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Home My WebLink About94-07191 -~ Ci -7 -s Q) c::t: ( \, ~ ,'. J "f . I' f' r> . - 0- - C' , ! ! ! I i I 1 I I I : ! i I . .. . ~~~~~-~-------------~~-~-~~~~~~ ~ - ~~- - - ~ ,. ~ 8 IN THE COURT OF COMMON PLEAS 8 8 8 8 OF CUMBERLAND COUNTY S ~ * . ~ . . STATE OF "\,~. .:1" PENNA. ~ $ . Ii! ' . 8 6 PATRICIA M. aEED,: ~ 8 Ii! PLAINTIFF N (). ...7.1~J...... ,GJ.YJk, Il) 9'1 ,;, ~f " 8 VIII".";II.'{ 8 8 KEVIN L. REED, ~ 8 DEFENDANT S $ Ii! ~ ~ ~ ,;, ~ ~ ~ ~ ~ ~ ~ 8 ~ ~ ~. $ ~ ~ ~ ~ 8 ~ ~ . 11-.. _ DECREE IN DIVORCE 8 ~ 8 8 $ ~ ~ " ~ ., ~ ~ -:> AND NOW, ",...: ,~'!ne....z. ~".,"" 19, ~$'., it is ordered and decreed that...,....,. ,~~':l'.R.~<;:p.. .'1:, ~,E;F;I?,.....,......,....., plaintiff, and...., ., .....". ".. . ({.E.~:nl. ,1," ,F,E,I;;Q, .. .. ,. ,. .. , ,.. ... , ", 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; .. ~ .. >:I ~ .~ THE PARTIES SEPARATION AGREEMENT OF JUNE 12. 1995, IS ........., ....................... ......... ......... ...... .,. .... ......., ,., ,~ :, , INCORP.QRATEn ,HEREIN, AS. A, ,F.INAL ,ORDER, OF, .COllR'!:. . , , . . . . . . . . . . . , . . . ,~ ~ ~ .~ ~ ny The .1lI.;/t. aLl. * Attest:.. ~..~,~ E~~~,_ ~.r;' I~ & ~"l<''- ,,<-:'~k ~~7 I,~ V' - --7- P.IOthoZary Of I~ ~ --_..-..- '........,~~_..--~., '-. -~-'~-'~-- ,.-, . , ~-" '..- '. -, . ,~ ~-~~~~***~~'~'~*'~~*~.*ro*~' BBPARATIOM AGRBIKBHT THIS AGREEMENT made this /2 It. day of J -' e- , 1995, by and between Patricia M. Reed of Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "Wife"), and Kevin L. Reed of Newville, Cumberland County, Pennsylvania (hereinafter referred to as "Husband"). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on December 5, 1987, in CUmberland County, Pennsylvania: and WHEREAS, differences have arisen between Husband and Wife in consequence of which they have chosen to live separate and apart from each other: and WHEREAS, Husband has discussed with his attorney, Bradley L. Griffie, Esquire, and Wife has discussed with her attorney, Michael A. Scherer, Esquire, their assets and liabilities as of the date of this Agreement, and both having been advised by their attorneys of their rights and desires to the provisions hereinafter set forth. NOW, THEREFORE, the parties hereto intending to be legally bound hereby do covenant and agree: 1. SeDaration: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. Interterence: Each party shall be tree from interterence, authority, and contact by the other, as tully as it he or she were single and unmarried except as may be necessary to carry out the provisions ot this Agreement. 3. wi te' s Debts: wite represents and warrants to Husband that she will not contract or incur any debts or liabilities tor which Husband or his estate might be responsible and shall indemnity and save harmless Husband trom any and all claims or demands made against him by reason ot debts or obligations incurred by her other than those debts incurred pursuant to any sections ot this Agreement. 4. Husband's Debts Husband represents and warrants to wite that he will not contract or incur any debt or liability tor which wite or her estate might be responsible and shall indemnity and save harmless wite from any and all claims or demands made against her by reason of debts or obligations incurred by her other than those debts incurred pursuant to any section of this Agreement. 5. outstandinq Joint Debts: The parties acknowledge that, at this point, the only outstanding joint debt that they have relates to the encumbrance on their former marital residence located at 309 Shed Road, Newville, cumberland County, Pennsylvania. Husband agrees to accept sole and exclusive responsibility for repayment ot the debt due and owing to Farmers Home Administration relative to the encumbrance on this real estate. Husband will indemnify wife and hold her harmless from and against any and all collection activity on account of the aforesaid encumbrance and shall see that the encumbrance is paid in a timely fashion. 6. Mutual Release: sub:ject to the provisions ot this Agreement, each party has released and discharged, and by this Agreement does for himsel t or hersel f, and his or her heirs, legal representati ves, executors, administrators, and assigns, release and discharge the other ot and from all causes ot action, claims, rights or demands, whatsoever in law or equity, which either of the p!lrties ever had or now has against the other, except any or all cause or causes of action for divorce or any action to entorce this Agreement. 