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Home My WebLink About95-04433 ,.J ~] .- j . -7 tJ ~ (/J ... \- J ~ J ~ ~ o Z " ~ :".~ \1,':'-.' "J' :~'. : ; ''- .~,.' - .", ,1 ','1. - -,'~ " .'J .t1 , ,.' .i. ," .,'.' ,",: - ~:.: ' -:', ',\' , ,',. ;:-:.'; .-;-- , ~.' - .t..';~' - !" ".,' ;,' ;-t'.. i~ ,'" - ~~ ,.\.:, '" ,',.:.' 1,' \::~ ,~ ~~t ..'-" ;:., , ,11 ,,' .' .:;~ ,:~ ", .':'.}; .;~'//;l . '"." f~ ~, ~~~~~~~-~~-~~~-~-~~~~~~---~---~ ~ - - ~ ,.' ~ ~ s ~ e ~ e 8 8 ~ ,.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF * PENNA. EDWIN RODRIGUEZ, , HH, H....' '.....H......'... !I ,i II ,t II il :1 N II, .??~.~~,~........ f:!:YI~..... 1995 PIAINTIFF, ~ ,.' ~ VerslIs SUZANNE L, RODRIGUEZ, ...... - .......,... ...... ........... .......... ,', ~ DEFENDANT . .:. <:' e " <:' DECREE IN DIVORCE i '.' 81 ~ " 8 $ ~ ~ ., AND NOW, ... P.~".~b~.. .~. ... ... .. 19. .q.>.. it is ordered and decreed that..... .~~. ~9P~j:91,J??:........ ...... .......... ..... plaintiff, and.. SUZANNE: l.,. ROPRI.~................................... 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;none. The Property and CUstody Settleroont Agreement of the parties dated August 29, 1995, attached hereto and incorporated herein as Exhibit "A", shall have the same force and effect as if it had been origimllly encered'as 'an 'Order'of'COurc'provfdedi nowever;'tna~ '~He'sard'Agreemerit'sHall nQ~.~~g~.w~~n.~n~s.Q~~~~.Q~~.~n&ll .~~~&~n.~~~ .qqn~~&q~~&l.v.&lQ~,... .... ... ~ .', ~ ,,~ ~ 8 ~ '.' ~ .0, I': " ~ .:+:. .:.:- .:+:. ':0:' .:.;. .:+:. .:.:. .:.:. .:+:. .:+:. II. .' Oy The Courl: ~ lriL ",.. " a r. c. ' Allest: 1. /')!'-7[1 /;l. z.J: ~Iu!~' ~ '-UO '-7 -klh",rc, K ~ ~ ' ."7" '.;prothonotllry ~ r.' ~ ,~ ~ ~ ~ ~ :;'----. ~~:. .:.t:. ".. . -, ., .' .:.:. .:+:. .:.:. .:+:. .:.;. .:+:. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. . 8 ~ . . . ~ $ 8 8 . ~ ~ . 8 r~ ~ ~ " (I ~ ~ ~ ~ ~ ,.~ M ~., ~ '.' .;; ~ i ... ,', ~ ~ '.' .', ~ v '.' ~ '.' ~~ i~ /"., I~ I... i i , I \ l I \ IJ.b Ii5 M. doJ'I.,.J 1$ 4 ~.L ~.~.9.5'" 7~ }#.{p.Jt. $111 EDWIN RODRIGUEZ, IN ntE COORT OF C<M>\CX'l PLEAS OF CU>lBERLAND COONI'Y. PENNSYLVANIA Plaintiff, NO. 4433 CIVIL 1995 vs. SlJZJ\NNE L. RODRIGUEZ, Defendant. IN DIVORCE. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information. to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: By regular mail. Acceptance of Service signed by Defendant on 9/8/95 and filed on 9/20/95 3. Canplete either Paragraph A. or B. (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None. All issues were settled in the Property and CUstody Settlement Agreement to be incorporated in the Divorce Decree 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code LlrltJJJ! - I Attorney for Plaintiff~ ~ "1-->/ ~ - '. , "t,\ "'.'" ..- .' - ' ~,i,t:~~. '.';-oJ ~ . ." '~,' .;-j-; '. -'.",1",("',' ,~ ..' " ;J:< ~. ' < ~::\,~ -, ". ~\t "0<.....' " "~4'.<~U~.!,:~'!;t\:.!,,,:'~'l ,:,'.' ;";,,:}:.,<~,, !. '::/l::~' "<""'-'~"'\!';';'~:l'.[f i",".;.." ".,!","F',y", :::~:';'I;\~"j<'{~i:i<2':'1"':~;"''C):: ~c,:" .";:~:,:.; ",,\' ." ~.,:.};;:;"", ,'tt>j~?J~~;:i',:ji,"" ';,::1;;; T", 'If 'i~!"'" t\.,:,,~,.,~.. ~;;..: ,'<:'.>' ~'.. 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""'1" ','i' ',:::.;;:;::1Y:$~;;1!i;t"~lj'~ II.!).! ,,<' ,', " " ;" " .;}~{ }:I\:,:t,""'''''~''';hL'''';;:i' t5,.c . h' r...,);:.,'.,,:_I~:";'::"(""'''' OM'" ..:l": ' )"," .~,v.,..;.-:~",:.- ,~ ~-'." . -II: ... t h." I - .' .' , "'".!'-:",,-.r,:: ~:l'i'};;':~;;~~:S-~~::~~:'a '" ; " _, ' ' " ,.' ,',' ,'... "","''',,'' - ",Ii' 1,' .... I' , ;',:" ,: " "/'.;" "c..;":",..."...,~\<':,p,>;i,",,,:' l:: _".. ./"\<'~f:-~~'~~~~l'.I"li~t";,;i-"..'i;'i/~+r l...... " 'li!'C' ,,~,.. '~"<"':""';"'" f" , ,~~~)/,,( :: ,'( z ~:.