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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 0 final order has not yet
been entered;
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a:\fearnbaugh,agt file" 45.33.94,01
,
and In general, the settling of any and all claims and possible claims against the other or against
their respective estates,
NOW, THEREFORE,ln consideration of these considerations, and the mutual promises and
undertakings hereln8fter set forth, and for other good and valuable consideration, receipt and
sufficiency of which Is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE,
each Intending to be legally bound, hereby covenant and agree as follows:
1, 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, Undsay,
Esquire, and HUSBAND Is represented by Constance P. Brunt, Esquire,
2, Divorce: The parties agree to the entry of a Decree In Divorce, The parties will
execute, on the date of this agreement, Affidavits of Consent under Section 3301 (c) of the Divorce
Code, consenting to the entry of a Decree In Divorce,
3, Personal Property: The parties acknowledge, with one exception, that they have
equitably and satisfactorily divided all of their personal property, and that all personal property shall
be the sole and Individual property of the p8rty In whose possession It Is as of the date of this
agreement. A small te8pot, shaped liked an English cottage, which was a wedding present and
which Is presently In the possession of WIFE shall be the property of HUSBAND,
2
a:\fearnbaugh,agt file # 4533-94.01
,
WIFE will retain the 1980 Plymouth Citation, and HUSBAND waives any Interest
therein, HUSBAND shall retain a 1987 Buick Skylark, and WIFE waives any Interest therein, Both
parties agree to be exclusively responsible for any lien encumbering any vehicle In his or her
possession, and the parties will execute any and all documents to transfer all right, title and Interest
In said property to the person who retains possession.
HUSBAND waives any Interest he may have In the mobile home In which WIFE
permanently resides, and will execute any and all documents necessary to give effect to this
Agreement.
4. Marital Debt: HUSBAND will pay all marital debt Incurred In his name and the parltes'
Sears charge account, the Boscov's account, and any debt to HUSBAND's parents, HUSBAND
will Indemnify and hold WIFE harmless on account of any claim resulting from said debts,
WIFE will pay $3,000,00 to HUSBAND's grandparents upon notice to her that a fully
executed Release of All Claims by the grandparents against WIFE Is In the file of the attorney for
the HUSBAND, Upon payment of the $3,000,00, HUSBAND's attorney will forward said Release
to the attorney for WIFE.
5, Alimony: The parties waive any claim that they may have one against the other for
alimony or spousal support, The parties acknowledge that each has sufficient assets with which
to maintain themselves after divorce,
3
a:\feambaugh,agt file # 4533-94,01
. '
,
6, Other Debt: The parties have, In their own names, certain credit card accounts and
other debt, other than that set out In Paragraph 4 above, Each party will be solely responsible for
the debt. Each party will Incur no debt Into the Mure for which the other may be liable, and will
Indemnify and hold the other harmless for any debt so Incurred,
7, Modification: No modification, rescission, or amendment of this agreement shall
be effective unless In writing signed by each of the parties hereto,
8, Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania,
9, Agreement Binding on Parties and Heirs: This agreement, except as otherwise
expressly provided herein, shall bind the parties hereto, and their respective heirs, executors,
administrators, legal representatives, assigns and successors In any Interest of the parties.
10, Agreement Not to be Merged: This agreement shall be Incorporated Into the final
decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not
be merged Into said decree, The parties shall have the right to enforce this agreement under the
Divorce Code of 1980, as amended, and In addition, shall retain any remedies In law or In equity
under this agreement as an Independent contract, Such remedies in law or equity are specifically
not waived or released,
11, Documonts: The parties hereto agree that they will execute and deliver one to the
other any documents necessary to give effect to the terms of this Agreement.
4
ll:\f.cllrnbllugh,agt file '* 4533-94,01
12, Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise,
rele8se, quitclaim and forever discharge the other and the estate of such other, for all time to
come, and for all purposes whatsoever, of and from any and all rights, titles, Interests or claims
In or against the property (Including Income and gain from property hereafter accruing, of the
other) or against the estate of such other, of whatever nature and wheresoever situate, which she
or he now has or at any time hereafter may have against such other, the estate of such other or
any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of
such other, or by way of dower or curtesy, or claims In the nature of dower or curtesy, or widows'
or widowers' rights, family exemption or similar allowance, or under the intestate laws, or the right
to take against the spouse's will; or the right to treat a lifetime conveyance by the other as
test8mentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of Pennsylvania, any other State, or any other Country, or any
rights which either spouse may have, or at any time hereafter have, for past, present or Mure
support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except and only except, all rights and
agreements and Obligations of whatsoever nature arising or which may arise under this Agreement
or before the breach of any thereof, It 15 the intention of HUSBAND and WIFE to give to each
other by the execution of this Agreement a full, complete and general release with respect to any
and all property of any kind or nature, real, personal or mixed, which the other now owns or may
5
a:\fearnbaugh,agt file #,4533-94-01
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 94 - 6816 CIVIL TERM
IN DIVORCE
LORI MICHELLE FEARNBAUGH,
Plaintiff
VB.
