HomeMy WebLinkAbout06-4590JANICE KOHUT,
Plaintiff
V.
ROBERT W. KOHUT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. l.tuj- v62?
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 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 Court House,
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
Telephone No. (717) 249-3166 or 1-800-990-9108
andra L. Meil n
Attorney for Plaintiff
TUCKER ARENSBERG, P.C.
P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
JANICE KOHUT,
Plaintiff
V.
ROBERT W. KOHUT,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIAl
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
COUNT I - DIVORCE
1. Plaintiff is Janice Kohut, an adult individual who is
sui juris and resides at 400 Independence Court, Mechanicsburg,
Cumberland County, Pennsylvania 17050.
2. Defendant is Robert W. Kohut, an adult individual who
is sui juris and resides at 1363 Kiner Boulevard, Carlisle,
Cumberland County, Pennsylvania 17013. The present whereabouts of
the Defendant, Robert W. Kohut, to the knowledge of the Plaintiff,
is the same.
3. Both Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 5,
1998, in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
8. The Plaintiff avers that the grounds on which the
action is based is that the marriage is irretrievably broken.
COUNT II - CUSTODY
9. Plaintiff seeks shared legal and
custody of the parties' son, Robert E. Kohut,
1999. The child was not born out of wedlock.
Due to Plaintiff's recent move and by
parties, the child is temporarily in the primary
of Defendant with periods of partial phys:
Plaintiff.
shared physical
born August 30,
agreement of the
physical custody
.cal custody in
During the past five years, the child has resided with
the following persons and at the following addresses:
Plaintiff, Defendant 1363 Kiner Boulevard From 8/30/99 to
Andrea Gutting Carlisle, PA 17013 6/9/06
Defendant 1363 Kiner Boulevard 6/9/06 to
Carlisle, PA 17013 present
The mother of the child is Plaintiff, currently residing at
400 Independence Court, Mechanicsburg, PA. She is married.
The father of the child is Defendant, currently residing at
1363 Kiner Boulevard, Carlisle, PA. He is married.
10. The relationship of Plaintiff to the child is that of
mother. The Plaintiff currently resides with her daughter, Andrea
Gutting.
11. The relationship of Defendant to the child is that of
father. The Defendant currently resides with Robert E. Kohut.
12. Plaintiff has not participated as a party or witness,
or in another capacity, in other litigation concerning the custody
of the child in this or another court.
13. The best interest and permanent welfare of the child
will be served by granting the relief requested because Plaintiff
and Defendant have been both been integral in care giving for
their son and Plaintiff desires to continue said role.
14. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action.
WHEREFORE, Plaintiff requests the Court to enter a Decree:
A. Dissolving the marriage between Plaintiff and
Defendant; and
B. Grant shared legal and shared physical custody of the
parties' son; and
C. For such further relief as the Court may determine
equitable and just.
TUCKER ARENSBERG, P.C.
3'andra L. Meilton, Esquire
I.D. No. 32551
111 N. Front Street
P.O. Box 889
Harrisburg, PA 17108
717-234-4121
Attorneys for Plaintiff
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. Section 4904, relating to
unsworn falsification to authorities.
, Pi'alnt
Dated: 7'31-4&
88682.1
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JANICE KOHUT IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBERT W.KOHUT
DEFENDANT
06-4590 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, August 15, 2006 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator,
at MDJ Manlove, 1901 State St., Camp Hill PA 17011 on Tuesday, September 12, 2006 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/ Melissa P. Greevy Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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JANICE KOHUT,
Plaintiff
V.
ROBERT W. KOHUT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-4590 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this day of September, 2006, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Legal Custody. The parties, Janice Kohut and Robert W. Kohut, shall have
shared legal custody of the minor child, Robert E. Kohut, born August 30, 1999. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non-emergency decisions affecting the children's general well-being including, but not
limited to, all decisions regarding their health, education and religion. Pursuant to the terms
of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining
to the children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. All decisions affecting the
children's growth and development including, but not limited to, choice of camp, if any;
choice of child care provider; medical and dental treatment; psychotherapy, or like
treatment; decisions relating to actual or potential litigation involving the children directly or
as a 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 with the parents jointly, after discussion and consultation with
each other and with a view toward obtaining and following a harmonious policy in the
children's best interest.
2. Physical Custody. The parties will have a shared physical custody schedule
year round, whereby they alternate weeks of custody each Friday, with the exchange time
being after the conclusion of the Friday school day. In the event that the child is ill or
otherwise not in school on Friday, the parent receiving custody on that Friday will be
responsible to care for the child unless other arrangements are made, with first priority to be
given to having the child be with the parent who has just relinquished custody. Mother's first
week of custody shall commence on September 15, 2006. Father's week of custody shall
commence on September 22, 2006.
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N0.06-4590 CIVIL TERM
3. Vacation. The parties will exercise vacation during their regularly-scheduled
summer custodial weeks.
