HomeMy WebLinkAbout06-5961
MEGHAN A. REHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. :No. OG
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant IN DIVORCE
NOTICE
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:
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA 17013-3387
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
MEGHAN A. REHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. oL 5 ca i ('j'-Z-t''
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant IN DIVORCE
DIVORCE COMPLAINT
1. Plaintiff is Meghan Rehman, who currently resides at 491 North Nursery Drive,
Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Michael G. Rehman, who currently resides at 491 North Nursery
Drive, Mechanicsburg, Cumberland County, Pennsylvania.
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 Defendant were married on September 17, 2005 in Cumberland
County, Pennsylvania.
5. There have been no prior actions for divorce or for annulment between the parties.
6. Defendant is not a member of the Armed Forces of the United States of America
or any of its allies.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a decree
dissolving the marriage between the Plaintiff and Defendant.
Date:
Respectfully submitted,
NESTICO, DRUBYI HILDABRAND, L.L.P.
By:
Richard B. Druby, Es uire
Attorney I.D. No. 61904
840 East Chocolate Avenue
Hershey, Pennsylvania 17033
(717) 533-5406
(717) 533-5717
Attorney for Plaintiff
10/03/06 TUE 15:20 FAX 17174580047 CRABTREE-tOHRBAUGH
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn
falsification to authorities.
Date: 101 3 Job
lVleghan
RI 001
W - Y
V
MEGHAN A. REHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 06-5961
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed
on October 11, 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.
Vhann!A.Rehman, Date:
Plaintiff
CZP
f CJ
MEGHAN A. REHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 06-5961
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with
the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. '
4904 relating to unsworn falsification to authorities.
i
Date: ? Do
Me ehman, Plaintiff
? L7
rt
" ? rs.;?_
_ ,? _
?? ?', cW
-?
-
?a =_
?+
__ . • xy
??; r?
??
MEGHAN A. REHMAN. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 06-5961
MICHAEL G. REHMAN, CIVIL ACTION- LAVA'
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed
on October 11, 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 unworn falsification to authorities.
Date: 51-0-7
Michael G. Rehman, Defendant
,
IF
<jl
MEGHAN A. REHMAN,
Plaintiff
V.
MICHAEL G. REHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-5961
CIVIL ACTION- LAW
INDIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that 1 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:
'
?'{
"C f"F
i
?
C'x
;
?? 1. s;`}..
'"?
?" _?? ?
?
. ?i
rJ,l
MEGHAN A. REHMAN,
Plaintiff
V.
MICHAEL G. REHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-5961
CIVIL ACTION- LAW
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT FOR DIVORCE
I, Richard B. Druby, Esquire, counsel for Plaintiff, hereby certify that on October
16, 2006, I served on the defendant, Michael G. Rehman, a copy of the Complaint for
Divorce via certified mail, return receipt requested. The cover letter for said service is
attached hereto as Exhibit A.
The postal authorities never returned the green return receipt. However, the
"Track and Confirm" service of the United States Postal Service indicates that the same
was delivered on October 24, 2006. A copy of the "Track and Confirm" receipt is
attached hereto as Exhibit B. Additionally, Mr. Rehman has executed an Affidavit of
Acceptance of Service indicating that he did accept service of the Complaint on October
24, 2006. Mr. Rehman's Affidavit is attached hereto as Exhibit C.
Respectfully submitted,
Date: 51-11-0
By:
Richard B. Druby
Attorney I.D. No. 19
840 East Chocolate Avenue
Hershey, Pennsylvania 17033
Tel: (717) 533-5406
Fax: (717) 533-5717
Attorney for Plaintiff
LLP
G'xb?6;t fl
HNDH NESTICO, DRUBY & IIILDABRUH LLP
ATTORNEYS AT LAW 840 Eut Chocolate Avenue, Hershey. PA 17033
Phone (717) 533-5406 Fax (717) 333-3717
www.hersheypalaw.com
October 18, 2006
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED, RESTRICTED DELIVERY
Michael Rehman
4 Lonk Lane
Mechanicsburg, PA 17058
Re: Meghan Rehman v. Michael Rehman
Cumberland County C.P. No. 06-5961
Dear Mr. Rehman:
You are hereby served with the Divorce Complaint in the above matter.
