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Home My WebLink About05-5230 Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 ELISABETH ROWENA BREWER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO.O~- S~O CIVIL TERM DAVID LEWIS BREWER, JR., 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 following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Front and Market Streets, Harrisburg, Pennsylvania 17101. 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 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion do demanda. U sted puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE EST A DEMANDA A UN ABODAGO INMEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SER VICIO, V A Y A EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A DlRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PAl 70 13 (717) 249-3166 Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (717) 540-9170 ELISABETH ROWENA BREWER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. OS'- ..5'~30 CIVIL TERM DAVID LE\VIS BREWER, JR., Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Elisabeth Rowena Brewer, by her attorney, Cara A. Boyanowski, Esquire, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Elisabeth Rowena Brewer, is an adult individual who resides at 5253 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, David Lewis Brewer, Jr., is an adult individual who resides at 5253 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Plaintiff has been a bona fide resident ofthe Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. County, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the United States of America. 6. There have been no prior actions in divorce between the parties. 7. Plaintiff avers that there are no children born of this marriage. 8. The Plaintiff and the Defendant are not members of the Armed Services of the United States or any of its allies. 9. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. She has declined counseling. 10. The causes of action and sections of Divorce Code under which Plaintiff is proceeding are: A. Section 3301 (c). The marriage of the parties is irretrievably broken. After ninety (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. B. Section 3301 (d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on September 28,2005. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II EQUIT ABLE DISTRIBUTION 11. Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as though set forth in full. 12. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of their marriage, May 19, 2001, until the date of their separation, September 28,2005. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property . I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. S4904 relating to unsworn falsification to authorities. ("r: .~ {l By: t(lM~/LU~ Elisabeth Rowena Brewer, Plaintiff Date: \O~ 3~o5 By:~~anCM3L Attorney No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (717) 540-9170 Attorney for Plaintiff f"'... ---lq. ~ ' ..J 9.; _ N~ -~D ~ ~ ~ ~ . r: % B % (3 ..c ~ I ...t,~ ~ .-- Vb ~~ :E r r(2 r:-? ';":-;; r--=> (^) ~=; ..:n Z::'t'l :.-:! r. c-' --I I Ui ~ -r:J -~. ~? ~.) (j; AGREEMENT BETWEEN ELISABETH ROWENA BREWER AND DAVID LEWIS BREWER, JR. Cara A. Boyanowski, Esquire Counsel for Wife Susan Kay Candiello, Esquire Counsel for Husband 1 ,0 ~.~ ,-- !:J u;~ "'-1 r _-j -,. r':-1Z! 1"..) i -~n .< TABLE OF CONTENTS SECTION I: Introduction 3 SECTION II: General Provisions 4 SECTION III: Alimony and Alimony Pendente Lite Provisions 10 SECTION IV: Property Distribution Provisions 10 SECTION V: Closing Provisions and Execution IS 2 SECTION I INTRODUCTION THIS AGREEMENT made this :5 rd day of NOLlunb.L~.J , 2005, by and between ELISABETH ROWENA BREWER ("Wife") and DAVID LEWIS BREWER, JR. ("Husband"). WITNESSETH: WHEREAS, Elisabeth Rowena Brewer, Social Security Number 196-48-4128, was born on March 23, 1972, and currently resides at 5253 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. WHEREAS, David Lewis Brewer, Jr., Social Security Number 165-54-8360, was born on June 20, 1970, and currently resides at 5253 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. WHEREAS, the parties hereto are Husband and Wife, having been married on May 19, 2001, in Harrisburg, Dauphin County, Pennsylvania. Wherein thereafter, the parties separated on September 28, 2005. WHEREAS, the union of the parties produced no children. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of such property; the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the mutual promises, set forth herein and for other good and valuable considerations, Wife and Husband, each intending to be legally bound hereby agrees as follows: 3 SECTION II GENERAL PROVISIONS 1. MUTUAL CONSENT DIVORCE The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of Section 3301 (c) ofthe Divorce Code of 1980, as amended and will execute the documents necessary to effectuate a divorce under those provisions concurrently with the execution of this Agreement. 