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POST-NUPTIAL AGREEMENT
\
THIS AGREEMENT made and entered into this ,J.J ~ day of
A....~
,
, 1995 by and between:
JOHN L." RAUSCH, III of 2010 Good Hope Road,
Enola, Cumberland county, Pennsylvania, party
of th" ~:I-~r !'la.rr. (her'3inafter "Hu!:band"),
AND
DENISE L. RAUSCH, of 6014 Hummingbird Lane,
Mechanicsburg, Cumberland County,
Pennsylvania, party of the second part,
(hereinafter "Wife")
WITNESSETH:
WHEREAS, Husband and Wife (collectively referred to herein
as
"the parties")
l~'
were married to each other on October 6, 1990
Cumberland County, Pennsylvania; and
in
WHEREAS, the parties hereto have accumulated certain assets
and property during their marriage;
WHEREAS, the parties hereto have had no children of their
marriage and have not adopted any children; and
LAW O"'ICIS
SNELBAKER
a
BRENNEMAN
WHEREAS, certain differences have arisen between the
parties, as a consequence of which they have heretofore
separated and now live separate and apart from each other; and
WHEREAS, Wife commenced an action in Divorce docketed to
No. 94-2919 civil Term, in the Court of Common Pleas of
Cumberland county, Pennsylvania (hereinafter the "Divorce
Action"); and
WHEREAS, the parties agree that their marriage is
irretrievably bro~en; and
WHEREAS, the parties acknowledge that each has had the full
opportunity to be advised independently and represented by
separate counsel concerning their respective rights, duties and
obligations arising out of their marital status: Husband being
represented by Keith O. Brenneman, Esquire and Wife by Judith A.
Calkin, Esquire.
WHEREAS, the parties having a full opportunity to be so
advised of their respective rights, duties and obligations
arising out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and
all other aspects of each other's property and their jointly
owned assets and liabilities, have come to an agreement for the
final settlement of their property and affairs.
NOW THEREFORE, in consideration of these presents and the
mutual covenants, promises, terms and conditions hereinafter set
forth and to be kept and performed by each party hereto, and
LAW OPFlce.
SNELBAKER
a
BRENNEMAN
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intending to be legally bound hereby, the parties mutually agree
as follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and
paragraphs are incorporated by reference herein in their
entirety.
2. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties declare and agree that they have, prior to the
execution of this Post-Nuptial Agreement, voluntarily agreed to
divide and have physically divided and distributed between
themselves all assets which they acquired during their marriage,
whether or not said property is or would be deemed to be marital
I.AW O",CU
SNELDAKER
a
BRENNEMAN
property under Pennsylvania Divorce Code and subject to
equitable distribution. The parties further declare and agree
that prior to the execution hereof, they have voluntarily
distributed between themselves all assets and property which
each brought with them into their marriage.
The parties declare and acknowledge that they are
fully aware and familiar with all assets and property that each
has brought into the marriage and that has been obtained or
acquired separately or jointly by them during the course of
their marriage and therefore waive any evaluation thereof. Each
party expressly releases the other of and from any and all right
of equitable distribution or claims to assets and property of
-)-
any kind or nature whatever possessed by the other party.
Wife acknowledges that Husband prior to the parties'
marriage purchased the real property located at 2010 Good Hope
Road, Enola, Pennsylvania. Wife hereby waives and releases any
claim, right and/or interest in and to said real property, as
well as any appreciation in value thereof that may have occurred
during the parties' marriage and agrees to execute a deed
conveying any interest she may have in said property to any
purchaser(s) of said property, if required by the purchaser(s).
Husband hereby waives and releases any claim, right and/or
interest in any real property acquired by Wife after the
parties' separation.
3. DIVISION OF LIABILITIES. The parties declare and agree
that they have divided and allocated between themselves all
debts and liabilities, whether or not incurred by them during
the course of their marriage.
Husband shall continue to remain solely liable for
payment of the mortgagl. and home equity ~oan encumbering the
real property at 2010 Good Hope Road, Enola, Pennsylvania.
