Loading...
HomeMy WebLinkAbout10-3764In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Plaintiff V. Shang L Peery_ Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) ) Term, 2 4 Case Number: Notice to Defend and Claim Rights TO: Shana L Peery t7 n You have been sued in Court. If you wish to defend against the claim 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 child(ren). When the grounds for divorce are indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the prothonotary at , Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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: Lawyer Referral Service (enter address below): jU bt ` c SSA r c? 3X Ea,-f4 3e, 6 d -+ Phone: 7 b a V! j. 1 f- (o -36?2 .00 . 00 ? -2y.3 ?,e- AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service (enter address below): Phone: AMERICANS WITH DISABILITIES ACT OF 1990 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 our office. All arrangements must be made at least seventy-two (72) hours prior to any hearing or business before the Court. You must attend the scheduled conference of hearing. Date: TvA4_k_d ? nt Name (PTaTi 'ff) Signs u n iff) Mailing Address: 15 r Phone: 717-243-6632 ao ?b . Boiling Springs, Pennsylvania, 17007 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Plaintiff V. Term, 2 Case Number: Shang L Peery Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Complaint for Divorce COUNTI REQUEST FOR DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Steven J Peery, who currently resides at 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 2. Defendant is Shana L Peery, who currently resides at 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 3. Steven J Peery (the Plaintiff) has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on May 22, 1993 in the city of Carlisle, in the state of Pennsylvania. Attached hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage. 5. The Defendant is not currently pregnant. 6. The Plaintiff and Defendant are the parents of the following children born, or legally adopted of the marriage under the age of eighteen (18) who are not under the continuing jurisdiction of any other court: The information about the children is as follows: Child #1 Full Name: Sierra Lynn Peery Age: 13 Date of Birth: October 27, 1996 Sex: Female Child #2 Full Name: Maxwell J Peery Age: 9 Date of Birth: July 25, 2000 Sex: Male 7. Military Status: The Plaintiff is not in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. The Defendant is not in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8. There have been no prior actions for divorce or annulment between the parties. 9. There are no protective orders between the Plaintiff and Defendant. 10. The Defendant has been advised of the availability of counseling and the right to request that the Court require the parties to participate in Counseling. 11. The marriage of the parties is irretrievable broken. 12. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce code dissolving the marriage between Plaintiff and Defendant. COUNT II REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTION 3104(A)(1) AND (3) AND 3323(B) OF THE DIVORCE CODE 13. Paragraphs I through 12 are incorporated herein and made part hereof by reference as though fully set forth. 14. Plaintiff and Defendant have reached an agreement on issues including, but not limited to the following; Property and Debt, Retirement Accounts, Spousal Maintenance, Health Insurance, Child Custody, Visitation, Child Support, and Tax Filings. WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate a signed Marital Settlement Agreement reached between Plaintiff and Defendant in the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. Furthermore, the Plaintiff has chosen to act as his own attorney in a pro se fashion, and understands that he has the legal right to repicasentatum- by an attorney. He fully understands his rights and considers the terms of th ies' agre ent to fair, reasonable and in the best interest of the children. Plaintiff VERIFICATION I verify that the statements made in the that false statements mp ? i i unsworn falsification to e are true and correct. I understand 8 Pa. C.S. Section 4904, relating to Plaintiff Date:.3?? D3 , Q /0 . ?U60 2 Print Name (Plaintiff, Pro Se) Mailing Address: 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 Phone: 717-243-6632 I In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Plaintiff V. Shang L Peery Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Term, 2 Case Number ?Q C { re ) Y'n 3 ?6q rr / p I-C Fq Affidavit of Verification THE STATE OF: Pennsylvania COUNTY OF: Cumberland BEFORE ME, Steven J Peery, the undersigned authority and the Plaintiff in the above referenced case, on this day personally appeared who, being by me duly sworn, upon oath says: My name is: Steven J Peery Social Security #: ` Driver's License/ State ID #F: i My mailing address is: 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 Phone:' The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief, and that I am authorized to make this affidavit. Date. ?? u-h? e93 90/0 S RN TO AN C SUBSCRIBED BEFORE ME by the said on this to certifyAh' Ait nd d seal of office. Notar?-Pfflic, State of Notary Seal My commission expires: (! C4- Notarial Seal Kristen Smith, Notary Pu'?Aic S. Middleton, Cumberland County *I cam* aion Expbvs ?H?o14 ? v In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery ) Term, 2 Plaintiff ) V. ) Case Number: Shang L Peery ) Defendant ) N And in the interests of (minor children) ) c?