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HomeMy WebLinkAbout08-2666John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RINEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COUR OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE/CUSTODY 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, Room 101, Dauphin County Courthouse, Front and Market Streets, Harrisburg, PA. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 1249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 1249-3166 (800) 990-9108 John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RINEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OP- ,444 CIVIL ACTION - LAW DIVORCE/CUSTODY COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Shannon Donofrio- Ri n eer, by her attorneys, Purcell, Krug & Haller, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Shannon Donofrio-Rineer, an adult individual whose current address is temporary at this time, being located in Cumberland County, Pennsylvania. 2. Defendant is Michael J. Rineer, an adult individual whose current address is 8 Hazelwood Path, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 3, 1995, in Enola, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there is one child of the parties under the age of 18: Jonas M. Donofrio-Rineer, born April 12, 2000. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The marriage is irretrievably broken and/or the Defendant has offered the Plaintiff, the injured and innocent spouse, such indignities as to render her condition intolerable and life burdensome. 10. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 11. Plaintiff requests the Court to enter a Decree in Divorce. a COUNT I - EQUITABLE DISTRIBUTION 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth at length. 13. Both parties are owners of real estate, in addition to personal property located therein. Both parties further own intangible and tangible property. COUNT II - ALIMONY 14. Plaintiff incorporates herein by reference paragraphs 1 through 12 as if set forth at length. 15. Plaintiff lacks sufficient funds to provide for her reasonable needs and is unable to support herself through appropriate employment. COUNT III - CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES 16. Plaintiff incorporates herein by reference paragraphs 1 through 12 as if set forth at length. 17. Plaintiff does not have sufficient funds for herself or to pay counsel fees and expenses incidental to this action necessary to prosecute the same. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: (a) Dissolving the marriage between the Plaintiff and Defendant; (b) Equitably distributing all property, both personal and real, owned by the parties; (c) Ordering alimony, alimony pendente lite, counsel fees and expenses necessary for the Plaintiff to adequately prosecute this case; and 3 (d) Such further relief as the Court may deem equitable and just. PURCELL, KRUG & HALLER By John V. Purc I, Jr., Esquire 955 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 DATE: 41 X31 0 A? oho e to $A- ?* -lt D W rte, ? ro John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RINEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 8_ a 66 (P CIVIL ACTION - LAW DIVORCE/CUSTODY PLAINTIFF'S PETITION TO ENJOIN DISPOSITION OF ASSETS AND NOW comes the above-named Plaintiff, by her attorney, John W. Purcell, Jr., who Petitions this Court to enjoin the Defendant's disposition of certain marital assets, based upon the following. 1. The Petitioner herein is the Plaintiff. The Respondent herein in the Defendant. 2. Plaintiff and Defendant have been married for almost 13 years and have one child. 3. During the marriage, the parties have enjoyed the acquisition of certain assets, including the following: a. Respondent's interest in his 401 K through his employment with First Horizon, along with a pension with UPS. b. Defendant's interest in her 401 K and pension through IBM. C. Approximately $200,000 in UPS stock, all of which was purchased during the time of the marriage. d. A checking account and a savings account, along with certain amounts of cash. 4. Other than the above assets, the only assets of significance which the parties own include the marital residence located at 8 Hazelwood Path, Mechanicsburg, Cumberland County, Pennsylvania, which is titled in the names jointly, and in which they have equity of an indeterminate amount, along with various items of personal property, furniture, appliances, etc. located in the marital home. 5. The parties have recently been forced to separate, and the wife has been forced to remove herself from the marital home. 6. Almost immediately prior to her removal from the marital home, Defendant closed out the joint savings and checking accounts, withdrawing approximately $13,000 from the same, in addition to taking approximately $2,000 in cash from a safe in the marital home, and has relocated the funds to an unknown location. 