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Home My WebLink About09-3513Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff TERRY J. DOEBLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE DOEBLER, Defendant NO. U 4- 3 SI 3 C-u -e,- CIVIL ACTION - LAW 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 maybe 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, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6100 Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff TERRY J. DOEBLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE DOEBLER, Defendant NO. CIVIL ACTION - LAW IN DIVORCE AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro do veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presenter comparecencia escrita en persona o por abogado y presenter en la Core por escrito sus defenses o sus objeciones a law demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualgiuer dinero reclamado en la demanda o por cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6100 Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff TERRY J. DOEBLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE DOEBLER, Defendant NO. U q • 3S/3 Cc? CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this day of , 2009, comes the -JQ? . - iC7- Plaintiff, Terry J. Doebler, by and through his attorney, Cindy L. Hribal, Esq., Carrucoli & Associates, P.C., and files this Complaint in Divorce of which the following is a statement: Plaintiff is Terry J. Doebler, who currently has a mailing address of P.O. Box 629, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is Laurie Doebler, who currently resides at 305 Bonniebrook Road, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff 4. The Plaintiff and Defendant were married on April 13, 1980 in Hickorytown, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers that the marriage is irretrievably broken. 7. Plaintiff and Defendant have been living separate and apart since May 13, 2007. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in such counseling. 8. Plaintiff does not request counseling, pursuant to §§3301(c) and 3301(d) of the Divorce Code. 9. Neither party in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully !Jup. qj?,No. 202325 Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff VERIFICATION I, Terry J. Doebler, verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. Date: Terrys Doebl Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff TERRY J. DOEBLER Plaintiff V. LAURIE DOEBLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE CERTIFICATE OF SERVICE I, Cindy L. Hribal, Esq., counsel for Plaintiff hereby certify that a copy of the Complaint for Divorce, directed to Defendant, was served upon Defendant Pt Defendant's residence, 305 Bonnie Brook Ave., Carlisle, Pennsylvania, 17013, this ?_ day of 2009, by first-class mail, postage prepaid, and certified mail, return receipt 'este(pursuant to Pa. C.R.P. 1930.4(c). 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 Carrucoli & Associates, P.C. a F,:_ti. ,- 33F'Sti c,t /o G8 a ;2 sroZ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA TERRY J. DOEBLER, Plaintiff v. : LAURIE DOEBLER, Defendant No. 09-3513 n c 4 ~ ..~ ` ri , ~i;-r-. C_.r :~ ~jZ~ r r~ ~ M~ -mil .~ W i ), _ - ~:,. ~..~ -- J' ' ~ n J ~ ' ~~ ~~ .~="' "'V CIVIL ACTION -LAW IN DIVORCE DEFENDANTS PETITON FOR ALIMONY PENDENTE LITE AND NOW, comes Laurie Doebler, by and through her privately retained counsel, Karl E. Rominger, Esquire and in support of her Petition, avers as follows: 1. Plaintiff filed a Divorce Complaint on May 27, 2009. 2. Defendant is without sufficient property and otherwise unable to financially support herself. 3. Plaintiff is presently employed and receiving substantial income and benefits and is able to pay for alimony, and alimony pendente lite for Defendant WHEREFORE, your Petitioner prays this Honorable Court to award Alimony Pendente Lite in an amount equal to the Pennsylvania State support guidelines. Date: 3une 8, 2010 Respectfully submitted, Rominger & Associates K~1B. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA TERRY J. DOEBLER, Plaintiff No. 09-3513 v. LAURIE DOEBLER, Defendant CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Kazl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of Defendants Petition for Alimony Pendente Lite upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Cazlisle, Pennsylvania, addressed as follows: Date: June 8, 2010 Cindy L. Hribal, Esquire CARRUCOLI & ASSOCIATES 875 Mazket Street, Suite 200 Lemoyne, Pennsylvania 17043 Respectfully submitted, Rominger & Associates Kazl ominger, Esquire 155 South Hanover Street Cazlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA TERRA' J. DOEBLER, No. 09-3513 Plaintiff y~ I f ._J Vr : ~ i,~~ : CIVIL ACTION -LAW , ~ ~ ~~~~ __~ LAURIE DOEBLER, ~ '~-'' Defendant IN DIVORCF, - -. " ~~~- COUNTER CLAIM EQUITABLE DISTRIBUTION 1. A Divorce action was filed by the Plaintiff on May 26, 2009. 2. Defendant seeks economic relief. 