HomeMy WebLinkAbout04-6093
CORINNE P. REBINSKI,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY , PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. OV.l..o09J ~T~
HENRY L. REBINSKI,
Defendant
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 foregoing 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 in 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 at:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
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
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
II
CORINNE P. REBINSKI,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.Oll.&DQ.J
HENRY L REBINSKI,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
II
CORINNE P. REBINSKI,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. o<J.{,()Q3
HENRY L. REBINSKI,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, CORINNE P. REBINSKI, by her
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is CORINNE P. REBINSKI, an adult individual who currently resides
at 4 Mayfair Court in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is HENRY L. REBINSKI, an adult individual who currently
resides at 7108 Salem Park Circle in Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 10 September 1983 in Steelton,
Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
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COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
Samu L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 1 8
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:))~ /~;;'ooi
~ P fl~L
CORINNE P. REBINSKI
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II
CORINNE P. REBINSKI,
PLAINTIFF
IN THE COURT OF COMMON
PL.EAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2004-6093 CIVIL TERM
HENRY L. REBINSKI,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
I, HENRY L. REBINSKI, hereby accept service of thl~ Divorce Complaint filed in this
matter and acknowledge receipt of a copy of the Complaint.
Date: IJ./;).() /0 'i
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HENR~ REBINSKI
7108 Salem Park Circle
Mechanicsburg, PA 17055
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CORINNE P REBINSKI,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2004-6093 CIVIL TERM
HENRY L REBINSKI,
Defendant
IN DIVORCE
MOTION FOR ENTRY OF RETIREMENT BENEFITS ORDER
AND DOMESTIC RELATIONS ORDER
AND NOW comes the Plaintiff, by her attorney, Samuel L. Andes, and moves the court
to enter the attached Retirement Benefits Order and Domestic Relations Order, to divide and
distribute the Defendant's account within the Federal Thrift Savings Plan and the Federal
Employees Retirement System, based upon the agreement of the parties, and in particular the
provisions of Paragraph 2 of that Agreement, a copy of which Agreement is attached to this
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I Motion and marked as EXHIBIT A.
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15 April 2005
c~~
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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EXHIBIT A
This agreement is made on the I sl day of November, 2004, between Corinne P.
Rebinski, the Wife, of 4 Mayfair Court, Hampden Township, County of Cumberland,
State of Penn. sylvania, and Henry L. Rebinski, the Husband, of7l08 Salem Park Circle,
Township of Hampden, County of Cumberland, State of Pennsylvania.
We were married on the lOth day of September, 1983, in the Town of Steel ton, County of
Dauphin, State of Pennsylvania.
The following children were born into our marriage:
Child's name
Child's Birth date
Child's sex
Michael Rebinski
Matthew T. Rebinski
Shannon M. Rebinski
June 26, 1987
June 6,1989
June 16, 1992
Male
Male
Female
As a result of disputes and serious differences, we sincerely believe that our marriage is
irretrievably broken and there is no possible chance for reconciliation.
We both desire to settle by agreement all of our marital affairs, including the division of
all of our property and bills, and spousal support or alimony and all issues relating to our
children, including custody, visitation, and child support.
Therefore, in consideration of our mutual promises, and other good and valuable
consideration, we agree as follows:
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1. We both desire and agree to permanently live separate and apart from each other,
as if we were single, according to the terms of this agreement. We each agree not
to annoy, harass, or interfere with the other in any manner.
2. We agree that the following property shall be the sole and separate property of the
Wife, and the Husband transfers and quit-claims any interest that he may have in
the property to the Wife:
a. Jewelry valued at $1,000;
b. Silverware valued at $500;
c. 2001 Toyota Camry, VIN# 4t18622klOl 10695, valued at $11,000;
d. 1998 Dodge Conversion van, VIN # 286H8llYlWKl03608, valued at
$11,000;
e. $4791 cash in Members First FCU, Checking account # 251965;
f. $5,003 cash in Members First FCU, Savings account #251965;
g. $1558 cash in Members First Federal Credit Union IRA account #21448,
beneficiary Corinne P. Rebinski;
h, Brown Schultz Sheridan & Fritz Retirement Plan for Corinne P. Rebinski,
value, $ 8750;
We also agree that Wife will obtain a Retirement Benefits Court Order in
order to facilitate the transfer of $54,921 as of November 1, 2004, with
earnings thereon from November 1,2004 until the date of transfer from the
Federal Retirement Thrift Savings Plan Account for Henry L Rebinski
(having a total value of$ 118,593 as of November 1,2004) to the Brown
Schultz Sheridan & Fritz Retirement Plan for Corinne P. Rebinski.