I am also enclosing a copy of the fully executed Marriage Settlement Agreement.
Very truly yours,
NESTICO, DRU, 3VA HILBABRAND, LLP
By:
Richard B.
RBD/akd
Enclosures
cc: Meghan Rehman (w/enc.)
?x?t??? ?
USPS - Track & Confirm
UNITEOSTATES
>` POSTAL SERVICE*
Page 1 of 1
Horne I Help I Slgn In
I ck 8 Conflrm FAQs
Tra
Track & Confirm
Search Results
Label/Receipt Number: 7006 0100 0004 3080 6984
Status: Delivered
Your item was delivered at 10:45 am on October 24, 2006 in HERSHEY,
PA 17033. A proof of delivery record may be available through your local
Post Office for a fee.
Additional information for this item Is stored in files offline.
Resrwe offline Oetsilis >Rti ( Return to USPS.com Nome a '!
L. .................................................................................... ......J w...,..,........... .............. ._....................... ......... ....................................... F
Track & Confirm
Enter Label/Receipt Number.
( Gor)
POSTAL INSPECTORS site map contact us govemment services jobs National & Premier Accounts
Preserving the Trust Copyright ®1999-2004 USPS. All Rights Reserved. Tema of Use Privacy Policy F
1 ittv://trkcnfrmI.smi.ust)s.com/PTSTntemetWeh/IntPrT.ahi-]Tnn„irt, A,. 1% ,+
6X4,bl t ?
MEGHAN A. REHMAN,
Plaintiff
V.
MICHAEL G. REHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-5961
CIVIL ACTION- LAW
IN DIVORCE
AFFIDAVIT OF ACCEPTANCE OF SERVICE
I, Michael G. Rehman, hereby certify that I accepted service Divorce Complaint on
October 24, 2006. Said Complaint was served on me by Certified Mail, Return Receipt
Requested.
Dated:
Michael G. Rehman,
CERTIFICATE OF SERVICE
I, Richard B. Druby, Esquire, of the law firm of Nestico, Druby & Hildabrand,
LLP, hereby certify that on the Aday of May 2007, a copy of the foregoing document
was sent via First Class U.S. Mail, postage paid, to the following:
Michael Rehman
120 Stonebridge Drive
Dillsburg, PA 17019
u l
}
7"
r i'({
MEGHAN A. REHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 06-5961
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant IN DIVORCE
PRA ECIPE TO TRANSMI T RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of
divorce decree:
1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Certified mail, return receipt
requested, delivered on October 24, 2006. See Affidavit of Service previously
filed.
3. Date of execution of the Affidavit of Consent required by 43301(c) of the
Divorce Code: By Plaintiff. April 18, 2007 filed on May 15, 2007; by
Defendant: May 9, 2007 filed on May 15, 2007.
4. Related claims pending: None. All claims resolved pursuant to the original
Marriage Settlement Agreement dated October 13, 2006, attached hereto as
Exhibit A, which will be incorporated, but not merged, into the Divorce Decree.
5. (a) Date and manner of service of the notice of intention to file praecipe a
copy of which is attached: May 11, 2007 by First Class U.S. Mail,
postage paid. See Exhibit B.
(b) Date Plaintiffs and Defendant's Waiver of Notice in 43301(c) Divorce
was filed with the Prothonotary: May 15, 2007
Respectfully submitted,
Date: 1.161
NESTIC". 13UR,Y &
By:
Richard B. Drub , Es irp/
Attorney I.D. No. 04
840 East Chocolate Avenue
Hershey, Pennsylvania 17033
(717) 533-5406
Attorney for Plaintiff
L.L.P.