2. EFFECT OF DIVORCE DECREE The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 3. AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE DECREE The provisions of this Agreement may be incorporated by reference but shall not be deemed merged into any judgment or decree for divorce obtained by either party. This agreement shall survive any such final decree of divorce, shall be entirely independent thereof, and the parties intend that all obligations contained herein shall retain their contractual nature in any enforcement proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement action filed to the divorce complaint. 4. DATE OF EXECUTION The "date of execution" or "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 5. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to Wife by her attorney, Cara A. Boyanowski, Esquire and the provisions of this Agreement and their legal effect have been fully explained to Husband by his attorney, Susan Kay Candiello, Esquire. The parties acknowledge that they fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 6. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement, and each party acknowledges that there has been a full and fair disclosure of the parties' marital assets and debts and the parties' respective incomes, which has been provided to each party. 7. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all ofthe property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a Court hold hearings and make decisions on the matters covered by this Agreement, which Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Given said understanding and acknowledgment, both parties hereby waive the foregoing procedural rights. 8. BANKRUPTCY The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to 5 terminate this Agreement in which event the division of the parties' mutual assets and all other rights determined by this Agreement shall be subject to Court determination the same as if the parties had never executed this Agreement. 9. TAX PROVISIONS The parties believe and agree, and have been so advised by their respective attorneys, that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 10. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any contact, restraint, interference or authority, direct or indirect, by the other in all respects as fully as ifthey were unmarried. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means whatsoever with him or her. 11. MUTUAL RELEASES Except as otherwise expressly provided by this Agreement: A. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either 6 may have or at any time hereafter have for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights, agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the other not expressly set forth herein. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrations, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties or otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities or the other or by way of dower, curtsy, widow's rights, family exemption or similar allowance, 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 or the United States, or any other country. It is expressly understood, however, that neither the provisions of this release nor the subsequent entry of a divorce decree are intended to defeat the right of either party to receive any insurance proceeds at the death of the other of which she or he is the named beneficiary (whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest or residuary portion of the other's estate under his or her will, or to act as personal representative or executor if so named by the will of the other, whether such will was executed prior or subsequent to this Agreement. C. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. 12. PRESERVATION OF RECORDS Each party will keep and preserve for a period offour (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 7 13. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any subsequent default ofthe same or similar nature. 14. REMEDIES IN THE EVENT OF A BREACH Any party breaching this Agreement shall be liable to the other party for all costs, including reasonable counsel fees incurred by the non-breaching party to enforce his or her rights under the provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of whether litigation is instituted. In the event of default of any of the provisions of this Agreement by one of the parties, the remedies available to the other are cwnulative and include all remedies at law and in equity, including those for breach of contract, under theories or equity, under the Domestic Relations Code as amended, including Section 3105 of the Domestic Relations Code (which includes contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies specifically referred to in this Agreement. 15. LAW OF PENNSYL VANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 16. AGREEMENT BINDING ON HEIRS Except as may otherwise be provided, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assIgns. 17. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 8 18. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (within ten (10) days at most after demand thereof) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 19. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision hereof be construed as a waiver of strict performance of any other obligations herein. 20. SEVERABILITY AND INDEPENDENT AND SEP ARA TE COVENANTS The parties agree that each separate obligation contained in this Agreement shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 21. MANNER OF GIVING NOTICE Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return receipt requested, to Elisabeth Rowena Brewer, 5253 Meadowbrook Drive, Mechanicsburg, Pennsylvania 17050, or counsel for Elisabeth Rowena Brewer, or such other address as Wife from time to time may designate in writing. Any notice required by this Agreement to be sent to Husband shall be sent by certified mail, return receipt requested, to David Lewis Brewer, Jr., 5253 Meadowbrook Drive, Mechanicsburg, Pennsylvania, 17050, or counsel for David Lewis Brewer, Jr., or such other address as Husband from 9 Time-to-time may designate in writing. 22. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. SECTION III ALIMONY AND ALIMONY PENDENTE LITE PROVISIONS AND HEALTH INSURANCE PROVISIONS 1. ALIMONY The parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance, alimony pendente lite or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other payment for support, maintenance, alimony pendente lite or alimony. SECTION IV PROPERTY DISTRIBUTION PROVISIONS 1. PERSONAL PROPERTY Husband and Wife do hereby acknowledge that they have divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. A 10 list of the personal property of the parties depicting who will receive the item, is attached hereto and incorporated herein as Exhibit "A." It is expected that Wife will remove her designated items from the Marital Residence on or before November 5,2005. Husband agrees to permit Wife access to the Marital Residence on or before this date, so Wife may remove her property. It is agreed between the parties that all property designated on the list as "Beth" shall be the sole and separate property of Wife; and all property designated on the list as "David" shall be the sole and separate property of Husband. The parties do hereby specifically waive, release, renounce and forever, abandon any claims, which either may have with respect to the listed items, which shall thereafter be the sole and exclusive property of person so designated. 2. RETIREMENT BENEFITS A. Pinnacle Health System 403 (b) TSA T Plan - Wife was a Participant in the Pinnacle Health System 403 (b) TSA T Plan. She participated in and contributed to this retirement plan prior to the parties' date of marriage. The parties agree that the sum of$7,630.29 reflects the pre-marital portion of this retirement account. The parties acknowledge that the present date value of this account is $11 ,915.70, leaving a marital value of$4,285.41. The parties agree that Wife shall retain sole ownership and possession over this asset, and Husband specifically releases and waives any and all interest, claim or right he may have to this asset. B. Pinnacle Health Svstem 403 (b) TSAT Plan - Husband was a Participant in the Pim1acle Health System 403 (b) TSAT Plan. He participated in and contributed to this retirement plan prior to the parties' date of marriage. The parties agree that the sum of $9,680.33 reflects the pre-marital portion of this retirement account. The parties acknowledge that the present date value of this account is $11,563.04, leaving a marital value of$I,882.71. The parties agree that Husband shall retain sole ownership and possession over this asset, and Wife specifically releases and waives any and all interest, claim or right she may have to this asset. C. TIAA CREF Retirement Account - Wife was a Participant in the TIAA CREF retirement plan during the parties' marriage. The parties acknowledge that the present date value of this account is $13,685.95. The parties agree that Wife shall retain sole ownership and possession over this asset, and Husband specifically releases and waives any and all interest, claim or right he may have to this asset. D. Fidelity Retirement Savinl!:s Account (Milton S. Hershev Medical Center) - Wife is a Participant in the Fidelity Retirement Savings Account, through her employment with Milton S. Hershey Medical Center. The parties acknowledge that the present date value of this account is $17,933.56. The parties agree that Wife shall retain sole ownership and possession over this asset, 11 and Husband specifically releases and waives any and all interest, claim or right he may have to this asset. E. Fidelity Retirement Saviul!s Account (Holv Spirit Hospital) - Husband is a Participant in the Fidelity Retirement Savings Account, through his employment with Holy Spirit Hospital. The parties acknowledge that the present date value of this account is $806.82. The parties agree that Husband shall retain sole ownership and possession over this