- a , C7 T1 Z t-lrl a q, ZI Sierra Lynn Peery (Age: 13) :? a L Maxwell J Peery (Age: 9) r < 't? COUNSELING NOTICE (Under PA. R.C.P. Rule z 1920.45(a) (1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section Indignities 3301(a) (6) Section 3301 Irretrievable Breakdown (c) Mutual Consent Section 3301 Irretrievable Breakdown (c) Two (2) Year Separation Where the Court Determines That There is a Reasonable Prospect of Reconciliation A list of qualified professionals is available for inspection in the office of the Appointments Clerk of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations Branch of the Family Court of Philadelphia. Date: i L to E Z Print Name (Plaintiff) I - Id In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Plaintiff V. Shang L Peery Defendant And in the interests of (minor children) Term, 2 Case Number: C `= =n -73 t, Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) COUNSELING NOTICE (Under PA. R.C.P. Rule 1920.45(a) (1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a) (6) Indignities Section 3301 Irretrievable Breakdown (c) Mutual Consent Section 3301 Irretrievable Breakdown (c) Two (2) Year Separation Where the Court Determines That There is a Reasonable Prospect of Reconciliation A list of qualified professionals is available for inspection in the office of the Appointments Clerk of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations Branch of the Family Court of Philadelphia. Date: J\' 'C e 1 7 O lCJ Sham- L- Print Name (Defendant) • r Signature (Defendant) In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Mamage of: Steven J Peer Plaintiff V. Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Acceptance of Service Term, 2 Case Number• odd ~©'" ~37~0 C7 G ra o ::~ d ~ ~j ~~.. ..e.. ~7') ~ . ~.~:' ~ "q ~1 ^ ~j mw' C ~ .~' :~ 7 ~,~~ rr '1 I, Shana L Peery, Defendant in the above-captioned action depose and say that on this date I hereby accept service of the Complaint in Divorce and Notice to Defend and Claim Rights with Notice of Availability of Counseling. 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 unswom falsification to authorities. Date: J un P 7 as 1 y shy ~-. ~ ~- Print Name (Defendant) ` ~ V~ )Q(Yl£~. ~~ x\00 (1 ~ ~ Signature (Defendant) ~- Mailing Address: 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 Phone:717-243-6632 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of. Steven J Peery Plaintiff V. Shana L Peery Defendant And in the interests of (minor children) Case Number: O 10-037& Judge: - -? Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) AFFIDAVIT OF CONSENT (Plaintiff THE STATE OF: Pennsylvania COUNTY OF: Cumberland 1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint for Divorce. 3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the Decree of Divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: >'? r? d Print Name (Plaintiff) A In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Plaintiff V. Shana L Peery Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) ) } Term, 2 Case Number: 0610- 0.3 76 q AFFIDAVIT OF CONSENT (Defendant) THE STATE OF: Pennsylvania COUNTY OF: Cumberland M Mrn ? r- f C`? r-n (A 1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on 1 U'-U v r)'7 , "7 0 /Z-) 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint for Divorce. 3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the Decree of Divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to authorities. Date: ; 114 _, u30 t C I el_ Print Name (Defendant) oof? Signature (Defendant) In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery _ Plaintiff V. Shang L Peery _ Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Term, 2 } Case Number: fro - 0 3 76 T1 (r? j Y WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE. (Defendant) THE STATE OF: Pennsylvania COUNTY OF: Cumberland 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, distribution of debts, child custody, visitation, child support, lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court. 3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a copy of the Decree of Divorce 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date:- k2 :)m bcf I d , (3010 Print Name (Defendant) ?\ `?.?1}} awe (Defen?t? ? ? Sim In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery - Plaintiff V. Shana L Peed _ Defendant And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Term, 2 Case Number: ?c/0-037&T 271-6 `-3? r .? f-n WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE. (Plaintiff) THE STATE OF: Pennsylvania COUNTY OF: Cumberland 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, distribution of debts, child custody, visitation, child support, lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court. 3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a copy of the Decree of Divorce 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. l___ Date: _._?)e ioq Lj y 3 c_ Print Name (Plaintiff) 4. Related Claims Pending: None. Date: Mailing Address: 15 Orion fed, Boiling Springs, Pennsylvania, 17007 Phone: 717-243-6632 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Case Number: '190/0 0 3 6 `-) Husband V. Shang L Peery Wife And in the interests of (minor children) Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Judge: C- _71 ti . _ _ `71 Marital Settlement Agreement This agreement is made on 0 ID , between Steven J Peery, the Husband, who lives at 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 and the county of Cumberland and Shana L Peery, the Wife, who lives at 15 Orion Rd, Boiling Springs, Pennsylvania, 17007 and the county of Cumberland. The Husband and Wife may from time to time throughout this agreement, individually and collectively, be referred to as "Party" or "Parties" and "Parent" or "Parents". 