BRIAN M. FEARNBAUGH,
EEMI;NI
THIS Agreement made this IJ'I-.L day of IIp; , 1995
by and between LORI MICHELLE FEARNBAUGH, of 283 Redwood Lane, Carlisle, Cumberland
County, Pennsylvania, hereinafter referred to as WIFE, and BRIAN M. FEARNBAUGH, of 327
Rosewood Lane, Enola, Pennsylvania, hereinafter referred to as HUSBAND,
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been Joined In m8rrlage on
March 5, 1994, In Mechanlcsburg, Pennsylvania; and
WHEREAS, a Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County, Pennsylvania, to No, 94-6816, Civil Term; and
WHEREAS, the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other, Including, without limitation,
the settling of all matters between them relating to the ownership of real and personal property,
a:\fearnbaugh,agt file #.4533-94.01
and in general, the settling of any and all claims and possible claims against the other or against
their respective estates,
NOW, THEREFORE,ln consideration of these consl-Jeratlons, and the mutual promises and
undertakings hereinafter set forth, and for other good and valuable consideration, receipt and
sufficiency of which Is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE,
each Intending to be legally bound, hereby covenant and agree as follows:
1, Advice of Counsel: The parties hereto acknowledge that each has been notllled
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, Undsay,
Esquire, and HUSBAND Is represented by Constance P. Brunt, Esquire.
2, Divorce: The parties agree to the entry of a Decree In Divorce, The parties will
execute, on the date of this agreement, Affidavits of Consent under Section 3301 (c) of the Divorce
Code, consenting to the entry of a Decree In Divorce.
3, Personal Property: The parties acknowledge, with one exception, that they have
equitably and satisfactorily divided all of their personal property, and that all personal property shall
be the sole and individual property of the party In whose possession It Is as of the date of this
agreement. A small teapot, shaped liked an English cottage, which was a wedding present and
which Is presently In the possession of WIFE shall be the property of HUSBAND.
2
a:\fearnbaugh,agt .file #,4533-94.01
WIFE will retain tha 1980 Plymouth Citation, and HUSBAND waives any Interest
therein, HUSBAND shall ret81n a 1987 Buick Skylark, and WIFE waives any Interest therein, Both
parties agree to be exclusively responsible for any lien encumbering any vehicle In his or her
possession, and the parties will execute any and all documents to transfer all right, title and Interest
In said properly to the person who retains possession,
HUSBAND waives any Interest he may have In the mobile home In which WIFE
permanently resides, and will execute any and all documents necessary to give effect to this
Agreement.
4. MarItal Debt: HUSBAND will pay all marital debt Incurred In his name and the parites'
Sears charge account, the Boscov's account, and any debt to HUSBAND's parents, HUSBAND
will Indemnify and hold WIFE harmless on account of any claim resulting from said debts,
WIFE will pay $3,000,00 to HUSBAND's grandparents upon notice to her that a fully
executed Release of All Claims by the grandparents against WIFE Is In the file of the attorney for
the HUSBAND, Upon payment of the $3,000.00, HUSBAND's attorney will forward said Release
to the attorney for WIFE.
5, Alimony: The parties waive any claim that they may have one against the other for
alimony or spousal support, The parties acknowledge that each has sufficient assets with which
to maintain themselves after divorce,
3
a:\fearnbaugh.ngt file 'II: 4533.94.01
6, Other Debt: The parties have, In their own names, certain credit card accounts and
other debt, other than that set out In Paragraph 4 above, Each party wUl be solely responsible for
the debt. Each party will Incur no debt Into the future for which the other may be liable, and will
Indemnify snd hold the other harmless for any debt so Incurred.
7. Modification: No modification, rescission, or amendment of this agreement shall
be effective unless In wrlllng signed by each of the parties hereto,
8. Applicable Law: Allllcts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania.
9, Agreement Binding on Parties and Heirs: This agreement, except as otherwise
expressly provided herein, shall bind the parties hereto, and their respective heirs, executors,
administrators, legal representallves, assigns and successors In any Interest of the parties.
10, Agreement Not to be Merged: This agreement shall be Incorporated Into the final
decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not
be merged Into said decree. The parties shall have the right to enforce this agreement under the
Divorce Code of 1980, as amended, and In addlllon, shall retain any remedies In law or In equity
under this egreement as an Independent contract, Such remedies In law or equity are speclflcally
not waived or released.
11, Documents: The parties hereto egree that they will execute and deliver one to the
other any documents necessary to give effect to the terms of this Agreement.
