 200 North Hanover Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 conference. Esq PIATES Street n Q i . ?"cy P , ? _?? ) J - -:;.: f .? '?'. ii R S 't_" 'r ?„ ? t^'J :.c ? .? dJ MARITAL SEPARATION AGREEMENT THIS AGREEMENT, entered into on the specified date below, by and between Alicia R. Rininger, (hereinafter referred to as "WIFE") and Steven R. Brown, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on November 3, 2000; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner that conforms to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each party to this agreement acknowledges and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of counsel; B. Is fully and completely informed of the facts relating to the subject matter of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all of the above information from the other party. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on behalf of both parties during the marriage. 7. DEBTS AND LIABILITIES: It is further mutually agreed by and between the parties that WIFE will be responsible for the following debts, liabilities, contracts and payments relating to the same: a. 1996 Ford Explorer. The parties agree that HUSBAND will execute a limited power of attorney authorizing the transfer of the vehicle title relating to the above vehicle to WIFE immediately after full execution of this agreement. 8. CASH ASSETS AND OTHER ASSETS: The Parties have previously separated cash assets and other assets not otherwise mentioned by this Agreement to their satisfaction. 9. PERSONAL PROPERTY: The Parties agree that HUSBAND will assume full ownership of the following personal property now in WIFE'S possession: a. Black dresser and mirror; b. Black door chest; C. Black night stand; d. Two (2) porcelain lamps; e. Two (2) brown end tables; f. Kitchen table and four (4) chairs. The Parties agree that WIFE will assume full ownership of the following personal property now in HUSBAND'S possession: a. One (1) of two (2) air conditioners of her choice; b. Bed purchased by WIFE'S Grandfather; C. Any and all toys previously purchased for WIFE'S daughter Leanna. The Parties agree that the above mentioned items of personal property will be exchanged at a location to be agreed upon. HUSBAND will give to WIFE the five (5) or six (6) portrait pictures of the parties' son in his possession. HUSBAND will give to WIFE all pictures of WIFE's daughter, Leanna, in his possession. The Parties agree to share the cost of copying any other family pictures which both Parties wish to possess. The respective Party currently possessing any other personal property not mentioned by this Agreement at the time this Agreement is executed will assume full ownership of said property. 10. SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be granted. 11. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. Additionally, each party waives and relinquishes any and all rights to share in any estate inheritances or bequests the other may receive and/or be entitled to. 12. INCOME TAX RETURNS: All future income tax returns will be filed separately and the parties will each retain any refund due to them. 13. DIVORCE: HUSBAND and WIFE agree to voluntarily execute all necessary documents to finalize a divorce. Documents necessary to finalize the divorce will be signed and returned by both parties within fifteen (15) days after this agreement is fully executed. 14. BREACH: In the event of the breach of this agreement by either party, the non'oreaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek specific performance of the terms of this agreement, where such damages are not ascertainable. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain monetary damages and/or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. 15. ADDITIONAL INSTSRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. 16. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect are fully understood by both parties. HUSBAND'S legal counsel is Mark F. Bayley, Esquire. WIFE'S legal counsel is Hannah Herman-Snyder, Esquire. 17. 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. 18. APPLICABLE LAW: This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 19. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 20. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. Notwithstanding such incorporation, this Agreement shall not be merged into the Decree, but shall survive the same and shall be binding and conclusive on the parties for all time. 21. DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 22. MARITAL DEBT: Each party hereby confirms they have not incurred any additional debt since their separation that has in any way obligated the other party. Neither party will take any action to incur additional debt of any nature whatsoever in the other party's name from the date of execution of this Agreement forward. 