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:l IN THE COURT OF COMMON PLEAS *
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lI!i OF CUMBERLAND COUNTY 8
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:1 STATE OF '* PENNA. :
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~ GA~LE L. ijOLINGER, *
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8 Plaintiff *
8, \'..1'"11,, CIVIL ACTION - LAW 8
8 RICHARD D. WHITE, JR., IN DIVORCE 8
~ Defendant 8
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! AND Now........_tJ/h.,,':'..1-...... 199?..._. it is ordered and ~
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8 are divorcflc1 from ~he bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not vet
been entered;
NONE
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GAYLE L BOUNGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
v.
CIVIL ACTION - LAW
94-5542 CIVIL TERM
RICHARD D. WHITE, JR.,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following infonnation, to the court for entry of a
divorce decree:
1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: On or about September 4, 1994 the
defendant was served with a copy of the divorce complaint via certified mail, "restricted delivery",
with Return Receipt No. P 282 342 364 addressed to him at 306 South Hanover Street,
Apartment #3, Carlisle, PeMSylvania 17013.
3. Date of execu'don of the affidavit of consent required by Section 3301(c) of the
Divorce Code:
By the plaintiff:
January 23. 1995
By the defendant:
January 23, 1995
4. Related claims pending: None
January 23
,1995
LZ!-
GAYLE L BOLINGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLV ANlA
CMLACfION. LAW
94. 55J >CIVIL TERM
IN DIVORCE
RICHARD D. WHITE, JR.,
Derendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in divorce or annulment may be entered against you by the
court. A judgment may also be entered against you for any other claim or relief requested in these
papers by the plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT BA VE 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 Administrator
Cumberland County Courthouse
1 Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
'1'.249.6200
GAYLE L BOLINGER,
PIalDtlft'
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENSSYLVANIA
CIVIL ACTION. LAW
9....5542 CIVIL TERM
RICHARD D. WHITE, JR.,
Defendant
IN DIVORCE
dFFlDA VIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R,CP. RULE NO. 1920.4 (a)(1) (I),
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
NOW. Marcus A McKnight, lII, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the complaint in divorce was served upon the defendant on
September 4, 1994. by certified mail, "restricted detivery", addressed to him at 306 South
Hanover Street, Apartment #3, Carlisle, Pennsylvania 17013, Return Receipt No. P 282 342 364.
3. That the said receipt for certified mail is signed and is attached hereto and made a part
hereof.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. . Section 4904, relating to
unsworn falsification to authorities
January 6,1995
HT, m, ESQUIRE
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HR RICHARD D WHITE.JR
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DOMESTIC RETURN RtCE""
GAYLE L. BOUNCER,
Plalntlll'
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
RICHARD D. WHITE. JR.,
Defendant
94-!s.tl CIVIL TERM
IN DIVORCE
STlPVLA nON
AND NOW, this 15th day of March, 1995, come the parties to this action and malte the
following stipulation:
1.
The plaintiff is Gayle L. Bolinger, an adult individual residing lit 7 South Acorn Drive,
Boiling Springs, Pennsylvania 17007, with a social security number ofJ07-56-9830.
2.
The defendant is Richard D. White, Jr., an adult individual residing at 306 South Hanover
Street, Apt. 3, Carlisle, Pennsylvania 17013, with a social security number of230-56-7670.
3.
The parties entered into a Maniage Settlement Agreement a copy of which is attached
hereto and marked as Exhibit "A" and is made a part of that stipulation.
4.
The parties now desire the enlry of an Order of Coun which specifically addresses the
subject of the Coast Guard Pension oflhe defendant.
VERIF,CA TIO.N
The fDregoina Stipulation contains facts which are true and correct to the best of my
knowledge, infonnation and belief. I understand that false statements herein made are aubject to
the penalties of 18 Pa.C.S.A Section 4904, relating to unsworn falsification to authorities.
~~ h ~r
RICHARD D. WHITE, JR.
Date: March \ 5'"' . 1995
J
sale or exchange of assets. The parties also agree that tbey desire to resolve the issues regarding
the support and custody of their minor children, Andrew Bolinger White, born June S, 1985, age
9, and Elissa Bolinger White, born September I 1,1987, age 7.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may sele~1 as they have heretofore been doing. Neither party shall
molest. harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his Dr her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admllled by the pan ie" and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
(I) is represented by counsel of his or her own choosing;
(2) is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
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(S) has carefully read each provision of this Agreement; and
(6) fully and compl~tely understands each provision of this Agreement, both as to
the IUbject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
S.
It is tht purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and aU property that would
qualify as marital property under the PeMsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their beirs and
assigns. The parties bave attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
a~sets, and the division is being effected without the introduction of outside funds or other
property not cOllstituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
IInder the PeMsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure ofall debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts Dr transfers for inadequate consideration of
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Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by Dr on behalf of ~ither or both Parties during
marriage.
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7.
