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HomeMy WebLinkAbout94-03098 , I I/J I 7 i I i ~ j Q) ~ ~ ~ I ......... , I 1 001 ()-- ~ t( . ~ I -:.:' ':.:' ':.:' ':.:', ,:.:-:.:, ,':':' ::t:' ';4 '~ ~ ~ ~ ~ M " ~ " ~ ~ ~ M 1') 94 " ~ M .' ~ ~ " ~ " I, ~ DECREE IN ~ DIVORCE ~ ~/,~8Pf\i: AND NOW, ~~e, 19q~, it is ordered and Is I: )~ .:+:. .:.:. .:+:. .~:. .:.:. ,;-:. .:.:.' .:.:. .:.:. :+:. .:+:. .:.: .:.: ':.:' ':.:' :.:,:.:. :.:. :.;, ':.: ;. :.: ~ ,-"...~ ." ,.. ~ 8, ~I 81 8 8 8 ~ 8 8 ~ ~ ~ ~ ~ 8 ~ w ~ ~ ~ 0) ~ ~ ~ ~ ~ ~ 8 w ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF I~~t PENNA. \.~...., BRIGITTE REID, :\11 94-3098 Plaintiff \'I'L~ll' LAURENCE J. REID, Defendant ,BRIGITTE ,REID., , . . " plaintiff, , " defendanl, decreed Ihat and. . ,LAURENCE ,J. ' REID, are divorced from the bonds of matrimony. The courl retains jurlsdicllon of Ihe following claims which hove been raised of record in this action for which a final order has not yel been entered; ~ ~ ~ 8 " w r.' ~ ~ ~ - ~ . - . .. ~:' .>>:. .w., ,~,' .The. .t,erms, ,of, the ,Hurrl age Settlement Agreement, dated, 9/23/94., ~re.1~c~rpo~~ted,but not merged, 1nto, t~ls Order., \" ) ~.,....>\ '.. t ). .J ( nc..\I\lfh_~ic't\1 '\) )t'.;ll)\Un", :),,/,., P'IIIItt1l1tJlill\ ~ ~ ~ i',- /, " ;: I~ I~ ;1,< t ~: ~ ~ ~ ~ ''< w. ''< .I, ~ ~ .~ :~ . :.: :.: -~.. :t>:t: -:.::.:- -:.;-:.::.::.: :t: :.' ;~: ;.; ~.: :t: ;t: :t: :.: ~"""'- MARRIAGB SBTTLBHBNT AGRBBMBNT AGREEMENT made this J. J,.f.Jday of and between Laurence J. Reid (Husband) Camp Hill, Pennsylvania. Sf' iJ I~ 1/1 bt! r , 1994, by ( and Brigitte Reid (Wife), at WIT N E SSE T H: WHEREAS, the parties hereto are Husband and Wife, having been married on August 20, 1971, in Philadelphia, Pennsylvania/ and WHEREAS, on June 8, 1994, the Wife instituted a divorce action against the Husband in the Court of Common Pleas of Cumberland County, Pennsylvania, at No, 94-3098 Civil Term/ and WHEREAS, it is the intention of the parties to live separate and apart from each other and it is their desire to enter into an agreement resolving all of their respective financial and property rights, and all other respective rights, remedies, privileges and obligations arising out of the marital relationship or otherwise, including the equitable division of marital property and, in general, the settling of any and all claims and poesible claims by one against the other or against their respective estates/ and MiEREAS, the Wife has been fully, separately and independently apprised and advised of her legal rights, remedies, privileges and obligations arising out of the marriage relation or otherwise, by couneel of her own choice and selection, namely William H. Andring, Eequire/ and M!EREAS, the Husband has been fully, separately and independently apprised of his right to consult and be advised of his legal rights, remedies, privileges and obligations arising out of the marriage relation or otherwise I and m~EREAS, both parties have made independent inquiry and investigation with reepect to their respective legal rights, remedies, privileges and obligations arising out of marriage or otherwise and each has been fully informed of each other's assets, properties, property holdings, income and prospects I and WHEREAS, Husband and Wife each warrants and represents to the other that he or she fully understands the provisions of this Agreement and their legal effect, 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 influencel and m~EREAS, Husband and Wife each repreeent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, of the sources and amount of the income of such party of every type whatsoever, and of all other facts relating to the subject matter of this Agreementl NOW THEREFORE, in consideration of the promises, covenants and undertakings hereinafter set forth, Wife and Husband, each intending to be legally bound hereby, covenant and agree ae follows: 1, INCORPORATION OF PREAMBLE. The recitale set forth in the preamble to this Agreement are incorporated herein and made a part hereof as if fUlly set forth in the body of the Agreement. 2 2, SEPARATION AND NONINTEHFERENCE, It will be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her, 3. MUTUAL RELEASE. SUbject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all cauees of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce. 4. EQUITABLE DIVISION. By this Agreement the parties have intended to affect an equitable divieion of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 5. EFFECT OF DIVORCE DECREE. A. AGREEMENT NOT PREDICATED ON DIVORCE . It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non.defense of any action for 3 divorcel provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, upon just, legal and proper groundsl nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing Husband and Wife to executive the Agreement. Husband and Wife each knowingly and understandingly hereby waives any and all possible claims that this Agreement is, for any reason, illegal or for any reason whatsoever, unenforceable in whole or in part. Husband and Wife each do hereby warrant, covenant and agree that, in any possible even, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. B. ENTRY AS PART OF DECREE . It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. C. MUTUAL CONSENT DIVORCE - The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire martial counseling, and that they both consent to the entry of a 4 decree in divorce pursuant to 23 Pa.C.S.A. Section 3301(c). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents and to direct their re~pective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent permitted by law and the applicable Rules of civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 6. DIVISION OF PERSONAL PROPERTY. Husband and Wife have divided all personal property constituting marital property prior to the signing of this agreement. Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to personal items which shall become the sole and separate property of the other. 7. DIVISION OF MOTOR VEHICLES. With respect to the motor vehicles owned by one or both of the parties, they agree as follows: Each party shall retain the vehicle currently in his or her possession. The titles to the said motor vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided, on the date of execution of this Agreement or at any time thereafter at the request of either party. 5 O. AFTER - ACQUIRED I'lmsONAI. PHOPER'I'Y. Each of the parties shall heroaftor own and enjoy, indopendent of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though ho or she were unmarried. 9. RESPONSIBILITY FOR DEBTS. Each party covenants and represents that he or she shall not hereafter incur or contract any debt, charge or liability whatsoever for which the other spouse or his or her legal representatives or his or her property or estate may become liable. The Husband and Wife each agree to pay in full his or her own individual debts and to keep the other party free, harmless and indemnified of and from any of his or her individual debts. Husband hereby agrees to assume full responsibility for the payment of any and all debts incurred by Husband or Wife during the course of the marriage, and to pay in full all such debts and to keep Wife free, harmless and indemnified of and from any of such debts, including but not limited to Mastercard Account No. 5351 0490 1401 9450; Visa Card Account No. 4332-1121'2364- 9208; First Cash Line Account No. 8125-790-309-600; City Bank Cash Line No. 259324880; Pennsylvania State Employees Credit Union Personal Service Loan with Visa, No. 183-30-9705; and any and all debts or accounts incurred or contracted for by Husband in his individual name during or subsequent to the marriage. Husband shall undertake any action necessary, including the payment or Closing of such accounts, in order to remove any liability of Wife for such debts within ten days from the signing of this Agreement. 6 10. LEGAl, F~;f:S Each party shall pay his or her own attorneys fees. 11. AI,IMONY Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now ur hereafter have against the other for support, maintenance, alimony pendente lite or alimony. Husband and Wife further, VOluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support, maintenance, alimony pendente lite or alimony. 12. PENSION PROGRAMS. A. Husband hereby forever waives any rights which he may now have or to which he may hereafter otherwise become entitled, either as participant, spouse of participant. or beneficiary, as to any pension or profit sharing rights of the Wife, including but not limited to employee pension plans, employee profit sharing plans, Keogh plans, and individual retirement accounts, or any other employee benefit covered by Sections 401, 403 or 408 of the Internal Revenue Code, as amended, and specifically including any retirement benefits earned by wife as a result of her employment by the West Shore School District. This waiver shall be deemed a revocation of any written beneficiary designation and shall bar Husband from receiving benefits under such express written beneficiary designation, unless such designation is made or reaffirmed in writing on or after the date of this Agreement. B. Husband is a member of the Commonwealth of Pennsylvania, State Employes' Retirement System (hereinafter referred to as "SERS"). 