~~.:,:~~,~it~~~..:!,r;~~~~~:~:~,i,l.:~'~;~'~}.~,~+;,~~',: 6- '" :,:,:',!,,:,;:'!"""'.;;,::,:)::':,~ ." /!I' - ,'. "',....".;,... "c'; ... i,)~~J~4~~~:i~;;~,I/!,;\\'; ...::" ,,;;~;i~~ii?~{;,:. '. , ,':C:,: i~"W,,"':"~(~ ,;if,ae L"''':-:~::' .,/-j ..,." "" ,~..," ..,... ',!-".l-"~'" ".'" !". >.',}'..:f,", ,j.,~,.~,,: ':' , .:'~_\ "I',*\lX":\y;;;.t'~:\,\,~>,14;,~,,t;~/.'\.,. ':ft,':'3~<:." ..\\1~' 1~' ';;' ,q~;!::.'l~'" ~<,'" ,c "...~ ":"'J'.r~"'J."="">~"<,j',,,,,,S ..,,;:n,.~h' "', "' \, ,',"'of' '..'. " ': ",e .~. J,h' ..',.- ..." 'i':;";" '''. "..,..,; ,'" ",~. .,. \~<" .. , " ' ,,<,~';' '. ..' \ ~_".\:,., . ',," _.'c~. ' ." ,,'~' ",~",,_,,~~'~'''''r'''''' ...p", 'I" .... ," , ,.'" ".,,~" Vr" "'?f'"-''' . . -:...; ,'.w' '''O>~{.P'"'-' ').t ,~ ..}~... ;1.~. . .. ~.It ,., j:;,~, ~~ ". , " .... ~",' . :<',~ ~I ~ . ~~ ~I ',-, '. . ".; "'f.- ~ . .A 'u , , .....:--- ,.". ._...,-~.~.,..,.,.~"--,,," ,,';,. '" ..,..;.- 1-",'-":' EDWIN RODRIGUEZ, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION - LAW NO.: q.'J~- If Ir J :3 (}.,tA).<.fL ,) UV~ , vs. SUZANNE L. RODRIGUEZ, Dcfcndant. IN DIVORCE [' \ \ ~OTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to dcfcnd against thc claims sct forth in thc following pagcs, you must takc prompt action. You arc warncd that if you fail to do so, the case may procccd without you, and a Dccrcc of Divorcc or annulmcnt may be cntcrcd against you by thc Court. A judgmcnt may also bc cntcrcd against you for any othcr claim or rclief rcqucstcd in thcsc papers by thc Plaintiff. You may lose moncy or property or othcr rights important you, including custody or visitation of your childrcn. , When the grounds of thc divorcc arc indignitics or irrClricvablc brcakdown of thc marriage, you may request marriagc counselling. A list of marriagc counsellors is availablc in the Officc of thc Prothonotary, Carlislc, Pcnnsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 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. I I \ CUMBERLAND COUNTY COURT ADMINISTRATOR'S OFFICE Cumbcrland County Court House Fourth Floor Onc Courl House Squarc Carlislc, Pcnnsylvania l7013 (717) 240-6200 EDWIN RODRIGUEZ, vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION. LAW Plaintiff, SUZANNE L. RODRIGUEZ, NO.: Dcfcndant. IN DIVORCE NOTICIA Le han dcmandado a ustcd cn la cortc. Si ustcd guicrc dcfcndcrsc dc cstas dcmandas cxpucstas cn las paginas siguicntcs, ustcd ticnc vicntc (20) dias dc plazo al partir dc la fccha dc la dcmanda y la notification. Ustcd dcbc prcscntar una aparicncia cscrita 0 cn persona 0 por abogado y archivar en la cortc cn forma cscrita sus dercnsa.~ 0 sus objcctioncs a las dcmandas cn contra dc su persona. Sca avisado quc si ustcd no sc dcricndc, la cortc tomara mcdidas y pucde entrar una ordcn contra usted sin prcvio aviso 0 notification y por cualquicr qucja 0 alivio que cs pedido cn la peticion dc dcmanda. Ustcd pucdc dincro 0 sus propicdadcs 0 otros dcrcchos importantcs para ustcd. LLEVE ESTA DEMANDAA UN ABODAGO INMEDIATAMENTE. SI NOTIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUlR ASISTENCIA LEGAL, CUMBERLAND COUNTY COURT ADMINISTRATOR'S OFFICE Cumbcrland County Court House Fourth Floor Onc Court House Squarc Carlislc, Pcnnsylvania 17013 (717) 240-6200 vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION. LAW EDWIN RODRIGUEZ, Plaintiff, SUZANNE L. RODRIGUEZ, NO.: Defendant. IN DIVORCE COMPLAINT NOW COMES thc Plaintiff by his allorncy, Karl M. Lcdebohm, and brings thc following complaint: COUNT NO. 1: SECTION 3301 (C) OF THE DIVORCE CODE 1. Plainliff is an adult individual who rcsides at 418 Third Strcct, New Cumberland, Pennsylvania, 17070. 