asset, and Wife specifically releases and waives any and all interest, claim or right she may have to this asset. F. State Farm Roth Individual Retirement Account - Wife is the owner of a Roth IRA through State Farm Bank. The parties acknowledge that the present date value of this account is $2,537.97. The parties agree that Wife shall retain sole ownership and possession over this asset, and Husband specifically releases and waives any and all interest, claim or right he may have to this asset. G. State Farm Roth Individual Retirement Account - Husband is the owner of a Roth IRA through State Farm Bank. The parties acknowledge that the present date value of this account is $5,427.4 7. The parties agree that Husband shall retain sole ownership and possession over this asset, and Wife specifically releases and waives any and all interest, claim or right she may have to this asset. 3. INVESTMENT ACCOUNTS Husband is the owner of an UBS Financial Service, Inc. investment account (Account No. UH-H2552-35), with a present date value of $372.60, and an E Trade Financial stock account (Account No. 6663-5566), with a present date value of$6,065.18. The parties agree that Husband shall retain sole ownership and possession over these two investment accounts and Wife specifically releases and waives any and all interest, claim or right she may have to these assets. 4. BANK ACCOUNTS Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that these accounts shall be the sole and separate property of the person in whose name they are titled and each party waives any right, title or interest he/she may have in the other party's account. 12 5. AUTOMOBILES Husband and Wife are the owners of various automobiles. Husband and Wife agree that these vehicles shall be the sole and separate property of the person in whose name they are titled and each party waives any right, title, or interest he/she may have in the other party's vehicle. 6. CASH PAYMENT The parties acknowledges that in order to effectuate a 50/50 distribution of the marital assets, Husband must make a cash payment to Wife of$3,280.00. Wife agrees to defer payment of this sum for a period of no more than one hundred and twenty months from the date of signing of this Agreement, so long as Husband continues to reside in and holds title to the Marital Residence. During this period of time, Husband will not incur interest changes on the sum he must pay to Wife, nor will he be penalized for satisfying the obligation prior to the expiration of one hundred and twenty months term. In the event Husband lists the property for sale, the above loan terms shall become null and void, and Husband will satisfy his $3,280.00 obligation to Wife from the proceeds of the sale of the Marital Residence. Said debt to be paid to Wife on the date of settlement. 7. CURRENT LIABILITIES Wife and Husband represent that they have taken all steps necessary to make sure that no credit cards or similar accounts exist as of the date of execution ofthis Agreement which provide for joint liability. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable. 8. PAYMENT OF LEGAL FEES Each party shall assume responsibility for his/her own attorney fees, costs, and expenses. 9. AFTER-ACOUlRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired by him or her after the parties' date of separation, that being, September 28, 2005, with full 13 power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as through he or she were unmarried. 10. REAL ESTATE A. Marital Residence: The parties acknowledge that they are the owners of real property, located at 5253 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "Marital Residence"). This property is encumbered with a mortgage. The parties agree as follows with respect to the Marital Residence: (1) Husband shall apply for refinancing of the existing Mortgage in order to remove Wife's name from it. The refinance shall be completed on or before the 30th day following the execution date of this Agreement. Husband shall pay all costs associated with the refinancing of the existing mortgage. In the event Husband is unable to obtain refinancing on or before the 30th day following the execution date of this Agreement, he will immediately list the Marital Residence for sale and pay to Wife the sum of $3,280.00 from the sales proceeds, as set forth in Section IV, Paragraph Six, above. (2) Wife shall make, execute and deliver all documents in the usual form conveying, transferring and granting to Husband all of Wife's right, title and interest in and to the Marital Residence. Husband shall prepare the deed of conveyance, at his expense. Wife agrees to execute the Deed at, or before settlement on, the refinancing ofthe existing mortgage. In the event Wife signs the Deed prior to the date of settlement, the escrow agent agrees to hold the Deed in escrow, until such time as the refinance is complete. (3) Wife agrees that as of the date of execution of this Agreement, any and all title policies and any other policy of insurance with respect to the Marital