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We also agree that 50% of Husband's Federal Employee Retirement System
Pension accrued as of November I, 2004 is to be awarded to Wife and that
Wife will obtain a Domestic Relations Court Order to facilitate the transfer.
This award is to include pre-retirement death benefits which will be pro-rata if
there is an eligible spouse or the entire amount if there is no eligible spouse.
Upon Husband's retirement Wife has the option to have the benefits payable
on a joint and survivor basis.
We also agree that Wife will sign a Quit Claim Deed to transfer the family
home located at 7108 Salem Park Circle, Mechanicsburg, PA to Husband and
Husband will pay Wife the amount of $ 68,828 for her share within 30 days
after Wife signs the Quit Claim Deed.
We agree that the following property shall be the sole and separate property of the
Husband, and the Wife transfers and quit-claims any interest that she may have in
the property to the Husband:
a. The family home located at 7108 Salem Park Circle, Mechanicsburg,
Pennsylvania ,value $150,000 as of November I ,2004, with the legal
description as follows:
. Lot No. 46 of the Plan of Lots known as Salem Park which is
recorded in the Cumberland County Recorder of Deeds Office, in
Plan Book 25, Page 12, and the dwelling house erected thereon
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known and numbered as 7108 Salem Park Circle, Hampden
Township, Cumberland County, Pennsylvania.
b. 1998 Ford Fl50 Truck, VIN# lFTZXI8WOWNB6804l, value $10,000;
c. $208 cash in Members First FCU, Checking account # 21448;
d. $1,038 cash in Members First FCU, Savings account # 21448;
e. $ 10,350 cash in Members First FCU, new savings account #(not given);
f. $ 95 cash in Members First Federal Credit Union savings account #46260.
g. $1214 cash in Members First Federal Credit Union IRA account #46260,
beneficiary Henry L. Rebinski;
h. After the transfer of the amount specified above to Wife's Brown Schultz
Sheridan Fritz 40 I (k) account, the Federal Retirement Thrift Savings Plan
Account for Henry L. Rebinski, (value after transfer $ 63,672).
1. 1978 Pontiac Firebird, VIN # 02587A8N138313, value $500;
J. Baseball card collection, value $3,000.
Furthermore, we agree that we have come to an equitable agreement on the
distribution of the household furnishings and goods, valued at approximately $10,000.
We also agree that certain household items listed on schedule A, located at Husband's
home at 7108 Salem Park Circle, Mechanicsburg and at Wife's home at 4 Mayfair Court,
Camp Hill will be shared by both Husband and Wife. Also, certain other items listed on
schedule A, located at Husband's home, belong to Wife and she has permission to
retrieve them upon adequate advance notice to Husband.
Furthermore, we agree that the following Pennsylvania Tuition Account Program
credits:
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Account # 0006041836, to the benefit of Michael H. Rebinski, amount, $18,975,
Account # 0006041925, to the benefit of Matthew 1. Rebinski, amount, $18,975,
will be used for the sole purpose of the secondary education and related expenses
of our three children. Any money remaining in the funds after all three have obtained a
four year degree, or have chosen not to pursue such higher education within the five years
subsequent to their high school graduation, will then be equally divided between husband
and wife.
3, We agree that the Wife shall pay and indemnifY and hold the Husband harmless
from the following debts:
a Member's First VISA credit card Account # 4287590002519656;
b. USAA Mastercard Account # 5491237095140383;
c. Kohl's credit card Account # 029735554703;
d. Fees for legal services rendered by Samuel Andes, attorney for Wife, and
fees for services of Harry Leister, pension specialist with Conrad M.
Siegel and Associates, related to the divorce.
