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CHRISTINE M. ROBISON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO: 95.1624 CIVIL TERM
DIRK A. ROBISON,
CIVIL ACTION. DIVORCE
Defendant
{VlARIT AL SETTLEMENT A GREEMENT
THIS Agreement made this 2 ~ day of ~d ' 19!f1, by
and between CHRISTINE M. ROBISON, of Maple streetU'lnut Bottom, Pennsylvania, hereinafter
referred to as WIFE, and DIRK A. ROBISON, of 655 Mud Level Road, Shippensburg, Cumberland
County, Pennsylvania, hereinafter referred to as HUSBAND,
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been joined in marriage on July
25, 1984, in Hagerstown, Maryland; and
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WHEREAS, a Complaint for Divorce has been filed in Ihe Court of Common Pleas of
Cumberland County, Pennsylvania, to No. 95-1624, 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 10 the ownership of real and personal property, and in general,
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the settling of any and all claims and possible claims against the other or. against their respective
estates.
NOW, THEREFORE, in consideration of these considerations, 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 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, Esquire.
and HUSBAND is represented by Sally J. Winder, Esquire. Each party acknowledges and accepts
that this agreement is, in 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 that 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.
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 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.
HUSBAND will retain the 1985 Mazda truck and the 1984 Toyota Wagon.
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4. Real Property: The parties were owners 01 a home at 655 Mud Level Road.
Shippensburg, Cumberland County, Pennsylvania. The property has been sold and the liens on the
property paid. The parties are satislied with the disposition 01 the marital home.
The parties are also partners with Robert and Karen Cordell in the ownership 01 two houses.
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one, a two-unit property at 176 Kennedy Street, Chambersburg, Pennsylvania and the other a three- ' I
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unit property at 12 Spring Street, Chambersburg, Pennsylvania. The rent Irom the various units shall !
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be used to pay the respective mortgages outstanding on the two properties. Upon the sale 01 the
property, HUSBAND and WIFE shall equally split their hall 01 the sales price. In the event that the
partnership realizes a prolit, the parties will equally share their hall 01 the pro lit annually and will
report on their respective income tax returns one-quarter 01 the income from the partnership. In the
alternative, if in a given year the partnership shows a loss, the parties will equaily contribute to their
share of such loss and shall be entitled to take one-hall 01 their combined share 01 the loss on each
parties income tax return. Upon the sale 01 one or both 01 the properties, the parties will equally
divide any gain on their income tax returns in the year the gain is realized.
5. Alimony: The parties waive any claim that they may have one against the other lor
alimony or spousal support. The parties acknowledge that each has sufficient assets with which
to maintain themselves after divorce.
6. Marital Debt: The parties have, in their own names, certain credit card accounts
which may include some marital debt. Each party will be responsible lor payment 01 the balances
on the credit card accounts in his or her name. In particular, WIFE shall be solely responsible lor
the GM Mastercard, the Discover Card and her school loan. HUSBAND will be solely responsible
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for the City Bank Visa account, and the Lowe's account. Each party will indemnify and hold the
other harmless on account of any obligation for which he or she has agreed to be solely responsible
according to the terms of this paragraph.
7. Custody: The parties are parents of one child, JOHN COLEMAN ROBISON, born
November 10, 1992. The parties shall share legal custody of said child. WIFE shall have primary
physical custody of said child, and HUSBAND shall have partial custody of said child at such times
as the parties can agree. WIFE will not unreasonably alter the pallern of partial custody which is !
the parties practice as of the date of this agreement so long as HUSBAND refrains from the
consumption of alcohol during his periods of partial custody.
8. Modification: No modification, rescission, or amendment of this agreement shall be
effective unless in writing signed by each of the parties hereto.
9. Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania.
10. 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.
11. 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
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under this agreement as an Independent contract. Such remedies In law.or equity are specifically
not waived or released.
12. Documents: 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.
13. 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 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 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 hereafter 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
I 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
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Agreement a full, complete and general release with respect to any and aU property of any kind or
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nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and
only except, all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agreement, or for the breach of any thereof, subject, however, to the
implementation and satisfaction of the condition precedent as set forth herein above.
14. 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 costs 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. IN WITNESS WHEREOF, the
parties hereto have set their hands and seals the day and year first above written.
