HomeMy WebLinkAbout01-2098 VERIFICATION
I, D. Thomas Fowler, verify that the statements made in the foregoing Complaint in
Divorce are tree and correct to the best of my knowledge, information and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unswom falsification to authorities.
Date' q_ ~..6~ D. Thomas Fowler
REAGER & ADLER, P.C.
ATTORNEYS AT LAW
2331 MARKET STREET
CAMP HILL, PA 17011-4642
(717) 763-1383
·
D. THOMAS FOWLER, · IN THE COURT OF COMMON PLEAS
Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 01-2098
·
RENAE L. FOWI~R, · 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(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Service was accepted by the
Defendant on the 13t~ day of April, 2001, by certified mail, return receipt requested, receipt
number P 902 067 188.
3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce
Code: by D. Thomas Fowler, Plaintiff, on March 25, 2002; by Renae L. Fowler, Defendant, on
March 29, 2002.
4. Related claims pending: Settled by Agreement dated March 29, 2002.
5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: April 9, 2002
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: April 9, 2002
Respectfully submitted,
REAGER & ADLER, PC
2331 Market Street
Can~ Hill, PA 17011
(717) 763-1383
~d
! r
D. THOMAS FOWLER, · IN THE COURT OF COMMON PLEAS
Plaint~ ' CUMBE~~ COUNTY, PENNSYLVANIA
· NO. 01-2098
·
RENAE L. FOWI~R, ' CIVIL ACTION- LAW
Defendant · IN DIVORCE
AFFIDAVIT OF SERVICE
I, Debra Denison Cantor, Esquire of REAGER & ADLER, P.C. do hereby certify that I
served a certified copy of the Divorce Complaint on the Defendant Renae L. Fowler, by Certified
Mail, Restricted Delivery on the 13ta day of April, 2001 as is evidenced by the signature of the
Defendant on the Return Receipt card attached hereto as Exhibit A. Said Corr~laint in Divorce
was mailed to Defendant by depositing a true and exact copy thereof in the United States mail,
fa'st class, Certified Mai/, Restricted Delivery, Return Receipt Requested postage prepaid,
addressed as follows:
Renae Fowler
25 White Oak Boulevard
Mechanicsburg, PA 17055
Date: ~//- ~: V~ ~
LER, P.C.
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. (717) 763-1383
Atty. Id. No. 36461
&Iflder: R E:
-. .~, ?. Date of Delivery .........
· .' .~ :.-.~
DEBRA DENISON CANTOR
REAGER & ADLER, PC
2331 MARKET STREET P 902 067 188
CAMP HILL, PA 17011
ure (IS]Addressee or []
---- ~--..~._..._ ,. ?;. ~.~ .,.~ ~ '?~ . ,:... . .
8. Addressee's Address (if different from addmss used by sender.) 3. Article '
~[~..E-~AE FOWL'~....
'b'~ii~F'Xa~;~'~- .......................................................... M E C H A N I C S B U R ~ 'PA.::.'::~:~:O 55
State ...........~j'l~' ~'~' ~,~1~
PS Form 3811, December 1994 I JSA4/99 CMF-088 DOMESTIC RETURNRECEiPT '
EXHIBIT "A"
·
D. THOMAS FOWLER, 'IN THE COURT OF COMMON PLEAS
Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA
·
· NO. 01-2098
o
RENAE L. FOWLER, 'CIVIL ACTION- LAW
Defendant · IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on April 9, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety
(90) days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unswom falsification to authorities.
Date: 3.'05' 0&
D. THOMAS FOWLER
D. THOMAS FOWLER, · IN THE COURT OF COMMON PLEAS
Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA
·
'NO. 01-2098
·
RENAE L. FOWLER, · CIVIL ACTION- LAW
Defendant · IN DIVORCE
OF DIVORCE DEC~REE UNDER
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by
the Court and that a copy of the Decree will be sent to me immediately after it is filed
with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating
to unswom falsification to authorities.
