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HomeMy WebLinkAbout95-04565 -'. '\, ~ " '. '.:"':'.;c.' '.:.:-: ..lfr.;c.:'''...., '.;c.' :'X.':.;c.::.;c.; ,,-.e-:'.;c.- .:C" -,.;. '".:-: '.:+:. '.:.:-: '.:':-".;c.: ":C.',X:.:C">:4C(XIIO(>:~;.:wx :,,~ :-llI>:XIIO(~~ ~ 1'- @. 8 ;.0, 'I ~ IN THE COURT OF COMMON PLEAS $. ~ ~ e OF CUMBERLAND COUNTY ~ :, .1 8 Q ~ ~ ^ ~ ,~. 8 ~ STATE OF ~_'" PENNA. ~ ~ '~ a ~ ~ 8 .~~~,J).!..~~,.......,.,..<<.......,..<<.......,....<<..<<. ~ N ().......~~.7,1~,l?~.. G~y.g'....... 19 " ~ ~ ~ 8 ~ r: ~ , ~ ~ ~ ~ e ....d.. .. ~ ~ ~ '=: e ~ " ~ ~ ~ ~ ~ ~ $ ~: i!! L ~ ~ ~ ~ ~ ~ ......., '...".." ......... ,..Plaintiff........ '''....,.., ...,.., .......,... Versus .~.!'I.".~~"",.......,..,....,..w"..................... .. ,..........Defendant, DECREE IN o I V 0 R ~~ it.l.l~}'f;4- . . , . . . .9. , . . . .. 19...,... It is ordered and 8 I ~ ~ ., ~ $ M " ~ ~ AND NOW,.... decreed that .......~~~.. .~~.c;~........................I.' plaintiff, and ..... .~. t-t,. ~~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . r 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 . ~t~~' ~~lFUI:I:~~' P!lP~!;tP. .t/1fl,t. ,t,~ .t.e.I)l!f\,. ,c;q~~~~ql]fj.'!l1'! ,c;ql{lll)qt)~li .liq~ .f9J;'~h ..... ,.. wr en i:lUparatoLVn and Property Settlerrent made and entered into by the. parties. on. June, 19." 1996." are .incOI:pocated ,into ,this ,000cL'ea ,by ,mfereflc:e thereto, but not rrerged into this Decree. ..' ~ ;:, " 8 " ~ ~ ? s s -__ ~...--____.....___.__ ----.......-...~ M ~~*~~~~~~~~~,.~,.~:._.~~~ro_~~ I$' ... en :~ f:r; '.. ~~ CA ~-.).- !AlP . -, . ~ -.- f" :1: -.J::;: ...., -0; ". ' J:.:: -J8 (.1 C') , "f/J IF I '}"" I :;; l" -J "Ji';J 1; :::;, :'1 a. 1- .. L1. lO [3 O. c, . .' , . . NOW, THEREFORE. in consideration or the above recitals and the following covenants and promises mutually made and mutually to be kept the parties heretorore, intending to be legally bound and to legally bind their heirs, successors, and assigns thereby. covenant, promise. and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place or places as he or she may from time to time choose or deem fiL 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to cany out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other. nor compel the other to cohabit with the other. nor in any way harass or malign the other, nor in any way interfere with the peaceable existence. separate and apart from the other in all respects as if he or she were single and unmarried. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since their separation on August 2, 1995, she has nol. and in the future she shall not, contracl or incur any debt or liability for which Husband or his Estate might be responsible and shall indemnify and save Husband harmless from any and all claims and demands made against him by reason of debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since their separation on August 2,1995, he has nol, and in the future he will nol. contract or incur any debt or liability for which Wife or her Estate might be responsible and shall indemniry and safe Wife hann1ess from any and all claims and demands made against her by reason or debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: Husband and Wife acknowledge and agree that they have no outstanding debts and obligations or the Husband and Wife including prior to the signing of this Agreement. except as follows: ltmn Person Assuming Resoonsibility 15 Wheatland Drive. Silver Spring Township Real Estate Taxes ror 1995/1996 to Date Wire 2 " . . Each party agrees to pay the outstanding joint debts set fOM herein and further agrees to indemnify and save hannless the other from any and all claims and demands made against either of them by reason of such debts or obligations, 6. MUTUAL RELEASE: Subject 10 the provisions of this Agreement. each party waives his or her rights to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980. Subject to the provisions of this Agreement, each party has released and discharged. and by this Agreement does for himself or herself. and his or her heirs, legal representatives, executors, administrators. and assigns. release and discharge the other of and from all causes of action. claims. rights or demands whatsoever in law or equity which either of the parties ever had or now have against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for divorce and except in any or all causes of action for breach of any provision of this Agreement. Each party also waives his or her right to request marital counseling pursuant to 23 Pa. C.S.A. Section 3302. 7. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY: The parties have a1tempted to distribute their marital property in a manner which conforms to the criteria set fOM in 23 Po. C.S.A. 93501. m.~. and taking in10 account the following considerations: the length of marriage; the fact that it is the second marriage for Wife and rust marriage for Husband: the age. health. station. amount and sources of income. vocational skills. employability, estate. liabilities and needs of each of the parties: the contribution of each pany to the education. training for increased earnings power of the other party; the opportunity of each party for future acquisitions of capital assets and income: the sources of income of both parties, including bu1 not limited to medical. retirement. insurance or other benefits; the contribution or dissipation of each party in the acquisition. preservation. depreciation or appreciation of the marital property. including the contribution of each spouse as a homemaker; the value of the property set apart to each party: !he standard of living that the parties established in the marriage: and the economic circumstances of each party at the lime !he division of property is to become effective. The division of existing marital property is not intended by the parties to constitu1e in any way a sale or exchange of assets. and the division is being effected without the introduction of outside funds or other property not cons1ituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 3 A. DISTRffiUTION OF PERSONAl. PROPERTY: The parties hereto mutually agree lhatlhey have affected a satisfactory division of lhe furniture. household furnishings. appliances and olher household personal property be1ween lhem and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession, and this Agwement shall have effect of an assignment or bill of sale from each party to lhe other for such property as may be in the individual possession of each of the parties hereto. The parties hereto have divided between themselves to lheir mutual satisfaction. all items of tangible and intangible marital property. Further. Husband agrees to waive any right, title and inlcrest he may have regarding intangible assets currently titled in Wife's name. but acquired during the marriage. Those assets are FNBN Financial Corp.; Van Kampen Merrit Fund; Putnam Investments; Corefund: Lord. Abbett & Co.: Phoenix funds: and the Independent Fmancial Group. Neither. party shall make any claims to any such items of marital property, or of the separate personal property of each other, which is now in the possession and/or under the control of lhe other. Should it become necessary. the parties each agree to sign, upon request. any titles or docurnents necessary to give effect to Ibis paragraph. Property shall be deemed in the possession or under lhe control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of lhe signing of Ibis Agreement and. in the case of intangible personal property, if any physical or written evidence of ownership. such as passbook. checkbook. policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of his or her own individual pension or other employee benefits, plans or retiremen1 benefits in any nature with the exception of Social Security Benefits to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits. From and after the date of the signing of this Agreement. bolh parties shall have the complete freedom of disposition as to hisiher separate property and any property which is in lheir possession or control pursuant to this Agreement and may mortgage, sell, grant. convey, or otherwise encumber or dispose of such property. whether real or personal. whether such property was acquired before. during or after marriage and neither Husband nor Wife need join in. consent to, or acknowledge any deed, mortgage or other inslniment of the other pertaining to such disposition of property. 