7. In addition, the day after removing herself from the home, Petitioner went back to the home to retrieve her personal items of clothing and jewelry, and found that all of it had been removed from the marital home. a 8. Upon questioning, Defendant admitted that he had packed up all of the personal belongings of the Plaintiff and placed them on the front porch, after which they disappeared. 9. Given the type of neighborhood they live in, Petitioner does not believe that they "disappeared" but that the Defendant had spirited them to some place unknown in order to prevent Petitioner from having them. Respondent has subsequently given most of the items back to the Petitioner. 10. Given the irrational manner in which the Defendant is acting, and given the fact that he has already spitefully removed much of the marital assets from the home, Petitioner is concerned that he will continue to do the same thing with respect to his retirement accounts and the UPS stock, along with the cash removed from the bank accounts. 11. Liquidation of any of these accounts by the Respondent jeopardizes the Petitioner's financial security, both now and in the future, and will cause irreparable harm to the Petitioner. Enjoining the Respondent from liquidating, encumbering or otherwise alienating the various accounts and assets will cause Defendant no financial or other harm. 12. Petitioner requests this Court to Order that the funds appropriated by the Respondent in the amount of $15,000 be either divided equally between the parties for their mutual use, subject to consideration by the Court on the equitable distribution claim, or placed into an escrow account until further Order of Court or consent of the parties. 13. Petitioner further requests this Court to enjoin the Defendant from liquidating, encumbering or otherwise alienating or disposing of any other assets of the parties, either held separately or jointly, without the consent of the Petitioner or further Order of the Court. WHEREFORE, Petitioner requests this Honorable Court to enter the relief requested above. Respectfully submitted, PURCELL, KRUG & HALLER By L?? Joh . Purcell, Jr., Esquire 29955 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 DATE: OH t e/ 30.0 r VERIFICATION I verify that the statements made in the foregoing PETTTT9N To EN OTN DTcnn¢Tm J_Q N OF ASSETS 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. n Dated: i--f *( Shannon Donofrio-Ri eer ??, ,t,7ev 1'^J - -71 T`_? ;J C. r : .-< APR 2 82008?pV SHANNON DONOFRIO-RI NEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6'9- acac6(e Ciyzt ter'--% CIVIL ACTION - LAW DIVORCE/CUSTODY ORDER AND NOW, this day of , 2008, upon consideration of the attached Petition to Enjoin Disposition of Assets, this Court hereby issues a Rule upon the Defendant to show cause, if any, why the relief prayed for therein should not 3 be granted. The Rule shall be served upon Defendant or Defendant's counsel of record ox Do by regular mail and shall be returnable 01,30 4-M. -6 Pending further Order of this Court Defend nt shall of liquidate, encumber, alienate or otherwise dispose of any held BY THE J. Distribution List: John W. Purcell, Jr., Esquire Purcell Krug & Haller 1710 N. Front Street Harrisburg, PA 17102 Michael J. Rineer 8 Hazelwood Path Mechanicsburg, PA 17050 d i-o taf,e? ,Y? ?-- N ?- ?, ,,a? -- C ?7 ? :: ?? ;. y _ ...-? l }?J Z u-L? t C.) ?---? l /' ir- John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RI NEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2664CIVIL TERM CIVIL ACTION - LAW DIVORCE ORDER OF COURT AND NOW, this V) 344 day of , 2008, upon consideration of the Plaintiff's Petition to Enjoin Disposition of Assets, and upon representation by counsel for both parties that the matters set forth in the Petition have been settled and mutually agreed upon, that Agreement is hereby embodied in this Court Order. It is therefore ORDERED AND DECREED as follows: Neither party shall sell, transfer, convey, assign, alienate, encumber, dissipate or otherwise transfer any marital assets without the written consent of the other party or Court Order, including both parties' interest in their respective retirement accounts, 401 K's or pensions, and all UPS stock. 2. Defendant shall pay to Plaintiff the sum of $6,000 as partial distribution of the funds previously held in the parties' joint bank accounts. 3. Defendant shall pay to Plaintiff one-half of the 2007 income tax refunds, and one-half of the 2007 tax stimulus rebate, upon receipt. --k, -- J AW /'• 4, Defendant will return to Plaintiff all of her remaining books which are currently in his possession, her Spanish compact discs and any other music discs presently in his possession. To the extent any such items have been destroyed by Defendant, Plaintiff will purchase new ones and will be reimbursed by Defendant within 10 days of receipt provided to him. 5. Nothing distributed herein shall be deemed a final distribution of any assets for purposes of equitable distribution under the Divorce Code. BN By J. c SID John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RI NEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA oz -aZ(o(o(o NO. 48-26WIVIL TERM CIVIL ACTION - LAW DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that Shannon Donofrio- Ri neer, Plaintiff in the above captioned divorce action, hereby elects to resume the prior surname of Shannon L. Donofrio, and gives this written notice pursuant to the provisions of 54 P.S. § 704. Date: kD d Shannon Donofrio-Rine uA? 9?t Shannon L. Donofrio Commonwealth of Pennsylvania County of 7R?pEkk ?