D. THOMAS FOWLER
D. THOMAS FOWLER,
Plaintiff · IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY PENNSYLVANIA
· NO. 01-2098 CIVIL TERM
RENAE L. FOWLER, ' CIVIL ACTION - LAW
·
Defendant · IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
(1) A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on April 9, 2001.
(2) The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of
filing and service of the Complaint.
(3) I consent to the entry of a final decree of divorce without
formal notice of the intention to request entry of a divorce
decree.
(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 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. Sec. 4904 relating to
unsworn falsification to authorities.
DATED
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this ~c~'~ day of f)qa~'o.l,~ ,2002, by and between
Renae L. Fowler, (hereinafter "WIFE") and D. Thomas Fowler, (hereinafter "HUSBAND");
WITNE S SETH:
WHEREAS, the parties hereto were married on June 10,1989; and
WHEREAS, the parties have one minor child of this marriage, namely Brandon
Thomas, date of birth October 19, 1996; and
WHEREAS, difficulties have arisen between the parties and it is therefore their
intention to live separate and apart for the rest of their lives and the parties are desirous of
settling completely the economic and other rights and obligations between each other,
including, but not limited to: the equitable distribution of the marital property; past, present
and future support; alimony, alimony pendente lite; and, in general, any and all other claims
and possible claims by one against the other or against their respective estates; and
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
kept and performed by each party and intending to be legally bound hereby, the parties do
hereby agree as follows-
1. ADVICE OF COUNSEL.
The provisions of this Agreement and their legal effect have been fully explained to the
parties by their respective counsel. HUSBAND is represented Debra Denison Cantor, Esquire
of Reager & Adler, PC. WIFE is represented by Lori K. Serratelli, Esquire.
The parties further declare that each is executing the Agreement freely and voluntarily
having either obtained sufficient knowledge and disclosure of their respective legal rights and
obligations, or if counsel has not been consulted, expressly waiving the right to obtain such
knowledge. The parties each acknowledge that this Agreement is fair and equitable and is not
the result of any fraud, coercion, duress, undue influence or collusion.
2. DIVORCE ACTION.
The parties acknowledge that their marriage is irretrievably broken and that they shall
secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code. A divorce
action was filed by HUSBAND with the Court of Common Pleas of Cumberland County,
Pennsylvania at Civil Action No. 01-2098 on April 1, 2001. The parties agree to execute
Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a
Divorce Decree concurrently with the execution of this Agreement or upon expiration of ninety
(90) days.
This Agreement shall remain in full force and effect after such time as a final decree in
divorce may be entered with respect to the parties. The parties agree that the terms of this
Agreement shall be incorporated into any Divorce Decree which may be entered with respect
to them and specifically referenced in the Divorce Decree. This Agreement shall not merge
with the divorce decree, but shall continue to have independent contractual significance.
3. DATE OF EXECUTION.
The "date of execution" and "execution date" of this Agreement shall be defined as the
date upon which it is executed by the parties if they have each executed the Agreement on the
same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be
defined as the date of execution by the party last executing this Agreement.
4. MUTUAL RELEASES.
Each party absolutely and unconditionally release the other and the estate of the other
from any and all rights and obligations which either may have for past, present, or future
obligations, arising out of the marital relationship or otherwise, including all rights and
benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described
herein.
Page 2 of 13
,
Each party absolutely and unconditionally releases the other and his or her heirs,
executors, and estate from any claims arising by virtue of the marital relationship of the parties.
The above release shall be effective whether such claims arise by way of widow's or widower's
rights, family exemption, or under the intestate laws, or the right to take against the spouse's
will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights
of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any state, Commonwealth, or territory of the United States, or any other
country.
Except for any cause of action for divorce which either party may have or claim to have,
each party gives to the other by the execution of this Agreement an absolute and unconditional
release form all claims whatsoever, in law or in equity which either party now has against the
other.
