HomeMy WebLinkAbout06-3859REBECCA L. WENNICK,
Plaintiff
VS.
STEVEN DOUGLAS, IUa,114 i c K
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNT//Y77, PENNSYLVANIA
NO. CHG.
CIVIL ACTION- AT 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
may proceed without you, and a decree of divorce, or annulment may be entered against you by the
court. A judgment may also be entered against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
REBECCA L. WENNICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. t
STEVEN DOUGLAS, ba enrN%?K : CIVIL ACTION- AT LAW- IN DIVORCE
Defendant
DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION CLAIM
The Plaintiff, Rebecca L. Wennick, by and through her attorneys, The Law Offices of
Patrick F. Lauer, Jr., LLC, makes the following Complaint in Divorce:
COUNT I-NO FAULT DIVORCE--§§ 3301(c) or 3301(d)
1. The Plaintiff, Rebecca L. Wennick, is an adult individual currently residing at 13
Belvedere Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. The Defendant, Steven Wennick, is an adult individual currently residing at 36
Blue Spruce Drive, Enola, Cumberland County, Pennsylvania, 17025.
3. The Plaintiff has been a bona fide resident of the Commonwealth for at lease six
months.
4. The parties were married on November 5, 1988, in Chambersburg, Pennsylvania.
5. There has been no prior action for divorce or annulment instituted by either of the
parties in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised that counseling is available and that the Plaintiff
may have the right to request that the court require the parties to participate in counseling.
8. This action is not collusive.
9. There are three children born to this marriage, Evan H. Wennick, born November
30, 1993, age 12; Benjamin S. Wennick, born July 25, 1996, age 9; and Wilson R.
Wennick, born December 18, 2001, age 4.
WHEREFORE, the Plaintiff requests this Honorable Court enter a decree of Divorce in
this matter.
COUNT II-EQUITABLE DISTRIBUTION--§ 3502(a)
10. Paragraphs one (1) through nine (9) of this Complaint are incorporated herein by
reference as if set forth specifically below.
11. During the course of the marriage, the parties acquired property and incurred debt,
titled jointly, individually, or both, which remains in possession of the individual parties.
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to equitably
divide, distribute, or assign the marital property between the parties in such proportion as the
court deems just after consideration of all relevant factors and thereby enter an order of equitable
distribution of marital property pursuant to §3502(a) of the Divorce Code.
COUNT III-REQUEST FOR ALIMONY PENDETE LITE AND ALIMONY PURSUANT
TO SECTIONS 3701(a) and 3702 OF THE DIVORCE CODE
12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein
by reference as if set forth specifically below.
13. Plaintiff is unable to sustain herself during the course of litigation.
14. Plaintiff lacks sufficient property to provide for her reasonable needs and is
unable to sustain herself through appropriate employment.
15. Plaintiff requests the Court to enter an award of alimony pendente lite until
hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3701(a)
3702 of the Divorce Code.
WHERFORE, Plaintiff respectfully requests this Honorable Court to enter an award
alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor
pursuant to Sections 3701(a) and 3702 of the Divorce Code.
Respectfully submitted,
Shana M. Pug ire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011
Date.07- 0(I-m4 ID# 200952 Tel. (717) 763-1800
REBECCA L. WENNICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO.
STEVEN DOUGLAS, ; CIVIL ACTION- AT LAW- IN DIVORCE
Defendant
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom
falsification to authorities.
Date: ' holy,
Signature: &19L46L. L Ukf-4L_, u[
Rebecca L. Wennick
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REBECCA L. WENNICK,
Plaintiff
VS.
STEVEN D. WENNICK;
Defendant
: IN THE COURT OF COMMON. PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:,No.. 2006 - 3859 CIVIL TERM
CIVIL ACTION - AT LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July
10, 2006.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety
days have elapsed from the date of filing 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.
4. 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
unworn falsification to authorities.
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Date: &-7 Signature:
REBECCA L. WENNICK
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REBECCA L. WENNICK,
Plaintiff
vs.
