HomeMy WebLinkAbout95-04870
.
~T'" .
~
J
.
'I
~
c
~
cD
I
:
!
5
~
J
o
r
00
-=r
;':;a ,9?
/ ~J 9l
{;d {~~/';"~ ~ t:~ 0aub
7.
~AG fr,J# d:- "~ C~t.~t!f
DEBRA BEIIIIETT,
.
.
IN THE COURT OF COMMOII pLBAS
CUMBERLAIIDCOUIITY, PEIIIISYLVAIIIA
110. 95 - 4870 Civil Term
PLAINTIFF
.
.
.
.
v.
RODIIEY L. BEIIIIETT,
DEFEIIDAIIT.
III DIVORCE
.
.
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record, together with the following
information, to the Court for the entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of service of the complaint:
September 13, 1995, by certified U.S. Mail, restricted delivery, on
the Defendant.
3. Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Code: by plaintiff January 18,
1996; by defendant January 18, 1996.
4. Related claims pending:
None, the Property Settlement
Agreement dated January 18, 1996 is to be incorporated into the
Decree in Divorce.
!km.J j) '-~~Gj
Thomas D. Gould
Attorney for Plaintiff
>- -
fY;
;:": -
tu~.~ <-..I
('\'
r,-
I~~; -.;
Y.. .~
C' 1"\1
" c ('. .
L "1" ,
1 ..
I' . ~
'- "
'- , L'
DEBRA BEIIIIETT, . III THE COURT or COMMOII pLBAS
.
PLAINTIFF . CUMBERLANDCOUIITY, PEIIIISYLVAIIIA
.
.
.
v. . 110. 95-4870 Civil Term
.
.
.
RODIIEY L. BEIIIIET!, . 1M DIVORCE
.
DErEIfDAIIT .
.
WAIVER OF NOTICE OF INTENTIOII TO REOUBST
ENTRY or A DIVORCE DECREE UlfDER
SECTIOII 3301(0\ OF THE DIVORCE CODE
1. I consent to the entry of a final decree without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees 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 after it is filed with the prothonotary.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
l
)' I,
Debra Bennett
..... ,'J ~
i-; - .
j:-: 2>
a.u("; ~ -...;, ~:
gi' ; - .
O~-
t. ,
l'. " r~
I,
i.~ '.
h
I'. . -, h ,
C ,.J
PLAINTIrr
IN THE COURT OF COMMOII pLBAS
CUMBERLAIIDCOUIITY, PEIIIISYLVAIIIA
110. 95-4870 Civil Term
DEBRA BEIIIIET!,
v.
RODIIEI L. BEIIIIETT,
DEFEIIDAIIT
IN DIVORCE
WAIVER OF IIOTICE OF INTEIITIOII TO REOUEST
ENTRY or A DIVORCE DECREE UNDER
SBCTIOII 3301lc) OF THE DIVORCE CODE
1. I consent to the entry of a final decree without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees 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 after it is filed with the prothonotary.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
/}1hv
&~, ,{ p~?~a(
Roclae,"'L. BeDDett
>- <'1 i:~
0-
.~ _"r
I~
tuf~ CO . 0-
;:;
0<'.' ~ - ;
fEr., - '.
-,; <'
'T)~' .
c.r' r..., , '.
'-"- C',' - .
-. -
i.L:t: h,
L' ":' !
". ,
I ,~ .::",,:"
(,) l':) ::>
1.:./'\ U
.fIIM.'~, 'fh1fl"
AlIUllll'f ATLAW
,1.. MAt'" ITtllEl
.....MAHSTOWN. ". 17011
717-7'1-1..'
"'t.
, "'-,"',,- ;". ,-
vTr... ~ ',' " oJ
~~~ii~l~ ~ '..~, i": '..~-:F :6
.: :,~jf~"~..:, .' ,:c ~~~i:;;~..' \0
, '{{It:i1i~~I:''~~~r/~, '/;J'
.~' ';-~~~f ,'i~:";:tO', c
, ",,.... ~ ~~., .. .
- .,.....~ 'Q,_a~.. \I)''''
::"'" :",t',' .."'!~~!:[ ': Ie,,..,,. "'/
.,. .",~. w. ,- J"'",
._'J -W___w ~ ~ "
. ',...,...'I<oj!;-...." '-
~. ":31-" ~ ,;~ ',370,< ...'~ ,
, .,'~.,'~
. t;:<.;" ~";:..\},:, l' -: ,>,,' :..~,
~?i~~i~j~:~~
t
."1.
Q
~
g
-
.;
.',
',.,-
',-
"',",;-'"
,--.
<.'
