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Home My WebLink About06-0777 Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Phone: 717-737-0100 Supreme Court 10# 32112 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, Plaintiff NO. Jrxt -177 c:'IV; I Y. CIVIL ACTION - LAW. HAROLD L. SLOOP, DIVORCE Defendant 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 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone No. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, Plaintiff NO. v. CIVIL ACTION - LAW. HAROLD L. SLOOP, DIVORCE Defendant AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte, Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion reclamados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidadas 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en La York County Judicial Center, 45 North George Street, York, Pennsylvania 17401. 51 USTED NO RECLAMA PENSION ALlMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone No. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, Plaintiff NO. 0(.-'7 71 Cc~"':f r~ V. CIVIL ACTION- LAW HAROLD L. SLOOP, DIVORCE Defendant COMPLAINT Plaintiff, Rayette I. Sloop by her attorney, Diane G. Radcliff, Esquire, and files this Complaint in Divorce of which the following is a statement: COUNT I DIVORCE 1. The Plaintiff is Rayette l. Sloop, an adult individual who currently resides 5 Stine Avenue, Carlisle, Cumberland County, PA 17013. 2. The Defendant is Harold L. Sloop, an adult individual residing at 428 Chestnut Street, Mt. Holly Springs, Cumberland County, PA 17065. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 21, 1999 at Newville, Cumberland County, Pennsylvania. 5. Plaintiff avers that there are no children under the age of eighteen (18) years born of the marriage. 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in -1- counseling. 8. Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. Plaintiff avers that the grounds on which the action is based are: A. Section 3301 Cc) Mutual Consent No-Fault: The marriage is irretrievably broken; B. Section 3301 Cd) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT /I EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 are incorporated by reference hereto as fully as though the same were set forth at length. 12. Plaintiff and Defendant have acquired property, both real and personal, and incurred debts during their marriage during the period from January 21, 1999, the date of their marriage, until December 15,2005, the date of their separation, all of which are "marital property" or "marital debts". 13. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 14. Plaintiff and Defendant have been unable to agree as to an equitable division of -2- . ,. the marital property and marital debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT III ALIMONY PENDENTE LITE 15. Paragraphs 1 through 10 are incorporated by reference hereto as fully as though the same were set forth at length. 16. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 17. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until the entry of the divorce decree and final resolution of the economic issues involved in this case. Respectfully submitted, ( G. RADCLIFF, ESQUIRE . ale Road Camp Hill, PA 1701 1 Phone: (717) 737-0100 Supreme Court ID # 32112 Attorney for Plaintiff -3- . .. VERIFICATION RAYETTE I. SLOOP verifies that the statements made in this Complaint are true and correct. RA YETTE I. SLOOP understands that false statements herein are made subject to the penalties of 18 Pa.c.S. Section 4904, relating to unsworn falsification to authorities. ~~ttJ ~S~ RA YE E I. SLOOP Date: J/7/0 (Q f t -4. (-) CJ 't:>\ C' "Tt ~ 0> ~ "~..' ! - 'T1 '... ~. fTl (-["iF ~ ~ l:~.J I 'if -J ....~) '1 "'"" ~ ~ <cs ~ '-'J ---------------- YOUR HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU 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 MAY GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, - 2 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYETTE I. SLOOP, Plaintiff NO~"" 77) CIVIL TERM CIVIL ACTION - LAW v, IN DIVORCE HAROLD L SLOOP, Defendant P ACSES NO. PETITION FOR ORDER FOR ALIMONY PENDENTE LITE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this Zctay of kb t', l (l U;\; , 20 0 (., , comes the Petitioner, Rayette I. Sloop, who files the this Petition for Alimony endent Lite and respectfully represents that: 1. Petitioner is Rayette I. Sloop, an adult individual who currently resides 5 Stine A venue, Carlisle, Cumberland County, PA 17013, and is the Plaintiff in this case, 2, Respondent is Harold L. Sloop, an adult individual residing at 428 Chestnut Street, Mt. Holly Springs, Cumberland County, P A 17065, and is the Defendant in this case, 3. Petitioner and Respondent married on January 21, 1999 at Newville, Cumberland County, Pennsylvania, and separated on December 15, 2005, 4. Respondent has not sufficiently provided support for the Petitioner. 5. Petitioner is not on a financial par with Respondent in prosecuting and/or defending this Divorce Action, and is unable to support herself in accordance with the standard ofliving established during the marriage, 6. The within action was instituted by the filing of a Divorce Complaint by Petitioner/Plaintiff, on February 7, 2006. 