STEVEN D. WENNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2006 - 3859 CIVIL TERM
CIVIL ACTION - AT LAW
IN DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF ADIVORCE 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.
4. I verify that the statements made in this affidavit are true and correct. I understand I
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unworn falsification to authorities.
Date: ? d Signature: &?' /' ` d L
REBECCA L. WENNICK
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REBECCA L. WENNICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 2006 - 3859 CIVIL TERM
STEVEN D. WENNICK, CIVIL ACTION - AT LAW
Defendant IN DIVORCE
NOTICE TO THE DEFENDANT
IF YOU WISH TO DENY ANY OF THE STATEMENTS SET. FORTE IN THIS.
AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS
AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL
BE ADMITTED.
AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on June 3, 2006, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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: S W l
Rebecca L. Wennick, Plaintiff
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REBECCA L. WENNICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 2006 - 3859 CIVIL TERM
STEVEN D. WENNICK, CIVIL ACTION - AT LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
TO THE PROTHONOTARY:
I, Marlin L. Markley, Esquire, verify the Affidavit Under § 3301(d) of the Divorce
Code has been served upon the Defendant indicated above by first class, certified mail #
7008-0150-003-6464-2514, restricted delivery, return receipt requested, prepaid postage,
pursuant to the requirements of Pa. R.C.P. 1930.4.
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Respect y bmitted,
arl' ar squire
Law O es of Patrick F. Lauer, Jr., LLC
2108 M et Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this day of , 2007, by and
between REBECCA L. WENNICK, "WIFE" and STEVE D. WENNICK, "HUSBAND".
WHEREAS, the parties hereto were married on November 5, 1988 in Chambersburg,
Franklin County, Pennsylvania; and
WHEREAS, difficulties have arisen between the parties and it is therefore their intention
to live separate and apart for the rest of their lives and the parties are desirous of settling
completely the economic and other rights and obligations between each other, including, but not
limited to: the equitable distribution of the marital property; past, present and future support,
alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by
one against the other or against their respective estates.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
kept and performed by each party and intending to be legally bound hereby, the parties do hereby
agree as follow:
1. Advice of Counsel. The provisions of this Agreement and their legal effect have
been fully explained to WIFE by her counsel, Marlin L. Markley, Esquire. With full knowledge
of the implications of this agreement, HUSBAND has elected not to seek independent legal
counsel.
The parties further declare that each is executing this Agreement freely and voluntarily
having either obtained sufficient knowledge and disclosure of their respective legal rights and
obligations, or if counsel has not been consulted, expressly waiving the right to obtain such
knowledge. The parties each acknowledge that this Agreement is fair and equitable and is not the
result of any fraud, coercion, duress, undue influence and/or collusion.
2. Divorce Action. The parties acknowledge that their marriage is irretrievably
broken and that they shall secure a mutual consent no fault divorce pursuant to §3301(c) of the
Divorce Code. A divorce action has been filed by WIFE with the Court of Common Pleas of
Cumberland County, Pennsylvania. However, on the date of execution of this Agreement, the
parties have agreed to finalize the divorce on a mutually agreed upon date.
3. Date of Execution. The "date of execution" and "execution date" of this
Agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date"
of this Agreement shall be defined as the date of execution by the party last executing this
Agreement. The Agreement shall be effective on the date of execution.
4. Mutual Releases. Each party absolutely and unconditionally releases the other
and the estate of the other from any and all rights and obligations which either may have for past,
present, or future obligations, arising out of the marital relationship or otherwise, including all
rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as
described herein.
Each party absolutely and unconditionally releases the other and his or her heirs,
executors, and estate from any claims arising by virtue of the marital relationship of the parties.
The above release shall be effective whether such claims arise by way of widow's or widower's
rights, family exemption, or under the intestate laws, or the right to take against the spouse's will,
or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a
surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of
Pennsylvania, any state, Commonwealth, or territory of the United States, or any other country.