,'-",'
"~ ,
'\~ '.~ ,',
j"
,<
"
. "':!"k ...."'y,.,.,~. \+,~ I .~ '. '"
~~~:ii'i;
,- ..
~ ~--_. -'-,--
'f,.:;:.;
l!-
.
.
.
..
;
\
0',";
',t.
'", ~...,
,
".'
':~:
(/).
,~"
"'~.',
-i'-
t:
.0'-,
...'.' ::, ,,"~
. .~,.
'1i ,:,':.u" ;
~'~
~D. ^",
',..'
"'.':
;-', ,
"",,-
,,'. ',.
" '-i-
. c' '.~:
"'1'
.,~:" ..
;;
..-<
. ~ .
. -_. --'-'- - ---
,
. '-~4;
:r",j;.:'-
~'"./.- .,
it' '::,}h\:f;{~~;(
.... ,. .,' ,,+
":>~\{~::i .::t:-:;;:Si~;:' .~'-::. <:~J,;t..
.. .. "'<'.
):'l;f'1~~i~~~1'C'
,
,''f:,.''":.\:,:-
.
.
~ ~';"
"
.
DEBRA BEIIIIBTT,
.
.
IN THE COURT OF COMMOII PLEAS
CUMBBRLAIIDCOUNTY, PEIIIISYLVAIIIA
RO. 1-{'il70 Civil 1995
PLAIIITIPr
.
.
v.
.
.
.
.
.
.
RODIIEY L. BEIIIIETT,
DEP'ENDlUfT.
IH DIVORCE
.
.
1I0TICE TO DEPBIID AND CLAIM RIGHTS
YOU HAVE BEER SUED III 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 fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, inclUding custody or visitation of your children.
When the ground for is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Court Administrator's
Office, Fourth floor, Cumberland County Courthouse, Hanover and
High Streets, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S 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.
Cumberland County Court Administrator
Cumberland County Courthouse
Fourth Floor
Hanover and High Streets
Carlisle, PA 17013
(717) 697-0371
DEBRA BEIIIIETT, . IN THE COURT or COMMON pLBAS
.
PLAINTIrr . CUMBERLAND COUNTY, PEIIIISYLVAIIIA
.
.
.
v. . NO. Civil 1995
.
RODIIEl' L. BEIIIIETT, . IN DIVORCE
.
DEFENDANT. .
.
COMPLAINT UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Debra Bennett, who resides at 107 North
sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania,
17055.
2. The Defendant is Rodney L. Bennett, who resides at 107
Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania,
17055.
3. The Plaintiff and Defendant have been bona fide residents
of 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 October 30,
1993 in Franklin County, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
PLAINTIrF
IN THE COURT or COMMOII PLBAS
CUMBERLANDCOUIITY, PEIIIISYLVAIIIA
NO. 4870 Civil 1995
DEBRA BEIIIIETT,
v.
RODIIEY L. BEIIIIETT,
DErEIfDAIIT.
IN DIVORCE
AFFIDAVIT OF COIISENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on September 13, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of the Complaint.
3. I consent to the entry of a Final Decree of Divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses, if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
~JZIl{,
/
/
_ .'1
. '...,. I '
,v Y(;
i~ c/~(? ,J~'1l ILl r-cu
~.
bra Bennett
>- ("') 2:
e<; -
~ ., : "
C' ~
~""
c .- >:
~r u..
0'\ , )
Lu-
-=-'('J .
u:- . ,.;.!~
~" - . '
L\. .':) :l
(.; c' U
'.,
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 4870 CIVIL 1995
DEBRA BENNETT,
PLAINTIFF
RODNEY L. BENNETT,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301 Ie) of the Divorce Code was
filed on September 13, 1995.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and
ninety days have elapsed from the date of filing of the Complaint and since service
has been effectuated.
3. I consent to the entry of a Final Decree in Divorce.
4. I understand that if a claim for alimony, alimony pendente lite, equitable
distribution of marital property or counsel fees or expenses has not been filed with the
Court before the entry of a Final Decree in Divorce, the right to claim any of them will
be lost.
5. I have been advised of the availability of marriage counseling, and
understand that I may request that the Court require that my spouse and I participate
in counseling. I further understand that the Court maintains a list of marriage
counselors in the Prothonotary's Office, which list is available to me upon request.
Being so advised, I do not request that the Court requile that my spouse and I
participate In counseling prior to a divorce decree being handed down by the Court,
..
I verify that the statements made In this Affidavit are true and correct. I
understend that false statements herein are made subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
Date: /lle /9(,
~
. , L
' .,..~ ~ Mf'/f?-d
Rodney L:. Bennett. Defendant
~ M ...-
..:r r~:
5 '" :'-j -
LU_, (>;.~.
u. .,- '-' ~..'
ll:L") . .
