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HomeMy WebLinkAbout06-6306 S. ELIZABETH WRIGHT, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. Ck. - 10.306 C, 'ul'L~h'] KENNETH E. WRIGHT, Defendant : CML 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 foIIowing pages, you must take action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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 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, Cumberland County Courthouse, One Courthouse Square, 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. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 Telephone (800) 990-9108 I · S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud. se Ie avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por las Corte. una decision puede tambien ser emitida en su contra por caulquier otra queja 0 compensacion eclamados por eI demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando Ia base para eI divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede soIicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County, One Courthouse Square, Carlisle, P A 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMTIDO, USTED PUEDE PE,RDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle; PA 17013 Telefono (800) 990-9108 S. ELIZABETH WRIGHT, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. LX- - t..Jof.. e~:L '7~1 : CIVIL ACTION - LAW : IN DIVORCE KENNETH E. WRIGHT, Defendant COMPLAINT IN DIVORCE AND NOW, comes Plaintiff, S. Elizabeth Wright, by and through his counsel, Linda A. Clotfelter, who files this Complaint in Divorce and in support thereof states the following: 1. Plaintiff is S. Elizabeth Wright, (hereinafter "Plaintiff') an adult individual who resides at 31 Circle Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Kenneth E. Wright, (hereinafter "Defendant"), an adult individual who resides at 2101 Cedar Run Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Divorce Complaint. 4. Plaintiff and Defendant were married on April 10, 1993, In York County, Pennsylvania. 5. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since August 27, 2006. 6. There have been no prior actions of divorce or for annulment between the parties and there are no pending divorce proceedings upon the filing date of this Complaint. 7. Plaintiff avers that the marriage is irretrievably broken. 8. Plaintiff requests that the court to enter a decree of divorce. 9. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff, S. Elizabeth Wright, respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this Court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Date: I 0 I-~O I 0 (., y: L' da A. Clotfelter, Esquire A orney ill No. 72963 21 East Trindle Road, Suite 100 Mechanicsburg, P A 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, S. ELIZABETH WRIGHT, verify that the statements in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. 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: I (jiB 0 ! 0 h J't~ ,Jf4 /S.EIi~tiff ~ 1t (J ~ \, ~ ~ ~ ~ ~ 0' ~ """ ~ . ~ -u ~ ~ ~ o ,..." egO 7 Cr" -n g ~ ~ ~.G~ ~ ~::J ~f: '- ...;~) ~~ -.:..,:) _ t5 f11 .. ::--1 W ~ CO -< t "l., S. ELIZABETH WRIGHT, Plaintiff, VS. KENNETH E. WRIGHT, Defendant ',1, : IN THE COURT OF COMMON PLEAS OF . : CUMBERlAND COUNTY, PENNSYLVANIA : NO. 06-6306 CIVIL : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, KENNETH E. WRIGHT, Defendant in the above-captioned matter, hereby accept service of the Complaint in Divorce on this date. Date: 11 / "7 / 0 & I . k~f~ KENNETH E. WRIGH efendant P.O. Box 1575 Camp Hill, PA 17001 \. '>~ S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-6306 CIVIL KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 9th day of November, 2006, the undersigned hereby certifies that a true and correct copy of the foregoing ACCEPTANCE OF SERVICE was served upon the opposing party by United States First Class Mail, postage prepaid: Kenneth E. Wright P.O. Box 1575 Camp Hill, PA 17001 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Sf. - c.n -::: C:-:' .., ,. - .~ S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF . : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-6306 CIVIL KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, KENNETH E. WRIGHT, Defendant in the above-captioned matter, hereby accept service of the Complaint in Divorce on this date. Date: 11 / '7 / 0 C I . kh/",-4 7~r KENNETH E. WRIGH efendant P.O. Box 1575 Camp Hill, P A 17001 '. ? -- S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 06-6306 CIVIL KENNETH E. WRIGHT, Defendant : CML ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 9th day of November, 2006, the undersigned hereby certifies that a true and correct copy of the foregoing ACCEPTANCE OF SERVICE was served upon the opposing party by United States First Class Mail, postage prepaid: Kenneth E. Wright P.O. Box 1575 Camp Hill, P A 17001 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER 1-';' ~ff~ ~:l /I; Q, -.. .-1 :c---=.\ r.-'\\~~ \..;/ -- u" - 0~' <-.n ~;J tl S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 06-6306 KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 30, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if! do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 3/7,/07 4Y~ 'Ji;d ~~ S. EL ZAB~ WRIGHT, Plain' r--:> = = ....... -- _Xc;'" ""',':;-J s:o I I",Q o -n ~,-u nr-- :~~~1 :: -'j., .