Except for any cause of action for divorce which either party may have or claim to have,
each party gives to the other by the execution of this Agreement an absolute and unconditional
release from all claims whatsoever, in law or in equity which either party now has against the
other.
5. Financial and Procedural Disclosure. The parties confirm that each has relied
on the accuracy of the financial disclosure of the other as an inducement to the execution of this
Agreement. Each party understands that he/she had the right to obtain from the other party a
complete inventory or list of all property that either or both parties owned at the time of
separation or currently own and that each party had the right to have all such property valued by
means of appraisals or otherwise. Both parties understand that they have the right to have a court
hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby
acknowledge that this Agreement is fair and equitable, and that the terms adequately provide for
his or her interests, and that this Agreement is not a result of fraud, duress or undue influence
exercised by either party upon the other or by any person or persons upon either party.
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6. Separation/Non-Interference. The parties agree that, for all purposes, the date of
separation shall be July 10, 2006, the date on which the Divorce Complaint was filed.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They
shall be free from any interference, direct or indirect, by the other in all respects as fully as if
they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on and
engage in any business, occupation, profession or employment which to him or her may seem
advisable. WIFE and HUSBAND shall not harass, disturb, or malign each other or the respective
families of each other.
7. . Marital Residence. The parties marital residence is situated at 13 Belvedere
Drive, Mechanicsburg, Cumberland County. The parties mutually agree that WIFE shall retain
sole possession of the residence free of any right, claim, title, or interest of HUSBAND. WIFE
shall assume all liabilities and obligations in connection with the upkeep and maintenance of the
property, including, but not limited to, payment of real estate taxes, mortgages, assessments, and
homeowner's insurance. WIFE shall indemnify and hold HUSBAND harmless from any and all
claims of every kind arising out of or in connection with said property. If necessary, HUSBAND
shall execute a deed conveying all his rights, title, and interest in and to said real property to
WIFE or a Release of Marital Rights. HUSBAND hereby relinquishes any claim, right, title,
and/or interest that he may have or would have in the residence, as well as any equity therein.
8. Furnishings and Personalty. The parties agree that they have divided by
agreement between themselves all furnishings and personalty located in the Marital Residence,
including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and
equipment. Accordingly WIFE shall retain sole and exclusive ownership of all furnishings and
personalty currently in her possession, free and clear of any right, title, claim, and/or interest of
HUSBAND and HUSBAND shall retain all items of furnishings and personal property currently
in his possession as his sole and separate property free and clear of any right, tile, claim, and/or
interest of WIFE.
9. Debts. The parties acknowledge and agree that marital debt will be apportioned as
follows: WIFE will assume all liability incurred for the debts listed below, and shall indemnify
and save HUSBAND harmless from any and all claims or demands made against him by reason
of such debts or obligations.
a. Kohl's credit card
b. Old Navy credit card
c. Boscov's credit card
d. Wells Fargo credit card
e. Amaco credit card
f. Belco Credit Union Visa credit card
g. Chase Bank credit card with the last four digits of 2753.
HUSBAND will assume all liability incurred for the debts listed below, and shall
indemnify and save HUSBAND harmless from any and all claims or demands made againsthim
by reason of such debts or obligations.
a. Exxon credit card
b. Discover credit card
c. Chase Bank credit card with the last four digits of 4762.
HUSBAND represents and warrants to WIFE that since July 10, 2006, he has not, and in
the future he will not, contract or incur any debt or liability for which WIFE or her estate might
be responsible, and he shall indemnify and save WIFE harmless from any and all claims or
demands made against her by reason of such debts or obligations incurred by him since the date
of said separation, except as otherwise set forth herein.
WIFE represents and warrants to HUSBAND that since July 10, 2006, she has not, and in
the future she will not, contract or incur any debt or liability for which HUSBAND or his estate
might be responsible, and he shall indemnify and save HUSBAND harmless from any and all
claims or demands made against him by reason of such debts or obligations incurred by her since
the date of said separation, except as otherwise set forth herein.
