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HomeMy WebLinkAbout05-5548ROBIN ELIZABETH SEIER, Plaintiff V. CHRIS RICHARD SEIER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PA CIVIL ACTION - LAW NO. 05-5-SW CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS [Pa. R.C.P. No. 1920.71, 42 Pa. C.S.A.] 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. 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 the Cumberland County Courthouse. 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. 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 South Bedford Street Carlisle, PA 17013 717.249.3166 ROBIN ELIZABETH SEIER, Plaintiff V. CHRIS RICHARD SEIER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 05-?5'S11 a' CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE MUTUAL CONSENT OR IRRETRIVABLE BREAKDOWN SECTION 3301(c) [Pa. R.C.P. No. 1920.72, 42 Pa. C.S.A.] 1. The Plaintiff is Robin Elizabeth Seier, who currently resides in the County of Cumberland, Commonwealth of Pennsylvania, with the address of 625 Brisbain Lane, Enola, PA, 17025. 2. The Defendant is Chris Richard Seier, who currently resides in the County of Cumberland, Commonwealth of Pennsylvania, with the address of 136 Kenlin Drive, Carlisle, PA, 17013. 3. 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 in Divorce. The Plaintiff and Defendant read, write and understand the English Language. 4. The Plaintiff and Defendant were married on August 5, 2000, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior legal actions, and there are no pending legal actions, of Divorce or Annulment in Cumberland County, Pennsylvania, nor in any other jurisdiction. 6. The marriage between the Plaintiff and Defendant is irretrievably broken and Plaintiff and Defendant consent to a mutual dissolution of the bonds of matrimony. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the Plaintiff and the Defendant to participate in counseling; notwithstanding, the Plaintiff does not desire counseling as the marriage is irretrievably broken. 8. The Plaintiff and Defendant have no mutual children, and consequently Child Custody and Child Support are not at issue. 9. The Plaintiff and Defendant have gainful employment, and consequently Spousal Support is not at issue. 10. The Plaintiff and Defendant have marital and non-marital personal and real property, however such is being equitably divided and distributed, and consequently Property Rights is not at issue. 11. The Plaintiff respectfully requests the Court to enter a Decree in Divorce. 1, the Plaintiff herein, verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. October 26, 2005 & a -_ Robin Elizabeth Seier 625 Brisbain Lane Enola, PA 17025 717.418.0140 G-A oE? a ROBIN ELIZABETH SEIER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY. PA v. CIVIL ACTION - LAW CHRIS RICHARD SEIER, NO.05-5548 CIVIL TERM Defendant IN DIVORCE SERVICE OF ORIGINAL PROCESS IN DIVORCE [Pa. R.C.P. Nos. 1920.4 and 1930.4, 42 Pa. C.S.A.] The Complaint in Divorce was duly filed on October 26, 2005. Service of Original Process of the Complaint in Divorce was attempted from October 26, 2005 to November 10, 2005, in accord with Pa. R.C.P. No. 1930.4(d), but was unsuccessful and not completed. Service of Original Process of the Complaint in Divorce was attempted, in accord with Pa. R.C.P. Nil. 1930.4(c), on November 10, 2005 and was successful and completed an November 14, 2005. Therefore, the undersigned hereby verifies that the Complaint in Divorce, as above-captioned, was duly served an the Defendant by United States First Class Certified Mail, addressed to the Defendant at 136 Kenlin Drive, Carlisle, PA, 17013, restricted to addressee delivery only, on November 14, 2005; the applicable Postal Service receipts, and returned receipt card signed by the Defendant, are attached hereto and made a part hereof as proof of Service of Original Process. The statements made in this Service of Original Process are true and correct, and the undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. November 15, 2005 Ap4i effrey J. Wand, Esquire P.O. Box 11731 Harrisburg, PA 17108 717.657.3650 [PA Supreme Court No. 38579] :attachment ROBIN ELIZABETH SEIER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW CHRIS RICHARD SEIER, NO. D5-5548 CIVIL TERM Defendant IN DIVORCE SERVICE OF ORIGINAL PROCESS IN DIVORCE [Pa. R.C.P. Noe. 1920.4 and 1930.4(c), 42 Pa. C.S.A.] ra C7 Er u- Q' rr M1 ru o Certmed Fee a C3 Retum Receipt Fee (Endorsement Required) Restnc[etl Delivery Fee (Endorsement Required) ru ¦ Complete items 1, 2, and 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 mailpiece, a on the front if space permits. 