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HomeMy WebLinkAbout10-2413APRIL SHERWOOD, Plaintiff V. DAVID SHERWOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. to - ayQ : 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 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 on the first floor of the Cumberland County Courthouse, Carlisle, Cumberland County, 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Court Administrator at (717) 780-6624. A llfaarg?rtnts must be made at least 72 hours prior to any hearing or business -Plno before the Court. 43sa.od - LAik. car S`'z3 Melanie L. Erb, Esquire 2132 Market Street Camp Hill, PA 17011 717-975-9446 MerbLoDdcdlaw.net APRIL SHERWOOD, Plaintiff V. DAVID SHERWOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, April Sherwood, by and through her attorney, Melanie L. Erb, Esquire and the Dethlefs-Pykosh Law Group, LLC, who brings this Complaint in Divorce and avers as follows: Plaintiff is April Sherwood, an adult individual currently residing at 3013 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is David Sherwood, an adult individual currently residing at 3009 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff avers that Defendant has also been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. I 5. The parties were married on September 3, 1988 in Burlington County, New Jersey. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken 8. The parties have been separated since March 20, 2006. 9. Plaintiff avers that neither party is an active member of the United States Military or its allies. 10. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff waives that right. 11. Plaintiff avers that Defendant has been advised of the availability of counseling and that Defendant may have the right to request that the Court require the parties to participate in counseling. 12. Plaintiff avers the grounds for divorce: a. The marriage is irretrievably broken; b. The parties consent to the divorce; or in the alternative, c. The parties have lived separate and apart for a period or two (2) years. WHEREFORE, Plaintiff, April Sherwood, respectfully requests this Honorable Court grant a Decree in Divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. Respectfully Submitted, Mel? iie.-L. Erb, Esquire Attornev I.D. No. 84445 The Law Offices of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 717-975-9446 Attorney for Plaintiff . • VERIFICATION I, APRIL SHERWOOD, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. I 1/o ?" go,, 141W AP L S E WOOD -l - ID DATE APRIL SHERWOOD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 10-02413 DAVID SHERWOOD, CIVIL ACTION–LAW Defendant IN DIVORCE C > ENTRY OF APPEARANCE r- N t' TO THE PROTHONOTARY: N) Kindly enter my appearance on behalf of the Defendant, David Sherwood, in the above- captioned matter. Respectfully submitted, 1C, H " J n M. Kerr, Esquire Attorney I.D.#26414 John Kerr Law, P.C. 5020 Ritter Road Suite 104 Mechanicsburg, PA 17055 (717)766-4008 Dated:April 2, 2013 5020 Ritter Road Suite 104 McCb8tliCSbUfg,PA 17055 PHotve: 717.766.4008 Rnx: 717.766.4066 CERTIFICATE OF SERVICE The undersigned hereby certifies that he has served a copy of the foregoing, "Entry of Appearance," on the below-named individual in the manner indicated: First-Class Mail, Postage Prepaid: Melanie Erb, Esquire 2132 Market Street Camp Hill, PA 17011 John M. Kerr, Esquire 5020 Ritter Road Suite 104 Mechanicsburg, PA 17055 (717)766-4008 Dated:April 2, 2013 �ohn�,rr aw.PC 5020 Ritter Road Suite 104 Mechanicsburg,PA 17055 PHONE: 717.766.4008 FAx: 717.766.4066 APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 10-02413 DAVID SHERWOOD, : CIVIL ACTION—LAW Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE rnrn r 1. Check either(a)or(b): �' 770 . v/(a) I do not oppose the entry of a divorce decree. --0 - :CD :< (b) I oppose the entry of a divorce decree because (check(i),(ii)or both): c z) (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either(a)or(b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property,lawyer's fees or expenses or other important rights. I 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 to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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 nalties o 18 Pa.C.S. §4904,relating to unworn falsification to authorities. DATE: :� 7413 David Sherwood, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counteraffidavit. r APRIL SH � |N THE COURT QFCOMMON PLE4 C= -� _ + Plaintiff CUMBERLAND COUNTY, PEN --r- ' -� ; °* r�r- � NO. 10"02413 ^�r- , �or' °' CD . � CIVIL ACTION-LAW r� �� C)-� � IN DIVORCE N) /n�' DAVDSHERVVOOO` � - . Defendant DEFENDANT DAVID SHERWOOD'S STATEMENT OF ECONOMIC CLAIMS AND NOW,comes David Sherwood(hereinafter,°Husband°\ Oefendantinthe above-captioned matter, by his counsel,John M. Kerr,Esquire, pursuant to Pa.R.Civ.p. 1920.42(d)(2Landfiles the within Statement of Economic Claims accompanying his Counter- Affidavit under§33D1(6)ofthmDivmrce{ome, mepreoentingaaho|kovvo: 1. The parties,April and David Sherwood,'are the owners of certain real estate with improvements located at 3013 Lisburn Road,Mechanicsburg, Pennsylvania 17055. 