10. Indemnification of Husband and Wife. If any claim, action, or proceeding is
hereafter initiated to hold WIFE liable for the debts or obligations assumed by HUSBAND under
this Agreement, HUSBAND will, at his sole, expense, defend WIFE against any such claim,'
action or proceeding, whether or not well-founded, and indemnify her and her property against
any damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by WIFE in connection therewith.
If any claim, action nor proceeding is hereafter initiated seeking to hold HUSBAND
liable for the debts or obligations assumed by WIFE under this Agreement, WIFE will, at her
sole expense, defend HUSBAND against any such claim, action or proceeding, whether or not
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well-founded, and indemnify him and his property against any damages or loss resulting
therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by
HUSBAND in connection therewith.
11. Retirement and/or Pension Benefits. Both HUSBAND and WIFE have
retirement accounts and/or pensions benefits that may be subject to equitable distribution under
the Divorce Code. Both parties acknowledge their right to have the retirement accounts valued to
determine the value of the marital property; however both parties expressly waive their rights to
do so.
12. Bank Accounts. The parties hereby agree that they have divided to their mutual
satisfaction all the monies situated in all bank accounts. Each party agrees that hereinafter, the
accounts held in their own names or for the benefit of said party, remains their sole and exclusive
property, free and clear of any right, claim, title, or interest of the other.
13. Cash Payment. In consideration of and for HUSBAND'S waiver and
relinquishment of all rights arising from the marital relationship, WIFE shall pay HUSBAND a
lump some of $25,000.00. Payment shall be made within seven (7) days of WIFE'S refinance of
the marital home. The parties agree that the payment to HUSBAND as described in this
paragraph is fair and equitable in exchange for HUSBAND'S interest in marital property herein
identified, and is therefore equitable distribution, without any tax consequences to either party.
14. Vehicles. There are two marital vehicles, namely a Toyota and a 2006 Ford
Fusion. The parties agree that HUSBAND will undertake all financial responsibility for the 2006
Ford Fusion, including, but not limited to, loan payments, insurance premiums, and maintenance.
The parties also agree that WIFE will undertake all financial responsibility for the Toyota,
including, but not limited to, loan payments, insurance premiums, and maintenance.
If, by the time of execution of this agreement, title has not been transferred to reflect sole
ownership of the Toyota in WIFE and sole ownership of the Ford in HUSBAND, such
arrangements shall be made within five (5) business days of the execution date of this
Agreement.
15. Spousal Support, Alimony Pendente Lite, and Alimony. Husband. shall pay to
Wife the sum of $300.00 per month as alimony. The payment is due on the first day of the
month following the granting of the divorce decree and by the first day of each subsequent
5
month. The paragraph shall have no impact on support or alimony pendente lite payments
ordered by domestic relations or the court until the divorce decree is granted.
The alimony shall continue until Husband's death, Wife's death, Wife's remarriage, or
Wife's cohabitation with another man, not her spouse or a member of her immediate family,
whichever occurs first. Otherwise, the alimony shall not be subject to termination.
16. Income Taxes. Wife shall have the benefit of the parties three children for
income tax purposes.
17. Children's extracurricular activities and Health Insurance. Both parties shall
share equally in the costs of the children's extracurricular activities to include, but not limited to
sports, clubs, and trips.
Husband is responsible for providing the children's health care insurance and is
responsible for 50%0 of un-reimbursed medical expenses.
18. Attorney Fees and Court Costs. Each parry hereby agrees to be solely
responsible for his or her own counsel fees, costs and expenses. Neither shall seek any
contribution thereto from the other except as otherwise expressly provided herein.
19. Attorney's Fees for Enforcement. In the event that either party breaches any
provision of this Agreement and the other party retains counsel to assist in enforcing the terms
thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses
(including interest and travel costs, if applicable) which are incurred by the other party in
enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by
amicable resolution. It is the specific agreement and intent of the parties that a breaching or
wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel
fees incurred by the non-breaching party in protecting and enforcing his or her rights under this
Agreement.