LAW OFFICIS
SNELBAKER
a
BRENNEMAN
4. FUTURE OBLIGATIONS. The parties agree that any and all
obligations incurred subsequent their separation, in April,
1994, shall be the sole and separate liability and respon-
sibility of the party incurring the obligation and each party
agrees that he/she will not incur or attempt to incur any
-4-
obligations for or on behalf of the other party and will
indemnify and hold harmless the other party of and from any and
all liability arising from such future obligation.
5. COUNSEL FEES. Each party to this Post-Nuptial
Agreement shall be responsible for paying his or her own counsel
fees and related costs associa~ed with the processing of the
Divorce Action and the negotiation, execution and consummation
of the provisions of this Post-Nuptial Agreement.
6. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of
and from any and all claims which either may have against the
other for spousal support and for all claims which either may
have against the other by reason of and pursuant to the
Pennsylvania Divorce Code (and the divorce law of any other
jurisdiction) including, but not limited to, alimony, alimony
pendente lite, equitable distribution of marital property,
counsel fees, costs and expenses, except that the p~rformance of
any obligation created hereunder may be enforced by any remedies
under the Pennsylvania Divorce Code.
LAW On-ICES
SNELDAKER
a
BRENNEMAN
7. DIVORCE. The parties agree to terminate their marriage
by mutual consent without counselling and each agrees to execute
the necessary affidavits and consents to procure a consensual
divorce under the provisions of the Pennsylvania Divorce Code,
such documents to be filed in the Divorce Action.
-5-
8. GENERAL RELEASE. Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of
the parties hereto by these presents, for himself or herself,
his or her heirs, executors, administrators or assigns, does
hereby remise, release, quit-claim and forever discharge the
other party hereto, his or her heirs, executors, administrators
or assigns, or any of them, of any and all claims, demands,
damages, actions, causes of action or suits at law or in equity
of whatsoever kind or nature, for or because of any matter or
thing done, omitted or suffered to be done by such other party
prior to the date hereof, except that this release shall in no
way exonerate or discharge either party from the obligations and
promises made or imposed by reason of this Agreement.
9. SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Post-Nuptial Agreement shall survive any
action in divorce which may be instituted or prosecuted by
eit~er ~arty, and no order, judgment or decree of divorce,
LAW OFPICII:I
SNELDAKER
a
BRENNEMAN
temporary, interlocutory, final or permanent, shall affect or
modify the terms of this Agreement, but said Agreement may be
enforced by any remedy at law or in equity, inclUding
enforcement proceedings under the Pennsylvania Divorce Code.
The parties agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this
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Agreement shall not be merged into said order or decree in
divorce.
10. COOPERATION. The parties agree to cooperate with each
other and to make, execute, acknowledge and deliver such
instruments and take such further action as may hereafter be
determined to be requi~ite and necessary to effect the purposes
and intention of this Post-Nuptial Agreement.
11. VOLUNTARY EXECUTION. The parties declare and
acknowledge that they have had the opportunity to have the
provisions of this Post-Nuptial Agreement and their legal effect
fully explained to them by independent counsel of their choosing
and each party acknowledges that this Post-Nuptial 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 to the extent
same has been requested by each of them.
12. ENTIRE AGREEMENT. This Post-Nuptial Agreement
contains the entire understanding of the parties and there are
LAW o",lcn
SNELBAKER
a
BRENNEMAN
no representations, warranties, covenants or undertakings other
than those expressly set forth herein. The parties acknowledge
and agree that the provisions of this Agreement with respect to
the distribution and division of marital and separate property
-7-
~
,
are fair, equitable and satisfactory to them based on the length
of their marriage and other relevant factors which have been
taken into consideration by the parties. Both parties hereby
accept the provisions of this Agreement with respect to the
division of property in lieu of and in full and final settlement
and satisfaction of all claims and demands that they may now
have or hereafter have against the other for equitable
distribution of their property by any court of competent
jurisdiction pursuant to the Pennsylvania Divorce Code or any
amendments thereto. Each party voluntarily and intelligently
waives and relinquishes any right to seek a court ordered
determination and distribution of marital property, but 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 the provisions of this Agreement.