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REAL ESTATE: HUSBAND agrees to convey all right, title and interest which he bas
in the real estate situate at 7 South Acorn Drive, Boiling Springs, PeMSylvania 17007, and any
equity there to WIFE. WIFE agrees to hold harmless HUSBAND from any obligation and
payment from the Mortgage on said real estate. If HUSBAND attempts to purchase real estate
and he is turned down by three (3) mortgage lenden which cite as the sole reason for the denial
the existance of the joint mortgage with WIFE, WIFE agrees to refinance said mortgage within
120 days of said proof received from HUSBAND.
8.
SPOUSAL SUPPORT: It is the mutua! desire of the parties that HUSBAND will not be
required to pay support to the WIFE. WIFE will not provide any financial support to the
HUSBA\,'O. The parties also waive any right they have to receive alimony payments from the
other following the entry of the Divorce Decree in this mailer.
9.
CHILD SUPPORT: HUSBAND will pay the sum of Five Hundred and no/loo
(S500.00) Dollars per month as support for Andrew Bolinger White and the sum of Five Hundred
and no/I 00 ($500.00) Dollars per month for Elissa Bolinger White. WIFE will be entitled to use
both children as federal income tax exemptions.
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HUSBAND agrees to continue paymenl of child support until each child attains the age of
eighteen (18) years. The duty of HUSBAND to pay child support will end for each respective
child upon the marriage of said child, the child no longer being a full.time student, or said child
attaining the age of eighteen (18) years.
The parties agree that said support payments will be made directly between the parties.
WIFE has the option to make the support an Order of Court through Domestic Relations if
HUSBANl) fails to make the payments as set forth herein.
The parties acknowledge that the ConunDnwealth of Pennsylvania has established a
fonnula and guidelines for the determination of and level of child support which is presumed to be
the appropriate amount. The parties further acknowledge that they are aware of the Pennsylvania
statutes applicable to child support, understand them, and have had a full opportunity to discuss
them with counsel of his or her own choosing. The parties further stipulate that they agree the
amount set forth herein is the appropriate level of child support payable, notwithstanding the
statutory guidelines for child support, and both parties hereby waive the application of the
statutory guidelines to child support payable by HUSBAND to WIFE.
h is agreed that either party may hereafter petition any court having jurisdiction of this
cause for an increase or decrease of child support showing of substantial changes in the financial
circumstances of either such part or the children.
The parties agree that as long as support payments are due the HUSBAND will carry and
maintain life insurance in the amount of $ 1 00,000.00, naming Andrew Bolinger White and Elissa
Bolinger White Dr a trustee as sole irrevocable beneficiaries. The HUSBAND will provide the
WIFE with annual proof of such coverage.
The parties further agree that as long as support payments are due the WIFE will carry
and maintain life insurance in the amount of $200,000.00 naming Andrew Bolinger White and
Elissa Bolinger White or a trustee as sole irrevocable beneficiaries. The WIFE will provide the
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HUSBAND with annual proof of such coverage.
The parties agree that the WIFE will carry and maintain adequate health and
hospitalization insurance for the children as long as she is employed by Dickinson College. If, in
the future, she is no longer employed by Dickinson College, HUSBAND agrees to carry and
maintain adequate medical and hospitalization insurance for the ~hildren for as long as support
payments are due. The parent obligated to provide such insurance will provide the other parent
with annual proof of such coverage.
The husband agrees to maintain Survivor Benefit Plan annuity coverage for the children
for as long as they are eligible beneficiaries.
As additional child support, the parties agree to the following:
a. If the children's combined medical and dental bills exceed $600.00
in any given year and the WIFE is providing their medical
insurance coverage, the HUSBAND agrees to reimburse the WIFE
for any amounts not reimbursed to her by insurance. The WIFE
will cooperate by providing the HUSBAND with any
documentation he needs to file a claim with CHAMPUS.
b. The HUSBAND will pay 50% of the cost of auto insurance for
each child w hen he or she stans 10 drive.
The parties agree, until all obligations for support payments under this Agreement have
tenninated, to exchange their income tax returns, with all attachments and evidence of gross
income, for the prior year in April after the returns have been filed.
10.
CUSTODY OF THE CHILDREN: The parties agree that custody of Andrew Bolinger
White, born June 5,1985, age 9, and Elissa Bolinger White, born September 11,1987, age 7, will
6
be Ii follows:
a. The parties will have joint legal custody of Andrew and Elissa.
b. WIFE will have primary physical custody of Andrew and Elissa,
c. HUSBAND will have the following periods of physical custody of
Andrew and Elissa.
i. Every other weekend from 3:30 P.M. on Friday until 9:00 A.M.
on Monday morning;
ii. On the remaining Fridays, from 3:30 P.M. until the bedtime of the
children;
iii. The following vacation periods each year: three weeks during the
summer vacation of the children, the children's Easter vacation,
and Labor Day.
iv, The following holidays on even years; New Year's Day, Fourth of
July, Christmas Day as well as the school vacation days between
Christmas and New Year's Day. The following holidays on odd
years; Memorilll Day, Thanksgiving vacation, and Christmas Eve.
v. Any other periods of time the parties believe to be in the best
interests of the children.
d. If the parties are unable to agree on periods of HUSBAND'S custody of
the children, they agree to seek the services of a mediation service to
resolve their differences before resorting to custody litigation in the
Courts.
