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Home My WebLink About94-01894 Ii .J",_ '" I . J j ~ I, , I :~. :, , j',,' . '," f ... DIANE M. RODI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 94-1894 CIVIL ACTION - LAW IN DIVORCE DALE A. RODI, Defendant , AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 14, 1994. 2. The- marriage of Plaintiff and Defendanl is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim lhem before a divorce is granled. 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: 1/ p.J {fll JJ li4<- 1\0~ D1A ~. RODI -:r CT> :c a- N "" (""") >-,.. "'-- .r p t-: ...1 t.<1 (~;:~:,:o:: ~';"'(,J.t ;:.:. ';"'-':-"1 '/~ "'. :i ;.. - 1" ...... ...... :- c:> = ., L ,~1:~: l' :;.) ......C. ';;;1 , .' - (:.,.--:. ';ft:"j1.ttr''''''-'' ~ -- ,...., ,- , '.. . . -. l DIANE M. RODl, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1894 CIVIL ACTION - LAW IN DIVORCE v. DALE A. RODI, Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of lhe Divorce Code was filed on April 14, 1994. 2. The marriage of Plainliff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. I verify that the stalements made in lhis affidavit are true and correct. I understand that false stalements herein are made subject to the penallies of 18 Pa. C. S. Seclion 4904 relating to unsworn falsification to authorities. Date: 11- ,; -71.( k~4 DALE A. RODl ."1' -::r en ~ >-~ "'.- .t :T. ;..- 'l.' Ulr,i..,~ :~~~j ,~ . p(.,"I -':.r. '~: ~.~~ ,.~""L- ';-..~ to.) ::w:: 0- N 'Y) (Y) ~ r-....I ,.. CC> = , I..... .. . - en ~ ;-;>- -':; I.......,. ;l~ :, :,~ C~-';J ..:, 'r _,~~ ~ C.: ,.... ("'0") , , , ..- -~ ~" .... ::_~ , L.:~':: '. ..~iij;! ~;tj .".., ,.. <=> ::.: " .f.. . .IT .' . BLACKBURN & SPERTZEL AI/orney. Ar Low 20 South Market Slreel Mechanicsburg. PA 17055 Thlephone 17171 796,1600 . .. . . .- ,....' , -..,....,.' , . . ~ Diane M. Rodi, Plaintiff IN THE COURT OF COMMON PLEAS Cumberland County, Pennsylvania v. NO. 94-1894 Dale A. Rodi, CIVIL ACTION -- LAW IN DIVORCE Defendant AFFIDA VIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND Deborah K. Spertzel, Esquire, the atlorney for the Plaintiff, being duly sworn according to law, says lhat she mailed by certified mail a true and correct copy of lhe Complainl in Divorce in lhis aclion to the Defendant at his residence, and that the Defendant did receive same on April 26, 1994, as evidenced by lhe signed receipt attached hereto as Exhibil "A". @"~"l (~~~ eborah K. Spe I, Esq ire Sworn to ~nd subscribed before me this ~ N r:. day of IVI9UE,tr~ . 1994 ~ n ~OJJ.e~{~ NOlary Pu~lic II J ~ ~ (t<Cf (, My Commission Expires: (""Nao . NcWoaI Seal Roy EafIe CoOl<. ~ P\dC C<llItY ~~I998 t.\IlIlOl<. i'i \.. <il 1/::; >- \.., 'f) o ~ -.. ~ c t: ... 0 . e ;: U1 ~~ II" - -' -0 C ._" \I III > - ~~ oE \I U1 o u. <:l:: IT1 ..."O~2i .. ..cuc;:t ct .9-'_ :! :) ;J u:C a o~ c u t: .5. C r, ~ lI'" Q)Q)coloP N a: (.) z:: <!) . ~r Cl a. . -I !, 1. .{ ~ ,~,jf,--:c_. - . (" .-., . . . . ' EXHIBIT A ~'''$;: '. _--";~~' ~'~:"",::,;;:~~"""~".' ...;...:,::,:~;:;~~t f(ll~l~.....lI1d/tfa 10;, . ....?:'{t;,~;Jif'9.~ ~',iliO. ,;~0.rlC!~;~1J;,I;1 If [;~~.~3,"'4db; " , .' lalloWlngHrvI.~:Il~r~iii!!!~ ~ ~~8"';:: =.~..dlt _011....,...... - ....... IMI: '.' "'.' ~ ,..:,\:;;~~~ . ~.~~,t:J.,"m'~'l:" ""'" 01 dlt m......... Of ":'~ lM"d,~ " 1. ,0 "dd:~~~."dd~/r :~.lW~~-,,' Rioolpl, ,ft"lQll ............ftIIlIIllIcobllOw....--Z. rY:...Ukll8CI'DIuv, .iV',","; .,'Ilio_..........ohowlO_....__-.,londdlt_. JI'lJl ",. ". ",' , \, , ..it.:.' " , ' , , . " ConlUlt Imut" lor IH.' ,.- ' ",.~(~rtIcII Add....... to: 41. Artlcl. Num~r S () 1f' ~;;}'buT(;. A Rod 'f f), ,,3 ',. ,'''' .' 4b. S.rvl.. Type 'i.5.17.~tl1c..1jll" lAtHI, 0 Reglltlled g ~~:ed '~'MiJ1A.lIh5b~u, R ~:'~:M'II ORllUrnRICIIPt!OIil . " I 711' S' t. 01 D~~::dr... IOnlv II rlClu..'-,'lt ~" . r: II plldl , '.' :' 1'.!I,e..S"tUII CAgllltl , '.,:1 "'~'l'SForm .Jl.....18.,.~RECEIPT. ~.; .':,.1., .,,;~;:: ' ",':, ;~.,..,";.:7<,"":;~~.,,_;,,',.i,",,j,~' ~/.'~!','l,',l,'",..,''-''",.','~,~,'.,._':i,.'!i,,''; ,"" .' ~..f ~~ ., '~-.. , , .:.~, ,:J.., ~~ ,,' '+', ;>i,:t;_,\,:v..,,/:\i: ",~{:~,,;-;;;"":;'~<; ~ ~ . < . , 1661 "\lOr '008E 1\lIO~ Sd J r (~J ~~ ~ € a .:: ~ \~ II! ) '::J I - C"" "' ,., - t'1 r:- _ [)o ~~ ! e ?, ,:="" '", '" ..;::r-: on - c---'i -- . Q) ,'" co ~~ .<1 ),~ .....,..? wI." ->;1 ~ (:~:,~ ~ / ..' .', " ~ '"' .... -=< '. .', ',,) - 8 . . .' . . . ) . BLACKIlUHN & SI'EHTZEL ,\ttlmlt')'.'i AI /.aUI 20 Soulh Markel Slreel Meehanicshurg, I'A 17055 Telephone 17171 796.1600 . . ~ , (.. \ ~E M. RODl, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW NO. '1'1, IN'Y ~ T~ IN DIVORCE v. DALE A. RODl, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish 10 defend against the claims set forth in the foregoing pages, you must take prompt aClion. You are warned lhat 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 againsl 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 lhe marriage, you may requesl marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prolhonotary 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 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. Court Administralor, Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 r. "",".'''1 DIANE M. RODl, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW NO. C) </- Ir1'! (!u:;J 7...u.- IN DIVORCE Plaintiff v. DALE A. RODl, Defendant NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a Complainl in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This nOlice is to advise you that in accordance with Section 3302 (d) of lhe Divorce Code, you may requesl that lhe court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available al the Domeslic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound 10 choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenly days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right 10 request counseling. DIANE M. RODl, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. q 'I- If l} 'I d..;.:i -r...u-.... DALE A. RODl, Defendant CIVIL ACTION -- LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER THE DIVORCE CODE OF 1980 SECTION 3301 (c) COUNT I 1. Plaintiff is Diane M. Rodi and she resides at 563 Meggan Lane, Mechanicsburg, Cumberland County, Pennsylvania since 1992. 