2' This real estate served as the marital home. 3. For a period of fifteen(15)years, Husband contributed to paying the mortgage. 4. Husband believes the real estate 10 have a market value uf$18O.00'0O. .WHEREFORE, Husband requests that said real estate be equitably divided as part of the present divorce proceedings. Respectfully yours, ohn PC: 5020 Wter Road Sufte 104 Mechardcsburg.PA j 705s ° m°sm. r/rrmz*ouo Esquire pAx. r'z,nn.wxM Attorney|.D.#26414 John Kerr Law, P.C. 5O2O Ritter Road,Suite 1O4 Mechanicsburg, PA17O5S (717)766-4008 Dated: April 8,2013 CERTIFICATE OF SERVICE The undersigned hereby certifies that he has served a copy of the foregoing, "Defendant David Sherwood's Statement of Economic Claims,"on the below-named individual in the manner indicated: First-Class Mail, Postage Prepaid Melanie L. Erb, Esquire Dethlefs-Pykosh Law Group, LLC. 2132 Market Street Camp Hill, PA 17011 J n M. Kerr, Esquire 5020 Ritter Road Suite 104 Mechanicsburg, PA 17055 (717)766-4008 Dated:April 8, 2013 �ohn I<err aw,PC 5020 Ritter Road State 104 Medkinl(SbU[g,PA 17055 Pram: 717.766.4008 FAx: 717.766.4066 APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSV4Nlik.-> v. : NO. 10-02413 zx -�7 rn -_ z dirt DAVID SHERWOOD, : CIVIL ACTION — LAW .�A ‘..0 a Defendant : IN DIVORCE cc n z • MARITAL SETTLEMENT AGREEMENT _.. THIS AGREEMENT, made this ,tct- day of 3 .1� ,� , 20 I " , by and between DAVID SHERWOOD (hereinafter referred to as "Husband") and APRIL SHERWOOD (hereinafter referred to as "Wife"). WHEREAS, Husband and Wife were married on September 8, 1988 in Mechanicsburg, Cumberland County, Pennsylvania; and WHEREAS, As a consequence of disputes and unhappy differences, the parties have separated. The parties desire to confirm their separation and make arrangements in connection therewith, including the settlement of their property rights, and all other rights and obligations arising out of the marriage relationship; and WHEREAS, Parties desire to completely settle their property rights, separation of their marital and non-marital, real and personal, belonging to each and/or both of the parties hereto and all other rights, entitlements, benefits, and privileges involved between the parties hereto arising directly or indirectly out of the marriage relationship; and WHEREAS, Parties have had adequate time and opportunity to consult with separate legal counsel of their own; and WHEREAS, Wife has retained the Dethlefs-Pykosh Law Group, LLC as her separate counsel; and WHEREAS, Husband has retained John Kerr Law, PC as his separate counsel; and WHEREAS, both Parties acknowledge that they are satisfied with the legal advice they have received and/or the opportunity to consult legal counsel and understand the full importance of the Agreement they are entering into; and NOW THEREFORE, in consideration of the promises and of the marriage, and in further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. SEPARATION AND NONINTERFERENCE A. It will be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. B. Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 2. MUTUAL 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 and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against the other, except any or all cause 2 or causes of action for divorce. 3. FULL DISCLOSURE The provisions of this Agreement and their legal effect are fully understood by each party to this agreement, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Husband and wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever and of all other facts relating to the subject matter of this Agreement. Both parties represent that the terms of this Agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this Agreement. 4. EQUITABLE DIVISION By this Agreement, the parties have intended to effect an equitable division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 5. SUBSEQUENT DIVORCE A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or 3 actions for divorce upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or from making any just or proper defense thereto. 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 Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole or in part. Husband and wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever by stopped from asserting any illegality or unenforceability as to all or any part of this Agreement. B. ENTRY AS PART OF DECREE - It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purpose of enforcement only. The parties mutually agree that this Agreement shall not be filed with the Prothonotary to protect the privacy of the parties regarding financial matters unless there becomes a need to enforce the Agreement. C. MUTUAL CONSENT DIVORCE - The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section 4 3301(c). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent permitted by law and the applicable Rules of Civil Procedure, the named Defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 6. EQUITABLE DISTRIBUTION PAYMENT The parties agree that Wife shall transfer to Husband, a payment of $23,500.00 upon the sale of the marital residence located at 3013 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania. 7. DIVISION OF PERSONAL PROPERTY The parties agree that Husband and Wife have previously divided, to their mutual satisfaction, the possessions contained in the marital residence. 8. VEHICLES Wife shall retain possession of the motor vehicle(s) that is currently in her possession. Husband shall retain possession of the motor vehicle(s) that is currently in his possession. The parties agree to cooperate with the transfer of titles of the vehicles to the party specified in this agreement. The parties agree that each shall be responsible for all expenses and liabilities associated with their respective motor vehicles. The parties shall indemnify and hold the other harmless for failure to pay. Each party agrees to waive any right, title and interest in the other parties' vehicle. 9. LIABILITIES 5 The parties mutually agree that each shall be solely liable for any and all debt in either in his or her name except as set forth in this Agreement. Husband and Wife agree that each shall be responsible for personal debt in their own name, unless otherwise indicated in this Agreement. Each shall identify and hold the other harmless for failure to pay such debts. 10. AFTER-ACQUIRED PERSONAL PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her after date of separation, 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. 11. DISPOSITION OF PROPERTY From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her 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 acauired 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. 12. REAL ESTATE As of the date of the execution of this Agreement, the parties shall transfer and assign their rights, title, claim and interest in specific property. The parties' marital residence located at 3013 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania, shall become now and forever the sole property of 6 Wife. Both parties agree that any and all inheritances from Wife's grandfather and Wife's mother, including any increase in value on said inheritances, shall be deemed the separate property of Wife and shall not be subject to equitable distribution. Wife shall promptly list for sale the marital residence for a price solely determined by Wife, any proceeds shall be divided as follows: a. Wife shall be fully reimbursed for the inheritance funds that she used to payoff of the first mortgage; and b. Wife shall be fully reimbursed for the inheritance funds that she used to payoff of the second mortgage; and c. Any and all settlement charges shall be deducted from the proceeds of the sale; and d. Husband shall receive the sum of$23,500.00; and e. Any remaining proceeds, if any, shall be the Wife's property. Husband agrees to now and forever relinquish all rights and interest whether in law or equity in the marital residence and Wife's aforementioned inheritances now and in the future, except as provided herein, and shall cooperate in completing any documents required by the mortgage holder, Wife, or any other entity to accomplish the intent of this Agreement. Wife shall be responsible for paying all taxes, costs, fees associates with said property. Wife agrees to indemnify and hold Husband against any loss or liability resulting from the ownership of said property. Such agreement shall be binding on all heirs, executors, administrators or assigns of Husband. 7 13. COUNSEL FEES The parties mutually agree to be solely responsible for payment of his or her attorney fees in connection with this Agreement and any future divorce action. 14. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT The parties mutually agree that, being aware of the income, education, income potential and assets and holdings of the other or having the opportunity to discover such information, each shall waive any and all past, present or future claims for spousal support, alimony pendente lite, and alimony. 15. PENSION and EMPLOYMENT BENEFITS Wife hereby releases any other interest that she has in the retirement and employment benefits of Husband accumulated as the result of his employment and any other additional benefits he may have accrued, except as set forth in this Agreement. Husband hereby releases any interest that he has in the retirement benefits of Wife accumulated as the result of her employment and any other additional benefits she may have accrued. This waiver is a full and complete discharge of each party's marital claim. The parties agree to execute any and all documents necessary to effectuate the terms herein contained. 16. TAX RETURNS The parties mutually agree that they will file separate federal, state and local tax returns unless otherwise mutually agreed upon. 17. MISCELLANEOUS The parties believe and agree, that the division of property hereto made by this Agreement is a non-taxable sale or exchange of such property. Each party promises not 8 to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. 