~!- -,;-, ;:~ ~~~ ~:~ 5; :..<: -0 -','- ......:;::.;. co " S. ELIZABETH WRIGHT, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-6306 KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (Cl 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. Date: 3/7/07 r-.:> = ,= ~ o II -:l :::1-" fllp 'ulQ -i) C;, ;;~:; ~~? ';~--~p 'h-, ~.~ C{l S ~ ~ ~ ....,...i.. "';::.-;t1 ::':1 I ...0 -v -,,... ~ co o I S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-6306 KENNETHE. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 30, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ?/ t /7- C) 0'1 , t{y~v6j 7 ,L~ Kenneth E. Wright, Defenda6t ~ :3 ~ -- ~ \ u.J "'"0 :5~ o -'tl :?:--o f"i'1 ?-: -Q r:: < "t -;'J1 Sv:i, ~, ....,., (t;~ .-,...'\ '?Q :....::. - .. - co () I S. ELIZABETH WRIGHT, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-6306 KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : 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. ~ Q);.,jiY . Date: ? / f /';; 0 {17 Kenneth E. Wright, Defendant Q ~~ 'Cf, ,::;:> ;-> -::Jf{,. ?::.'ift ....0 \ ..0 q. .-\ ~-l\ f'f\f'" ~~() t:0, ~"~.\[) ':,) :.\\ :J;f~ ,Jf6 :-<.:. -0 ~.; - -- ct) MARITAL SETTLEMENT AGREEMENT ff-.. THIS AGREEMENT, made this ~ day of ' /J1 U // C h , 2007, between S. ELIZABETH WRIGHT, (hereinafter referred to as Wife), and KENNETH E. WRIGHT, (hereinafter referred to as Husband). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 10, 1993, and they were separated within the meaning of the Pennsylvania Divorce Code as of August 27, 2006; and WHEREAS, there were no children born of this marriage; and WHEREAS, disputes and difficulties have arisen between the parties, and it is the present intention of Husband and Wife to live separate and apart, and the parties hereto are desirous of settling 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 Husband by Wife; the settling of all matters between them relating to the equitable division of marital property; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates; and WHEREAS, Husband and Wife declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of his or her selection; that Wife is being represented in this proceeding by Linda A. Clotfelter, Esquire; and that Husband has been informed that he has the right to independent legal counsel of his choice but Husband has chosen not to be represented by counsel in this proceeding. The parties represent and warrant that they have fully disclosed to each other all assets of any nature owned by each, all debts or obligations for which the other party may be liable in whole or part, and all sources and amounts of income. -1- WHEREAS, the parties acknowledge that they fully understand the facts, and they acknowledge and accept that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. PERSONAL RIGHTS. It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The parties shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried, except as may be necessary to carry out the provisions of this Agreement. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means in any manner whatsoever with him or her. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. MUTUAL RELEASE. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the person, property or estate of the other party which he or she now has or at any time hereafter may have against the other party including but not limited to past, present, future support, maintenance, -2- alimony, alimony pendente lite, counsel fees, costs or expenses, but not including rights, agreements and obligations of this Agreement or for breach of any provision of this Agreement. It is the intention of Husband and Wife to give to each other, by the execution of the Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision hereof. It is further specifically understood and agreed by and between the parties hereto that each accepts the provisions herein made by the other in lieu of and in full settlement and satisfaction of any and all of their rights against the other or any past, present and future claims on account of support and maintenance; that it is specifically understood and agreed that the payments, transfers and other considerations herein recited so comprehend and discharge any and all such claims by each other against the other, and same are in full settlement and satisfaction of all claims against the other party, except any counsel fees, costs or expenses as may be incurred in connection with a breach of the Agreement as set forth hereinafter in Paragraph 18. 3. RELEASE OF TESTAMENTARY CLAIMS. Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by last will and testament or otherwise, and each of them agrees that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would have become entitled thereto as if the decedent had been the last to die. This provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's estate whatsoever, and it is intended to confer third-party beneficiary rights upon the heirs and -3- beneficiaries of each. Either party may, however, make such provision for the other as he or she may desire in and by his or her Last Will and Testament; and each of the parties further covenants and agrees that he or she will permit any Last Will and Testament of the other to be probated and allowed administration; and that neither Husband nor Wife will claim against or contest the will and estate of the other except as necessary to enforce any breach by the decedent of any provision of this Agreement. Each of the parties hereby releases, relinquishes, and waives any and all rights to act as personal representative of the other party's estate. Each of the parties hereto further covenants and agrees for himself and herself as well as his or her heirs, executors, administrators or assigns, for the purpose of enforcing any of the rights addressed in this Agreement. 