-\ On the `-1, ' day of P,rs2008, before me a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the written document and acknowledgment that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal My Commission Expires: Notarial Seal ' Kimberly S. DeFalco, Notary Pd*-. City Of Harrisburg, Dawhin Canty W Canmission a0res Jan. 17, 2009 Member, Pennsylvania Association of Notaries FT; Q Last Printed: September 22, 2008 2:41 PM MARGARET M. SIMOK, ESQUIRE MARIA P. COGNETTI & ASSOCIATES Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 717-909-4060 Attorney for Defendant SHANNON DONOFRIO-RINEER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL J. RINEER, Defendant NO. 08-2666 CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Michael J. Rineer, Defendant in the above-captioned matter. Date: 7 o-S-08 TO THE PROTHONOTARY: Respectfully Submitted: By: JOH R aFENSTERMACHER, ESQUIRE Kindly enter my appearance on behalf of Michael J. Rineer, Defendant, in the above-captioned divorce matter. Respectfully submitted, Date: 1'30/o$ By: MARGA T S. SIMOK, ESQUIRE C) C._ ra ? =TZ ' r?i , ? ? , , - ? 57 SHANNON DONOFRIO-RINEER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2666 CIVIL TERM MICHAEL J.RINEER Defendant ACTION IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Margaret M. Simok, Esquire, of Cognetti & Associates, on behalf of Michael J. Rineer, Defendant in the above-captioned divorce action, and enter the appearance of Margaret M. Simok, Esquire, of Scaringi & Scaringi, P.C. Date: S - I Sb 9 Date: S -? -0 9 Respectfully Submitted, Margar M. Simok, Esquire Cognetti & Associates 210 Grandview Avenue, Suite 110 Camp Hill, PA 17011 62?a Margar M. Simok, Esquire Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17101 THE /f?'? j cu"t ?L t i.? ~'~ SHANNON DONOFRIO-RINEER, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :NO.08-2666 CIVIL TERM ~~ ~, MICHAEL J. RINEER ~ ^ ~ ' .T~ Defendant :ACTION IN DIVORCE ~1 g ~~~ ' `~ Y; --, ~--- ~~.; , c~ PRAECIPE - ~~-, TO THE PROTHONOTARY: '' ~, ., ~ =:.. Please withdraw the appearance of Margaret M. Simok, Esquire of Scanngi Lei Scaringi, P.C., on behalf of Michael J. Rineer, Defendant in the above-captioned divorce action, and enter the appearance of Margaret M. Simok, Esquire of Maria P. Cognetti & Associates. Respectfully Submitted, Date: 7 -~,, -gyp Dater a 7 -IO Margar M. Simok, Esquire Scaringi & Scaringi, PC 2000 Linglestown Road; Suite 106 Harrisburg, PA 17110 Attorney I.D. No. 89633 ~' Margate .Simok, Esquire Maria P. Cognetti & Associates 210 Grandview Avenue, Suite 110 Camp Hill, PA 17011 Attorney I.D. No. 89633 SHANNON DONOFRIO-RINEER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-2666 MICHAEL J. RINEER, : CIVIL ACTION - LAW Defendant : IN DIVORCE rq tj) eR +f9 ? ? j;+ ACCEPTANCE OF SERVICE z C •'S' ( ,rte A i'". ..-? ..rte Sr Y f On this, the day of May, 2008, I Michael J. Rineer, do hereby ac?A r service of the Complaint in Divorce, filed on April 24, 2008, regarding the above-captioned matter. M 9 Michael J Rineer John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com c t C T MONO-TARR 2lI APR -7 QM ti: 17 '-1U1%WRLANO COUNT' PENNSYLVANIA SHANNON DONOFRIO-RINEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-266 CIVIL TERM CIVIL ACTION - LAW DIVORCE/CUSTODY AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 24, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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. §4904 relating to unsworn falsification to authorities. Date: 31'g3 1 4"ttM, ?6w PW? Shannon Donofrio-Rineer MARGARET M. SIMOK, ESQUIRE MARIA P. COGNETTI & ASSOCIATES Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 717-909-4060 E-mail: msimok@cognettilaw.com Attornev for Defendant 911 AP -1 ,M II: I? CUMBERLAND COUNTY PENNSYLVANIA SHANNON DONOFRIO-RINSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-266 MICHAEL J. RINEER, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 24, 2008. 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 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: V29 / "-"'- Michael J. Ri eer i ?!S a LF..A 3 4'70 ti0 TAR 1 2311 A°5°7 M11:1? TIMBERLAND COUNTY i:NNSYLVANIA MARGARET M. SIMOE, ESQUIRE MARIA P. COGNETTI & ASSOCIATES Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 717-909-4060 E-mail: msimokna,cognettilaw.com Attornev for Defendant SHANNON DONOFRIO-RINSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-266 MICHAEL J. RINEER, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 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 Waiver 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: 3 Z -/)/ ) K 99- - Michael J. Rineer ' ILL j f .?i^?`(/?"????+tti7V t?,{?n?L?^ ?