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(Seal)
CHRISTINE M. ROBISON
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DIRK A: ROBISON
(Seal)
6
CHRISTINE M. ROBISON,
PlnintilT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACfION . DIVORCE
V5.
NO. 9S. 1624
CIVIL TERM
DIRK A. ROBISON,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
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 (cl 3301 (dill I of the
Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: U.S. Mail. First-Class. Certified. Return
Receiot. dated June 16. 1995,
3. IComplete either paragraph (a) or Ibll.
la) Date of execution of the affidavit of consent required by Section
3301 (c) of the Divorce Code: by the Plaintiff June 11. 1997 ; by the
Defendant Januarv 19. 1998
(Ill (1) Oate ef elleeutieR ef lhe PlaiAtiff's affiEla'/it requireEl by SeelieR
aa911E11 af lhe Oiveree CeEle:
121 Oale af ser-/iee af the PlaiRliff's affiElavit upaR IRe OafeRElaRt:
4. Related claims pending: None
5. Complete either lal or Ibl.
la) Date and manner of service of the notice of intention to file praecipe
to transmit record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in 33011c) Divorce was filed with the
Prothonotary:
Date Defendant's Waiver of Notice in 33011c) Divorce was filed with the
Prothonotary:
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CHRISTINE M. ROBISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNlY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
.
.
VB.
DIRK A. ROBISON,
Defendant
NO. 95. l(c,;} V
IN DIVORCE
CIVIL TERM
.
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NQI1.C.E
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 fall to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you
by the Court. A judgment may also be entered against you for any other claim or relief requested
in these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for 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, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERlY, LAWYERS
FEES OR EXPENSES BEFORE A DECREE OF 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.
Court Administrator, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 240-6200
.:\robilon.com me' 4618-~1
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CHRISTINE M. ROBISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
VB.
NO. 95 _ / (., .i 'I
CIVIL TERM
DIRK A. ROBISON,
Defendant
IN DIVORCE
CHRISTINE M. ROBISON, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER
& LINDSAY, respectfully represents:
1. The Plaintiff is Christine M. Robison, who currently resides at 655 Mud Level Road,
Shippensburg, Cumberland County, Pennsylvania, where she has resided for a period in excess
of six months prior to the filing of this Complaint.
2. The Defendant is Dirk A. Robison, who currently resides at 655 Mud Level Road,
Shippensburg, Cumberland County, Pennsylvania, where he has resided for a period in excess
of six months prior to the filing of this Complaint.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth
of Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 25, 1984, at Hagerstown, Maryland.
5. That there have been no prior actions of divorce or for annulment between the parties
in this or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is
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I, hereby verify that the statements made in the within instrument 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. ection 4904, relating to unsworn falsification
to authorities.
Date:
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CHRISTINE M. ROIUSON,
PlnintllT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
vs.
NO. 95. 1624 CIVIL TERM
DIRK A. ROBISON,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSEN[
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on March 30, 1995.
2. The marriage of Plaintiff and Defendant is irretrievahly hroken and ninety
days have elapsed from the date of filing the Complaint.
3. I consent wthe entry of a Final Decree of Divorce without service of Notice
of Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNnER ~3301(c) OF THE DIVORCE CODE
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I consent w the entry of a Final Decree of Divorce without Notice.
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2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them hefore a divorce is granted.
3. I understand that I will not he divorced until a Divorce Decree is entered by
the Court and that a copy of the Decree will he sent W me immediately after it is filed with
the Prothonotary.
I verify that the statement made in this Affidavit are true ;\I1d correct. I understand
Date:
that false statements herein are made suhje
to unsworn falsification to authorities. "
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VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
CHRISTINE M. ROBISON,
Plaintiff
NO. 95. 1624 CIVIL TERM
DIRK A. ROBISON,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under ~ 3301 (c) 01 the Divorce Cude was liIed on June 14, 1995.
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 alter service 01 notice 01 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 penallles 01 18 Pa.C,S. 4904 relating to
unsworn falsification to authorities.
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Dirk A. Robison. Defendant
Date:
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WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
!i3301 (el OF THE DIVORCE CODE
1. I consent to the entry of a final Decree 01 Divorce willlOut notice,
2. I understand that I may lose rights concerning alimony. division 01 property, lawyer's lees 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 alter it Is tiled with the Prothonotary,
I verify that the statements made in this Affidavit are true and correct to the best ot my knowledge. Information
and belief. I understand that false statements herein are made subject to the penalties 0118 Pa,C,S, 4904 relating to
unsworn falsification to authorities.