1. Article Addressed to: l 3b ? o?i? 13 MENEM FEDERAL SQUARE STATION HARRISBURG, Pennsylvania 171089998 4134870115-0095 ./10/2005 (717)238-2202 11:05:48 AM MEMO! NONE Sales Receipt - Product Sale Unit Final Description Qty Price Price CARLISLE PA 17013 $0 .37 First-Class Return Receipt (Green Card) $1 .75 Restricted Delivery $3 .50 Certified $2 .30 Label Serial 111: 70042890000279969491 Customer Postage -$0 .37 Subtotal: $7 .55 Total: Issue PVI: $7.55 $7.55 ` A. Signature X L" 11 Agent 0 Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address diffemnt from item 19 ? Yes N YES, enter delivery address below: y SF No 3. Ice Type - Ceraf dl Mail 0 Express Mall Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Reehkhd-D*jeryP fflxft Pbe) 114yes 2. Article Number 7004 2890 0002 7996 9491 (transfer ftm servicb PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 s ? Senr TO ? ? , ¢trk S1'ra7q Apt No.; __ -_ or PO Box No. -a--------------- ---- City, State, ZIP+4 Zp „ r?` ?? ? q 1;3 PS Form 3800, June 2002 S?o Rr?,,c t?, lnftcti.n. (? n1 I I C51 ; t ?'l Y ro Michael S. Travis Attorney at Law ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 ROBIN E. SEIER, Plaintiff, V. CHRIS R. SEIER, Defendant To the Prothonotary: COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 05-5548 CIVIL ACTION - DIVORCE ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Chris i divorce. Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 Attorney for Defendant in the above Date: ??G?o? ROBIN E. SEIER, ) COURT OF COMMON PLEAS Plaintiff, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) No. 05-5548 CHRIS R. SEIER, ) CIVIL ACTION - DIVORCE Defendant ) CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document was served on the below persons by first class U.S. Mail, postage prepaid, or the means specified: Jeffrey J. Wood, Esquire 5723 Cricket Lane PO Box 11731 Harrisburg, PA 17108 Date: /1 j? 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 ID No. 77399 ?._? :t ., ? { C.- . , _'_` _ , C "? ' t O :? F„ i _ -C ' (]i i MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this day of 200$, by and between Robin E. Seier, (hereinafter referred to as "Wife,") and Chris A. Seier, (hereinafter referred to as "Husband"). WITNESSETH: WHEREAS, the Husband and Wife were lawfully married August 5, 2000; and WHEREAS, there were no children born of this marriage; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; DEFINITIONS (a) Date of Execution of this Agreement. The phrase "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the parties if they each have 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. (b) Distribution Date. The phrase "distribution date" shall be defined as fourteen days following the entry of a final decree in divorce and the filing of Waivers of Appeals by each party. If the fourteenth day falls on a weekend or holiday, the distribution date shall be the next business date. ADVICE OF COUNSEL The parties have had an opportunity to review the provisions of this Agreement with their respective counsel. Husband is represented by Michael S. Travis, Esquire. Wife is represented by . Husband and Wife acknowledge that 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. The parties further acknowledge that they have each made to the other a full accounting of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purpose of this Agreement. Each party agrees that he or she shall not at any future time raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement with the exception of disclosure that may have been fraudulently withheld. SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. INTERFERENCE Each party shall be free from interference, authority, and contact by the other as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of the agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, follow, stalk, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. DIVISION OF PERSONAL PROPERTY Excepting the list of property attached as Exhibit A, the parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible marital property. Neither parry shall make any claim to any other such items of marital property, or to the separate personal property of either party, which are now in the possession and/or under the control of the other. Wife shall deliver to Husband the items listed on Exhibit A within thirty (30) days of the Execution Date of this Agreement. Financial Accounts. The parties have equally divided all joint checking, savings and other non-retirement accounts to their mutual satisfaction. The parties agree to retain their separate financial accounts. The parties agree to cooperate in transferring any title or document to accomplish the above distribution. Neither party will make further claim to any joint financial account following the distribution date of this Agreement. 