• , ' 1J( 1Sli 2011 APR - 7 Atl 11: 17 P,UMBERLAND COUNTY CIA John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RI NEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-266 CIVIL TERM CIVIL ACTION - LAW DIVORCE/CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4-3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 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: 3I S-$1 Shannon Donofrio-Rineer r SEPARATION AND P D COUNTY , X'N5YLVAr11A PROPERTY SETTLEMENT AGREEMENT iw THIS AGREEMENT, made this day of 4 !tI 2011, by and -I between Shannon Donofrio, hereinafter referred to as Wife, and Michael Rineer, hereinafter referred to as Husband. WITNESSETH: WHEREAS, Husband and Wife were lawfully married on June 3, 1995; and WHEREAS, Two (2) children were born of this marriage, Jonas Michael Rineer (DOB: 4/12/2000) and Lucas Matthew Rineer (DOB: 8/20/2008), (hereinafter referred to as children); and WHEREAS, certain differences have arisen between the parties as a result of which they separated on April 15, 2008, and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which will distribute their marital property in a manner which is considered to be an equitable division of all joint property, and will provide for the mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, there has been a complete disclosure of the earnings and property of each party, and each understands his/her rights under the Divorce Code of the Commonwealth of Pennsylvania; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband by his attorney, Margaret M. Simok, Esquire, and Wife by her attorney, John W. Purcell, Esquire, have come to the agreement, which follows: NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound, covenant, promise and agree as follows: 1. Separation. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place that he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart. 2. Interference. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. Wife's Debts. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 4. Husband's Debts. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. Outstanding Joint Debts. The parties acknowledge and agree that they have no outstanding debts and obligations incurred prior to the signing of this Agreement, except as follows: None. In the event that either party contracted or incurred any debts since the date of separation, the party who incurred said debt shall be responsible for the payment thereof, regardless of the name in which the account may have been charged, and such party shall indemnify, defend and hold the other party harmless from any claim or demand made against that party by reason of such debt. 6. Equitable Distribution of Marital Propertv. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that it is the first marriage for Husband and Wife; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division of being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. A. Distribution of Personal Property. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits, except as stated herein. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to their separate property and any property which is in their possession or control, pursuant to this Agreement, and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. B. Distribution of Real Estate. Wife has transferred to Husband, prior to the execution of this Agreement, all of her interest in and title to their jointly owned real estate at 8 Hazelwood Path, Mechanicsburg, PA 17050. Wife acknowledges that she has no claim, right, interest or title whatsoever in said property and further agrees never to assert any claim to said property in the future. 7. Vehicles. Notwithstanding Paragraph 6 of this Agreement, Husband shall retain possession and ownership of the 2007 Pontiac Solstice presently in his possession. Wife hereby transfers all of her right, title and interest in said vehicles to Husband. In consideration thereof, Husband shall assume full responsibility for 5 payment and eventual satisfaction of any and all liens presently encumbering the vehicles, and to indemnify, defend and hold Wife harmless for the same. Wife shall sign any title or other documents necessary to transfer ownership of said vehicles at any time, upon demand, within 30 days of the execution of this Agreement provided demand is made, and further shall indemnify Husband for any costs, including actual counsel fees, incurred by Husband to enforce this provision. Notwithstanding Paragraph 6 of this Agreement, Wife shall retain possession and ownership of the RAV4 2008 presently in her possession. Husband hereby transfers all of his right, title and interest in said vehicle to Wife. In consideration thereof, Wife shall assume full responsibility for payment and eventual satisfaction of any and all liens presently encumbering the vehicle, and to indemnify, defend and hold Husband harmless for the same. Husband shall sign any title or other documents necessary to transfer ownership of said vehicle at any time, upon demand, within 30 days of the execution of this Agreement provided demand is made, and further shall indemnify Wife for any costs, including actual counsel fees, incurred by Wife to enforce this provision. In consideration of the transfer of the 2007 Pontiac Solstice, Husband shall pay to wife the sum of $3,000.00, concurrent with the execution of this Agreement. 