Residence shall be endorsed to reflect Husband as sole owner thereof and further agrees that Husband shall be entitled to receive any payments now or hereafter due under any such insurance policies. (4) Except as otherwise provided herein, commencing on the execution date of this Agreement, Husband shall be solely responsible for all costs, expenses and liabilities associated with or attributable to the Marital Residence regardless of when the same shall have been incurred including, but not limited to, taxes, insurance premiums and maintenance, and Husband shall keep Wife and her property, successors, assigns, heirs, executors and administrators indemnified and held harmless from any liability, costs or expense, including attorney's fees, which may be 14 incurred in connection with such liabilities and expenses or resulting from Wife's ownership interest in said property. SECTION V CLOSING PROVISIONS AND EXECUTION Each of the parties has carefully read and fully considered this Agreement and all of the statements, terms, conditions, and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals on the date indicated below. IId.{)Jft~/ ELISABETH ROWENA BREWER /'-j /,?(,"---J , / /~,/jj. ~ , .. ,'" // ' ...J .., /j''''' " If7E' II/Jk DATE //-J-os - DATE D // / 15 EXHIBIT "A" 16 YYm~k:cJ~{L - -----_._-" --~~- ~ ___Cor ~9DS!Y\.9- __::. l::lov.Jl^J..- _~Y-~ RC.-~, -=- ~ _~u_____. "~-~ _ _~_tm,G~ -:. 1:x>-.\J<.c\ 'Tu.Cr"'-Q..-V\--\. YY\c..../'->-- -: D~q-, .-. ..---."---.-------------, --rn,~ ~ :;:;-("~'c.---... ~o....A. -_ ~Jlck: _..__._------~_..._-_.-.....:.-,. ,Ll~~---= 'R,R.T-- ,_~~ :::_~\llcl-.. _~\~O~_ _ 'Y \~":~<---- ~ ~.... :: hG'l(l cf,. \ tJ c \.U....-- ,-::- -r~'-h.., ___.\l ~ .-."'-___..,__~~_ \. 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D(]\~~ - --trL~Q&,--~-~ ____ \'Y'\.CiCI'\ W\~ -: ~ ~ --..,.---------- . ____~~L '\6o..V \m Q.\I\ i' \ -'JIL.- OCLCho,-""M -- 67~ - ~_.- -_--\.-------- . -_.._-------~..;.------- ----.------ --+- ___" _ _____.._l.-;___~.___._ ---_---....:...--_---~ ---._------------ , -- ---- -------_._~- " / , . . Cara A. Boyanowski, Esquire Supreme Court I.D, No, 68736 SERRA TELL! SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 Te1epbone: (717) 540-9170 Facsimile: (717) 540-5481 Attorney for Plaintiff, Elisabeth Rowena Brewer ELISABETH ROWENA BREWER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 05-5230 CIVIL TERM DAVID LEWIS BREWER, JR., 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 S3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: A copy of the Divorce Complaint was served upon Defendant, David Lewis Brewer, Jr., by certified mail, restricted delivery, on October 12,2005. A copy of the Affidavit of Service and the Domestic Return Receipt card, signed by Defendant, have been filed of record with this Honorable Court. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff: January 11,2006,2005; by Defendant: January II, 2006. ,. (b)(l) Date of execution of the affidavit required by S3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: Nf A. 4. Related claims pending: None. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record; a copy of which is attached: N/A. (b) Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: January 12,2006 (anticipated). Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: January 12, 2006 (anticipated). Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON Q~o~~ Supreme Court LD. No. 68736 2080 Linglestown Road Suite 20 1 Harrisburg, PA 17110 (717) 540-9170 r"~) -;\ .., r"0 r'~ ,I, en ..(; .< Cara A, Boyanowski. Esquire Supreme Court I.D. No. 68736 SERRA TELL! SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 Telephone: (7 I 7) 540-9170 Facsimile: (717) 540-5481 Attorney for Plaintiff, Elisabeth Rowena Brewer ELISABETH ROWENA BREWER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 05-5230 CIVIL TERM DAVID LEWIS BREWER, JR., Defendant IN DIVORCE AFFIDAVIT OF SERVICE Cara A. Boyanowski, Esquire, being duly sworn according to law, deposes and says that she is an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on the 12th day of October, 2005, she did serve upon David 1. Brewer, the Defendant in the foregoing case, a true and correct copy of the Complaint in Divorce by sending same to him, by celiified mail, rcstricted delivery, addressed to 5253 Meadowbrook Drive, Mechanicsburg, Pennsylvania, 17050. The receipt for said Complaint is attached hereto as Exhibit "A." Said copy of the Complaint was duly endorsed with notice to Defendant to appear and answer or the matter would proceed without him. Sworn to and subscribed before me this ,~ if Ldayof ~ ,2006. NOtARIAl. SEAL OEBAAA EVANGElISTl Nolorv Publl<: SUSQUElWlNA ~DAUPHIN COUN"lY My C<lmml$llOn Explle. Mav 7. 2008 BYO~~~~ow:b Attorney No. 68736 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 ~Lhj,ji01JL/t r-- l_. ,;. .-0', ~.2t" ,'~... . Complete items 1, 2. end 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the mailpiec8, or on the front if space permits. 