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Home My WebLink About02-3596 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High $1reet Carlisle, PA Bonnie L. Schult, Plaintiff Wemer A. Schult, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 3.~q/,, CML TERM : CiVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divome 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 Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Date: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY By: Johnn~"~Kepec~, Est~e Supr~e Court ID #53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHtJFF, FLOWER & LINDSAY 26 W. High Street Bonnie L. Schult, Plaintiff Wemer A.Schult, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) .OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Bonnie L. Schult, who currently resides at 929 Nixon Drive, Mechanicsburg PA 17055, Cumberland County, Pennsylvania. 2. Defendant is Werner A. Schult, who currently resides at 4621 Holtzschwamm Road, Thomasville PA 17364,York County, Pennsylvania. 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 February 15, 1992 in Thomasville, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiffrequests Your Honorable Court to enter a decree in divorce. By: Respectfully submitted, saiD s, SHUF owflg & LINr s^y lm~/J, ope,c, lf~sq ~ff~e Sut~,e~ne Co~[~ g53147 26 West Hi~ S~eet C~lisle, PA 17013 (717) 243-6222 Co~el for ~e Pl~nfiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA AFFIDAVIT I, Bonnie L. Schult, being duly sworn according to law, depose and say: (1) ! have been advised of the availability of marriage counseling and understand that ! may request that the cour~ require that my spouse and ! participate in counseling. (2) ! understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, ! do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn £alsification to authorities. Dated: _~~ Bonme L. S6h~ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High SHeet Carlisle, PA ~VERIFICATION I verify that the statements made in this Complaint 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 author/ties. BOnme L. Sch~li, Plaintiff ..... SAIDIS SHUFF, FLOWEI~ & LINDSAY 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE On this _~ day o ,2002, I, Johnna Kopecky, hereby certify that I served a tree and correct copy of the foregoing Divorce Complaint via Urfited States Mail, certified, restricted delivery and return receipt requested, postage prepaid, addressed as follows: Werner A. Schult 4621 Holtzschwamm Road Thomasville PA 17364 By: SA1DIS, SHUFF, FLOWER & LINDSAY ~Esquire I.D. #53147 26 West High Street Carlisle PA 17013 717.243.6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY A'I'roRI~YS*AT*LAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF V. WERNER A. SCHULT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 - 3596 CIVILTERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE AND now, this /~ day o , 2002, I, CAROL J. LINDSAY, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the Defendant, WERNER A. SCHULT, on August 2, 2002, with the Complaint in Divorce by Certified Mail, Restricted Deliver, Addressee Only, Return Receipt Requested, addressed to: Werner A. Schult 4621 Holtzschwamm Road Thomasville, PA 17364 and proof thereof, the signed Return Receipt Card, is attached hereto. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff 26 ~eCt High Street Carlisle, PA 17013 SAIDIS SHUFF, FLOWER & LINDSAY A'I'I*ORNEYS.AT.LAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF V. WERNER A. SCHULT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 - 3596 CIVILTERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. WernerA. Schult, Defendant Date: ]]/,~'~J¢~'..2 / // SAIDIS SHUFF, FLOWER & LINDSAY ATroI/I~YSsATsLAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002 - 3596 CIVILTERM WERNER A. SCHULT, DEFENDANT CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Bonnie L. Schult, Plaintiff Date: //,/'~//~',~ SAIDIS SHUFF, FLOWER & LINDSAY A~ORI~YSsATsLAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF V. WERNER A. SCHULT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- 3596 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under {}3301(c) of the Divorce Code was filed on July 29, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. WernerA. Schult, Defendant Date: /~,/~/~.;Z SAIDIS SHUFF, FLOWER & LINDSAY ATrOR~Y~AT*IAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF V. WERNER A. SCHULT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- 3596 CIVILTERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under {}3301(c) of the Divorce Code was filed on July 29, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Bonnie L. Schult, Plaintiff Date: SAIDIS SHUFF, FLOWER & LINDSAY ATfORNEY~*ATeLAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002 - 3596 CIVILTERM WERNER A. SCHULT, DEFENDANT To the Prothonotary: CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) ......'~'~/.4~/4, ~.-J~ ,) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mail; Return Receipt signed by Defendant, Werner A. Schult, August 2, 2002, and filed herewith. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff November 26, 2002; by the Defendant November 27, 2002. (b) r~ n.-,*,.,..., cf ,.,..,.,..,~.,v,*""", ,..,"~ ,~,,-, Dl-,i,.,~r.,,,- .-,~,,~..,,;, ..... .'.,-,,4 ~.,, \--/ ,-.-~,~ ,.,, ~ , 4. Related claims pending: None 5. Complete either (a) or (b). (a) n.,,.. p,"'3OOlpC +'" + ..... ;* ..... ,4 C '""" 0¢ ,.,k;,-.~. % .......... (b) Date Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: December ,2002 Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: December ,, 2002,,'3 Carol J. Lirf'dsa~,, ;~t[orney for Plaintiff SAIDIS SHD-FF, FLOWER & LINDSAY AITORNEYS.AT.LAW 26 W. High Street Carlisle, PA BONNIE L. SCHULT, PLAINTIFF V. WERNER A. SCHULT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · NO. 2002- 3596 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this ]~"'f/'/ day of /~'pJ/.