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HomeMy WebLinkAbout02-2010MARK ALLEN REED, PLAINTIFF ¥$. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA · NO STACY MARIE REED, : CIVIL ACTION - LAW DEFENDANT : ACTION FOR DIVORCE / CUSTODY 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 bc 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, One Courthouse Square, Carlisle, PA 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 1-800-990-9108 MARK ALLEN REED, PLAINTIFF STACY MARIE REED, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : d~ -Rolo : NO. CML TERM : : CIVIl, ACTION - LAW : ACTION FOR DIVORCE / CUSTODY COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, MARK ALLEN REED, by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and makes the following consolidated complaint in divorce for divorce and custody. 1. Plaintiff is MARK ALLEN REED, an adult individual, who currently resides at 877 Old Silver Spring Road, Meehanicsburg, Cumberland County, Pennsylvania, 17055. The Plaintiff has resided in Cumberland County for over one (1) year. 2. Defendant is STACY MARIE REED, an adult individual, who currently resides at 40 Village Court, Mechanicsburg, Cumberland County, Penn.~lvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defenda~tt were lawfully married on September 9, 1999. 5. There have been no prior actions of divorce or for annulment between the parties except this Complaint filed for divorce. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the court require the parties to participate in counseling. Plaintiff has chosen not to engage in, or to request any counseling. Neither Plaintiff nor Defendant was a member of the United States Military Services. 9. Plaintiff and Defendant have one (1) child from their marriage, TYI,ER ALLEN REED, bom August 10, 1999. 10. thereto. 11. COUNT I - REQUEST FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE Paragraphs 1 through 9 of this Complaint are incorporated herein by reference After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiffbelieves Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff, MARK ALLEN REED, respectfully requests the court to enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. COUNT II - REQUEST FOR CONFIRMATION OF CUSTODY UNDER SECTIONS 3104(a)(2) and 3323(b) OF THE DIVORCE CODE Paragraphs 1 through 11 of this Complaint are incorporated herein by reference 12. thereto. 13. The parties are the parents of the following unemancipated child who resides with the Plaintiff and Defendant: NAME AGE SEX DATE OF BIRTH TYLER ALLEN REED 2 Years Male August 10, 1999 14. During the past five (5) years the child has resided with the parties and at the addresses herein indicated: WITH WHOM Plaintiff and Defendant Plaintiff Defendant ADDRESS 877 Old Silver Spring Road Mechanicsburg, PA 877 Old Silver Spring Road Mechanicsburg, PA 40 Village Court Mechanicsburg, PA FROM / TO Birth to June, 2001 June, 2001 to Present June, 2001 to Present 15. Plaintiff has not participated in any other litigation concerning the child in this or any other state. 16. There are no other proceedings pending involving custody of the child in this or any other state. 17. Plaintiff knows of no person not a party to these proceedings who has physical custody of the child or who claims to have custody, partial custody or visitation rights with respect to the child. 18. The best interests of the child will be served if both Plaintiff and Defendant have Shared Legal and Physical Custody of their child. WHEREFORE, Plaintiff, MARK ALLEN REED, respectfully requests that, pursuant to Sections 3104(a)(2) and 3323(b) of the Divorce Code, the Court enter an order confirming Shared Legal and Physical Custody with Plaintiff, MARK ALLEN REED, and Defendant, STACY MARIE REED, of the parties' minor child, TYLER ALLEN REED. Respeclfully submitted, Dated: April~, 2002 LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Susan Kay Cal~ll~, Esquire Counsel for Plaintiff PA I.D. tt 64998-~ 5021 East Trindle Road Suitel00 Mechanicsburg PA 17050 (717) 796-1930 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are tree and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: t-I -..2 ~ - 02_ MARK ALLEN REED MARK ALLEN REED : PLAINTIFF : : V. : 02-2010 .: STACY MARIE REED DEFENDANT : IN CUSTODY : ORDER OF COURT AND NOW, Wednesday, May 01, 2002 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Meehaniesburg, PA 17055 on Wednesday, May 22, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabihtes 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 heating or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ............ ~fqO MARK ALLEN REED, PLAINTIFF IrS. STACY MARIE REED, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 02-2010 CIVIL TERM : : CIVIL ACTION - LAW : ACTION FOR DIVORCE / CUSTODY ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I hereby accept service of the Complaint for No-Fault Divorce Under Section 3301(c) of the Divorce Code and the Wednesday, May 1, 2002 Order of Court scheduling the Pre-Hearing Custody Conference for Wednesday, May 22, 2002 at 8:30 a.m., in the above matter. Dated: Mayt~)/-~, 2002 Respectfully submitted, MAY 8 200Z MARK A. REED, VS. STACY M. REED, Plaintiff Defendant :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2010 CIVIL ACTION LAW : : : IN CUSTODY ORDER OF COURT AND NOW, this 21st day of May, 2002, the Conciliator, having been advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Conciliation Conference scheduled for May 22, 2002 is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator MARK ALLEN REED, PLAINTIFF VS. STACY MARIE REED, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 02-2010 CIVIL TERM : CIVIL ACTION - LAW : CUSTODY STIPULATION FOR AGREED ORDER OF CUSTODY The Plaintiff (hereinafter sometimes referred to as "Father") is MARK ALLEN REED, who currently resides at 877 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. The Defendant (hereinafter sometimes referred to as "Mother") is STACY MARIE REED, who currently resides at 40 Village Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. TYLER ALLEN REED (hereinafter sometimes referred to as "Tyler"), born on August 10, 1999, is the subject of this Stipulation for Agreed Order of Custody and is the natural child of the Plalntiffand Defend_~nt. It is Plaintiff and Defendant's belief that it is in the best interests of their minor child to have a meaningful ongoing relationship with both his natural Mother and natural Father, provided the child is in a safe environment. WHEREFORE, Plaintiff, MARK ALLEN REED, and Defendant, STACY MARIE REED, have entered into a mutual agreement regarding the custody of their child and respectfully request this Honorable Court to enter the following Order: 1. Plaintiff and Defendant shall share Legal Custody (as defined in 23 Pa.C.S.A. Section 5302) of their minor child, TYLER ALLEN REED. 2. All decisions affecting their child's growth and development including, but not limited to: choice of camp, if any; choice of day care provider; medical and dental treatment; psychotherapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving their child, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities shall be considered major decisions and shall be made by Father and Mother, jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in their child's best interest. 3. Mother and Father agree to keep the other informed of the progress of their child's education and social adjustments. Mother and Father agree not to impair the other's right to shared legal or physical custody of their child. Mother and Father agree to give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well-being of their child. 4. While in the presence of their child, neither Mother nor Father shall make or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom their child should respect and love. 5. While in the presence of the child, neither Mother nor Father nor any other person shall dis'cuss terms of custody, legal proceedings, or any other topic, to which it is not in the best interests of the child to be exposed. 6. It shall be the obligation of each parent to make their child available to the other in accordance with the physical custody schedule and to encourage their child to participate in the plan hereby agreed and ordered. 7. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. 8. With regard to any emergency decisions which must be made, the parent with whom the child is physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Day-to-day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 9. Mother and Father shall be entitled to complete and full infmmation from any doctor, dentist, teacher or authority and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may and are encouraged to attend school conferences and activities. 10. Neither Mother nor Father shall schedule activities or appointments for their child which would require their attendance or participation at said activity or appoinh-aent during a time when their child is scheduled to be in the physical custody of the other parent without that parent's express prior approval. 11. Mother and Father shall Share Physical Custody of their minor child, TYLER ALLEN REED, according to the following schedule: A. Mother and Father shall alternate weeks of visitation with their son. The exchange of their son shall occur each Monday when the parent who has custody the previous week takes the child to the child care giver and the parent who shall begin their week of custody picks the child up at the child care giver. If for some reason the child care giver is not being used, the parents shall exchange their son with the party beginning their week of custody picking the child up at the residence of the party ending their week of custody; B. Mother and Father shall have the ability to request one to two (1-2) evening visits with Tyler during the week they do not have custody of Tyler. This evening visit shall be scheduled with the parent with custody of Tyler a minimum of twenty-four (24) hours before the requested evening of visitation. This period of visitation shall begin when the parent leaves work through 