4. Holidays. The following holiday schedule shall supercede the regular
schedule:
A. Independence Day Labor Day and Memorial Day. Father shall have custody
for Independence Day each year in order for the child to participate in a
traditional family trip to the lake. Father shall have custody for Labor Day
weekend each year and Mother shall have custody for Memorial Day weekend
each year. For Labor Day and Memorial Day, the custodial period shall begin
on Friday, and shall end on Tuesday morning, when the child is returned to
school.
B. Thanksgiving. The parties shall equally split the time that the child is out of
school for the Thanksgiving break. Thanksgiving Day shall be included in the
first part of the Thanksgiving holiday, however, the day itself shall not be split.
In even-numbered years, Mother shall have custody for the first half of
Thanksgiving break, and Father shall have custody for the second half of
Thanksgiving break. In odd-numbered years, Father shall have custody for
the first half of the Thanksgiving break, and Mother shall have custody for the
second half of Thanksgiving break.
C. Christmas. Christmas shall be divided into two segments, Segment A and
Segment B. Segment A shall be from December 23rd at 6:00 p.m. until
December 25th at 2:00 p.m. Segment B shall be from December 25th at 2:00
p.m. until December 28th at 6:00 p.m. In even-numbered years, Father shall
have Segment A and Mother shall have Segment B. In odd-numbered years,
Mother shall have Segment A and Father shall have Segment B.
D. Mother's Day and Father's Day. Father will have custody for Father's Day.
Mother will have custody for Mother's Day. The custodial time for this holiday
shall commence at 6:00 p.m. the day before the holiday and continue until
6:00 p.m. the day of the holiday.
E. Easter. The parties will split the time that the child is off from school for the
Easter break. In odd-numbered years, Mother will have custody for the
segment of the Easter break that includes Easter Day. In the even-numbered
years, Father will have custody for the segment of the Easter break that
includes Easter Day.
NO. 06-4590 CIVIL TERM
5. After the parties have tried the schedule in Paragraph 2 for sixty days, if an
additional Conference is needed, counsel or either party may contact the Conciliator by fax
to request that the Custody Conciliation Conference be reconvened. No petition will be
necessary if the request is made within ninety days of commencing the schedule provided in
Paragraph 2.
Dist: /Sandra yL.
Robert W
Wilton, Esquire, P. O. Box 889, Harrisburg, PA 17108
Kohut, 1363 Kiner Blvd, Carlisle, PA 17015
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JANICE KOHUT,
Plaintiff
V.
ROBERT W. KOHUT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-4590 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF
Robert E. Kohut August 30, 1999 Mother and Father
2. Mother filed a Divorce Complaint with a count for custody on August 9, 2006.
A Custody Conciliation Conference was scheduled for September 12, 2006. Present for the
conference were: the Mother, Janice Kohut, and her counsel, Sandra L. Meilton, Esquire;
the Father, Robert W. Kohut, participated pro se.
3. The parties reached an agreement in the
Date
n Order as attached.
IQlelissa Peel Greevy, Esquire
Custody Conciliator
:283092
JANICE KOHUT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 06-4590 Civil Term
ROBERT W. KOHUT, CIVIL ACTION - LAW
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Robert W. Kohut, hereby certify that I received the certified and time stamped
copy of the Complaint in Divorce filed in the above matter.
Date:
89541.1
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JANICE KOHUT,
Plaintiff No. 2006-4590 (Civil Term)
V.
CIVIL ACTION - LAW
ROBERT W. KOHUT,
Defendant (In Divorce)
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August
9, 2006.
2. The marriage of Plaintiff and 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.
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: 4
Robert W. Kohut, Defendan
C3
Sandra L. Wilton, Esquire
Quintina A Laudermilch, Esquire
DALEY ZUCKER MEILTON
MINER GINGRICH, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
smeilton@dzmmf,,Iaw.com
tlaudermilchadzmmglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JANICE KOHUT,
Plaintiff No. 2006-4590 (Civil Term)
V.
CIVIL ACTION - LAW
ROBERT W. KOHUT,
Defendant (In Divorce)
AFFIDAVIT OF CONSENT
A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August
9, 2006.
2. The marriage of Plaintiff and 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.
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: OALe
Cl)'a'n6ice Kohut, Plai
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Sandra L. Meilton, Esquire
Quintina M. Laudermilch, Esquire
DALEY ZUCKER MEILTON
MINER GINGRICH, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
smeilton@dzmmL,Iaw.com
tlaudermilchAdzmmglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JANICE KOHUT, :
Plaintiff ; No. 2006-4590 (Civil Term)
V.
CIVIL ACTION - LAW
ROBERT W. KOHUT, :
Defendant (In Divorce)
WAIVER OR NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Date:
C ice Kohut, Plain iff
4
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JANICE KOHUT,
Plaintiff
V.