e. The parties agree that major decisions pertaining to discipline, education,
health, extracurricl:lar and summer activities, travel (other than normal
vacations), religious training. medical and dental care, and welfare of the
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children will be decided by both parents after reasonable and adequate
discussion. The parties also agree that the parent with physical custody
shall have control over the minor day-to-day decisions affecting the
children, including any medical or d.:ntal emergencies. The parties
further agree that if, after reasonable allempts, they are unable to rea"h
an agreement on any of the decisions affecting their children, they will
jointly seek professional mediation to resolve their differences.
f. The parties also agree that each has the right to know of any
circumstances or decisions that affect the children and that each has the
right to any medical, dental, Dr school records of their children. Neither
party will do anything to hamper or interfere with the natural and
continuing relationship between the children and the other parent.
11.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided as follows to the satisfaction of the parties:
a. The WIFE will receive the following:
i. All the funds in Vanguard Pnme Money Market Account #9846152391;
ii, All the funds in Vanguard Prime Money Market Account #9863221739;
iii. All the funds in Vanguard Index Trust Fund:
iv. All the funds in Members First Credit Union in both the joint and in
WIFE'S individual account;
v. WIFE'S individual retirement accounts;
vi. WIFE'S nAAlCREF retirement accounts;
vii. All of the furniture and personal property located at the real estate;
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viii. Her own automobile.
b.
The HUSBAND will receive the following:
I. All of the funds located in the USAA Savings Bank in the joint account;
n. All ofthe funds in the MEMBERS FIRST CREDIT UNION in his
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individual account;
All of the funds in the FAA Credit Union in his individual account;
iv. HUSBAND'S individual retirement account;
v. HUSBAND'S own automobile;
vi. All of his personal belongings and furnishing in his possession.
The WIFE hereby waives all right and title which she may have in any personal property of
the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property
of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any
claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of
same as fully and effectually, in all respects and for all purposes as ifhe or she were unmarried.
Each party agrees that neither will ir,cur obligations, liens Dr liabilities on account of the
DIner and th~t from the dale of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
12.
HUSBAND'S MILITARY RETIREMENT PENSION: The parties acknowledge that
HUSBAND has retired from active service with the United Stated Coast Guard after perfonning
in excess of twenty (20) years of creditable military service toward retirement. The parties further
acknowledge they were married for fourteen (14) years and their entire marriage coincided with
9
the Member's active duty military servi~. By reason of his former military service. HUSBAND
or "Member" now receives retirement pay which c:onslitutes marital property. He herehy assigns
to WIFE or "Former Spouse" an annuity that equals 28% of the Member's total (gross) military
retired pay less the premium to provide a survivor benefit annuity for the Former Spouse. The
Former Spouse will also be entitled to 28% of any cost of living increases received by thc
Member. Direct payment of the Former Spouse's share of the Membcr's military rctired pay shall
bc made dircctly by thc appropriatc military disbursing office to the Formcr Spouse. If the
Member's gross military retired pay is further reduced by government employment. or for any
othcr rcason, and the Former Spouse docs not receive directly from the appropriate military
disbursing office the full amount due to her under this order, the Membcr agrees to pay directly to
thc Formcr Spouse the differcnce caused by any reduction in pay
It is specifically understood that Member guarantees to the Former Spouse that he sha1l
not mergc his military pcnsion with any other government pension nor lake any action whatsoevcr
so as to defeat the Former Spousc's right to share in the monthly military retircd pay and bencfits
as set forth in this Agrcement. Member agrees to indemnil)o the Former Spouse regardless of
whether the Member mergcs his military retirement with any future govcrnment or othcr
employmcnt retirement at the same rate and amount that would have been paid to her in thc
absence of any such merger.
The Fonner Spouse's right to receive a retirement annuity pursuant to this order shall
cornmence January I, 1995. and shall continue as long as the Member has a right to receivc such
payments. and shall terminate on the death of the Member or the Fonner Spouse. whichevcr
occurs first. The entitlement of the Fonner Spouse to share in the Member's retired pay shall not
terminate upon her remarriage.
The parties believe that all of the statutory requirements under the Uniformed Services
Former Spouses' Protection Act havc been met 10 as to allow the Former Spouse to qualifY for
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direct payment of hcr share of the Member's military retired pay from the appropriate military
disbursing office. However, thc Former Spouse's entitlement to receipt of her specified share of
the military retired pay is not dependent upon such direct payment. If the military disbursing
office determines that payment of the full amount due to the Former Spouse under this order
cannot be made directly to the Former Spouse for any reason, direct payment shall be made of the
maximum amount permissible in accordanc!: with existing law and regulations. In the event that
Member receives all or any portion of the payments which, pursuant to this order, should have
been paid to the Former Spouse, including amounts received by the Member prior to
implementation of direct payment and sums which the military disbursing office has detcrmined
cannot be paid directly to the Former Spouse, the Member shall be deemed to be a constructive
trustee of such amounts for the Former Spouse's benefit and shall pay same to her within three (3)
days of receipt. In the event the Fonner Spouse receives any portion of the payments which,
Jhlrsuant to this order, should have been paid to the Member, she shall be deemed to be a
constructive trustee of such amounts for the Member's benefit and shall pay same to him within
three (3) days of receipts. The parties shall cooperate as appropriate to avoid overpayment to
either the Member of the Former Spouse. The Member shall furnish the Former Spouse with
documentation evidencing his receipt of military retired pay and the apportionment between the
Member and the Former Spouse no less frequently than every six months.