4 B. PJSTRIBJIJlQN.oEREALJ~S~TA'rn: Husband agrees to transfer to Wife all of his interest and tille to their jointly owned real estale at IS Whealland Drive, Mechanicsburg. Cumberland County, Pennsylvania. Wife covenants and agrees to pay all real estate taxes for 1995 and the:eafter, along with any c1ean.up costs associa1ed with the property and ownership of same. Wife also agrees 10 accept Forty-one Thousand Four Hundred Thirty-three and 36/100 Dollars ($41.433.36) as payment in full of her share and interest regarding insurance claim benefits issued to Husband under his American Bankers Insurance Co. of Florida Policy No, CPll041096400; Claim No. 001000000704 regarding 15 Whealland Drive. Mechanicsburg. Pennsylvania. Said payment in full has been made heretofore to Wife. and there is no further payments due or owing Wife. Further, Husband also agrees 10 transfer to Wife all of his interest, claim and tille to the real estate tilled in Wife's name located at Locust Valley. Bamesville, Schuylkill County, Pennsylvania, and Wife covenants and agrees to pay all real estate taxes for 1995 and thereafter associated with the property and ownership of same. Further, Wife also agrees to waive all of her interest. claim and/or title to the real estate titled in Husband's name located at 10 Houston Drive, Mechanicsburg. Pennsylvania, and Husband covenants and agrees to pay all real estate taxes for 1996 and thereafter associated with the property and ownership of same. Finally. Husband waives any and all right, tille or interest he may have in pending or future litigation as it relates to the fire loss of the residence known as 15 Whealland Drive, Mechanicsburg. Pennsylvania which occurred on November 30, 1995. C. TAX LIABILITY: The parties believe and agree that the division of property heretofore made by this Agreement is a non-taxable division of property be1ween co-owners rather than a taxable sale or exchange of such property. Each party promises n01 to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issues which is inconsis1ent with the positions se1 forth in the preceding sentences on his or her Federal or State Income Tax Return. 8. MOTOR VEHICLES: With respect to the motor vehicles owned by the parties, they agree as follows: Husband to receive the 1991 Chevrolet Van and 1991 Chevrolet Metro. These said vehicles shall be the exclusive property of the Husband. With respec1 to the motor vehicles leased by the Wife. the parties agree the Subaru SVX shall be the exclusive property of the Wife. 5 9. PENSION AND IlETIREMEI'ITJlErillfl.l'S: The parties recognize that Wife has a pension and retirement plan through Teachers Insurance and Annuity Association. Husband agrees to waive all right. title and interest to these assets. 10. HMLTH INSURANCE: After the date of entry of the Decree in Divorce. the parties shall be responsible for obtaining their own individual health insurance coverage. Husband agrees to pay Wife's COBRA premiums for twelve (12) months from the date of divorce provided Wife cannot be covered by another source of health insurance coverage. Husband shall not be responsible for any uninsured medical expenses and Husband's payment of COBRA premiums on Wife's behalf shall be considered alimony by Husband and Wife. 11. t\L1MONY /SUPPORT: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair. adequate and satisfactory to them and are accepted by them in lieu of a full and final selllement and satisfaction of any claims or demands that either may now or hereinafter have against the other for support. maintenance. or alimony except as provided in paragraph 10 herein. Husband and Wife further, voluntarily and intelligently. waive and relinquish any righ1to seek from the other any paymen1 for support or alimony except as provided in paragraph 10 herein. ,. 