All
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, by and between MICHAEL G. REHMAN (hereinafter "Husband")
and MEGHAN A. REHMAN(hereinafter "Wife"),
WHEREAS, the parties are Husband and Wife, married on September 17, 2005; and
WHEREAS, no children were born of the marriage; and
WHEREAS, unhappy differences and difficulties have arisen between the parties, in
consequence of which the parties intend to live separate and apart for the rest of their natural
lives; and
WHEREAS, the parties desire to settle fully and finally their respective financial and
property rights and obligations as between each other, including but not limited to the ownership
and equitable distribution of real and personal property; past, present and future support, alimony
and/or maintenance; and any and all claims which either party has, or may have, against the other
or the other's estate;
NOW, THEREFORE, in consideration of the mutual promises, covenants and
undertakings hereinafter set forth and for other good and valuable consideration, receipt of which
the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant
and agree as follows:
I. SEPARATION
Each party shall have the right to live separate and apart from the other party, free from the
other party's interference, authority and control. Neither party shall interfere with the other or
attempt to interfere with the other, nor compel the other party's cohabitation.
2. SUBSEQUENT DIVORCE
The parties acknowledge that Wife has filed a Complaint in Divorce in Cumberland
County, Pennsylvania to Docket No. 06-5961, claiming that the marriage is irretrievably
broken under the no-fault mutual consent provisions of Section 3301(c) of the Pennsylvania
Divorce Code. Husband hereby expresses 4agreement that the marriage is irretrievably
broken and expresses his intent to execute, contemporaneously with executing this Agreement,
any and all affidavits or other documents necessary for the parties to obtain an absolute
divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights
to request court-ordered marriage counseling under the Divorce Code.
3. HUSBAND'S AND WIFE'S DEBTS
Except as otherwise set forth in this Agreement, the parties represent and warrant to each
other that they have not incurred and will not contract or incur any debt or liability for which the
other or the other's estate might be responsible. Each party shall indemnify and save harmless the
other party from any and all claims or demands made against the other by reason of debts or
obligations incurred by that party.
4. WAIVER OF RIGHTS AND MUTUAL RELEASES
Except as provided in this Agreement, both parties absolutely and unconditionally release
and forever discharge each other and their 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, whether such claims exist now or arise in the future. This release shall be
effective regardless of whether such claims arise out of former or future acts, contracts,
engagements or liabilities of the parties or by way of dower, curtesy, widow's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
/ A4 ?k
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 other country.
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, each party gives to the
other 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 arising out of the marriage.
5. FULL DISCLOSURE
The parties do hereby warrant, represent, declare and agree that each has relied on the
substantial accuracy of the financial disclosure of the other, as an inducement to the
execution of this agreement and each party acknowledges that there has been a full and fair
disclosure of the parties' assets and liabilities which has been provided to each party and any
further enumeration or statement thereof in this Agreement is specifically waived.
6. REAL ESTATE
The parties prior to the marriage owned jointly improved real property situated at 491
North Nursery Drive, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter "Marital
Residence"). The Marital Residence is encumbered by a mortgage owed to Countrywide (Account
No. 108438624) having an approximate balance of $193,300.00.
Husband hereby agrees to transfer all of his right, title and interest in the property to Wife
by fee simple absolute deed contemporaneously with the signing of this Agreement. Husband
agrees to assign to Wife any and all interest which he has had or may have in any insurance
Au"t ut
policies covering the real estate, or in the proceeds from such policies, or in any prepaid real estate
taxes.
Wife retains the exclusive right to use all related mortgage interest and real estate taxes for
deductions on his income tax returns for tax year 2006 and beyond. Husband hereby waives any
right or interest in the mortgage interest and real estate tax deductions for the Marital Residence.
In exchange for the above, Husband agrees to accept the sum of Twenty Three Thousand
($23,000.00) Dollars, payable on October 15, 2006 when Husband vacates the Marital Residence
or when Husband executes the deed, whichever is later, as the value of, and in full and final
satisfaction of, his equitable interest in the Marital Residence. Accordingly, Husband hereby
waives any further right, title and interest he may have in the Marital Residence.
