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HomeMy WebLinkAbout08-4671 IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § CIVIL ACTION - LAW 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § § TERM . § CASE NO. 7 / Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § § IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be 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 at the CUMBERLAND County Courthouse, I lout -VxC tmQ(room number and address) C.f\is? PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AN 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, 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 REDUCED FEE OR NO FEE Office of the Prothonotary CUMBERLAND County Courthouse 1 Coucklno-.Me- z (address) Caxkiske , PA. 1:7612; TRUE Telephone( :11:1 ) coti()- fc16CZ ht Testimony A and the seal of PYF RErnRD , here unto set my h& Court at Car;i;12, Pa. of ...... ...... Prothonotary This ....... `. da IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § CIVIL ACTION - LAW 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § § TERM § CASE NO. 0f- Y47/ 0,L, j T-c- Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § § IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE !ODE 1. Plaintiff is Bobby Jo Klinepeter who resides at; 3001 Yale Avenue; Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Matthew Robert Klinepeter who resides at: 3001 Yale Avenue; Camp Hill, Cumberland County, Pennsylvania 17011. 3. ® Plaintiff and/or ® Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on August 6, 2005 at Jennerstown, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members Civil Relief Act of 2003. 6. There has been no prior action of divorce or for annulment between the parties. 7.The marriage is irretrievably broken. Complaint for Divorce; Page 1 8. After 90 days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in marriage counseling. 10. There are no children born to or adopted by the parties to this marriage and none are expected. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and Defendant. COUNT H REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(8) OF THE DIVORCE CODE. Paragraphs 1-10 are incorporated herein and made a part hereof by reference as though fully set forth. The parties have entered into a written Marital Settlement Agreement providing for the distribution of their property, debts, and spousal support, a copy of which is attached hereto and incorporated by this reference the same as if filly set forth at length. WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between the parties into the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. Complaint for Divorce; Page 2 r r 74w??,.ao Bobby Jo inepeter I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unworn falsification to authorities. Date: hobby o Klinepeter, Pro Per p\ N w cc? ,`.7 - Gl _ t? Ail IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW 08 - Y(41 oe"; t TERM CASE NO. IN DIVORCE ACCEPTANCE OF SERVICE I, Matthew Robert Klinepeter, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divorce filed in the above-captioned matter. 9/5/ Date atthew Ro er, defendant T-F ., ? ?, ,` ? -``sz ?.? , ; ? -, f ??-: c_;-a ?-?, ..?? . - .' r_-, =,:; IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § § § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW M- 41-71 0-ivel TERM CASE NO. IN DIVORCE AFFIDAVIT AS TO SIGNATURE Bobby Jo Klinepeter, being duly sworn according to law, deposes and says that Bobby Jo Klinepeter is the Plaintiff in the above-captioned divorce action; that Bobby Jo Klinepeter is familiar with the signature of the Defendant; and that the signature on the Acceptance of Service attached hereto as Exhibit "A" is the signature of the Defendant, Matthew Robert Klinepeter. Date: F Sworn to and subscribed before me this the r?? ;0 1)46"& obby o Klinepeter, Plaintiff day of Notary Public ?b „ ? ` R, =r? ? _F ,?F ??'? t.,: 1 __ IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW TERM CASE NO. -_!:jt'7 i IN DIVORCE AFFIDAVIT OF CONSENT A complaint in Divorce under 3301(c) of the Divorce Code was filed on y-- 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the 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 contained herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. DATE: t?y Mbar 7. =k= Matthew Robert ep er WAIVER OF NOTICE TO INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without any notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18. Pa. C.S. §49 relating to upsWorn falsification to authorities. Dated: l V Cl?}e M Q, f aCK? atthew Robeepeter C7 ? i ??