The Member shall not take any action that would defeat or adversely affect the right of the
Fonner Spouse to receive her specified percentage of his retired payor that would cause a
reduction of or limitation in the amount of the military retired pay to which the Former Spouse is
entitled pursuant to this order. The Member shall indemnify and hold the Former Spouse
harmless with regard to this provision.
To the extent required by law, each party shall be responsible for payment of all Federal
and State income taxes attributable to the share of the military retired pay received by him or her,
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and each shall prepare and tile appropriate withholding fOIlTlJ with the military disbursing office
for this purpose. If the Member receives credit for taxes withheld which pertain to the Fonner
Spouse's share of the retired pay, the Fonner Spouse shall be entitled to credit luch wlthholdings
against the taxes imposed on her share of the retired pay, and the Member Ihall Instruct the
appropriate Federal and State taxing authorities to 10 apply such wlthhDldings to the Fonner
Spouse's credit.
At the time of his retirement from the United States Coast Guard, the Member elected an
lMuity for the Fonner Spouse under the Survivor Benefit Plan in the maximum amount pennilted
by law. The Member shall immediately take all necessary steps to designate the Fonner Spouse as
the sole beneficiary of a fonner spouse survivor's benefit annuity in the maximum amount allowed
by law, to the exclusion of any future wife or future dependent children of the Member. If the
Member dies beforo making this election, he shall be deemed to have made the election required
by this provision, and the Former Spouse shall be entitled to the maximum pennisaible survivor's
annuity.
13.
MARITAL DEBTS: Each party will be responsible for their own debt incurred after the
date of separation and asrees to hold harmless the other from any debt associated with their
automobiles set forth above.
14.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE Dr any other employee benefits, Including
but not limited to retirement, profit sharing Dr medical benefits of either party, shall be their own
except as specifically provided In this Agreement. WIFE waives all right, title and claim to
HUSBAND's employee benefits except the retirement as provided in Parasraph Twelve (12) of
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this Agreement, and HUSBAND waives all right, tide, and claim to any of WIFE'S employee
benefit., except that WIFE agrees to maintain HUSBAND on her health and dental insurance plan
through her place of employment until the divorce is final. Thereafter any health coverage will be
dependent on HUSBAND'S payment for said coverage as well II the WIFE'S continued
employment and Dickinson College. Notwithstanding the above, WIFE may maintain the life
insurance policy which she owns on the life of the HUSBAND.
IS.
BENEFfI:S AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE.
16.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce. Otherwise each party shall pay all
of their own respective counsel fees.
17.
BREACH: If either party breaches any provisions of this Agreement, the other party sha1l
have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
13
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.
'.
18.
ADDITIONAL INSTRUMENTS: Each of the panies .hall from time to time, at the
request of the other, execute, acknowledge and deliver to the other puty any and all t\lrther
instruments that may be reasonably required to &ive full fDree and effect to the provisions of this
Agreement.
19.
VOLUNTARY EXECUTION: The provisions of thi. Agreement and their legal effect
have been fully explained to the panies by their respective eounsel, and each party acknowledges
!hat the Agreement is fair and equitable, and th.t it is being entered into voluntarily, and that it is
not the result of any duress or undue influence. The provisions of this Agreement are fully
understood by both parties and each party scknowledges that the Agreement is fair and equitable,
that it is being entered into voluntarily, and that it i. not the result of any duress or undue
influence.
20.
ENTIRE AGREEMENT: Thi. Agreement eonlains the entire understanding of the
panies anL there are no represenlations, warranties, eovenants or undenakings other than those
Ilxpressly set fonh herein
21.
APPLICABLE LAW: This Agreement .hall be eonstrued under the Law. of the
Commonweahh of Pennsylvania
14
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, ,
22.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may Dr have been executed prior to the date and time of this
Agreement are null and void and of no effect.
23.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each part)' hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widows
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
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 intereats, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year lilSl above wrillen.
;J:. kdY~
, GA ifE L. BOLINGER
(SEAL)
(SEAL)
RICHARD D. WHITE,
15
c
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1 i
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7
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t.
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNlY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, thi~day ofJanuary, 1995,' Notary
Public, in and for the Commonwealt~; of Pennsylvania and County of Cumberland, OA YLE L
BOLINGER, known to me (or satisfactorily proven) til be the person whose name i. .ubscribed
to the within Marriage Settlement Agreement, and acknowledge. that she executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
;'
Nola.'iaI Seal
_A. Mllnisa1. NrAiuy I'IJl1ic
CarlsIo Bora. OJlT'lJet1ard O;J.rtJ
...,~~Doc. 15.1006
-
COMMONWEALTH OF PENNSYL VANIA
S5:
COUNlY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this~ay of January, 1995, . Notary
Public,; i i:d for Ih~ Commonwealth ofPennsy'vania and County ofCumberlanJ, RICHARD D.