8. UPS Stock and Dividends. The parties have an interest in certain UPS stock accrued during the marriage. One-half (1/2) of the marital portion of that stock, (One Thousand Sixty Eight (1068) shares) shall be transferred to Wife, with the balance being retained by Husband. In addition to the transfer of the actual stock, Husband shall pay to Wife the sum of $5,373.38 (as of Decemeber 31, 2010) as her interest in 6 the marital portion of the stock dividends received by husband since the date of separation through December 31, 2010. The transfer of stock shall be made within 30 days of the execution of this agreement, or upon a date reasonably attainable by the transfer agent, if not within 30 days. In the event that any dividends are issued between the date of the last dividend included in the above payment, and the transfer of stock, or should any dividend be received by Husband for wife's portion of the stock in the future, Husband shall immediately pay over to wife one half of the marital portion of the amount received. 9. Alimony. Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of property are fair, adequate and satisfactory to them, and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further voluntarily and intelligently waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indemnify, defend and hold the other harmless against any future action for support or alimony, modification or extension of same, brought by or on behalf of the other and the results of such action, such indemnity to include the actual counsel fees of the defendant in any such future action. 10. Alimony Pendente Lite Counsel Fees and Expenses. Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties is fair, adequate and satisfactory to them. Both parties shall accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses, or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. Each party shall be responsible for his or her own counsel fees, and each agrees to indemnify, defend and save the other harmless from any action commenced against the other for alimony pendente lite, counsel fees and/or expenses. 11. Prior Tax Returns. The parties acknowledge that they have filed various joint income tax returns during the course of their marriage. In the event that any additional taxes, penalties or interest are assessed as a result of any such joint return, the party responsible for under-reporting income or claiming any improper deduction shall indemnify and save the other party harmless from such tax liability, penalties, interest, counsel fees, accountant's fees, costs and expenses. 12. Warranty as to Existing Obligations. Each party represents they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, expect for obligations arising out of this Agreement. 13. Warranty as to Future Obligations. Husband/Wife covenant, warrant, represent and agree that with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 14. Bank Accounts. Husband/Wife acknowledge that they each possess certain bank accounts and the like in their respective names. They hereby agree that each shall become the sole owner of their respective accounts and they each hereby waive any interest in, or claim to, any funds held by the other in such accounts. 15. Pensions, Annuities and/or Retirement Benefits. Husband agrees that any monies which Wife has acquired through her interest in pensions, profit sharing, 401(k), savings and thrift plans, annuities and/or retirement benefits through her present or past employers shall remain her sole and exclusive property. Husband agrees to waive any interest he may have in any such property and further agrees that he will not assert any such claim in the future. Husband hereby covenants and agrees that he will execute any spousal waivers that may be required under the Pension Reform Act of 1974, the Retirement Equity Act of 1984, or any similar Federal or State statute that is now in effect or may be enacted. This paragraph is intended to substitute for any other statement, prepared form, or document which might be required by any plan, fund, trust, administrator, trustee, or similar entity or person, so that Wife may receive said benefits as if she were never married. Wife agrees that any monies which Husband has acquired through his interest in pensions, profit sharing, 401(k), savings and thrift plans, annuities and/or retirement benefits through his present or past employers shall remain his sole and exclusive property. Wife agrees to waive any interest she may have in any such property and further agrees that she will not assert any such claim in the future. Wife hereby covenants and agrees that she will execute any spousal waivers that may be required under the Pension Reform Act of 1974, the Retirement Equity Act of 1984, or any similar Federal or State statute that is now in effect or may be enacted. This paragraph is intended to substitute for any other statement, prepared form, or document which might be required by any plan, fund, trust, administrator, trustee, or similar entity or person, so that Wife may receive said benefits as if he were never married. 