Wife agrees to use her best efforts to have Husband removed from the obligation of the
mortgage and note as soon as possible.
7. DIVISION OF PERSONAL PROPERTY
(a) All items listed on Exhibit A attached hereto are to be the sole and separate
property of Husband. Husband shall remove the personal property items from the Marital
Residence by October 15, 2006 and the RBR & Sons business property by October 29, 2006 or
the property shall become the sole and separate property of Wife.
(b) All other items of personal property, including the dog, Murphy, that are contained
in the Marital Residence shall become the sole and separate property of Wife upon execution of
this Agreement.
8. MOTOR VEHICLES
(a) Wife shall retain sole and exclusive possession and/or ownership of the 2003
Ford Explorer that is her premarital asset. Husband hereby waives any and all right, title or
9 1V1?/?
interest he may have in that vehicle. Wife shall be individually responsible for the payment of any
further encumbrances and automobile liability insurance on the vehicle which she will retain.
(b) Husband shall retain sole and exclusive possession and/or ownership of the 2003
Chevrolet Avalanche that is his premarital asset. Wife hereby waives any and all right, title or
interest she may have in that vehicle. Husband shall be individually responsible for the payment of
any encumbrances and automobile liability insurance on the vehicles which he will retain.
(c) Both parties agree to execute, within thirty (30) days of the date of this
Agreement, or as soon as practicable thereafter, any and all forms, titles and documents necessary
to transfer the aforesaid vehicle from joint ownership to individual ownership, as specified herein
and to transfer the loan obligations and encumbrances from joint obligations to individual
obligations as specified herein.
9. RETIREMENT/PENSION/PROFIT SHARING/401 k BENEFITS/SAVINGS STOCK
INVESTMENT AND OWNERSHIP PLANS
The parties acknowledge that Husband owns or is a participant in retirement plans.
Husband owns or participates in the following plans:
Robert B. Rehman & Sons Pension Trust Fund, with an approximate value of
$16,000.00.
The parties acknowledge that Wife owns or is a participant in retirement plans. Wife
owns or participates in the following plans:
401(k) through Crabtree, Rohrbaugh & Associates, with an approximate value of
$3,000.00.
The parties agree that the parties shall retain as their sole and separate property the retirement
plans in whose name the plan or fund is held. The parties hereby waive and relinquish any and all
/ MK
rights they may now have or hereafter acquire, under the present or future laws of any jurisdiction
to share in the proceeds of the other's retirement/pension and/or profit sharing benefits.
10. DIVISION OF BANK ACCOUNTS
Husband and Wife acknowledge that, during their marriage they maintained the following
accounts:
(a) Joint checking (Account No. 5000687976) and savings accounts at PNC Bank;
(b) A checking account in Husband's name at PNC Bank;
(c) An account at Member's First Federal Credit Union (Account No. 219419) in
Wife's name.
The parties agree that all joint bank accounts have been closed and divided to their mutual
satisfaction prior to the execution of this Agreement. The parties further agree that the
PNC account in Husband's name alone will be the sole and separate property of Husband and
Wife hereby waives any right, title and interest in that account. The parties further agree that the
Member's First Account in Wife's name alone will be the sole and separate property of Wife and
Husband hereby waives any right, title and interest in that account.
IL HORSES
The parties acknowledge that Wife owns and/or maintains two (2) horses. The first horse,
Louis, is owned by Wife's parents and is not part of the marital estate. The other horse, Joey,
shall be the sole and separate property of Wife and Husband waives any right, title and interest in
the horses.
12. JOINT DEBTS
The parties acknowledge that they have no debts which are jointly incurred during their
marriage other than as set forth in this Agreement. Any debts or obligations incurred by either
party in his/her individual name, other than those specified herein, whether incurred before or
after separation, are the sole responsibility of the party in whose name the debt or obligation was
incurred.
13. AFTER-ACQUIRED PROPERTY
Each of the parties shall own and enjoy, independently of any claim or right of the other,
all real property and all items of personal property, tangible or intangible, hereafter acquired, with
full power to dispose of the same as fully and effectively as though he or she were unmarried. Any
property so acquired shall be owned solely by that party and the other party shall have no claim to
that property.