1. Recitals: The parties are making this agreement with reference to the following facts: The parties were married on May 22, 1993 in the city of Carlisle, in the state of Pennsylvania, and separated on or about, May 1, 2010. As a result of serious disputes, conflict of personalities, and unique goals and differences, the parties honestly believe that the marriage is irretrievably broken and that there is no possible chance for reconciliation. For this reason each party desires to settle fully and finally all aspects and rights, by this agreement, of the marital affairs including, but not limited to; Property and Debt Distribution, The Marital Home, Retirement/Pension/Profit Sharing/401k Accounts, Spousal Maintenance, Child Custody, Visitation, Child Support, Medical and Health Insurance, Secondary School Expenses, Child care, Tax Exemptions, and Income Tax Returns. The parties each hereby acknowledge that there are 2 children born, or legally adopted of the marriage under the age of eighteen (18). The information about each child is as follows: Child #1 Full Name: Sierra Lynn Peery Age: 13 Date of Birth: October 27, 1996 Sex: Female Child #2 Full Name: Maxwell J Peery Age: 9 Date of Birth: July 25, 2000 Sex: Male The parties each now intend by this agreement to settle fully and finally all of their respective rights and obligations arising out of or related to the marriage that otherwise could be adjudicated in the above captioned case number. There is no other pending action filed by either party regarding the dissolution of the marriage. The date of execution of this agreement is the day on which the agreement is signed by both parties. Any transfer of property, funds, debts and/or documents pursuant to the agreement shall be made on the date of the execution of this agreement, if not already done so, unless otherwise specified in this agreement. The parties both agree to lead separate lives, and, except for the duties and obligations imposed and assumed under this agreement, each shall be free from interference and control of the other as fully as if he or she were single. The parties each agree not to molest, interfere with, or harass the other. 2. Properly and Debt Distribution: As of May 1, 2010, the parties have each possessed his and her marital and non-marital property and have been responsible for the marital and non- marital (separate) debt that will be described below. The parties agree that the following marital property, shall be the sole and separate property of Steven J Peery, the Husband, and Shana L Peery, the Wife transfers and quitclaims any interest that she may have in this marital property to the Husband: 2003 Kia Rio Sectional couch Barbeque Grill Roll top desk 57 inch Hitachi TV RCA DVD player Half of the DVD's Kenwood surround sound system Wood and glass audio pier Brown Patio chairs, small table All of the tools in garage with the exception of 1 tool box All of the power tools, Half of shed and yard equipment Xbox and games Dell desktop and desk Guns, Dyson Vacuum, Laundry stand/shelf Camcorder Master bedroom set Kodak digital camera Eat in Kitchen table and 4 chairs 27 inch tv Fathers coins Half of dishes/etc Misc pictures, wall hangings DVD copy of all digital pictures and music The parties agree that the following marital property shall be the sole and separate property of Shana L Peery, the Wife, and Steven J Peery, the Husband transfers and quitclaims any interest that he may have in this marital property to the Wife: 2002 Black Nissan Frontier truck Dining room table, 6 chairs and hutch Laptop Desk Scanner/printer File cabinet Hitachi 51 inch TV 19 inch color tv Panasonic DVD player Half of the dvd's Black patio furniture, 4 chairs and table Brown wicker chairs and table Swing set Canon EOS Digital camera Coffee and end tables Wooden coat/sitting bench Half round table and mirror Living and dining room rugs Safe 2 dogs - Lou and Oscar Carpet cleaner Half of dishes/pans etc Half of the shed - Yard maintenance equip Misc small appliances, wall hangings Half of coins/2 dollar bills The parties agree that Steven J Peery, the Husband, shall pay and indemnify and hold Shana L Peery, the Wife, harmless from the following marital debts: 100% of JCPenny Credit Card (acct# xxx-xxx-x-7) amount $459.11 100% of Lowes Credit Card (acct# xxxxxxxxxxxx8621) amount $1324.11 $419.00 of Kohl's Credit Card (acct# xxx-xxx-449) amount $2092.96 $7985 of Chase Credit Card (acct# xxxxxxxxxxxx7538) amount $9981.91 $597.00 of PSECU Visa (acct#xxxxxxx887) amount $2979.95 100% of ACS School loan (acct# xxxxxxxx-1) amount $11321.68 'The parties agree that Shana L Peery, the Wife, shall pay and indemnify and hold Steven J Peery, the Husband, harmless from the following marital debts: $1673.00 of Kohl's Credit Card (acct# xxx-xxx-449) amount $2092.96 $2382.00 of PSECU Visa Card (acct#xxxxxxx887) amount $2979.95 100% of Old Navy Credit Card (acct# xxxxxxxxxxxx6169) amount $404.15 $1996.00 of Chase Credit Card (acct# xxxxxxxxxxxx.7538) amount $9981.91 The parties agree that the following non-marital (separate) property shall be the sole and separate property of Steven J Peery, the Husband, and Shana L Peery, the Wife transfers and quitclaims any interest that she may have in this non-marital (separate) property to the Husband: None The parties agree that the following non-marital (separate) property shall be the sole and separate property of Shana L Peery, the Wife, and Steven J Peery, the Husband transfers and quitclaims any interest that he may have in this non-marital (separate) property to the Wife: None The parties agree that Steven J Peery, the Husband, shall pay and indemnify and hold Shana L Peery, the Wife, harmless from the following non-marital (separate) debts: None The parties agree that Shana L Peery, the Wife, shall pay and indemnify and hold Steven J Peery, the Husband, harmless from the following non-marital (separate) debts: None The parties