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HomeMy WebLinkAbout06-1256or JOAN M. ROUSE, Plaintiff VS. MARTIN H. ROUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 7?Sly CIVIL ACTION - LAW : 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 will proceed without you and a decree in divorce or annulment may 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 or your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, Pennsylvania 17013 (717) 249-3166 it, JOAN M. ROUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- / 2 r- CIVIL ACTION - LAW MARTIN H. ROUSE, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Joan M. Rouse, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is Joan M. Rouse, an adult individual, currently residing at 1400 Bent Creek Blvd., Apt 204, Mechanicsburg, Cumberland County, Pennsylvania 17050 since August, 2005. 2. Defendant is Martin H. Rouse, an adult individual, currently residing at 2707 Walnut Street, Camp Hill, Cumberland County, Pennsylvania 17011 since 1992. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 7, 1996 in Enola, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, 1 A. 4acg4eline M. Verney, Esquire Supreme Ct. ID. 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff 1 v ?? ?? JOAN M. ROUSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2006-1256 CIVIL ACTION - LAW MARTIN H. ROUSE, Defendant IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1930.4 (e) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I, Jacqueline M. Verney, Esquire, being duly sworn according to law, deposes and says that she is the attorney for plaintiff, Joan M. Rouse, and that she did serve a true and correct copy of the divorce Complaint that was filed in the above matter, by U.S. mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the defendant, Martin H. Rouse, on March 8, 2006. The receipt form is attached hereto as EXHIBIT "A". Al, cqu 'ne M. Verney, Esquire #231 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff Ah.. Sworn to and subscribed before me this /0 day of C'' J 12006. hoTi &.IiIAS. vF€i! (V?P.A{.?@P.':pp'??,F?. yoLi(^?.. L? ( P?,?I A Cs^f f C?, WiIi5i45. :k 4Ptrea to- e4- ZOOG ¦ Complete items 1, 2, and 3. Also complete roam 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 mailpieoe, or on the front if space permits. 1. Article Addressed to: ?r. Mar+-nJ 14. kouse, c;101 w(AlhcL? ?f'?ted l ? P?-7611 A. X by D. Is delivery sddress ddferem from Rm 0 Yes If YES, enter delivery address bebw: 0 No 3. Service Type 0 Corned mail 0 Express mail 0 Reglstered 0 Return Receipt for Merchandise, 0 Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ON" 2. Artblfertro a 7003 1010 0001 1198 2714 (riarrs/er flbrrr setvtce /Bee1 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M1540 EXHIBIT "A" ._ J Pill I V JOAN M. ROUSE, V. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE MARTIN H. ROUSE, Defendant To the Prothonotary: NO. 06-1256 CIVIL PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearance of Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire and Beckley & Madden, of Counsel, on behalf of the Defendant, Martin H. Rouse, in the above-captioned matter. DATED: March 31, 2006 Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, Pennsylvania 17108 (717) 233-7691 L-"Momas A. Beckley, Esquire Elizabeth S. Beckley, Esquire Attorneys for Defendant Y CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was served upon the following and in the manner indicated below: VIA FIRST CLASS MAIL Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Dated: March 31, 2006 %?Elizalieth'S. Beckley ;squi e ' _ ?. l r .{ i J -? , i -i la ? * ? JOAN M. ROUSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006-1256 CIVIL TERM MARTIN H. ROUSE, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, hereby intends to resume and hereafter use the previous name of Joan M. Cook and gives this written notice avowing her intention in accordance with applicable law. ll/ V. W&W-v Joan M. e To be known as: Joan M. Co COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND B jFv On the G) day of , 20X, before me, a notary public, personally appeared Joan M. Cook (formerly no n as Joan M. Rouse), known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto T-- nd and seal. ? l COMMONWEALTH OF PENNSYLVAPMA Notary Public NOTARIAL SEAL VALERIE F. GSELI, Notary Public Carlisle Boro., Cumberland County My Commission Expires October 9, 2010 JOAN M. ROUSE, : IN THE COURT OF COMMON PLEAS OF n/k/a JOAN M. COOK, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-1256 CIVIL ACTION - LAW MARTIN H. ROUSE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 6, 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. 1 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. Date: 1 lu- 0 6 a-n 9 ? Joan ri ook, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE I . I consent to the entry of a final decree of divorce without notice. 2. 1 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. section 4904 relating to unsworn falsification to authorities. Date: ??