4. FINANCIAL DISCLOSURE. The parties waive their rights to require the filing of financial statements by the other, although the parties have been advised that it is their legal right to have these disclosures made prior to entering into this Agreement, and by entering into this Agreement without reliance upon financial disclosure, the parties are forever waiving their right to request or use that as a basis to overturn this Agreement or any part thereof. 5. INCOME TAX MATTERS AND CONSIDERATIONS. With respect to income tax matters regarding the parties the following shall apply: a. Prior Returns and Tax Years: The parties have heretofore filed both joint and individual federal and state tax returns. Both parties agree that in the event of any deficiency, penalty or other obligation for federal, state or local income tax returns, filings or for the failure of a party to properly file, each party will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment therewith. Such tax, interest, penalty, or expense shall be paid solely and -4- entirely by the individual who is finally determined to be the cause of the misrepresentations, failure to disclose the nature and extent of his or her separate income on the returns related to the marriage of the parties. b. Current Returns: Each party agreed to be solely responsible for his or her tax liabilities and filings and shall indemnify and hold the other harmless from any liability related to same. c. Transfers per A~reement: The transfers of property pursuant to this Agreement are transfers between Husband and Wife incident to their divorce and as such are nontaxable, with no gain or loss recognized. The transferee's basis in the property shall be the adjusted basis of the transferor immediately before the transfer. The transfers herein are an equal division of marital property for full and adequate consideration and as such will not result in any gift tax liability. 6. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a court hold hearings and make decision on the matters covered by this Agreement, which court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Each party acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and is in his or her best interests, and that the agreement is not the -5- result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either party. Given said understanding and acknowledgment, both parties hereby waive the following procedural rights: a. Inventory: The right to obtain an inventory of all marital and separate property as defined by the Pennsylvania Divorce Code. b. Income and Expense Statement: The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code, except in instances where such an income and expense statement is hereafter required to be filed in any support action or any other proceedings pursuant to an Order of Court. c. Discovery: The right to have any discovery as may be permitted by the Rules of Civil Procedure, except discovery arising out of a breach of this Agreement, out of any support action, or out of any other proceedings in which discovery is specifically ordered by the court. d. Determination of Marital and Non-Marital Property: The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines to be marital. e. Other Rights and Remedies: The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including, but not limited to, possible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony), counsel fees, costs, and expenses. -6- 7. EQUITABLE DISTRffiUTION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner, which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being affected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. The parties agree to the equitable distribution of the marital property as follows: A. MOTOR VEHICLES. The parties acknowledge that there are four (4) motor vehicles that are marital property under Pennsylvania law that must be distributed. It is specifically agreed by the parties that Wife shall retain the jointly titled 1988 (Black) Volvo Sedan and the jointly titled 1988 (Grey) Volvo sedan, effective upon the execution of this Agreement. It is further agreed that Husband shall retain the jointly titled 1989 (Black) Volvo station wagon and the 1990 (Blue) Volvo station wagon presently titled to Husband, except that in the event that Husband relocates out of the Commonwealth of Pennsylvania or Wife's 1988 Black Volvo sedan becomes inoperational, then Husband shall transfer to Wife the 1989 (Black) Volvo station wagon. If Husband's 1990 (Blue) Volvo station wagon becomes inoperational, then Wife shall transfer to Husband the 1989 (Black) Volvo station wagon. Each party shall become the full and sole owner of the automobile(s) as designated herein and each party agrees to execute any documentation necessary to effectuate the terms of this provision. Each party shall be fully and solely responsible for any