ROBERT W. KOHUT,
Defendant
No. 2006-4590 (Civil Term)
CIVIL ACTION - LAW
(In Divorce)
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER F 3301(c) AND & 3301(d) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities.
Date: Ot
Robert . Kohut, Defendant
f rJ
71
Sandra L. Wilton, Esquire
Quintina M. Laudermilch, Esquire
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
smeilton ,dzmmglaw.com
tlaudermilchnu,dzmmglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JANICE KOHUT,
Plaintiff No. 2006-4590 (Civil Term)
V.
CIVIL ACTION - LAW
ROBERT W. KOHUT,
Defendant (In Divorce)
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT is made this day of ? /k.b(Z , 2008, by and
between Janice Kohut, whose current address is 400 Independence Court, Mechanicsburg,
Cumberland County, Pennsylvania, hereinafter referred to as Wife, and Robert W. Kohut, whose
current address is 1363 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania,
hereinafter referred to as Husband.
WITNESSETH
WHEREAS, Husband and Wife were lawfully married on June 5, 1998 at Carlisle,
Cumberland County, Pennsylvania; and
WHEREAS, one child was born of this marriage, namely, Robert E. Kohut whose date of
birth is August 30, 1999; and
WHEREAS, Wife filed a Complaint for Divorce on August 9, 2006 in the Court of
Common Pleas of Cumberland County, Pennsylvania, Docket Number 2006-4590.
Page 1 of 19
WHEREAS, Certain differences have arisen between the parties as a result of which they
have separated and now live separate and apart from one another, and are desirous of settling fully
and finally their respective financial and property rights and obligations as between each other,
including, without limitation by specification: the settling of all matters between them relating to
the past, present and future support 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 for equitable distribution of all marital property; and a resolution
of all mutual responsibilities and rights growing out of the marriage relationship; and
NOW THEREFORE, in consideration of the above recitals and the following covenants
and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally
bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree
as follows:
1. ADVICE OF COUNSEL: The parties acknowledge that each has had the
opportunity to consult with an attorney of the party's choice. Wife is represented by Sandra L.
Meilton, Esquire of Daley Zucker Meilton Miner & Gingrich, LLC. Husband has voluntarily
chosen not to be represented by counsel. To the extent Husband has chosen not to be represented
by counsel, Husband has knowingly and voluntarily, without persuasion, influence, or coercion by
Wife, waived the right to do so with respect to the advisability of entering into this agreement, and
elects to enter into the agreement and be legally bound by its terms. It is further acknowledged by
the unrepresented party that he has not relied on any representations made by counsel for Wife.
Page 2 of 19
2. SEPARATION: It shall be lawful for each parry at all times hereafter to live
separate and apart from the other at such place or places as he or she may from time to time
choose or deem fit.
3. PERSONAL RIGHTS: Each party shall be free from interference, authority and
contact by the other, as fully as if he or she were single and unmarried, except as may be
necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor
attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in
any way harass or malign the other, nor in any way interfere with the peaceful existence, separate
and apart from the other in all respects as if he or she were single and unmarried.
4. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The
parties agree that the terms of this Agreement may be incorporated into any divorce decree
which may be entered with respect to them. Notwithstanding such incorporation, this Agreement
shall not be merged in the decree, but shall survive the same and shall be binding and conclusive
on the parties for all times.
5. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This
Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or
absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such
defense as may be available to either party. This Agreement is not intended to condone and shall
not be deemed to be a condonation on the part of either party hereto of any act or acts on the part
of the other party which have occasioned the disputes or unhappy differences which have
occurred prior to or which may occur subsequent to the date hereof. The parties intend to secure
a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code
of 1990.
Page 3 of 19
6. 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.
7. 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 any 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 whatever claims, if any, he or she may have with respect to the above items
which shall become the sole and separate property of the other, with full power to him or her to
dispose of the same as fully and effectually, as though he or she were unmarried.
8. MOTOR VEHICLES: The parties acknowledge that they individually and/or
jointly hold titles to the following vehicles:
1973 Revcon Motorhome
1991 Audi 200
1988 Toyota Landcruiser
1976 Buick Electra
1991 Chevy Suburban
1970 Buick Skylark
1970 Buick Gran Sport
1970 Buick Gran Sport
1968 Buick Gran Sport
1970 Buick Sportwagon
1969 Buick Sportwagon
1968 Buick Sportwagon
Page 4 of 19
1993 Volvo 240
1991 Volvo 940
All of the above-listed vehicles are currently in Husband's possession. Regardless of
when the above-referenced vehicles were acquired, the parties agree that above-listed vehicles
shall become the sole and exclusive property of Husband subject to any liens held on said vehicles
and Wife hereby relinquishes any right, title or interest she may have in and to all of the above-
listed vehicles. Husband shall acquire and maintain separate insurance on the above-listed
vehicles, and shall hold harmless and indemnify Wife from any loss thereon. Husband
specifically agrees to assume full responsibility and pay in due course, any encumbrance on any
of the above-listed the vehicle(s) and agrees to indemnify Wife from any loss by reason of his
default in the payment thereof and agrees to save Wife harmless from any future liability with
regard thereto
The titles to the above-listed motor vehicles shall be executed by the parties, if
appropriate for effecting transfer as herein provided, on the date of execution of this Agreement
and the said executed title shall be delivered to the proper parties on the distribution date.