both hereby represent and warrant that as of the date of this agreement, they do not possess any property or interests in property other than the items listed in this agreement; and that the items set forth and listed in the agreement constitute full and complete disclosure. In addition to the items listed in this agreement, if any undisclosed property or interests in property is discovered subsequently, and a court of competent jurisdiction determines it to be marital or community property of the parties, such discovery and determination shall not invalidate this agreement but, the property or the interest in it shall at the election of the discovering party (i) be divided equally or equitably in kind or (ii) be accounted for by the party in possession who may pay to the discovering party a sum of money to offset an equal or equitable portion. The parties both hereby represent and warrant that except for the debts and obligations set forth and listed above, each has not incurred any other outstanding debt or obligation on which the other may become liable, nor has either party incurred any obligation that could henceforth be enforced against any asset held or received pursuant to this agreement. In the event that any outstanding debt or obligation of any kind has been incurred by either party, other than those listed above (and is hereafter asserted against the other), the party actually incurring the debt or obligation shall assume and be solely responsible for paying it and shall hold the other party harmless from all claims with respect to the debts, obligations, and expenses with respect to those debts. In the event that the other party becomes a debtor in any bankruptcy or financial reorganization proceeding of any kind while this agreement is in effect, that debtor party waives any and all rights to any property held by the other party which is in fulfillment of this agreement. The debtor party will also convey to the other party that the bankruptcy or financial reorganization proceeding is going to take place. The parties acknowledge and agree that the credit history established by them during their marriage shall be deemed to have the credit history of both parties, not withstanding ordinary practices of creditors and credit reporting agencies that may have reported such credit history in the name of one party. Both parties agree to cooperate and execute any documents as may be required to enable each other to provide to prospective creditors the full credit history of the parties that was established during the marriage. The parties each represent to the other that from the date of this agreement each party shall not charge or incur or cause to be incurred any liability or obligations based on the credit or name of the other. Each of the parties shall do whatever is necessary to close immediately all joint accounts. The parties each forever waive any right to inherit from the other and the right to receive any property on the death of the other, except as a beneficiary of any life insurance policy, by reason of a will, codicil, or republication of will by the other party executed subsequent to the date of this agreement. The parties each waives all right to act as administrator of the other party's estate and all right to request or petition for the appointment of any person to serve as such representative or to act as the executor of the other's will, unless expressly named in a will, codicil, or republication of will by the other party executed subsequent to the date of this agreement. 3. Marital Home: There is a marital home of this marriage located at: 15 Orion Rd, Boiling Springs, Pennsylvania 17007, with a legal description of. Beginning at a point located on the southern right of way line of Orion Rd, a 50 foot wide road, said point also being on the dividing lines of lots 13 and 14; thence along said dividing line, South 03 degrees 20 minutes 44 seconds West, a distance of 125.00 feet to a point located along lands now or formerly owned by Country side acres; thence along said lands, North 86 degrees 39 minutes 16 seconds West, a distance of 160.00 feet to a point located at the dividing line of lots 13 and 12, said point being the southwest most point of lot 13; thence along said dividing line of lots 13 and 12, North 03 degrees 20 minutes 44 seconds East, a distance of 125.00 feet to a point located along the southern right of way line of Orion Rd, a 50 foot wide road; thence along said right of way, South 86 degrees 39 minutes 16 seconds East, a distance of 160.00 feet to the point and place of Beginning Containing 20,000 square feet, more or less. Being lot 13, as shown on a final subdivision plan for Froge Hills, recorded as aforesaid. The parties agree that this real estate shall be listed or made available for sale at current market price of $269,900.00. In the event that the parties cannot promptly agree on the actual sale price, any other terms for listing, on terms of any subsequent modification of those terms, on acceptance or counter offer, or any offer received, either party may apply to the court for a resolution of the dispute. Upon the completion of any escrow for sale of the real estate, the net proceeds or losses of this sale after deduction of all expenses, taxes, liens and mortgages will be divided as follows: Husband shall receive 50% from the gains of the sale of the said real estate. Should the sale of this real estate result in a net loss, the Husband will be obligated to pay 50% of the debt accrued from the sale. Wife shall receive 50% from the gains of the sale of the said real estate. Should the sale of this real estate result in a net loss, the Wife will be obligated to pay 50% of the debt accrued from the sale. "Net Proceeds or Losses" from