` Joan . ook, Plaintiff ;? ?' ?> .-- ??? -? ?_? ;.? ?? ? ? -r - ._ ti .1. T :- , = k?+? ? . 7l?„ ? , ,u3_ = _- r ?: .. .a ?} =_ JOAN M. ROUSE, : IN THE COURT OF COMMON PLEAS OF n/k/a JOAN M. COOK, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-1256 CIVIL ACTION - LAW MARTIN H. ROUSE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 6, 2006. 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. 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. Date: z1f, Martin H. Rouse, Defendant 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. section 4904 relating to unsworn falsification to authorities. Date: 448 Martin H. Rouse, Defendant N b ri v C :.7 i.' -?? t"FZ 1 l 4 T a JOAN M. ROUSE, n/k/a JOAN M. COOK, Plaintiff VS. MARTIN H. ROUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1256 CIVIL ACTION - LAW IN DIVORCE MARITAL PROPERTY AND SETTLEMENT AGREEMENT This Agreement, made and entered into this 16 it-+1 day of 2008, between Joan M. Rouse, now known as Joan M. Cook, hereinafter referred to as "Wife," and Martin H. Rouse, hereinafter referred to as "Husband." WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on September 7, 1996 in Enola, Pennsylvania; and, WHEREAS, a Complaint in Divorce was filed in the Cumberland County Court of Common Pleas at No. 2006-1256 on March 6, 2006; and, WHEREAS, certain differences have arisen by and between the parties as a result of which they have now separated and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligation as between each other including, without limitation by specification: the settling of all 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 all claims and possible claims by one against the other or against their respective estates; and, WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; and, WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of her right of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to counsel fees, or expenses and other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtesy, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future; NOW, THEREFORE, the parties hereto intending to be legally bound hereby do hereby mutually agree as follows: 1. Advice of Counsel. Husband and Wife acknowledge that they have been given the opportunity to obtain the advice of counsel regarding the provisions of this Agreement and their legal effect in advance of the date set forth above to permit such independent review. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel of his or her selection, and that each fully understands the facts and has been fully informed as to his or her legal rights and obligation, and each party acknowledges and accepts that this 2 Agreement is, and under the circumstances, fair and equitable, after having the opportunity to receive such advice and with such knowledge, and that execution of this Agreement is not the result of any improper or illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has had the opportunity to be fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and having the opportunity to be fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to have the Court of Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order effecting the respective parties' rights to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 2. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 3. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3 4. Mutual Property and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of dower or curtesy, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 4 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution of married property ordered by the Court pursuant to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenances, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, exce t as otherwise expressly provided for herein. 5. Division of Personal Property. Except as set forth hereinafter, the parties agree that they are in the process of dividing their personal property including all household items, accounts, mutual funds and automobiles to their mutual satisfaction. Said division shall be completed by June 15, 2008. Each party agrees to execute whatever document is necessary to accomplish the intent of this paragraph. Household items. The parties satisfactorily dividJall their personal propertX,as- s Motor Vehicles. Husband shall hereinafter retain all right, title and interest in the two pickup trucks that he currently has in his possession, along with any debt that has been incurred or will be incurred in relation thereto. Wife shall retain her 1997 Acura that she currently has in her possession, along with any debt that has been incurred or will incurred in relation thereto. Upon the signing of this agreement, each party shall have the freedom of disposition as to their separate property which is in their possession or control pursuant to this Agreement and may 5 mortgage, sell, grant, convey or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. 