2. Defendant is an adult individual who rcsidcs at 960 Pleasant Grove Road, York Haven, York County, Pcnnsylvania, 17370. 3. Defendant has bccn a bonafidc rcsidcnt in thc Commonwcalth of Pennsylvania for at least six (6) months immediatcly prcviously to thc filing of this complainl. 4. Thc partics werc lawfully married on or about April 29. 1988 at Hagcrstown, Washington County, Maryland by Linda D. Dorricr. 5. Plaintiff avcrs thalthcrc arc Iwo childrcn of Ihc marriagc undcr thc agc of 18; namely, Damicn Michacl Rodrigucz born on March 14, 1988 and Mcgan SU1.annc Rodrigucz born on Fcbruary 17, 1990. 6. Thc partics havc bccn separatcd sincc un or abuut August of 1990. 7. Thcrc havc bccn no prior actions of divorcc or fur annulmcnt bctwccn Ihc partics. 8. Plaintiff avers that thc grounds upon which this action is based arc that thc marrlagc Is irrctrlcvably brokcn. WHEREFORE, thc Plaintiff prays thc Honorablc Court to cntcr a Dccrcc in Divurce, divorcing thc Plaintiff from thc bonds of matrimony hcrctoforc contractcd betwccn thc Plaintiff and thc Dcfcndant. Rcspectfully submittcd this -.1l!!day of _~t1",,,-I- . 1995. ~ rl . Lcdcbohm. Esquirc Attorncy for Plaintiff Attorncy I.D. No.: 59012 100 Old York Road P.O Box 236 Ncw Cumbcrland, PA 17070-0236 (717)774-3122 I, Edwin Rodrlgucz, Plaintiff In thc forcgoing action, bcing duly sworn according to law, COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) depose and say: That I ccrtify that thc statcmcnts madc in this Complaint arc truc and corrcct. I understand that false statcmcnts hcrcin are madc subjcct to thc pcnaltics of 18 Pa. C.S. Section 4904, rclating to unsworn falsifications to authorities. Subscribed and sworn to bcfore me thc undcrslgncd Notary Public, this / f .,.4 day of ~/..<: f: , 1995. J...;uu ht.. d~w Notary Public My Commission Expircs: Notarial Seal Lisa M, Ledebohm. NOlary Public New Cumberland Boro. Cumllelland Counly My Commission Expire' JulV 20, \998 Mentlot. PemsyMII1lIAsGoOaDon cl Nolatias .~.._. -'.'.'~''''.'''-~''''~'''''~_., . EDWIN RODRIGUEZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VR. CIVIL ACTION - LAW SUZANNE L. RODRIGUEZ, Defendant. NO.: 954433 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 33111(c) of the Divorce Code was filed on August 18, 1995. 2. The marriage of Plainliff and Defcndant is irrelrievably broken, and ninety (90) days have elapscd from the dale of Ihe filing of the Complaint. 3. I conscntto the enlry of a Final Decree of Divorce. 4. I understand that I may losc righls concerning alimony, division of propcrly, lawyer's fees or expcnses if I do not claim them before a divorce is granted. I verify that the statements madc in this Affidavit arc truc and corrcc\. I undcrstand that falsc statcmcnls hcrein arc made subject 10 Ihe pcnaltics of 18 Pa. C.S. Scction 4904 rclating to unsworn falsificalions to authorities. Datcd: "\L"'\~C; b..l.')'f-1Ul.! L lZ'<!.U~~"'Y SUZANNE L. RODRIGUEZ ~ co IJ') .. ~~ I! '" :c ~ "- Q~ - :52': I U ~~ LLI C t5 IJ') 0\ "-~--;~.-~- ... .--..,"'- ,,,,-~... .'.' . . EDWIN RODRIGUEZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY,PENNSYLVANIA CIVIL ACTION - LAW vs. SUZANNE L. RODRIGUEZ, NO.: 95-4433 Civil Tcrm Defcndant. IN DIVORCE ACCEPTANCE OF SERVICE I, Suzannc L. Rodrigucz, the Dcfcndant in thc abovc captioncd mattcr, do hcrcby ccrtify that a truc and corrcct copy of thc Complaint with attachcd Noticc to Dcfcnd and Claim Rights and Notice as to Counsclling filcd in thc abovc-captioncd mattcr has been dclivcrcd to me and that service of samc is hcreby accepted this ~ day of ~-k,,1c-/ , 1995. ~'L\H L. ~c,..