~r '- r:~
.n -'t;
UIL. -~..
--'" . ,,, I
u:.
Ie ~. ! -'c-
". .n ~
'-' l..\ U
.
.
,'" ~ ~ 1 end/or 2 lor eddltIonII MfVIcet.
e'Camplele ~ 3, end 4a . b.
,ol'llnt J!!Ut !\IfIlI end eddr_ on the ........ of II"- lorm 10
~Wt CII\ ""'"' II"- CIId 10 you.
~. ,t,.. IhIa fOrm to 1IIIlronl 01 111I mIllploce, or on 111I
bIclt II ope. don not permit.
. 'Willi ''lletum ReceIpt RtlqUIItId" on 1III1MIlpIece nut 10
theoirtlclt ,
'3. AttIcle AddreuId 10:
RoJo'e'f L. Bennett
10'1 r\J. Sportini..tlil/
m t. c..\\ Q ~c.s b Clr:g ,7q If}
I 1110 wIIh to rocllve the
loIIowlng urvIcu (lor III """"
1111:
1.0~EJ
2.Yr R..........y
c~, ~~~~~~
4a. Article Number
Z
4b. Serva Type
Reglltlred 0 InlUred
Certilied 0 coo
O:~reu Meil ~elUm RocIlpt lor
7. Dill 01 olllvery
8. AddroIIII'l A
, end I" II
P8~
. Octabet 1880 .~
.
.
I
l
-
DEBRA BEIIIIETT, . III THE COURT or COMMOR PLEAS
.
PLAIIITIFF . CUMBERLANDCOUIITt, PEIIIISYLVAIIIA
.
.
.
v. . RO. 95 - 4870 Civil Terlll
.
.
.
RODIIBY L. BEIIIIETT, . IR DIVORCE
.
DBFEIIDAIIT. .
.
CERTIFICATE OF SERVICE
I, Thomas D. Gould, attorney for Plaintiff, in the above
captioned action for divorce, hereby certify that a conformed and
certified copy of the Complaint in Divorce was served upon the
Defendant by Certified Mail No. Z 435 659 303, restricted delivery,
return receipt requested, by depositing the same in the United
States mail on September 13, 1995, pursuant to Rule 1920.4 of the
Amendments to the Pennsylvania Rules of Civil Procedure relating to
the Divorce Code. As indicated by the green return receipt card
attached hereto, the Complaint was received by the Defendant on
9-15-95.
~""~) D. ~j:,,1
Thomas D. Gould
ID # 36508
Attorney At Law
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
~ c") '-
..:r -
"'-
I- r:J .4.-
u,lS , '- )-
0.. ~ ~ : ~.
-.( .
I.L. . .... ,
~'
I. e' ;
oiL
_.I,.. ~ , '
u:-- .,- 't2..
f - :'->
l-'- ,')
l..> t- , L.o
PROPERTY SETTLEMENT AGREEMENT
q~ - 4~70 {~
THIS AGREEMENT, made this ~day of ~, 1996, by and
between RODNEY L. BENNETT, hereinafter called "Husband", and DEBRA BENNETT,
hereinafter called "Wife".
WITNESSETH:
WHEREAS, Husband and Wife were legally married on October 30, 1993;
WHEREAS, differences have arisen between Husband and Wife in consequence
of which they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and
obligations.
NOW THEREFORE, in consideration of the premises and covenants contained
herein, it is agreed by and between the parties hereto that:
1. SEPARATION.
It shall be lawful for each party at all times hereafter to live separate and apart
from each other at such place as he or she from time to time shall choose or deem fit.
The foregoing provision shall not be taken as an admission on the part of either party
of the lawfulness or unlawfulness of the causes leading to their living apart.
2. INTERFERENCES.
Each party shall be free from interference, authority and control by the other,
as fully as if he or she wele single and unmarried. except as may be necessary to
carry out the provisions of this Agreement, Neither party shall molest or attempt to
endeavor to molest the other, or in any way harass or malign the other, nor in any
other way interfere with the peaceful existence, separate and apart from the other.
3. DIVISION OF REAL PROPERTY.
Wife agrees to transfer all her right, title and interest in and to the real estate
situated at 107 North Sporting Hill Road, Mechanicsburg, Cumberland County,
Pennsylvania, now titled in the name of Husband and Wife as tenants by the entireties
to the Husband and agrees to immediately execute now or in the future any and all
deeds, documents, or papers necessary to effect such transfer of title upon request.