We agree that the Husband shall pay and indemnifY and hold the Wife harmless
from the following debts:
a. Chase Visa credit card Account # 44159701 0001 3932
b. Kohl's credit card Account# 033 5499 976 00.
We also agree not to incur any further debts or obligations for which the other
may be liable.
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4. We both agree that, as spousal support or alimony, the Husband shall pay to the
Wife the sum of $1 00 per month, payable on the I st day of each month. The first
payment will be due on the first day of November, 2004, and the payments shall
continue until the first of the following occurrences: (I) the date that either of us
dies; (2) the date that the Wife remarries; or (3) the date that all of our children
reach the age of eighteen or graduate from high school, which ever occurs later.
We both agree that the amount and duration of the payments may be modified by
mutual agreement (due to changes in either spouse's economic position) or by a
court in the future. We also both agree that these payments should be made
directly to the spouse to whom they are due.
5. We both agree that it is in the best interest of our children for both parents to have
joint legal and physical custody ofthem. We acknowledge that all of our children
presently have residences at both of our homes. They will spend time at both of
our homes based upon a schedule which we mutually agree upon is in their best
interest. We both agree that the actual physical residence of our children may be
changed at any time as we mutually agree.
All decisions pertaining to the education, discipline, health, extracurricular and
summer activities, religious training, medical and dental care, and welfare of our
children will be decided by both of us after reasonable and adequate discussion.
We also agree that the parent with physical custody shall have control over the
minor day-to-day decisions affecting the children, including any medical OT dental
emergencies, We agree that if, after reasonable attempts, we are unable to reach
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an agreement on any of the decisions affecting our children, we will jointly seek
professional mediation to resolve our differences.
We also agree that each of us has the right to know of any significant
circumstances or significant decisions that affect our children and that each of us
has the right to any medical, dental, or school records of our children. Neither of
us will do anything to hamper or interfere with the natural and continuing
relationship between our children and the other parent.
We both realize that the well-being of our children is of paramount importance
and, therefore, we agree that our children should have as much contact as possible
with both parents. We intend to attempt to spend Easter, Thanksgiving, Christmas
and at least one vacation together as a family. In the event, however, that we
decide not to spend the above named holidays and vacation together, we agree to
alternate which holiday all children spend with each parent as follows: starting
with the first holiday we don't spend together as a family, we will alternate every
holiday for Easter, Thanksgiving and Christmas. ("The holiday" shall mean at
least two full consecutive days, one of which is the actual holiday day.)
We also agree that all of the children should spend some time with each parent
and also with their siblings. In the event, however, that we agree that one or more
of the children maintain the majority oftheir physical residence with only one of
us, the other parent has the right to be with all of the children at least every other
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weekend (from Friday evening to Sunday evening) and also two weekday
evenings with one weekday overnight stay_ At times when there is no school, the
weekday stay should include one entire day (i.e.: from one evening, overnight, the
next day until late evening).
We additionally agree to use our very best efforts to insure that our children
receive the most care, love and affection possible from both parents throughout
their entire childhood.
6. We both agree that the Husband will pay to the Wife, as child support, the amount
of$ 500 per month. The payment will begin on the first day of November 2004,
and will continue monthly. Monthly payments will continue until each child
reaches the age of eighteen or graduates from high school, which ever occurs
later, and will end when the last child reaches eighteen or graduates from high
school, which ever occurs later, except that regardless of the preceding
stipulation, the $500 peT month payment will continue until October 1,2005. We
both agree that the payment will be reduced each time one of the children reaches
the age of eighteen or graduates from high school, which ever occurs later. The
reduction will be in the same proportion as the per child reductions in the "Basic
Child Support Schedule" contained in Rule 1910.16-3. Support guidelines, of the
Pennsylvania Code. We both agree that this obligation is subject to modification
by mutual agreement (based upon changes in either spouses' economic
circumstances or changes in the status of the children), or by either party filing for
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support modification. We agree that the required child support payments should
be made directly to the parent to whom they are due.