WHITE, JR., known to me (or satisfactorily proven) to be the person whose name is subscribed
to the within Marriage Settlement Agreement , and acknowledges that he executed the same for
the purposes therein contained.
IN WITNESS WHEREOF,I have hereunto set my hand and official seal.
NotanJI SroI
BotzI A. Momsa'. Ml;Jry PLtIic
Catto;IoBora.CUlTCer\.wC",nl',
...,CoMtiooonI:>.....O'C,'~. liJC.<i
OOC""AMlln,'i^ MIA-B . PtxnYN.lI'W I of t"~IUf(,$
16
GA YLE L. BOLINGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V AN IA
v.
CIVIL ACTION - LAW
RICHARD D. WHITE, JR.,
Defendant
94-5542 CIVIL TERM
IN DIVORCE
ORDER OF COURT
AND NOW, this --2b day of ~ ~
,
, 1998, upon consideration of the
attached Amended Marriage Settlement Agreement, the tenns of said document are entered as an
Order of this Court.
By Jhecourt:
'C
EDGAR B. BA YL~Y, JUDGE
-
5.
The parties desire that the tenns of the Amended Marriage Settlement Agreement be
made an Order Dflhe Court.
AND NOW, intending to legally bound, the parties enter their hands and seals,
WITNESSETH:
j . J/J ,..&..- . (SEAL)
~ING~
R~)dLk~~~~(sEALl
~/.. ~ ~'IA
2
..fJIJ::NDED
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MARRIAGE SETTLE.~/ENT AGREEMENT
THIS AGREEMENT made this ~ d..y of J.~, 1998, by and between
GA YLE 1.. BOLINGER, (hereinalier referred III as "wY,,) and RICHARD D. WHITE,
JR., (hereinaftcr refcrred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on May 24, 1980 in Portage,
Indiana; and were separated on July I, 1994. The parties were divorced on February I. 1995 at
94-5542 Civil Term.
The parties hercto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be linal and shalllorever detennine their respective rights.
The division of e~isting marital property is not intended by the parties to constitute in any way a
sale or e~change of assets. The parties also agree that they desire to resolve the issues regarding
the support and custody of their minor children, Andrew Bolinger White, born June 5. 1985. age
9, and Elissa Bolinger White, born September II, 1987, age 7.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have hereto lore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any mailer whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and bene lit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specilied
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respecti vely:
( I) is represented by counsel 0 I' his or her own choosing;
(2) is fully and completely inlonned of the lacts relating to the subject mailer of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agreement; and
(6) fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the purpose and intent of this Agreement to settle forever and completely the intcrest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Codc, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge. lien.
charge. security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts an,1
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Fedcral Tax Returns filed by or on behalf of either or both Parties during
marriage.
3
7.
REAL ESTATE: HUSBAND agre:e:s to convey all right, title: and inte:rest which he has
in the: real estate situate at 7 South Acorn Drive, Boiling Springs, Pennsylvania 17007, and any
equity there to WIFE. WIFE agrees to hold harmless HUSBAND from any obligation and
payment from the Mortgage on said real estate:. If HUSBAND allempts to purchase real estate
and he is turned down by thrce (3) mortgage Ie:nders which cite as the sole reason for the denial
the existence of the joint mortgage with WIFE, WIFE agrees to retinance said mortgage within
120 days of said proof received from HUSBAND.
8.
SPOUSAL SUPPORT: It is the mutual desire of the parties that HUSBAND will not be
required to pay support to the WIFE. WIFE will not provide any financial support to the
HUSBAND. The parties also waive any right they have to receive alimony payments from the
other following the entry of the Divorce Decree in this mailer.
9.
CHILD SUPPORT: HUSBAND will pay the sum of Five Hundred and Seventy Five
and no/100 ($575.00) Dollars per month as support tor Andrew Bolinger White and the sum of
Five Hundred and Seventy Five and no/IOO (S575.00) Dollars per month for Elissa Bolinger
White. WIFE will be entitled to use both children as federal income tax exemptions. The duty
of HUSBAND to pay child support will end for each respective child upon the marriage of said
child or when said child graduates from high school.
The parties agree that said child support payments will be made directly between the
parties. WIFE has the option to make the: support an Order of Court through Domestic Relations
if HUSBAND fails to make the payments as set tonh herein.
The parties acknowledge that the Commonwealth of Pennsylvania has established a
tormula and guidelines for the determination of and level of child support which is presumed to
4
be the appropriate amount. The parties further acknowledge that they arc aware of the
Pennsylvania statutes applicable to child support. understand them. and have had a full
opportunity to discuss them with counsel of his or her own choosing. The parties further
stipulate that they agree the amount set forth herein is the appropriate level of child support
payable. notwithstanding the statutory guidelines for child support, and both parties hereby
waive the application of the statutory guidelines to child support payable by HUSBAND to
WIFE.
It is ab'Teed that either party may hereafter petition any court having jurisdiction of this
cause for an increase or decrease of child support showing of substantial changes in the financial
circumstances of either such part or the children.