5. FINANCIAL AND PROCEDURAL DISCLOSURE.
The parties confirm that each has relied on the accuracy of the financial disclosure of
the other as an inducement to the execution of this Agreement. Each party understands that
he/she had the right to obtain from the other party a complete inventory or list of all property
that either or both parties owned at the time of separation or currently and that each party had
the right to have all such property valued by means of appraisals or otherwise. Both parties
understand that they have right to have a court hold hearings and make decisions on the
matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is
fair and equitable, and that the terms adequately provide for his or her interests, and that this
Agreement is not a result of fraud, duress or undue influence exercised by either party upon
the other or by any person or persons upon either party.
6. SEPARATION/NON-INTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart.
They shall be free from any interference, direct or indirect, by the other in all respects as fully
as if they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on
Page 3 of 13
and engage in any business, occupation, profession or employment which to him or her may
seem advisable. WIFE and HUSBAND shall not harass, disturb, or malign each other or the
respective families of each other.
7. REAL PROPERTY.
A. 25 White Oak Boulevard, Mechanicsburg, PA.
The parties are the joint owners of real property located at 25 White Oak Boulevard,
Mechanicsburg, Pennsylvania. HUSBAND agrees to waive any right, title and interest that he
may have to said property. Concurrently with the execution of the Marital Settlement
Agreement, HUSBAND shall execute a deed transferring his interest in the home to WIFE.
Said deed shall be prepared and held in escrow by HUSBAND's counsel until the following
terms are met.
Upon the execution of this Agreement, WIFE shall maintain sole and exclusive
possession of the marital home. WIFE agrees to be solely responsible for all costs and expenses
associated with the marital home, including but not limited to mortgage(s), taxes, insurance,
and utilities. WIFE shall make all said payments in a timely manner. WIFE agrees to refinance
the home no later than May 1, 2005. At the time of refinance, HUSBAND agrees to pay one-
half of one percent (1%) of the title transfer fee associated with the refinance. This contribution
shall not exceed $500.00. Upon notification of the refinance, HUSBAND's counsel shall release
the deed contingent on HUSBAND's release from the mortgage obligation. In the event that
WIFE is unable to refinance the home by May 1, 2005, the home shall be listed for immediate
sale. Both parties agree to cooperate fully with the sale, including the listing with an acceptable
agent, and the reduction of price in order to sell the home.
In exchange for his waiver of interest in the marital home, HUSBAND shall receive
$10,000.00 for his interest. $2,000.00 shall be paid to HUSBAND upon the entry of the divorce
decree. WIFE shall continue to make $2,000.00 payments per year to HUSBAND due no later
than May ~1st of each year. Failure to make such payments shall result in the immediate listing
of the home for sale. Upon the sale or refinance of the home, the entire outstanding balance
Page 4 of 13
owed to HUSBAND shall be paid prior to any distributions being made to WIFE. After
payment in full of $10,000.00 to HUSBAND, WIFE shall retain any and all proceeds.
B. Timeshare.
The parties jointly own a timeshare located at Villas of Ocean Pines, Unit 32, Interval
13,11029 Cathel Road, Berlin, MD 21811. The parties agree that they shall continue to maintain
joint ownership of said timeshare and will equally divide all costs and expenses of the
timeshare on an annual basis. The parties shall alternate the use of the timeshare as mutually
agreed upon. In the event that either party wishes to relinquish their joint ownership of the
timeshare, the other party shall have the right of first refusal in purchasing the interest. In the
event that neither party wishes to retain the timeshare, the parties will agree to sell the
timeshare and after the deduction of all costs and expenses, shall equally share any and all
proceeds from said sale.
8. DEBTS.
The parties agree and represent that there is no joint credit card debt or outstanding
loan obligations. If a party has acquired debt, the parties agree that each shall assume full and
complete responsibility for his or her own debts.
HUSBAND represents and warrants to WIFE that since the separation he has not, and
in the future he will not, contract or incur any debt or liability for which WIFE or her estate
might be responsible, and he shall indemnify and save WIFE harmless from any and all claims
or demands made against her by reason of such debts or obligations incurred by him since the
date of said separation, except as otherwise set forth herein.