7. In the Divorce Complaint Petitioner raised a claim for Alimony Pendente Lite, 8. This Petition is filed to secure the entry of an order for alimony pendente lite on the - 1 - Plaintiffs claim for Alimony Pendente Lite. 9. A background information sheet pertaining to this claim for Alimony Pendente Lite is being filed with Domestic Relations concurrently herewith as required by Local Rules of Court, 10. The amount of Alimony Pendente Lite requested by the Petitioner is the maximum amount provided for under the guidelines, WHEREFORE, Petitioner prays that the Court enter an Order: A. Requiring the Respondent to pay the Petitioner Alimony Pendente Lite in the maximum amount provided for by law under the state support guidelines; B. Requiring the Respondent to provide medical insurance and support for the Petitioner. Respectfully submitted, CLIFF, ESQU 3 e Road CampHill,PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975.0697 Attorney for Petitioner - 2 - . " VERIFICATION I verify that the statements made in this Petition for Alimony Pendent Lite 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, ~p~ DATE: ~/I/O!t - 3 - r, 'c .~ ---x V\ "" ~ -.- ') -s ()> i-'.\ ('. ...., \: :~..:) ,:,:') <.:)... "r" Q ..." en en \ --' ..., w RA YETTE I. SLOOP, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE HAROLD L. SLOOP, JR, Defendant/Respondent NO. 06-777 CIVIL TERM IN DIVORCE PACSES # 506108023 ORDER OF COURT AND NOW, this 7th day of February, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before RJ, Shadday on Februarv 13. 2006 at 9:00 A.M. for a conference, at 13 N, Hanoyer St, Carlisle, PA 17013, atier which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. **This petition will be heard in conjunction with the complaint for spousal support. ** YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W.2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910,11<0 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed on February 7, 2006 to: Petitioner Respondent Diane G. Radcliff, Esquire Date ofOrdcr: February 7. 2006 /1' I 11 b'+'4~'7r adday, Conference Officer ,..., (, V YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249.3166 cd61 ( ::- -q .." .... rrl :.r' t:>:) "ri , C) C,,) In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RAYETTE 1. SLOOP ) Docket Number 06-777 CIVIL Plaintiff ) vs, ) PACSES Case Number 506108023 HAROLD L. SLOOP JR ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 13TH DAY OF FEBRUARY, 2006 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or Gi) Other REQUEST FOR APL CONFERENCE filed on FEBRUARY 7, 2006 in the above captioned matter is dismissed without prejudice due to: AN ORDER OF SPOUSAL SUPPORT BEING ESTABLISHED UNDER PACSES $506108023 AND DOCKETED AT 53 S 2006, o The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: M.~~'.~~ JUDGE DRO: R.J. Shadday Service Type M Form OE-506 Worker ID 21005 C) -i"j -.-, r c"":'.' ,~" ... c..] (.) --I :~:-~~ U) . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYETTE I. SLOOP, Plaintiff NO. 2006-777 v. CIVIL ACTION - LAW. HAROLD L. SLOOP, DIVORCE Defendant AFFIDAVIT OF SERVICE I, Diane G. Radcliff, Esquire, being duly sworn according to law, depose and say that on February 10, 2006, I served a true and correct copy of the Complaint in Divorce upon Harold L. Sloop, the Defendant, by Certified Mail, Restricted Delivery, addressed as follows: Harold L. Sloop, Jr. 428 Chestnut Street Mt. Holly Springs, PA 17065 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. /' I , Sworn to and subscribed before me a Notary Public in and for Cumberland cour:l' Pennsylvania this J~" day of "b~..'J ' 20 OU. ~W or. ~A NOTARY PUBLIC C My commission expires: COMMO:-~J~'t:hL; :,.; ;)f PENNSYL\/f'",'HA '-t-~;t;]li~\ Seal ' I Deborah l. [k)nlcy, Nolary Public I Camp Hill Bom, Cumbertand County I My Commission ~~~~ Sept. 23, 2007 Member, Penwvi-'I?'I;; A,,<tiation Of ~Jat2;i" . - . . Complete items 1, 2, and 3. Also complete ~em 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 mail piece. or,~ the front if space permits. 1. Art. Addressed to: ~L~0. '1;''% ~ M /ll;t ~ M)/lI.A1fh jJ/J . --, T "'T /10~S 3'l:?':'lce Type ~Ified Mall 0 Express Mall o Registered 0 Return Receipt for Merchandl$8 o Insured Mail 0 C.O.D, .. ,- 4__~ Yes 2. Article Number (T"'nsfer from -label) PS Form 3811, February 2004 7005 0390 0003 2641 5650 DomestIc Return Receipt 102595-02-M-1540 ; EXHIBIT "A" RETURN RECEIPT CARD o f,; -'"J ., , c. I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO.).COl.o- 11') CIVIL TERM RA YETTE I. SLOOP, CIVIL ACTION - LAW v. IN DIVORCE 2.00(P-",,, HAROLD L. SLOOP, Defendant PACSES NO. INCOME AND EXPENSE STATEMENT OF RAYETTE I. SLOOP ~!llfln.I!.Fl__ In 1IE::.1\1I18 U'fl!. r "L. __. J HI, nil! I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DATE: ~L~~ _~ RAYE E I. SLOOP , -1 - PART I. INCOME A. EMPLOYMENT INFORMATION: I EmpLoye" I T"get Pay Period: BIweekly B. INCOME: DESCRIPTION BIWEEKLY MONTHLY YEARLY Gross Income $8.50/hr. @ 30-32 hrs/wk. $527.00 $1,141.83 $13,702.00 (62 biweekly hours used) FICA ($40.32) ($87.36) ($1,048.32) Federal Tax ($20.20) ($43.77) ($525.20) State Tax ($16.65) ($36.08) ($432.90) Local Tax @1.6% ($8.43 ) ($18.27) ($219.18) Union Dues N/A N/A N/A Mandatory Retirement N/A N/A N/A TvTAL: .." IX$.14'1.4I1J ~"''''L~7: ",,<:,', .,',' ".,.: ... ",.