7. Al imonv . Al imonv Pendente Lite. SDousal SUDDOrt and Maintenance: The parties specifically are aware of, acknowledge and understand their right to demand alimony, alimony pendente lite and support and hereby waive their right to these claims against the other party now and in the future. Both parties agree not to make a claim for alimony, alimony pendente lite now, during any future divorce proceeding between the parties, or at anytime thereafter. 8. Division of Personal PrODertv: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property, including automobiles, which have heretotore been used by them in common, and neither will make any claim to any such items which are in the possessioll or under the control ot the other. 9. Division ot Real ProDertv: wite agrees to waive, relinquish and transter uny and all ot her right, title and interest in the real estate located at 309 Shed Road, Newville, Cumberland County, Pennsylvania, to Husband. wite will execute a Deed contemporaneously with the execution of this Separation and Property Settlement Agreement so conveying her interest and shall deliver said Deed to Husband or Husband's legal representative within tive (5) days ot executing the Deed and this Agreement. Wite shall make no claim or demand ot any nature whatsoever relative to rights of possession or ownership, either legal or equitable, in the said property from the date of this Agreement and the Deed torward. Wite acknowledges the lack of equitable value in the real estate at this time and, therefore, agrees she will not receive any reimbursement or payment of any nature relative to her transfer of interest in the real estate. 10. Insurance and other Benefits: The parties agree that neither party shall have or make any claim whatsoever concerning any insurance benefits, retirement benefits, or other similar benefits due or accruing to the other party. 11. Waiver of Claims Aqainst 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 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, widow's allowance. right to take in intestacy, right to take against th~ 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 interests, rights, and claims. This Paragraph shall not affect either party's right or power to expressly include the other party in any will or other document, whether written in the past or in th~ future. 12. Breach: If either party breaches any provision 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. In the ev(mt that one party is deemed to be the breaching party, the other party shall be entitled to claim attorney's fees, costs and expenses from the breaching party to the non-breaching party for costs and expenses associated with enforcing this Agreement. 13. Counsel Fees: The parties agree that should a divorce action be maintained by either of the parties to dissolve their marriage, neither party shall make a claim for counsel fees from 1 -:-r. ~ ~q ::"-; , ,) ~ oX) .s ~\ ;7 ff\ .~., ro -;) '-.1 ri ., _J ~ ~ '" ~~ <J- @ - il: ~~ U) ...: 1<1 ...:l :r 0. . ;.. 1<1 '" Z8 . tJ 1<1 oZ 0 '" 8;3: ~tJ...: t<l 0 ...:10( '" OH t<l P > ex: ...:I 5 0 OtJZ "'.... 1<1..., H H I t<l r- tJOo( .... 1<11: 0 >ZtJ t ~ ...... "'Ill HOp: :r: ~ :S r.,Z!:i :r..., .'tl Z tJHO ~ ~ ~ ~ 00(;.. I: . H '" > ...:II: 8> u ~ ...:IU) ...:..... III tJH E U ~ ~ 8"'Z Hill Z.... 8 "':0 0 ~ '" ",t<lZ tJ.... Z z: Hlll ~ ~ tJ~f<l Ho. >0 H ...:IZ :s ~ o 0. '" ...: HH 5 e tJtJ 8 1<1 ...:I > ~ 0( ::.: 0. C2 ,. H ~ 1<Ir., 0. :r tJ a:l 0 b :Co tJ I 8 '<l' Z '" H . . . , . . . , 11I:.. . ,. PA'IRICIA M. REED, IN THE CXXJRT OF cx:r<<:N PlEAS OF plaintiff 0JMBERLl\ND a:uNTY, PENNSYLVANIA v. 94- '1' ')1 CIVIL TERM KEVIN L. REED, CIVIL ACl'IGI-LAW Defendant IN DIVORCE NOl'ICE 'I'O DEFEND AND ClAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take pratpt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights .inp:>rtant 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 CUn'berland County Court House, Carlisle, Pennsylvania. YOO SHOOLD TAKE nus PAPER'I'O YOOR ATlORNEY AT G1CE. IF YOO 00 NOl' HAVE AN ATI'ORNEY OR CAIm:1l' AFFORD mE, en 'I'O OR 'I'ELEPHCNE THE OFFICE SET FOR'IH BEILW 'I'O FIND OUT WHERE YOO CAN GET LEGAL HELP. Court Administrator Cwnberland County Court House Fourth Floor Carlisle, PA l70l3 Telephone: (7l7) 240-6200