3. There are economic issues between the parties which have not been resolved. WHERF,FORE, Defendant repuests this Honorable Court resolve the economic sssues. Dated: October 19, 2012 Karl E. Rominger, Esquire 155 South Hanover Street Ca~•lisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant Laurie Doehler f ~a ~ ~,~ ~, ~~ yap IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA TERRY J. DOEBLER, Plaintiff ~. LAURIE DOEBLER, Defendant No. 09-3513 CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE L Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify ghat I this day served a copy of the Counter-Claim Equitable Distribution upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Cindy Hribal, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 Dated: October 19, 2012 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-b070 Supreme Court ID # 81924 Attorney for Defendant Laurie Doebler Cam!coli & Associates, P.C. 875 'Market Street Lemoyne. PA 17043 ~"'~"l''61 I>~4 At*.crnev~ for Plaintiff ~: ttri ` ~'r f a(Y y TERRY S. DOEBLER, G ,:. ~ : ~ ` ~} Plaintiff ` ~T~i THE COURT OF COMMON PLEAS ~~"ClF CUMBERLAND COCNTY, PENNSYLVANIA v. LAURIE DOEBLER, Defendant NO. 09-3513 CIVIL ACTION - LA~V IN DIVORCE COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCVE CODE 1. Check either (a) or (b): ~_ (a} I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart fora. period of at least two years. (ii) The marriage is not irretrievably broken. Z. Check either (a) ~or (b): (a) I do not wish to make anv claims for economic relief. 1 understand that I may lose rights concerning alimony, division of property, la~ti~; er's fees or expenses if I do not claim them before a divorce is granted, (b) I wish to claim economic relief which may include alirr~ony, division of property, law:yer's fees or expenses or other important rights, l understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail tc~ do so before Carruco!i ~. Associates, P.C. 875 !Market Street Lemoyne. F'A 1 ~ 0~3 (~1~)76i-12i<r A?torne+s for PlaintifY the date set forth on the Notice of :Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file and economic claims. I verify that the statements :made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of l 8 Pa C.~. ~ 4904 relating to unsworn falsification to authorities. DA7-E~. `~i_ l~ , _ C .. ~ ~\ LAURIE DOEBLER Carrucoli & Associates, P.C. 875 Market Street, Suite 120 Lemoyne, PA 17043 (717) 761-1274 Attorney for Plaintiff TERRY S. DOEBLER, Plaintiff v. LAURIE DOEBLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-3513 CIVIL ACTION — IN DIVORCE AFFIDAVIT OF CONSENT v r CA) LAW ZC:a 1. A complaint in Divorce under 3301(c) of the Divorce Code was filed on May 26, 2009. 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: C. -L , 31 `k 713 CL7) Ca C -n L Carrucoli & Associates, P.C. 875 Market Street Lemoyne, PA 17043 (717) 761-1274 Attorneys for Plaintiff TERRY S. DOEBLER, Plaintiff v. LAURIE DOEBLER, Defendant ::3 -OFFICE O T H N O TAR 2014 OCT 30 PM 3: 53 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, • PENNSYLVANIA NO. 09-3513 CIVIL ACTION — LAW IN DIVORCE Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 067 OsOq Carrucoli & Associates, P.C. 875 Market Street, Suite 120 Lemoyne, PA 17043 (717) 761-1274 Attorney for Plaintiff TERRY S. DOEBLER, Plaintiff CUMBERLAND u0Ui PENNSYLVANIA ZjJr, rel I iEEC 10 Pt I 2: v. LAURIE DOEBLER, Defendant " SIN THE COURT OF COMMON PLEAS ej- YOF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-3513 CIVIL ACTION — LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under 3301(c) of the Divorce Code was filed on May 26, 2009. 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: \ 21411-1 LAURIE DOEBLER Carrucoli & Associates, P.C. 875 Market Street Lemoyne, PA 17043 (717) 761-1274 Attorneys for Plaintiff ri! LIJ-C 1�II.Y THE PROTH!ONO TAI i' 2614 DEC 10 P11 2: 39 CUMBERLAND COUNTY TERRY S. DOEBLINNSYLVANIA Plaintiff v. LAURIE DOEBLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-3513 CIVIL ACTION — LAW IN DIVORCE Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: a/c' 111-1 LAURIE DOEBLER Carrucoli & Associates, P.C. 875 Market Street Lemoyne, PA 17043 (717) 761-1274 Attorney for Plaintiff TERRY S. DOEBLER, Plaintiff v. LAURIE DOEBLER, Defendant � DECP� a1 n. 3S3Sr`:il 1 S 19 3• c,'4PE.t, NP SYLVA A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Oa -Q551. CIVIL ACTION — LAW IN DIVORCE PROOF OF SERVICE I, Cindy L. Villanella, Esq., Counsel for the Plaintiff, Terry S. Doebler, hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant, Laurie Doebler, via Certified First Class Mail. A copy of the Acceptance of Service is attached. Date: and - i el a, Esq. Sup 'eme s • ID 202325 C. rucoli & Associates, P.C. 875 Market Street Suite 100 Lemoyne, PA 17043 (717)761-1274 SENDER: COMPLETE THIS SECTION. • Complete Items 1, 2, and 3. Also complete item 4 If Restricted Delivery Is desired. • Print your name and address on the reverse so that we can return the card to you. 14 U. Attach Os card to the back of the mallpiece.': or on the front if space permits. 1. Article Addressed to: cmr 6 oe.b\Ve- 305 oloin44 rzook. Ccx, Va\ I-70 13 COMPLETE THIS SECTION ON DELIVERY A. Signature X B. Received by ( Printed Name) LftutG O 0 Agent , 0 Addressee C. Date of Delivery D. Is delivery address different from Item 1? 