8:00 p.m. that same evening. If the parent without custody does not work on the day they are requesting visitation, they may request the child for the entire day through 8:00 p.m. that same evening. The parent without custody getting Tyler for visitation shall be responsible for the transportation of Tyler; C. The parties shall alternate the following holidays. Holidays shall begin at 5:00 p.m. the evening of the day before the holiday and extend through 8:00 p.m. the evening of the holiday. Father shall have the even numbered holidays and Mother the odd numbered holidays in the even numbered years, to alternate annually thereafter: l) New Year's Eve and Day, (this holiday shall be determined by the year in which the New Year's Eve occurs); 2) Easter; 3) Memorial Day; 4) Independence Day (This day may be extended later in the evening to attend fireworks.); 5) Labor day; 6) Thanksgiving Day. D. Christmas: Mother and Father shall alternate Christmas with Mother getting Schedule A in the even numbered years and Father getting Schedule B in the even numbered years, to alternate annually thereafter. A. To begin Christmas Eve at 5:00 p.m. through Christmas Day at 2:00 p.m. B. To begin Christmas Day at 2:00 p.m. through December 26 at 8:00 p.m. E. Father shall have the child on Father's Day and Mother shall have the child on Mothers Day, from 9:00 a.m. through 8:00 p.m.; F. Mother and Father shall have the option of requesting one (1) to two (2) consecutive weeks of vacation during the year with their child providing a minimum of thirty (30) days' notice of the time requested is given to the other G. The parties are encouraged to discuss and cooperate with each other when sharing and making requests for changes in periods of visitation. All permanent changes in periods of custody from' the those contained in this custody agreement shall be made in writing and signed by both parties; H. All holidays, vacations, and specially designated times for visitation with their child shall supersede the regularly scheduled visitation. 12. Father and Mother agree they will not interfere with telephone calls or any other form of communication between the party without custody of the child and the child. 13. Mother and Father agree to contact each other in a timely manner to give each other "Right of First Refusal" for any time when they will not be with Tyler for more than a four 14. Mother and Father agree to share transportation equally, with the party beginning their period of visitation being responsible to get Tyler, unless transportation is otherwise specifically stated for that period of visitation. 15. Communication between the parties at the time of the transfer of Tyler shall be limited to important information about the child. The parties shall not disparage or engage the other in any arguments at the time of the exchange of the child. 16. Mother and Father agree to be responsible for any ordinary everyday expenses which occur during their individual custody periods with their child. 17. Mother and Father agree to equally (50/50) share all child care expenses. 18. Father agrees to provide Tyler with health insurance. The parties agree to equally (50/50) divide all uncovered medical, dental, orthodontia, vision and psychological expenses for Tyler. 19. The parent with physical custody of the child agrees to keep the other parent fully aware and informed of any successes, difficulties, activities, emergencies, etc., in which their child has become involved. 20. Mother and Father agree to provide each other with current information regarding the day care provider and any other individuals and/or activities when their child is in the care of an adult other than an activity within their child's school. Mother and Father also agree to have each other listed as an emergency contact with that adult and/or agency. 21. Neither Mother or Father shall consume any alcoholic beverages, controlled substances, or prescription drugs, which would interfere with their ability to provide the child with a safe environment, twenty-four (24) hours prior to and/or during their custody periods with the child. 22. Mother and Father shall be free to muBjoily agree to alter and/or change the terms of this agreement. If the alteration and/or agreement is permanent and/or a change which will occur on numerous occasions, the parties agree the alteration and/or change shall be in writing and signed by both parents. DATED: MARK ALLEN REED DATED: [THIS SPACE IS INTENTIONALLY LEFT BLANK.] COMMONWEALTH OF PENNSYLVANIA : : COUNTY OF CLcx~3eq \&~x6~ : SS: On this, the e)~~>~ day ofrX ~l~.x~ ,2002, before me, a Notary Public for the Commonwealth of Pennsylv/thia, ~e undersigned officer, personally appeared I~[S~RK ALLEN REED known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and notarial seal. My Commission Expires: (~ c~)~ , Notmy Public Expires &or. 4, 2005 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF ~ L~Xct~/&xx~ : SS: On this, the o33cfi day of ~ ,2002, before me, a Notary Public for the Commonwealth of Peunsyl~ania,~he undersigned officer, personally appeared