7 C. SERS, as a creature of statuLe, is controlled by the State Employes' Retirement Code, 71 Pa. C.S. Sections 5101.5956 ("Retirement Code") . D. Husband's date ot birth III April 11, 1938, and his Social Security number is 183.30.9705. E. Wife'lI date of birth Is January 4, 1951, and her Social Security number is 165-48'1929. F. Husband's last known mailing address Is 916 Shetters Lane, Camp Hill, Pennsylvania 17011. G. Wife's current mailing address is 501 B, South Eighteenth Street, Camp Hill, Pennsylvania 17011. It is the responsibility of Wife to keep a current mailing addresll on file with SERS at all times. H. (a) The marital property component of Husband's retirement benefit equals: (1) the Coverture Fraction multiplied by (2) the Husband's retirement benefit on the effective date of HUllband's retirement. (b) The Coverture Fraction is a fraction with a value less than or equal to one. The numerator is the amount of Husband's service, as defined by SERS, for the period of time from August 20, 1971, to June B, 1994. The denominator is the total amount of Husband'S service, as defined by SERS, on the effective date of Husband's retirement. (c) Twenty-five percent (25\) of the marital property component of Husband's reti rement benef i t is to be allocated to the Wife as her equitable distribution portion of this marital asset. I. Husband's retirement benefit is defined as all monies paid to or on behalf of Husband by SERB, inCluding any lump sum withdrawals B or scheduled or ad hoc increalles, but excluding the disability portion of any dillabi 11 ty annui ti es paid to Husband by BERS or any deferred compensation benefi tll paid to Husband by SERS. '1'he equitable distribution portion of the marital property component of Husband's retirement benefit, as set forth in Paragraph OJ), shall be payable to Wife and shall commence as soon as administratively feasible on or about the date the Husband actually enters pay status and SERB approves a Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later. J. Husband shall nominate Wife as a beneficiary to the extent of Wife I s equitable distribution portion in Husband's retirement benefit for any death benefits payable by SERS. In addition, Husband shall execute and deliver to Wife an authorization, in a form acceptable to SERS, which will authorize SERS to release to Wife all information concerning Husband's retirement account including but not limited to Husband I s current Nomination of Beneficiaries form for death benefits. Wife shall deliver the authorization to SERB which will allow the Wife to check that she has been and continues to be properly nominated under this paragraph. K. The term and amounts of Husband's retirement benefits payable to the Wife after SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement is dependent upon which options are selected by Husband upon retirement. Husband and wife expressly agree that Husband shall select the following retirement option(s) upon filing an Application for Retirement Allowance with SERS: Option 1 or Option 4. L. Wife may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Husband and Wife 9 for amounts paid to each. M. In the event of the death of Wife prior to receipt of all of her payments payable to her from SERS under this Order, any death benefit or retirement benefit payable to Wife by Sf:RS shall be paid to wife's Estate to the extent of Wife's equitable distribution portion of lIusband' s red rement benef it as set forth In pa ragraphs II through J. Wife agrees to executive a will, testamentary trust, or any or all other documents necessary to assure that in the event of the death of Wife prior to receipt of all of her payments payable to her from SERS under this order, any amounts paid by BERS to Wife's Estate shall be paid to or enure solely to the benefit of the children of Husband and wife. N. In no event shall Wife have greater benefits or rights other than those which are available to Husband. Wife is not entitled to any benefit not otherwise provided by SERS. The Wife is only entitled to the specific benefits offered by BERS as provided in this Order. All other rights, privileges and options offered by SERS not granted to Wife by this Order are preserved for Husband. O. It is specifically intended and agreed by the parties hereto that this Order: (a) Does not require SERS to provide any type or form of benefit, or any option not otherwise provided under the Retirement Code; (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Husband based upon cost of living or increases based on other than actuarial values. P. The Court of Common Pleas of Cumberland County, 10 Pennsylvania, shall retain jurisdiction to amend any Domeotic Relations Order incorporating this Stipulation and Agreement, but only fo. the purpose of establishing it or maintaining it as a Domestic Relations Order, provided, however, that no such amendment shall require SERS to provide any type or form of benefit, or any option not otherwise provided by SERB, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. Q. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations Order and this Marriage Bettlement Agreement and any attendant documents shall be served upon SERS immediately. The Domestic Relations Order shall take effect immediately upon SERB approval and SERS approval of any attendant documents and then shall remain in effect until further Order of Court. 13. DIVISION OF OTHER ABSETS. All assets including, but not limited to, savings accounts, checking accounts, certificates of deposit and life insurance pOlicies shall be the sole and separate property of the title holder of said interest, unless otherwise provided in this Agreement. 14. TAXES. Husband or Wife shall be entitled to claim one of their children as a dependent on their tax returns for a given year if that child resides with that parent for a majority of the days in the year. Husband and Wife agree to execute any and all documents necessary for these dependency deductions. The parties believe and agree, and have been so advised by their respective attorneys, that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners 11 rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 15. HEALTH INBURANCE - CHILDREN Husband agrees to provide health insurance for the children. However, if such insurance should become unavailable to Husband through his employer and Wife has entitlement to insurance through her employer, Wife shall provide such insurance and Husband shall reimburse to Wife any out-of-pocket expenses incurred by Wife in providing such insurance. 16. CHILD CUBTODY AND BUPPORT. Husband and Wife are the parents of three children, Krystal, age 17; Adrienne, age IS; and Michael, age 12. Krystal presently resides with wife, while Adrienne and Michael presently reside with Husband. Husband and Wife agree that Husband shall be responsible for the 12 support of the children, and shall hold Wife harmless from any action or proceeding for child support. Husband and Wife further agree that the wishes of each individual child shall be determinative as to the parent with which that child resides, and further agree that the Husband's obligation to provide support for the children shall not be effected or diminished if any child resides with wife. 17. GENERAL PROVISIONS. A. WARRANTY AS TO EXISTING OBLIGATIONB - Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities, or obligations of every kind which may have heretofore been incurred by them, inCluding those for necessities, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each covenant, warrant, represent, and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. C. INDEMNIFICATION - Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than those described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that 13 if any claim, action, or proceeding is hereafter initiated seeking to hold the other party liable for any other debt, obligation, liability, act, or omission of such party, such party will, at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the other party in respect to all damages reSUlting therefrom. Damages, as used herein, shall include any claim, action, demand, loss, cost, expense, liability (joint or severable), penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or in attempting to avoid same or oppose the imposition thereof or in enforcing this indemnity, resulting to Husband or Wife from (a) any inaccurate representation made by or on behalf of either Husband or Wife to the other in or pursuant to this Agreement; (b) breach of any of the warranties made by or on behalf of the Husband or Wife in or pursuant to this Agreement; or (c) breach or default in the performance by Husband or Wife of any of the obligations to be performed by such party hereunder. The Husband or wife shall reimburse the other on demand for any payment made by such party at any time after the entry of divorce decree, based upon the jUdgment of any court of competent jurisdiction or pursuant to a bona fide compromise or settlement of claims, demands, or actions, in respect of any damages to which the foregoing indemnity relates. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis of a claim for indemnity by either the Husband or Wife against the other pursuant to the terms of this Agreement. 14 D. SEVERABILITY - If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. E. OTHER DOCUMENTATION - Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. F. 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. G. WAIVER OR MODIFICATION TO BE IN WRITING - No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. H. MUTUAL COOPERATION - Each party shall, at any time and from time to time hereafter, take any and all steps and execute, 15 acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. I. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the commonwealth of Pennsylvania. J. BINDING EFFECT - Except as otherwise stated herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. K. NO WAIVER OF DEFAULT - This Agreement shall remain in full force and effect unless and until terminated under and pursuant to 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 hereafter to enforce the 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 nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. L. HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience or reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction, or effect. M. WAIVER OF CLAIMB AGAINST ESTATEB - 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 16 she may have or hereafter acquire, under the present or future laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, inclUding, without limitation, dower, curtesy, their statutory equivalents, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of other, and right to act as administrator or executor of the other's estate, and each party will, at the request of the other, execute, 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, rights and claims. N. ATTORNEY'S 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 parties hereby agree that the breaching party will pay all reasonable attorneys' fees, court costs, and expenses incurred by the other party in enforcing the Agreement. have signed and sealed .:Je,? Te m it'r I this Agreement on the bound hereby, the ,)J,,-//. d f ay 0 parties IN WITNEBS WHEREOF, and intending to be , 1994, Camp Hill, Pennsylvania. In the presence of: 0vfLc;/~' S IJ:f~7/~ (i , .--..'- ., ~ Brigitte ~ (SEAL) ~~c? . -t- Lau ence J. R (BEAL) 17 " " ~ - -\. , . . [1[1 j , I "'I '91 I d Ii I , , \';." ;1.t,.' ~ L\h'r' 'i," ilr " . . , ) II - - .- ~!'t" '~"""~" ,.-.~-""".. "', - . ~ .~- "-"'- - -, ~" :&....." .., "-"'f~~ ,." ... .., .. .. l."""" J;"\- . .~-,," __ _..~ _. -,:": ~_~';'" . l____""'~~..}~...,.~;J~~~~~~"'!i\t~{.<<l~t.~~..,,~>'\ftrl-V~ Hl,.',44..I iltl;. OCT III II 23 PH '94 L" !ii (;('1'., l i-'i. ',' il'S~l' IllCI. iiijW"rA~'f (! ,:-' ,lfY '~ i ,: ," ... :<'_"_~"''''''''''''.':''F,~J..;;".,._.t.. ",,""'-""___ "+"4",,*,-~' .. . , " '"'-:.'..-.."."'..._,;,.-.,.',...,0;.,....:.,.._.._,. - '-'-"-f> ., .. -. ~. , . .;,."';" t. .b .....~ :fOP. BRIGI'rTE REID, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 9/r- jvqJ (I('LL,-~.:JL1.1Y'-- LAURENCE J. REID, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICB TO DBFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Court House, 1 Court House Square, Carlisle, PA 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. Cumberland County Lawyer Referral Service Court Administrator Cumberland County Court House Carlisle, Pennsylvania 17013 (717) 240-6200 . BRIGITTE REID, I IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA v. I I No. LAURENCE J. REID, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT UNDBR SBCTION 3301(0) OR 3301(41. or THB DIVORCB CODB COUNT I DIVORCB 1. Plaintiff is Brigitte Reid, who currently resides at 5018 South Eighteenth Street, camp Hill, Cumberland County, Pennsylvania, since April 1, 1994. 2. Defendant is Laurence J. Reid, who currently resides at 916 Shetters Lane, Lower Allen Township, Cumberland County, Pennsylvania, since August 1990. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 20, 1971, at Philadelphia, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Defendant is not in the military service. B. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. CAL, ~~. (i! 57~61'f.J' JUH 8 II 25 fH '!N Qf r, . 'l '~i f,~E ci:.i! 'i '~I"\']'!n!lIH10l ~~ \ I". ." CI'''N/- , ~IISII "\' u , .'. ~ A ill.(J ~~ .JCf! . , .. '-'- .. ...."""_'".""~"'......'-"....i...~~..^'..._....~...."'........'"'....... /)J - ~J-J1J .s: Ic) /0' /C;r'kfJ I;r~1 (( q J{, tttj - ,....-- ""c""__~~ ~. ,.j " ....~., ,eo,. , I' . -, --r:.J: ." 1...;;.c.:...... ., ; ,,;~~,~'. .' "+t .~~-' f' . . , tI , . .. I'.... , , . .' . .~ '" n,q. ,.,. .__._"'._......;~" .._,.,"..P,.:,'~;:_'"" ;,.,."'..,.1'.....>, . ",..,...".t,.....""", Oct III 4 ~3 rH t9~ l'i' \~lHl; \~j Hlt;t'" ; I 1/1.. .. i,' i Ah~' illT " ~ BRIGITTE REID, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, I PENNSYLVANIA v. I I No. 94-3098 CIVIL TERM LAURENCE J. REID, I CIVIL ACTION - LAW Defendant I IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on June I, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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 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 I f-I-f~7~ L . OClll1 II u r~ 1M . 'I,r.l O[ ~ t, IVlil'.I~I'Y CliPI :1,"'[' "C;n 11 l'EHh'..i ',h~'~ /.;' ~ ., I~ . .\. ..., .~._.... II' I . I .-1>1, \- -:~-- , .. . , If . " t .. -- " Oct III It ~3 rH '9~ CI l'1'h fI <t , IIU'I' 'Ah~ . ':0 Ilifi ,f:' ! .', . , , . J' ., -. J . l;. -.'