~ Suza c L. Rodriguez >\-.- ,v ::c c.- .... "" C"? ~... ~~ oC~ t-, ~ ~~.:-~_.~ ,- ~.._...; ::::c..:. n:. ~;:, :...:1.- ." ~ - ~ ....... ... .... V"t . . .' other or against their respective estates. 3. Wife has been independently represented by Attorney Gregory J. Katshir in coMection with the preparation of this Agreement. 4. The Parties have lived separate and apart since on or about August of 1990 and may and shall, at all times hereinafter mentioned live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or Indirect, by the other in all respects as if he or she were unmarried. Each may reside at such place or places as he or she may select. S. The Marital assets of the Parties consist of household furnishings and personal property, individual checking and savings accounts not in excess of $1,000.00, a pension in Husband's name alone through Husband's place of employment, a statement of which is attached and incorporated herein as Exhibit "A", and a pension in Wife's name alone through Wife's place of employment, a statement of which is attached and incorporated herein as Exhibit "B". 6. During the course of the marriage, Wife and Husband have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without the necessity of ascertaining for what purpose and to who's use each of the bills were incurred, that the Parties shall be responsible for the debts that each has separately incurred after August of 1990, the date of separation, and agree to indemnify and save harmless each other for same. 7. The Parties acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and inventory of same, and no statement or representation by either party as to value shall be deemed a misstatement or mlsrcprescntation to the other or bc deemed fraudulent. 2 -. " I .. . 8. Husband shall have as his sole and separate property all household furnishings and personal property, now In his possession, all bank aCCOunts now In his name alone and the said pension in his name alone. 9. Wife shall have as her sole and separate property all household furnishings and personal property, now In her POssession, all bank aCCOunts now In her name alone and the said pension In her name alone. 10. Each Party shall retain as his or her own separate property, any pension, stock, savings, retirement or other plan through hls/her place of employment whether vested or non vested, and both Husband and Wife specifically waive any right that either may have In the said pension, stock, savings retirement or other plan of the other that Husband or Wife may have acquired thereto by their marriage to each other. Each Party shall be and remain the sole Owner of any other asset in his or her control not specifically Covered by this Agreement. 11. Each of the Parties shall hereafter own and enjoy independently of any claims or right of the Other, all items of perSOnal property, tangible or intangible, acquired by him or her after August of 1990, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 12. The Parties acknowledge and agree lhat a Support Order enlered by the York County Court of Common Pleas on Iune 12, 1995 to Docket No. 1889 Support Action 1990, a copy of which is attached hereto and Incorporated by rcferencc hercin as Exhibit "C", shall remain in full force and effect subject to the review and modification of same, from time to time, by the Court or by application by the Parties to the Court for such modification. 3 '. .' 13. The Parties acknowledge and agree that Wife has paid to Husband, prior to the time hereof, $100.00 towards the cost of filing the Complaint in Divorce in this matter which shall be the extent of Wife's contribution to Husband's legal fees. Each party shall be solely responsible to pay his or her own legal fees In connection with this agreement and fiUng for and obtaining a consensual, No-Fault Divorce Decree. 