and all financial or other obligations -7- associated with the vehicle(s) and he or she shall indemnify and hold harmless the other party from any and all liability therefor. Each party also agrees that he or she shall obtain the necessary automobile insurance for the vehicle he or she is retaining with no lapse in coverage. B. AIRPLANE. The parties acknowledge that their marital property includes a Taylorcraft airplane. It is specifically agreed by the parties that Husband shall retain exclusive use and ownership of the Taylorcraft airplane and he shall be fully and solely responsible for any and all liabilities associated with the aircraft and he shall hold Wife harmless from same. In exchange, Wife shall waive any and all interest that she has in same. The parties further agree that each shall execute any and all documentation necessary to carry out the transfer as designated herein. c. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties acknowledge that Wife purchased many of the household good and furnishings found within the marital residence prior to the marriage and as such, they are non- marital property and will not be addressed in this agreement. With respect to the household goods and personal property obtained during the marriage, the parties acknowledge that they have previously divided between themselves to their mutual satisfaction, their marital household goods and personal property. Neither party shall make any claim to any such items of marital property designated to the other party, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles, or -8- documents necessary to give effect to this Paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, it is physically in the possession or control of the party at the time of the signing of this Agreement or as per the time limitations described, above, and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. D. PENSION. PROFIT -SHARING. RETIREMENT. OR OTHER PLANS RELATED TO EMPLOYMENT. The parties acknowledge that Husband has a retirement account with Pennsylvania Blue Shield now known as Highmark while Wife presently has no pension, profit-sharing, retirement, or similar retirement plan related to employment. Wife agrees to waive any rights that she may have in Husband's retirement account as described herein and it shall be Husband's sole and separate property. E. DISTRIBUTION OF CASH ASSETS. STOCKS AND BONDS AND INVESTMENT ACCOUNTS. The parties agree that they have distributed to each, to their mutual satisfaction, the sums deposited in the marital bank accounts, investment accounts, and other similar accounts. The parties further agree that they shall retain as their respective sole and separate property any other depository or brokerage accounts, stocks, or bonds held in their respective individual names. F. TRUST BENEFITS. The parties acknowledge that they do not own any real estate as marital property. However, Wife has been one of several parties holding -9- beneficial interest in a Trust whose res consists of residential real estate that was utilized as a marital residence via a lease agreement. Husband is not nor has ever been a holder of beneficial interest in said Trust. It is specifically acknowledged by the parties hereto that since May 2002, they have benefited from the use of residential real estate titled to the Glenwood Group Trust by virtue of a lease agreement with the owner. It is further acknowledged by the parties that each has personally guaranteed the secured note held by the seller of the real estate that is titled to the Glenwood Group Trust. It is specifically agreed by the parties that Wife shall retain exclusive use and ownership of any interest that either party may have had, may have, or may have in the future in the residential real estate titled to the Glenwood Group Trust that was utilized as the marital residence of the parties, and Husband shall waive any and all rights that he may have in same. With respect to any financial or other liability for the rights in the real estate titled to the Glenwood Group Trust, Wife agrees to be solely responsible for the liabilities and she shall hold Husband harmless from same. Both parties specifically agree that each shall, immediately upon request, execute any and all documents necessary to immediately and effectively carry out the terms of this provision regardless of the identity of the requestor. G. CORPORATION. The parties acknowledge that Wife owns shares in Alliance IT Corporation, a Nevada corporation. The parties specifically agree that Husband shall retain exclusive use and ownership of the corporation and Wife shall be compensated for her participation and interest in same as more fully described herein. In exchange for the compensation to be paid to Wife as a -10- Manager and/or in the form of alimony, Wife agrees to waIve any and all ownership rights she may have in the corporation. To effectuate this provision, Wife shall transfer any and all stock she presently holds in Alliance IT Corporation to payoff loans ($27,229.02) and interest ($4,596.36) totaling $31,825.33 and in exchange for the transfer of stock. The terms of this specific paragraph shall be completed within thirty (30) days of the date of execution of this Agreement. Wife shall also receive additional monetary consideration as further described below. This compensation shaIl be in the form of