16. After-Aguired Property. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 17. Tax Advice. Both parties hereby acknowledge and agree that they have had the opportunity to retain their own accountants, certified public accountants, tax advisor or tax attorney with reference to the tax implication of this agreement. Further, neither party has been given any tax advice whatsoever by their respective attorneys. Further, both parties hereby acknowledge they have been advised, by their respective attorneys, to seek their own independent tax advice by retaining an accountant, certified public accountant, tax attorney, or tax advisor with reference to the tax implications involved in this Agreement. Further, the parties acknowledge and agreed that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent tax advice. 10 18. Applicability of Tax Law to Property Transfers. The parties hereby agree and express their intent that any transferred property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to any transfers set forth in this Agreement without recognition of gain of such transfers and subject to the carry-over basis provisions of the said Act. 19. Waiver of Claims. Except as here and otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she shall now have or hereafter require, under the present and future laws of any jurisdiction, to share the property or estate of the other as a result of the marital relationship, including without limitation dower, curtesy, statutory allowance, widows-allowance, widowers-allowance, right to intestacy, right to take against the Will, and the right to act as administrator or executor of the others' estate. Each party 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 rights, interests and claims. 20. Divorce. A Complaint in Divorce has been filed by Wife to No. 08-2666 Civil Term, in the Court of Common Pleas of Cumberland County, Pennsylvania, and either party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an affidavit evidencing their consent to the divorce, pursuant to Section 3301(c) of the Divorce Code simultaneous with the execution of this agreement. 11 In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees, resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. 21. Time of Distribution. The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective parties immediately upon the execution of this Agreement. All spousal support and other such obligations, including alimony, shall immediately terminate. The parties shall cooperate by executing whatever documents are necessary to effectuate a divorce under Section 3301(c) or 3301(d) of the Pennsylvania Divorce Code, and this Agreement to cooperate shall be enforceable by an assumpsit action for specific performance. However, upon refusal to consent, all distributed property shall be returned to the party originally in possession, until the time of final decree. 22. Reconciliation. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. 23. Release. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release, indemnify (including actual legal fees) and discharge the other of and from all causes of 12 action, claims, rights, or demands whatsoever, in law or equity, civil or criminal, including equitable distribution, spousal support, alimony, counsel fees, alimony pendente lite, and expenses which either of the parties against the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or under any other statutory or common law, except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling, pursuant to Section 3302 of the Divorce Code. 24. Waivers of Claims Against Estates. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, 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 any right existing now or in the future under the Pennsylvania Divorce Code, as amended from time to time, 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. Each further waives any right to inherit or receive property or act as the personal representative of the estate of the other by Will, Codicil, intestacy, or insurance policy, unless such Will, Codicil, or insurance policy (designation of beneficiary) is dated subsequent to the effective date of this Agreement. 13 25. Rights on Execution. Immediately upon the execution of this Agreement, the rights of each party against the other, despite their continuing marital status, shall terminate and be as if they were never married. 26. Breach. In the event of breach of any of the terms of this Agreement, the nonbreaching party shall be paid, as part of any award or judgment against the breaching party, all costs, including actual counsel fees paid to his or her attorney. 