14. LIFE INSURANCE
The parties hereby waive and relinquish any right or interest, of whatever nature,
including claims to the cash value of any life insurance policies which either may have against the
other.
15. WAIVER OF SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE
Husband and Wife hereby waive and release any and all right, title, interest, claims or
demand of whatsoever nature which he or she now has or hereafter can, shall or may have against
the other or the respective separate property of the other under the laws of the Commonwealth of
Pennsylvania or any other governing state, country, territory or jurisdiction in the nature of
spousal support, separate maintenance or support, alimony, either pendente lite, temporary,
? -??/ 'loll
rehabilitative, permanent or lump sum and right to seek equitable or community distribution or
division or assignment of property or similar marital right.
16. COUNSEL FEES
Each party shall be responsible for the payment of his or her own counsel fees, except as
otherwise specified herein.
17. TAX MATTERS
The parties have negotiated this Agreement with the understanding and intention to
equally divide their marital property. The parties have determined that such equal 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 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.
Further, as stated in Paragraph 6 above, Wife shall retain exclusive right to use all related
mortgage interest and real estate taxes for deductions on his income tax returns for tax year 2006
and beyond. Husband hereby waives any right or interest in the mortgage interest and real estate
tax deductions for the Marital Residence.
18. ADVICE OF COUNSEL
The parties acknowledge that each has received or has had the opportunity to receive
independent legal advice from counsel of their selection and that they have been informed fully 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.
.-AQ /. 8k?
Each party confirms that he/she understands fully the terms, conditions, and provisions of
this Agreement and believes them to be fair, just, adequate and reasonable under the existing
circumstances. The parties further confirm that each is entering into this Agreement freely and
voluntarily and that the execution of this Agreement is not the result of any duress, undue
influence, collusion, or improper or illegal agreement.
19. EFFECT OF DIVORCE DECREE ON AGREEMENT
The parties agree that this Agreement shall continue in full force and effect after such time
as a final Decree in Divorce may be entered with respect to the parties. Upon entry of the Decree,
the provisions of this Agreement may be incorporated by reference or in substance, but they shall
not be deemed merged into such Decree. The Agreement shall survive any such Decree in
Divorce, shall be independent thereof, and the parties intend that all obligations contained in this
Agreement shall retain their contractual nature in any enforcement proceedings, whether
enforcement is sought in an action on the contract itself at law or in equity, or in any enforcement
action filed to the divorce caption as provided in Section 3105(a) of the Divorce Code, as
amended. However, 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.
20. DATE OF EXECUTION
The "date of execution", "date of this agreement" or "execution date" of this Agreement is
the date upon which it is signed by the parties if they sign the Agreement on the same date.
Otherwise, the "date of execution", "date of this agreement" or "execution date" shall be the date
on which the last party signed this Agreement.
21. HEADINGS NOT PART OF AGREEMENT
The descriptive headings preceding the paragraphs are for convenience and shall not affect
the meaning, construction or effect of this Agreement.
22. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS
Each separate obligation 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.
23. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding on and shall ensure to the benefit of the parties and their
respective heirs, executors, administrators, successors, and assigns.
24. 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, warranties,
covenants or promises other than those expressly set forth in this Agreement.
25. MODIFICATION OR WAIVER TO BE IN WRITING
No modification or waiver of any term of this Agreement shall be valid unless in writing
and signed by both parties.
26. NO WAIVER OF DEFAULT
The failure of either party to insist upon strict performance of any term of this Agreement
shall not constitute a waiver by that party to demand strict performance in the future .
10
? ? ?Vl
27. VOLUNTARY EXECUTION
The parties acknowledge that this Agreement is fair and equitable, and that they have
reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or
improper or illegal agreements.
28. APPLICABLE LAW
This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania
and more specifically under the Divorce Code of 1980, as amended.