2. Defendant is Dale A. Rodi and he resides at 563 Meggan Lane, Mechanicsburg, Cumberland County, Pennsylvania since 1992. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 28, 1976 in Clearfield County, Pennsylvania. 5. There have been no prior actions of divorce or annulment filed on behalf of the parties. 6. Neither of the parties 10 this action is presenlly a member of the Armed Forces. ~ '.-' ....'""'--. ".,=~-..... 7. Plaintiff and Defendant are bo!h citizens of the United Slates. 8. Plaintiff has been advised of the availabilily of counseling and thai she may have the right to require lhe parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require lhe parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff avers that the grounds on which this acHon is based is that !he marriage is irretrievably broken. COUNT II 10. Paragraphs I through 9 of lhis Complaint are incorporated herein by reference. 11. Plaintiff requests the equitable distribution of marilal property. 2 WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce and an Order for the equitable distribution of marital property and any other relief that the Court may deem just and equitable. By: Respectfully submiued, Blackburn & Spertzel (j)~~-" j(A;vAftf Deborah K. Spertzel, uire 20 South Market Street Mechanicsburg, PA 17055 Supreme Court 10 43121 (717) 796-1600 Date: Io}- J,1 ,fj" 3 - ....... ,_.',0"" ," -", JlI!" ~r""" ''''',...'.........."'''',''',..",',.',,....;,~ ,~ 'l-<"~ "'''~,''','''"''c'.,-,''.''"..', ,,"-",to COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND AFFIDAVIT Diane M. Rodi, being duly sworn according to law, deposes and says that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of her knowledge, informalion and belief. ML.ut1I. ~ /JI I!u. · Dla M. Rodl Sworn to and subscribed before me this I (} rJ.. day of J1PHll , 1994. ~{ ~ Atn,ft- tary Public My Commission Expires: NOTARIAl. SG'.I. JANEl $, SWlfI. /.';:,:a'v r/:~ r:a~o Hill. Cumber'Jr"l (,~""!i My CommiSSion hr::f';J~ 16,1997 . IN 'lllE COORT "IF COIMCl'l PLEAS OF ClJ>lBERLAND c:cx.mY. PENNSYLVANIA DIANE M. RODI NO. 94-1894 CIVIL 19 '," vs. DALE A. RODI PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record. together with the following information. to the court for ent~~ of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: Canplaint served 4-26-94 certified'mail restricted delivery -. - 3. ~eanplete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff 11-21-94 by the defendant 11-18-94 B. (1) Date of execution of the plaintiff I s affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: none - parties executed marital settlement agreement which is attached to final decree 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code " (';JL "/L- Jt 41.1-1.-I;/\) Attorney for Plaintiff/Bcf~n~-~t .., I a; - :s:: a- ~ C") ~ ~ ::e ~~ ::~'" \4Jl.-'c.:;r. C,,)';r.c.J_1 ~C) c::,.^~" ~:; ~ -:. ;~ ~, ',...t.1' '_,' ;f'~ ~, ~~'.;~::i: ,.-;;) ,...c... '" .. . -' . . . "::r en ~ >- .....0- -0(' .....~ J.... "I":" i:e "', IT) .' , ,: ~..~':~ :....:~ -~, ,", \"".> : .~. ......, <-..I ::0- cr = .' . . . " . ..," '. .. ~ .;, ; BLACKBURN & SPEHTZEL Allom")'. AI Lu", 20 Soulh Market Street Mechanicsburg, PA 17055 Thlephone 1717) 796,1600 .~ !;. 1._ ,- # , <<<-' ...' ...~.... ')f" ':C-'.*" <* ... ... .:.> .:c. .:.:. .:c. .:.:. .:c- .:+:. .:+:- ,:.:,:-:,.:c-::.:c-!;...,;..:c:~.,,:.:_:<c- ,~.-=~ '.' , r .'- f - ;--:-~-.~ ~ ~ . ~ ~ . tJ/" ., "; IN THE COURT OF COMMON PLEAS : 8", OF CUMBERLAND COUNTY ~ ~ ~ : STATE OF * PENNA. l 8 ~ $ ember 10, 1994 ~ , 'fthStarilirig 'such ':' t .shall ,in j~ upon the partie ~ ~ )~ i: I~ I'" ;S ) , ,;~ I::: I~ , " ", P~qM.ROD.l, Plai,ntiff, ,,"',',' ",."".. " Nt), ..~,~:1.~~t,.., ................, 19 .: ,'~ ~ .; .....u.......... $ ~ '.' VCI'SIIS " , .i , DALE A. ROD!, Defendant .', :, *- ',' ." ,', ~ .', e DECREE IN IVORCE .. .. .. .. .. .. ~~.. '. 19 ,~~ , it is ordered and ,', ~ ,'~ ~ AND NOW, ,\) ~ ~ ~ ~ ~ .'~ '\-1 d h DIANE M ROD! I . rff .io!ecree t at .',,'.',,'. ,', " '.' , , , '.' , , , " .", ,'" , , , . " " , , '" p am I . ~ ' .. , ..' .. ..~, ~~, ~~.. .. , .. , .. , .. , .. , .. .. , .. .. , .. , .. ", defendant, are divorced from the bonds of matrimony. ..... 8 t:i ~ 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; No claims are pending. The Marital Settlement Agreement dated shall' be'lhcorporatei:f bY' re'ference IntO 'the' bIVo'ice Dee ' , ',' . , incorporation" this, Agrearent. shal~ not. I:le. marg.ed ~ s: all respects survive the same and be forever bi n, D Tee ulA: ,/ *- ~.' ~ !="' "'; ~ 8 $ ~ ~ f.' AlIest:--*,,"r,('<a ~t; .I?~J. .6, ,'~n.? /:" % ' ~ Ct' Jil..~ ') Prothonotary ~ M " ~ ~ ? ~ ~ - - -, :{.>:' ,;,0:,,' 8 ~ ~ ,', ~ ~ $ ~ !~ 8 ~ ~ ~ "', ~ i ~~ .', ~ Q ~~ !t! ',' ,', ~ ~ ',' ,', ~ ~ ',' ,.. ~ '.-.. - '-,-',~-~-"."-_..., -... -~,,-~~,~,~ ~ . "'-~..~-- _.'~..,. '~ '!i\ *~*~**~~***~~*~~~~~~~ .--,~"-_....'~, ,< ,,,,-.,.,.,-,,-~ 1 , '. , ~ . , . yf~ ~ '7J 0/ //~'7j?' J , .. " MARITAL SETILEMENT AGREEMENT This AGREEMENT made lhis IS' M day of n 0 ~ (' f<, I, e t\ , 1994, by and between Dale A. Rodi ("Husband" and/or "Father") and Diane M. Radi ("Wife" and/or "Mother"), al Mechanicsburg, Pennsylvania. WITNESSETH: Whereas, the parties herelo are Husband and Wife, having been married on February 28, 1976 in Clearfield County, Pennsylvania. Whereas the parties are the parenls of Thomas Andrew Rodi and Brian Radi. Whereas, difficulties have arisen between the parties and it is their inlention to live separate and apart, and the parties are desirous of sellling complelely the economic and other rights and obligations between each other including, without limilation: the ownership and equilable distribulion of marilal property, the pasl, present and future support, alimony, alimony pendente lite and/or mainlenance of either of them, the issue of health insurance for their children, the issue of educational expenses for their children, paymenl of counsel fees and in general, any and all claims and possible claims by one against the other or againsl their respective eslates and to accept the provisions of this Agreement in lieu of and in full scttlemenl and satisfaction of all such rights and claims. NOW. THEREFORE, Husband and Wife, in consideration of the above recitals and the following covenants and promises mutually made and mutually 10 be kept, lhe parties . "-' ~ herelofore, each intending to be legally bound and 10 legally bind lheir heirs, successors and assigns lhereby covenant, promise and agree as follows: I. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This agreement shall nol be considered 10 bar the right of Wife or Husband to a divorce on lawful grounds if such grounds now exist or shall hereafler exist or to such defense as may be I available to either party. This agreement is not intended to condone and shall not be deemed 10 be a condonalion on lhe part of either party of any act on lhe part of the olher party which has caused the disputes. The parties intend to secure a mutual consenl, no-fault divorce pursuant to the provisions of Section 3301 (c) of the Pennsylvania Divorce Code of 1980, as amended and agree on the execution date of this Agreement to execule affidavils consenting to the entry of a final decree in divorce. 2. EFFECT OF DIVORCE DECREE: 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. 3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The terms of the Agreement shall be incorporated inlo any divorce decree which may be enlered wilh respect to the parties, but they shall nol be merged into such decree. The Court of Common Pleas which may enler such divorce decree shall retain continuing jurisdiction 2 ~ . over the parties and the subject maller of lhe Agreemenl for the purpose of enforcement of any of the provisions thereof. This Agreement shall survive any such decree in divorce, shall be independent thereof, and the parties inlend that all obligations contained in this Agreement shall retain their contraclual nalure 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 10 lhe divorce caption. 4. DATE OF EXECUTION: The "date of execution" or "execution dale" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "dale of execution" or "execution date" of the Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. DISTRIBUTION DATE: Notwithstanding the date of execution of lhis Agreement as aforesaid and unless otherwise provided by a specific provision of this Agreement, the lransfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the tenth (lOth) day following the entry of a final decree in divorce with respect to lhe parties. 6. ADVICE OF COUNSEL: 3 , .. ' Wife and Husband declare lhat each has had a full and fair opportunity to oblain independent legal advice of counsel of lheir seleclion; lhal Wife has been independenlly represented by counsel Deborah K. Spertzel, Esquire and lhat Husband, cognizanl of his right to legal representation, declares that it is his express, voluntary and knowing intention not to avail himself of his right to counsel and choose instead to represent himself with respect to the preparation and execution of this Agreement. Each party confirms lhat he or she fully understands the terms, conditions and provisions of this Agreement and believes them 10 be fair, just, adequale and reasonable under the exisling facts and circumstances. The parties further confirm that each is entering inlO this Agreement freely and voluntarily and that execution of this Agreement is not the result of any duress, undue influence, collusion or improper or illegal agreemenls. Each party has had full and fair disclosure of the parties' assets and liabilities as described in Exhibit A and B. 7. PERSONAL RIGHTS: Wife and Husband may and shall, at all times hereafter, live separale and apart. They shall be free from any interference, direct or indirect, by lhe other in all respecls as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupalion, profession or employment which to him or her may seem advisable. Wife and Husband shall not harass, disturb or malign each other or the respective 4 . . . ~. families of each other. 8. MUTUAL RELEASES: Except as olherwise expressly provided by this Agreemenl: (a) Each party absolutely and unconditionally releases and forever discharges the other and the estate of the other from any and all righlS and obligations which either may have for past, present or future support or mainlenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any olher right or obligation, economic or otherwise, whether arising out of the marital relationship or olherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendmenls, as well as under any other law of any other jurisdiction except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. (b) Each party absolutely and uncondilionally releases the other and his or her heirs, executors, and estate from any claims arising by virtue of the marital relationship of the parties. The above release shall be effeclive whether such claim arises by way of widow's or widower's rights, family exemption, or under the intestate laws, or lhe right to take against the spouse's will, or lhe right 10 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 Terrilory of the United 5 " . States, or any other country. The parties each waive and release any and all right to receive insurance proceeds at the death of the other, whelher as named beneficiary or otherwise, as well as any right to receive any portion of lhe estale of lhe olher under his or her will (if executed prior to the execution dale hereof), or to acl as personal representatives of the estate of the other. (c) Except for any cause of action for divorce which eilher party may have or claim to have, and except for the obligations of lhe parties contained in this Agreement and such rights as are expressly reserved herein. each party gives to the other by the execution of this Agreemenl an absolute and unconditional release from all claims whalsoever, in law or in equilY, which either party now has against the other. 9. FINANCIAL DISCLOSURE: Attached hereto as Schedules "A" and "B" are the financial disclosures of the parties wilh respect to their assets and liabilities. Each party confirms that he or she is relying upon the substantial accuracy of the financial disclosure as an inducement to the execution of this Agreement. No representations or warranties have been made by eilher party to the other, or by anyone else, as to lhe financial status of the other, except as expressly set forth in this Agreement and Schedules" A" and "B". 