` " - .? ? r... ors `-' .c' r„?-? c`- ?? Z ??. ?"" J c? t IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § § Matthew Robert Klinepeter, Defendant 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW TERM CASE NO. 4(a711 G' J i 1 IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under 3301(c) of the Divorce Code was filed on Lou g. 'J 1 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the 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 contained herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. DATE: NcakhQr ?c?U$ Bobby Jo Klinepeter WAIVER OF NOTICE TO INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without any notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18. Pa. C.S. §4904 relating to unworn falsification to authorities. Dated: bbl ?? 2A ,fi`t'( ? ?n '0 #,, Bobby Jo Klinepeter t-o o ? CA "< IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW TERM CASE NO. M _ t4 -11 G. %? IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the t-Nkday of Pk ju 11-S 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301(c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. 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. 7. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Dated:- ?-P/'CZ ???_ ?? Bobby Jo inepeter, Plaintiff C CD? C .% t un IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW TERM CASE NO. -ns? -?jt-t l DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the day of C?mCA(, s F- , _? : _• 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301(c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. 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. 7. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Dated: L'•eMur -7 Matthew Robert Klinepeter, Defendant -as IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § CIVIL ACTION - LAW TERM CASE NO. IN DIVORCE NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT You are hereby given notice that ten (10) days following mailing of this notice, a Praecipe to Transmit Record, together with a proposed Final Decree of Divorce, will be filed in this matter with the Appointment Clerk's Office, Room at in , Pennsylvania. Exact copies of the Praecipe and the proposed Final Decree in Divorce are enclosed herewith. After the praecipe and proposed Final Decree in Divorce are filed, you will have a period of ten days during which you may file objections to the entry of the Final Decree based upon this Praecipe. If you dispute any of the information on the Praecipe or Final Decree you must act within that ten-day period. Any objections must be filed in writing with the Appointment Clerk's Office, Room , , Pennsylvania . If no objections are filed before the expiration of the ten-day period, this case will be submitted to the Court for entry of the Final Decree. Dated: J?cygec bLc J+V_ laintiff, Bobb Jo Klinepeter M t CIO cn 0 IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Bobby Jo Klinepeter, Plaintiff § 3001 Yale Avenue § Camp Hill, Pennsylvania 17011 § 717-503-9378 § VS. § Matthew Robert Klinepeter, Defendant § 3001 Yale Avenue § CIVIL ACTION - LAW TERM CASE NO. n% - 46-71 GQ i J EXHIBIT A Camp Hill, Pennsylvania 17011 717-503-9387 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT made and entered into this the day of, between Bobby Jo Klinepeter, residing at 3001 Yale Avenue, Camp Hill, Penn vania 17011 and Matthew Robert Klinepeter, residing at 3001 Yale Avenue, Camp Hill, Pennsylvania 17011. WHEREAS we were married to each other at on August 6, 2005 and lived as husband and wife until such time as we separated on A, gayg and have remained in a bona fide state of separation since that time; WHEREAS a permanent breakdown of the marriage has arisen between us and we are now living separate and apart from each other, and WHEREAS we now intend, by this agreement, to make a final and complete settlement of all of our of our rights and obligations concerning division of property, spousal support, and employee retirement benefits; and WHEREAS in consideration of the premises and mutual promises and undertakings herein contained, and for other good and valuable consideration, the parties agree to the following: 1. THE PARTIES AGREE to live separate and apart from the other party, with the intention thereafter never again to resume the marital relationship, free from any control, restraint or interference, direct of indirect with the other party, and in all respects to live as if he or she were sole and unmarried. MUTUAL RELEASE: Wife and Husband from this date and at all time hereafter may