The parties agree that as long as support payments are due the HUSBAND will carry and
maintain life insurance in the amount of $1 00,000.00, naming Andrew Bolinger White and Elissa
Bolinger White or a trustee as sole irrevocable beneticiaries. The HUSBAND will provide the
WIFE with annual proofofsuch coverage.
The parties further agree that as long as support payments are due the WIFE will carry
and maintain life insurance in the amount of 5200,000.00 naming Andrew Bolinger White and
Elissa Bolinger White or a trustee as sole irrevocable beneticiaries. The WIFE will provide the
HUSBAND wi:h annual proof of such coverage.
The parties agree that the WIFE will carry and maintain adequate health and
hospitalization insurance for the children as long as she is employed by Dickinson College. If, in
the future, she is no longer employed by Dickinson College, WIFE will carry comparable
coverage if available from her new employer. If said coverage is not available from her new
employer, HUSBAND agrees to carry and maintain adequate medical and hospitalization
insurance for the children for as long as support payments are due. The parent obligated to
provide such insurance will provide the other parent with annual proof of such coverage.
The husband agrees to maintain Survivor Benetit Plan annuity coverage for the children
for as long as they are eligible beneticiaries.
s
As additional child support, the parties agree to the l(lllowing:
a. If the children's combined medical and dental bills exceed S600.00
in any given year and the WIFE is providing their medical
insurance coverage, the HUSBAND agrees to reimburse the WIFE
for any amounts not reimbursed to her by insurance. The WIFE
will cooperate by providing the HUSBAND with any
documentation he needs to tile a claim with CHAMPUS.
b. The HUSBAND will pay 50% of the cost of auto insurance for
each child when he or she starts to drive.
The parties agree, until all obligations for support payments under this Agreement have
tenninated,to exchange all their W-2 lonns, I099R fonns, and 1099 lonns related to any
employment or contract work as evidence of gross income lor the previous year. Said lonns lor
the previous tax year will be exchanged on or before March I of each year.
10.
CUSTODY OF THE CHILDREN: The parties agree that custody of Andrew Bolinger
While, born June 5, 1985, age 9, and Elissa Bolinger White, born September II, 1987, age 7,
will be as follows:
a. The parties will have joint legal custody of Andrew and Elissa.
b. WIFE will have primary physical custody of Andrew and Elissa.
c. HUSBAND will have the following periods of physical custody of
Andrew and Elissa.
i. In even years: the children's October holiday, Christmas
vacation, February holiday, Easter vacation, and four (4) weeks
in the summer, preferably divided into two, two-week periods,
6
II. In odd years: the !:hildren's Thanksgiving vacation. Fehruary
holiday, Easter vacation. and four (4) weeks in the summer.
preferably divided into two. two-week periods.
iii. Any other periods of time the parties believe to be in the bllst
interest of thll children.
d. If the parties are unable to agree on periods of HUSBAND'S custody of
the children, they agree to seek the serviclls of a mediation service to
resolve their differences betiJre resorting to custody litigation in the
Courts.
e. The parties agree that major decisions pertaining to discipline,
education, health, extracurricular and summer activities, travel (other
than nonnal vacations). religious training, medical and dental care, and
welfare of the children will be decided by both parents after reasonable
and adequate discussion. The parties also agree that the parent with
physical custody shall have control over the minor day-to-day decisions
affecting the children, including any medical or dental emergencies. The
parties further agree that it: atter reasonable attempts, they are unable to
reach an agreement on any of the decisions affecting their children, they
will jointly seek professional mediation to resolve their differences.
f. The parties also agree that each has the right to know of any
circumstances or decisions that affect thc children and that each has the
right to any medical, dental. or school rccords of their children. Neither
party will do anything to hamper or interfere with the natural and
continuing relationship between the children and the other parent.
7
g. HUSBAND agrees to pay the round trip airfare for the ,hildren to tly
frum Dulles International or aWl airports during the times he has physical custody,
HUSBAND agrees to provide tickets or continnation of electronic tickets prior to two
(2) weeks from the scheduled departure of said ,hildren. HUSBAND further agrees to
reimburse WI FE for the round trip mileage or I;osts incurred as a result of transporting
the children. Eliss~. and Andrew, to and from Dulles International or BWI airports at the
mileage rate set by the IRS tor business travel whenever they visit their father.
Reimbursement of WIFE'S expenses will be made within fifteen (IS) days of the
children's return home to WIFE
II.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided as tollows to the satisfaction of the parties:
a. The WIFE will receive the following:
i. All the funds in Vanguard Prime Money Market Account #9846152391;
ii. All the funds in Vanguard Prime Money Market Account #9863221739;
iii. All the funds in Vanguard Index Trust Fund:
iv. All the funds in Members First Credit Union in both the joint and in
WIFE'S individual account;
v. WIFE'S individual retirement accounts;
vi. WIFE'S TlAAlCREF retirement accounts;
vii. All of the furniture and personal property located at the real estate;
viii. Her own automobile.
b. The HUSBAND will receive the tollowing:
i. All of the funds located in the USAA Savings Bank in the joint account;
8
ii. All of the funds in the MEMBERS FIRST CREDIT UNION in his
individual account;
iii. All of the funds in the FAA Credit Union in his individual account;
iv. HUSBAND'S indivirlual retirement account;
v. HUSBAND'S own automobile;
vi. All of his personal belongings and fumishing in his possession.