10. MODIFICATION TO BE IN WRITING: 6 '1 , ~ , " , . '. f , " 'I ..J I i I 1 I No modificalion or waiver of any of lhe terms hereof shall be valid unless in wriling and " " :; signed by both parties. II. LAW OF PENNSYLVANIA APPLICABLE: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 12. AGREEMENT BINDING ON HEIRS: Except as may otherwise be provided, this Agreement shall be binding on the parties hereto and lheir respective heirs, executors, adminislrators, successors and assigns. 13. INTEGRATION: This Agreement conslitutes lhe entire understanding of lhe parties and supersedes any and all prior agreements and negotiations between them. There are no representalions or warranties other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the dislribution and division of marital and separate property are fair, equitable and satisfactory to lhem based on the length of their marriage and other relevant faclors which have been taken into consideration by the parties. BOlh parties hereby accept lhe provisions of this Agreement with respect to the division of property in lieu of and in full and final selllement and satisfaction of all claims and demands lhal lhey may now have or hereafler have against lhe olher for equitable distribulion of their 7 , property or for alimony, alimony pendente lite, counsel fees or costs by any court of competent jurisdiclion pursuant to the Divorce Code of 1980 or any other laws. Husband and Wife each voluntarily and inlelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, bUI nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing lhe provisions of this Agreement. 14. OTHER DOCUMENTATION: Within ten (10) days after demand lherefor, lhe parties will execule any and all wrillen instruments, assignments, releases, satisfactions, deeds, noles or such olher writings as may be reasonable, necessary or desirable for the proper effectuation of this Agreement. 15. NO WAIVER OF DEFAULT: This Agreement shall remain in full force and effect unless terminated under the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party lhereafter to enforce lhe same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nalure, nor shall it be construed as a waiver of strict performance of any other obligations herein. 16. REMEDIES AND SANCTIONS: 8 . In addition to such olher remedies and sanctions available under applicable law, the parties may utilize any remedy or sanction set forth in the Pennsylvania Divorce Code, as amended, 10 enforce any term of this Agreement as lhough it had been an order of the Court. 17. ATIORNEYS FEES FOR ENFORCEMENT: In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys fees, court costs and expenses (including interest and travel costs if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecling and enforcing his or her rights under this Agreement. 18. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 19. TRANSFER OF REAL ESTATE: Husband and Wife hold title as tenants by the entireties to the premises identified as 563 9 . Meggan Lane, Mechanicsburg, Cumberland County, Pennsylvania (lhe marital residence). The parties agree as follows with respeclto the marital residence: (a) On lhe execution dale of lhis Agreement, Husband shall deliver to Wife a warranty deed conveying to Wife all of his righi, title and inlerest in and to the marital residence. Thereafter, Wife shall be lhe sole owner of lhe marital residence and shall be permilled to record that deed and take any olher action with respect thereto that she deems appropriate. Husband shall have thirty (30) days from the date that a Divorce Decree is signed to move from the residence localed at 563 Meggan Lane, Mechanicsburg, Cumberland County, Pennsylvania. If ejectment proceedings or other such proceedings are required to remove Husband from the residence after the thirty (30) days have elapsed, Wife shall be entitled to any damages, COSls and allorneys' fees incurred in the ejectment proceedings. (b) Commencing on the execution date of this Agreement, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for all future costs or liabilities associaled with or allributable to maintaining the marital residence (including, but notlimiled 10, all real estate taxes, water and sewer rents, gas, electric and telephone service, homeowners insurance and gardening expenses and repairs) and Wife shall ;i q ,] \J :1 ij keep Husband and his successors, assigns, heirs, executors and administrators indemnified and held harmless from any liabililY, cost or expenses, including allorneys fees, which are 10 I ~ :j . incurred in connection with such mainlenance, cost, and expense or resulting from Wife's ownership interest in the marital residence. (c) There is presently oulstanding against the marital residence a mortgage in favor of York Federal (Loan number 0160048314). Commencing on the date of execulion of this Agreement, Wife shall be solely responsible for the timely paymenl of all past, present, and future principal, interest and other fees due under the mortgage. (d) Husband and Wife agree to lake all sleps necessary to have the mortgage transferred to Wife's name alone, provided, however, that York Federal agrees to such a change. (e) Wife shall indemnify and hold Husband harmless from any liability, cost or expense, including attorneys' fees, incurred subsequent to the execution date of this Agreement in connection with any expense required to be made by Wife including, but not limited to, the mortgage, property taxes, and insurance with respect to the aforesaid premises, and in the event that Wife should die and, at that lime, there should remain any outstanding balance on the mortgage, it shall be Wife's estate's obligation to promptly satisfy the mortgage. (I) Wife shall cooperate by providing or signing any necessary documents required by Husband if he decides to purchase a residence and is required to secure a mortgage to any II , , financial institulion or mortgage company. These documents would verify Wife's liability on the mortgage on the