1. Article Addressed to: (DL>ld 'J". brM-Vt> 5~3 UJodowbvcrl.. Dr. tJJ cro.n i <:1) Mg, ffi rlcfb D. Is delIvery address different If YES. enter delivery address be 3~se e Type Certified Mall [J Express Mall Registered 0 Return Receipt for Merchandise o Insured Msrl 0 C.O.D. 4. Restrtcted Delivery? (Extra Fee) Yes 2. Article Number l \ I I q ~\" rr",nsferfromsOlVicf>labeQ 1-CO - \ ..,0 -OCO<.:>"CO~ -<.J..l ~ PS Form 3811. February 2004 Domestic Return Receipt 102595-02-M-1540 - .... '-- ~'i~: :---:! -u., " r,J I:'? (.Jl :< Carn A, Boyanowski, Esquire Supreme Court I. D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 ELISABETH ROWENA BREWER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 05-5230 CIVIL TERM DAVID LEWIS BREWER, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under 93301(c) ofthe Divorce Code was filed on October 5, 2005. 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 ofa 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.A. 94904 relating to unsworn falsification to authorities. Date: January 11, 2006 By: f7 ' ~' L;{lt(/(I~ . '/4'/rlll(.(b/ Elisabeth Rowena Brewer, Plaintiff Social Security No. /'rr'Y - y-fVI Jl ;::.:; t-) -;fl t' " :",,) C1 Cara A. Boyanowski, Esquire Supreme Court 1.0. No. 68736 2080 Linglestown Road Suite 20! Harrisburg, P A 17110 (717) 540-9170 ELISABETH ROWENA BREWER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 05-5230 CIVIL TERM DAVID LEWIS BREWER, JR., Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. [understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree wiII 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.A. 94904 relating to unsworn falsification to authorities. Date: January 11, 2006 ~- , (/ ,.'j" ',' , By: (a'I:!:. ,42'/}"(/{1.~/;'u Elisabeth Rowena Brewer, Plaintiff " ~ v ~11 '-- f,j r:-? (,)"1 -- - Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (7J 7) 540-9170 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELISABETH ROWENA BREWER, Plaintiff v. NO. 05-5230 CIVIL TERM DAVID LEWIS BREWER, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) ofthe Divorce Code was filed on October 5, 2005. 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 ofa 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.A. ~4904 relating to unsworn falsification to authorities. Date: January 11, 2006 By: Social Security No. /&-5-- .->1-''63&D (_ _I r ~( r'0 .'''; (I\ , Cam A, Boyanowski, Esquire Supreme Court J.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 7110 (7] 7) 540-9170 ELISABETH ROWENA BREWER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 05-5230 CIVIL TERM DAVID LEWIS BREWER, JR., Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330l(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of ] 8 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. Date: January 11, 2006 By: .- C.._ {~..) l".) r}""' ",,:+::f. :t' . :t':f. :t':t' :f.:t':f. :f.~ :f.:f.:f.:t' :t':f.++:f.:t'+~+:t':t':f.:f.+:f.:f.++:t' ++:t'+'f.+:t'+ :f. :t'+++:f.:t':t':f.++++:t':f.++++""++~ . . IN THE COURT OF COMMON PLEAS . OFCUMBERLANDCOUNTY . . . . . . . . . . ELISABETH ROWENA BREWER, PENNA. STATE OF . . No. 05-5230 CIVIL TERM . . . . . . . . . . . . . . . . . . Plaintiff VERSUS DAVID LEWIS BREWER, JR., Defendant DECREE IN . . . . . . . . . . . . . . . . . DIVORCE f 18 ' , .200 ~ IT IS ORDERED AND AND NOW, ..~... / Elisabeth Rowena Brewer DECREED THAT , PLAI NTI FF, AND DaVId Lewis Brewer, , DEFENDANT, Jr. BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No claims remain. ** to tenus of said Agreement. . . . . . . . . . . . . . . . . . . '" + '" +: Of '" Of PROTHONOTARY +:t''f.+++.+++++++:t':t':t'+:t''t':t'+:t':t':f.+'+:f.'f+'f+:f.:t' :t''++.'t'+ . + '+ '+: 't' '+ '+ '+ :t' ,++' ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . _ tprl1 ~i'h 'fInTP;l iI" :Z /f/ , '" "rif"" M'l r'l . 're,(>?-?"4""~~ y3!J, , . ~'It7' [f I 1(}' rt?/ . .~, ~ .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,-0 ( 11'~\h~'+v, OllWfl'l0A 0,-evll.Q..y Plaintiff Vs lli\\\o...i~\A)\",12,C't'\}.}--l-r )6L Defendant FileNo. O':=:,- c;'()~...) IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff 1 defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or .1- after the entry of a Final Decree in Divorce dated qQrU(~ I S J'J90 hereby elects to resume the prior surname of C {i- +e.. , and gives this written notice avowing his 1 her intention pursuant to th~rovisions of 54 P.S. 704. Date: tJ3//0& {'t~fLJ. J1.~dv SIgnature (JI C/;4tIt/JIIe(b~ Signature of name being resumed COMMONWEh,LTH OF PENNSYLVANIA ) COUNTY OF u"M.krW ) On the ~ day of v;,ua.r, , 2006" , before me, the Prothonotary or the I notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ~ 'lifJ (fr 1f , Prothonotary or Notary Public ~--- "--"-1 ~=~ IIYCOUMlSSlON~__i:.=r fA-:rD :it;J,;) {,~-d Rtf ~ ~ 0 ""', c, 0 ~~ ~ -n <7' \) <- ::? "-- ~ in?J -..:) C). -orn GJ eN ;;:~'-rl U) F f}~ ,-:( -0 :1~ ~ ( - :~)rTl V .. j~ r- :1 :D r \D -< :-") I P JAlIWOl\ -" ,. , ....WTOM YAATO~ . 3t!IJllIltIlU03 'ftIl\IOl) ~T:!f\1'3 J.Iall'M , 1l1(,~ ,nIIAl!\IJ.t 23!l!~ \'\t'::,":1 >: ,.,.,__".P~_ .. __,.,,,00.. '.'~ ........,. ., .~t