purchase, acquire, own, hold, possess, encumber, dispose of and convey all classes and kinds of property both real and personal as though unmarried and free from the consent, joinder and interference of the other party, it being the understanding and agreement on the part of each of the parties hereto that in the sale, transfer and conveyance of any property hereafter, real or personal, it shall not be necessary in order for the grantee to have good title, that the other party hereto shall sign and execute to the grantee the deed, conveyance, deed of trust, mortgage or bill of sale conveying or selling the property, it being the agreement and covenant of the parties hereto that each has forever released and discharged the property of the other from all claims, interest and estate on his or her part, and that each shall be in the same position as if such party were single or unmarried. It. DIVISION OF PROPERTY: We agree to divide the property of our marital estate as follows: 1. Bobby Jo Klinepeter Transfers to Matthew Robert Ilinepeter as sole and separate property, and Bobby Jo Klinepeter is divested of all right, title, and interest in and to the following property. House. A house described by street address as 3001 Yale Avenue, Camp Hill, Pennsylvania 17011 together with all prepaid insurance and legally described as: . The house has a lien against it payable to Mr. J. Dixon Earley. Through a separate agreement drawn up by a layer, Matthew R. Klinepeter will receive the property known as 3001 Yale Avenue, Camp Hill, PA. The plaintiff, Bobby Jo Klinepeter will be receiving an amount of $13,500 from the parents as her share and in doing so sever all ties to the home stated above, including, but not limited to payments and any liens on the property. The house will become the sole responsibility of Matthew R. Klinepeter. Personal Property. Household Furniture, etc. All household furniture, furnishings, fixtures, goods, appliances, and equipment in the possession of or subject to the control of Matthew Robert Klinepeter, including but not limited to the following: Bike Blue; Furniture Love Seat, Ottoman, and Couch; Lay-Z-Boy; Large Desk - black and brown; Dresser brown tall; Dresser brown long; Filing Cabinet; Brown Tall Lamps that go with the desk set; TV-RCA brown and black; TV-Silver Sanyo; Wii - and all the games (including guitar hero); Long brown wooden - storage unit made by Matt's parents; Small light brown table with drawer; Small light brown night stand; Rug in living room (dark green, red, tan); Runner (2) small and large; 2 DVD Player - Panasonic and Apex; VCR-RCA; Black Computer ASUS; Silver Computer Dell; Logitech Speakers; Thrusters; Cyber Acoustic Stereo speakers; Black CD holder w/light; Brown Sconces; Cases of Movies; Laptop - Dell; Monitor flat screen 19 wide HansG; (2) Silver Lamps; All of my CD's; Kayak & Paddles; Guitar and Amp; (1) white rocking chair; Rocking Chair Susan and Greg gave to us Brown w/seat cushion; Round End Table light colored; 12 Off-White dishes in Glass Cabinet; '/2 Glasses in Glass cabinet; '/2 Silverware; Memory Foam; Heated Mattress pad; Office Chair Taupe; Large Tent; Green Shovel; Coke Plates and Blue plates; Small Digital Camera; Mincer; Coffee Maker, Orange and gray fold up chair, Brown 2 level table downstairs with spindles; Silver tall floor lamp; Baseball bat, mitt, and balls; Work Lights - Orange; Ladder; and Drill. Clothing, etc. All clothing, jewelry, and other personal effects in the possession of or subject to the control of Matthew Robert Klinepeter. Cash. All cash in the possession of or subject to the sole control of Matthew Robert Klinepeter. Checking Accounts. All checking accounts at all banks or other financial institutions which stand in the sole name of Matthew Robert Klinepeter or from which Matthew Robert Klinepeter has the sole right to withdraw funds. Investment Account. Husband shall receive 50% of the ING Account. Vehicle. The vehicle described as a 2004 Jeep Grand Cherokee with vehicle identification number #1J4GZ58SOSC789313 including all prepaid insurance, keys, and title documents. The property has a lien against it payable to Fulton Bank on loan number ending in #5019. Employment Benefits. All sums and all rights related to any profit sharing plan, retirement plan, pension plan, or like benefit program existing by reason of Matthew Robert Klinepeter's past, present, or future employment and not otherwise awarded to Bobby Jo Klinepeter in this agreement. 