13. WAIVER. The waiver of any term, conditions, clause or
provision of this Agreement shall in no way be deemed or
cClrsidered a waivel: of any otiler term, c\lndi.:icn, clause or
provision of this Agreement.
14. APPLICABLE LAW. This Agreement shall be construed,
interpreted and enforced according to the laws of the
Commonwealth of Pennsylvania.
LAW O",C.I
SNELBAKER
a
BRENNEMAN
15. HEADINGS. The headings or titles of the numbered
paragraphs of this Agreement have been used only for the purpose
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of convenience and shall not be resorted to for the purposes of
interpretation or construction of the text of this Agreement.
IN WITNESS WHEREOF, the parties have hereunto set their
respective hands and seals the day and year first above written
intending to legally bind themselves and their respective heirs,
personal representatives and'aRsigns.
WITNESSED BY:
Jt::: 11~t It~?~<-<-
Keith O. Brenneman, Esquire
(SEAL)
DenT).WN..L~cA(SEALI
Date:
LAW O'...CEI
SNELBAKER
a
BRENNEMAN
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94-2919 civil Term
JOHN L. RAUSCH, III
c:\~~ h~:ON - CIVIL ACTION
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i::=~=m~~ion, ':0 ~be COU~ :0: ent=y of a civo:ce dec=ee:
1. Gro~~c for ~ivorce: irre,;:rievab1e breakcown
~~cer Sec':.ior: (X) 3301 (c) ( ) 3301 (d) (l) of the Divorce
Coce.
( Check
a?plica:~e section).
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~a':.e a~~ ma~ner of service 0: the comp~ain';::
June 6. 1995 Certifi~d-RpRtrioted Delivery
3. (Comple':.e ei':.her paragraph (a) or (b).
(a) Da~e of execu':.ion of the affidavit of consent
re~uired :y Sec~ion 3301(c) of the Divorce Coce: by
pl~i:l1:i:=--'- . -&}-rd-I~.."
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8/25/95
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(b) (~) Da':.e of execution of the plaintiff's
affidavit re~uired by Section 3301 (d) of the Divorce Code:
: (2) cate 0: se:vice c: the Plai::~i:=ls
a:ficavit upon ~he Defencan~:
4. Rela~ed clai~ pe~d1~q:
NONF.
5. Date and manner of sarvice of the notice of intention
:0 ::le ?raec~?e :0
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:ecord, a CODY of which
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DENISE L. RAUSCH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACTION-IN DIVORCE 1
NO. 94- eX '1 (7 {}A..M.A_-L. v~u.-m./
JOHN L. RAUSCH, III.
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN
against the claims set
take prompt action.
You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be
entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property
or other rights important to you, including custody or
visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is
available in the Court Administrator's Office, Cumberland County
Courthouse, Carlisle, PA.
SUED IN COURT. If you wish to defend
forth in the following pages, you must
PROPERTY,
ANNULMENT
THEM.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
YOU SHOULD
IF YOU DO NOT HAVE
TELEPHONE THE OFFICE
GET LEGAL HELP.
TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
A LAWYER OR CANNOT AfFORD ONE, GO TO OR
SET FORTH BELOW TO FIND OUT WHERE YOU CAN
Court Administrator
4th Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
r.
DENISE L. RAUSCH, . IN THE COURT OF COMMON PLEAS
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. . NO.
.
.
.
JOHN L. RAUSCH, III, . CIVIL ACTION-LAW
.
Defendant . IN DIVORCE
.
COMPLAINT IN DIVORCE
3301(c)
1. Plaintiff is DENISE L. RAUSCH, who resides at 2010
Good Hope Road, Enola, Cumberland County, Pennsylvania.
2. Defendant is JOHN L. RAUSCH, III, who resides at
2010 Good Hope Road, Enola, Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident in the
Commonwealth
for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October
6, 1990 in Cumberland County, Pennsylvania.
5. There has been no prior action for divorce or
for annulment between the parties.