0 Yes If YES, enter delivery address below: 0 No • Service Type 0 Certified Mail 0 Registered O Insured Mall O Express Mall 0 Retum Receipt for Merchandise O C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Transfer from service label) 7007 2680 0001 8109 8922 - PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 Attorney for Plaintiff TERRY S. DOEBLER, Plaintiff v. LAURIE DOEBLER, Defendant 1 L. t th 2L15 J1,11 —9 PO 2: 5 s! CUMBERLAND COUP,TY PENNS "LV Ri HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-3513 CIVIL ACTION — LAW IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made and concluded as of the day of , 2014, by and between Terry S. Doebler (hereinafter referred to as "Husband"), and Laurie Doebler (hereinafter referred to as "Wife"), being of, and consenting to, for all purposes of jurisdiction concerning this Agreement, the Commonwealth of Pennsylvania. ARTICLE I STATUS OF PARTIES 1.01. Date of Marriage. The parties were married on April 13, 1979 in Hickorytown, Pennsylvania and ever since that date have been and now are husband and wife. 1.02. Children of the Parties. There were two children born of this marriage. Jason Doebler Abbey Doebler Born: January 17, 1985 Born: July 21, 1989 1.03. Separation of Parties. Unhappy differences have arisen between the parties, and as a result, the parties have separated. Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff ARTICLE II ENFORCEABILITY, CONSIDERATION, AND PURPOSE OF AGREEMENT 2.01. Intent to Live Apart. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this agreement to set forth the respective rights and duties of the parties. 2.02. Settlement of Property. The parties are desirous of settling completely the economic and other rights and obligations between each other including, without limitation: the ownership and equitable distribution of marital property; the past, present and future support, alimony, alimony pendente lite and/or maintenance of either of them; and in general, all other claims and possible claims by one against the other or against their respective estates. 2.03. Enforceability and Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall be forever binding and conclusive on the parties, and independent legal action may be brought to enforce the terms of this Agreement by either Husband or Wife until it shall have been fully satisfied and performed. 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. This agreement will become effective and binding upon both parties upon execution of this agreement by both parties. ARTICLE III DIVISION OF PROPERTY/DEBT 3.01. Real Estate: The following constitutes all the real estate owned by the parties of this agreement: Real Estate located at 305 Bonnybrook Road, Carlisle, Pennsylvania. 2 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff Both parties agree that Wife has secured financing to remove Husband's name from the marital residence, and at the time of settlement shall pay to Husband $19,502.73, which represents forty percent (40%) of the equity in the home. Wife shall pay the above amount to Husband within ten (10) days of settlement and such payment shall be in one lump sum. Both parties agree that this amount takes into consideration Husband's half of the martial debt, equaling $5,000.00. 3.02. Remainder of Property. The parties have divided all the rest, residue and remainder of property owned by them to their mutual satisfaction, the personal effects, household furniture and furnishings, any stocks, bonds, or other securities, savings or checking accounts, certificates of deposit, money market funds and all other articles of personal property and each party shall retain such property as his or her sole and separate property, except as provided for in this Agreement. 3.03. 401(k) and Retirement Accounts. Except as otherwise herein provided, each party hereto releases the other from any and all claims regarding each parties stocks, bonds, or other securities, savings or checking accounts, certificates of deposit, money market funds, any and all bank accounts, pensions, 401(k)s, IRAs or other retirement assets. Each party shall retain such property as his or her sole and separate property, retirement accounts and/or 401(k)s. 3.04. Marital Debt. Husband and Wife agree that Husband has paid to Wife $5,000.00, representing half of the martial debt (see paragraph 3.01). Wife shall immediately pay off and close any and all credit cards in joint names. Except as otherwise herein previously addressed, any and all debt currently in a parties' name shall be the sole responsibility of that party. Both parties have made a full disclosure of any debts in his or her name and hereby warrant that he or she has not caused and will not cause a debt in the other's name. 3 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff ARTICLE IV GENERAL PROVISIONS 4.01. General Release of All Claims. Except as otherwise herein provided, each party hereto releases the other from all claims, liabilities, debts, obligations, actions and causes or action