escrow designates all proceeds or losses received by the parties upon close of escrow for sale of the real estate after satisfaction in full of all encumbrances and after deductions of all fees, costs, and expenses incident of sale, including, without limitation, all real estate broker's fees, transfer taxes, and attorney's fees in connection with the sale. During the period from this date until close of escrow for sale of the real estate, both Wife and Husband shall be entitled to use and have possession of the real estate as a principal residence subiect to each party being entitled to reasonable ingress and egress. If major repairs are required to the real estate prior to close of escrow of sale, the parties each shall be obligated to pay one-half (50%) of the costs of any repairs, taxes, mortgages, and insurances associated with the real estate. Major repairs are defined as those in excess of $300.00. Except in case of emergency, major repairs shall be made by the agreement of the parties. 4. Retirement Accounts/Pensions/401ks/Profit Sharing Plans: The parties agree that the marital portion of all present pension benefits, retirement funds, 401k's, profit sharing plans and accounts of the like will be addressed as follows: The parties agree to divide only the following account as follows: The Husband agrees that the Wife will be entitled to 50% of the financial account titled: State Employees Retirement System with an account number of xxxxx9018. The parties shall instruct the administrators and the trustees of the State Employees Retirement System account number xxxxx9018, to take all actions necessary to carry out the terms of this agreement. The parties agree to cooperate with one another to ensure that this domestic relations order, or order of the like, is drafted and submitted to the court and the account administrator for approval. Any payment made out of the above mentioned account will be executed only by drafting and submitting the appropriate domestic relations order, or order of the like, to the judge and/or account administrator for approval and execution. The parties each waive all present and future claims to the other's pension benefits, retirement funds, 401 k's, profit sharing plans and account of the like other than the account mentioned above. 5. Spousal Maintenance: The Husband shall pay to Wife for rehabilitative spousal maintenance, the sum of $650 per month payable in advance on the first (1st) day of each month commencing on December 20, 2010 and continuing thereafter until the earliest of the following events (i) death of either party, (ii) remarriage of (iii) the cohabitation by the Wife with a person of the opposite sex in a relationship similar to a husband-wife relationship for 90 continuous or noncontinuous days in a 12 month period, (iiii) a duration of 12 years has passed since the first payment was made. The provisions of this agreement pertaining to payments of rehabilitative spousal maintenance shall not be subject to modification by any order or judgment of any court, and neither party shall request or apply for a modification at anytime or under any circumstances to any court. The Wife hereby acknowledges and agrees that Husband will make payments to him/her as set forth on the understanding that the Husband will have the right to deduct the entire amount of the payments from his/her federal, state and local income tax returns for all years in which the payments are made. The Wife agrees that all payments received by Husband shall be included as gross income by Wife in all federal, state and local income tax returns filed for the years that such payments are received. The parties both agree each will be responsible for his and her own health and medical insurance coverage. 6. Medical/Health Insurance: The parties agree that for as long as the child support payments are being made, the Wife will carry and maintain health, dental, and hospitalization insurance for the children's benefit, pay any required deductible amount, and pay a portion equal to his or her percentage of income of necessary medical or dental expenses of the children that are not covered by such insurance. 7. Tax Exemptions: The parties agree they will both be entitled to claim the children as dependants on his and her federal, state, and local tax returns alternating each year according to current IRS regulations. The defendant shall claim the children on all odd years and the plaintiff shall claim the children on all even years. 8. Income Tax Returns: The parties agree that they will file joint federal, state and local tax returns for the calendar year in which this agreement is made into effect. The parties both agree that they will cooperate in the filing of any necessary tax returns and if any tax refunds are due on jointly filed returns they shall be divided equally. For each calendar year after the year this agreement is made into effect, each party shall file separate federal, state and local income tax returns, in which each shall include and report all of his or her separate income and shall pay all income taxes due. The parties each agree to notify the other promptly in the event the IRS or any state or local taxing authority provides notice of an audit, deficiency, refund, or the adjustment regarding a tax return that was jointly filed or that should have been jointly filed. The party receiving such notice from a taxing authority shall provide a copy of the notice to the other party within 20 days of receiving it. The parties further agree to cooperate fully with the other in any claims for refunds or in defending against any deficiencies that may be determined with respect to joint income tax returns filed (or to be filed). This includes, without limitation, the making, executing, and filing of amended income tax returns; applications for refunds, protests, and other instruments; and documents as may be required. The costs and expenses for such will be divided equally between the parties. 