18. LEGAL ADVICE The provisions of this agreement and their legal effect have been fully explained to the parties by their respective counsel. The wife has employed and had the benefit of counsel of Darrell C. Dethlefs, Esquire, as her attorney. The Husband has employed and had the benefit of counsel of John Kerr, Esquire as his attorney. Each party acknowledges that he or she fully understands the facts and fully understands his or her legal rights and obligations and each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of the agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The respective parties do hereby warrant, represent and declare and do acknowledge and agree that each is and has been fully and completely informed of and is familiar with and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statement thereof in this agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and further agrees for himself and herself and his or her heirs, executors, administrators and assigns, that he or she will never at any time sue the other party or his or her heirs, 9 executors, administrators or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full disclosure or that there was any absence or lack of full, proper or independent representation. 19. GENERAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS - Each party represents that 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 or hold the other party harmless from 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, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at all times hereafter save harmless and keep the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. C. SEVERABILITY - If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions 10 precedent, shall in no way void or alter the remaining obligations of the parties. D. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they will forthwith execute any and all written assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. E. ENTIRE AGREEMENT-This Agreement contains the entire understanding of the parities, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. F. WAIVER OR MODIFICATION TO BE IN WRITING - No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. G. MUTUAL COOPERATION - Each party shall, at any time and from to time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. I. BINDING EFFECT - Except as otherwise stated herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. 11 J. NO WAIVER OF DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. K. HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or referenced and shall not constitute a part of this Agreement nor shall they affect its meaning, construction, or effect. L. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein otherwise provide, 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 have or hereafter acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, their statutory equivalents, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of other, and right to act as administrator or executor of the other's estate, and 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 interests, rights and claims. M. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that either party 12 breaches any provision of this Agreement, and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay for all reasonable attorney's fees, court costs, and expenses incurred by the other party in enforcing the Agreement. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the"Ask- day of J^- -°! , 20 s k In the presence of: Aril herwood, Plaintiff April David Sherwood, Defendant 13 APRIL SHERWOOD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO: 10 - 2413 CIVIL DAVID SHERWOOD, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 6 "', day of 2014, the economic claims raised in the proceedings having been resolved in accordance with a marital settlement agreement dated January 20, 2014 , the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, K in A. Hess, P.J. CC: �Melanie L. Erb At orney for Plaintiff John M. Kerr � Attorney for Defendant T 3= `" -;CD APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSY-�_VANIAc:: V. : NO. 10-02413 zW � ,�?r z:z - ; DAVID SHERWOOD, : CIVIL ACTION — LAW �'�� Q° Defendant : IN DIVORCE <o MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of 20 I`' by and between DAVID SHERWOOD (hereinafter referred to as "Husband") and APRIL SHERWOOD (hereinafter referred to as "Wife"). WHEREAS, Husband and Wife were married on September 8, 1988 in Mechanicsburg, Cumberland County, Pennsylvania; and WHEREAS, As a consequence of disputes and unhappy differences, the parties have separated. The parties desire to confirm their separation and make arrangements in connection therewith, including the settlement of their property rights, and all other rights and obligations arising out of the marriage relationship; and WHEREAS, Parties desire to completely settle their property rights, separation of their marital and non-marital, real and personal, belonging to each and/or both of the parties hereto and all other