STACY MARIE REED known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Stipulation for Agreed Order of Custody, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and notarial seal. Notary Public 6 My Commission Expires: C~ J__ KJmbedv R: Hanford, Notary Public ! ~ ~mm~alo~ Expires Apr. 4, 2005 MARK ALLEN REED, PLAINTIFF STACY MARIE REED, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBEI~!,AND COUNTY, : PENNSYLVANIA : : NO. 02-2010 CIVIL TERM : : CML ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this 9o ' day of <fo-~ ,2002, upon consideration of the ~ I e attached Stipulation for Agreed Order of Custody, Plaintiff, MARK ALLEN REED, and Defendant, STACY MARIE REED, shall SHARE LEGAL AND PHYSICAL CUSTODY of their son, TYLER ALLEN REED, in accordance with the language contained in the within Stipulation. BY THE COURT, MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT is entered into this ~ day of between MARK ALLEN REED and STACY MARIE REED. ,2002, by and RECITALS Wife's Birthday and Social Security Number: November 30, 1978 196-68-9053 Husband's Birthday and Social Security Number: December t9, 1976 160-68-4300 Date of Marriage: September 9, 1999 Place of Marriage: Mechanicsburg, Pennsylvania Last Marital Residence: 877 Old Silver Spring Road, Mechanicsburg, Pennsylvania, 17055 Date of Separation: June, 2001 Children: Tyler Allen Reed, Born August 10, 1999 Pending Court Proceedings: None Divorce Court of Common Pleas No. 02-2010 Civil Term of Cumberland County, Pennsylwmia WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling: fully and finally their respective financial and property rights and obligations as between each other including, without limitation: the ownership and equitable distribution of marital property; the past, present and future support, and/or maintenance of Wife by Husband; and, in general, any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premis, es and of the 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: PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any contact, restraint, interference or authority, direct or indirect, by the other in all respects as fully as 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 molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means whatsoever with him or her. WAIVER OF RIGHTS AND MUTUAL RELEASES Except as otherwise expressly provided by this Agreement: (a) Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either may have or at any time hereafter have for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights, agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Neither party shalI have any obligation to the other not expressly set forth herein. (b) Each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties or otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or furore acts, contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's fights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. It is expressly understood, however, that neither the provisions of this release nor the subsequent entry of a divorce decree are intended to defeat the right of either party to receive any insurance proceeds at the death of the other of which she or he is the named beneficiary (whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest or residuary portion of the other's estate under his or her will, or to act as personal representative or executor if so named by the will of the other, whether such will was executed prior or subsequent to this., Agreement. 2 (c) Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. FINANCIAL DISCLOSURE The parties have disclosed to each other and they are each aware of the extent of each other's income, assets, liabilities, holdings and estate. AGREEMENT TO BE INCORPORATED BUT NOT MERGED INTO DIVORCE DECREE In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be deemed merged into such judgment or decree. This agreement shall survive any such final judgment or decree of absolute divorce, shall be entirely independent thereof, and the p~ties intend that all obligations contained herein shall retain their contractual nature in any etfforcement proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement action filed to the divorce caption. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in Section 3105(a) of the Divorce Code, as amended. As provided in Section 3105(c), provisions of this Agreement regarding equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modification by the court. Concurrently with the execution of this Agreement, the parties shall sign Affidavits of Consent and Waivers of Notice of Intention to Request Entry of Final Divorce Decree. Husband shall be responsible for filing these documents and finalizing the divorce. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Susan Kay Candiello, Esquire, for Husband. Wife has been apprised of her need for counsel and has waived her right to counsel. (Please see Waiver of Right to Counsel attached hereto and made a part hereof at Exhibit "A".) The parties acknowledge that each has been advised of their right to obtain independent legal advice from counsel of their selection and that they haVe been fully informed as to their legal rights and obligations, including all rights available to them under the Pennsylvania Divorce Code of 1980, as amended, and other applicable laws. Each party confirms tl~t he or she fully understands the terms, conditions and provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the existing circumstances. VOLUNTARY EXECUTION Each party understands the terms and conditions of ttds Agreement and acknowledges that the Agreement is fair and equitable. The parties have reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or improper or illegal agreements. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature.. Notwithstanding this provision, under applicable Pennsylvania law, the parties understand that any provision of this Agreement relating to child support or to custody shall be subject to modification by the Court upon a showing of changed circumstances. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. AGREEMENT BINDING ON HEIRS Except as may otherwise be provided, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 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. ADDITIONAL INSTRUMENTS Wife and Husband covenant and agree that they will forthwith (and within at most ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect 'unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision hereof be construed as a waiver of strict performance of any other obligations herein. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS The parties agree that each separate obligation cont~dned in this Agreement shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the remaining obligatic,ns of the parties. MANNER OF GIVING NOTICE Any notice required by this Agreement to be sent to Withe shall be sent by certified mail, return receipt requested, to Wife at 40 Village Court, Mechanicsburg, Pennsylvania, 17050, or such other address as Wife from time to time may designate in writing. Any notice required by this Agreement to be sent to Husband shall be sent by certified mail, return receipt requested, to Susan Kay Candiello, Esquire, at the Law Firm of Susan Kay Candiello, P.C., 5021 East Trindle Road, Suite 100, Mechanicsburg, Pennsylvania, 17050, or such other address as Husband from time to time may designate in writing. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 5 BANKRUPTCY OR REORGANIZATION PROCEEDINGS In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any fight to claim any exemption (whether granted under state or federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby assigns, transfers and conveys to the creditor-spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorneys' fees and costs incurred in the enforcement of this Paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of federal or state law to the contrary, and each party waives any and all right to assert that any obligation hereunder is discharged or dischargeable. EFFECT OF RECONCILIATION OR RECONCILIATION ATTEMPT This Agreement shall remain in full force and effect ew~n if the parties reconcile, cohabit as husband and wife, or attempt 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. EXISTING AND FUTURE PERSONAL OBLIGATIONS Further, Wife and Husband each covenant, warrant, represent and agree that neither has heretofore contracted for any debt, liability or obligation for w]hich the other or the estate of the other may be responsible or liable except as specifically disclosed and provided for by the terms of this Agreement. The parties further covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and indemnify the other and the estate of the other from all debts, charges and liabilities incurred after the execution date hereof, except as may be otherwise specifically provided herein, as well as from all debts, liabilities or obligations of every kind which have been incurred heretofore by either party', including those for necessities, except for obligations arising out of this Agreement. ENFORCEMENT The parties intend that this Agreement shall be subject to enforcement under the Pennsylvania Divorce Code of 1980, as amended, and that, notwithstanding any language herein that may be construed to the contrary, this Agreement is not subj eot to modification except under such terms as the parties have specifically provided for in this Agreement. ENFORCEMENT OF SUPPORT AND ALIMONY PROVISIONS The parties hereby agree that all of the support and alimony provisions contained in this Agreement (including both direct and indirect contributions to support and alimony, such as health care payments and the maintenance of health and/or life insurance) may be enforceable by an action in support in accordance with Pennsylvania Rules of Civil Procedure 1910.1 et seq. REMEDIES AND SANCTIONS In addition to such other remedies and sanctions available under applicable law, the parties may utilize any remedy or sanction set forth in the Pennsylvania Divorce Code, as amended, to enforce any term of this Agreement as though it had been an order of the Court. 