marital residence. They would also verify that under lhis Agreement, Wife will indemnify Husband from liability on the mortgage on the marital residence. (g) If, for any reason, York Federal refuses to transfer the mortgage on the marital residence to Wife's name alone, Wife shall insure the marital residence to at least the extent of lhe present mortgage and Wife shall deliver to Husband each year documentation evidencing that this property is insured at least to the extent of the present mortgage until such present mortgage is paid off. 21. PERSONAL PROPERTY: Wife and Husband agree that they have divided between themselves 10 their mutual satisfaction all items of tangible personal property found in the marital home. Neither party shall make a claim to any such item of tangible personal property whether said items are marital property or are items of separate personal property of either party which are now in the possession or under the control of the other party. Tangible personal property shall be deemed to be in the possession or under the control of either party if the item is physically in possession or control of the party at the time of the signing of this Agreement. 22. INTANGIBLE PERSONAL PROPERTY: Wife and Husband agree lhat they have previously divided all intangible personal property 12 including all checking and savings accounls. 23. AUTOMOBILES: Wife and Husband agree lhat Wife shall relain lhe 1988 Mazda and the 1984 Datsun automobiles which are currenlly used by Wife. Wife ana Husband agree lhalthe Husband shall retain the 1990 Ford Aeroslar Van which is currently used by Husband. Both parties agree lhat each shall execute such documenls of transfer, if any, as may be necessary to transfer title to these vehicles to lhe proper party and 10 be responsible for any debts incurred thereon. 24. PENSION AND RETIREMENT PLANS: Wife acknowledges lhatthe marilal property of the parties includes Husband's pension plan and profit sharing plan through his employment wilh DriveKore Inc. Wife further acknowledges that she has been informed of her right to oblain an independent appraisal of Husband's pension inlerest and, notwithslanding the same, Wife forever waives and relinquishes any right, interesl or claim lhal she might have in and 10 Husband's aforesaid pension interest. Likewise, Husband acknowledges that the marilal property of the parties includes Wife's pension plan through her employment with Cumberland Orthopaedic Associates Ltd. Husband further acknowledges that he has been informed of his right to oblain an independent appraisal of Wife's pension inlerest and, notwithslanding lhe same, 13 Husband forever waives and relinquishes any right, interesl or claim thai he might have in and to Wife's aforesaid pension interest. Wife and Husband shall each be deemed to be in possession or control of their own individual pension or other employee benefit plans from retirement benefits of any nature for lhe period following the dissolution of the marriage. As 10 retirement benefils for lhe period of lhe marriage, il is hereby agreed that each spouse shall be considered as having his or her own retir~ment benefits and Wife and Husband respectively will not be eligible for assignment of the spouse's pension or olher relirement benefils for any period before, during or following the dissolution of the marriage. 25. WARRANTY AS TO EXISTING AND FUTURE OBLIGATIONS: Wife and Husband each warrant lhal neither has heretofore contracted for any liability for which the other or lhe estate of the other may be responsible except as specifically disclosed and provided for by the terms of this Agreement. The parties further warrant that each will now and at all times hereafter save harmless and indemnify the olher and the estate of the other from all liabilities incurred after the execution date hereof, except as may be otherwise specifically provided herein, as well as from all liabilities of every kind which have been incurred heretofore by either party, including those for necessilies, except for obligations arising out of lhis Agreement. Except as may be otherwise expressly provided herein, the parties agree that all joinl credit andlor charge accounts and revolving loan accounts shall be 14 I .I , terminated immediately, and no charges shall be incurred by either party against any joint account from the date of the execulion of this Agreement. The following liabilities and obligations shaH be the sole responsibility of Wife upon execution of this Agreement: 1. PHEAA school loan account number 208429173PA 2. Hess's account number 6702184982 3. Hess's furniture account number 6546149058 4. Montgomery Wards account number 229048767 5. American General loan number 017627907-L 6. BonTon account number 050247162 7. Boscov's account number 3521362 The following liabilities and obligations shall be the sole responsibility of Husband upon execution of this Agreement: 1. Household Finance loan number 18226679 2. Household Finance line of credit 71330325862337 3. United Consumer Finance loan number 61033631 4. Spiegle account number 4400715696 5. Harrisburg Belco loan number 710320 6. Visa wilh Belco 710320 15 7. Sears accounl number 5484097402672 26. LIFE INSURANCE: The parties agree to maintain lheir present life insurance policies and each agree to designate their children as primary irrevocable beneficiaries thereof. The parents' obligation to retain their children as beneficiaries of their respective insurance policies as aforesaid shall terminale at such time as each child has completed normal education requirements, including college, and have become self-supporting, at which time Father and Mother may designate anyone they desire as beneficiaries of lhese policies. As long as the parties are bound under this paragraph, lhey shall: a. promptly pay all premiums on these policies; b. ,nol creale any lien on, not pledge. and not borrow against these policies; c. not change the designation of their children as irrevocable beneficiaries; d. not change lhe method for payment of the principal sum of lhe children as irrevocable primary beneficiaries; e. provide lhe other parent, at his or her request, with a copy of said policies. 