9. REAL PROPERTY: The parties hereby agree that Wife shall execute and
deliver all documents in the usual form conveying, transferring and granting to Husband all of
her right, title and interest in and to their jointly-owned real estate at 1363 Kiner Boulevard,
Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as the "marital residence"),
subject to the mortgage(s) given to Husband and Wife. The deed to said property shall be held in
escrow by Wife's attorney until such time as Husband refinances the property so as to eliminate
Wife from any obligation on the mortgage(s). The refinancing shall be accomplished within
sixty (60) days of execution of this Agreement. If Husband is able to accomplish said
Page 5 of 19
refinancing, then Wife's attorney shall release the deed from escrow in order to consummate said
refinancing.
In the event that Husband is unable to refinance the property within sixty (60) days of
execution of this agreement, the parties agree that the property will be listed for sale with a
realtor familiar with properties in Carlisle, Cumberland County, Pennsylvania. All proceeds
from the sale of the house shall be used to satisfy the existing mortgage, home equity line and/or
any other liens on the property. Any and all remaining proceeds after the payment of all closing
costs, realtor fees, mortgage(s), home equity line of credit and any other liens on the property
shall be retained by Husband.
Both prior to and after the refinance or sale of the marital residence, Husband
agrees to be solely responsible for the payment of any and all mortgages, taxes, insurance, liens
and utility bills relative to said real estate and agrees to indemnify and hold Wife harmless from
any responsibility thereunder.
10. AFTER-ACQUIRED PERSONAL PROPERTUREAL ESTATE: Each of the
parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of
personal property, tangible or intangible, and any real estate hereafter acquired by him or her, 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.
11. WAIVERS OF RETIREMENT & PENSION INTERESTS: Each party
hereto hereby relinquishes any right, title or interest he or she may have in or to any intangible
personal property currently titled in the name of or in the possession of the other party, including,
but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts,
employment benefits, including retirement accounts, savings plans, pension plans, stock plans,
Page 6of19
401(k) plans, 403 (b) plans and the like.
A. HUSBAND'S 401(k): The parties acknowledge that Husband has a
401(k) account as a result of his employment with Vale National Training Center and a 401(k)
account as a result of his ownership interest in Appraisal Concepts (hereinafter referred to as
"Husband's 401(k) accounts"). Wife acknowledges that she has been informed of her right to
obtain an independent appraisal and/or valuation of Husband's 401(k) accounts and any marital
interest she may have therein, and notwithstanding same, Wife hereby forever waives and
relinquishes any right, title interest or claim she might otherwise have in and to Husband's
401(k) accounts. Immediately upon presentation thereof, Wife agrees to execute any and all
documents necessary to effectuate a complete and total waiver of her rights in and to Husband's
401(k) accounts.
B. WIFE'S 401(k): The parties acknowledge that Wife has a 401(k) account
as a result of her employment with Bristol West Insurance Group (hereinafter referred to as
"Wife's 401(k)"). Husband acknowledges that he has been informed of his right to obtain an
independent appraisal and/or valuation of Wife's 401(k) account and any marital interest he may
have therein, and notwithstanding same, Husband hereby forever waives and relinquishes any
right, title interest or claim he might otherwise have in and to Wife's 401(k) account.
Immediately upon presentation thereof, Husband agrees to execute any and all documents
necessary to effectuate a complete and total waiver of his rights in and to Wife's 401(k) account.
C. REQUIRED ERISA WAIVER LANGUAGE: To the extent applicable,
each party understands that had they not given up all of their respective rights to the other's
pensions, each party may have the right to have the other spouse's pension paid in the special
Qualified Joint Survivor Annuity (hereinafter referred to as "QJSA") payment form; however, each
Page 7 of 19
party agrees to give up that right. Husband and Wife understand that by signing this Agreement,
each is giving up his and her respective right to receive the special QJSA payment form.
Each parry hereto understands that by signing this Agreement, they may each choose any
retirement benefit form and/or any beneficiary that is allowed by the plan without telling the
other and without obtaining the other's agreement. Each party hereto also understands that
he/she can change the retirement benefit form selected and/or the name of the beneficiary at any
time before retirement begins without telling the other and without getting the other's
permission.