14. Husband and Wife each do hereby mutually remise, release, quit claim, and forever discharge the other in the estate of such other, for aU time to come, and for aU purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the estate of such other, of whatever nature and whatsoever situate, which he or she 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 widows or widowers rights, family exemptions or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or thc right to treat a lifetime conveyance by thc other as testamcntary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whcther arising undcr the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country, or any right which either party may have or at any time hereafter have against the other for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenscs, whether arising as a result of Ihe marital relationship or otherwise, except, and only exccpt, all rights and agreements and obligations of whatsoever nalure arising or which may arise under this Agreement, the said support order entered by the York County Court of Common Picas to 4 .' Docket Number 1889 Support Order 1990, or for the breach of any part thereof. It is the intention of Husband and Wife to give 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 hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or the above stated support order or for the breach of any provision thereof. 15. Husband and Wife do hereby agree, release and give up any and all rights they have or may respectfully have against each other for alimony, legal fees, except as otherwise provided herein, spousal support or maintenance, for themselves except as provided for in this agreement. It shall be from this date the sole responsibility of each of the respective Parties to sustain themselves without seeking any support from the other Party, and except as provided for herein, it shall be the sole responsibility of Wife and Husband to sustain themselves without seeking any support from the other. 16. Husband and Wife represent to each other that neither of them has heretofore created any debts, liabilities or obligations that would bind the other and that each covenant, warrant, represent and agree that each will now, at all times hereafter, save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other prior to or after the date hereof except as otherwise specified herein. 17. Husband and Wife both agree that they have been respectively advised and are aware of the contents of the provisions of the Divorce Code of 1980, as amended, in Pennsylvania wherein considerations are set forth in determining an appropriate amount, if any. to be paid in 5 the form of alimony. Afler being fully advised of the contents of the Divorce Code of 1980, as amended, both Partie. voluntarily and intelligently waive and relinquish any right to seek .from thc othcr payment for .upport, alimony and maintcnance except as providcd for hcrein. 18. Wife shall have primary physical custody and sole legal custody of the said Damien Michael Rodrlgucz Ilnd Megan SUi'.lInne Rodriguez. Husband shall have secondary physical custody and liberal visitation of the said children as Ihe Parties may agree. 19. Nelthcr Party shall remove the children from the Commonwealth of Pennsylvania for the purpose of relocating or otherwisc without first having obtained the written consent of the uther party. Both Pllrtlcs agree to promptly Inform the other of any change in residence of elthcr Party includIng address and telephone number. 