2. Matthew Robert Klinepeter Transfers to Bobby Jo Klinepeter as sole and separate property and Matthew Robert Klinepeter is divested of all right, title, and interest in and to the following property: House. A house described by street address as 3001 Yale Avenue, Camp Hill, Pennsylvania 17011 together with all prepaid insurance and legally described as: . The house has a lien against it payable to Mr. J. Dixon Earley. Through a separate agreement drawn up by a layer, Matthew R. Klmepeter will receive the property known as 3001 Yale Avenue, Camp Hill, PA. The plaintiff, Bobby Jo Klinepeter will be receiving an amount of $13,500 from the parents as her share and in doing so sever all ties to the home stated above, including, but not limited to payments and any liens on the property. The house will become the sole responsibility of Matthew R. Klinepeter. Personal Property: Household Furniture, etc. All household furniture, furnishings, fixtures, goods, appliances, and equipment in the possession of or subject to the sole control of Bobby Jo Klinepeter, including but not limited to the following: Mittens; Cat House; Hope Chest; All Cat items; Bike Silver; Day Bed; Leather Chair; Yellow Wooden Desk w/bookcase; 1 black stackable item; End Tables; Piano; Table and chairs; Coffee Table; Entertainment Unit; Off-white night stand by my bed; Other runners in the bedroom light colored the same length (2); Bike Rack; Black Computer Athlon; Flat Monitor; Black Stool; Brown Stools in the kitchen; Little carved wooden tray on coffee table; All doileys; laptop Apple for work; (2) Brown Lamps with gold shades; Brown lamp with leaf shade; pot with plant; All my CD's; Canon Camera with Telephoto Lens; Manhatten drawing pad; End tables brown one level upstairs; (2) printers Epson Photosmart 8200 HP DeskJet; Easel and anything art related; (1) white rocking chair; Rug upstairs; Green Dish; %z Off-White dishes in Glass Cabinet; `h Glasses in Glass cabinet; % Silverware; Wine glasses; Pots and pans; Waffle maker; Mixing bowls; Toaster; Toaster-Oven; Microwave-in garage; Knife Set in kitchen; Spice Rack; Ironing Board; Most bedding; (2) small tents; (2) Blow- up Mattress; Orange chair; Orange Shovel; Speakers that go with wife's computer and base; Blender, Serving Platters; Roaster; Creative with headphones; Shovel for digging; Clippers; Rug upstairs; Lg. Crockpot/sm.Crockpot; Set of orange chairs; Set of black canisters (4) with spoons; Cake holder; Vases; and Mower. Clothing, etc. All clothing, jewelry, and other personal effects in the possession of or subject to the sole control of Bobby Jo Klinepeter. Cash. All cash in the possession of or subject to the sole control of Bobby Jo Klinepeter. Checldng Accounts. All checking accounts at all banks or other financial institutions which stand in Bobby Jo Klinepeter's sole name or from which Bobby Jo Klinepeter has the sole right to withdraw funds. Investment Account. Wife shall receive 50% of the ING Account. Vehicle. The vehicle described as a 2002 Chevrolet Malibu with vehicle identification number #IG1NE52J92M602376 together with all prepaid insurance, keys, and title documents. The property has alien against it payable to First Commonwealth Bank with loan number ending in #6307. Employment Benefits. All sums and all rights related to any profit sharing plan, retirement plan, pension plan, or like benefit program existing by reason of Bobby Jo Klinepeter's past, present, or future employment and not otherwise awarded to Matthew Robert Klinepeter in this agreement. DEBTS TO BE PAID BY Matthew Robert Klinepeter Matthew Robert Klinepeter shall pay, as a part of the division of the estate of the parties, the following and shall indemnify and hold Bobby Jo Klinepeter and Bobby Jo Klinepeter's property harmless from any failure to so discharge these items: House. One promissory note payable to the order of Mr. J. Dixon Earley . The note is secured by a lien against the house located at the street address of 3001 Yale Avenue, Camp Hill, Pennsylvania 17011. Vehicle. One promissory note, payable to the order of Fulton Bank with loan number ending in #5019, with an estimate balance due and owing of $13,145.90. The note is secured by a lien against vehicle described as a 2004 Jeep Grand Cherokee with vehicle identification number #1J4GZ58SOSC789313. A lien is recorded by financing statement in the proper office in the county and state. Any and all debts, charges, liabilities, and other obligations incurred solely by Matthew Robert Klinepeter from and after the parties date of separation unless express provision is made in this agreement to the contrary. All debt associated with any property awarded to Matthew Robert Klinepeter. DEBTS