of every kind that have been incurred relating to or arising from the marriage between the parties. Each party hereby releases the other from any right which each may have had, may have or may hereafter have, as against the other including but not limited to spousal support or maintenance, alimony, alimony pendente lite, counsel fees other than those enumerated in this Agreement, costs or expenses other than those enumerated in this Agreement, and equitable distribution, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach thereof. It is the intention of the parties to give to each other by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real or personal or mixed, which the other owns or may hereafter acquire and a determination of any and all other ancillary matters which may be asserted pursuant to the. Pennsylvania Divorce Code of 1980, as amended, except as to the right of either party to prosecute an action for divorce subject however, to the implementation and satisfaction of the conditions as set forth in this Agreement. 4.02. Waiver of Estate Claim. Except as otherwise herein provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all right 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 martial relationship including, without limitation, dower, thirds, courtesy, allowance, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of the other, and right to act as administrator/executor of the other's estate and each party will, at the request of the other, execute, acknowledge and 4 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff 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. The parties waive and release any and all rights to the other's estate, including the rights of set-off, any and all distributive shares and any and all rights of election provided for by the laws of this or any other state or jurisdiction. 4.03. Spousal Support, Alimony & Alimony Pendente Lite. Each party waives any and all right to receive payments on account of spousal support, maintenance, alimony pendent lite, alimony, counsel fees or costs or any other payments of a similar nature to which he or she, in the absence of this Agreement, might be entitled by statute, including rights arising pursuant to the Divorce Code of 1980, as amended, or any similar laws of any jurisdiction which may be applicable now or at any time in the future. 4.04. Indemnification. Each party represents and warrants to the other that he or she will not incur any debt, obligation or other liability, other than those already described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that if any claim, action, or proceeding is hereafter initiated seeking to hold the other party liable for any other debt, obligation, liability, act or omission of such party, such party will, at his or her sole expense, defend the other against any claim or demand, whether or not well-founded, and that he or she will indemnify or hold harmless the other party in respect to all damages resulting therefrom. 4.05. Execution of Documents. Each party shall, at the request of the other party, properly execute any and all documents which may require their signature for the purpose of effectuating all of the terms and conditions of this agreement so as to give full force and effect to this agreement. The parties further agree to sign Affidavits of Consent and Waivers of Notice in conjunction with this agreement and filed with Cumberland County Prothonotary within ten (10) days of signing such documents so that the divorce may be finalized. 5 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff 4.06. Right to Live Separately and Free from Interference. Each party shall live separately and apart from the 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 use, ownership, enjoyment or disposition of any property now owned or hereafter acquired by the other. 4.07. Agreement Voluntary and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she, respectively: (1) Is fully and completely informed as to the facts relating to the subject matter of this Agreement and as to the rights and liabilities of both parties; (2) Has received full disclosure of all assets and the value of all assets, whether marital or non -marital of the other party; (3) Enters into this Agreement voluntarily with the opportunity of receiving the advice of independent counsel; (4) Has given careful and mature thought to the making of this Agreement; (5) Has carefully read each provision of this Agreement; (6) Fully and completely understand each provision of this Agreement, both as to the subject matter and legal effect. 