< $11,476.40 - 2- E. OTHER INCOME: DESCRIPTION WEEKLY MONTHLY YEARLY Interest $0.00 $0.00 $0.00 Dividends $0.00 $0.00 $0.00 Pensions $0.00 $0.00 $0.00 Annuities $0.00 $0.00 $0.00 Social Security $0.00 $0.00 $0.00 Rents $0.00 $0.00 $0.00 Royalties $0.00 $0.00 $0.00 Expense Account $0.00 $0.00 $0.00 Gifts $0.00 $0.00 $0.00 Unemployment Compensation $0.00 $0.00 $0.00 Workman's Compensation $0.00 $0.00 $0.00 l:1come Tax Refunds $0.00 $0.00 $0.00 Support or Alimony $0.00 $0.00 $0.00 Commissions $0.00 $0.00 $0.00 Tips $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 TOTAL OTHER INCOME " "'i i<i/'l111'l $0.00 $0.00 - 3 - PART II. EXPENSES -' '.,",", ',',. ''-"' ','," ...,......., !,....Y/'_~n'INT COMMENTS HOME EXPENSES: Rent First Mortgage Home Equity Loan Maintenance and Repairs Electric $30.00 Gas Oil Telephone $60.00 Water Sewer Trash EMPLOYMENT Public Transportation Lunches $108.00 @ $5/day Other Employment Expenses TAXES: Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld Per Capita/Occupation Taxes $1.00 .4- DESCRIPTIO'N MONTHI..'f'i,'AMP\..lNT COMMENTS INSURANCE: Homeowners Insurance Automobile Insurance $67.00 Est. @ $200/3 months Life Insurance Accident Insurance Health Insurance Other Insurance AUTOMOBILE EXPENSES: Payments Fuel $130.00 @ $25/wk Maintenance and Repair $50.00 @ $600/yr License and Registration $4.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $10.00 Optical Dental $6.00 Orthodontic Hospital Medicine $13.00 @ $40/3 mo Special Needs/Therapy Etc. - 5 - DESCRIPTION MONTHL'fAM,OUNT COMMENTS EDUCATIONAL EXPENSES: Private School ParochiaL School ColLege /Vocational Religious Training or Education Books/Fees and Supplies Other Educational Expenses PERSONAL EXPENSES: Clothing $75.00 Food $430.00 $100/wk Barber and Hair Dresser $30.00 Memberships Other Personal Expenses $15.00 CREDIT CARDS AND LOANS: MISCELLANEOUS EXPENSES: Household Help Child Care Newspapers/ Magazines/ Books $5.00 Entertainment $100.00 Pay TV $30.00 Vacations $50.00 Gifts $20.00 - 6 - DESC.RIPTION MONTHI.YAMOUNT COMMENTS Legal Fees $150.00 Charitable Contributions $43.00 Other Child Support (not this action) Other Spousal Support or Alimony (not this action) Dog Food $35.00 Vet $50.00 - TOTAL EXPENSES $1,512.00 - 7- PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION , VALUE H W JT Checking PNC 400.00 x Savings PNC 620.00 x Credit Union Stocks/bonds Real Estate Other TOTAL 1,02(J.OO PART IV. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COMPANY POI..lCYNO. H W C Hospital Capital Blue Cross YWP80007200401 x x Medical Capital Blue Cross YWP80007200401 x x Health Accident Disability Income Dental Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child - 8 - PART V. SUPPLEMENTAL INCOME STATEMENT [ .[ ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached Business Telephone: (c) Name of Business: Business Address: (d) Nature of Business (check one) [] 1. Sole Proprietorship [] 2. Partnershi p [] 3. Joi nt Venture [] 4. Professional [] 5. Corporation [] 6. Other (e) Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period: 4. Net income per pay period: 5. Specify deductions, if any: .-) '.ell ~, u\ '---i ,: f;>;l .r- C. _..--~-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION RA YETTE I. SLOOP Plaintiff Docket No. 00053 S 2006 v. PACSES Case No. 305107971 HAROLD L. SLOOP, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYETTE I. SLOOP, VNO. 2006-777 CIVIL TERM Plaintiff CIVIL ACTION - LAW v. IN DIVORCE HAROLD L. SLOOP, Defendant PACSES NO. 506108023 APPEAL OF SUPPORT ORDER AND REOUEST FOR HEARING DE NOVO DATE OF ORDER (SUPPORT ACTION): February 13, 2006 AMOUNT OF SPOUSAL SUPPORT ORDER: $509.00 SUPPORT FOR: Spouse, Rayette I. Sloop PARTY FILING APPEAL/DE NOVO HEARING REQUEST: Rayette I. Sloop REASONS FOR APPEAL/DE NOVO HEARING REQUEST: Support amount was not properly calculated as it did not use the correct amount of Unemployment Compensation received by Defendant, Harold L. Sloop, Jr. WHEREFORE, Plaintiff, Rayette I. Slooop, requests this Honorable Court to hold a Hearing De Novo in the above captioned case and to enter an appropriate support order based on the facts of th is case. SIGNATURE OF ATTORNEY I APPELLANT: ~Pi \ CLIFF, ESQUIRE Road Camp Hill, PA 17011 Phone: (717) 7}7'O1O(} Date: ;2 / ~ I I 6 rr I ! 'r ~ ~ A-- D I;: l::) -0 " ;-':~; \".,::; ~.,,) . :.;~ (',:) :;:2 c:: ~ ORIGINAl. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, v. HAROLD L. SLOOP, Plaintiff Defendant NO. 2006-7n CIVIL ACTION - LAW. DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 7, 2006 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 81.JNV aD) 0 (D ~Q,~ YE I. SLOOP ...._ ,(< ~J,.~ ,.''I,..~"" ~~ .,,.,~' ':"-' .: :.; <-" "'~ c:.:;t ,::)'" '- c:. r~-'~ :~ '"'n ,--' ;G, ," I U'j ~ - - co' (~J I' "- ...-'.' 6 ORIGIIW. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, Plaintiff NO. 2006-777 v. CIVIL ACTION - LAW. HAROLD L. SLOOP, DIVORCE Defendant WAIVER OF NOTI~%UEST S~C E 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 made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Dated:81Yl'\L.;2D; oCn '. '. ~,I"'; ':' ". <~~ ....."... (] ..