~,~'~,E',~ ,2002, BETVVEEN WERNER A. SCHULT, of 4621 Holtzschwamm Road, Thomasville, York County, Pennsylvania 17364, hereinafter referred to as Husband, AND BONNIE L. SCHULT, of 929 Nixon Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, hereinafter referred to as Wife· RECITALS: R.I: The parties hereto are husband and wife, having been joined in marriage on, February 15, 1992 in Thomasville, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 2002-3596 Civil Term on July 29, 2002; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite· R4: The parties also desire to settle their issues of Counsel fees and costs, and the settling of any and all claims and possible claims against the other or SAIDIS SHUFF, FLOWER & LINDSAY ATTOP. A~:YS.AT*LAW 26 W. High Street Carlisle, PA against their respective estates. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: ('1) SEPARATION: It shall 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 from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. On or about December '1, 2002, the parties shall execute and file an Affidavit of Consent and Waiver of Notice Forms, necessary to finalize said divorce. (3) REAL PROPERTY: The parties are the owners of a house at 462'1 Holtzschwamm Road, Thomasville, York County, Pennsylvania encumbered by a SAIDIS SHUFF, FLOWER & LINDSAY A'ITORNEYS*AT.LAW 26 W. High Street Carlisle, PA mortgage for which Husband is solely liable. Within 45 days of the date of this agreement, Husband will pay to Wife $10,000.00 in full satisfaction of her interest in the marital estate, including the marital home, and on the same date as that payment is made, Wife will provide to Husband a special warranty deed transferring to him all her right, title and interest in the marital home. Husband shall pay for all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify her from any loss thereon. (4) DEBT: A. MARITAL DEBT: Husband and Wife acknowledge and agree that there are no outstanding debts and obligations in the name of one party, individually or jointly, for which the other might be liable. Each party commits to paying any debt titled in his or her name. Each party shall pay the outstanding debts in his or her and agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations. B: POST SEPARATION DEBT: In the event that either party contracted or incurred any debt since the date of separation on July 18, 2002, the party who incurred said debt shall be responsible for the payment thereof regardless 3 SAIDIS SHUFF, FLOWER & LINDSAY AITORNEYS*AT.LAW 26 W. High Street Carlisle, PA of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Within 10 days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Wife will retain the 1989 Ford Ranger and Husband will retain the 1990 Ford F-150 and the 1986 Firebird. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the 4 SAIDIS SHUFF, FLOWER & LINDSAY ATlCORNEYS,AT,LAW 26 W. High Street Carlisle, PA sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like. (8) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Wife is represented by Carol J. Lindsay and Husband has been advised that he may be represented by counsel of his choice. Each party acknowledges and accepts that SAIDIS SHUFF, FLOWER & LINDSAY ATr0RNEYS~,AT,,LAW 26 W. High Street Carlisle, PA this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. {10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) INCOME TAX: and State Tax returns. Both The parties have heretofore filed joint Federal parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or 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. {12) BANKRUPTCY: The parties hereby agree that the provisions of this SAIDIS SHUFF, FLOWER & LINDSAY ATtORNeYS*AT*LAW 26 W. High Street Carlisle, PA Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. ('13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. ('14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. ('15) FULL SETTLEMENT: Except as herein otherwise provided, each SAIDIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS.AT*LAW 26 W. High Street Carlisle, PA party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. ,All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. ,All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; SAIDIS SHUFF, FLOWER & LINDSAY ATrOP,,NEYS*AT*LAW 26 W. High Street Carlisle, PA D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: and (2) (3) to take against the other's will; under the laws of intestacy; to a family exemption or similar allowance; (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party 9 SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS.AT*LAW 26 W. High Street Carlisle, PA now has, or may hereafter have, against or with respect to the other. (17) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other 10 SAIDIS SHUFF, Iq,OWF, R & LINDSAY ATrOP. NE¥S*AT*LAW 26 W. High Street Carlisle, PA than those herein contained. (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: - - / ~/ Bonni~ L.'SChult - - Werner A. Schult NOTARIAL SEAL Gregory L. Brer~neman, Notary Public West Manchester' Twp., York County My Commission Expires Feb. 17, 2006 IN THE COURT Of COMMON PLEAS Bonnie L. Schult, Plaintiff VERSUS Werner A. Schult, Defendant Of CUMBERLAND COUNTY NO. 2002-3596 Decree IN DIVORCE AND NOW,~ ,~ RED AND DECREED THAT Bonnie L. Schult , PLAINTIFF, Werner A. Schult AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; NONE. The terms of the Property Settlement Agreement dated November 18, 2002 are incorporated, but not merged, into this Decree in Divorce. PrOThONOTArY