23. EQUITABLE DISTRIBUTION: It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either of them during the marriage as contemplated by The Act of April 2, 1980 (P.L. No. 63, No. 26), known as "The Divorce Code," 23 P.S. 101 et seq. of the Commonwealth of Pennsylvania, and as amended. 24. SUMMARY OF EFFECT OF AGREEMENT: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against the other for any past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims raised by them in the divorce action pending between the parties. 25. RECONCILIATION: The parties shall only effectuate a legal reconciliation which supersedes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation, which action, if not consummated by the aforesaid agreement, shall not affect in any way the legal affect of this Agreement or cause any new marital rights or obligations to accrue. 26. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 27. NO WAIVER OF DEFAULT: This agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it b€ construed as a waiver of strici performance of any other obligations herein. 28. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any court into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contract. 29. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 30. NOTICES: Any and all notice given hereunder shall be in writing and shall be sent registered mail, return receipt requested: a. To Husband in care of Mark F. Bayley, Esquire at 155 S. Hanover Street, Carlisle, PA 17013. b. To Wife in care of Griie & Associates at 200 North Hanover Street, Carlisle, PA 17013. 31. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 32. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executor, administrators, successors and assigns. parties. This agreement shall become effective immediately upon its execution by both IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on the date indicated below. WITNESSES: l J CT - Steven R. town Date Alicia R. Rini ger Date COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS PERSONALLY APPEARED B FORE ME, a notary public for Cumberland County Pennsylvania, this , Ck day of 52005, Steven R. Brown, known to me (or satisfactorily proven) to be the perso whose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. tary Publil Linda J. JurWaf, Notaq PuWc C&"e Bozo. Cunbedad COL" WCommiasiaiEVp wJuly23.2006 COMMONWEALTH OF PENNSYLN??`1 A6S0=h01O(N0W" : SS COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County Pennsylvania, this JL1 day of 2005, Alicia R. Rininger, known to me (or satisfactorily proven) to be the person hose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. ??" ?1 XLi?t;? Notary Publ' NOTARIAL SEAL ROBNI J. GOSHORN, NOTARY PUBLIC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 17 2007 T Y7 it O O? rn o ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEVEN R. BROWN, : N0.95 391 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on January 30, 2004, reinstated on June 29, 2004, and service was made on July 7, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 9'/ -o ALICIA R. RININE , Plaintiff - n t? o <n -TI C ".:'.. ::: N O l7 U Cl) r i L:: O T7 N G { ALICIA R. RININGER, Plaintiff V. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW 01(- NO. %-391 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(.) OF THE DIVORCE CODE I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNS WORN FALSIFICATION TO AUTHORITIES. 1 -1 DATE: 9-? y s j2 ALICIA R. RININGER, Plain iff `? ? ? -n u+ C? rnFn n r" C: C7 a ? 1 ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEVEN R. BROWN, 6u Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on January 30, 2004, reinstated on June 29, 2004, and service was made on July 7, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: al (o .?F, l/C e STEVEN R. WN,De fendant C7 N r.? 96 r"-- _a ?- ire ALICIA R. RININGER, Plaintiff V. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 04- 3q/ IN DIVORCE THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: Q - to - p $?; 9 A STEVEN R. BROWN, Defendant O 70 ,V ALICIA R. (BROWN) RININGER, Plaintiff V. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-391 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) 3301(d)(1) efthe Diveree Cede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Acceptance of Service by Defendant dated July 7, 2004. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: 9/19/05 by Defendant: 9/6/05 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff s affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 20, 2005 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 20, 2005 Nobna.h N ?nm&1v- A m,?i Hannah Herman-Snyder, Esq 're GRIFFIE & ASSOCIATES Attorney for Plaintiff ? o Q C cn N O C) CJ CD -? N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ALICIA R. (BROWN) RININGER, Plaintiff No. 04-391 CIVIL TERM VERSUS STEVEN R. BROWN Defendant DECREE IN DIVORCE AND NOW, September 30 v 2005 , IT IS ORDERED AND DECREED THAT Alicia R. (Brown) Rininger , PLAINTIFF, AND Steven R. Brown DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The parties' Marital Separation Agreement dated September 6, 2005 is incorporated herein but merged. E A 4' ALICIA R. RININGER, Plaintiff VS. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-391 CIVIL TERM IN DIVORCE PETITION FOR ENFORCEMENT OF A MARITAL SEPARATION AGREEMENT AND NOW comes Petitioner, Alicia R. Rininger, by and through her attorney, Hannah Herman-Snyder, Esquire and the law firm of Griffie & Associates and avers as follows: 1. Petitioner is the above named Plaintiff, an adult individual currently residing at a confidential address. 2. Respondent is the above named Defendant, an adult individual currently residing at 7001 Old Scotland Road, Shippensburg, Cumberland County, Pennsylvania. 3. The parties entered into a Marital Settlement Agreement effective September 6, 2005, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A." 4. Pursuant to the Marital Settlement Agreement, Paragraph nine (9), the parties were to exchange personal property, and Respondent received his personal property immediately after the Marital Settlement Agreement VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: &n vl?? .:LICK; R. P,N.I`1CER ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the J_aj 'day of February, 2009, cause a copy of Plaintiff's Petition for Enforcement of a Marital Separation Agreement to be served upon Defendant/Respondent by serving him by first- class mail, postage prepaid at the following address: Steven R. Brown 7001 Old Scotland Road Shippensburg, PA 17257 DATE: ?) - y -- () q 1)4 & Hannah Herman-Snyder, Es ire Attorney for Plaintiff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 MARITAL SEPARATION AGREEMENT THIS AGREEMENT, entered into on the specified date below, by and between Alicia R. Rininger, (hereinafter referred to as "WIFE") and Steven R. Brown, (hereinafter referred to as "HUSBAND"). . WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on November 3, 2000; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating-to the ownership and equitable distribution of real and personal property; the settling of 'all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration'of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and- WIFE, each intending to be legally bound, hereby covenant and agree as follows: I . The parties intend to maintain separate and permanent domiciles and to live apart -from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to. divide their matrimonial property in a manner that conforms to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by thee parties to constitute in any way a sale or exchange of assets. 3. . Further, the parties agree to continue living separately and apartfrom each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or er sole use an3-benefit. Neitherparty-shall-interfere with the-uses,----. ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. J a c? Uto -A- a 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each party to this agreement acknowledges .and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of . . counsel; B. Is fully and completely informed of the facts relating to the subject matter. of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all of the above information from the other party. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on behalf of both parties during the marriage. 7. DEBTS AND LIABILITIES: It is further mutually agreed by and between the parties that WIFE will be responsible for the following debts, liabilities, contracts and payments relating to the same: a: 1996 Ford Explorer. The parties agree that HUSBAND will execute a limited power of attorney authorizing the transfer of the vehicle title relating to the above vehicle to WIFE immediately after full execution of this agreement. 8. CASH ASSETS AND OTHER ASSETS: The Parties have previously separated cash assets and other assets not otherwise mentioned by this Agreement to their satisfaction. 9. PERSONAL PROPERTY: The Parties agree that HUSBAND will assume full ownership of the following personal property now in WIFE'S possession: a. Black dresser and mirror; b. Black door chest; C. Black night stand; d. . Two (2) porcelain lamps; e. Two (2) brown end tables; f. Kitchen table and four (4) chairs. The Parties agree that WIFE will assume full ownership of the following personal property now in HUSBAND'S possession: a. One .