Each party hereto understands that were he/she not to give up his/her rights in each
other's respective pensions, he/she could limit. each other's choice to a particular retirement
benefit form and/or a particular beneficiary who would receive payments from the plan after the
death of the other and that by signing this Agreement, each is giving up that right. Each
understands that he/she does not have to sign this Agreement and each party acknowledges that
he/she is signing this Agreement voluntarily. Each party further understands that if he/she does
not sign this Agreement, then he/she may receive payments from the plan in the special QJSA
payment form.
12. APPRAISAL CONCEPTS: The parties hereby acknowledge that Husband is a
Five Percent (5%) owner of a business entity, Appraisal Concepts (hereinafter referred to as
"Appraisal Concepts"), and that Husband acquired said ownership interest prior to the parties'
marriage. Wife acknowledges that she has been informed of her right to obtain an independent
appraisal and/or valuation of Husband's ownership interest in Appraisal Concepts and any
marital interest she may have therein, and notwithstanding same, Wife hereby forever waives
and relinquishes any right, title interest or claim she might otherwise have in and to Husband's
Page 8of19
ownership interest in Appraisal Concepts.
14. DEBTS:
a. MARITAL DEBT: Except as otherwise herein provided, Husband and
Wife acknowledge and agree that there are no outstanding debts and obligations of which they
are aware or for which the other might be liable incurred prior to the execution of this
Agreement.
The parties agree that there are certain outstanding credit card debts incurred by the
parties during the marriage. The parties hereby acknowledge that they have divided the credit
card debt to their mutual satisfaction prior to the execution of this Agreement. The parties agree
that Wife has assumed and will pay in full all marital credit card debt incurred in her name alone
and shall indemnify and save Husband harmless from any and all claims or demands made
against her by reason of debts or obligations incurred by Wife. Wife hereby agrees to have
Husband's name removed from any and all credit cards which she is responsible for paying
within fifteen (15) days of execution of this Agreement.
The parties further agree that Husband has assumed and will pay in full all marital credit
card debt incurred in his name alone and shall indemnify and save Wife harmless from any and
all claims or demands made against him by reason of debts or obligations incurred by Husband.
Husband hereby agrees to have Wife's name removed from any and all credit cards which he is
responsible for paying within fifteen (15) days of execution of this Agreement.
b. POST SEPARATION DEBT: Except as otherwise herein provided, In
the event that either party contracted or incurred any debt since the date of separation, the party
owing said debt shall be responsible for the payment thereof regardless of the name in which the
debt may have been incurred and shall indemnify and save harmless the other party from any and
Page 9 of 19
all claims or demands made against him or her by reason of debts or obligations incurred by the
other party.
C. FUTURE DEBT: Except as otherwise herein provided, from the date of
the Agreement, neither party shall contract or incur any debt or liability for which the other party
or his or her property or estate might be responsible and shall indemnify and save harmless the
other party from any and all claims or demands made against him or her by reason of debts or
obligations incurred by the other party.
14. DIVISION OF BANK ACCOUNTS: Except as otherwise provided, the parties
acknowledge that any and all joint bank accounts have been closed or divided to their mutual.
satisfaction prior to the execution of this Agreement. Husband and Wife hereby waive all right,
title, claim or interest they may have by equitable distribution in their respective bank accounts,
checking or savings, if any, and each party waives against the other any duty of accounting for
disposition of any jointly held funds.
15. LIFE INSURANCE: To the extent that either of the parties have life insurance
policies, simultaneously with the execution of this Agreement, those policies shall become the sole
and separate property of the individual owning the policy. Nothing in this Agreement will prevent
either party from designating beneficiaries under or encumbering their respective life insurance
policies.
16. HEALTH INSURANCE: Each party shall be responsible for obtaining and
maintaining his or her own health insurance coverage and for his or her own unreimbursed
medical expenses. To the extent medical insurance coverage is affected by marital status, it shall
be the individual responsibility of Husband and Wife to immediately notify his or her employer
of the change in marital status.
Page 10 of 19
The parties hereby acknowledge that their son, Robert, is currently covered under
Husband's medical and dental insurance plan. Husband agrees to continue to maintain coverage
under his medical and dental plans for Robert, as long as it is available at a reasonable cost. Any
unreimbursed medical expenses incurred on behalf of Robert while he is covered under either
party's insurance shall be equally shared by the parties.
17. CUSTODY AND SUPPORT: The parties hereby acknowledge that they share
custody of their minor child, Robert, pursuant to the terms of a Custody Order dated September
21, 2006. The parties further acknowledge that there are certain day care expenses incurred on
behalf of their son, Robert and the parties hereby agree to equally share the day care expenses
incurred on behalf of Robert.
18. DEPENDENCY EXEMPTIONS: The parties agree that they shall alternate
claiming their child, Robert, on his or her annual federal income tax return until the dependency
exemption is no longer available for the child. Husband shall claim Robert in odd numbered tax
years and Wife shall claim Robert in even numbered tax years. Both Husband and Wife agree to
take all steps necessary and execute any and all documents to accomplish the intention of this
subparagraph.