- >::-, r--' ~~ '"'" I..,:.:. \ c.)"\ ~: C? c..) v:~ ."'-, '-':i'\ -< ~"7:4) 'f1'1'f::1", '- )'-" 6 OR'Gfn:.~. RA YETIE I. SLOOP, Plaintiff IN TIIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA vs. CIVIL ACTION - LAW DIVORCE HAROLD L. SLOOP, Defendant NO. 2006-777 AFFIDAVIT OF CONSENT A Complaint in divorce under ~3301(d) of the Divorce Code was filed on 1 - l' ;:)/'7/D(p , and served on .::L/IO /6(" 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date offiling the Complaint and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. o.re ~b ,T- '" .. , c: ~. :J,_ f""~) C::::;J ,'--'~;~' 2~~' (-:~:. C.___' --11 -', -T. \",';'~ ()-, ~.,., c' o ORI'"; " RA YETIE . SLOOP, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA vs. CIVIL ACTION - LAW DIVORCE HAROLD L. SLOOP, Defendant NO. 2006-777 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER 63301(0 AND 6 3301(D) OF THE DIVORCE CODE I. 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! 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. M~ OLD. 0 f . 0'\ ''::', ~- ~ u) <..,:: -:? -' \"'.';' . ~,' 6 ,......"''!'r~r ..>t t-. ,t.l" _ .' {J ...... ~ .. ,.....~. ~...i.;\'i. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, Plaintiff NO. 2006-777 CIVIL TERM v. CIVIL ACTION - LAW HAROLD L. SLOOP, DIVORCE Defendant MARITAL AGREEMENT BETWEEN HAROLD L. SLOOP AND RA VETTE I. SLOOP TABLE OF CONTENTS PREAMBLE."...."............."....."...."".....".."."..."."..."..".."".."""".... 01 SECTION I General Provisions ................................. ...................... ...... 01 SECTION II Distribution of Property and Debts........................................... 06 SECTION III Counsel Fees, Support, Alimony, and Health Insurance .................. 11 SECTION IV Closing Provisions and Execution ............................................ 12 NOTARy,,,,,..,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,..,, ...".."""""""..""""".."""""..".."""""""...."" 13 PREAMBLE THIS AGREEMENT made this ~y of J.. ,.. ~ 2006, by and between RA VETTE I. SLOOP, ("Wife") of 5 Stine Avenue, Carlisle, PA 17013, and HAROLD L. SLOOP, ("Husband") of 428 Chestnut Street, Mt. Holly Springs, PA 17065 WITNESETH: WHEREAS, the parties hereto are husband and wife. They were married on 1/29/1999 in Cumberland County, Pennsylvania, and were separated on 12/15/2005. WHEREAS, There were no children born of this marriage. WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife 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 by specification: the settling of aU matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and aU claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: SECTION I GENERAL PROVISIONS 1.01. INCORPORATION OF PREAMBLE. The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of this Agreement. 1.02. DIVORCE DECREE. The parties acknowledge that their marriage is irretrievably broken and that they will secure a mutual consent no.fault Divorce Decree in the above - 1 - captioned divorce action. Upon the execution of this Agreement, the parties shall execute and deliver to Wife's attorney their respective Affidavits of Consent and Waivers of Notice. Within five (5) business days of receipt of those signed Affidavits and Waivers, Wife's attorney will file all the remaining documents necessary to secure the entry of the Divorce Decree at Wife sole cost and expense. If either party has filed a counterclaim, counter-affidavit, or any claim for economic relief, he or she agrees that any such claims have been fully resolved by virtue of this Agreement, and he or she shall withdraw any such claims and, if necessary, shall take such further steps as may be necessary to allow for a prompt finalization of any divorce action between the parties. 1.03. EFFECT OF DIVORCE DECREE. INCORPORATION AND MERGER. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. This Agreement shall not, however, merge with the Divorce Decree, but rather, it shall continue to have independent contractual significance and each party shall maintain their contractual remedies as well as Court remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. 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. 1.04. DATES. The "date of execution", "execution date" or "date of this Agreement" shall be defined as the date of execution by the party last executing this Agreement. 1.05. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Richard R. Gan, Esquire for Husband, and Diane G. Radcliff, Esquire, for Wife. The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations. They acknowledge and accept that this Agreement is, under the circumstances, 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. 1.06. 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. 1.07. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. Each party understands that he -2- or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or botl1 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. 1.08. 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 terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to Court determination the same as if this Agreement had never been executed by the parties. 