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 parties hereby agree that the breaching party will pay all attorney's fees incurred by tlhe other party in enforcing the Agreement, provided that the enforcing party is successful in establishing that a breach has occurred. EQUITABLE DISTRIRUTION 1. PERSONAL PROPERTY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property; and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon any claims, which either may have with respect to the above items, which shall hereafter be the sole and exclusive property of the other. 2. MOTOR VEHICLES A. The 1994 Ford Explorer is titled in Husband's nan~e only with a loan which is in Husband's name only. Husband wishes to keep this vehicle. Husband agrees to be solely responsible for all loans, expenses and insurance for this vehicle. This vehicle shall hereinafter be the sole and exclusive property of Husband. B. The 1996 Mitsubishi Eclipse is titled in both Husband and Wife's names. There is a joint loan for this vehicle with Members First. Within six (6) months from the date of the execution of this Agreement, Wife agrees to sell this vehicle and pay off the joint loan. Until Wife has sold the vehicle, Wife agrees to make a payment to Husband each week, in an amount equal to one-fourth (1/4) of the monthly car payment due on this vehicle. Husband shall then be responsible for making the monthly car payment on this vehicle. C. The parties agree to execute any documents necessary to effectuate the provisions of this Paragraph on the execution date hereof, including Vehicle Sales and Use Tax Returns as necessary to make any conveyances on a tax-free basis if pos.,;ible. The said documents shall be delivered to the party entitled to receive same pursuant hereto on execution date. D. In the event that any documents of title to the said 'vehicles shall be in the hands of a bank or other holder ora lien or encumbrance upon either of the said vehicles, and it is intended that such vehicle be conveyed subject to the said lien or encumbrance, the parties agree that they will advise the bank and/or lienholder as to the transfer of title and they further agree to execute whatever documents may be required to transfer title where the parties' documents of title are in the hands of such bank and/or lienholder. 3. BANK ACCOUNTS The parties had a joint checking account which has been completely used to pay off household and marital bills. The parties agree that they will execute any documents necessary to effectuate the provisions of this Paragraph on execution date. 4. RETIREMENT INTEREST Neither party has any retirement/pension plan. 5. MARITAL RESIDENCE / DIVISION OF EQUITY Marital Residence/Value There is little or no equity in the marital residence. Husband has decided to remain in thc marital residence. Wife has already left the marital residence. The marital residence is deeded in both Husband and Wife's names. There is a mortgage on the marital residence in both Husband and Wife's names. Husband shall obtain a release to remove Wife's name l~rom the mortgage. Wife agrees to sign all documents necessary to accomplish this. Husband agrees to be fully responsible for all expenses, costs, insurance, mortgage payments, taxes, liens, and any other expenses related to or connected with the marital residence. Husband's attorney will draft a Deed to the marital residence transferring Wife's interest in the marital residence solely to Husband. Wife will execute this Deed at the time of the execution of this Agreement. 6. JOINT DEBTS AND LIABILITIES The parties have agreed to assume all debt, expenses, insurance costs associated with their individual vehicles. Wife has agreed to sell her vehicle to pay off the loan for the vehicle in full. Husband will obtain a release removing Wife's name from the mortgage on the marital residence and assume full responsibility for all mortgage payments, loans, liens, taxes, expenses, fees and costs associated with the marital residence. The parties have separated their individual and joint credit card accounts. The parties have agreed to assume full responsibility for each of their individual credit card accounts, if any. The parties have a joint loan with Members First, which was obtained to consolidate several debts the parties incurred while married. Husband agrees to assume full responsibility for this loan. Wife has incurred some medical debt for her own health care since the parties' separation. Wife shall assume full responsibility for all debt she has incurred for her health care. Wife has a cell telephone, which is in Husband's name. Wife does not have the ability to obtain a cell telephone without Husband co-signing. Husband will agree to continue as the co-signer for Wife's cell telephone, provided Wife pays the cell telephone bill in a timely and appropriate manner. When the contract for this cell telephone expires, Husband will no longer agree to be the co-signer for Wife's cell telephone. Each party warrants to the other that he/she does not have any credit cards in joint names. Any obligations incurred by either party in his or her individual name, whether incurred before or after the parties' separation, and including credit cards, are the sole responsibility of the party in whose name the debt or obligation was incurred. 