The WIFE hercby waives all right and title which she may havc in any personal property
of t~e HUSBAND. HUSBAND likewisc waivcs any interest which hc has in the personal
property of the WIFE. Hencelorth, cach of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated. which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of
same as fully and effectually, in all respects and for all purposes as ifhe or she were unmarried.
Each pany a!.t'J'ees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
12.
HUSBAND'S l\IILIT ARY RETIREMENT PENSION: The parties acknowledge that
HUSBAND has retired from active service with the United Stated Coast Guard after perfonning
in excess of twenty (20) years of creditable military service toward retirement. The parties
lurther acknowledge they were married for fourteen (\4) years and their entire marriage
coincided with the Member's active duty military service. By reason of his fonner military
service, HUSBAND or "Member" now receives retirement pay which constitutes marital
property. He hereby assigns to WIFE or "Fonner Spouse" an annuity that equals 28% of the
Member's total (gross) military retired pay less the premium to provide a survivor bene lit annuity
for the Fonner Spouse The Fonner Spouse will also be entitled to 28% of any cost of living
9
Increases received by thc Mcmbcr. Direct paymcnt of thc Fonncr Spousc's sharc of thc
Membcr's military rctired pay shall bc madc dirc:ctly by thc appropriate military disbursing ofticc
to the Fonner Spousc. If the Member's gross military retired pay is further reduccd by
government employment, or lor any other reason. and the Fonner Spouse does not receive
directly !Tom the appropriate military disbursing ollice the full amount due to her under this
order. the Member agrees to pay directly to the Fonner Spousc the differencc caused by any
reduction in pay.
It is specilically understood that Mcmbcr guarantees to the Fonncr Spouse that hc shall
not merge his military pension with any other government pension nor take any action
whatsoever so as to dcfeat the Fonner Spousc's right to share in the monthly military retired pay
and benelits as set forth in this Agreemcnt. Membcr agrces to indemnify the Fonner Spouse
regardless of whether the Member merges his military retirement with any future government or
other employment retirement at the samc ratc and amount that would have been paid to her in the
absence of any such mcrger.
The Fonner Spouse's right to receivc a retirement annuity pursuant to this order shall
commence January I, 1995. and shall cuntinue as long as the Membcr has a right to receive such
payments, and shall tenninate on the death of the Member or the Fonner Spouse, whichever
occurs first. The entitlement of the Fonner Spouse to share in the Member's retired pay shall not
tenninate upon her remarriage.
The parties believe that all of the statutory requirements under the Unifonned Services
Fonner Spouses' Protection Act have been met so as to allow the Fonner Spouse to qualify for
direct payment of her share of the Member's military retired pay !Tom the appropriate military
disbursing oflice. However, the Fonner Spouse's entitlement to receipt of her specified share of
the military retired pay is not dependent upon such direct payment. If the military disbursing
ollice detennines that payment of the full amount due to the Fonner Spouse under this order
cannot be made directly to the Fonner Spouse for any reason, direct payment shall be made of
the maximum amount pennissible in accordance with existing law and regulations. In the event
10
that Member re.eives all or any portion of the payments whi<.:h. pursuant to this order, should
have becn paid to thc Former Spouse, induding amounts rcceived by the Member prior to
implemcntation of direct payment and 3ums which the military disbursing office has detcrmincd
cannot be paid dircctly to the Former Spouse, the Member shall be deemcd to be a constructive
trustce of such amounts tor the Former Spousc's bcnetit and shall pay same to her within thrce
(3) days of receipt. In the event the Former Spouse re.eivcs any portion ofthc paymcnts which,
pursuant to this order, should have been paid to the Member, she shall be decmed to be a
constructive trustce of such amounts tor the Mcmber's bcnetit and shall pay samc to him within
three (3) days of receipts. The parties shall cooperate as appropriate to avoid overpayment to
either the Member of the Former Spouse. The Member shall furnish the Former Spousc with
documentation evidencing his receipt of military retired pay and thc apportionment between the
Member and the Former Spouse no less frequently than every six months.
The Member shall not take any action that would dcfeat or adversely affect the right of
the Former Spousc to receive hcr specified percentage of his retired payor that would cause a
reduction of or limitation in the amount of the military rctired pay to which the Fonner Spouse is
entitled pursuant to this order. The Member shall indemnify and hold the Former Spouse
harmless with regard to this provision.
To the extent required by law, each party shall be responsible for payment of all Fedcral
and State income taxes attributable to the share of the military retired pay rcceived by him or her,
and each shall prepare and file appropriate withholding forms with the military disbursing office
for this purpose. If the Member receives credit for taxes withheld which pertain to the Former
Spouse's share of the retired pay, the Former Spouse shall be entitled to credit such withholdings
against the taxes imposed on her share of the rctired pay, and the Member shall instruct the
appropriate Federal and State taxing authorities to so apply such withholdings to the Former
Spouse's credit.