1.09. MUTUAL RELEASES. Except as other wise expressly provided in this Agreement, Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from the following: A. Claims Al'lainst Prooertv or Estate: Any and all right, title, interest and/or claims in or against the other party, the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other party, the estate of such other party or the property of the other party or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other. B. Life Time Conveyances: 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 (i) the Commonwealth of Pennsylvania, (ii) State, Commonwealth or Territory of the United States, or (iii) any other country; C. Marital Ril'lhts: Any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether - 3 - arising as a result of the marital relation or otherwise. D. Breach Exception: The foregoing shall not apply to all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 1.10. WAIVER OR MODIFICATION. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 1.11. MUTUAL COOPERATION. Each party shall, atanytime, and from time to time hereafter, and within five (5) business days of request, take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 1.12. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 1.13. 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. 1.14. BREACH. If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/ or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies: A. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 PA. C.S.A. 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said statute or replacement thereof by any other similar laws. B. Damaszes: The right to damages arising out of breach of the terms of this -4- Agreement, which damages shall include reimbursement of all reasonable attorney's fees and costs incurred as the result of the breach and in bringing the damage action. C. Other Remedies: Any other remedies provided for in law or in equity. D. Considerations for Reasonable Attornevs Fees: Any award of "reasonable attorneys fees" as used in this paragraph shall be based on consideration of (1) the hourly rate charged; (2) the services rendered; and (3) the necessity of the services rendered. Determination of reasonableness shall not take into consideration the amount or nature of the obligation sought to be enforced or any possibility of settlement for less than the obligation sought to be enforced by the non-breaching party. E. Breach Notice: In the event of an alleged breach of any term of this Agreement, the aggrieved party shall provide written notice to the breaching party and his or her counsel of his or her intent to take action to enforce his or her rights under the Agreement and to remedy such breach. The breaching party shall have a period of fifteen (15) days from the mailing of such notice to cure the alleged breach prior to the institution of any proceedings of any nature for enforcement of this Agreement. 1.15. INCOME TAX MATTERS. With respect to income tax matters regarding the parties the following shall apply: A. Prior Returns: The parties have heretofore filed joint federal and state 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 arising out of such joint filing, each will be responsible for payment of half of such tax and any interest, penalty or other expense arising therefrom and shall indemnify and hold harmless the other from and against any loss or liability as a result thereof. B. Current Returns: The parties shall file individual tax returns for the current tax year and for every tax year hereafter. C. Preservation of Records: Each party will keep and preserve for a period of three (3) years from the date of their divorce all financial records relating to the marital estate, and each party will allow the other party access to those records as may be reasonably necessary from time to time. 1.16. EFFECT OF RECONCILIATION. This Agreement shall remain in full force and effect even - 5 - if the parties reconcile, cohabit as Husband and Wife or otherwise, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shall be no modification or waiver of any of the terms hereof unless the parties, in writing, signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. SECTION II DISTRIBUTION OF PROPERTY 2.01. FINAL EQUITABLE DISTRIBUTION OF PROPERTY. The parties agree that the division of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the Court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. 2.02. DISTRIBUTION OF PROPERTY AND DEBTS. The parties' marital assets and debts shall be divided and distributed as follows: A. Personal Prooertv: The parties' tangible personal property including, but without limitation with specifiC reference to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other personal property ("the Personal Property") shall be divided and distributed as follows: 1. To Wife: All items of personal property in the possession of Wife, not otherwise distributed to Husband herein, including, but not limited to, the three (3) dogs known as Digger, Sparky and Buster. Additionally Wife shall receive the fireproof safe in Husband's possession to be made available tot her within fourteen (14) days of the date of this Agreement. 