compensation for her duties a Manager and/or it shall be in the form of regular monthly alimony payments by Husband to Wife, depending upon the factual circumstances at the time of payment, as described in this Agreement. Wife shall resign her rights and duties as the Vice President of Operations of Alliance IT Corporation and remain as a Manager. Wife shall continue to manage the daily affairs of AIliance IT Corporation for a period of no less then five (5) years. It is agreed by the parties that Wife shaIl be compensated as an independent contractor for her position as Manager for the term of a minimum of five (5) years. In exchange for her role and duties as Manager, Wife shall be paid 50% of the corporate income after regular and usual direct corporate expenses until the divorce is final and no later than February 15, 2007. Upon the finalization of the divorce and no later than February 15,2007, Wife shaIl be paid the sum of 35% of the corporate income of Alliance IT Coronation, after regular and usual direct corporate expenses on a monthly basis for a period of twenty-four (24) months. Thereafter, Wife shaIl be compensated at a rate of 30% of corporate -11- income after regular and usual direct corporate expenses on a monthly basis for a period of thirty-six (36) months. The parties have completed an analysis of the history of the income and expenses related to Alliance IT Corporation and they have agreed upon the terms of this paragraph in reliance upon figures known to date. More specifically, the agreed upon terms are based upon the anticipated annual income of $100,000.00 and normal operating and other expenses of approximately $4,000.00 per year. Annual income is calculated by the formula: husband's hourly rate X 40 hours/week X 50 weeks/year, currently $50 X 40 X 50 = $100,000. Should husband's hourly rate change, the basis shall be re- calculated based on the new rate. The "calculated income" of the corporation to be used in calculating Wife's compensation shall be calculated using the formula above. The parties have agreed upon the compensation package for Wife as Manager as designated herein. It is specifically stipulated and agreed by the parties that should Wife's position as Manager with the Alliance IT Corporation be terminated by husband or the corporation for any reason whatsoever prior to the end of the five (5) year term, Wife will be paid alimony at the same rate and terms as her compensation as described for her Managerial duties as described above, but in the form of alimony as more specifically described below. Furthermore, Wife's alimony payments shall continue for a period of time no less than sixty (60) months from February 15, 2007. For the purposes of calculating the amount of alimony, it shall be equal to Wife's compensation as Manager (same being at a rates of 35% and 30% of the corporate income after the regular and usual corporate expenses as based upon the calculated corporate income and -12- expenses as designated in this section for terms of twenty-four (24) and thirty-six (36) months respectively). If Alliance IT Corporation ceases to conduct business such that it fails to produces the compensation or alimony for Wife as designated herein, Husband shaH pay to Wife the sum of money equal to the sum paid to Wife as designated in this section for terms of twenty-four (24) and thirty-six (36) months respectively), of the corporate income of Alliance IT Corporation after regular and usual direct corporate expenses in a sum equal to the calculated income and expenses described in this Agreement. Said payments shaH be timely made on a monthly basis such that there is no lapse in payment to Wife by Alliance IT Corporation as her Management compensation or in lieu thereof by Husband due to his personal guarantee of Wife's continued payments as designated herein, as alimony. If husband should find himself working as an employee requiring income taxes to be paid, Wife shall be paid alimony of 35% of Husband's income for twenty-four (24) months and 30% of Husband's income for thirty-six (36) months. Husband's income will based on his after tax income with Husband's payroH tax withholding not exceeding the tax tables for the pertinent tax year. H. LIMITED LIABILITY COMPANIES. It is acknowledged by the parties that Wife is presently a member of two (2) limited liability companies. More specifically, Wife is the sole member of Anthony Properties, LLC and she has a 50% interest as a member of Beau Monde Enterprises, LLC. It is specifically agreed by the parties that Wife shall retain any and aH interests in the limited liability companies described herein and Husband shaH waive any and aH rights to -13- same. Both parties agree to execute immediately upon request any documents necessary to effectuate the terms of this provision. 