20. Waiver of Rights. Both parties hereby waive the following procedural rights:
(a) The right to obtain an inventory and the appraisement of all marital and
non-marital property;
(b) The right to obtain an income and expense statement of either party;
(c) The right to have all property identified and appraised;
(d) The right to discovery as provided by the Pennsylvania Rules of Civil
Procedure; and
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(e) The right to have the court make all determinations regarding marital and
non-marital property, equitable distribution, spousal support, alimony
pendente-liter alimony, counsel fees and costs and expenses.
21. Mutual. Cooperation. WIFE and HUSBAND shall mutuallycooperate with each
other in order to carry through the terms of this Agreement, including but not limited to, the
signing of documents.
22. Void Clauses; If any term, condition, clause or provision of this Agreement shall
be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this Agreement, and in all other respects this
Agreement shall be valid and continue in full force, effect and operation.
23. Applicable Law. This Agreement shall be constructed under the laws of the
Commonwealth of Pennsylvania.
24. Entire Agreement. This Agreement contains the entire understanding of the
parties. There are no other representations, warranties, covenants, or undertakings other than
those expressly set forth herein. HUSBAND and WIFE acknowledge and agree that the
provisions of this Agreement with respect to the distribution and division of marital and separate
property are fair, equitable, and satisfactory to them, based on the length of their marriage and
other relevant factors which have been taken into account by the parties.
Both parties hereby accept the provisions of this Agreement with respect to the division
of property in lieu of and in full and final satisfaction. of all claims and demands that they may
now have or hereafter have against the other for equitable distribution of their property by any
court of competent jurisdiction. HUSBAND and WIFE each voluntarily and intelligently waive
and relinquish any right to seek a court ordered determination and distribution of marital
property, but nothing herein shall constitute a waiver by either party of any rights to seek the
relief of any court for the purposes of enforcing the provisions of this Agreement.
25. Voluntary Execution. Each party acknowledges that the Agreement is fair and
equitable, that it's being entered into voluntarily, with full knowledge of the assets of both
parties, and that it is not the result of any duress or undue influence. The parties acknowledge
that they have been furnished with all information relating to the financial affairs of the other
which has been requested by each of them.
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26. Descriptive headings. The descriptive headings used herein are for convenience
only. They shall have no effect whatsoever in determining the rights or obligations of the parties.
27. Release. Subject to the provisions of this Agreement, each party has released and
discharged, and by this Agreement does for himself or herself, and his or her heirs, legal
representatives, executors, administrators and assigns, release, indemnify (including actual legal
fees) and discharge the other of and from all causes of action, claims, rights, or demands,
whatsoever in law or equity, including equitable distribution, spousal support, alimony pendente
lite, alimony, counsel fees, and expenses which of the parties against the other ever had, now
has, or may have in the future under the Pennsylvania Divorce Code as amended, in this or any
other State's statutory or common law.
28.. Contract Interpretation. For purposes of contract interpretation and for the
purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared
jointly by the parties.
IN WITNESS THEREOF, the parties hereto have set their hands and seals of the day
first above written.
This agreement is executed in duplicate. WIFE and HUSBAND acknowledge the receipt
of a duly executed copy hereof.
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Witness
Witness
Rebecca L. Wennick, Wife
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Steven D. Wennick, Husband
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
Rebecca L. Wennick, being first duly sworn, deposes, and says that she has read the
forgoing Marital Settlement Agreement and subscribed to the same and that it is a true and
correct statement of fact and that it was entered into without any undue influence, fraud, coercion
or misrepresentation of any sort and that it is her voluntary act and deed.
Subscribed and sworn to before me this day of , 2007.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Shelby A. Nelsof +, Notary Public
Camp Hill Boro, Cumberland County
My Commission Ex fires Aug. 20, 2009
Member, Pennsylvanas Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Notary Public
ss
Steven Wennick, being first duly sworn, deposes, and says that he has read the forgoing
Marital Settlement Agreement and subscribed to the same and that it is a true and correct
statement of fact and that it was entered into without any undue influence, fraud, coercion or
misrepresentation of any sort and that it is his voluntary act and deed.