2. To Husband: All items of personal property in the possession of Husband, not otherwise distributed to Wife herein. B. Vehicle(sland Vehicle Loan(sl: The parties' vehicles, boats, snowmobiles, motorcycles, trailers, campers and the like owned by one or both of the parties, or the trade in value thereof if the Vehicles have been sold or traded in prior to the date of this Agreement ("Vehicles"), and loans associated therewith, shall be -6- divided and distributed as follows: 1. To Wife: The following vehicles, the titles to each of which are unencumbered: A. The 2000 Ford Taurus, bearing VIN #1FAFP53254A233111 B. The 1974 Chevrolet Nova, bearing VIN #1x27d4k161506 C. The 1987 Ford Mustang, bearing VIN #1fabp44a9hf139234 2. To Husband: The following vehicles, the titles to each of which are unencumbered: A. The 1987 Chevrolet Truck, bearing VIN #1GCCR14H6HS131913 B. The 1983 Chevrolet Truck, bearing VIN #2GECK14H8D1164242 C. The 1985 Ford Escort, bearing VIN #1 FABP3194m0811 0 D. The 1993 Ford Escort, bearing VIN #1FAFP53254A233111 c. Accounts: The parties' bank accounts, certificates of deposit, and other monetary deposits, ("the Accounts") shall be divided and distributed as follows: 1. To Wife: The funds previously received by Wife from the parties' joint PNC Checking account. 2. To Husband: The funds previously received by Husband from the parties' joint PNC Checking Account. D. Investments: The parties shares of stock, brokerage accounts and other investments (the "Investments") shall be divided and distributed as follows: 1. To Wife: None. 2. To Husband: None. E. Life Insurance: The parties' life insurance policy and the cash value thereof shall be divided and distributed as follows: 1. To Wife: None. 2. To Husband: None. F. Retirement Plans: The parties' Pension Plan, Retirement Plan, IRA Account, Profit Sharing Plan, 401.K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, any - 7- employee benefit plan and/or any other retirement type pLans (the "Retirement Plans") shall be divided and distributed as follows: 1. To Wife: Wife's None. 2. To Husband: Husband's Fry Communications Retirement plan(s). G. Real Estate: The jointly owned real estate known and numbered as 428 Chestnut Street, Mt. Holly Springs, PA 17065, ("the Real Estate"), encumbered with a mortgage with ABN-AMRO, securing a note bearing Loan #0634150368 and a mortgage with PNC securing a PNC Home Equity Line of Credit bearing Loan #40 03 048110426037, ("the Mortgages"), shall be divided and distributed in accordance with the following: 1. Convevance: Wife shall prepare and 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 ReaL Estate. The deed of conveyance therefor shall be executed by Wife upon Wife's signing of this Agreement and held in escrow by Wife's attorney pending the refinance/assumption of the Mortgages, at which time the deed shall be delivered to Husband to record. 2. Liens. Encumbrances and EXDenses: The said conveyance shall be subject to all liens and encumbrances covenants and restrictions of record including, but not limited to, the lien of the Mortgages, reaL estate taxes and any other municipal liens. Husband shall hereinafter be soLely responsibLe for the payment of the Mortgages, real estate taxes, other municipal liens and any and all other expenses associated with the ReaL Estate, whether incurred in the past, present or future, and shall indemnify, protect and save Wife harmless therefrom. 3. Refinance: Husband shall apply for refinancing/assumption of the Mortgage within fifteen (15) business days of the date of this Agreement and shall complete that refinance/assumption within sixty (60) days of the date of this Agreement so as to reLease Wife from further liability thereunder. The costs of refinancing/ assumption shall be paid by Husband. 4. Sale: In the event Husband has not obtained the refinancing/assumption within the sixty (60) day time period aforesaid, the parties shall list the real estate for sale with a qualified reaL estate broker and shall market and sell the Real Estate, the parties further agreeing to follow all reasonable advice as to listing and sales offered by their broker. Upon said saLe all - 8 - proceeds will be paid to Husband as Husband's sole and separate property. H. Monetarv Payment: None. I. Debts: The parties' marital debts, loans, credit cards and other obligations, not otherwise divided and distributed herein, shall be divided and distributed as follows: 1. To Wife: Wife shall be solely liable for and shall timely pay any credit cards, loans, debts and liabilities incurred in Wife's individual name. 2. To Husband: Husband shall be solely liable for and shall timely pay the following debts: A. the Chase Visa account previously in the parties' joint names and now in husband's sole name. B. Any credit cards, loans, debts and liabilities incurred in Husband's individual name. 2.03. MISCELLANEOUS DISTRIBUTION PROVISIONS: The following miscellaneous provision shall apply to the distribution of the parties' marital assets and debts: A. As Is Condition: Except as otherwise specifically herein provided, and with respect to the transfer of any tangible assets provided for in this Marital Agreement, the parties acknowledge that he or she have had the opportunity to inspect and view the assets that he or she is to receive as his or her sole and separate property and he or she