29. ATTORNEYS' FEES FOR ENFORCEMENT
If either party breaches any provision of this Agreement, the breaching party shall pay all
reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that
the enforcing party is successful in establishing that a breach has occurred.
30. INDEMNIFICATION
Each party represents and warrants to the other that he or she had not incurred any
debt, obligation, or other liability, other than described in this Agreement, on which the other
party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding
is hereinafter initiated seeking to hold the other party liable for any other debts, obligations,
liability, act or omission of such party, such party will at his or her sole expense, defend the other
against any such claim or demand, whether or not well-founded, and that he or she will indemnify
and hold harmless the other party in respect of all damages as resulting therefrom. Damages as
used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other
damage, including without limitation, counsel fees and other costs and expenses reasonably
incurred in investigating or attempting to avoid same or in opposing the imposition thereof or
enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made
11 =J? / W
by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the
warranties made by Husband or Wife in this Agreement, or breach or default in performance by
Husband or Wife of any of the obligations to be performed by such party hereunder. The
Husband or Wife agrees to give the other prompt written notice of any litigation threatened or
instituted against either party which might constitute the basis for a claim for indemnity pursuant
to the terms of this Agreement.
IN WITNESS WHEREOF, the parties have set their hands and seals;
12 /
MEGHAN A. REHMAN
WITNESS:
EXHIBIT A
Property to be Retained by Husband
1. Restoration Hardware patio furniture, including the chairs, cushions, table,
umbrella and base;
2. Grill, grill cover and accessories;
3. Set of orange towels;
4. Cuisinart toaster oven;
5. Powder Room toiletries (trashcan, toothbrush holder, soap dish, soap dispenser (2)
and tissue holder);
6. King size comforter;
7. All property in the basement except the Christmas and other holiday decorations
and the refrigerator;
8. All business property of RBR & Sons, Inc. located in the basement;
9. Black Samsonite luggage;
10. Restoration Hardware drinking glasses.
13 /
COMMONWEALTH OF PENNSYLVANIA:
SS
?u
COUNTY OF
On this, the 3 4 day of a-I o bek--- 2006, before me a Notary Public in and for
said County and State the undersigned officer, personally appeared MEGHAN A. REHMAN,
known to me (or satisfactorily proven) to be the person whose name is described to the within
instrument, and acknowledged that they executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
My Commission Expires
otary Public
t4OTARM SFAL
Deborah K. Miscevich, Notary Public
Derry Twp., Dauphin County
My commission expires November 23, 2006
14 / 11, ,
COMMONWEALTH OF PENNSYLVANIA:
: SS
COUNTY OF
On this, the day of'-1ohe?C, 2006, before me a Notary Public in and for
said County and State the undersigned officer, personally appeared MICHAEL G. REHMAN,
known to me (or satisfactorily proven) to be the person whose name is described to the within
instrument, and acknowledged that they executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
My Commission Expires ,
Y
otary Publi
NOTARIAL SEAL
Deborah K. Miscevich, Notary Public
Derry Twp., Dauphin County
My commission expires November 23, 2006
15 lm/ /MM4,z
6
X
NDH nmo flfflct OKUBY & KBIBRO LLP
ATTORNEYS AT LAW 840 East Chocolate Avenue, Hershey, PA 17033
Phone (717) 533-5406 Fax (717) 533-5717
www.hernheypalaw.com
May 11, 2007
Michael Rehman
120 Stonebridge Drive
Dillsburg, PA 17019
Re: Meghan Rehman v. Michael Rehman
Cumberland County C.P. No. 06-5961
Dear Mr. Rehman:
Enclosed is a Notice of Intention to Request Entry of a Divorce Decree and a Counter-
Affidavit. Because you are un-represented by counsel, I am required to give you this Notice.
cannot provide any legal advice to you. Therefore, read the documents carefully and act
accordingly.
If you take no action whatsoever, l will file a Praecipe to Transmit the Record and ask the
Court to enter a Divorce Decree and incorporate, but not merge, the prior Property Settlement
Agreement into the Divorce Decree.