7. We both agree that neither of us shall remain as the beneficiary on any life
insurance policy carried by the other. We both agree that both spouses will carry
and maintain life insurance in the amount of $100,000 each (or in a lesser amount
at a maximum cost net of experience rebates of$275 year. If the net cost exceeds
$275, Wife agrees to reimburse Husband for the difference) with the AICPA
Insurance Trust CPA Plan, Wife's policy # 5609420, Husband's policy #
5609427-7, naming our children as sole irrevocable beneficiaries until the earlier
date that our youngest child has become self-supporting or reached age 22.
8. We both agree that as long as Husband is employed as a federal employee, he will
carry and maintain health, dental, and hospitalization insurance for each the
children's benefit as is now in effect until the earlier date that each child has
become self-supporting or reached age 22.
9. Wife agrees to cooperate fully in completing the process required for an
annulment of the marriage in the Roman Catholic Church at Husband's request.
Husband agrees to pay all related costs.
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10. We both agree that we will cooperate in the filing of any necessary tax returns.
We also agree that any tax refunds or taxes due for 2004 will be split in
proportion to our gross income for federal income tax purposes.
We also agree that starting with the tax year ending December 2004 and in
subsequent years, Husband can claim sons Michael and Matthew and Wife can
claim daughter ShaMon as dependents without regard to any conditions. We
agree that neither of us will claim the other children as dependents. We agree that
we may mutually agree to change this arrangement at any time.
11. We both desiTe that, in the event of our divorce or dissolution of marriage, this
marital settlement agreement shall be incorporated into but shall not merge into
any subsequent decree of divorce or dissolution of marriage and that, by the terms
of the judgment or decree, we both be ordered to comply with the terms of this
agreement, but that this agreement shall survive.
12. We both agree to disclose our income information to each olher on an annual
basis.
13. PERSONAL PROPERTY. The parties hereto mutually agree that they have
effected a satisfactory division of the furniture, household furnishings, appliances,
and other household and personal property between them and they mutually agree
that each party shall, from and after the date hereof, be the sole and separate
owner of all such tangible personal property presently in his or her possession,
except for the property detailed on Scheduled A attached, whether said property
was heretofore owned jointly or individually by the parties hereto, and this
agreement shall have the effect of an assignment or receipt from each party to the
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other for such property as may be in the individual possessions of each of the
parties hereto.
14. WAIVER OF FURTHER ALIMONY, SUPPORT AND ALIMONY PENDENTE LITE.
15. The parties acknowledge that they are aware of the income, education, income
potential, and assets and holdings of the other or have had full and ample
opportunity to become familiar with such items, Both parties acknowledge that
they are able to support and maintain themselves comfortably, without
contribution from the other beyond that as provided for in this Property
Settlement Agreement, upon the income and assets owned by each of them. The
parties hereby accept the mutual covenants and terms of this Agreement and the
benefits and properties passed to them hereunder in lieu of any and all further
rights to support or alimony for themself, counsel fees, and alimony pendente lite
at this time and during any and all further or future actions of divorce brought by
either of the parties hereto and the parties do hereby remise, release, quit claim,
and relinquish forever any and all right to support, alimony, alimony pendente
lite, counsel fees and expenses beyond those provided for herein, during the
pendency of or as a result of any such actions, as provided by the Divorce Code of
Pennsylvania or any other applicable statute, at this time and at any time in the
future.
16. WAIVER OF EQUITABLE DISTRIBUTION. The parties acknowledge that
each of them have had a full and ample opportunity to consult with counsel of
their choice regarding their claims arising out ofthe marriage and divorce and that
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they have specifically reviewed their rights to the equitable distribution of marital
property, including rights of discovery, the right to compel a filing of an
Inventory and Appraisement, and the right to have the court review the assets and
claims of the parties and decide them as part of the divorce action. Being aware of
those rights, and being aware of the marital property owned by each of the parties,
the parties hereto, in consideration of the other terms and provisions of this
agreement, do hereby waive, release and quitclaim any further right to have a
court or any other tribunal equitably distribute or divide their marital property and
do hereby further waive, release and quitclaim any and all claim against or
interest in assets now currently in the possession or held in the name of the other,
it being their intention to accept the terms and provisions of this agreement in full
satisfaction of all of their claims to the marital property of the parties and the
equitable distribution of the same.