rights, entitlements, benefits, and privileges involved between the parties hereto arising directly or indirectly out of the marriage relationship; and WHEREAS, Parties have had adequate time and opportunity to consult with separate legal counsel of their own; and WHEREAS, Wife has retained the Dethlefs-Pykosh Law Group, LLC as her separate counsel; and WHEREAS, Husband has retained John Kerr Law, PC as his separate counsel; and WHEREAS, both Parties acknowledge that they are satisfied with the legal advice they have received and/or the opportunity to consult legal counsel and understand the full importance of the Agreement they are entering into; and NOW THEREFORE, in consideration of the promises and of the marriage, and in further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. SEPARATION AND NONINTERFERENCE A. It will be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. B. Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 2. MUTUAL 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 and discharge the other of and from all causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against the other, except any or all cause 2 or causes of action for divorce. 3. FULL DISCLOSURE The provisions of this Agreement and their legal effect are fully understood by each party to this agreement, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Husband and wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever and of all other facts relating to the subject matter of this Agreement. Both parties represent that the terms of this Agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this Agreement. 4. EQUITABLE DIVISION By this Agreement, the parties have intended to effect an equitable division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 5. SUBSEQUENT DIVORCE A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or 3 actions for divorce upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or from making any just or proper defense thereto. 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 Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole or in part. Husband and wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever by stopped from asserting any illegality or unenforceability as to all or any part of this Agreement. B. ENTRY AS PART OF DECREE - It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purpose of enforcement only. The parties mutually agree that this Agreement shall not be filed with the Prothonotary to protect the privacy of the parties regarding financial matters unless there becomes a need to enforce the Agreement. C. MUTUAL CONSENT DIVORCE - The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section 4 3301(c). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent permitted by law and the applicable Rules of Civil Procedure, the named Defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 6. EQUITABLE DISTRIBUTION PAYMENT The parties agree that Wife shall transfer to Husband, a payment of $23,500.00 upon the sale of the marital residence located at 3013 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania. 7. DIVISION OF PERSONAL PROPERTY The parties agree that Husband and Wife have previously divided, to their mutual satisfaction, the possessions contained in the marital residence. 8. VEHICLES Wife shall retain possession of the motor vehicle(s) that is currently in her possession. Husband shall retain possession of the motor vehicle(s) that is currently in his possession. The parties agree to cooperate with the transfer of titles of the vehicles to the party specified in this agreement. The parties agree that each shall be responsible for all expenses and liabilities associated with their respective motor vehicles. The parties shall indemnify and hold the other harmless for failure to pay. Each party agrees to waive any right, title and interest in the other parties' vehicle. 9. LIABILITIES 5 The parties mutually agree that each shall be solely liable for any and all debt in either in his or her name except as set forth in this Agreement. Husband and Wife agree that each shall be responsible for personal debt in their own name, unless otherwise indicated in this Agreement. Each shall identify and hold the other harmless for failure to pay such debts. 10. AFTER-ACQUIRED PERSONAL PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her after date of separation, 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. 11. DISPOSITION OF PROPERTY From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her 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. 