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Dirk A. Robison, Delenclant
Date: V;J V" \ /', 1 C; Ii'
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Tr.cl "0 Colyer
Office Manager/Reporter April 8, 1997
Carol J. Lindsay
Attorney at Law
FLOWER, MORGENTHAL, FLOWER & LINDSAY
11 East High Street
Carlisle, PA 17013
RE: Christine M. Robison vs. Dirk A. Robison
No. 95 - 1624 Civil
In Divorce
West Shore
697-0371 Ext. 6535
Dirk A. Robison
655 Mud Level Road
Shippensburg, PA 17257
Dear Ms. Lindsay and Mr. Robison:
By order of Court of President Judge Harold E. Sheely
dated March 24, 1997, the full-time Master has been appointed in
the above referenced divorce proceedings.
A divorce complaint was filed on March 3D, 1995, raising
grounds for divorce of irretrievable breakdown of the marriage.
No economic claims were raised in the complaint. Consequently,
I am not going to issue a directive for the filing of pre-trial
statements but I will allow counsel for Plaintiff or Mr.
Robison, who apparently is representing himself, an opportunity
to file an amended complaint or petition raising economic
claims. If no economic claims are raised within the next two
(2) weeks, I will prepare an order vacating my appointment.
Very truly yours,
E. Robert EliCker, II
Divorce Master
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
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CHRISTINE M. ROBISON. moves the court to appoint a master with re~~ct tQ"the:?'''
following claims: ::' i:ri ~
CHRISTINE M. ROBISON.
Plaintiff
vs.
NO. 95.1624 CIVIL TERM
DIRK A. ROBISON.
IN DIVORCE
Defendant
(e) Distribution of Property
() Support
(e) Counsel Fees
(e) Costs and Expenses
(e) Divorce
() Annulment
() Alimony
() Alimony Pendente Lite
and in support of the motion states:
(1) Discovery is complete as to the claim(s) for which the appointment of a
master Is requested.
(2) The Defendant has not appeared in the action personally or by his attorney.
(3) The statutory ground(s) for divorce is/are 3301(c).
(4) Delete the inapplicable paragraph(s).
(a) The action is not contested.
(b) An agreement has been reached with respect to the following
claims: none
(c) The action is contested with respect to the following claims:
Distribution of property, counsel fees. costs and expenses.
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take 1/2 day.
(7) Additional information. if any. relevant to the motion: none
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AND NOW, this ;;. <I tJi day of I nil ,~[ A
Esquire, is appointed master with respect to the following claims:
orooertv. counsel fees. costs and exoenses.
Date:
3{nt'7
,199-,7.
Distribution ,2f
By the Court.
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LAW OFFICES
FLOWER, MORGENTHAL, FLOWER & LINDSAY
^ l>Ro"lL\SlnHAI. ('{JRI'UKATIUN
II EAST HIGH STREET
CARLISLE, PENNSYLVANIA 17013-3016
JAMIJS D. I~.OWI!R
IlOClIJR M. MORCiI!NIlIAI.
JAMI~~ D. IUlWIJlt. Jft.
CAROl. J. I.INllSl\ Y
(717) 243-SS13
"AX: (717) 24J-(,s1lJ
E.mail: FMI~.I.aW@aol.C.om
JlJI!I'SCII &< MORClI!f'{I1IAL
(1'I75.19llS)
I~.()WI!R, KRAMI!R
MORGf!I\ITllAl.&< I~.OWI!R
February 5,1998
E. Robert Elicker, II, Esquire
9 North Hanover Street
Carlisle, PA 17013
RE: Robison v. Robison
No. 95-1624 Civil Term
Dear Bob:
The parties have settled their case. Please find enclosed two copies of the Marital
Settlement Agreement. Kindly ask the Court to vacate your appointment.
Thank you for your assistance.
Very truly yours,
FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C.
fJ4t1L
Carol J. Lindsay
CJLltjb
Enclosures
cc: Sally J. Winder, Esquire
,-
CHRISTINE M. ROBISON, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95 - 1624 CIVIL
.
.
.
DIRK A. ROBISON, .
.