7. SEPARATE ASSETS A. Release: The parties hereby agree that as to each of ltheir separate assets, as that term is defined herein, the party not having title to or possession of any particular separate asset hereby waives, releases, relinquishes and forever abandons any and all claim therein, and acknowledges that hereafter the party having title to or possession of a separate asset is the sole and exclusive owner thereof. B. Limitation to Assets Disclosed: The above release is subject to the proviso that it shall be effective only as to those assets disclosed to the other party, although such assets need not be specifically named or disposed of in this Agreement. Neither party intends by the execution hereof to release any claim, which he or she may have in assets, which have not been disclosed. C. Definition: The term "separate asset" is deemed l~or purposes of this Agreement as designating any asset of any kind (whether real, personal or mixed, tangible or intangible) which is presently titled either in the sole name ora party hereto or jointly with one of the parties hereto and a third party or parties. The term also includes any untitled asset which is presently in the sole possession of one of the parties hereto. The term shall further include any business interests owned by either party, whether individually or together with a l~hird party or parties. D. Indemnification as to Expenses: Each of the parties hereby guarantees to indemnify and hold the other harmless from any liability, cost or expense, including attorneys' fees and interest, which either may be in the future or has been previously incurred with respect to the parties' separate assets as defined herein. 8. AFTER-ACQUIRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired by him or her after execution of this Agreement, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 9. WAIVER OF ALIMONY Husband and Wife do hereby waive, release and give up any rights, which either may have against the other to receive alimony or other post-divorce maintenance or support. It shall be, from the execution date of this Agreement, the sole responsibility of each of the respective parties to sustain himself or herself without seeking any support from the other party. 10. INCOME TAX RETURNS Husband and Wife have filed joint income tax returns while married. If the parties are entitled to a refund and/or incur any liability as a result ofjoinl! income tax returns filed during the parties' marriage, the refund and/or the liability shall be eqtmlly divided between them. The cost of preparing and handling any prior income tax return from the parties' married years shall be shared equally between them. Husband and Wife agree to promptly make available to each other all records and information necessary or helpful for the preparation of any tax returns, any claim for refunds, and defense of any tax audit. 11. COUNSEL FEES AND EXPENSES The parties have agreed to equally share all counsel fees and expenses incurred in obtaining this divorce. Payments by both Husband and Wife shall be made during the ninety (90) day waiting period for the divorce. The divorce shall not be finalized until the payments from both Husband and Wife have been paid in full. 10 Each of the parties has carefully read and fully considered this Agreement and aH of the statements, terms, conditions and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals the day and year first written above, r~ ~ WITNESS  MARK A;LLEN REED HUSBAND COMMONWEALTH OF PENNSYLVANIA - · SS: COUNTY OF C. o~_x~heq kttx'x ok · On this, the c~c& day of ~ ,21)02, before me, a Notary Public for the Commonwealth of Pennsylvania,°the t~dersigned officer, personally appeared STACY MARIE REED known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marital Property Settlement Agreement, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and not~al seal· Notary Public~3 My Commission Expires: Notarial Seal M~.R. Hanford, Notary Public rg Bom_, Cum .l~rland County ission rr. xpires Apr. 4, 2005 11 COMMONWEALTH OF PENNSYLVANIA · COUNTY OF C~3e~/cx~x~ .' SS: On this, the ~ day of /~ ,21!02, before me, a Notary Public for the Commonwealth of Pennsylvanid0the u~dersigned officer, personally appeared MARK ALLEN REEl) known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marital Property Settlement Agreement, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and not~al seal. Notary Public ~ My Commission Expires: i Notarial Seal ! I'~mbefly R. Hanford, Notary Public CumL , , County ! ~-y <,umm~s~on Ex, res .,~pr. 4. 