(1) of two (2) air conditioners of her choice; b. Bed purchased by WIFE'S Grandfather; C. Any and all toys previously purchased for WIFE'S daughter Leann.. The Parties agree that the above mentioned items of personal property will be exchanged at a location to be agreed upon. . HUSBAND will give to WIFE the five (5) or six (6) portrait pictures of the parties' son in his possession. HUSBAND will give to WIFE all pictures of WIFE's daughter, Leanna, in his possession. The Parties agree to share the cost of copying any other family pictures which _bothParrtim wish to ,.possess. The respective Party currently possessing any other personal property not mentioned by this Agreement at the time this Agreement is executed will assume full ownership of said property. 10. SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be. granted. 11. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each parry may dispose ofhis or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory -allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. Additionally, each party waives and relinquishes any and all rights to share in any estate inheritances or bequests the other may receive and/or be entitled to. 12. INCOME TAX RETURNS: All future income tax returns will be filed separately and the parties will each retain any refund due to them. 13. DIVORCE: HUSBAND and WIFE agree to voluntarily execute all necessary documents to finalize a divorce. Documents necessary to finalize the divorce will be signed and returned by both parties within fifteen (15) days after this agreement is.fully executed. 14. BREACH: In the event of the breach of this agreement by either party,. the nonbreaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek specific performance of the terms of this agreement, where such damages are not ascertainable. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain monetary damages and/or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. 15. ADDITIONAL INSTSRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. ..__ _._.-. -- 16. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect are fully understood by both parties. HUSBAND'S legal counsel is Mark F. Bayley, Esquire. WIFE'S legal counsel is Hannah Herman-Snyder, Esquire. 17. 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. 18. APPLICABLE LAW: This agreement shall be construed under-the laws of the Commonwealth of Pennsylvania. 19. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date. and time of this agreement are null and void and of no effect. 20. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. Notwithstanding such incorporation, this Agreement shall not be merged into the Decree, but shall survive the same and shall be binding.and conclusive on the parties for all time. 21. DATE OF EXECUTION:. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 22. MARITAL DEBT: Each party hereby confirms they have not incurred any additional debt since their separation that has. in anyway obligated -the other parry. Neither party will take any action to incur additional debt of any nature whatsoever in the other party's name from the date of execution of this Agreement forward. 23. EQUITABLE DISTRIBUTION: It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either ofthem. during the marriage as contemplated by The Act of April 2, 1980 (P.L. No. 63, No. 26), known as "The Divorce Code," 23 P.S. 101 et seq. of the Commonwealth of Pennsylvania, and as amended. 24. SUMMARY OF EFFECT OF AGREEMENT: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against the other for any past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims raised by them in the divorce action pending between the parties. 25. RECONCILIATION: The parties shall only effectuate a legal reconciliation which supersedes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation, which action, if not consummated by the aforesaid agreement, shall not affect in any way the legal affect of this Agreement or cause any new marital rights or obligations to accrue. 26. SEVERABILITY: If any term, condition, clause or provision of this Agreement :shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement'and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 27. NO WAIVER OF DEFAULT: This agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, no shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar'natdre, nor shall it be construed as a waiver of strict performance of any other obligations herein. 28. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any court into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contract. 29. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 30. NOTICES: Any and all notice given hereunder shall be in writing and shall be sent registered mail, return receipt requested: a. To Husband in care of Mark F. Bayley, Esquire at 155 S. Hanover Street, Carlisle, PA 17013. b. To Wife in care of Griffie & Associates at 200 North Hanover Street, Carlisle, PA 17013. 31. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 32. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executor, administrators, successors and assigns. 33. This agreement shall become effective immediately upon its execution by both parties. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on the date indicatedbelow. WJTNESSES: COMMONWEALTH OF PENNSYLVANIA . : SS COUNTY OF CUMBERLAND PERSONALLY APPEARED By{.FORE ME, a notary public for Cumberland County Pennsylvania, this day of r _ 2005, Steven R. Brown, known to me (or satisfactorily proven) to be the personwhose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHREOF, I have'hereunto set my hand and official seal. r ?idtary Publ L' sari sea L kftj. JmV&, F1G'ia<y Pd*- Cari b Bm. Cumberland County My Conrr*w m Expires July 2i. 2006 Nowin COMMONWEALTH OF PENNSYLVIX °M Of SS COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE lid, a notary public for Cumberland County f , 2005, Alicia R. Rininger, known to me Pennsylvania, this 1 day o p (or satisfactorily proven) to be the erson hose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. A ALICIA R. RININGER, Plaintiff VS. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-391 CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Alicia Rininger to proceed in forma pauperis. I, Hannah Herman-Snyder, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Respectfully submitted, Date: •- I p _ n 9 0 m n - S?l ? Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ?- -n l-: -C Ix rn ? T} k?3 r FEB 1 " 20619 62 ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant IN DIVORCE ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW this 3 day of FcG,•r _, 2009, upon presentation and consideration of the within Petition, it is hereby ORDERED and DECREED that a Rule is hereby issued upon the Defendant/Respondent, Steven R. Brown, to which he shall respond within / days. .V'C'r-u'?-?- By the Court, J. Cc: /annah Herman-Snyder, Esquire Attorney for Plaintiff Xeven R. Brown Pro Se a- CD a! w Qr% ?L` ALICIA R. RININGER Plaintiff VS. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 04-391 CIVIL TERM IN DIVORCE ANSWER TO PETITION FOR ENFORCEMENT OF A MARITAL SEPARATION AGREEMENT AND NOW, comes the Respondent, Steven R. Brown, Pro Se, and respectfully represents as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. Respondent did not receive all his personal property. He did not receive the kitchen table and four (4) chairs. It was trying to even get Petitioner to set a time, place and location for the exchange to take place. A copy of a letter from Ms. Hannah Herman-Snyder to Respondent's former attorney, Mr. Mark Bayley, dated October 31, 2005, shows that Petitioner's attorney sent her client a second request regarding where the property exchange was to take place, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A". Petitioner did receive her personal property at the same time Respondent received some of his personal property. It should be noted that Respondent has not received all of his personal property to date and should be monetarily compensated for same, if Petitioner claims that they no longer exist. 5. Denied. Respondent did contact Petitioner's attorney regarding this matter to which no response was received. 6. Denied. These items were returned to Petitioner at the same time Respondent received some of his personal property. Strict proof of allegation is required at time of trial. 7. Denied. Respondent should not be responsible for costs, expenses and reasonable attorney's fees for Petitioner since she received all her personal property at the same time Respondent received some of his personal property. 8. Admitted. 9. Admitted. WHEREFORE, Respondent, Steven R. Brown, respectfully requests that this Honorable Court dismiss the Petition for Enforcement of a Marital Separation Agreement and find that he has properly complied with the Marital Separation Agreement. If this matter requires Respondent to retain legal counsel, he requests that Petitioner be responsible for costs, expenses, and reasonable attorney's fees pursuant to paragraph fourteen (14) of the Marital Settlement Agreement effective September 6, 2005. Additionally, Respondent requests that he be monetarily compensated for the personal belongings that he did not receive. Respectfully submitted, F C. 17 Z 1-1 ' 2 009 DATE 'Steven R. Brown, Pro Se 7001 Olde Scotland Road Shippensburg, PA 17257 (717) 977-1690 F °. M FA F_Q1 GjuFFTE & Assoc'AI rES radley L. Griffie, Esquire unah Herman-Snyder, Esquire Robin J. Goshorn Office Manager Reply to. Carlisle 100 Lincoln Way East, Suite D Chanbersburg, PA 17201 (717) 267-1350 October 31, 2005 Mark F. Bayley, Esquire Rominger, Bayley & Whare 155 South Hanover Street Carlisle, PA 17013 RE: Rininger vs. Brown Dear Mark: (800) 347-5552 Fax(717)243-5063 I have forwarded your second request for a response as to where a property exchange can take place to my client and am still awaiting a response. I will contact you once I have received a response from Ms. Rininger. Your attention is appreciated. Very truly yours, Hannah Herman-Snyder