19. WAIVER OF ALIMONY: Both parties acknowledge and agree that the
provisions of this Agreement providing for equitable distribution of marital property are fair,
adequate and satisfactory to them and are accepted by them in lieu of and in full and final
settlement and satisfaction of any claims or demands that either may now or hereafter have
against the other for support, maintenance or alimony. Husband and Wife further voluntarily and
intelligently waive and relinquish any right to seek from the other any payment for support or
alimony.
Page 11 of 19
20. ALIMONY PENDENTE LITE, COUNSEL FEES, AND EXPENSES:
Husband and Wife acknowledge and agree that the provisions of this Agreement providing for
the equitable distribution of marital property of the parties are fair, adequate and satisfactory to
them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full
and final settlement and satisfaction of all claims and demands that either may now or hereafter
have against the other for spousal support, alimony pendente lite, counsel fees or expenses or any
other provision for their support and maintenance before, during and after the commencement of
any proceedings for divorce or annulment between the parties.
21. INCOME TAX: The parties have heretofore filed certain joint income tax returns
and the parties represent and warrant that they have heretofore duly paid all income taxes due on
such returns; that they do not owe any interest or penalties with respect thereto; that no tax
deficiency is pending or threatened against the parties; and that no audit is pending with respect to
any such returns. Both parties agree that in the event any deficiency in federal, state or local
income tax is proposed, or any assessment of any such tax is made against either of them, each will
indemnify and hold harmless the other from and against any loss or liability for any such tax
deficiency or assessment and any interest, penalty and expense incurred in connection therewith.
Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is
finally determined to be the cause of the misrepresentations or failures to disclose the nature and
extent of his or her separate income on the aforesaid joint returns.
22. TAX MATTERS: The parties have negotiated this Agreement with the
understanding and intention to divide their mutual property. The parties have determined that
such division conforms to a right and just standard with regard to the rights of each party. The
division of existing marital property is not, except as may be otherwise expressly provided
Page 12 of 19
herein, intended by the parties to constitute in any way a sale or exchange of assets. It is
understood that the property transfers described in this Agreement fall within the provisions of
Section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any
gain or loss upon the transfer by the transferor.
23. BANKRUPTCY: The parties hereby agree that the provisions of this Agreement
shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations
contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a
discharge of any obligations assumed hereunder, the other party shall have the right to declare
this Agreement to be null and void and to terminate this Agreement in which event the division
of the parties' marital assets and all other rights determined by this Agreement, including
alimony, shall be subject to court determination the same as if this Agreement had never been
entered into.
24. COMPLETE DISCLOSURE: Each of the parties hereto acknowledges that he
or she is aware of his or her right to seek discovery, including but not limited to, written
interrogatories, motions for production of documents, the taking of oral depositions, the filing of
inventories, and all other means of discovery permitted under the Pennsylvania Divorce Code or
the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or
she is aware of his or her right to have the real and/or personal property, estate and assets,
earnings and income of the other assessed or evaluated by the Courts of this Commonwealth or
any.other Court of competent jurisdiction. The respective parties do hereby acknowledge,
recognize and accept that there has been full and fair disclosure to the other of his or her assets
and liabilities, and each party agrees that any right to further disclosure, valuation, enumeration
or statement hereof in this Agreement is hereby specifically waived, and the parties do not wish
Page 13 of 19
to make or append hereto any further enumeration or statement. The parties hereby acknowledge
and agree that the division of the marital assets as set forth in this Agreement are fair, reasonable
and equitable, and are satisfactory to them. Each of the parties hereto further covenants and
agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or
she will never at any time hereafter sue the other party or his or her heirs, executors,
administrators and assigns in any action of contention, direct or indirect, and allege therein that
there was a denial of any rights to full disclosure, or that there was any fraud, duress, undue
influence, or that there was a failure to have available full, proper and independent representation
by legal counsel.
Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable
distribution, pursuant to the Pennsylvania Divorce Code, of any interest owned by the other party
in an asset of any nature at any time prior to the date of execution of this Agreement that was not
disclosed to the other party or his or her counsel prior to the date of the within Agreement is
expressly reserved. In the event that either party, at any time hereafter, discovers such an
undisclosed asset, the party shall have the right to petition the Court of Common Pleas of
Cumberland County to make equitable distribution of said asset. The non-disclosing parry shall
be responsible for payment of counsel fees, costs or expenses incurred by the other party in
seeking equitable distribution of said asset.
25. DIVORCE: Wife has commenced an action for divorce from Husband pursuant
to Section 3301(c) of the Pennsylvania Divorce Code (irretrievable breakdown) by the filing of a
Complaint on August 9, 2006. Both parties shall, at the time of the execution of this Agreement,
furnish Wife's attorney with an Affidavit of Consent and Waiver of Notice evidencing that each
of them consents to the divorce.