2005 12 MARK ALLEN REED, PLAINTIFF vs. STACY MARIE REED, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLV~NIA : : NO. 02-2010 CIVIL TERM : : CIVIL ACTION - LAW : DIVORCE WAIVER OF RIGHT TO COUNSEL FOR MARITAL pROPERTY SETTLEMENT AGREEMENT I, STACY MARIE REED, do hereby acknowledge that I am the Wife in this divorce action· I have agreed to and executed the attached Marital Property Settlement Agreement voluntarily. I am not under any duress, nor were there any threats or promises made to me to coerce my execution of this Agreement. I fully understand my property rights as Wife in this divorce action are determined by this Marital Property Settlement Agreement. I agree to fulfill my responsibilities and obligations under this Marital Property Settlement Agreement. I have been advised of and do hereby waive my rights to an attomey to represent me on the issue of the Marital Property Settlement Agreement. Date:~ ~, ~_ _ ~_.-~ ,2002 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CLL~%~-~Ox~C~ SS: On this, the c,3~~ day of [X/(c~ ,2002, before me, a Notary Public for the Commonwealth of Pennsylvania, the undeYsigndd officer, personally appeared STACY MARIE REEl) known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Waiver of Right to Counsel for Marital Property Settlement Agreement, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have set my hand and notarial seal. otary¢ My Commission Expires: ~ .J-"~...~ Notarial Seal I~R~' -Hanf°rd' N°tary Public ~ ~, Cure.nd ~ml~n E~m, ~r. 4, ~5 EXHIBIT "A" MARK ALLEN REED, PLAINTIFF VS. STACY MARIE REED, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 02-2010 C. IVIL TERM : : CIVIL ACTION - LAW : ACTION FOR', DIVORCE / CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 24, 2002. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce, after the service of notice of intention to request entry of the decree. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 5. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the Statements 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 unswom falsification to authorities. /bATE MARK ALLEN REED MARK ALLEN REED, PLAINTIFF VS. STACY MARIE REED, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV/~NIA NO. 02-2010 C. IVIL TERM CIVIL ACTION - LAW : ACTION FOR DIVORCE / CUSTODY ~'N E F NTENT T ~ DV R DE REEUNDER E TI 3 lc~ 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 tree 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. DATEr// MARK ALLEN REED MARK ALLEN REED, PLAINTIFF ¥$. STACY MARIE REED, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2010 CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR: DIVORCE / CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 24, 2002. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce, a~'ter the service of notice of intention to request entry of the decree. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 5. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a ~fivorce decree being handed down by the Court. I verify that the Statements 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 unswom falsification to authorities. MARK ALLEN REED, PLAINTIFF VS. STACY MARIE REED, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2010 CIVIL TERM CIVIL ACTION - LAW : ACTION FOR DIVORCE / CUSTODY AI R F TI E F INTE I T RE~ DIVOR E DE REE R E TI lc~ 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. DA~E /~ I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. MARK ALLEN REED, PLAINTIFF : IN THE COURT OF COMMON PLEAS : OF CUMBERIAND COUNTY, : PENNSYLVANIA vs. : NO. 02-2010 CIVIL TERM : STACY MARIE REED, : CIVIL ACTION - LAW DEFENDANT : ACTION FOR DIVORCE / CUSTODY PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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. Date and manner of service of Complaint: The Defendant, Stacy Marie Reed, signed the Acceptance of Service on May 6, 2002. Said ,Acceptance of Service was filed with the Cumberland County Prothonotary on May 1.4, 2002. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code by: Plaintiff: February 5, 2003 Defendant: February 5, 2003 4. (a) Related claims pending: None (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: All claims (d) Please see the Marital Property Settlement Agreement which is being filed simultaneously with this Praecipe to Transmit Record and is to be incorporated but not merged into the Divorce Decree. 5. I certify that the Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301(c) of Divorce Code as required by Rule 1920.42(e)(1) was executed on February 5, 2003 by the Plaintiff and on February 5, 2003 by the Defendant, and that these documents are being filed simultaneously with this Praecipe to Transmit Record. I further certify that all other documents required by Rule 1920.42 are enclosed herewith. Dated: February lO, 2003 Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Susan Kay Can ilO, E ui'r -- "-' - Counsel for Plaintiff] PA I.D. # 6499~__..,/ 5021 East Trindle iRoad Suite 100 Mechanicsburg PA 17050 (717) 796-1930 IN THE COURT OF COIVllVION OF CUMBERLAND COUNTY STATE OF ~' , , PENNA. PLEAS P~~ VERSUS STACY MARIE REED, DEFENDANT NO. 02-2010 CIVIL TERM DECREE iN DIVORCE AND NOW, DECREED THAT A N d STACY MARIE R.E~) ArE DIVORCED FROM THE BONDS Of MATRIMONY. , 2003 , IT IS OrDErED AND , PLAINTIFF, _, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; PROTHONOTARY