HHS/i g Cc: Alicia R. Rininger Attorneys and Counselors at Law 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 EXHIBIT A ALICIA R. RR41NGER : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA vs. : NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Steven R. Brown, Pro Se, hereby certify that I did, the Z q day of February, 2009, cause a copy of Respondent's Answer to Petition for Enforcement of a Marital Separation Agreement to be served upon Plaintiff/Petitioner, through her attorney, by serving her by first-class mail, postage prepaid at the following address: Hannah Herman-Snyder, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 Date: February 7- Y , 2009 Steven R. Brown, Pro Se 7001 Olde Scotland Road Shippensburg, PA 17257 (717) 977-1690 ? 1 ' ti ? :,Y .. ?. ...' 4 ,' ? '?a ?_ r? "i"i ..Ci .. T --.-t _ t7'1i_ ? i i? Pa3 ?^' a: ? ?_ :'"a `s .,j ?`?_ 1 lCh. t? ... - .. .. ? ?.? ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant IN DIVORCE PETITION FOR HEARING IN REGARDS TO ENFORCEMENT OF A MARITAL SEPARATION AGREEMENT AND NOW COMES Petitioner, Alicia R. Rininger, by and through her attorney, Hannah Herman-Snyder, Esquire, and the law firm of Griffie and Associates and avers as follows: 1. Petitioner is the above named Plaintiff, an adult individual currently residing at a confidential address. 2. Respondent is the above named Defendant, an adult individual currently residing at 7001 Old Scotland Road, Shippensburg, Cumberland County, Pennsylvania. 3. The parties entered into a Marital Settlement Agreement effective September 6, 2005, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A." 4. Petitioner filed a Petition for Enforcement of a Marital Separation Agreement on February 10, 2009 as there are some unresolved issues in regards to the exchange of personal property, which was to be exchanged pursuant to the terms of the Marital Settlement Agreement, and an Order of Court and Rule to Show Cause was issued by the Honorable Kevin A. Hess on February 13, 2009. 5. An Answer to the Petition for Enforcement of Marital Separation Agreement was filed by the Respondent on February 24, 2009. 6. The issue is now ready for a decision as the parties still disagree as to the exchange of personal property. 7. The Honorable Kevin A. Hess issued the Order of Court and Rule to Show Cause in regards to this matter. 8. Respondent is being provided with notice of the filing of this petition via first class mail, postage prepaid. WHEREFORE, Petition requests this Honorable Court schedule a hearing and at that time enter an Order that Respondent provide three (3) times and dates as well as a neutral location in regards to a place to exchange personal property so that the parties can meet to exchange the personal belongings, and in the alternative, direct the Respondent pay Petitioner $3,000.00 as well as reasonable attorney's fees to be paid directly to Mid Penn Legal Services. Respectfully Submitted, Hannah Herman-Snyder, Esgiire Attorney for Plaintiff/Petitioner GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. Cf, DATE: LU LICIA R. RINING R MARITAL SEPARATION AGREEMENT THIS AGREEMENT, entered into on the specified date below, by and between Alicia R Rininger, (hereinafter referred to as "WIFE") and Steven R. Brown, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on November 3,2000; and culties have arisen between WHEREAS, diverse, unhappy differences, disputes and diffi the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and-WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have at-tempted to. divide their matrimonial property in a manner that conforms to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. . Further, the parties agree to continue living separately and apartfrom each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each parry may carry on _ and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use an3-lierief it: -Neither party-shall-interfere-with the uses; -,----- ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. a 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each party to this agreement acknowledges and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of counsel; B. Is frilly and completely informed of the facts relating to the subject matter, of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each,party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. 'Each party acknowledges that, to the extent desired, he or she has had access to all of the above information from the other party. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on behalf of both parties during the marriage. 7. DEBTS AND LIABILITIES: It is further mutually agreed by and between the parties that WIFE will be responsible for the following debts, liabilities, contracts and payments relating to the same: a. 1996 Ford Explorer. The parties agree that HUSBAND will execute a limited power of attorney authorizing the transfer of the vehicle title relating to the above vehicle to WIFE immediately after full execution of this agreement. 