12. AI,JMONY PENDENTE LITE. COUNSEL FEES. AND EXPENSES: Husband and Wife acknowledge and agree thai the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair. adequate and satisfactory to them. Both panies agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands thai either may now or hereafter have agains1 the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before. during, and after the commencement of these proceedings for divorce or annulment between the panies. 13. CHILD SUPPORT: Husband is the primary physical cus10dial parent pWliuantto an Order of Court, dated January 3. 1996, and allached as Exhibit "A". HusbandlFather agrees to waive a claim of child support from Wife for the period January 3, 1996 through June 3, 1997 at which time child support. if sought. shall be delf'l1l1ined in accordance with appropriate support guidelines. It is further agreed that Husband and Wife will share equally in their children's college 6 education and/or vocational education until !he child(ren) graduate from college or reach !he age of twentY-l\Uo (22). whichever occurs last. Further. for tax year beginning 1996. Wife may claim Alanna Cremo, Adrianna Cremo. and Stephen Cremo and Fa1her shall claim Zachary Cremo. Grcggory Cremo and Alexander Cremo for Income Tax considerations for tax year beginning 1996. 14. C/lIW.J:!1S1illL'\:'; As directed by Order of Court, dated January 3. 1996 and allached hereto as Exhibit "A". 15. M!ITlID-.CR~..MQkS01iS.JI'lc.: Wife hereby forever waives any claim and interest she may have to Husband's interes1 and/or ownership rights in Metro Cremo & Sons, Inc. 16. CREMO & ASSOCIATES: Husband forever waives any claim and interes1 he may have to Wife's interest and/or ownership rights of Cremo & Associates. 17. INCOME TAX PRIOR RETURNS: The parties have hereunto filed certain joint Income Tax Returns through and including Tax Year 1994. Wife represents and warrants to !he Husband !hat she has heretofore duly paid all Income Taxes due on such returns: and she does not owe any interest or penalties with respect !hereto; and !hat no tax deficiency is pending or threatened agains1 him; and !hat no audit is pending wi!h respect to any such retum. If !here is any deficiency assessment on any of !he aforesaid returns, !he Wife shall give Husband immediate n01icc !hereof. in writing. The Wife further warrants !hat she shall pay !he amount ultima1ely detennined to be due, toge!her wi!h interest and penalties, if any. as well as all expenses !hat may be incurred if he decides to contest !he asscssment. 18. WAIVERS OF CLAIMS AGAINST EST A T]S: Except as herein o!herwise 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 now have or !hereafter acquire, under !he present or future laws of any jurisdiction. to share in !he property of !he estate of the o!her as a result of !he marital relationship, including wi!houtlimitation. dower, curtsey. statutory allowance, widow's allowance, right to take intestacy, right to take agains1!he will of !he o!her. and right to act as Administrator or Executor of !he o!her's estate. Each will. at !he request of !he o!her. execute. acknowledge. and deliver any and all instruments which may be nL'Ccssary or advisable to carry into effect !his mutual waiver and relinquishment of all such interest, rights, and claims. 7 19. MUTUAL CONSENT DIVORCE: The parties agree and acknowledge that their marriage is irretrievably broken. that they do nol desire marital counseling. and that they both consent to the entry of a Decree in Divorce pursuant to 23 Pa. C.S.A. ~3301(c). Accordingly. both parties agree to forthwith execute such consents. affidavits, or other documents and to direct their respective attorneys to forthwith file consents, affidavits. or other documents as may be necessary to promptly proceed to ob1ain a divorce pursuant to said Section 23 Pa. C,S.A. ~3301 (c). Upon request to the extent pennitted by law and the applicable Rules of Civil Procedure, the named Defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no Order, Judgment or Decree In Divorce. temporary. fmal or pennanent shall affect or modify the financiallem1S of this Agrecment, This Agreement shall be incorporated but shall no1 be merged with said Judgment or Decree of fmal Divorce. but shall be incorpora1ed for the purpose of enforcement only. 20. BREACH AND ENFORCEMENT: 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. and the party breaching this Agreement shall be responsible for payment of attorney fees, legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 21. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time. at the reques1 of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and eCfectto the provisions of this Agreement. 22. TAX ADVICE: Both parties hereto hereby acknowledge and agree that they have had the OPPOrtuni1y to re1ain their own accountants. certified public accoun1ants. tax advisor. or tax attorney with reference to tax implications of this Agreement. Further neither party has been given any tax advice whatsoever by their respective attorneys. Further. both parties hereby acknowledge that they have been advised, by their respective attorneys. if any. to seek their own independent tax advice by retaining an accounlant. certified public accountant. tax attomey. or tax 8 ., advisor with reference to the laX implications involved in this Agreement. Funher, the parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent tax advice. 23. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily. with the full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all infonnation related to the fmancial affairs of the other which has been requested by each of them or by their respective counsel. 24. ENTIRE AGREEMENT: This Agreement contains the entire undennanding of the parties. There are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the lengt.'t of their marriage and other relevant factors which have been taken into consideration by the parties. Bo!h parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and fmal settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any Court of competent jurisdiction pursuant 10 23 Pa. C.S.A. 53501, m. acll. or any other laws. Husband and Wife each voluntarily and intelligently waiver or relinquish any right to seek a court ordered tenninatlon and distribution of marital property but nothing herein contained shall constitute a waiver of either party of any rights to seek the relief of any Court for the purpose of enforcing the provisions of this AgreemenL 25. DISCLOSURE: Husband and Wife each represent and warran1to the other that he or she has made full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest. the sources and amount of income of such party or every type whatsoever and of all other facts relating to the subject matter of !his Agreement. 9 '. 26. MODIFICA liON AND WAIVER: Modification and waiver of any other provisions of this Agreement shall be effective only if made in writing and executed with the same Cormality of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 27. PRIOR AGREEMENT: It is understood and agreed that any and all property se1t1ement agreements which may have been executed prior to the date and time of this Agreement are null and void and of no effect. 28. DEA lH PRIOR TO DIVORCE: If either WiCe or Husband dies before the entry of a fmal decree in divorce between the parties then this Agreement shall be considered null and void and as though it had never been entered into, and the parties restored to the status that they had before this Agreement was entered in10. 29. DEFAULT OR DELAY IN PA YMENlS OR OBUOA TION PERFORMANCE UNDER AGREEMENT: In the event that either party defaults with respect to any payments to be made hereunder, or any obligation to be performed hereunder, and in addition to any and all other remedies provided in any other documents or agreements. and said default is not remedied within ten (10) days after sending of a written notice by certified mail to the deCaulting party specifying said deCault, the defaulting party hereby agrees to indenmiCy the party injured, or to reimbWlie him or her Cor any and all altOmey's fees and disbursements resulting from or made necessary by the bringing oC any suit or other proceeding. whether by complaint or counterclaim to enforce any obligation or to collect such payment. provided such suit or other proceeding