WIFE represents and warrants to HUSBAND that since the separation she has not, and
in the future she will not, contract or incur any debt or liability for which HUSBAND or his
estate might be responsible, and he shall indemnify and save HUSBAND harmless from any
and all claims or demands made against him by reason of such debts or obligations incurred
by her since the date of said separation, except as otherwise set forth herein.
Page 5 of 13
9. RETIREMENT BENEFITS.
HUSBAND is the owner of a 401K through this employment with XPEDX. The 401K
is held by XPEDX, account number 192-64-2539. The approximate value of the 401K is
$35,000.00 WIFE is the owner of a 401K with her employer Highmark. The 401K is held at
account number 161462775 with American Express and has an approximate value of
$24,300.00. WIFE is also the owner of a mutual fund account number 671818286, held with Van
Kemper. The approximate value of this mutual fund is $534.00 after a withdrawal by WIFE.
HUSBAND hereby waives his right, title and interest to and of WIFE's 401K and
mutual fund as above defined. WIFE hereby waives her right, title and interest to any of
HUSBAND's 401K as above defined. The parties acknowledge that here are no additional
retirement accounts held by either party at this time.
10. PERSONAL PROPERTY AND BANK ACCOUNTS.
The parties acknowledge that all household goods have been divided by mutual
agreement. All property held in WIFE's name shall be retained by her; all property held in
HUSBAND's name shall be retained by him.
The parties also agree that all bank accounts held by the parties have been divided
equally. The bank accounts held solely in individual names shall become the sole and
separate property of the party in whose name it is registered. Each party does hereby
specifically waive and release his/her right, title and interest in the other party's respective
accounts.
The parties are owners of a Lab/Mix dog named Booger. WIFE shall maintain
ownership of the dog. However, HUSBAND agrees to contribute to its care by paying one-half
the cost of all veterinary fees and by assuming the cost of all food necessary for the parties'
dog.
11. VEHICLES.
The parties are the owners of a 1996 Honda Passport and a 1996 Nissan Maxima. WIFE
shall retain the 1996 Honda Passport and HUSBAND agrees to execute title to transfer his
interest in the vehicle at the time of execution of the Marital Settlement Agreement.
Page 6 of 13
HUSBAND shall retain the 1996 Nissan Maxima and the car loan applicable thereto. WIFE
agrees to execute any and all documentation necessary to effectuate the transfer of this vehicle
to HUSBAND and waives any right, title and interest she may have to said vehicle.
12. ALIMONY.
HUSBAND agrees to pay to WIFE the sum of $440.00 per month in alimony made
payable beginning the first day after the entry of the divorce decree and continuing until the
same date in the year 2005. The amount shall be calculated by use of the spousal support
guidelines whereby WIFE's net income is subtracted from HUSBAND's net income. This
amount shall be reduced by the child support amount and multiplied by 30% for the alimony
award. Said amount shall be paid directly to WIFE no later than the 15~h day of each month.
Said alimony shall be suspended upon WIFE's remarriage or cohabitation. If, prior to May 1,
2005, WIFE removes either of said conditions, alimony shall resume beginning the month
following the termination of the condition and continuing until no later than May 1, 2005.
WIFE is required to provide notice within 15 days upon her remarriage or cohabitation as
defined in the Divorce Code and within 15 days of the removal of said condition. Alimony
shall terminate upon WIFE's or HUSBAND's death.
13. CHILD SUPPORT.
HUSBAND agrees to pay $920.00 per month for the support of the parties' minor child,
Brandon Thomas, date of birth October 19, 1996. Said child support includes the cost of day
care. WIFE shall be responsible for making all payments to the day care provider directly.
WIFE shall be responsible for the first $250.00 of medical expenses for the child and thereafter
medical expenses shall be divided equally. The parties reserve the right to have child support
re-examined by the Domestic Relations Office upon any change of circumstance. Said payment
shall be made directly to WIFE beginning the month following the execution of this Agreement
and shall be payable no later than the 15th day of each month.