Subscribed and sworn to before me this 1.
ALTH OF PENNSYLVANIA
Notarial Seal
Shelby A. Nt' bm Notary Public
Camp Hill Boro, glrq oiand County
My Commissicrt Mq*oe Aug. 20, 2009
Member. Pennsylvania Association of Notaries
-day of , 2007.
Notary Public
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REBECCA L. WENNICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 2006 - 3859 CIVIL TERM
STEVEN D. WENNICK, CIVIL ACTION = AT LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
TO THE PROTHONOTARY:
1, Marlin L. Markley, Esquire, verify the Complaint in Divorce has been served upon
the Defendant indicated above by first class, certified mail # 7005-0390-0006-3485-7395,
restricted delivery, return receipt requested, prepaid postage, pursuant to the requirements of
Pa. R.C.P. 1930.4
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Marti kley, Esquire
Law Offic of Patrick F. Lauer, Jr., LLC
2108 Mar t Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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REBECCA L. WENNICK,
Plaintiff
VS.
STEVEN D. WENNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2006 - 3859 CIVIL TERM
CIVIL ACTION - AT LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
TO THE PROTHONOTARY:
I, Marlin L. Markley, Esquire, verify the Notice of Intention to Request Entry and
the Counter-Affidavit Under § 3301(d) of the Divorce Code has been served upon the
Defendant indicated above by first class, certified mail # 7008-0150-0003-6464-2583,
restricted delivery, return receipt requested, prepaid postage, pursuant to the requirements of
Pa. R.C.P. 1930.4.
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lMm 4 If Restricted Delivery Is desired.
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so that we can return the card to you.
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La es of as ck F. Lauer, Jr., LLC
108 arket Street, Aztec Building
Camp ill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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REBECCA L. WENNICK,
Plaintiff
VS.
STEVEN D. WENNICK,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2006 - 3859 CIVIL TERM
CIVIL ACTION - AT LAW
IN DIVORCE
Transmit the record, together with the following information, to the Court for entry
of a divorce decree:
1. Ground for Divorce: Irretrievable breakdown under § c) § 3301(d)(1) of the
Divorce Code.
2. Date and Manner of service of the Complaint:
Service by certified mail #7005-0390-0006-3485-7395, delivered on July 14, 2006. See
attached Affidavit of Service.
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 the Plaintiff ;
by the Defendant
(b) Date of execution of the affidavit required by § 3301(d) of the
Divorce Code: August R,20OR;
Date of filing and service of the Plaintiffs affidavit upon the
respondent: Filed on Au»ct 11, 20OR; gerved on Aua st 27,2008;
4. Related claims pending: Please inenrnorate, without merging, the
attached Marital Settlement Agreement of the parties intn the Divnrce Decree_
5. (Complete either paragraph (a) or (b).)
(a) Date and manner of service of the Notice of Intention to File
Praecipe to Transmit Record, a copy of which is attached, Service by
certified mail #7008-0150-0003-6464-2583, delivered on nctnher 23, 2008;
(b) Date Plaintiff s Waiver of Notice in § 3301(c) Divorce was filed with
the Prothonotary: ;
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed
with the Prothonotary:
It - ( 3 -2,0,9 y
Date:
Marlin L. M squire
2108 arke Street, Aztec Building
Camp Hill, nnsylvania 170114706
ID# 84745 Tel. (717) 763-1800
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Rebecca L. Wennick
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
Steven D. Wennick
NO. 2006-3859
DIVORCE DECREE
AND NOW, A/e? Grp , .Zsae , it is ordered and decreed that
Rebecca L. Wennick
plaintiff, and
Steven D. Wennick , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (if no
claims remain indicate "None.")
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By the Court,
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