17. WAIVER OF EST A TE RIGHTS. Husband releases his inchoate intestate rights
in the estate of Wife and Wife releases her inchoate intestate rights in the estate of
Husband, and each of the parties hereto by these presents for himself or herself,
his or her heirs, executors, administrators, or assigns, does remise, release, quit
claim, and forever discharge the other party hereto, his or her heirs, executors,
administrators, or assigns, or any of them, of any and all claims, demands,
damages, actions, causes of action or suits of law or in equity, of whatsoever kind
or nature, for or because of any matter or thing done, omitted, or suffered to be
done by such other party prior to the date hereof; except that this release shall in
no way exonerate or discharge either party hereto from the obligations and
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promises made and imposed by reason ofthis agreement and shall in no way
affect any cause of action in absolute divorce which either party may have against
the other.
18. WAIVER OF PROPERTY CLAIMS AND ESTATE CLAIMS. Except as
heTein otherwise provided, each party hereto may dispose of his or hef property in
any way, and each party hereby expressly waives and relinquishes any and all
rights he or she may now have or hereaftef acquire, under the present or future
laws of any jurisdiction, to share in the property or the estate of the other as a
result ofthe marital relationship, including, without limitation, the right to
equitable division of marital property, alimony, alimony pendente lite, and
counsel fees, except as provided for otherwise in this Agreement, dower,
courtesy, statutory allowance, widow's allowance, right to take in intestacy, right
to take against the will of the other, and right to act as administrator or executor of
the other's estate, and each 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.
19. REPRESENTATION AS TO NO DEBTS, The parties hereto mutually
represent to the other than neither of them has incurred any debts in the name of
the other not previously disclosed or provided for in this agreement. Each of the
parties hereby represents to the other that neither one of them have incurred Of
contracted for debts in the name of the other or for which the other is or would be
legally liable from and after the date of the parties' separation. Both parties hereto
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mutually agree and promise that as of November 1,2004, neither will contract or
otherwise incur debts in the other's or joint names without the prior permission
and consent of the other party hereto. Both parties hereto represent and warrant to
the other party that they have not so contracted any debts unbeknownst to the
other up to the time and date ofthis Agreement.
20. DISCLOSURE. Both ofthe parties hereto represent to the other that they have
made full disclosure of the assets and income sources owned, controlled, or
enjoyed by either of them and that neither party hereto has withheld any financial
information from the other. Each of the parties represents that they have reviewed
such information, as well as the law of Peffi1sylvania as it relates to their rights,
obligations, and claims arising out of their marriage and of any divorce action
which has or may be filed between the parties with an attorney of their choice, or
had the opportunity to review such matters with an attorney of their choice and
voluntarily decide not to do so. Further, the parties each acknowledge that they
are aware that they have the right to compel the other party to provide full
financial information about all assets owned by either party and all liabilities
owned by either party and have the right to have a court force such disclosure in a
divorce action. Being aware ofthose rights, the parties expressly waive the right
to further disclosure or discovery regarding marital assets, liabilities, incomes,
and finances and agree that they are satisfied with their understanding of their
legal rights and obligations. Being so aware and satisfied, the parties mutually
accept the terms and provisions of this agreement in full satisfaction of any and all
rights or obligations arising of their martial status or the divorce action now
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pending or to be filed between them.
21. We each understand that we have the right to representation by separate lawyers.
We each fully understand our rights and we each consider the terms of this
agreement to be fair and reasonable. Both of us agree to execute and deliver any
documents, make any endorsements, and do any and all acts that may be
necessary or convenient to carry out all of the terms of this agreement.
We agree that this document is intended to be the full and entiTe settlement and
agreement between us regarding our marital rights and obligation and that this agreement
should be interpreted and governed by the laws of the State of Pennsylvania.
We also agree that every provision of this agreement is expTessly made binding upon the
heirs, assigns, executors, administrators, successors in interest, and representatives of
each of us.
Signed and dated this 99 th day of December, 2004.
Witness
(lPJ7A _.D ~ ~ 72e,~i....'
Corinne Patricia Rebinski
) :t-J ~
Hen Leonard Rebinski
State of Pennsylvania
SS.