12. REAL ESTATE As of the date of the execution of this Agreement, the parties shall transfer and assign their rights, title, claim and interest in specific property. The parties' marital residence located at 3013 Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania, shall become now and forever the sole property of 6 Wife. Both parties agree that any and all inheritances from Wife's grandfather and Wife's mother, including any increase in value on said inheritances, shall be deemed the separate property of Wife and shall not be subject to equitable distribution. Wife shall promptly list for sale the marital residence for a price solely determined by Wife, any proceeds shall be divided as follows: a. Wife shall be fully reimbursed for the inheritance funds that she used to payoff of the first mortgage; and b. Wife shall be fully reimbursed for the inheritance funds that she used to payoff of the second mortgage; and C. Any and all settlement charges shall be deducted from the proceeds of the sale; and d. Husband shall receive the sum of$23,500.00; and e. Any remaining proceeds, if any, shall be the Wife's property. Husband agrees to now and forever relinquish all rights and interest whether in law or equity in the marital residence and Wife's aforementioned inheritances now and in the future, except as provided herein, and shall cooperate in completing any documents required by the mortgage holder, Wife, or any other entity to accomplish the intent of this Agreement. Wife shall be responsible for paying all taxes, costs, fees associates with said property. Wife agrees to indemnify and hold Husband against any loss or liability resulting from the ownership of said property. Such agreement shall be binding on all heirs, executors, administrators or assigns of Husband. 7 13. COUNSEL FEES The parties mutually agree to be solely responsible for payment of his or her attorney fees in connection with this Agreement and any future divorce action. 14. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT The parties mutually agree that, being aware of the income, education, income potential and assets and holdings of the other or having the opportunity to discover such information, each shall waive any and all past, present or future claims for spousal support, alimony pendente lite, and alimony. 15. PENSION and EMPLOYMENT BENEFITS Wife hereby releases any other interest that she has in the retirement and employment benefits of Husband accumulated as the result of his employment and any other additional benefits he may have accrued, except as set forth in this Agreement. Husband hereby releases any interest that he has in the retirement benefits of Wife accumulated as the result of her employment and any other additional benefits she may have accrued. This waiver is a full and complete discharge of each party's marital claim. The parties agree to execute any and all documents necessary to effectuate the terms herein contained. 16. TAX RETURNS The parties mutually agree that they will file separate federal, state and local tax returns unless otherwise mutually agreed upon. 17. MISCELLANEOUS The parties believe and agree, that the division of property hereto made by this Agreement is a non-taxable sale or exchange of such property. Each party promises not 8 to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. 18. LEGAL ADVICE The provisions of this agreement and their legal effect have been fully explained to the parties by their respective counsel. The wife has employed and had the benefit of counsel of Darrell C. Dethlefs, Esquire, as her attorney. The Husband has employed and had the benefit of counsel of John Kerr, Esquire as his attorney. Each party acknowledges that he or she fully understands the facts and fully understands his or her legal rights and obligations and each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of the agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The respective parties do hereby warrant, represent and declare and do acknowledge and agree that each is and has been fully and completely informed of and is familiar with and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statement thereof in this agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and further agrees for himself and herself and his or her heirs, executors, administrators and assigns, that he or she will never at any time sue the other party or his or her heirs, 9 executors, administrators or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full disclosure or that there was any absence or lack of full, proper or independent representation. 19. GENERAL PROVISIONS A. WARRANTY AS TO EXISTING OBLIGATIONS - Each party represents that 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 or hold the other party harmless from 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, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at all times hereafter save harmless and keep the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. C. SEVERABILITY - If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions 10 precedent, shall in no way void or alter the remaining obligations of the parties. D. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they will forthwith execute any and all written assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. E. ENTIRE AGREEMENT-This Agreement contains the entire understanding of the parities, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. F. WAIVER OR MODIFICATION TO BE IN WRITING - No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. G. MUTUAL COOPERATION - Each party shall, at any time and from to time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. I. BINDING EFFECT - Except as otherwise stated herein, this Agreement .shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. 