8. DEBTS. Husband represents and warrants to Wife that since the separation he has not, and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible, and he shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of such debt or obligation incurred by him since the date of said separation, except as otherwise set forth herein. Wife represents and warrants to Husband that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible, and she shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. a. Marital Debt. During the course of the marriage, Husband and Wife have incurred certain bills and obligations that are marital debt. It is their specific desire to address a distribution of those debts herein. More specifically, the parties agree that each party shall retain as his or her sole and separate obligation any marital debt that is solely in his or her name. b. General Provision: Any debt herein described shall be deemed to include the current balance owed on the debt as of the date of execution of this Agreement. c. Wife's debts: Wife shall be solely responsible for the following bills and debts: 1. Trust: Any and all expenses related to the use of the real estate owned by the Glenwood Group Trust and utilized, via a lease agreement, by the parties as the marital residence. It is specifically agreed that any and all utility accounts including butt not limited to telephone and cable bills shall be transferred to Wife's name alone on or before April 1, 2007. In the interim, Wife shall be solely responsible for the payment of any and all utility accounts and shall hold Husband harmless for same. 2. Credit Card: Wife shall be responsible to make payments on the Bank of America credit card in Husband's name until January 31, 2007 (during the time -14- that Wife is entitled to 50% of the corporate income after regular and usual direct corporate expenses) and her obligation to pay same shaH expire on that date. 3. Other Debts: Any and all other debts, liabilities, obligations, loans, credit card accounts, and the like incurred in Wife's sole name, and not otherwise provided for herein. d. Husband's Debts: Husband shaH be solely responsible for the following bills and debts: 1. Credit Card Debt: The credit card debt titled to Husband's name totaling approximately $38,000.00. 2. Other Debts: Payments to Wife per Paragraph 7(G) and/or Paragraph 10 as weH as any and aH other debts, liabilities, obligations, loans, credit card accounts, and the like incurred in Husband's sole name, and not otherwise provided for herein. e. Indemnification: Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills which pursuant to the terms herein are not the responsibility of the other party. This includes but is not limited to any attorney's fees and costs incurred by the other party as the result of defending against the obligation and/or enforcing the provisions of this indemnification. f. No Further Charges on Joint Debts: Neither party shall make any further charges on any joint debt for which the other party may be responsible, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay same, except for the credit card debt to be paid by Wife as described in Paragraph 8(c)(2), above during the time that Wife pays for same and/or until January 31, 2007. Otherwise, from the date of this Agreement, each party shall only use those credit accounts or incur such further obligations for which that party is individuaHy and solely liable and the parties shall cooperate in closing any remaining accounts which provide for joint liability. g. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. 9. COUNSEL FEES AND COSTS. Husband and Wife each agree to be responsible for their own attorney's fees and costs incurred with respect to the negotiation and drafting of this Marital settlement Agreement and the divorce proceedings related thereto. 10. ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES AND -15- EXPENSES. Both parties accept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now or hereafter have against the other for alimony, alimony pendente lite, counsel fees or expenses, or for any other provisions for spousal support and maintenance before, during and after the commencement of any proceedings for the divorce or annulment between the parties, except that Wife shall be entitled to a Court Order for Alimony if at any time during the five (5) year period subsequent to January 31, 2007, Wife is not fully compensated as described in Paragraph 7(G), above wherein it states that Wife shall be paid by Husband (and the marital corporation) compensation pursuant to a contract with Alliance IT Corporation as Manager. If at any time Wife's compensation from Alliance IT Corporation is reduced in any way Husband shall pay to Wife alimony each month such that Wife is compensated to the extent that she should have been or would have been pursuant to the terms above describing her management position and the compensation package from Alliance IT Corporation in exchange for her waiver of rights as more specifically described therein, and also in consideration of the factors under Pennsylvania law for an award of alimony, given the length of the marriage and other pertinent and relevant factors. These payments shall be treated as alimony and as such, would be tax deductible to Husband and treated as income to Wife. The alimony payments from Husband to Wife as described herein would continue for a period of sixty (60) months from January, 31, 2007, and they shall only terminate at the expiration of that time period or the death of Wife, whichever is sooner. The alimony payments from Husband to Wife pursuant to the terms of this paragraph would not terminate upon Wife's remarriage or cohabitation, but they would terminate upon her death. 