II
At the time of .1is retirement Irom the United States Coast Guard, the Memher elected an
annuity for tr.e Fonner Spouse under the Survivor Benelit Plan in the maximum amount
pennitled by law. The Memher shall immediately take all necessary steps to designate the
Fonner Spouse as the sole beneficiary of a fonner spouse survivor's benelit annuity in the
maximum amount allowed by law, to the exclusion of any future wife or future dependent
children of the Member. If the Member dies before making this election, he shall be deemed to
have made the election required by this provision, and the Fonner Spouse shall be entitled to the
ma.~imum pennissible survivor's annuity.
13.
MARITAL DEBTS: Each party will be responsible for their own debt incurred after the
date of separation and agrees to hold hannless the other from any debt associated with their
automobiles set forth above.
14.
INSURANCE AND EMPLOYEE BENEFITS: The panies al,,'ree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own
except as specifically provided in this Ab'feemcnt. WIFE waivcs all right, title and claim to
HUSBAND's employec benefits except thc rctir~'Il1cnt as provided in Paragraph Twelve (12) of
this Agreement, and HUSBAND waives all right, title, and claim to any of WIFE'S employee
bencfits, cxccpt that WIFE agrecs to maintain HUSBAND on hcr hcalth and dental insurancc
plan through hcr placc of cmploymcnt until thc divorcc is final. Thcrcaftcr any health covcrage
will be depcndcnt on HUSBAND'S payment lor said eovcrage as well as the WIFE'S continued
cmployment and Dickinson College. Notwithstanding the above, WIFE may maintain the life
insurance policy which she owns on the life ofthc HUSBAND.
12
15.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to woive 011 right, tith: and
intcrcst whkh shc may have in the savings or checking or any othcr bank accounts of thc
HUSBAND. The HUSBAND agrees to waivc all interest which hc has in the bank accounts of
the WIFE.
16.
DIVORCE: The panics both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and Icgal fces of the party who is seeking the divorce. Otherwise each party shall pay
all of their own respective counsel fees.
17.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enlorcing their rights
under this Agreement.
18.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and dl'liver to the other party any and all further
instruments that may be reasonably required to give full force and elTect to '.he provisions of this
Agreement.
13
19.
VOLUNT ARY EXECUTION: Th.: provisions of this Ab'Teement and their legal effec:
havc been fully e~plcined to th.: panies by their respective counsel. and each pany acknowledgcs
that the Agreement is fair and eljuitable. and that it is being entered inlO voluntarily. and tbat it is
not the rcsult of any durcss or unduc inl1uencc. Thc provisions of this Agrecment life fully
understood by both partics and each party acknowledges that the Agreement is fair and equitable.
that it is being entercd into voluntarily, and that it is not the result of any duress or undue
intluencc.
20.
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 fonh herein.
21.
APPLICABLE LAW: This Agreement shall be construed undcr the laws of the
Commonwealth of Pennsylvania.
22.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
14
.
23.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided.
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hcrcafter acquire. under the present or
future laws of any jurisdiction. to share in the property or the estate of the other as a result of the
marital relationship. including without limitation. dower. curtesy. statutory allowance. widow's
allowance. right to take in intestacy. right to take against the Will of the other. and right to act as
administrator or executor of the other's estate. and each will, at the request of the other. execute.
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into ene.t this mutual waiver and rclinquishmcnt of all such interests. rights nnd claims.
IN WITNESS WHEREOF. the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
J.~
,
/GA Y L. BOLING
(SEAL)
:Daf~ 4. N'",
~~~ .tJ. fit;!l..
~~.
(SEAL)
CHARD D. WHITE,
15
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME. this ~ day of~. 1998. a
Notary Public. in and l()r thc Commonwcalth of Pennsylvania and CoQ. ofOCumberland.
GAYLE L. BOLINGER, known tll mc (or satislactorily proven) to be tho: person whose name is
subscribed to tho: within Marriage Seulemellt A!.-'Teement. and acknowledges that she executed
the same lor the purposes therein contained.
IN WITNESS WHEREOF. I have hereunto set my hand and otlicial seal.
Notarial Seal
Selll A Mornson. Notary Public
Carlisle P.<Jro. Cumbertand County
My Contn'i3Sion Expires Dee 15, 2000
em at. rannc;vh/~f1Ia A~'incialion 01 NnlJries
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME. this lotb day of YtJLY'. 1998. a
Notary Public. in and for tho: Commonwealth of Pennsylvania and C~berland.
RICHARD D. WHITE, JR" known to me (or satisfactorily proven) to be the person whose
name is subsr.ribed to the within Marriage Selllemo:nt Agreement . and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official selll.
Nalarial Seal
Belli A. MOrrison, NOlary Public
Carlisle Bora. Cumberland County
My Commission EJlptres Dec. 15, 2000
~'ftl\H1"r 1""'r1~\,IV,HlIJ "~..;nr.i,tlion 01 NOlaflp.s
DOCS fAMll" ~l~" MS,\.UlGR OlK'
16