11 J. NO WAIVER OF DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. K. HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or referenced and shall not constitute a part of this Agreement nor shall they affect its meaning, construction, or effect. L. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein otherwise provide, 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 have or hereafter acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, their statutory equivalents, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of other, and right to act as administrator or executor of the other's estate, and 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 interests, rights and claims. M. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that either party 12 breaches any provision of this Agreement, and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay for all reasonable attorney's fees, court costs, and expenses incurred by the other party in enforcing the Agreement. IN WITNESS WHEREOF, and intending to be bound hereby, the parties have signed and sealed this Agreement on the day of In the presence of: April herwood, Plaintiff David Sherwood, Defendant 13 APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS ri4 Plaintiff : CUMBERLAND COUNTY, PENNS gVA4111A=z ®rn r*'t v. : NO. 10-02413 tee _r_N • CD - :rt < '"C,'"C,DAVID SHERWOOD, : CIVIL ACTION—LAW Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(D) 1. A Complaint in Divorce under Section 3301(d) of the Divorce Code was filed on April 12, 2010. 2. The parties to this action separated on March 20, 2006 and have continued to live separate and apart for a period of at least two years. 3. The marriage of the Plaintiff and Defendant is irretrievably broken. 4. 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. 5. 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. Section 4904, relating to unsworn falsification to authorities. Date: .2-(p 4 t, April erwood, 'laintiff APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 10-02413 DAVID SHERWOOD, : CIVIL ACTION—LAW Defendant : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without Notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers' 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. Section 4904, relating to unsworn falsification to authorities. Date: 02 _.. � /L_/�._ .I%/.'l y/� April r/erwood P aintiff Ap S , c;4 nr r f. crl CD APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBLERAND COUNTY, PENNSYLVANIA v. c) ,, ., c.., : NO. 10- 02413' -� .c- DAVID SHERWOOD, : IN DIVORCE cnr , .mom; Defendant : CIVIL ACTION r- z- DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION §3301(c) & (d) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section §3301(c) and (d) of the Divorce Code was filed on April 12, 2010. 2. The marriage of the Plaintiff and the 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. 4. 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. Dated: 15 AP d 2 0 1 David Sherwood, Defendant APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBLERAND COUNTY, PENNSYLVANIIA eD V. erg --1 NO. 10 -02413 73 20 —0 frk DAVID SHERWOOD, • : IN DIVORCE Defendant : CIVIL ACTION 2CS�; .� � C WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) and (d) OF THE DIVORCE CODE 1. I consent to 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. Dated: )5r- 4 r l 20 I c� David Sherwood, Defendant r Darrell C. Dethlefs Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 DDethlefs @aol.com Attorney for Plaintiff APRIL SHERWOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.: 10-02413 DAVID SHERWOOD, : CIVIL ACTION - LAW Defendant, : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301 (D) of the Divorce Code. 2. Date and manner of service of the complaint: USPS First Class Mail, Acceptance of Service signed April 21, 2010 by John M. Kerr, Esquire. Certificate of Service was filed April 26, 2010. 3. Date of execution of the affidavit of consent required by Section 3301 (D) of the divorce code: by plaintiff February 6, 2014 filed on February 19, 2014, by Defendant April 15, 2014, filed April 21, 2014 4. Related claims pending: None. 5. Plaintiffs Waiver of Notice in § 3301 (d) Divorce was filed on April 19, 2014. 6. Defendant's Waiver of Notice in § 3301 (d) Divorce was filed April 21, 2014. Respectful 'ubmitted,_..,, ,- Darrell D.P ethlefs, Esquire Attorney ID No. 58805 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 DDethlefs @aol.com Attorney for Plaintiff : IN THE COURT OF COMMON PLEAS OF APRIL SHERWOOD : CUMBERLAND COUNTY, PENNSYLVANIA • V. •• DAVID SHERWOOD : NO. 10-02413 DIVORCE DECREE AND NOW, /194y / , Z0/*-1 , it is ordered and decreed that APRIL SHERWOOD , plaintiff, and DAVID SHERWOOD , 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, v := Atte.t: J. ` _ Prothonota I PT Cart aop9 mailed -b a-H-4 files I�alite4+copy maOec) Io &+4-9 Kerr hbilec1 5)1) '4