WIFE shall claim Brandon as a deduction on her tax return for the tax years 2001 and
2002. Thereafter, HUSBAND shall declare Brandon for tax purposes on odd numbered years,
Page 7 of 13
and WIFE shall declare Brandon for tax purposes on even numbered years. The parties shall
execute all documentation necessary for such filings.
Either party reserves the right to have this matter re-examined by the Domestic
Relations Office based on a change of circumstance.
14. CHILD CUSTODY.
A. Legal Custody:
The parties agree to shared legal custody of the said minor child. The parties agree that
major decisions concerning the child, including, but not necessarily limited to, the child's
health, welfare, education, religious training and upbringing shall be made by them jointly,
after discussion and consultation with each other, with a view toward obtaining and following
a harmonious policy in the child's best interest. Each party agrees not to impair the other
party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate
the affections of the child from the other party. Each party shall notify the other of any activity
or circumstance concerning their child that could reasonably be expected to be of concern to
the other. Day to day decisions shall be the responsibility of the parent then having physical
custody. With regard to any emergency decisions which must be made, the parent having
physical custody of the child at the time of the emergency shall be permitted to make any
immediate decisions necessitated thereby. However, that parent shall inform the other of the
emergency and consult with him or her as soon as possible. Each party shall be entitled to
· complete and full information from any doctor, dentist, teacher, professional or authority and
to have copies of any reports given to either party as a parent.
B. Physical Custody:
1. The parties shall share physical custody of the minor child on the following
schedule:
a. Week I Father shall have custody Friday evening through Sunday
morning at 9:00 a.m. and Monday evening through Wednesday
morning. Mother shall have custody the remaining period of
time.
Page 8 of 13
b. Week 2 Father shall have custody Sunday at 9:00 a.m. through
Wednesday at 9:00 a.m. Mother shall have custody the remaining
period of time.
c. The parties shall alternate week 1 and week 2 with the intent to
equally share custody with their minor child.
2. Mother shall exercise physical custody on Mother's Day; Father shall exercise
physical custody on Father's Day.
3. The parties agree to alternate Easter, Memorial Day, July 4th, Labor Day and
Thanksgiving. Thanksgiving shall be defined by Schedule A and Schedule B. Schedule A is
Wednesday evening through Friday evening. Schedule B is Friday evening through Sunday
evening. Father shall have Schedule B in even numbered years; Mother shall have Schedule
A in odd numbered years and the parties shall alternate thereafter.
4. Christmas shall be divided as follows: Schedule A shall be defined as
Christmas Eve at 1:00 p.m. until Christmas Day at l:00p.m. Mother shall have Schedule A in
odd numbered years. Schedule B shall be Christmas Day at 1:00 p.m. until December 26th at
1:00 p.m. Father shall have Schedule B in odd numbered years.
5. Schedule A shall also include New Year's Eve at 3:00 p.m. until New Year's
Day at 3:00 p.m.
C. Vacation.
Each party reserves the right to exercise 14 days of non-consecutive vacation per year
with 30 days' notice to the other parent.
D. Brandon's birthday shall be alternated between the parties with mother having even
years beginning in 2002 and father having odd years. Brandon's birthday shall be defined
from the evening of October 18 - October 19 at 6:00 p.m.
E. Each party shall have custody of Brandon on their respective birthdays.
15. BANKRUPTCY OR REORGANIZATION PROCEEDINGS.
In the event that either party becomes a debtor in any bankruptcy or financial
reorganization proceedings of any kind while any obligations remain to be performed by that
Page 9 of 13
party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor
spouse hereby waives, releases and relinquishes any right to claim any exemption (whether
granted under State or Federal law) to any property remaining in the debtor as a defense to any
claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney
fees and costs incurred in the enforcement of this paragraph or any other provision of this
Agreement. No obligation created by this Agreement shall be discharged or dischargeable,
regardless of Federal or State law to the contrary, and each party waives any and all right to
assert that obligation hereunder is discharged or dischargeable.
The parties mutually agree that in the event of bankruptcy or financial reorganization
proceedings by either party in the future, any monies to be paid to the other party, or to a third
party, pursuant to the terms of this Agreement shall constitute support and maintenance and
shall not be discharged in bankruptcy.