27. SEPARATE ASSETS: The parties hereby agree that as 10 each of their separate assets, as that term is defined therein, the party not having title to or possession of any particular separate asset hereby 16 waives any claim therein, and acknowledges that hereafter the party having title or possession of a separate asset is the sole and exclusive owner lhereof. The above release is subject to lhe proviso that it shall be effective only as to those assets disclosed to lhe olher party, which assets are described or referred 10 in Schedules" A" and "B" attached to this Agreement. Neither party intends by the execution hereof to release any claim which he or she may have in assets which have not been disclosed. The term "separate assets" is defined for purposes of lhis Agreement as designating any asset of any kind (whelher real, personal or mixed, tangible or intangible) which is presently titled either in the sole name of a party hereto or jointly with one of the parties hereto (and designated 10 be conveyed to one of the parties) or jointly with a third party or parties. The term also includes any untitled asset which is presently in the sole possession of one of the parties herelo. The parties agree to indemnify and hold one another harmless from any liability, cost or expense, including attorneys' fees and interest which either may be in the future or has previously incurred with respect to their separate assets as defined herein. 28. AFI'ER-ACOUlRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the olher, all items of property, be they real, personal or mixed, tangible or intangible, which are or were acquired by him or her after the parties' date of separation, with full power in him or 17 I i~ I . , L<o' ''''"'.';':'" ,.'..~,"':,"" .~'r,l: her to dispose of lhe same as fully and effeclively, in all respecls and for all purposes, as lhough he or she were unmarried. 29. HEALTH CARE Falher shall continue medical insurance coverage for his children such as is presenlly maintained by him at the lime of the execution of this Agreement. However, if the present medical insurance policy of Father will not permit him 10 continue medical insurance coverage on his children, for any reason, then if Mother or MOlher's spouse (in the event of Mother's remarriage) can oblain similar medical insurance coverage for their children, at no cost to them, Mother should arrange to obtain such medical coverage. If, at any time, MOlher or Mother's spouse (in the event of MOlher's remarriage) is able to oblain medical insurance coverage for the children that is better than the medical insurance coverage in force at that time for the children and, if such coverage is available to MOlher or Mother's spouse at no expense to them, she shall arrange to oblain such medical coverage, thus relieving Father of lhe responsibility to provide such coverage. In the event that such coverage is not available to Mother or Mother's spouse at no additional expense to them and if Father cannot oblain, through his place of employment, medical insurance coverage for the children, appropriate medical insurance coverage shall then be oblained for the children and Father and MOlher shall then each be responsible for payment of one-half of the premiums for such 18 medical insurance for lhe children. Falher and Mother agree lhal each shall be responsible for one-half of any reasonable and necessary medical, denial, oplical, prescriplion or hospital expense incurred for lhe children that is nol covered by medical insurance. Denial expenses specifically include the cost of orthodonlia. In lhe event lhat Father and Mother believe thai either of the children require psychialric or psychological therapy or lreatment, the Father and MOlher shall consult with each olher and the child's physician to determine the necessity for such treatment and if Father, Mother and lhe child's physician agree that such treatment is necessary, Father and Mother shall be equally responsible for payment of any expenses for such treatment that are not covered by medical insurance. Father and Mother, except for emergency procedures, shall be consulted by the olher party on the need for any medical or dental treatment for the children as well as on lhe general type of treatment needed. In regard to each party's responsibilily to pay for uncovered medical, denial, oplical, prescription or hospital expenses as set forth above, each party shall have certain obligations to assure that lhe expenses for which the olher shall be liable shall be necessary and appropriate. Specifically, each party shall use all medical, denial and hospilalization insurance that is in effect at lhe time lhal any of the expenditures as set forth above are incurred. Each party shall also choose physicians, dentists or other professionals who participate in lhe medical insurance program lhat is then in effecl, whenever possible. For 19 example, if Blue Cross/Blue Shield coverage is in effect at the lime that a particular medical service is necessary, each party shall choose a physician, dentist or other professional who will accept Blue Cross/Blue Shield payments as payment in full if such physicians, dentists or olher professionals are available and suitable. Neilher party shall incur any medical, dental, optical, prescription or hospital expense for lhe children unless such expense is deemed to be necessary. Excepl in cases of emergency, each party shall auempt to consult with the other party before any medical, dental, oplical, prescription or hospital expenses are incurred, except in the case of ongoing treatmenls of which the olher party had prior knowledge. In order to verify those expenses for which each party shall be responsible, pursuant to lhe foregoing, each party shall submit appropriale documents including bills or receipts, or cancelled checks, etc. in order to verify the amount of medical, dental, optical, prescription or hospital expenses that have been incurred for the children, such costs not having been covered by medical insurance, each party shall be responsible for the payment of fifly percent (50%) of such uncovered medical, dental, optical, prescription or hospital expenses only if the other party has provided appropriale verificalion of lhe medical expenses for which payment is requested. 