is fully aware of the condition of such tangible asset and is receiving those assets in "as is" physical condition, without warranty or representation by or from the other party. B. Title Transfer: If appropriate, for effectuating the transfers as herein provided, those titles shall be executed and delivered to the appropriate party on the date of this Agreement, unless another date is provided herein. C. Personaltv Transfer: if either party is entitled to any items of personal property in the possession of the other party as of the date of this Agreement, the parties shall promptly make arrangements so as to permit that party to remove the items of property from the other party's possession no later than thirty (30) days from the date of this Agreement. -9- D. Waiver. Each of the parties specifically waives, releases, renounces and forever abandons whatever right, title and interest they may have in any property that is to become the sole and separate property of the other party pursuant to the terms of this Agreement. E. Liens: In the event any asset is subject to a lien or encumbrance the party receiving the asset as his or her property shall take it subject to said lien and/or encumbrance and shall be solely responsible and liable therefor. F. Debt Balances and Prior Payments: Any debt herein described shall be deemed to include the current balance owed on the debt. Unless otherwise herein specifically provided, there shall be no adjustment in the distribution provisions for the payment of any portion of the marital debts prior to the execution of this Marital Agreement, whether or not that debt or the prior payment thereof is specifically referenced in this Paragraph, said payment having been taken into consideration in determining the distribution of marital assets and debts herein provided. G. Indemnification: Any party assuming an obligation pursuant to the terms of this Agreement shall indemnify, protect and hold the other party harmless from and against all any and all liability thereunder, including, but not limited to, any attorney's fees and costs incurred by the other party as the result of defending against the obligation and/or enforcing the provisions of this indemnification. H. Cancellation of Joint Debts: Any joint debt shall be canceled so that neither party can make any further charges thereunder, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay the same. I. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. J. No Further Joint Debt: From the date of this Agreement, each party shall only use those credit accounts or incur such further obligations for which that party is individually and solely liable and the parties shall cooperate in closing any remaining accounts which provide for joint liability. K. No Additional Debt: Each party represents and warrants to the other party that since the separation he or she has not, and in the future he or she will not, contract or incur any debt or liability for which the other party or the other party - 10- or the other party's estate might be responsible. L. Refinance: In the event a party is assuming a liability for which the parties are jointly liable, that party shall refinance the same within sixty (60) days of the date of this Agreement so as to release the other party from any and all liability thereunder. SECTION III COUNSEL FEES, SPOUSAL SUPPORT, APL, ALIMONY. AND HEALTH INSURANCE 3.01. WAIVER OF COUNSEL FEES. The parties hereto agree and do hereby waive any right and/or claim each may have, both now and in the future, against the other for counsel fees, costs and expenses. 3.02. ALIMONY. APL. AND SUPPORT. Except as hereafter provided the parties hereto agree and do hereby waive any right and/or claim they may have, both now and in the future, against the other for alimony, alimony pendente lite, spousal support and maintenance. The parties agree that the existing Spousal Support Order entered in the support case docketed to Cumberland Count No. 53 Support 2006, Pacses No. 305107971, shall remain in effect until the date of the entry of the divorce decree between the parties, upon which date it shall terminate. Any arrears or credits remaining as of that date shall be paid as directed by Domestic Relations. 3.03. HEALTH INSURANCE. The following shall apply regarding health insurance: A. Health Insurance for SDouse: Any party carrying health insurance on the other party shall continue to provide health insurance coverage on the other party until the date of the entry of the Divorce Decree. The party for whom that health insurance is provided shall be entitled to elect Cobra coverage under the other party's employment policy in accordance with federal Rules and regulations provided that he or she shall be solely be responsible for the payment of the costs and premiums therefor. B. Health Insurance Documentation: Any party having the insurance coverage on the other party pursuant to the terms of this Paragraph shall be required to provide the other party with all documentation pertaining to the insurance including, but not limited to, medical insurance cards, benefit booklets, claim submission forms and all statements pertaining to the determination of insurance - 11 - , , coverage as to each claim made thereunder. SECTION IV CLOSING PROVISIONS AND EXECUTION 4.01. COUNTERPARTS. This Agreement may be executed in counterparts, each of which shall be deemed .to be an original, but all of which shall constitute one and the same agreement. 