4
a:\fearnbaugh,agt file #,4533.94.01
12, Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of such other, for all time to
come, and for all purposes whatsoever, of and from any and all rIghts, titles, Interests or claIms
In or against the property (IncludIng Income and gain from property hereafter accruing, of the
other) or against the estate of such other, of whatever nature and wheresoever situate, which she
or he now has or at any time hereafter may have against such other, the estate of such other or
any part thereof, whether srlslng out of any former acts, contracts, engagements or IIebllltles of
such other, or by way of dower or curtesy, or claims in the nature of dower or curtesy, or widows'
or widowers' rights, family exemption or similar allowance, or under the intestate laws, or the right
to take against the spouse's will; or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to participate In a deceased spouse's estate,
whether arising under the laws of Pennsylvania, any other State, or any other Country, or any
rights which either spouse may have, or at any time hare after have, for past, present or future
support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except and only except, all rights and
agreements and obligations of whatsoever nature arising or which may arise under this Agreement
or before the breach of any thereof, It Is the Intention of HUSBAND and WIFE to give to each
other by the execution of this Agreement a full, complete snd general release with respect to any
and all property of any kind or nature, real, personal or mixed, which the other now owns or may
5
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LORI MICHELLE FEARNBAUGII, . IN THE COURT OF COMMON PLEAS OF
.
. CUMBERLAND COUNTY, PENNSYLVANIA
.
Plaintiff .
.
v. . CIVIL ACTION - LAW
.
.
.
BRIAN M. FEARNBAUGII, . No. 94-6816 civil Term
.
.
.
Defendant . IN DIVORCE
.
PRAECIPE
TO: Lawrence E. Welker, prothonotary
Please withdraw the Defendant's claims for equitable
distribution, alimony pendente ~, counsel fees, costs and
expenses, and alimony as set forth in his Counterclaim filed in
the above matter on December 14, 1994.
DATE:
t 11I/7.t-
k~
CONSTANCE P. BRUNT, ESQUIRE
3901 North Front street
Harrisburg, Pennsylvania 17110
(717) 232-7200
Attorney for Defendant
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LORI MICHELLE FEARNBAUGH.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 6816
1994
CIVIL
BRIAN M. FEARNBAUGH,
Defendant
IN DIVORCE
onDER AND NO'l'ICE SET'rING HEARING
To:
Lori Michelle Fearnbaugh
Carol J. Lindsay
Brian M. Fearnbaugh
Constance p, Brunt
. Plain tiff
, Counsel for Plaintiff
, Defendant
. Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the gmunds for divorce of indignities to the
person at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle. Pennsylvania, on the 11th day
of April . 1995, at 9:00 a.m., at which place
and time you will be given tne opportunity to present witnesses
and exhibits in support of your case.
By the Court,
~~ (:::
Harold E. Sheely,
,Judge
Date of Order and
Notice: 1/30/95
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP,
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
JAH 10
2 10 [,(\ '95
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CONST~CB P. BRUNT
Ii ;;;N.T LAW
LORI MICHELLE FRARNBAUGII,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
No. 94-6816 civil Term
BRIAN M. FEARNBAUGH,
Defendant
IN DIVORCE
PRAECIPE FOR BILL OF PARTICULaBa
TO THE PROTHONOTARY: LHwrence E. Welker
Please enter a Rule on Plaintiff, LORI MICHELLE
FEARNBAUGH, to file a Bill Of Particulars within twenty (20) days
after service of the Rule, or suffer judgment of non pros,
pursuant to Pa. R.C.P. 1920.21(b).
DATED: 1~/7/'l1
&~
CONSTANCE P. BRUNT, ESQUIRE
Attorney for Defendant
BYI&
AND NOW, to wit, this !I:} day of IJ2uj,~
1994, a Rule is entered on Plaintiff, LORI MICHELLE FEARNBAUGII,
to file a Bill Of Particulars within twenty (20) days after
service of the RUle, or suffer jUdgment of non pros.
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PlalntifCs repeated attempts to obtain psychiatric help for the Defendant failed as he would make
appointments with a psychologist and then fall to keep them.
S. During the course of their marriage, the Defendant controlled the finances, hiding credit
card bills and bank statements and advising Plaintiff when she could write checks on the joint checking
account and telling her that the credit card bills had been paid, As a result of Defendants
misstatements, PlaintifCs credit rating was ruined because her bills were not paid, sometimes for as
long as three months at a time. She suffered the Indignity of bouncing checks tendered on his advice
and the refusal of certain establishments to cash her checks after one of these Incidents.
6, Defendant commented to others in Plaintiffs presents that she was "good In bed" he
called her names and yelled at her in public,
7, Commencing May, 1994 two months after their marriage, Defendant stole approximately
twenty-one thousand ($21,000,00) dollars from Dauphin Deposit Bank by the strategy of depositing said
funds to the parties joint checking account, Defendant Implicated the Plaintiff In his theft by advising
her that the stole money was really inherited from his grandmother and inducing her to come with him
to purchase a vehicle with the proceeds. This behavior on the part of the Defendant exposed Plalntlff
to criminal investigation and to the humiliation of returning the vehicle when Plaintiff discovered it
was purchased with stolen money,
8. During a argument, the defendant threatened, once again, to kill himself and carried a
can of gasoline into the parties' home, He, thereafter poured gasoline over his head, splashing it on
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