TO BE PAID BY Bobby Jo Klinepeter Bobby Jo Klinepeter shall pay, as a part of the division of the estate of the parties, the following and shall indemnify and hold Matthew Robert Klinepeter and Matthew Robert Klinepeter's property harmless from any failure to so discharge these items: House. One promissory note payable to the order of Mr. J. Dixon Earley. The note is secured by a lien against the house located at the street address of 3001 Yale Avenue, Camp Hill, Pennsylvania 17011. Vehicle. One promissory note payable to the order of First Commonwealth Bank loan number ending in #6307, with an estimate balance due and owing of $2,485.19. The note is secured by a lien against vehicle described as a 2002 Chevrolet Malibu with vehicle identification number #1G1NE52J92M602376. Alien is recorded by financing statement in the proper office in the county and state. Accounts. All amounts owing as of the date of this agreement on the following accounts/loans: Name of Company Account/Loan # Amount 1. American Education Services ending in #0402 $8,737.37 2. Great Lakes Loan ending in #0004 $5,378.25 Any and all debts, charges, liabilities, and other obligations incurred solely by Bobby Jo Klinepeter from and after the parties' date of separation unless express provision is made in this agreement to the contrary. All debt associated with any property awarded to Bobby Jo Klinepeter. Ill. NOTICE Each party shall send to the other party, within three days of its receipt, a copy of any correspondence from creditor or taxing authority concerning any potential liability of the other party. IV. ALIMONY -MAINTENANCE: Both parties agree to waive any rights or claims that either may now have or in the future to receive alimony, maintenance, or spousal support from each other. Both parties understand the full import of this provision. V. NECESSARY DOCUMENTS: THE PARTIES AGREE TO EXECUTE AND DELIVER TO the other party any documents that may be reasonably required to accomplish the intention of this instrument and shall do all other necessary things to this end. VI. SUBSEQUENT DISSOLUTION OF MARRIAGE: It is agreed that this Agreement may be offered into evidence by either party in any dissolution of marriage proceeding, and if acceptable to the Court, this Agreement shall be incorporated by reference in any Final Judgment that may be rendered. However, notwithstanding incorporation in the Final Judgment, this Agreement shall not be merged in but shall survive the Final Judgement and be binding on the parties for all times. VII. AGREEMENT DESIGNED TO FACILITATE A DIVORCE OR DISSOLUTION OF THE PARTIES' MARRIAGE: This Agreement is entered into with the express intent to facilitate encourage, aid, and in any other manner lead to a divorce and or dissolution of the marriage between the parties hereto. VIII. SUBSEQUENT DISSOLUTION OF MARRIAGE: Respondent/Defendant herein, acknowledges receipt of a copy of the documents to be filed herein with this agreement of the parties attached as Exhibit "A", and states that he/she has read and understands the same. It is agreed that this Agreement shall be offered into evidence by either party in any dissolution of marriage proceeding, and if acceptable to the Court, this Agreement shall be incorporated by reference in any Final Judgment that may be rendered, and the parties shall be ordered to comply with all its provisions, and all warranties and remedies provided in this agreement shall be preserved. However, notwithstanding incorporation in the Final Judgment, this Agreement shall not be merged in but shall survive the Final Judgement and be binding on the parties for all times. IX. REPRESENTATION: The parties represent to each other: (a) Each had the right to independent counsel. Each party fully understands their legal rights and each is signing this Agreement freely and voluntarily, intending to be bound by it. (b) Each has made a full disclosure to the other of his or her current financial condition. (c) Each understands and agrees that this Agreement is intended to be the full and entire contract of the parties. (d) Each agrees that this Agreement and each provision of it is expressly made binding upon the heirs, assigns, executors, administrators, successors in interest and representatives of each party. X. WAIVER OF BREACH: No waiver of any breach by any party of the terms of this Agreement shall be deemed a waiver of any subsequent breach. XI. ENFORCEMENT OF THE AGREEMENT: Both parties agree that the Court granting the divorce, at the request of either party, insert in the Final Judgment a reservation of