6. Real Property. The parties acknowledge that they are the joint owners of real estate located at 2707 Walnut Street, Camp Hill, Cumberland County, Pennsylvania, and further acknowledge that both parties are named on a mortgage on said property. Husband hereby agrees to payoff/refinance the outstanding mortgage on said property by June 15, 2008. Acknowledging that a residential refinance requires a three day right of rescission, Husband shall require his refinance/closing agent to issue a check to Wife in the amount of $100,000.00 on the day of disbursement of the refinance. Wife agrees to execute a deed to Husband transferring all of her right, title and interest in said property at the time of settlement, which shall be held in escrow until Wife receives $100,000.00. Only if Wife receives the $100,000.00 may Wife's deed transferring her right title and interest in the real estate to Husband be effective and recorded. In the event that Husband does not refinance, but nevertheless pays off the current mortgage, Husband shall pay Wife the sum of $100,000.00 on the day that she signs a deed transferring all of her right title and interest to the property to Husband. 7. Debts. Husband and Wife hereby agree to be responsible for all of the debt in their individual names. Further Wife agrees to be responsible for her medical debt. 8. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will indemnify and hold the other harmless from any 6 and all liability thereof. 9. Spousal Support, Alimony and Alimony Pendente Lite. The parties hereby waive any right either may have to receive Spousal Support, Alimony or Alimony Pendente Lite. 10. Pensions/Retirement. Husband hereby waives any right, title or interest in any retirement, pension, IRA, or 401K that Wife has or may have an interest in. Wife hereby waives any right, title or interest in any retirement, pension, IRA, or 401 K, including any military pension that Husband has or may have an interest in. 11. Counsel fees. The parties shall be responsible for their respective counsel fees. 12. Divorce. The parties acknowledge their intention and agreement to proceed in an action in divorce to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in any divorce action. The parties agree to execute any and all documents necessary for the entry of a final divorce decree. 13. Breach. In the event that either parry breaches any provision of this Marital Property and Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 14. Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any court of competent jurisdiction. 15. Applicable Law and Execution. The parties hereto agree that this marital 7 r .' settlement agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 16. The Entire Agreement. The parties acknowledge and agree that this marital settlement agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 17. Incorporation and Judgment for Divorce. In the event that either Husband or Wife at any time hereafter obtain a divorce in the action for divorce presently pending between them, or otherwise, this agreement and all of its provisions shall be incorporated into any such judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this marital settlement agreement. 18. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. 8 WITNESS: JOAN ROUSE A JOAN (?>4, COOK MARTIN H. ROUSE V?L n y 1f ' . i JOAN M. ROUSE, : IN THE COURT OF COMMON PLEAS OF n/k/a JOAN M. COOK, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-1256 CIVIL ACTION-LAW MARTIN H. ROUSE, 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: Grounds for divorce: irretrievable breakdown under Section 3301 (c), 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Certified mail, return receipt requested restricted delivery dated March 8, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff May 22, 2008; by defendant June 12, 2008. (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff's affidavit upon the defendant 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 (b) record, a copy of which is attached Date plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: _June 16, 2008. Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 16, 2008. ll // ?V 4 ' aO ° cqu ne M. Verney, Esquire #23167 Attorney for Plaintiff 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 ? ° ? '? v- cra i n^ r : ?:: '? t'r'y ? '? ? ? ,?' ? '- ? L ?nT'M Y 1. {'iZ ? M _ Q l4 V ; ?`"? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF j PENNA. JOAN M. ROUSE, n/k/a =y', r- JOAN M. COOK, Plaintiff VERSUS MARTIN H. ROUSE, Defendant No. 2006-1256 CIVIL TERM DECREE IN DIVORCE AND NOW, 3.e-n c ( ? , Zao?, IT IS ORDERED AND DECREED THAT Joan M. Rouse, n/k/a Joan M. Cook Martin H. Rouse AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAI NTI FF, ,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; The parties' Marital Settlement Agreement dated June 16, 2008,is incorporatea nerein ana the uou E A ?5? -,,* -sa-u -7 Sal .'? 4 s }