9. Professional Fees and Costs: Each of the parties shall be solely responsible for paying his and her respective professional fees and costs incurred in connection with the negotiation and preparation of this agreement and the obtaining of any final judgment decreeing the dissolution of the marriage. Neither Husband nor Wife shall have any obligation whatsoever for any professional fees or costs incurred by the other party. 10. Advice of Counsel: The parties each acknowledge that they have the legal right to representation by separate attorneys. The parties each fully understand his and her rights and the contents of this agreement. The parties each consider the terms of this agreement to be fair and reasonable and each party accepts sole responsibility for any decisions, and potential repercussions of those decisions, which are presented as part of this agreement. 11. Mutual Releases: Each parry hereby releases the other from any claim of action that either may have against the other for any reason occurring prior to this agreement, whether that claim is founded in contract, tort, or any other basis. 12. Governing Law: The parties agree that this document is intended to be a full and an entire settlement and agreement between them regarding the marital rights and obligations and that this agreement, and all contents within and attached, shall be interpreted and governed by the laws of the State of Pennsylvania. 13. Entire Agreement: This agreement constitutes the entire and full agreement between the parties. If any clause is held unenforceable or found to be in any way non- executable, or if a court alters or holds unenforceable any clause in this agreement, this shall in no way affect or alter the other clauses in the agreement, which shall remain in full force. No amendment or modification to this agreement or any judgment, decree or order based on it shall be valid unless signed and agreed to by both parties or ordered by the court after a duly noticed hearing. 14. Further Assurances: The parties shall execute and deliver promptly on request any additional papers, documents, and other assurances reasonably necessary in connection with the performance of the obligations set forth in this agreement. In the event that either party fails or refuses to comply with the provisions of this agreement, the failing party shall reimburse the other party for all loses and expenses including, but not limited to, attorney's fees and all costs incurred as a result of such failure. 15. Captions and Interpretations: Paragraph captions have been used throughout this agreement for convenience and reference only and are not intended to be used in the construction or interpretation of this agreement or any of its provisions. No provision of this agreement is to be interpreted for or against any party by virtue of the fact that the provision was drafted by that party or that party's counsel. 16. Submission to Court for Incorporation: This agreement has been drafted and executed with the intention that it be submitted by either party to any court before which a Complaint for Divorce may be pending or initially filed for approval by the court and for incorporation into a Decree of Divorce pursuant to Sections 4104(a)(1) and (3) and 3323(b) of the Divorce Code. 17. Verification/Disclosure: The parties both have reviewed this agreement cooperatively and each party has fully and honestly disclosed to the other the extent of his or her assets, income, and financial situation, and therefore enter into this agreement reliance thereupon. 18. Successions: The parties each acknowledge that this agreement, and each provision of it, is expressly made binding upon the heirs, assigns, executors, administrators, representatives and successors in the interest of each parry. Signature (Wife) _?, ? - N-k&r ?Y'L Witne<, 1 Name G6? es 1 ign e Witne s #2 N me r" Witness 2 . afore state of- gem 11 51 Ul 14u i h County of Cl-t-66et4N. SWORN TO AND SUBSCRIBED BEFORE ME by the said On I , 20 10 , before me, the undersigned, a Notary Public in and for said State, personally appeared Steven J Peery, the Husband, known to me (or proved on the basis of satisfactory evidence) to be the person whose name is subscribed to within the instrument and acknowledged that he executed the same. Witness my hand and official seal. Notary Publi COMMONWEALTH OF PENNSYLVANIA Notary Seal NO=Na CAMELA J. ic Boro of CarlMy Commissi 14 Print Name (Wife) My commission expires: -?oiE State of ?tk M 5 L`04 N11 19 County of Lam} I`t u? SWORN TO AND SUBSCRIBED BEFORE ME by the said On I Lli- , 20 O before me, the undersigned, a Notary Public in and for said State, personally appeared Shana L Peery, the Wife, known to me (or proved on the basis of satisfactory evidence) to be the person whose name is subscribed to within the instrument and acknowledged that she executed the same. Witness my hand and official seal. Notary Public Notary Seal My commission expires: o? .;b l NyV? ALTH OF PENNSYLVANIA NOTARIAL SEAL CAMELA J. MANGES, Notary Public Ban) of Carlisle, Cumberland County My Comm4sion Expires June 21, 2014 -w In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery Plaintiff V. Shang L Peery _ Defendant And in the :interests of (minor children) Term, 2 Case Number: 9 f e_ 03 ? P q r -`R ? J rn c? } _n ^.a Sierra Lynn Peery (Age: 13) Maxwell J Peery (Age: 9) Praecipe to Transmit Record To the Prothonotary: Kindly Transmit the Record, together with the following information, the Court for entry of a Decree of Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and Manner of Service of the Complaint for Divorce: Approximate date of service: '1A, ? . 