County of Cumberland
NOTARIAL SEAL
GWEN A lEARY, NotilfY Public
Mechanicsburg Fv,.o.. Cumberland County
My Commiss;o', 'c xpires A s117, 2006
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e!UflI(}
On December~Cj th, 2004, Corinne Patricia Rebinski and Henry Leonard Rebinski
personally came before me and, being duly sworn, did state that they are the persons
described in the above document and that they signed the above document in my
presence as a free and voluntary act for the purposes stated.
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Marital Settlement Agreement of Corinne P. and Henry L. Rebinski
Schedule A
Items jointly owned as of November 1,2004 (located at either the family home or Wife
new residence) which Husband and Wife agree to share:
I. Family photos and photo albums
2. Collection of children's mementos
3. Camcorder
4. Kodak Easyshare Camera
5. Breadbaker
6. Collection of VCR tapes and DVD's existing as of November I, 2004
7. Christmas decorations
8. Halloween decorations and costumes
9. Craft supplies
10. Games
11. Recipes and cookbooks
12. Shopvac and Steamteam steam cleaner attachment
Furthermore Husband and Wife acknowledge that the following items located at the
family home belong to Wife and she has pel111ission to retrieve them upon adequate
advance notice to Husband:
I. Corinne's mother's teakwood dining table (in exchange for our other oak dining
table if requested)
2. Collection of stuffed animals
3. Two Paintings located on the walls ofthe master bedroom
4. Decorations and paintings hanging on two kitchen/dining room walls
5. Two paintings painted by Wife's great Uncle located in the family room
6. Ski equipment
I'
I .
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon the
Plaintiff and Defendant by regular mail, postage prepaid, addressed as follows:
Mr. Henry L. Rebinski
7108 Salem Park Circle
Mechanicsburg, PA 17055
Ms. Corinne P. Rebinski
c/o Brown Schultz Sheridan & Fritz
P.O. Box 67865
Harrisburg, PA 17106-7865
Date:
15 April 2005
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Amy arklns
Secretary for Samuel L. Andes
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Corinne Patricia Rebinski
Plaintiff
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RECEIVED APR 2 72005r
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
Henrv Leonard Rebinski
Defendant
NO.
() 'f- G r) q"3
RETIREMENT BENEFITS COURT ORDER
THIS MATTER having come before the court on motion, and the court, afteT
reviewing the motion and being otherwise fully advised of the matter:
ORDERED: Corinne Patricia Rebinski, social security # 173-56-6931, residing
at 4 Mayfair Court, Hampden Township, Cumberland County, Pennsylvania, is awarded
$ 54,92 1,00 from the Federal Retirement Thrift Saving Plan account of Henry Leonard
Rebinski, social security # 145-54-7970, residing at 7108 Salem Park Circle, Hampden
Township, Cumberland County, Pennsylvania as of November 1,2004.
FURTHER ORDERED: Earnings will be paid on the amount of the entitlement
undeT this ORDER until payment is made.
FURTHER ORDERED: The entire amount awarded is to be transferred to the
Plaintiffs retirement account in the Brown Schultz Sheridan Fritz Retirement Plan, clo
Corinne P. Rebinski, s.s. # 173-56-6931.
Mail to:
ATis Retirement Services
P.O. Box 1318
270 Walker Drive, Suite 200
State College, PA 16804-1318
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Accepted and Ordered thisJi day of ~~, 2005.
Judge
CONSENT TO ORDER:
i PLAINTIFF
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CORINNE P. REBINSKI,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2004-6093 CIVIL TERM
HENRY L. REBINSKI,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
6 December 2004 and served upon the Defendant on or about 20 December 2004.
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II have elapsed from the date of filing of the complaint and the date of service of the complaint
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2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
0In the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Il11tention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention
to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and i to participate in counseling and, being so advised, do not request that the
Oourt require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
rEJlating to unsworn falsification to authorities.