30. COUNSEL FEES. COSTS AND EXPENSES: Husband and Wife agree to pay their own counsel fees, costs and expenses associated with 20 lhis divorce. Neither shall seek any contribulion thereto from lhe other party. 31. DEPENDENCY EXEMPTION Husband shall be entitled to claim all dependency exemplions for lhe children for income tax purposes, and Wife hereby waives any right to claim such exemption on all her future income tax relurns. Wife agrees to execute Internal Revenue Service Form 8332 and any other document which may be required in order to release all future rights 10 claim dependency exemptions on account of lhe children. Husband is hereby authorized 10 file lhe said form or copies lhereof with his future income tax relurns and 10 make such other use of said form or olher documents as is reasonably necessary to effecluate the provisions of lhis paragraph, but only so long as Husband is in full compliance with his financial obligations under this Agreemenl. 32. lQlNT INCOME TAX INDEMNIFICATION: Husband agrees that he will be solely responsible and hold Wife harmless for any and all contingent or other liabilities on joint income tax returns previously filed by the parties and will agree to pay any claim or expenses arising out of such returns or liabilities (including reasonable counsel fees, tax, interest and penalties), unless additional liabilities are found to be allributable 10 misrepresentations or failure to disclose lhe nature and extent of Wife's income as il may appear on said previous tax return, in which case, Wife shall be responsible 21 I! I: " t t ~ , ;1 II " ~ 10 pay any claims or expenses related thereto. The parties hereto acknowledge that each will 22 immediately forward to the olher a copy of any deficiency notice or other correspondence received by either of them from the Internal Revenue Service or the Pennsylvania Department of Revenue concerning tax years for which a joint return has been filed. 33. EDUCATIONAL EXPENSES: The parties agree to make available to their children a college education or other post- secondary professional training provided thai each child demonslrates readiness, ability and motivation to secure the benefits of a higher educalion. The parties agree to contribute to the cost of lhis education talong into consideration the parenls' lhen income and other available educational resources, including but not Iimiled to fellowships, scholarships, grants and earnings of the children. The parents' obligation pursuant 10 this paragraph is conditioned on their being consulted with respect to the choice of educational institution and their approval lhereof obtained but the parenls' approval shall nol be unreasonably withheld. Educational expenses are defined to include tuition, room and board, books and supplies, a reasonable living allowance, transportation expenses to and from school, activities fees and memberships, clothing and equipment. 34. NOTICE OF CHANGE OF ADDRESS As long as any obligations remain to be performed pursuanl to the provisions of this Agreement, each party shall have the affirmalive obligalion to keep the olher informed of his or her residence address, and shall promplly notify the olher in writing of any change of address by giving the new residence address. 35. ALIMONY. SPOUSAL SUPPORT. ALIMONY PENDENTE LITE The parties acknowledge that by lhis Agreement, they have respectively secured and mainlained a subslantial and adequale fund with which to provide lhemselves sufficient financial resources for their comfort, maintenance and support. The parties acknowledge that the cosl of living may increase or decrease, that their respective eSlates may increase or decrease in value, that either may be employed or unemployed at various times in the fUlure, and that notwithslanding lhese or olher economic circumSlances, which may be changes in circumslances of a substantial and continuing nature, the terms of this Agreement are just and reasonable. Therefore, the parties hereby expressly waive, discharge, give up and release any and all righlS and causes which lhey may now or hereafter have by reason of the parties' marriage, separation or divorce to alimony, alimony pendenle Iile, spousal support and maintenance, and they further release any rights they may have to such modification of the terms of this Agreement in a Court of law or equity, it being understood lhat the foregoing , " constilutes a final determinalion for all times of either party's obligation 10 contribute to the , support and maintenance of the other. From the date of execution of this Agreement, it shall ,- , 23 , , . . be lhe sole responsibility of each parly to suslain himself or herself without seeking any support from the other. 36. VOLUNTARY EXECUTION THE PROVISIONS OF THIS AGREEMENT AND THEIR LEGAL EFFECT HAVE BEEN FULLY EXPLAINED TO WIFE BY HER COUNSEL AND HUSBAND, SINCE HE CHOSE NOT TO RETAIN COUNSEL, ACKNOWLEDGES THAT HE HAS READ THIS AGREEMENT AND THAT HE UNDERSTANDS ITS LEGAL EFFECT. EACH PARTY ACKNOWLEDGES THAT THE AGREEMENT IS FAIR AND EQUITABLE, THAT IT IS BEING ENTERED INTO VOLUNTARILY, WITH FULL KNOWLEDGE OF THE ASSETS OF BOTH PARTIES, AND THAT IT IS NOT THE RESULT OF ANY DURESS OR UNDUE INFLUENCE. THE PARTIES ACKNOWLEDGE THAT THEY HAVE BEEN FURNISHED WITH ALL INFORMATION RELATING TO THE FINANCIAL AFFAIRS OF THE OTHER. 24 ~ . , Each of the oartles has carefullv read and fullv considered this Al!reement and all of the statements. terms. conditions and orovisions thereof orior to sil!ninl! below. IN WITNESS WHEREOF, lhe parties hereto have executed this Agreement the day and year first written above. I f ,'(' ,LJfL i \ I (iJ-N lh ,~ D!~~lt. RODI / ./ ~~1;t WITNESS ' ~ I)~ C' (2.,L DALE A. ROD! 25 . ~'. . ~ , ./ ",'r', - i I! EXHIBIT A 26 MARITAL ASSETS I. Marital residence located at 563 Meggan Lane, Meehanicsburg, Pa. 2. 1988 Mazda 3. 1984 Datsun 4. 1990 Ford Aerostar Van 5. Checking account BELCO Dale Rodi 6. Checking account BELCO Diane Rodi 7. Savings account BELCO Dale Rodi 8. Savings account BELCO Diane Rodi 9. Life Insurance Columbus Mutual 10. Pension -- Drivekore 11. Pension -- Cumberland Orthopaedic Associates Ltd. 12. Household furnishings . .. . . . EXHIBIT B MARITAL LIABILITIES I. Mortgage on marital residence located at 563 Meggan Lane. Mechanicsburg. Pa. with York Federal. 