0 -7 _, d D / G) Type of service: (rsonal or ( ) certified mail. 3. Complete Paragraph (a) or (b). (a) date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the Divorce Code: ?. By Plaintiff: ,??1 (7tr t By Defendant: 4- 15 (l o . (b) date of execution of the Affidavit /Consent Waiver required by Section 3301 (d) of the Divorce Code: By Plaintiff- By Defendant: , STEVEN J. PEERY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANA L. PEERY, Defendant NO. 10-3764 CIVIL TERM ORDER OF COURT AND NOW, this 28`h day of September, 2010, upon consideration of Plaintiff's Praecipe To Transmit Record, and the final paragraph of the proposed Divorce Decree submitted with the praecipe not having been completed, a divorce decree will not be entered at this time, without prejudice to the parties' right to submit a new praecipe with a properly completed proposed divorce decree. The parties may wish to consult an attorney for advice as to the wording which they desire in the said paragraph. S? teven J. Peery 15 Orion Road Boiling Springs, PA 17007 Plaintiff, pro Se Shana L. Peery 15 Orion Road Boiling Springs, PA 17007 Defendant, pro Se Cof £.$ nn, lv-cc 4/;L,? //c-) <',:.a cj f ?y r : c, d M BY THE COURT, In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Steven J Peery ) Term, 2 Plaintiff ) v. ) Case Number: ~~ ~ _ ~ 3 7~ Y Shane L Peery ) c r ~,,, ~ ~:. a `' Defendant ) ,.~~ c ~ '~ ~ -- ~~ ~ `• ~ ~r=- -+ ,~ ~;-~ r-- _. r-n ~ r .._ ~ ~, And in the interests of (minor children) ) Ems. ~ -~ ~ ) ~ ~ ~ Sierra Lynn Peery (Age: 13) Lx"t -~; s~ ~~ Maxwell J Peery (Age: 9) Praecipe to Transmit Record To the Prothonotary: Kindly Transmit the Record, together with the following information, the Court for entry of a Decree of Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and Manner of Service of the Complaint for Divorce: Approximate date of rvice: J `'`'~'~ ~ ~ ~ ~~ ~ D Type of service: (~rsonal or ()certified mail. 3. Complete Paragraph (a) or (b). (a) date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the Divorce Code• By Plaintiff 5 u,•~. 6r.` I S , o?D C7> By Defendant: S a0 (t~ (b) date of execution of the Affidavit /Consent Waiver required by Section 3301 (d) of the Divorce Code: By Plaintiff: By Defendant: • 4. Related Claims Pending: None. Date: /~ ~~<~~ c'1 D ~ ~ ~~ v ~-~ Signature Mailing Address: 15 OriduBt~Boiling Springs, Pennsylvania, 17007 Phone:717-243-6632 Steven J Peery IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. Shana L Peery : No. 2010-03764 DIVORCE DECREE AND NOW, ~ ~~~_~ ~ ~, it is ordered and decreed that Steven J Peery plaintiff, and By the Court, Shana L Peery ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente life if any economic claims nmain 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.°) ~a~L Att t: J. _ ._ v;ol b. ~3uel/ Protl onotary-~ -~ ID -~' ~~ `~ta~` .` ~~~ ` ~ ` t., STEVEN J. PEERY Plaintiff v. SHANA L. PEERY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA c, ,�, NO. 2010-03764 rn co Z 73 -< CIVIL LAW _< n c DIVORCE < >() C.X) (j? STIPULATION AND AGREEMENT FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" r,1 I - rti cp • AND NOW, this ? Z » day of n.,u,.1 , 2014, the parties, Steven J. Peery, Plaintiff, and Shana L. Peery, Defendant, having been divorced by Decree dated October 5, 2010 in the Court of Common Pleas of Cumberland County, entered at Docket Number No. 2010-03764, do hereby stipulate and agree as follows: 1. The Plaintiff, STEVEN J. PEERY, (hereinafter referred to as "Member") is a member of the Commonwealth of Pennsylvania State Employees' Retirement System (hereinafter referred to as "SERS"). 2. SERS, as a creature of statute, is controlled by the State Employees' Retirement Code, 71 Pa. C.S. §§ 5101-5956 ("Retirement Code"). 3. Member's date of birth is May 22, 1968. Member's Social Security Number shall be provided to SERS on a separate document submitted to SERS together with this Stipulation and Agreement but not filed with the Court. 4. The Defendant, SHANA L. PEERY, (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is October 31, 1969. Alternate Payee's 0 Social Security Number shall be provided to SERS on a separate document submitted to SERS together with this Stipulation and Agreement but not filed with the Court. 5. Member's last known mailing address is: 900 Spring Circle Mechanicsburg, PA 17055 6. Alternate Payee's current mailing address is: 107 E. Springville Rd. Boiling Springs, PA 17007 It is the responsibility of Alternate Payee to keep a current mailing address on file with SERS at all times. 7. (a) The marital property component of Member's retirement benefit equals (1) the Coverture Fraction multiplied by (2) Member's retirement benefit on the effective date of Member's retirement calculated using the Retirement Code in effect on 05/01/10, the date of the parties' separation, and Member's final average salary at the time of retirement, provided however, that '` • if an amount other than the Member's final average salary is used to calculate the Member's retirement benefit, then that number shall be used. (b) The Coverture Fraction is a fraction with a value less than or equal to one. The numerator is the amount of Member's service, as defined by SERS, for the period of time from 05/22/93 (date of marriage), to 05/01/10 (date of separation). The denominator is the total amount of Member's service, as defined by SERS, on the effective date of Member's retirement. (c) Fifty percent ( 50 %) of the marital property component of Member's retirement benefit is to be allocated to Alternate Payee as the equitable distribution portion of this marital asset. 