Page 14 of 19
Each of the parties agree that this Agreement represents a complete and final agreement
as to their respective property rights which arose from the marital relation and therefore mutually
waive any and all rights they may have under Section 3501 (Equitable Distribution) of the
Pennsylvania Code, Act No. 1990-206.
This Agreement may be offered in evidence in the action for divorce and may be
incorporated by reference in the decree to be granted therein. Notwithstanding such
incorporation, this Agreement shall not be merged in the decree, but shall survive the same and
shall be binding and conclusive on the parties for all time.
26. RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that
each of them has read and understands his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no compulsion to do so but as a
voluntary act.
27. ADDITIONAL DOCUMENTS: Husband and Wife mutually agree to execute
such documents as may be necessary and expedient to carry out and fully implement the terms of
this Agreement.
28. RELEASE OF ALL CLAIMS: Subject to the provisions of this Agreement,
each party waives his or her right to alimony and any further distribution of property inasmuch as
the parties hereto agree that this Agreement provides for an equitable distribution of their marital
property in accordance with the Divorce Code of 1980. 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
and discharge the other of and from all causes of action, claims, rights or demands whatsoever
arising out of their marriage, except any or all cause or causes of action for divorce and except in
Page 15 of 19
any or all causes of action for breach of any provisions of this Agreement. Each party also
waives his or her right to request marital counseling pursuant to 23 Pa.C.S.A. Section 3302.
29. 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 continue in full force, effect and operation.
30. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and
agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a
separate and independent covenant and agreement.
31. GOVERNING LAW: All matters affecting the interpretation of this Agreement
and the rights of the Parties hereto shall be governed by the laws of the Commonwealth of
Pennsylvania.
32. BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred to enforce the
Agreement, including, but not limited to, court cost and 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.
33. ENTIRE UNDERSTANDING: This Agreement contains the entire
understanding of the parties and there are no representations, warranties, covenants or undertakings
other than those expressly set forth herein. 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 consideration by the parties. Both parties hereby
Page 16 of 19
accept the provisions of this Agreement with respect to the division of property in lieu of and in
full and final settlement and 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 pursuant to 23 Pa.C.S.A. Section 3501 et. sec. or any other laws. 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 contained shall constitute a
waiver by either parry of any rights to seek the relief of any court for the purpose of enforcing the
provisions of this Agreement.
34. AGREEMENT BINDING ON PARTIES AND HEIRS: It is understood and
agreed that not only the parties hereto, but also their heirs, administrators, executors and assigns,
shall be bound by all the terms, conditions and clauses of this Agreement.
35. WAIVER OR MODIFICATION TO BE IN WRITING: A modification or
waiver of any of the provisions of this Agreement shall be effective only if made in writing and
executed with the same formality as this Agreement. The failure of either party to insist upon
strict performance of any of the provisions of this Agreement shall not be construed as a waiver
of any subsequent default of the same or similar nature.
36. 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.
Page 17 of 19
37. HEADINGS NOT A 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.
38. CONSTRUCTION: No provision of this Agreement shall be interpreted for or
against any party because that parry or that parry's representative drafted this Agreement in whole
or in part.
IN WITNESS WHEREOF, the Parties have set their hands and seals to two counterparts
of this Agreement, each of which shall constitute an original, the day and year first above written.
Witness:
Page 18 of 19
COMMONWEALTH OF PENNSYLVANIA )
SS.
COUNTY OF DAUPHIN }
On this, the day of , 2008, before me, a notary public, the
undersigned officer, personally appeare nice Kohut, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and notarial seal.
coMM __j v% u.Tr+cW PVMsYLVMxA
NOTARIAL SEAL
PATRICIA A. PATTON, Notwy Public
Lower Paxson Twp., Da #m County U
1myCwnffftsiwExpkesjuw20,2010
COMMONWEALTH OF PENNSYLVANIA )
SS.
COUNTY OF'?EHi Cv??b4'? )
On this, the _ day of & , 2008, before me, a notary public, the
undersigned officer, personally appeared Robert W. Kohut, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and notarial seal.
WTAPAI$EL
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Page 19 of 19
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Sandra L. Meilton, Esquire
Quintina M. Laudermilch, Esquire
DALEY Z,UCKER MEILTON
MINER & GINGRICH, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
smeiltonAdzmmelaw.com
tlaudermilch(Uzmmglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JANICE KOHUT,
Plaintiff No. 2006-4590 (Civil Term)
V.
CIVIL ACTION - LAW
ROBERT W. KOHUT,
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:
1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: A true and correct certified copy of
the Divorce Complaint was served on Defendant on September 12, 2006. An Acceptance of
Service executed by the Defendant was filed on October 4, 2006.
3. As required by Section 3301(c) of the Divorce code, Plaintiff executed her
Affidavit of Consent on August 29, 2008 and Defendant executed his Affidavit of Consent on
September 6, 2008. The Affidavits are being filed contemporaneously herewith.