6. SPOUSAL SUPPORT/ALIMONY PENDENTE LITE Neither party shall receive support or APL until a Decree in Divorce is entered. ALIMONY Recognizing the parties have sufficient income and property for their support following the entry of a decree in divorce, both parties waive the right to receive alimony. 8. AUTOMOBILES The parties are the owners of two automobiles, a 1993 Ford Ranger, driven by Husband, and a 2001 Mazda Protege by Wife. The Ford shall be property of Husband. The Mazda shall be the property of Wife. Neither vehicle is encumbered by purchase money loan. Should any action be required to transfer title or other document of ownership, the parties will take steps to transfer and reflect ownership as soon as possible after the distribution date. Both parties agree to assume all responsibility and hold each other harmless for any and all liability, including insurance, costs and expenses associated with ownership of the above. The costs of any title transfers or fees shall be home equally by the parties. 4 9. DIVISION OF REAL PROPERTY The parties are owners of real property located at 625 Brisban Lane, Enola, Cumberland County, Pennsylvania, 17025 containing a residential dwelling. The parties shall list the property for sale with a realtor agreeable to both parties. The sale price shall also be agreed upon by both parties. The sale proceeds shall be used to pay the mortgage balance. Following payment of the mortgage balance, Husband shall be reimbursed the sum $1,800 for a loan against his TSP retirement, and the amount of mortgage payments he has made on the real estate since separation. Any remaining proceeds shall be equally divided between the parties. Any deficiency shall be equally shared by the parties. Wife shall be responsible for payment of the mortgage, taxes, insurance and utilities until the real estate is sold. 10. PENSION, RETIREMENT ACCOUNTS, INVESTMENT AND SAVINGS ACCOUNTS At the time of separation, the parties were titled to the following retirement accounts. Composition of accounts Husband: TSP US Navy Husband: FERS Navy Wife: Fidelity 401k rolled over from Dauphin County Pension Each party shall retain the retirement/pension accounts. Neither party shall make further claim to a retirement or financial account of the other party. 11. MEDICAL INSURANCE Neither party is required to maintain medical insurance coverage for the benefit of the other party following the entry of a Decree in Divorce. 12. MARITAL DEBTS (a) During the course of the marriage, the parties incurred the following obligations jointly: Real Estate mortgage: 625 Brisban Lane, Enola, PA, mortgagee: PHH, amt. $225,749.00 Second mortgage: none. All balances approximate. Payment of real estate debt is discussed under Paragraph 9, Real Estate. Individual Debts: Husband: School loans $9,000.00 MBNA $ 6,500.00 Wife: Capital One: $ 6,000.00 : $ 2,200.00 Student Loans: $37,000.00 All balances approximate. Each party agrees to pay their own individual debts, and indemnify and hold the other party harmless for any individual liability. (b) Wife and Husband represent that they have taken all steps necessary to make sure that no credit cards or similar accounts exist which provide for joint liability. From the date of execution of this Agreement, each party shall use only those cards and accounts for which that party is individually liable. (c) Since separation, neither party has contracted for any debts which the other will be responsible for and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. 13. FILING AND PAYMENT OF TAXES The parties agree to file separate income tax returns for the year a decree in divorce is entered. 14. DIVORCE The parties agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and allow to be filed the necessary documents to obtain a divorce under Section 3301(c) of the Divorce Code. 15. DEATH PRIOR TO DIVORCE If either Husband or Wife dies before the entry of a final decree in divorce between the parties, this Agreement is deemed to survive the death, and the parties, heirs or assigns shall enter into the same status as after the Agreement was entered into. 16. INCORPORATION This agreement is to be incorporated for the purposes of enforcement, but not merged into any subsequent Decree in Divorce. 17. CONTINUED COOPERATION The parties agree that they will, after the execution of this Agreement, execute any and all written instruments, assignments, releases, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this Agreement. 18. COUNSEL FEES Except as otherwise provided for in this Agreement, each party shall be responsible for his or her own legal fees and expenses. 19. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement or for seeking such other remedies or relief as may be available to him or her. 20. VOLUNTARY AGREEMENT The provisions of this Agreement are fully understood by both parties and each party acknowledges that the Agreement is fair and equitable; that it is being entered into voluntarily; and that it is not the result of any duress or undue influence. 21. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtsey, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate. 22. BINDING EFFECT This Agreement shall be binding upon the parties' heirs, successors and assigns. 23. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formalities as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 24. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time of this Agreement are null and void and of no effect. 25. 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. 26. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall not have any binding effect whatsoever in determining the rights or obligations of the parties. 27. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties set their hands and seals the day and the first written above. '1 9" i'kitness Chris R. Seier, Husband Witness Robin E. Seier, Wife 9 r PERSONALLY APPEARED BEFORE ME this I AAay o ' 12099, a notary public, in and for the Commonwealth of Pennsylvania, Chris R. Seier, kn to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. Commonwealth of Pennsylvania: 1 ss: County of GUwr/a fi . IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Not ay Public Cane Hill Born, Cumberland County My Commission Expires Aug. 20, 2009 Commonwealth of Pennsylvania: ss: County of &ffibcf br 7 No ublic PERSONALLY APPEARED BEFORE ME, this 1Q?day of 20(Y?a notary public, in and for the Commonwealth of Pennsylvania, Robin E Seier, kno to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that she executed the same for the purposes herein contained. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, 'Cumberland County My Commission Expires Aug. 20, 2009 i Notary ublic 1, Exhibit A ,, = ? ?- 4i. ROBIN ELIZABETH SEIER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW CHRIS RICHARD SEIER, NO. 05-5548 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Mutual Consent Divorce Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention (waived) 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 unworn falsification to authorities. September 5, 2007 I-o,L- Lsae-& 6l( Robin Elizabeth Seier CJ r ?' j== ROBIN ELIZABETH SEIER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW CHRIS RICHARD SEIER, NO. 05- 5548 CIVIL TERM 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 of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. September 5, 2007 Robin Elizabeth Seier 0 G °z r?ri -? m Cn -< ?_ 0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBIN E. SEIER, ) Plaintiff, ) VS. ) No. 2005-5548 CHRIS R. SEIER, ) IN DIVORCE Defendant. ) CIVIL TERM ADDENDUM TO MARRIAGE SETTLEMENT AGREEMENT DATED JANUARY 1 6, 2006 R 2MM5 U 0 P Now comes the parties hereto, Robin E. Seier, Plaintiff, and Chris R. Seier, Defendant. Whereas, the'parties executed a Marital Settlement Agreement dated January 16, 2006, filed January 19, 2006; Whereas, the parties reconciled in August of 2006, and subsequently permanently separated at the end of 2006; Whereas, the parties underwent substantial changes in the composition of property since separation, and have agreed to the division of marital assets, and the exclusion of non-marital assets, they agree as follows: 1. The real estate located at 625 Brisbain Lane, Enola, was sold for $270,000.00, on May 15, 2006. The TSP loan was repaid as agreed in the Marital Settlement Agreement, and Husband received the sum of $13,594.07, Wife receive4 the sum of $10,194.08. The parties accept this equitable distribution under the Marital Settlement Agreement. Neither party will make further claim to the sale proceeds. 2. On May 30, 2006, Husband used the proceeds of the sale to purchase real estate titled in his sole name at 23 Privet. Drive, Etters, PA. Wife does waive any interest in this real estate. Husband obtained a purchase money loan with SunTrust Bank. He agrees to indemnify and hold Wife harmless for any claim thereon. 3. On January 20, 2006, Husband traded the 1993 Ford Ranger discussed in Paragraph 8 of the MSA for a 2005 Hyundai Santa Fe, ditled solely in his name. Husband obtained a purchase money loan for this vehicle with Hyundai Motor Finance. Husband agrees to indemnify and hold Wife harmless for any claim thereon. 4. On or about August, 2006, Wife purchased a 2004 Ford Mustang, titled solely in her name. Wife obtained a purchase money loan for th? vehicle with Citizen's Auto Finance. Wife agrees to indemnify and hold Husband harmless f?r any claim thereon. Al 5. Wife has also obtained a 401 k with her employer, currently valued at approximately: $452.69. 