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NOW, THEREFORE, In consideration ot these considerations, and the mutual promises and
undertakings herelnatter set forth, and lor other good and valuable consideration, receipt and
sutflclency of which 15 hereby acl<nowledged by each 01 the parties hereto, I..USBAND and WIFE,
each Intending to be legally bound, hero by covenantl1nd agree os follows:
1. Advloe of Counsel: Hlll parties hereto ucl<nowledge that each has been notified
of his or her right to consult with counsel 01 IllS or hur cllOICO, and have been provided a copy of
this agreement with which to consult with counsel. HUSBAND Is represented by Carol J. Lindsey,
Esquire, end WIFE Is represented by Thol11as J. Williams, EsqUire, Eocll party acknowledges and
accepts thet this agreement Is, In the c1rcUl11stonces, loll' and eqUitable, and 1I10t It Is being entered
Into freely and voluntarily, after haVing received such odvlce 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 notlhe result 01 any improper or Illegal agreement or agreements.
2. Divorce: The parties agree to the ent:y of 0 Decree In Divorce. The parties will
execute, on the date 01 this agreement, Affidavits of Consent undel' Section 3301 (c) of the Divorce
Code, consenting to the entry of a Decree In Divorce ond Waivers of Notice.
3. Personal Property: The parties acknowledge that they have equitably and
satisfactorily divided all of their personal property, amI that all personal property shall be the sole
and Individual property of the party in whose possession it is os of the date of this agreement.
WIFE will retain the International Tractor wilh its oltochments, HUSBAND will retain the
Allschalmer Tractor and its attachments, HUSBAND will transfer to the parties' son the 1989
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Chevrolet Bla~er, Eaoh ot the parties shall retain his or her own retlroment benefits Including
penslonB, 401-1< Plans and annuities, WIFE will transfer 10 HUSBAND 011 of her Individual
retirement occounts from which shll warrants she has not made a withdrawal since the parties
separated In January, 19915, and In particular, her H(mlii Savings Bnnk Indlvlduul Retirement I
Account No, 184382024 13 gg 50,
4, Real Property: Tile pnrties are ownors of two trncls of IGnd, a house and I
approximately SIX acres at 80 Sllepllord ROGel. Newville, Cumberland County, Ponnsylvanla, and
an adjoining tract of opproximotely 90 ocres of farmlond, WIFE wllltrnnsfer to ~tUSBAND all her
right, title and Interest In the l10me on 80 SIlephard Road, Newville, Pennsylvania, and will deliver
a deed to sold home to HUSBAND on the dote <11 this Agreement. HUSBAND will be solely liable
for the home equity loon ond wlllmoko 011 payments thereon promptly and will Indemnify and hold
WIFE harmless against any claim IJased upon the home equity loon,
On the date of this Agreement, HUSBAND will transfer to WIFE all his right, title and
Interest In the 90 acres of adjOining fonY1 land by delivering to 11er a special warranty deed.
5. Alimony: The parties waive any claim that they may hElve ono against the other for
alimony or spousal support. The parties acknowledge that each has suHiclent assets with which
to maintain themselves atter divorce
6. Marital Debt: The parties have, in their own names, cerWin credit card accounts
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which may include some marital debt. Each party will be responSible for the debt on the credit
card accounts In his or her name, Each party will Incur no debt tor which the other may be liable,
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and will Indemnify and hold the other harmless for any debt so incurred,
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any part thereot, whether arising out of any tormer acts, contraots, engagements or liabilities of
such other, or by way ot dower or curtesy, or claims In the nature ot dower or curtesy, or wldoWB'
or widowers' rlgl1t6, fomlly exemption or similar allowance, or under the Intestate laws, or the right
to take against the spouse's will; or the right to Ireot 0 lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to pnrtlclpote In a deceased spouse's estate,
whether arising under the lows of Pennsylvania, any other Statu, or any other Country, or any
rights which either spouse may have, or al any time hereallOl' have, lor past, present or future
support or maintenance, ollmony, alimony pendente lile, COLJnSlll fees, costs or expenses, whether
arising es a result of the marital relation or otherwise, except and only except, all rights end
agreements and obllgallons of whatsoever nature arising or whicll may mise under this Agreement
or before the breach of any thereat. It IS the Intention of HUSBAND and WIFE to give to each
other by the execution of this Agreement a full, complete and geneml release with respect to any
and all property ot ony 1<lnd or nature, real, personal or mixed, which the other now owns or may
hereafter acquire, except and only except, all rights and ogreements and obligations of
whatsoever nature arising or which may arise under this Agreement, or for the breach of any
thereof, subJeot, however, to the implementation and satisfaction of the condition precedent as
set forth herein above.
13. 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 tile Agreement, Including,
but not limited to, court costs and counsel fees of the other party. In the event of breach, the
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.\.I,,~. '''III III.' 41IJ/),VI,11I
GREGORY R. SHADE,
Pllln"ff
IN THE COURT OF COMMON PLIAS OF
CUMBERLAND COUNTY, PENNSVLVANIA
CIVIL ACTION. DIVORCE
VI.
MARY H. SHADE,
Defendlnt
NO. 915.
IN DIVORCE
CIVIL TERM
COMf.LAI.N~lN-DlYJlliC.E
GREGORY R. SHADE, Plaintiff, by his attorneys, FLOWER, MORGENTHAL, FLOWER &
LINDSAY, P,C" respectfully represents:
1, The Plaintiff Is Gregory R, Shade, who currently resides at 1107 Pheasant Drive North,
Carlisle, Cumberland County, Pennsylvania, where he has resided since June, 1995.
:/, The Defendant Is Mary H, Shade, who currently resides at 80 Shephard Road, Newville,
Cumberland County, Pennsylvania, where she has resided since June, 1980.
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 November 23, 1969, at Newville,
Cumberland County, Pennsylvania,
5. That there have been no prior ectlons of divorce or for annulment between the parties
In this or In any other Jurisdiction,
6, The Plaintiff avers that he Is entitled to a divorce on the ground that the marriage Is
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