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IN THE COURT OF COMMON
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CORINNE P. REBINSKI,
Plaintiff
CIVIL ACTION - LAW
NO. 2004-6093 CIVIL TERM
HENRY L. REBINSKI,
Defendant
IN DIVORCE
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
a December 2004 and served upon the Defendant on or about 20 December 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
Have elapsed from the date of filing of the complaint and the date of service of the complaint
dn the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Imtention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention
hi> Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
tthe Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
qourt require that my spouse and I participate in counseling prior to the divorce becoming
fiflal.
I verify that the statements made in this Affidavit are true and correct and I understand
t~at false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904
n:jlating to unsworn falsification to authorities.
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CORINNE P. REBINSKI, ) INTHE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 2004-6093 CIVIL TERM
HENRY L. REBINSKI, )
Defendant ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
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1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
3, I understand that I will not be divorced until a divorce decree is entered by the court
alnd 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to
uhsworn falsification to authorities.
1"5 FtpJ2;/ .:<rJ05
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C RINNE P. REBINSKI
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CORINNE P REBINSKI, ) INTHECOURTOFCOMMON
Plaintiff ) PLEAS OF CUMBERLAND
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)
vs. ) CIVIL ACTION - LAW
)
) NO. 2004-6093 CIVIL TERM
HENRY L. REBINSKI, )
Defendant ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand that
false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
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CORINNE P. REBINSKI,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
V5.
CIVIL ACTION - LAW
NO. 2004-6093 CIVIL TERM
I' HENRY L. REBINSKI,
Defendant
IN DIVORCE
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I! TO THE PROTHONOTARY:
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PRAECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 Ic).
2. Date and manner of service of the Complaint: Acceptance of Service filed bv Plaintiff's
qounsel indicatinq service on or about 20 December 2004.
3. Complete either Paragraph la) or (b):
I
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(a) Date of execution of the Affidavit of Consent required by Section 3301
(c) of the Divorce Code: By Plaintiff: 15 April 2005 By Defendant: 7 April 2005
Ib) 11) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending:
None.
5. Complete either (a) or (bl:
la) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: Dated 15 April 2005 and filed contemporaneouslv herewith.
Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 7 April 2005 and filed contemporaneouslv herewith.
Date: 15 April 2005
By
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Samuel L. And
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
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$
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PENNA.
STATE OF
CORINNE P. REBlNSKl,
Plaintiff
No.
2004-6093
VERSUS
HENRY L. REBINSKl,
Defendant
DECREE IN
DIVORCE
~~
2005
--'
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AND NOW,
IT IS ORDERED AND
CORINNE P. REBINSKI
, PLAINTIFF,
DECREED THAT
HENRY L. REBINSKI
, DEFE N DANT,
AND
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:
NONE
By
+
+
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. -
Corinne Patricia Rebinski
Plaintiff
I
RECEIVED APR 2 7 2005 r
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
~
VS.
CIVIL ACTION - LAW
Henrv Leonard Rebinski
Defendant
NO.
[) '-1- C, () q~
RETIREMENT BENEFITS COURT ORDER
THIS MATTER having come before the court on motion, and the court, after
reviewing the motion and being otherwise fully advised of the matter:
ORDERED: Corinne Patricia Rebinski, social security # 173-56-6931, residing
at 4 Mayfair Court, Hampden Township, Cumberland County, Pennsylvania, is awarded
$ 54,921.00 from the Federal Retirement Thrift Saving Plan account of Henry Leonard
Rebinski, social security # 145-54-7970, residing at 7108 Salem Park Circle, Hampden
Township, Cumberland County, Pennsylvania as of November 1,2004.
FURTHER ORDERED: Earnings will be paid on the amount of the entitlement
under this ORDER until payment is made.
FURTHER ORDERED: The entire amount awarded is to be transferred to the
Plaintiff's retirement account in the Brown Schultz Sheridan Fritz Retirement Plan, clo
Corinne P. Rebinski, s.s. # 173-56-6931.
Mail to:
Aris Retirement Services
P.o. Box 1318
270 Walker Drive, Suite 200
State College, P A 16804-1318
~ Il.A:J
Accepted and Ordered thisJ8 day of ------+:. ,2005.
Judge
CONSENT TO ORDER:
PLAINTIFF
C~ ~//'1,4 '(
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Date '
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DEFENDANTIP~TI?r~NT
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