results in a judgment, decree or order in Cavor oC the suing party. In the event such suit or other proceeding results in a judgment, decree or order against the suing party. the suing party shall reimbWlie the other party Cor any and all expenses, costs and attorney's fees resulting Crom or made necessary by virtue of the bringing of such suit or proceeding. If such default is remedied after the commencement of this suit. or other proceeding referred to in the above paragraph. the indemnity and reimbursement obligation shall be operative with the same force and effect as iC judgment. decree or order had been made in Cavor of the party bringing such suit or other proceeding. 10 ~' fr: O' ~~ .,' ,.~. t-' en .... I~ ,,)~t'. ,~.,l - , ...... . . "12': ~L !..~ :: ... ' ') ;"I(n L (V) j~ L... I . ~ ~ -J ; jjtiJ ~ C? 1:11.1... . , ~ " ,lj, \,0 :'.> 0 o. U '\', :' \ '. \'.' ., ,. "..,'.' ' ."/\ ,.'. '"", "'J" 'I>. "i "'1,', ,\\' vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTV, PA NO. 95- '-/'5GS' ~ 11'9ili STEPHEN P. CREMO, Plaintiff ANNETTE M. CREMO, Defendant DIVORCE/CUSTODV ORDI'R AND NOW, this g/srday of ~Jwj-, 1995, upon oonsideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appe4.l: befor.e J)...""" 5.'5V1.I\,I':'1t:"s:., the ConciliaJ:or.J,_at -6 n' S Mc-d';', i ( ~~l.V' at --L.' 6V -<~-j.. ,q, (CWS- o'clook for a Prehearing Custody onference. At su~ a conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide groundS for entry of a temporary or permanent order. FOR 'l'HE COURT, By:j)~~ .)-J.~t~ Custody Conciliator ~! The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled indivlduals' having business before the court, please contaot our offioe. All arrangements must be made at least 72 hours prior to any hearing or business before the court. Vou must attend the scheduled conference or hearing. ., VOU SHOULD TAKE THIS PAPER TO VOUR LAWVER AT ONCE. IF VOU DO NOT HAVE A LAWVER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE VOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 21,0-6200 . ~ 1 ~!~ "J'l ~ "1 0- 'J" '6 p. g ~1 () ~ <) '" ? !l '" '.., , . ~ "'i . " , ';) Q <;:)' " "1 " ... .. .. ') .. ~ .." en - ~.- -,,,: .." hJ,'l ..~.t t.:? -..". ~~.. ;- I_Cl(.) .. '... ..- c-, ~ . l' T. ,~I :~~..: :.l;~ '." ~,l ,,- ~_ .: '"_~;- r . - :::,'- ~~ ::c: 0- 'D '" ('") = ....... ... '" --.. \'!J '>- .,. (') h; N ! ~. i-= .. "j_.~ UJC! (it ':h::l C>t, -- ,...~ ~ " I. EEr, ~ :;~ ~c: ('0') if) L.. I :.]:~~ '-' ,~ -.I> .-,,'1 _.I ti1l"'1) r-= :::> c'.JO- -) --..; 11- '0 ::i 0 0' u ~ g C') ~ C\,J c ;::. 0- ,,u~ 6i "'J i.") ;~r; lr - ',-,?:(: -("] ~[~ ~ .~ ")'-J ~ C':> :."':r';) w. I S-" '-co ,,_ !" ....J :',),=0 if 25 !:1u., ". ..,.: '<0 :.:J 0 en U ..~ \:; ..... c fr; .:r N '..", -1- t:i I- e;.. (") -.''''f. ~;;: . ) c,. fr'" 0" ~ ) :,:~ ~iJ. ~ n~ , - l.. ('0') -'f,) c :~'];~ j':;: I , 't_ltiJ o:l'.' :5 [!: :)~ -, ~; lI. en ::') (;) 0' 0 ~ ~ .:r t: ..-, ('-I ,- 6, ,...... r .~_:J _!: ()T-. ( .-.- I.J~t= 0 ~- gi ..:;,: . r' '~)~ 0 ('0') ::ill) &: I ..~ !Ii'>> ll-! _I ,.1m r!; ::J roo.. -, ;.E.ci . t5 \0 ::> c, U d. Father shall have opportunity to visit with his children on a dailY basis provided advance notice is communicated to the Mother. e. At any other time which the parties may mutually aflree. I,. Neither party shall abuse alcohol. use drugs, 01' smoke cigarettes in the same vehicle 01' household when they have custody of the children. 5. Both parents shall refrain from making dercgatory comments about the other party in the prsence of the ohildren. 6. The parties shall establish a no-conflict ~one in order to better negotiate issues regarding their minor children. J. Lisa Marie Coyne. Esquire For Plaintiff (Father) ; . -. ..... Sil, Iljil r' t. ",1 TRUE COpy FROM RECm'lO In T05tlill(HiY wh:;lI:nl, Ilmil) linIn :"ll my hand and tho ~t'..ll 01 ~~IJ (;(IIHI .:1 C,'II!r.IIJ. Pa. Tlrlr. I" ~ _day 01..&( t.>t..~ . 19 If \' \...)../1- (,'. 7luU,-", Jf1" , , r Prothonotary Annette M. Cremo, Pro Se ~ -1 t 0 .... C', (., " oJ .. .- N --, ~ i5'~ ... g - (~~~ (.c. c: (.,..;" r: p ..' r.J .,. ,- r- ~5f/:J c.: N ,., d!J <..' i.... :J; P1l,j F l.d tq "- CJ ,,- In ..;~ 0 ::l \1' U