2. PHEAA school loan account number 208429173 PA 3. Hess's account number 6702184982 4. Hess's furniture account number 6546149058 5. Montgomery Ward account number 229048767 6. Boscovs account number 3521362 7. American General loan number 017627907-L 8. Household Finance line of credit 71330325862337 9. Household Finance loan number 18226679 10. United Consumer Finance loan number 61033631 II. Sears account number 5484097402672 12. Visa account number 710320 13. Bonton account number 050247162 14. Harrisburg BELCO car loan number 710320 15. Spiegle account number 4400715696 27 , . COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On the 1/ I~ day of Hm"'6(>' , 1994, before me, the subscriber, a Notary Public for the Commonweallh of Pennsylvania, residing in the County of Cumberland, personally appeared before me Dale A. Rodi and in due form of law acknowledged lhe above Agreement to be his act and deed. :;;~ 1'''1<>-<y- Notary Public /'7ay t, /'1'1(. My Commission Expires: SS NoCaliaI Seal 11moII1y E. ~l. Notary Nlic t.Ioc:f1;ri:sbu BorO, Ctmleiland Ccunly My Cot1vrOssiCn ExpOes May 6 1996 McIrbef. l!l1flS)1Val1ia 01 t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On the j! .l.L day ofF r,\;" IUA/ , 1994, before me, the subscriber, a Notary Public for the Commonweallh of Pennsylvania, residing in the County of Cumberland, personally appeared before me Diane M. Rodi and in due form of law acknowledged the above Agreemenl to be her act and deed. I b ' '~ ';'~~Il.j.~ /,~ Notary Public i '-"1,1,.:f I I / I'll ~u Y ii'IS My rom mission xpirMiannaMScolI.NotaryPlAllc Canll Hill Boro, Cl.rrber1ai1d CounlY My eu..,lIs.Ioo1 E>qjn)s May 29, 1995 4f""~ol d!; - .... ....- -t'I t--. ~...1 o..aUf.:'7 UZ...l., -0 ','" ~~ X ~ ~J r~.--: :t;:'; ';I :'.jr. :;!.;~~~ => u.<.... -" IE ~ ("t') 'cG == -., . ~ I d!; .. .. ",r.; --tl wt:_i~' u:.r:~'~r: l-;:O""):-~ ~,::;;:'~"-' ;~ . :~~ ..' 1";'7- j "~J" l~",,~ I.~ :~~ (,., :IC a- ... ... ("I') IJ") c-..I .s; ~ ~ ".... BLACKBURN &. SI'ERTZEL "(turfier." All..,w 20 South Mark..."1 Street l\1l'chiJl1inhur~, I'A 17055 Tclephnl\l' lil7) 796.1fil)() : . ~ \ DIANE'M\ RODI, Plaintiff " , v. (, \r DALE A. RODI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA \ NO. 94-1894 CIVIL TERM Defendanl IN DIVORCE INVENTORY OF DIANE M. RODl Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within lhe preceding three years. ASSETS OF PARTIES Plaintiff marks on the list below those items applicable 10 the case at bar and itemizes the assets on the following pages. (X) 1. (X) 2. ( ) 3. ( ) 4. (X) 5. (X) 6. ( ) 7. ( ) 8. (X) 9. ( ) 10. ( ) II. ( ) 12. ( ) 13. ( ) 14. .' Real property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Conlents of safe deposit boxes Trusts Life insurance policies (indicale face value, cash surrender value and current beneficiaries Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property oulside lhe home f,"'~''''"'''''"" ".\;CJ"'" , ( ) IS. ( ) 16. ( ) 17. (X) 18. ( ) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. ( ) 24. (X) 25. ( ) 26. Business Employmentlermination benefits Profit sharing plans Pension plans (indicate employee contributions and date plan vests) Retirement plans, Individual Relirement Accounts Disability payments Litigation claims Military/V A benefils Education benefits Debts due, including loans, mortgages held Household furnishings and personalty Olher MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date lhis action was commenced: Item Number Description of Property Name of Owners 1. Marital residence located at Diane M. Rodi and Dale A. Rodi 563 Meggan Lane, Mechanicsburg Pa. 17055 2. 2. 1988 Mazda Diane M. Rodi and Dale A. Rodi 1984 Datsun Diane M. Rodi and Dale A. Rodi 2. 1990 Ford Aerostar Van Dale A. Rodi 5. Checking account Harrisburg BELCO #710320 Dale A. Rodi 5. Checking accounl Harrisburg BELCO 2 Item Number Description of Proper\y Reason for Exclusion . #404670 Diane M. Rodi 6. Savings Account Harrisburg DELCO #71 0230 Dale A. Rodi 6. Savings Account Harrisburg DELCO #404670 Diane M. Rodi 9. Life Insurance Columbus Mutual Diane M. Rodi and Dale A. Rodi 18. 18. Pension Drivekore Dale A. Rodi Pension Cumberland Orthopaedic Associates LTD Diane M. Rodi 25. Household furnishings Diane M. Rodi and Dale A. Rodi NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: 3 , LIABILITIES Diane M. Rodi Item Number Descriplion of Property Name of Creditor Name of Debtor House located a1563 York Federal Diane M. Rodi and Meggan Lane, Mechanicsburg #0160048314 Dale A. Rodi Pa. Mortgage 1. PHEAA school loan account number 208429173 PA Hess' account number 6702184982 Hess' furniture account number 6546149058 Montgomery Wards account number 229048767 Boscovs account number 3521362 American General loan number 017627907-L Household Finance line of credit 71330325862337 4 Diane M. Rodi Diane M. Rodi Diane M. Rodi Diane M. Rodi Diane M. Rodi and Dale A. Rodi Diane M. Rodi and Dale A. Rodi Household Finance loan number 18226679 United Consumer Finance loan number 61033631 Sears account number 5484097402672 Dale A. Rodi Diane M. Rodi and Dale A. Rodi Diane M. Rodi and Dale A. Rodi Visa account number Dale A. Rodi 710320 Bonton account number 050247162 Diane M. Rodi and Dale A. Rodi 1990 Ford Aerostar Van Harrisburg BELCO Dale A. Rodi Loan number 710320 Spiegle account number 4400715696 5 Dale A. Rodi Plaintiff verifies that the statemenlS made in this inventory are true and correct. Plaintiff understands that false statemenlS herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. A.{LO--toJ- ~L(~f Diane M. Rodi CERTIFICATE OF SERVICE I, Deborah K. Spertzel, Esquire, attorney for the plaintiff, Diane M. Rodi hereby certify that I this day served a copy of the foregoing Inventory of Diane M. Rodi on the person indicated below by depositing a copy of the same in lhe United States Mail, postage prepaid, at Mechanicsburg, Pennsylvania, and addressed as follows: Dale A. Rodi 563 Meggan Lane Mechanicsburg, Pa. 17055 7/d1 tt ~ Date rJl"hL~~~ Debofah K. Spe I, Esq re