4.08. Default, Costs, Expenses and Fees. If either party fails in the due performance of any of his or her material obligations hereunder, the other party shall have the right, at his or her election, to sue for damages for breach hereof or seek such other legal remedies as may be available to him or her. Nothing herein contained shall be construed to restrict or impair the other party's right to exercise this election. Each party agrees to pay all attorney's fees, costs, damages or collateral expenses that the other spouse may sustain or incur in any way whatsoever as a consequence of any default or breach by the other spouse of any of the terms or 6 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff provisions of this agreement, providing that the party who seeks to recover such fees, costs, expenses and damages, clearly demonstrates that a breach has in fact occurred. It is the specific agreement and intent of the parties that a breaching and wrong doing party • shall bear the burden and obligations of any costs, expenses, damages and fees incurred by himself or herself, as well as the other party in endeavoring to protect, enforce and preserve his or her rights under this Agreement. 4.09. Amendment or Modification. This Agreement may be amended or modified only by a written instrument signed by both parties. 4.10. Effect of Divorce Decree. The parties agree that 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, and shall continue in full force and effect, irrespective or whether the parties obtain a divorce. Husband and Wife agree that the terms of this Agreement may be incorporated into any divorce decree which may be entered with respect to the parties, but in any event shall not merge into the divorce decree and said agreement shall survive the divorce decree. 4.11. Partial Invalidity. 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 continue in full force, effect and operation; provided said provision is not essential to the meaning and basis of this Agreement and/or constitutes consideration for either party's agreement and promises. 4.12. Entire Agreement, Merger and Integration. Husband and Wife do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth in the preamble herein above; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforce or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any 7 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff term, condition, clause or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. 4.13. Binding Effect of Agreement. 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 not be construed as a waiver of any subsequent default of the same or similar nature. In the event either party has to go to court to enforce the provisions of this Agreement, the prevailing party shall be entitled to reimbursement of attorney's fees and court costs. 4.14. Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding on and inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors in interest of the parties. 4.15. Law Governing Agreement. This Agreement shall be governed by, and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties hereto, have hereunto set their hands and seals the day and year first above written. WITNESS: *//Lt:// LAURIE DOEBLER 8 Cindy L. Villanella, Esquire Carrucoli & Associates, P.C. 875 Market Street Suite 200 Lemoyne, PA 17043 (717)761-1274 Attorney for Plaintiff COMMONWEALTH OF COUNTY OF Hernia) On this, the 3 day of vA • • : SS: 002". , 2014, before me, the undersigned personally appeared TERRY S. DOEBLER, Plaintiff, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that they executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF 44 COUNTY OF NiVIA-btri"d On this, the Q day of ( bAA- 2014, before me, the undersigned personally appeared LAURIE DOEBLER, Defendant, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that they executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (SEAL) : SS: • • CINDY C. ADAMS Notary Public Commonwealth of Virginia 7337099 My Commission Expires Oct 31, 2014 COMMONWEALTH OF PENNSYLVANI NOTARIAL SEAL Tammie L. Crutcher, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept 9, 215 ME 8 It PENNSYLVANIA ASSOCIATION OF NOTAN 9 Terry S. Doeber vs. Laurie. Doebter http://www.ccpa.net/DocumentCenter/View/... : IN TILECOURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No, 09-3513 CIVIL TERM: PEA1CIPE TO TRANSMIT RECORD To the Prothonotary: C-11 rnC3 c— Transmit the record, together with the following infomiation, to the court for entry of a •dif4rer'd decree: c-> (.11 1. Ground for divorce: Irretrievable breakdown under § (330!(c)) end -- (Strike out inapplicable section.) 2, Date and manner of service of the complaint: 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 October 3, 2014 ; by defendant December 9, 2014 (b) () :Date of execution of the affidavit 'required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiffs § 3301(d) affidavit upon the respondent opposing party: 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 plaintiffs Waiver of Notice was filed with the Prothonotary: October 30, 2014 Date defendant's Waiver of Notice was filed with the Prothonota December 10.2014 AJArlrarig) fci1577ndt ' 441‘4' Page 1 of 1 2014-12-19 11:03 Terry S. Doebler : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA • V. • • Laurie Doebler • NO. 09-3513 DIVORCE DECREE AND NOW, /// (bte_d--- , 026 , it is ordered and decreed that Terry S. Doebler plaintiff, and Laurie Doebler , 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.") None. By the Court, Atst: J. 1 ,e, _ • Prothonotary Cert Lvpg rnai1 k Vi ltanelia Nahce + l.'opq Yi\ai lel k a i uhi Gtbet