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases, but excluding the disability portion of any disability annuities paid to Member by SERS as a result of a disability which occurs before Member's marriage to Alternate Payee or after the date of Member's and Alternate Payee's final separation. Member's retirement benefit does not include any deferred compensation benefits paid to Member by SERS or any enhancements to the Member's retirement benefit arising from post -separation monetary contributions made by Member. The equitable distribution portion of the marital property component of Member's retirement benefit, as set forth in Paragraph Seven (7), shall be payable to Alternate Payee and shall commence as soon as administratively feasible on or about the date Member actually enters pay status and SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits payable by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or other authorized representative of the Secretary, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of the equitable distribution portion payable to Alternate Payee and any other alternate payees named under other SERS-approved Domestic Relations Orders ("Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death. If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. 10. The term and amounts of Member's retirement benefits payable to Alternate Payee after SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement depends upon which option(s) Member selects at retirement. Member and Alternate Payee expressly agree that Member shall select Special Option 4 upon filing an Application for Retirement Allowance with SERS. Special Option 4. --A joint and equitable distribution percent [or portion] (as defined in paragraph 7) annuity payable during the lifetime of the Member, with an equitable distribution percent [or portion] (as defined in paragraph 7) of such annuity payable thereafter, to the Member's survivor annuitant, if living at the Member's death, as set forth in 71 Pa.C.S. Section 5705(a)(4), or any succeeding statute. Member may select any option offered by SERS under the Retirement Code at the time of retirement for the portion of the retirement benefit payable to Member. The Member shall designate the Alternate Payee as an irrevocable survivor annuitant. The intent of this Special Option 4 selection is to maintain level payments to the Alternate Payee for the Alternate Payee's life in the event of Member's death after retirement. The Alternate Payee's portion of the Member's benefit will be deducted from the Member's monthly annuity payment and paid by SERS to the Alternate Payee during the Member's lifetime. If the Alternate Payee dies while the Member is receiving retirement benefits, the Alternate Payee's portion of the Member's annuity shall by paid to the Alternate Payee's Estate for the remainder of the Member's lifetime. If the Member predeceases the Alternate Payee after retiring, the Alternate Payee will receive the Alternate Payee's equitable distribution portion of the Member's benefit in the form of a survivor annuity payable to the Alternate Payee for the duration of the Alternate Payee's life. In any event, all payments to any person or estate will stop when both the Member and Alternate Payee have died. 11. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to each. 12. In the event of the death of Alternate Payee prior to receipt of all of payments payable from SERS under a Domestic Relations Order incorporating this Stipulation and Agreement, any death benefit or retirement benefit payable to Alternate Payee by SERS shall be paid to Alternate Payee's Estate to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit as set forth in paragraphs 7 through 9. 13. In no event shall Alternate Payee have benefits or rights greater than those that are available to Member. Alternate Payee is not entitled to any benefit not otherwise provided by SERS. Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Stipulation and Agreement. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Stipulation and Agreement are preserved for Member. Member and Alternate Payee acknowledge that benefits paid pursuant to this Stipulation and Agreement are and shall remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. §1311, et seq. 14. It is specifically intended and agreed by the parties hereto that any Domestic Relations Order incorporating this Stipulation and Agreement: (a) Does not require SERS to provide any type of benefit, or any option, not otherwise provided under the Retirement Code; (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living adjustments or increases based on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that such amendment shall not require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that such amendment or right of the Court to so amend will not invalidate the parties' existing Domestic Relations Order. 17. Upon entry of a Domestic Relations Order incorporating this Stipulation and Agreement, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon SERS immediately. Such Domestic Relations Order shall take effect immediately upon SERS approval and SERS approval of any attendant documents and then shall remain in effect until such time as a further Order of Court amends or vacates the Domestic Relations Order. WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation Agreement, :do hereunto place their hands _ •c Plaintiff/Member rnate ayee Defendant/Alte This Order is entered on the date first written above. BY THE COURT: `/ DISTRIBUTION: enneth F. Lewis, Esq., 1101 North Front St., lst fl., Harrisburg, PA 17102 (counsel for Shana L. Peery) teven J. Peery, 900 Spring Circle, Mechanicsburg, PA 17055 ct, ear sjaafr( F A