4. Related claims pending: None. The parties executed a Property Settlement
Agreement on September 6, 2008, a copy of which is being filed contemporaneously herewith.
5. As required by Section 3301(c) of the Divorce Code, Plaintiff executed her
Waiver of Notice of Intention to Request Entry of Divorce Decree on August 29, 2008 and
Defendant executed his Waiver of Notice of Intention to Request Entry of Divorce Decree on
September 6, 2008. The Waivers of Notice are being filed contemporaneously herewith.
Respectfully submitted,
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
Date: By:
S dra L. Meilton, Esquire
Supreme Court ID # 32551
Quintina M. Laudermilch, Esquire
Supreme Court ID# 94664
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Attorneys for Plaintiff
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IN THE COURT OF COMMON PLEAS
JANICE KOHUT
OF CUMBERLAND COUNTY
STATE OF PENNA.
No. 2006-4590 Civil Term
VERSUS
ROBERT W. KOHUT
DECREE IN
DIVORCE
AND NOW, Se ll ,-,L) - ooh , IT IS ORDERED AND
DECREED THAT
JANICE KOHUT
, PLAINTIFF,
AND ROBERT W. KOHUT DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None.
AND IT IS FURTHER ORDERED, that the terms, conditions and
covenants set forth in the written Marital Settlement Agreement
made and entered into by the parties on Septeriiber '6, 2008, are
incorporated into this Decree by reference thereto, but not merged
into this Decree.
BY THE COURT:
ATT i/ J.
PROTHONOTARY
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Sandra L.Meilton,Esquire Tr a�:W o TH 11b I-
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Daley Zucker Meilton&Miner,LLC l 1 3 APR 12
635 North 12"`Street,Suite 101 f',i ' ('
Lemoyne,PA 17043 CUNSER6ft E iJI�
(717)724-9821 PENNSYL LAMA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
JANICE KOHUT,
Plaintiff Docket No. 2006-4590(Civil Term)
V. CIVIL ACTION-LAW
ROBERT W.KOHUT, IN DIVORCE/CUSTODY
Defendant
ORDER
AND NOW, this day of r�'i 1 _ 413, upon consideration of
the Petition to Withdraw as Counsel, it is hereby ORDERED and DECREED that Sandra L.
Meilton, Esquire, and Daley Zucker Meilton & Miner, LLC, are granted leave to withdraw as
counsel of record for the Plaintiff,Janice Kohut,in the above-captioned matter.
BY THE COURT:
J.
DISTRIBUTION:
Sandra L.Meilton,Esquire,635 North I Street,Suite 101,Lemoyne,PA 17043 (Petitioner)
Ms.Janice M. Kunkle,4000 Independence Court,Mechanicsburg,PA 17050(Plaintif,j')
Mr. Robert W. Kohut, 1363 Kiner Boulevard,Carlisle,PA 17013 (Defendant)
�'BprPS ma Jew 414;z�/
Art.
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Sandra L. Meilton, Esquire FILED-OF FICE
Daley Zucker Meilton & Miner, LLC OF fHE PRO HCNOTAR`i,
635 North 12t1i Street, Suite 101
Lemoyne, PA 17043 2Q13 APP 18 AM F1: 08
(717)724-9821
smeilton @dzmmglaw.com Ct1MBERLANDVVppCOUNTY
IN THE COURT OF COOlik lI'LEI OF
CUMBERLAND COUNTY, PENNSYLVANIA
•
JANICE KOHUT,
Plaintiff : Docket No. 2006-4590 (Civil Term)
•
v. • CIVIL ACTION-LAW
ROBERT W. KOHUT, • IN DIVORCE!CUSTODY
•
Defendant
PRAECIPE
TO THE PROTHONOTARY:
Pursuant to the Order entered by the Honorable Albert H. Masland on April 12, 2013,
granting leave for Sandra L. Meilton, Esquire, and Daley Zucker Meilton & Miner. LLC, to
withdraw as counsel of record for the Plaintiff, Janice Kohut, kindly withdraw the appearance of
Sandra L. Meilton, Esquire, and Daley Zucker Meilton & Miner, LLC, as counsel of record for
Plaintiff, Janice Kohut, in the above-captioned matter.
DALEY ZUCKER MEILTON & MINER, LLC
BY: 1
andra L. Meilton, Es.uire
Attorney I.D. #32551
635 North 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
CERTIFICATE OF SERVICE r
AND NOW, this if I day of f 2013, I, Gloria M. Rine,
Paralegal for Daley Zucker Meilton&Miner, LLC, hereby certify that I have this day served a copy
of the within document,by mailing same by first class mail,postage prepaid, addressed as follows:
Ms. Janice M. Kunkle
4000 Independence Court
Mechanicsburg, PA 17050
Mr. Robert W. Kohut
1363 Kiner Boulevard
Carlisle, PA 17013
Gloria M. Rine