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HomeMy WebLinkAbout02-3049JANE E. GEIMAN : IN ri'HE COURT OF COMMON PLEAS OF JON L. GEIMAN Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : CML ACTION - LAW : 2002 -.j?O~?ML TERM : 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 in 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 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, Carlisle, Pennsylvania 17013. 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 IHEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JANE E. GEIMAN Plaintiff JON L. GEIMAN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CML ACTION - LAW : 2002 - CML TERM :INDIVO C : oqc/ COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE AND NOW comes the Plaintiff, Jane E. Geiman, by and through hex attorney, Rebecca R. Hughes, Esquire, and files this complaint in divorce against the Defendant, Jon L. Geiman, representing as follows: 1. The Plaintiff is Jane E. Geiman, an adult individual residing at 1015 West South Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Jon L. Geiman, an adult individual whose last known address is 820 Forge Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divome. 4. The Plaintiff and the Defendant were married on March 25, 1979, in Carlisle, Cumberland County, Pennsylvania. 5. There are two children, both of majority age, born to this marriage: Mary Beth Geiman, bom March 17, 1981 (age 21); and Jonathan W. W. Geiman, bom September 19, 1982, (age 19). 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the Court require the parties to participate in counseling. 8. Pursuant to the Divorce Code, Section 3301(c), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties pursuant to Section 3301 (c) of the Divorce Code. Date: June ~ry0 ¢, 2002 Respectfully submitted, IRWIN, McKNIGHT & HUGHES l~e~becca IL I~ghes, Esquire Attorney for Plaintiff West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I.D. No. 67212 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. JANE E. GEIMAN Date: ~/~_ t/ ,2002 JANE E. GEIMAN : IN IHE COURT OF COMMON PLEAS OF Ve JON L. GEIMAN Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 2002 - 3049 CIVIL TERM : : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 25, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: ~% I~ ,2003 JAeNE E. GEIMAN JANE E. GEIMAN : IN THE COURT OF COMMON PLEAS OF Vo JON L. GEIMAN Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002 - 3049 CIVIL TERM : : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 25, 2002. 2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: ,2003 JON L. GEIMAN JANE E. GEIMAN Vo JON L. GEIMAN Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 2002 - 3049 CIVIL TERM : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST .ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made are subject to the penalti6s of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: /F ,2003 J~NE E. GEIMAN, Plaintiff JANE E. GEIMAN : 1N THE COURT OF COMMON PLEAS OF ~ JON L. GEIMAN Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 2002 - 3049 CIVIL TERM : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: &~". I~ ,2003 JON I~. GEI~AN, Defendant JANE E. GEIMAN : IN THE COURT OF COMMON PLEAS OF JON L. GEIMAN Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 2002 - 3049 CI3/-IL TERM : : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND : state: NOW, Rebecca R. Hughes, Esquire, being duly sworn according to law, does depose and That she is a competent adult and attorney for the Plaintiff in the captioned action. That a certified copy of the Complaint was served upon the Jon L. Geiman on June 27, 2002 by certified mail, remm receipt requested, addressed to 820 Forge Road, Carlisle, Pennsylvania 17013, with return receipt number 7099 3400 0018 4997 1001. o That the said receipt for certified mail is signed and attached hereto and made a part hereof. Date: I verify that the statements made in this affidavit are true ~x~d correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. IRWIN, McKNIGHT & HUGHES /[:3 3 By( SUPreme Court Id~ 67212 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Plaintiff Jane E. Geiman · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: JOl~l L ~GEIMAN 820 F~RGE ROAD ~IS~ PA 17013 2. Article Number (Copy from service label) 7099 3/~00 00[8 4997 100t A. Received by (Please Print Clearly) B. Date of Delivery X [] Agent [] Addressee D. em1? ~[~l~s If YES, enter delivery address below: o 3. Service Type ~] Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 r~' Postage 13- Certified Fee ~etum ~ecei~t Fee (Endorsement Required} Restricted Del I"1 (Endorsement Postmark Here I~ Total Postage & Fees --1- J Recipient's Name (Please Print Clearly) (to be completed by mailer) I~' | , p . o.; or PO Box No. ' ........................................................ m~~a- | 820 FORGE ROAD JANE E. GEIMAN JON L. GEIMAN Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 2002 - 3049 C]~IL TERM : : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Jon L. Geiman by certified mail, restricted delivery, on or about June 27, 2002. The Affidavit of Service was filed with the Prothontoary on or about January 30, 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff.' January 13, 2003; by defendant: January 16, 2003. (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: January 23, 2003. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: January 23, 2003. Date: January 30, 2003 MARRIA GE SETTLEMENT A GREEMENT THIS AGREEMENT made this ~.~lay of [~J0Ol~'_.tlXf~ .~t_~, 2002, by and between JANE ELLEN GEIMAN, (hereinafter referred to as "WIFE") and JON LESLIE GIEMAN, (hereinafter referred to as. "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on March 25, 1979; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, but not limited to the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, the settling of all claims and possible claims by one against the other or against their respective estates, and the equitable distribution of property and alimony for each party. The parties hereto agree and covenant as follows: It is the intent and purpose of this Agreement to set forth, the respective rights and duties of the parties while they continue to live apart from each other. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective fights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. · o Further, the parties agree to continue living separately and apart from the other at any place or places that he or she may select as they have heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. The consideration for this contract and agreement is the mutual benefit to be obtained by both of the parties hereto and the covenants and agreements of' each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: (1) Is represented by counsel of his or her own choosing, or if not represented by counsel, understands that he or she has the right to counsel: WIFE is represented by Rebecca R. Hughes, Esquire of Irwin, McKnight & Hughes; HUSBAND is not represented, however understands that he has: the right to representation but chooses not to obtain representation; (2) Is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities of the parties; (3) Is entering into this Agreement voluntarily after receiving the advice of counsel or after choosing not to consult an attorney; (4) Has given careful and mature thought to the making of this Agreement; (5) Has carefully read each provision of this Agreement; and (6) Fully. and completely understands each provision of this Agreement, both as to the subject matter and legal effect of each provision. This Agreement shall become effective immediately as of the date of execution. o It is the purpose and intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the rights of each party. 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 effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divorce Code relating to spousal support or alimony. o Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is' subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each Party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marriage. REAL ESTATE: HUSBAND agrees to transfer all right, title and interest which he may have in that marital property located at 1015 West South Street, Carlisle, Cumberland County, Pennsylvania, and any improvements thereon to WIFE and releases all claims which he may have regarding said real estate in accordance with this paragraph. WIFE agrees to pay any outstanding payments on any mortgages on said property, as well as all real estate taxes, insurance, and any maintenance and repair costs, and hold ItUSBAND harmless from any obligations on said payments and indemnify him if any claim is made against him. WIFE further agrees to make a good faith effort to remove HUSBAND's name from the mortgage currently against said property which is in both parties' names. HUSBAND hereby agrees to 4 execute a Deed conveying his interest in the property to WIFE simultaneous to the signing of this Agreement. PERSONAL PROPERTY: The parties agree that the personal property has been divided to the parties' mutual satisfaction. WIFE hereby waiw,~s all fight, title and interest which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any right, title and interest which he has in the personal property of WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or fight of the other party, all items of personal property of every kind, nature and description and 'wherever situated, which are then owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to HUSBAND or WIFE to. dispose of the same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. o AUTOMOBILES: WIFE hereby waives all right, title and interest in the Buick Park Avenue that HUSBAND currently is driving, and agrees to execute all documents necessary to transfer title of this vehicle to HUSBAND individually within thirty (30) days of this Agreement. HUSBAND shall hold WIFE harmless for any and all liability associated with the use and purchase of this vehicle, and shall be solely responsible for all insurance and other financial responsibility associated with said vehicle. HUSBAND hereby 'waives all right, title and interest in the two (2) Ford Escorts currently owned by the parties. HUS',BAND further agrees to execute all documents necessary to transfer title of one of the vehicles i[nto WIFE's name individually, and the other into the parties' daughter's name individually. WIFE shall hold HUSBAND harmless for any and all liability associated with the use and purchase of these vehicles, and shall be solely responsible for all insurance and other financial responsibility associated with said vehicles. 