20. Wife shall be enlitled to take any income tax exemptions and/or deductions allowable for the said chlldrcn for federal income tax purposes and under any applicable state or local tax provisions for a period of five (5) years from the date hereof and thereafter provided that the nld children are in Wife's custody for a period of at least 180 days out of the year for which thc exemptions or deductions are claimed. If in any tax year Husband violates this Agreement by claIming an exemplion for the said children as dependents for such year, and if the Internal Revenuc Service refuscs to allow dependency exemption Cor Ihe said children for such year to Wife, then Husband shall pay 10 Wife the amount of Wife's additional tax liability including penaltIes, fines and costs. 21. A decree in divorce, entered by a court of competent jurisdiction to either Party, shall not suspend, superscde or affect the terms of this Agreement. Both Parties agree to enter 6 a Consent Order or orders concerning the provisions of this Agreement in the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court of competent jurisdiction, as a part of a resolution of any divorce action filed or to be filed. This Agreement, and the terms and conditions contained herein, as well as the enforcement of said terms and conditions, shall not be contingent upon the granting of a Divorce Decree to either Party by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. Furthermore, both Parties hereto agree to timely execute the appropriate aCCldavlts and consents to secure a No-Fault Divorce as may be required by the Divorce Code of 1980, as amended. Both Parties hereto agree that this Agreement may be incorporated into a separate Court Order but shall not merge in such order in the Court of Common Pleas of Cumberland County, Pennsylvania. 22. Husband and Wife acknowledge that Husband will file a complaint in divorce before the Court of Common Pleas of Cumberland County, Pennsylvania, pursuant to Section 3301 (c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (hereinafter referred to as the "Code"). The provisions of this Agreement may be incorporated in any divorce decree that may be entered granting a decree of absolute divorce. 23. Husband and Wife covenant and agree that upon request of the other Party, they will forthwith execute and deliver to the other pdrty any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 24. Each of the Parties hereto represents to the other that he or she has made a full, 7 complete and accurate dlac:losure of all assets that he or she may own Individually or jointly belna as herein let forth at the tlmc this Agreement has been entered or executed. 25. The provIsions of this Agreement are fully understood by both Parties, and each party acknowledaes that this Agreement is fair and equitable, that it is being entered into voluntarily and that It Is not the result of any duress or any undue influence. 26. If either Party breachcs any provision of this Agrccment, thc other Party shall have thc rlaht, at his or her clectlon, to sue for damages for such brcach. Thc Party breaching this ^arcemcnt shall be responsible for the payment of reasonable legal fees and costs incurrcd by thc other In enforcing his or her rights under this Agreement or secking such other remedy or rcllcf as may be available to him or hcr. 27. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or othcrwise, then only that term, condition, clause or provisIon shall be strickcn from this Agrccment and in all othcr respects this Agrccmcnt shall be valid and contlnuc in full forcc, eCCect and operation. Likcwise the failure of any party to mcet his or her obligations undcr any onc or morc of thc paragraphs herein with thc exception of the satisfaction of thc conditions precedcnt, shall in no way void or alter the remaining obligations of the Parties. 28. This Agreement shall bc construcd in accordance with the laws of the Commonwealth of Pennsylvania. 29. The failure of either party hcrcto to cnforcc any tcrm or condition of this Agreement shall not constitute a waiver as to any subsequent violation or dcfault of such term or condition. 8 .' '. . 30. This Is the entire Agreement between the Parties hereto and shall be binding upon them, their heirs and assigns, and shall not be modified except In writing and signed by the Parties hereto. IN WITNESS WHEREOF, we have hereunto set our hands and seals the day and year first above written. L- b...v,~ L, l..lJl\A'\:"1- ne L. Rodriguei "Wife" 9 . . , COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cullt.6er lll'tel ) ) ss: ) On thls, the /ff/Ilday of , 1995, before me, a Notary Public in and for said Commonwealth and County, sonallyappeared Edwin Rodriguez, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. d2w ilL (tJ;;lLkiu~ Notary Public My Commission Expires: Notarial Seat U!03 1.4, ledebohm. Notary Public New Cumberland Boro. Cumberland County My Commission Expires July 20. 1998 MentJer, PEl.. v,Mril "1IlUV'i~ otNolaiel COMMONWEALTH OF PENNSYLVANIA ) ) ss: COUNTY OF CUMBERLAND ) On this, the ~ day of ~\.M..~ ,1995, before me, a Notary Public in and for said Commonwealth and County, personally appeared Suzanne L. Rodriguez, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~~ ~~~ Notary p:1lic My Commission Expires: 10 Not8I1aJ SeeJ le Tracy K.l<a\ahtr. Notary Public M ~ 801'0. CUmber1llnd County Y rnmlasJon Expires Juno 21.1999 . . . DUPL THE CENTRAL PENNSYLVANIA TEAMST~RS RCTIREMENT 1055 SPRING STRE~T WYOMISSING. PA 19610 MAILING ADDRESS: P.O. BOX 15223 READING. PA 19612-5223 INCOM!: PLAN 1994 ANNUAL EMPLOYEE BENEFIT STATEMENT .' 4'06'95 RODRIGUEZ EDWIN 418 3RD ST NW CUMBERLAND PA 17070 SOCIAL SECURITY - 105-50-8271 BIRTH DATE 2'22'59 SPOUSE NAME - SUZANNE RODRIGUEZ SPOUSE BIRTH DATE - 1'18'55 SPOUSE SOCIAL SECURITY NO.- 166-48-930" REPORTED DATE OF HIRE - 7'11'85 VESTED STATUS - 100X VESTED ESTIMATED NORMAL RETIREMENT DATE - 03'01'2016 DETAILS OF EMPLOYER CONTRIBUTIONS POSTED TO YOUR ACCOUNT FOR THE YEAR 1994 THAT WERE RECEIVED BY 3'17'95. EMPLDYER ROADWAY EXPRESS INC ROADWAY EXPRESS INC ROADWAY EXPRESS INC ROAOWAY EXPRESS INC ROADWAY EXPRESS INC ROADWAY EXPRESS INC ROAOWAY EXPRESS INC ROAOWAY EXPRESS INC ROADWAY EXPRESS INC ROAOWAY EXPRESS INC ROADWAY EXPRESS INC ROADWAY EXPRESS INC MONTH PO FOR JAN..94 FEB..94 MAR..94 APR..94 MAY..94 JUN..94 JUL..9" AUG..94 SEP..94 oCT..94 NOV..94 DEC..94 TOTAL LATE CONTRIBUTIONS'ADJUSTMENTS TO PREVIOUS YEARS - HOURS PAID 117 147 1117 57 104 160 148 160 184 160 160 192 TOTAL DOLLARS 325.84 409.39 !>20.79 170.14 310.44 477.60 44 t. 78 477.60 549.24 477.6\1 477.60 573.12 5.211.14 .00 DEVELOPMENT OF ACCUMULATED ACCOUNT BALANCE FHOM, 12'93 TO 12'94 : A. ACCOUNT BALANCE AS OF 12'31'1993 - B. CONTRI8UTIONS RECEIVED OURING 199" C. NET EARNINGS ADDED DURING 1994 - D. ACCOUNT BALANCE AS OFI2'31'1994 - 41.178.70 5.211.14 52B.97 46,918.81 . INCLUDES 11I9 ANNUALIZED RATE OF RETURN EARNED ON THE FUND FOR 1994 - 0.50 ~ NOTE: INTEREST IS ACTUALLY CREDIT~O TO YOUR ACCOUNT BASCO ON OUARTERLY RATES OF RETURN. THEREFORE THtS RATE CANNOT ~E USED TO VeqlFY THE "N~T EARNINGS ADDED" .AMoUNT ABOVE. YOUR ACCOUNT BALANCE SHOWN ABOVE IS SUBJECT TO ADDITIoNS.DELETIONS AND CORRECTIONS. r"V , 717-770-4611 DDRE-WIB ---------------------------------------------------------------------------- '. .. I BHPLOrB! HAMI! I DATE Of BIRTIf: SERVICE COMPUTATION DATE. DATB or SEPARATION I DArB OF RBTIREMENT. EHPLOlCEI1S AGE AT RETIREMENT. HIGH-3 AVERAGB SALARYI 841 P02 FlUG 29. ',95 .' , DATCI 08~28-1995 '. ., t,; 'j , nllB lHPLOYl!:1!: DATA ....._~-....