11. DIVORCE. A Complaint in Divorce has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to Civil Docket No. 2006-0636 Civil, and either -16- party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an affidavit evidencing their consent to the divorce, pursuant to Section 3301(c) of the Divorce Code concurrently with the execution of this Agreement. In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees, resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. 12. BANKRUPTCY. The parties further warrant that they have not heretofore instituted any proceedings pursuant to the bankruptcy laws nor are there any such proceedings pending with respect to them which have been initiated by others. It is stipulated and agreed by the parties that the terms of this Agreement as they resolve the economic issues between the parties incidental to their divorce and the obligations of the parties to each other resulting therefrom shall not be dischargeable in bankruptcy, should either party file for protection under the Bankruptcy Code at any time after the date of execution of this Agreement. The payments called for in this Agreement are not intended to be a debt which is affected by a discharge in bankruptcy and the terms of this Agreement are not subject to discharge in bankruptcy because the parties acknowledged that such are necessary for the parties to meet their financial obligations and to support and maintain their standard of living. The parties acknowledge that there are no bankruptcy proceedings presently pending and they agree not to file a bankruptcy action prior to the completion of their respective obligations pursuant to this Agreement. Furthermore, any debt addressed in this Agreement shall not be discharged in a -17- bankruptcy action filed by or on behalf of one of the parties hereto. Also, if either party files for bankruptcy, this Agreement shall constitute conclusive evidence of the parties' intent that the obligations in the nature of maintenance and support are not dischargeable under current bankruptcy law or under any amendment thereto. Further if either party institutes any action in bankruptcy or any other bankruptcy proceeding is instituted in which a party's right to have payments made by the other becomes a matter for judicial review, the parties agree to consent to any motion filed by the other with the bankruptcy courts, wherein the party may request that the bankruptcy courts abstain from deciding the discharge ability of said obligation and any other obligations to said party thereunder in order to allow the appropriate Court of Common Pleas to rule upon this issue. 13. RECONCILIATION. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. 14. INCORPORATION IN FINAL DIVORCE DECREE. The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties. The terms shall be incorporated into the final divorce decree for the purposes of enforcement only and any modification of the terms hereof shall be valid only if made in writing and signed by both of the parties. Any Court having jurisdiction shall enforce the provisions of this Agreement as if it were a Court Order. This Agreement shall survive in its entirety, resolving the spousal support, alimony, equitable distribution and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania, and no court asked to enforce or interpret this Agreement shall in any way change the terms of this Agreement. This Agreement may be enforced independently of any support order, divorce -18- decree or judgment and its terms shaH take precedence over same, remammg the primary obligation of each party. This Agreement shall remain in fuH force and effect regardless of any change in the marital status of the parties. It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable, and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement. 15. DA TE OF EXECUTION. The "date of execution" or "execution date" of the 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 shaH be defined as the date of execution by the party last executing the Agreement. 16. FULL DISCLOSURE. Each party asserts that he or she has made or shall make a fuH and complete disclosure of all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, and of all sources and amounts of income received or receivable by each party. 17. ENTIRE AGREEMENT. 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. 18. BREACH. If either party breaches any provision of this Agreement, the other party shall have the following rights and remedies, at his or her election, all of which shaH be deemed to be cumulative and not in the alternative, unless said cumulative effect would have an inconsistent result or would result in a windfall of the other party: -19- a. Specific Performance: The right to specific performance of the terms of this Agreement, in which event the non-breaching party shall be reimbursed for all reasonable attorney's fees and costs incurred as the result of said breach and in bringing the action for specific performance. b. Damages: The right to damages arIsmg out of breach of the terms of this Agreement, which damages shall include reimbursement of all reasonable attorney's fees and costs incurred as the result of the breach and in bringing the damage action. c. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 Pa.C.S.A. 789 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said statute or replacement thereof by any other similar laws. d. Other Remedies: Any other remedies provided for in law or in equity. e. Considerations for Reasonable Attorneys Fees: Any award of "reasonable attorney's fees" as used in this paragraph shall be based on consideration of (1) the hourly rate charged; (2) the services rendered; and (3) the necessity of the services rendered. Determination of reasonableness shall not take into consideration the amount or nature of the obligation sought to be enforced or any possibility of settlement for less than the obligation sought to be enforced by the non-breaching party. 19. PENNSYLVANIA LA W. The parties agree that the Laws of Pennsylvania shall forever govern the terms of this Agreement and any interpretation and/or enforcement thereof. 20. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless made in writing and signed by both of the parties. -20- 21. ADDITIONAL INSTRUMENTS. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments, including Deeds and other real estate-related documents, titles, or other documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 22. SEVERABILITY. 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 shall continue in full force, effect and operation. 23. WARRANTY. Husband and Wife again acknowledge that they have each read and understand this Agreement, and each warrants and represents that it is fair and equitable to each of them. 24. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in drermining~~~1~~:~~~a Ohl:o.dier I "',;,;.',i d :, '.J ;Pf.,'," ',,,)1 ")fjj(~ lJlii <M...~,J .':'I!~:) ; ; '-':l-t~JJ~tn;~;n<)-tM _ "'......, ,.,,;..',', _~..~.,l..".,..'".~,~.. .....-',""".. of the parties. 25. BINDING EFFECT. BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS WHEREOF, and intending to be legally bound hereby, the parties hereto JA3i. jAI~A!C\' anJ3:!T(ij:; i1 ~,Jli1i'; ;)/o.;G 11~(.<""" ""'~ t:M.ltJt38MU';, ..wr .1~M.H (,llft';. .r ~ /'lUll&'IOU "')'<;;..""!(i:'; ,M -21- have hereunto set their hands and seals the day and year first above written. This agreement is executed in duplicate, and each party hereto acknowledges receipt of a duly executed copy thereof. WITNESSES: ,4 ~h - aIta .:d'~ /s. EL ABVH WRIGHT rv~Y) s' 1J~j,- J KENNETH E. WRIGHT NOWIW SEAL IMIARA L TOME Notary PublIc CNII1H1LIlOIIOUGMt. C~COUN1Y My CommIIIIOn ElIpIr.. Nov 4. 2009 ~ (f~~/i(~ I ~ c.t(.~ q. WJu.~ s ~ ~~~. COMMONWEALTH OF PENNSYLVANIA SS. COUNTYOF C1A~/~ On this f1....day of MMt4A... ,2007, before me, the undersigned officer, personally appeared S. ELIZABETH WRIGHT, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. 7f~Q. rJ~ U' Nf);'~- ~IIL NOTMW. 11M LtO\ A CL01FILB Notary PublIc HAWDEN 1WP. ~ CN1Y My CommIIIIon Expne N\ 21, 2010 -22- ~CMQ~~ Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ \~d SS. On this L ~ of ~OO7, before me, the undersigned officer, personally appeared KENNETH E. WRIGHT, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. L~ihtO g~"YM Notary Public NOTARIAl SEAL BARBARA L TOME Notary Public CAMPHlLIOROUGH. CUMBERlAND COUNlY My CommIIIIon Expires Nov 4, 2009 -23- ~ c:? ~~ --' ~ ~''Sll :;,;>0 I ...0 \l,V \l(}V; "",:;All ",,,,,,)'Jl(J6 IJI~I~ ~.t '.:",;l? ,<", ", q.,O ') 'fM --0 ....- ...P- o -0 .-\ :t:-r. (~"".r'-:' :(~~~) "'., ' ( :2 ~~\ ~J' --\ ::'n :...:::. - - co S. ELIZABETH WRIGHT, Plaintiff, VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERIAND COUNTY, PENNSYLVANIA : NO. 06-6306 KENNETH E. WRIGHT, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the foIl owing information, to the Court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint was filed on October 30, 2006. 3. Date and manner of Service of the Complaint: November 3, 2006, by Acceptance of Service of Defendant, Kenneth E. Wright, as evidenced same filed November 15, 2006. 4. The Plaintiffs Mfidavit of Consent was executed by the Plaintiff on March 8, 2007 and filed on March 9, 2007. The Defendant's Mfidavit of Consent was executed on March 6,2007, and filed on March 9, 2007. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on March 8, 2007, and said waiver was filed on March 9, 2007. Defendant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on March 6, 2007, and said waiver was filed on March 9, 2007. 6. There are no related claims pending. The parties resolved the economic issues by written Marital Settlement Agreement dated March 8, 2007, which shaIl be incorporated but not merged into the divorce decree as per Paragraph 14 on page 18. RespectfuIly submitted, Date: $/ q I Dl y: Li da A. Clotfelter, Esquire orney LD. No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, P A 17050 (717) 796-1930 (Telephone) (717) 796-1933 (Facsimile) r:; b ....... ~ ~ :;;0 \ ...0 -0 -;3: ~ - ,-\ -r:"'"\t fi"r: -"tr: ~P'-( (~:~ ~\ ; )-,"'- '~:::h\ ~ ~ ;:.;:: ..-' CP ;t; ;Ii ;t; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. S. ELIZABETH WRIGHT. Plaintiff No. 06-6306 CIVIL VERSUS KENNETH E. WRIGHT. Defendant II DECREE IN DIVORCE '" ;Ii +. '" '" /Vl~ c;;r-]. ~A.,+1 . 2007 110 , IT IS ORDERED AND DECREED THAT , PLAINTIFF. AND KENNETH E. WRIGHT , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the parties' Marital Settlement Agreement dated March 8, 2007, shall be incorporated herein but not merged as per Paragraph 14 on Page 1 T: ame for the purpose of enforcement, only. A~TEST!,~ J. ~ ~ PROTHONOTARY ~ +. +. +. +. """"+. + +. ++++ + ~'+ +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. ~ +. +. +. +. +. +. +. +. +. +. +. +. -~.7 ~ ~ ~o' 1/-I: ~r? ~~~ LtJ.11-~ ~ \ '" ," "~ ' ",.J.,.:. "\". . fot.~.f<~( ;...~\,.