6. The Defendant is not a member of the Armed Forces.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availability of
marriage counseling
and
that she
may
have
the right to
request the Court to require the parties to participate in
such counseling.
Being so advised,
Plaintiff does
not
request that the Court require the parties to participate in
counseling prior to a Divorce Decree being handed down by the
Court.
WHEREFORE, the plaintiff prays your 1I0norable Court to
enter a Decree in Divorce from the bonds of matrimony.
Respectfully submittedl
.
c dith A. Cal I , Esquire
~Attorney for PlaIntIff
2201 North Second Street
lIarrlsburg, I'A 17110
(717) 238-2312
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Commonwealth of Pennsylvania:
ss.
County of Dauphin
I verify that the statements made in this Divorce
Petition 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:
, /'} J{j'
\ 'l Uti [ ,,' I aUj) ch
Denise L. Rausch
Sworn and Subscribed
before me this al1day
of rnU1.1, 1994.
t (LAAV'
Notary
eA~~
Public
NOTARIAL SEAL
ElLEN ROSENBLOOM., Nolary Public
Harrisllorg, DauphIn County
My Commission EJpircs May 8. 1995
CBRTIFICATB OF SBRVICB
I, .JudLth A. Cnlkln, do horoby certify that a true and
correct copy of tho wll.hln Dlvol:co PoUtion was mailed at
Harrisburg, PA., corllflod-roHl.rlclod delivery, postage pre-paid to
the following perRonl
John L. Rausch, III
20111 Good lIope Road
I-:nola, PA 17025)
Datel
C,'~
Judith A. Calkin,
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Esq.
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PENALTY FOR PRIVATE
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DENISE L. RAUSCH. . IN THE COURT OF COMMON PLEAS
.
Plaintiff CUMBERLANn COUNTY, PENNSYLVANIA
.
.
vs. . NO. 94-2919 Civil Term
.
JOHN L., RAUSCH, III, CIVIL ACTION-IN DIVORCE
Defendant . IN DIVORCE
.
AFFIDAVIT OF SERVICE
I, Judith A. calkin, Esquire, deposes and says:
1. That she is an adult indi,ridual residing in Dauphin
County, Pennsylvania.
2. That on June:;l, 1994
she sent by certified mail
restricted delivery, return receipt requested from Harrisburg,
Pennsylvani~ (No. 150 784 455
) the divorce complaint in the
above-captioned case to:
John Rausch, TII
2010 Good Hope Roao
Enola, PA
3. That on June 6, 1994
John Rausch
signed
~
A. Calkin, Esquire
ey for the Plaintiff
2201 North Second Street
Harrisburq, PA 17110
(717) 238-2312
this affidavit.
the receipt No. 150 784 455 which is
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PlaintIff
IN '('lIE COUR'I' OF COMMON PLEAS
CUMBERI,AND COUNTY, PENNA
NO. 94-2919 Civil Term
DEN I SE I.. RAUSCII,
VA.
.JOIIN [,. RFllJSCII, III,
Defendant
CIVil. FlC'I'ION-I.,AW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301(c) of the
Divorce Code was filed May 31, 1994.
2. '~e marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing of this 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 if I do
not claim them before a divorce is granted.
5. I understand I may request that the Court require my
spouse and I to partic ipate in marriage counseling, being so
advised, I do not request that'the Court require my spouse and I to
participate in marriage counseling.
1 understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
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Denise L. Rausch
IIn!'worn falsification l.o authorities.
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DENISE L. RAUSCH,
P laintif f
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 94-2919 Civil Term
vs.
JOHN L. RAUSCH, III,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint In Divorce under Section 3301(c) of the
Divorce Code was filed May 31, 1994.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing of this Complaint.
3. I consent to the entry of a Final Decree in Divorce.
4. 1 understand that 1 may lose rights concerning
alimony, division of property, lawyer's fees, or expenses if I do
not claim them before a divorce is granted.
5. I understand 1 may request that the Court require my
spouse and I to participate In marriage counseling, being so
advised, 1 do not request that the Court require my spouse and I to
participate in marriage counseling.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to
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