-..__.._- SUZANN! LISA RODRJGUI!Z 01/18/1955 01/02/1984 09/30/1"'\J~ 01/18/2017 62 YEARS 0 MONTHS 8 21,007 ) ,; ~ t ,;. FIRS SERVIce CREPIT. ......-...........~.....-~..R.ft.~MI.........n.....~w~.~~b.....~.......__..._ 29 !lAYS ..au.......-.....--......_.~_M_~..._..._._.N..................._............ 11 YEARS 8 MONTHS .... -- ... "eSTIMATBD" DEFERRED ReTIREMENT BENEFITS ----------------------------------- DBF!RR2P BASIc ANNUITY: ESTIHlTBD NBT ANNUITY. . [,-t f'>, .." \.Jo ,.",- AUtfUALL~ NORTRLY ..----..--- ------...-- $ 2,448,00 $ 204,00 ---.......---- -..-........-- $ 2,448,DO $ 204.00 a.......... .-....... ,1 I, L; ,; " 'f t~ ; ~ co In : lJ N ~~ , ~~ :c ?; ~, "- Q~ j: ~ ~0. I, I C 4- t~ ~~ CJ ~~ 1..1_' Co. .." , 15 V) a .' C1> \ -. ."'. ., , IN DIVORCE EDWIN RODRIGUEZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY . PENNSYLVANIA vs. CIVIL ACTION - LAW SUZANNE L. RODRIGUEZ, Defcndant. NO.: 954433 Civil Tcrm AFFIDA vrr REGARDING COUNSELLING I. I havc bccn advised of thc availability of marriagc counselling and undcrstand that I may rcqucst that thc Court rcquirc that my spousc and I participatc in counselling. 2. I undcrstand that thc Court maintains a list of marriagc counsellors in thc Domcstic Rclations Officc, which list is availablc to mc upon rcqucst. 3. Being so advised, I do not rcquirc that thc Court rcquirc that my spouse and I participatc in counselling prior to a divorcc dccrcc bcing handcd down by thc Court. I vcrify that falsc statcmcnts hcrcin arc subjcct to thc penal tics of III Pa. C.S. Scction 4904 rclating to unsworn falsifications to authoritics. Datcd: t1frll 11- /ffl{" t5 i Cl) ~ IJ') N 8~ ::: z. ~ I~ 0- ~~ ~ I -.. . ~ Co.) ~okE Lu C ::: ~ IJ') a 0'\ co ~i IJ') N .; ::t: Q.. O~ ~~ I ~ Co.) I.1J C a ts tf) en EDWIN RODRIGUEZ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. SUZANNE L. RODRIGUEZ Defendant NO: 95-4433 CIVIL TERM IN DIVORCE PRAECIPE FOR APPEARANCE To the Honorable, the Judges of This Court: Please enter my appearance in the above-captioned matter. Respectfully SUbmitted, >.(1 Gregory atshir, Esquire Attorney or Defendant PA ID I 61967 900 Market Street Lemoyne PA 17043 (717) 763-8133 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW EDWIN RODRIGUEZ, Plaintiff, vs. ) ) ) ) ) ) ) No: 95-4433 CIVIL TERM SUZANNE RODRIGUEZ, Defendant. IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Defendant in the above matter, having been granted a final decree in divorce on the ".\1.. day of December, 1995, hereby in~ds to resume and hereafter use the previous name of Sv2Al\liJ\ () and gives this written notice avowing her intention in accordance with the provisions of the December 16, 1982, P.L. 1309, 54 Pa. C.S.A. ~704 (effective March 16, 1982.) ~ i.l1~ L eCi(lll~ ~ature of Petitioner TO BE KNOWN AS: ~.lLll J Ltm Qt#. Sign ture - Intended COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) On the 17.-\-hday of December, 1995, before me, a Notary PUblic, personally appeared Suzanne Rodriguez, known to me to be the person whose name is subscribed to the within document and acknow13dged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. '-;\\0. ...', \::: t'o: \"",', ~ ~tary (Public - My commission expires: NoIartaJ Seal Tracy K. Katshlr, No!ary PublIc Lumoyno Bora, Cumbo~.nd Counly My Commission E'plres Juno 21, 1999