6. During their reconciliation and subsequent thereto, Wife obtained student loans to further her education with Citibank. Wife agrees to indemnify and hold Husband harmless for any claim thereon. 7. Since entering into the MSA, Husband has paid off the MBNA loan in the amount of $6,500 discussed at Paragraph 12 of the MSA. He currently has an additional Member's First Visa with an approximate account balance of $4,800.00. He also has obtained a Circuit City charge account with a $0.00 balance. He also has charge accounts with Amazon Visa and Wells Fargo, neither carry balances. He agrees to indemnify and hold Wife harmless for any claim(s) thereon. 8. Since entering into the MSA, Wife has extended the following lines of credit: Amazon Visa, Washington Mutual, and Circuit City. She agrees to indemnify and hold Husband harmless for any claims thereon. 9. Except as discussed above, all other terms of the MSA shall remain unchanged. Robin E. Seier, Plaintiff, date: Y4-1- "e, J\ Chris R. Seier, Defendant Se9" s ao o ? r Commonwealth of Pennsylvania: . ss: County of PERSONALLY APPEARED BEFORE ME, thiis day of , 2007, a notary public, in and for the Commonwealth of Pennsylvania, Robin E. Sei , known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that she executed the same for the purposes herein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWfAd.TH 0F PENNSYLVANIA NOAltlltl SEAL SUSAN J. MILLER, Notary Publk Camp IAN Baro CZsuo.; VIEW Cowb Aannal? 19.2000099 Commonwealth of Pennsylvania: County of Oven w--11? ss: ANotOxy-P-ublic PERSONALLY APPEARED BEFORE ME, this may of ?S,n?clvr?lrs?s , 2007, a notary public, in and for the Commonwealth of Pennsylvania, Chris R. Seder, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. LTH OF PENNSYLVANI Notaria l S"i t ws Nolacy,pto* in?Opt. 11,2* 7ti IrA "Mi. PWAI 1-1 -011- ? 0 rZ Notary blic R 1 *n . N ROBIN ELIZABETH SEIER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW CHRIS RICHARD SEIER, NO. 05- 5548 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT & WAIVER OF COUNSELING 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Mutual Consent Divorce Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the Decree. ?I 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint in Divorce on November 14, 2005. I verify that the statements made in this Affidavit afire true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. September '7 , 2007 V Chris Richa:td Seier -mN: ... ..,, d ?,tiD '1'l. '? ., ROBIN ELIZABETH SEIER, Plaintiff V. CHRIS RICHARD SEIER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CAVIL ACTION - LAW NO. 05- 5548 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF TIE DIVORCE CODE 1. I consent to the entry of a final decree of divt rce without notice. 2. I understand that I may lose rights concerning #limony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately, after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. September 2007 Chris Richard Seief ROBIN ELIZABETH SEIER, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW CHRIS RICHARD SEIER, Defendant NO. 05- 5548 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMa 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: Mutual Consent or irretrievable breakdown under § 3301(c) of the Pennsylvania Divorce Code. 2. Date and manner of service of the Complaint: Complaint was filed on October 26, 2005 and Service of Original Process was completed o6 the Defendant by United States First Class Certified Mail, Restricted Delivery, in accord with Pa. R,C.P. No. 1930.4(c), on November 14,2005; Proof of Service was duly filed on November 15, 2005..' 3. (a) Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff September 5, 2007 and filled September 5, 2007; by Defendant September A, 2007 and filed September 4, 2007. (b) Date of execution of the Affidavit-Waiver of Notice of Intention to Request Entry of a Divorce Decree: by Plaintiff on September 5, 2007 and filed September 5, 2007; by Defendant on September', 2007 and filed September _JL 2007. 4. Related claims pending: None; The Marital Settlement Agreement, and The Addendum to Marital Settlement Agreement, both signed and filed by the parties hereto, are to be incorporated into the Divorce Decree. September 1), 2007 Robin Elizabeth Seier Plaintiff 1101 Linoam Court; #609 Mechanicsburg, PA 17055 717.418.6140 4 IN THE COURT OF COMMON PLEAS AND NOW, Robin Elizabeth Seier VERSUS Chris Richard Seier OF CUMBERLAND COUNTY STATE OF PENNA. No. DECREE IN DIVORCE DECREED THAT AND September /2" Robin Elizabeth Seier Chris Richard Seier 05-5548 2007, IT IS ORDERED AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; however, the Marital Settlement Agreement, together with Addendum to the incorporated into this Divorce Decree. PROTHONOTARY La. fj1 lb