27. Incorporation in Final Divorce. The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties. Any Court having jurisdiction shall enforce the provisions of this Agreement as if it were a Court Order. This Agreement shall survive in its entirety, resolving the spousal support, alimony, equitable distribution and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania, and no court asked to enforce or interpret this Agreement shall in any way change the terms of this Agreement. This Agreement may be enforced independently of any support order, divorce decree or judgment and its terms shall take precedence over same, remaining the primary obligation of each party. This Agreement shall remain in full force and effect regardless of any change in the marital status of the parties. It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable, and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement. 28. Additional Instruments. 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 14 further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 29. Separability. In case any provision of this Agreement should be held to be contrary to, or invalid under, the law of any country, state or other jurisdiction, such illegality and invalidity shall not in any way affect the other provisions hereof, all of which shall continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate and undisputed covenant and agreement. 30 Entire Agreement. This Agreement contains the entire, complete and exclusive understanding of the parties, and there are no representations, warranties, covenants and undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them, based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to Section 3502(d) of the Divorce code or any other laws. Husband and wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any right to seek court relief for the purpose of enforcing the provisions of this Agreement. 15 31. Modification and Waiver. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 32. Intent. It is the intent of the parties by this Agreement to fully and finally foreclose any resort to the courts for relief on the basis of any statute or case law presently existing or which may exist at some time in the future within the Commonwealth of Pennsylvania, including but not limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended. This Agreement has been drafted and accepted on the basis that such resort would constitute a breach under this Agreement, entitling the nonbreaching party to reimbursement for actual counsel fees. Other than as provided by the terms of this instrument, it is intended that the court shall treat the parties as if they had never entered into a marital relationship. This Agreement shall be construed in accordance with the Laws of the Commonwealth of Pennsylvania which are in effect as of the date of the execution of this Agreement and, where such law is inconsistent, the terms of this instrument shall govern. 33. Voluntary Execution. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been 16 furnished with or are aware of all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. Each party further acknowledges that each has conducted his own independent investigation into the existence of the other's assets and liabilities and is not depending upon any representations made by the other party in agreeing to the terms hereof. 34. Descriptive Headings. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 35. Agreement Binding on Heirs. This Agreement shall be binding and shall inure to the benefit of the parties hereto, and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year first above written. WITNESS: 1.1?u"?ovnnVQ?t Shannon Donofrio Michael R' eer 17 j^tIf ? ?Q? r ` ? N?A ??J ?? John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com SHANNON DONOFRIO-RINEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2666 CIVIL TERM CIVIL ACTION - LAW DIVORCE/CUSTODY 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) of the Divorce Code. 2. Date and manner of service of the Complaint: by Acceptance of Service of Defendant, Michael J. Rineer, on May 15, 2008. 3. Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff: 3/28/11 and by Defendant: 3/29/11. (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 a Praecipe to Transmit Record, a copy of which is attached (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously herewith; Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously herewith. PURCELL, KRUG & HALLER By: o ;19 rcell, Jr., Esquire 1D# 955 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: Attorney for Plaintiff ?"? , ? I I I a SHANNON DONOFRIO-RINEER, Plaintiff V. MICHAEL J. RINEER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2666 CIVIL TERM CIVIL ACTION - LAW DIVORCE/CUSTODY DECREE IN DIVORCE , 2011, it is ordered and decreed AND NOW, this day of AJ?A that SHANNON DONOFRIO-RINEER, Plaintiff, and MICHAEL J. RINEER, Defendant, are divorced from the bonds of matrimony. The court retains jurisdiction over any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: None. The attached transcript of the parties' Settlement Agreement dated April 1, 2011, shall be incorporated into, but shall not merge in this final Decree in Divorce. BY COURT, Judge CERTIFIED ?lUr i I La 12011 41131i1- Oetfi. Copy Mailed-lc t ArMl Nofiee * Copy mailed -Fo allq -Z+rnok