Defendant : IN DIVORCE
ORDER OF ~URT
AND NOW, this ~ day of
1998, the economic claims raised in the proceedings
wr
,
resolved in accordance with a marital settlement agreement dated
January 28, 1998, the appointment of the Master is vacated and
counsel can file a praecipe transmitting the record to the Court
having been
requesting a final decree in divorce.
BY THE COURT,
co:
Carol J. Lindsay
Attorney for Plaintiff
Dirk A. Robison
Pro Se
er, P.J.
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the settling of any and all claims and possible claims against the other or. against their respective
estates.
NOW, THEREFORE, in consideration of these considerations, 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 aclmowledge 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 Sally J. Winder, Esquire. Each party acknowledges and accepts
that this agreement is, in 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 that 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.
2. Divorce: The parties agree to the entry of a Decree in Divorce. The parties will
execute, on the date of this agreement, AHidavits of Consent under Section 3301 (cl of the Divorce
Code, consenting to the entry of a Decree in Divorce.
3. Personal Property: The parties acknowledge 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.
HUSBAND will retain the 1985 Mazda truck and the 1984 Toyota Wagon,
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4. Real Property: The parties were owners of a home at 655 Mud Level Road.
Shippensburg, Cumberland County, Pennsylvania. The property has been sold and the liens on the
property paid. The parties are satisfied with the disposition of the marital home.
The parties are also partners with Robert and Karen Cordell in the ownership of two houses.
one, a two-unit property at 176 Kennedy Street, Chambersburg, Pennsylvania and the other a three- .
unit property at 12 Spring Street, Chambersburg, Pennsylvania. The rent from the various units shall
be used to pay the respective mortgages outstanding on the two properties. Upon the sale of the
property, HUSBAND and WIFE shall equally split their half of the sales price. In the event that the
partnership realizes a profit. the parties will equally share their half of the profit annually and will
report on their respective income tax returns one-quarter of the income from the partnership. In the
alternative, if in a given year the partnership shows a loss, the parties will equally contribute to their
share of such loss and shall be entitled to take one.half of their combined share of the loss on each
parties income tax return. Upon the sale of one or both of the properties. the parties will equally
divide any gain on their income tax returns in the year the gain is realized.
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.
6. Marital Debt: The parties have, in their own names, certain credit card accounts
which may include some marital debt. Each party will be responsible for payment of the balances
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on the credit card accounts in his or her name. In particular, WIFE shall be solely responsible for
the GM Mastercard, the Discover Card and her school loan. HUSBAND will be solely responsible
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for the City Bank Visa account, and the Lowe's account. Each party will indemnify and hold the
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other harmless on account of any obligation for which he or she has agreed to be solely responsib:e
according to the terms of this paragraph.
7. Custody: The parties are parents of one child, JOHN COLEMAN ROBISON, born
November 10. 1992. The parties shall share legal custody of said child. WIFE shall have primary
physical custody of said child, "nd HUSBAND shall have partial custody of said child at such times
as the parties can agree. WIFE will not unreasonably alter the pattern of partial custody which IS
the parties practice as of the date of this agreement so long as HUSBAND refrains from the
consumption of alcohol during his periods of partial custody.
8. Modification: No modification, rescission, or amendment of this agreement shall be
effective unless in writing signed by each of the parties hereto.
9. Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania.
10. 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.
11. 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
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under this agreement as an independent contract. Such remedies in law.or equity are specifically
not waived or released.
12. Documents: The parties hereto agree that they will execute and deliver one to the
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Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise. I
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other any documents necessary to give effect to the terms of this Agreement.
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release, quitclaim and forever discharge the other and the estate of such other, for all time to come, i
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and for all purposes whatsoever, of and from any and all rights, titles, interests or claims in or i
against the property (including income and gain from property hereafter accruing, of the other) or I
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against the estate of such other, of whatever nature and wheresoever situate, which she or he now !
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has or at any time hereafter may have against such other. the estate of such other or any part I
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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 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 hereafter 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
I 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
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Agreement a full, complete and general release with respect to any and aU property of any kind or
natura, real, personal or mixed, which the other now owns or may hereafter acquire, except and
only except, all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agreement, or for the breach of any thereof, subject, however, to the
Implementation and satisfaction of the condition precedent as set forth herein above.
14. 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 costs 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. IN WITNESS WHEREOF, the
parties hereto have set their hands and seals the day and year first above written.
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(Seal)
CHRISTINE M. ROBISON
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DIRK A. ROBISON
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(Seal)
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