4.02. FACSIMILE SIGNATURE. Each party agrees to accept and be bound by facsimile signatures hereto. 4.03. BINDING EFFECT. By signing this agreement, each party acknowledges having read and understood the entire agreement, and each party acknowledges that the provisions of this agreement shall be as binding upon the parties as if they were ordered by the Court after a full hearing. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have signed sealed and acknowledged this Agreement the day and year below written, which Agreement has been executed in various counterparts, each of which shall constitute an original. WITNESS: ~~ ~~ M,'Jc ~ IiAROLD L. SLOOP Date: b - d. g - 0 (p (SEAL) I (SEAL) E I. SLOOP 6 ~() -()~ Date: - 12- , . . . COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this the ,;;)8 day of XIV 1:; , 2006, before me the undersigned officer, personally appeared, HAROLD L. SLOOP, 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 therein contained. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jackie A, Kaltenbaugh, Notary Public South Middleton Twp., Cumberland County , My Commission Expires Oee, 24, 2009 Member, Pennsylvania Association of Notaries NOTARY PUB Y Commission Expires: COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this the ~.+ day 01'.::) ,-L , 2006, before me the undersigned officer, personally appeared, RAYETTE I. SLOOP, 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 therein contained. IN WITNESS WHEREOF, I h to set my hand and notarial seal. COMMONWEALTH OF PENNSYLVANIA Notanal Seal Diane G, Raddiff, Nolary Public Camp HiM Born, Cumberland County My Commission Expires Jan, 11, 2008 Member P~'1nsylv~!"i2~~,socia1it:l" Of Notanes - 13 - 5=' -~ . , C) _oil '-- < --1 ::-1~ I U1 -c., L-, L,,) ("... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYETTE I. SLOOP, Plaintiff NO. 2006-777 CIVIL ACTION - LAW DIVORCE v. HAROLD L. SLOOP, Defendant PRAECIPE OF 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 Section 3301 (c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filimz of Comolaint: February 7, 2006 b. Manner of Service of Comolaint: Certified Mail, Restricted Delivery c. Date of Service of Comolaint: February 10, 2006 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: June 30, 2006 b. Defendant: June 28, 2006 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301 (D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: Nt A b. Date of Filimz: NtA c. Date of Service: Nt A 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Marital Agreement dated June 30, 2006, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(D)(1)(1) OF THE DIVORCE CODE: a. Date of Service: Nt A b. Manner of Service: Nt A OR DATE WAIVER OF NOTICE IN SECTION 3301 (C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: July 5, 2006 b. Defendant's Waiver: July 5, 2006 5-- f DIA L F, ESQUIRE 3 8 Trindle Roa Camp , 7011 Supreme Court ID # 32112 Phone: (717) 737-0100 :',,) c:.' ~._- -- c,::' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RA YETTE I. SLOOP, Plaintiff NO. 2006-777 CIVIL ACTION - LAW DIVORCE v. HAROLD L. SLOOP, Defendant PRAECIPE OF 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 Section 3301 (c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filimz of Comolaint: February 7, 2006 b. Manner of Service of Comolaint: Certified Mail, Restricted Delivery c. Date of Service of Comolaint: February 10, 2006 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: June 30, 2006 b. Defendant: June 28, 2006 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301 (D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: NIA b. Date of Filimz: NI A c. Date of Service: NI A 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Marital Agreement dated June 30,2006, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(0)(1)(1) OF THE DIVORCE CODE: a. Date of Service: NI A b. Manner of Service: NI A OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: July 5,2006 b. Defendant's Waiver: July 5, 2006 CLIFF, ESQUIRE 3448 Trindle oad . , A 17011 Supreme Court I D # 32112 Phone: (717) 737-0100 o c ,r,,~ ;,; .-> = ~ (... c~, r;;'~ ..-^~j ";;::.h (.oJ -c -- ~ - .:.'"' N . . . . . . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY STATE OF . . PENNA. . . . . . RAYETTE I. SLOOP, . . Plaintiff No. 2006-777 CIVIL TERM . . . . . VERSUS . . HAROLD L. SLOOP, Defendant . . DECREE IN DIVORCE . . AND NOW, '!u\~ 1.~ . . . ,2006 , IT IS ORDERED AND . . . . DECREED THAT RAYETTE I. SLOOP , PLAI NTI FF, . . . AND HAROLD L. SLOOP , DEFENDANT, . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . No issues are outstanding. All issues have been resolved and settled by the Parties' Marital Agreement dated June 30, 2006, filed of record and incorporated into, but not merged with, this Decree. . . . . . . . . . . . . . . . . . . . J, . . . . . . . . . . . PROTHONOTARY . . . . :+;;+; 'of :+: '+' ;+;;ti .,.,,'+' 1-/7 ~ ~~ ~F:~~1"9 . ~.. \ 11: '. .. ' ,< , .., ,Ii..~' 't"\ ...t , . ' i \..._a. J<j, ?~.J;e'L 1(j.fje- L