16. ATTORNEY FEES, COURT COSTS.
Each party hereby agrees to be solely responsible for his or her own counsel fees, costs
and expenses. Neither shall seek any contribution thereto from the other except as otherwise
expressly provided herein.
17. ATTORNEYS' FEES FOR ENFORCEMENT.
In the event that either party breaches any provision of this Agreement and the other
party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all
reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if
applicable) which are incurred by the other party in enforcing the Agreement, whether
enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific
Agreement and intent of the parties that a breaching or wrongdoing party shall bear the
obligation of any and all costs, expenses and reasonable counsel fees incurred by the
nonbreaching party in protecting and enforcing his or her rights under this Agreement.
18. WAIVER OF RIGHTS.
Page 10 of 13
Both parties hereby waive the following procedural rights:
(a.) The right to obtain an inventory and the appraisement of all marital and
non-marital property;
(b.) The right to obtain an income and expense statement of either party;
(c.) The right to have all property identified and appraised;
(d.) The right to discovery as provided by the Pennsylvania Rules of Civil
Procedure; and
(e.) The right to have the court make all determinations regarding marital
and non-marital property, equitable distribution, spousal support,
alimony pendente lite, alimony, counsel fees and costs and expenses.
19. MUTUAL COOPERATION.
WIFE and HUSBAND shall mutually cooperate with each other in order to carry
through the terms of this Agreement, including but not limited to, the signing of documents.
20. VOID CLAUSES.
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.
21. APPLICABLE LAW.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
22. ENTIRE AGREEMENT.
This Agreement contains the entire understanding of the parties, and there are no
representations, warranties, covenants or undertakings other than those expressly set forth
herein.
Page 11 of 13
23. CONTRACT INTERPRETATION.
For purposes of contract interpretation and for the purpose in resolving any ambiguity
herein, the parties agree that this Agreement was prepared jointly by the parties.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day
first above written.
This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND
acknowledge the receipt of a duly executed copy hereof.
Witness D. Thomas Fowler
Witnes-s d Re~ae F}~W~er
Page 12 of 13
COMMONWEALTH OF PENNSYLVANIA ·
· SS.
COUNTY OF ~c I~ .
On the ~~'~' day of ~~Ltc~ ,2002, before me, a Notary
Public in and for the Commonwealth of Pennsylvania, the undesigned officer, personally
appeared D. Thomas Fowler, known to me (or satisfactory proven) to be one of the parties
executing the foregoing instrument, and she acknowledges the foregoing instrument to be her
free act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
Public
My Commission Expires:
[ Deborah L. Brenneman, Notary Pt~ic
! -c-;~'p-i~ii-Boro,Cumberland C_ou_n_~.. :
COMMONWEALTH OF /~~ .
· SS.
COUNTY OF dazerS/5//~ .
On the ~ J~ ~L~ day of '~'~d ~// ,2002, before me, a Notary
Public in and for~he Commonwealth of ,/8,,~ , the undesigned officer, personally
appeared Renae Fowler, known to me (or satisfactory proven) to be on of the parties executing
the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and
deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
Notary~ublic ~ .,//-/-
My Commission Expires: //C~//~~
ti. ·
'* 'dm,,
iNTHE cOUrT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
D. Thomas Fowler
No. 01-2098
VERSUS
Renae L. Fowler
DEC rEE IN
DIVORCE
AND
NOW,
//J~_~/'l I~~ , Z~- , IT IS ORDERED AND
DECREED That D. Thomas Fowler
, PLAINTIFF,
AND Renae L. Fowler , DEFENDANT,
ARE DIVORCED FROM The BONDS OF MATriMONY.
THE COURT RETAINS JURiSDiCTION Of THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YEt BEEN ENTERED;
The terms of the parties' Marital Settlement Agreement dated March 29, 2002
and attached hereto are incorporated herein but not merged herewith.
BY THE COUrt:/
ATT//~~: j.
PrOthONOtary