jurisdiction for the purpose of compelling either party to perform this Agreement, or any part thereof. The prevailing party shall be entitled to attorney's fees in connection with such proceeding. XII. GOVERNING LAW: This Agreement shall be interpreted and governed by the laws of the State of Pennsylvania. XIII. WAIVER OF SERVICE OF PROCESS AND FILING AN ANSWER: Defendant herein, acknowledges receipt of a copy of the documents to be filed herein, and states that he/she has read and understands the same, hereby waives the issuance, service, and return of process upon him/her in this action enters a voluntary appearance in this cause, waiving all time and right to plead, answer or appear in this action, and consents that the same may be set down for trial and heard by the court at any time hereafter without notice to, and in the absence of, this Defendant. XIV. WAIVER OF EMPLOYEE AND/OR MILITARY RETAINER OR RETIREMENT BENEFITS: Both parties agree to waive any rights, interests, or claims, that either may now have or in the future to receive employee and/or military retainer or retirement benefits resulting from the past, present or future employment and/or service of the other party in the Armed Forces of the United States. Both parties understand the full import of this provision. XV. CHANGE OF NAME: The parties agree that the Wife may have her name changed or restored to Bobby Jo Shank. SIGNED ON THIS THE -7-1-H day of UQ g-mbp r , ?- STATE OF Pennsylvania § COUNTY OF Cumberland §ss. M ew Robert Kl' a Pendant Before me, the undersigned, a Notary Public, on this 7..4 day of &&La& , Z009, personally appeared the above named Defendant, Matthew Robert Klinepeter, to me known to be the identical person who executed the above and foregoing Marital Settlement Agreement and personally acknowledged to me that he/she read, understood and signed the same; and that he/she executed the same as his/her free and voluntary act and deed for the uses and purposes therein set forth. IN WITNESS WHEREOF, I have hereunto affixed my signature and official seal the day and date heretofore stated. My commission expires: Kerwin jjdW. Notary Puibk Hsnwden Twp.. Cumb!d!y+d Ca SIGNED ON THIS THE 7-R--day of UQ,?emtec , &YA • STATE OF Pennsylvania § COUNTY OF Cumberland §ss. Bobby Jo Klinepeter, Plaintiff Before me, the undersigned, a Notary Public on this 7AI day of e4t, 2W?, personally appeared the above named Petitioner/Plaintiff, Bobby Jo Klinepeter, to me known to be the identical person who executed the above and foregoing Marital Settlement Agreement and personally acknowledged to me that he/she read, understood and signed the same; and that he/she executed the same as his/her free and voluntary act and deed for the uses and purposes therein set forth. IN WITNESS WHEREOF, I have hereunto affixed my signature and official seal the day and date heretofore stated. My commission expires. 7 (eat l,z oo?on?wF.a?TH or-??Ai?irl? NotaAal seal KWVM SW W Notary PUW My QWW*W0n EVk",P* 2B. 2012 Aseodatlon d tit 5 ey r VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. Ug y?-f1 CIVILTERM 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) of the Divorce Code. (Strike out inapplicable section). 2. : Date and manner of service of the complaint: A-I?a%t4 L OCIA SDILA& (PU .-U I 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 defendant MOt. PAo T. VNow1er by plaintiff 24h A A<\ ?? QDgAje' (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: 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: M" K 1+? QQC R A)A ?,K?ec? i? r R vgffx--,A!lT (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ttor ey for Plaintiff / Defendant T-A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 by 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 -j D?? , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: ignat re Lam. A Signatu e o name being resumed COMMONWEALTH qF PENNSYLVANIA ) COUNTY OF 6 LL ft crkti n, On the '141 G day of I Y6 0e-A-h e.' , 2006, before me, the Prothonotary or the notary public, personally appeared the above 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. NOTARIAL SEAL, PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 Notary Pull? is 41 -o a .C` Z rnm 7 G BOBBY JO KLINEPETER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW R. KLINEPETER, DEFENDANT NO. 08-4671 CIVIL TERM DIVORCE DECREE AND NOW, VIAW11%.- 18 , ?;W?F , it is ordered and decreed that BOBBY JO KLINEPETER , plaintiff, and MATTHEW R. KLINEPETER , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") k) owe- By t ourt, sty Attest: J. othonotary -a ?? ? ? , 4