10. MARITAL DEBTS: It is mutually agreed by and between the parties that WIFE shall assume all liability for and pay and indemnify the HUSBAND against all debts incurred by WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the parties' marital separation she has not contracted or incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE fitrther represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of this Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. HUSBAND shall assume all liability for and pay and indemnify the WIFE against all debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants to WIFE that since the parties' marital separation he has not contracted or incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or incur any debt or liability after the execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 6 11. INSURANCE and EMPLOYEE BENEFITS: HUSI~IAND and WIFE own Individual Retirement Accounts currently through Edward D. Jones & Co. Thc parties agree that HUSBAND shall retain the accounts listed in his name individually, and WIFE shall retain thc accounts listed in her name individually. Both parties shall waive all right, title and interest in thc other's IRA through Edward D. Jones, & Co. Furthermore,. HUSBAND has a 401K account through his employment with TYCO. WIFE hereby waives .all right, title and interest in this account, and shall execute all documents necessary to effec'tuate this waiver. WIFE has a retirement account through her employer, Women's Health Associates of Carlisle. ~HUSBAND hereby waives all right,, title and interest in this account, atnd shall execute all documents necessary to effectuate this waiver. HUSBAND is receiving health insurance through his previous employer, TYCO. HUSBAND agrees to maintain this insurance on WIFE through the end of the 2002 calendar year. HUSBAND currently has a term life insurance policy on his life with WIFE as the beneficiary. HUSBAND agrees to maintain this policy on his life however shall name his children, Mary Beth and Jonathan Gciman as thc beneficiaries of all death benefits associated with said policy. 12. BANK ACCOUNTS and TAX RETURNS: WIFE agrees to waive all right, title and interest which she may have in any savings or checking or any other bank accounts of HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may have in the savings or checking or any other bank accounts of YVIFE. The parties agree to file joint income tax returns for the: 2002 tax year. If the parties are entitled to a refund, said refund shall be divided equally between the parties. 13. ALIMONY and DIVORCE: HUSBAND agrees to waive all right to alimony, alimony pendente lite, spousal support, and any other support for the person from WIFE. Likewise, WIFE agrees to waive all right to alimony, alimony pendente lite, spousal support and any other support for the person from HUSBAND The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce by the first week of the 2003 year. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is :seeking the divorce. 14. BREACH: If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by 'the other in enforcing their rights under this Agreement. 15. ADDITIONAL INSTRUMENTS: Each of the parties shall fi.om time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 16. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained .to the parties by their respective counsel, are fully understood by both parties, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. It is the parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall continue to have independent contractual significance. Each party maintains his or her contractual remedies or any other remedies provided by law or statute. Those remedies shall include, but not be limited to, damages resulting from breach of this Agreement, specific enforcement of this Agreement and remedies pertaining to failure to comply with an order of court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in effect and as amended or hereafter enacted. 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. APPLICABLE LAW: Commonwealth of Pennsylvania. 18. This Agreement shall be construed under the Laws of the 19. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 20. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, 10 acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, fights and claims. IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written.. WITNESSES: LLEN GEIMAN ~ .,/r~. /.-~.Afl ~ JQNLESk_~ GEINIAN ' ~4SEAL) 11 COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND : 2002, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, JANE ELLEN GEIMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA · · : SS: COUNTY OF CUMBERLAND : Member, Pennsylvania Association el Notaries PERSONALLY APPEARED BEFORE ME, this ~' day o~ , 2002, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, JON LESLIE GEIMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. 12 Member, Pennsylvania Association et Notaries IN THE COURT OF COMMON JANE E. GE'i-MAN, OF CUMBERLAND COUNTY STATE OF ~, iPENnA. Plaintiff JON L. VERSUS GEIMAN~ Defendant No. 2002-3049 PLEAS AND NOW, DECREED THAT DECREE IN DIVORCE Jane E. German AND Jon L. German ~,~~, IT I$ ORDERED AND ARE DIVORCED FROM THE BONDS Of MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLI. OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED~~ The Narriage Settlement Agreemmnt dated November 5, 2002~and signed by the parties is hereby incorporated into this decree but not merged. TTEST~al~/_: J'