If you do have any questions, please give me a call and I will answer them to the extent
that I ethically can.
Very truly yours,
NESTICO B & ILDABRAND, LLP
By:?-?
Richard B ruby
RBD/akd
Enclosures
cc: Meghan Rehman (w/enc.)
MEGHAN A. REHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 06-5961
MICHAEL G. REHMAN, : CIVIL ACTION- LAW
Defendant : IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY OF -43301(c)
DIVORCE DECREE
TO: Michael Rehman
120 Stonebridge Drive
Dillsburg, PA 17019
You have signed a §3301(c) affidavit consenting to the entry of a divorce decree.
Therefore, the other party can request the court to enter a final decree in divorce on or after
June 1, 2007.
Unless you have already filed with the court a written claim for economic relief, you
must do so by the date in the paragraph above, or the court may grant the divorce and you will
lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone
does not protect your economic claims.
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 RFI..OW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEBANON COUNTY LEGAL SERVICES
118 NORTH EIGHTH STREET
LEBANON, PA 17046
(717) 274-2834
MEGHAN A. REHMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 06-5961
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant : IN DIVORCE
COUNTER-AFFIDAVIT UNDER 43301(c) OF THE DIVORCE CODE
I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I understand that I must file my economic claims with the Prothonotary in writing and
serve them on the other party. If I fail to do so before the date set forth on the Notice of
Intention to Request Divorce Decree, the divorce decree may be entered without further notice to
me, and I shall be unable thereafter to file any economic claims.
I verify that the statements made in this counter-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:
Michael G. Rehman, Defendant
NOTICE: IF YOU DO NOT WISH TO CLAIM ECONOMIC RELIEF, YOU SHOULD NOT
FILE THIS COUNTER-AFFIDAVIT.
r? ?
f i ?.. ?
? -rt
L
f
? ??
?
?
:
??
v4 ? t_,
?i (rvZ
_
f
??
?
?
.
,
?'C
l
?' ? Y
`'.;1
. ?
Y y? ?-.Yq ?
ss
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Meghan A. Rehman „
VERSUS
Michael G. Rehman
No. 06-5961
DECREE IN
DIVORCE
AND NOW, Z007 , IT IS ORDERED AND
DECREED THAT Meghan A. Rehman , PLAINTIFF,
AND
Michael G. Rehman 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;
BY THE C RT:
U
.?
ATTEST. J
PROTHONOTARY
f- emu,
.
, O. (2- I
Lo °?/
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Meghan A. Rehman
NO. 06-5961
VERSUS
AMENDED DECREE IN
DIVORCE
AND NOW, Quyw !3 2007 IT IS ORDERED AND
DECREED THAT Meghan A. Rehman , PLAINTIFF,
AND Michael G. Rehman 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;
Marriage Settlement AgreemQnt- f»11y exacjjted h- aet per 13
2006, previously filed with the Court, is incorporated,
but not merged, into this decree
E
A
4V
r„
MEGHAN A. REHMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 06-5961
MICHAEL G. REHMAN, CIVIL ACTION- LAW
Defendant IN DIVORCE
NOTICE OF ELECTION TO RESUME PRIOR NAME
Notice is hereby given that, a final decree in divorce having granted on the
11*
day of June 2007, Plaintiff Meghan A. Rehman hereby elects to resume her prior
name of Meghan A. Rohrbaugh, and gives this written notice of her intention in
accordance with the provisions of 54 Pa. C.S. §704.
i
Meghan Rehman
To be known as
42A. 0"
Meghan A. Rohrbaugh
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On the `7 day of June 2007, before me, a Notary Public, personally appeared
Meghan A. Rohrbaugh known to me to be the person whose name is subscribed to the
within document and acknowledged that she executed the foregoing for the purpose
therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
c
Notary Public
OOIVlb10NWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Deborah K. Miswvich, Notary Public
Decry Township, Dauphin canny
M a mminka ex im December 07,20 10
IZh
n
0
d
F
A
tf