8. CASH ASSETS AND OTHER ASSETS: The Parties have previously separated cash assets and other assets not otherwise mentioned by this Agreement to their satisfaction. 9. PERSONAL PROPERTY: The Parties agree that HUSBAND will assume full ownership of the following personal property now in WIFE'S possession: a. Black dresser and mirror; b. Black door chest; C. Black night stand; d. . Two (2) porcelain lamps; e. Two (2) brown end tables; f: Kitchen table and four (4) chairs. The Parties agree that WIFE will assume full ownership of the following personal property now in HUSBAND'S possession: a. One.(1) of two (2) air conditioners of her choice; b. Bed purchased by WIFE'S Grandfather; C. Any and all toys previously purchased for WIFE'S daughter Leanna. The Parties agree that the above mentioned items of personal property will be exchanged at a location to be agreed upon. HUSBAND will give to WIFE.the five (5) or six (6) portrait pictures of the parties' son in his possession. HUSBAND will give to. WIFE all pictures of WIFE's daughter, Leanna, in his possession. The Parties agree to share the cost of copying any other family pictures which - - -both Pw-tes wish to possess. The respective Party currently possessing any other personal property not mentioned by this Agreement at the time this Agreement is executed will assume full ownership of said property. 10. SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be. granted. 11. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each parry may dispose ofhis or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. Additionally, each party waives and relinquishes any and all rights to share in any estate inheritances or bequests the other may receive and/or be entitled to.. 12. INCOME TAX RETURNS: All future income tax returns will be filed separately and the parties will each retain any refund due to them. 13. DIVORCE: HUSBAND and WIFE agree to voluntarily execute all necessary documents to finalize a divorce. Documents necessary to finalize the divorce will be signed and retumed by both parties within fifteen (15) days after this agreement is fully executed. 14. BREACH: In the event of the breach of this agreement by either party, the ' nohbreaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek-specific performance of the terms of this agreement, where such damages are not ascertainable. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain monetary damages and/or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. 15. ADDITIONAL INSTSRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement._ 16. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect are fully understood by both parties. HUSBAND'S legal counsel is Mark F. Bayley, Esquire. WIFE'S legal counsel is Hannah Herman-Snyder, Esquire. 17. 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. 18. APPLICABLE LAW: This agreement shall be construed under-the laws of the Commonwealth of Pennsylvania 19. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 20. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. Notwithstanding such incorporation, this Agreement shall not be merged into the Decree, but shall survive the same and shall be binding. and conclusive on the parties for all time. 21. DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or. "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 22. MARITAL DEBT: Each party hereby confirms they have not incurred any additional debt since their separation that has. in anyway obligated the other party. Neither party will take any action to incur additional debt of any nature whatsoever in the other party's name from the date of execution of this Agreement forward. 23. EQUITABLE DISTRIBUTION: It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either ofthem during the marriage as contemplated by The Act of April 2, 1980 (P.L. No. 63, No. 26), known as "The Divorce Code," 23 P.S. 101 et seq. of the Commonwealth of Pennsylvania, and as amended. 24. SUMMARY OF EFFECT OF AGREEMENT: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against the other for any past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims raised by them in the divorce action pending between the parties. 25. RECONCILIATION: The parties shall only effectuate a legal reconciliation which supersedes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall remain in fill force and effect. Further, the parties may attempt a reconciliation, which action, if not consummated by the aforesaid agreement, shall not affect in any way the legal affect of this Agreement or cause any new marital rights or obligations to accrue. 26. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure -of any party to meet her or his obligations under any one or more of the paragraphs herein, with exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the-parties. 27. NO WAIVER OF DEFAULT: This agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar'natd.re, hor shall it be construed as a waiver of strict performance of any other obligations herein. 28. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any court into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contract. 29. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 30. NOTICES: Any and all notice given hereunder shall be in writing and shall be sent registered mail, return receipt requested: a. To Husband in care of Mark F. Bayley, Esquire at 155 S. Hanover Street, Carlisle, PA 17013. b. To Wife in care of Griffle & Associates at 200 North Hanover Street, Carlisle, PA 17013. 3.1. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 32. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executor, administrators, successors and assigns. 33. This agreement shall become effective immediately upon its execution by both parties. IN WITNESS WHEREOF, -the parties have hereunto set their hands and seals on the date indicated below. W7?'NESSES: . . C Steven R rown Date 17 Alicia R. ger V (J Date COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS PERSONALLY APPEARED B FORE ME, a notary public for Cumberland County Pennsylvania, this day of , ?^ , 2005, Steven R. Brown, known to me (or satisfactorily proven) to be the persodwhose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein .contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. tary Publii S?ar;at s? Ueda l Jumper, t+ owy Pd-1k Cafisle BUD, Ctm6wW4 County My comrygmm Expires J* 23.2006 COMMONWEALTH OF PENNSYL A won a N aWft SS COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE NE, a notary public for Cumberland County Pennsylvania, this /74 day of , 2005, Alicia R. Rininger, known to me (or satisfactorily proven) to be the person hose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. Notary Put PUBLIC D COUNTY ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-391 CIVIL TERM STEVEN R. BROWN, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the day of March, 2009, cause a copy of Plaintiff's Petition for Hearing in regards to Enforcement of a Marital Separation Agreement to be served upon Defendant/Respondent by serving him by first-class mail, postage prepaid at the following address: Steven R. Brown 7001 Old Scotland Road Shippensburg, PA 17257 DATE: Hannah Herman-Snyder, Esquire Attorney for Plaintiff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 RLED--OMr CE OF THE FROTHIONIOTAAY 2009 APR -7 PM I * ? 2 '0i ?f ALICIA R. RININGER, Plaintiff VS. STEVEN R. BROWN, APR 0 S 20094 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-391 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW this /34( day of 2009, upon presentation and consideration of the within Petition, it is hereby ORDERED and DECREED that a hearing is scheduled for the Aq4 day of . 2009, at //;0 o'clock, C4- m. in Courtroom No. `!` of the Cumberland County Co house. By the Court, Cc: ZHannah Herman Attorney ,--,Steven R. Brovo Pro Se ?/? X05 yder, Esquire Plaintiff' .LC I CL 4 f!M1 tt.1pp"st l .n ,? AINrIlt L I :ZI Wd £ I M 6081 i Kara W. Haggerty, E squire Attorney I.D. #: 869 14 2 West High Street Carlisle, PA 17013 (717) 249-0900 ALICIA R. RI NINGER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 04-391 CIVIL TERM STEVEN R. ROWN, Defendant PRA IN DIVORCE ECI Please PE FOR ENTRY QJE APPEARANCE nter my appearance on behalf of the Defendant, Steven R. Brown, in the above- captioned matt er. Respectfully submitted, ABOM & KUTULAKIS, LLP Date: Kara W. Haggerty, s e 2 :West High Stree Csle, PA 17013 (717) 249-0900 ID #86914 in AND L.L.P., here Appearance, u be deposited, JOW, this 2( -'??day of May, 2009, I, Kara W. Haggerty, Esquire ofAb om & Kutulakis, certify that I did serve a true and correct copy of the foregoing Praecipe for Entry of on the Hannah Herman-Snyder, Esquire, Counsel for Plaintiff, by depositing, or causing to me in the United States Mail, Certified Mail, postage prepaid addressed to the following: Hannah Herman-Snyder, Esquire 200 North Hanover Street Carlisle, PA 17013 Respectfully submitted, Abom & Kutulakis, L.L.P. L • ( 11 Kara W. Haggerty, F Attorney ID No.869 2 West High Street Carlisle, PA 17013 (717) 249-0900 OF THE 2009 MAY 22 Aj r ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 04-391 CIVIL STEVEN R. BROWN, Defendant IN RE: MOTION TO ENFORCE MARITAL SEPARATION AGREEMENT ORDER AND NOW, this Z q" day of May, 2009, the plaintiff having failed to meet her burden of proof, her petition for enforcement of marital property agreement is DENIED. BY THE COURT, ? Hannah Herman-Snyder, Esquire For the Plaintiff Steven R. Brown, Pro Se 7001 Old Scotland Road Shippensburg, PA 17257 Defendant :rlm (20P I IRS mzm LL ORO l