Wife further acknowledges that she has no claim, right, interest, or title whatsoever
in said property in the future. Said transfer shall be effective immediately and shall
be binding regardless of the marital status of the parties, The condition of said
transfer shall be Husband's agreement to continuously keep the property listed for sale
until sold. Pending sale, Husband shall indemnify and hold Wife harmless on the first
mortgage to City Mortgage of Pittsburgh as well as the home equity loan payable to
PNC Bank.
If any capital gains are realized from the sale of the aforesaid residence shall be
the sole responsibility of Husband.
4. EQUITABLE DISTRIBUTION.
In consideration of the division of the assets contained in this Agreement,
Husband shall pay to Wife in the form of equitable distribution, the sum of
2
$13,500.00. The said $13,500,00 is being held in escrow by John J, Connelly, Jr.,
Esquire, attorney for Husband, and shall be distributed to Wife upon the execution of
this Agreement. The parties agree that they shall execute, at the time of the
execution of this Agreement, consents to divorce permitting Wife's counsel, Thomas
D. Gould, Esquire, to immediately praecipe to \'ansmit the record, ~hereby securing
the Decree in Divorce promptly,
5. DIVISION OF PERSONAL PROPERTY,.
The parties have divided between them to their mutual satisfaction, personal
effects, household goods and furnishings and all other articles of personal property
which have heretofore been used in common by them, and neither party will make any
claim to any such items which are now in the possession or under the control of the
other. Should it become necessary, each party agrees to sign any title or documents
necessary to give effect to this paragraph, upon request. Wife's personal papers,
kitchen utensils and vacuum cleaner shall be returned to her by Husband within three
(3) days of the date of this Agreement.
6. INCOME TAX RETURNS.
The parties agree to file a joint income tax return for 1995. Wife has had
additional monies withheld from her pay check throughout the year in order to pay
additional tax. The accountant for the parties, Harvey Danowitz, CPA, shall calculate
Wife's liability on the joint return based on her income for the year and, after
determining said liability, in the event the amount Wife has had withheld flam her
3
check exceeds her liability, she shall receive those monies from the income tax refund.
The balance of said refund shall then be divided seventy (70%) percent to Husband
and thirty (30%) percent to Wife,
7. TAX ON PROPERTY DIVISION.
Husband hereby agrees to pay all Income taxes assessed against him, If any,
as a result of the division of the property of the parties hereunder. Wife hereby agrees
to pay all income taxes assessed against her, if any, as a result of the division of the
property of the parties hereunder.
8. DEBTS.
The parties have the following joint debts:
A. Home Mortgage with City Mortgage of Pittsburgh;
B. Home Equity Loan with PNC Bank;
C. Nations Bank of Delaware, N,A. Visa Card (cancelled); and
D. Sprint Cellular (cancelled).
Wife shall be responsible for the balance due to Nations Bank of Delaware, N.A,
with an approximate balance of $250.00 and the balance due to Sprint Cellular with
an approximate balance of $87.00. Pursuant to Paragraph 3 hereof, Husband shall
be solely responsible for the first mortgage to City Mortgage of Pittsburgh and the
home equity loan to PNC Bank until the property is sold and these obligations are
satisfied. Husband shall have sole responsibility for the Citibank Visa Card which was
solely in Husband's name prior to the marriage and for which Wife has no liability.
4
9. BREACH.
If either party breaches any provision of this Agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach. The party
breaching this contract shall be responsible for the payment of legal fees and costs
incurred by the other in enforcing his or her rights under this Agreement, or seeking
such other remedy or relief as may be available to him or her.
10. FULL DISCLOSURE.
Husband and Wife each represent and warrant to the other that he or she has
made a full and complete disclosure to the other of all assets of any nature
whatsoever in which such party of every type whatsoever and all other facts relating
to the subject matter of this Agreement.
11. ADDITIONAL INSTRUMENT.
Each of the parties shall on demand execute and deliver to the other any deeds,
bills of sale, assignment, consents to change of beneficiary on insurance policies, tax
returns and other documents and do or caused to be done any other act or thing that
may be necessary or desirable to the provisions and purposes of this Agreement. If
either party fails on demand to comply with this provision, that party shall pay to the
other all attorneys' fees, costs and other expenses reasonably incurred as a result of
such failure.
12. WIFE'S DEBTS.
Wife represents and warrants to Husband that since the parties' separation she
5
has not and In the future she will not contract 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 or demands made against him by reason of debts or
obligations incurred by her.
13. HUSBAND'S DEBTS.
Husband represents and warrants to Wife that since the parties' separation he
has not and In the future he will not contract or incur any debt or liability for which
Wife or her estate might be responsible and shall indemnify and save Wife harmless
from any and all claims or demands made against her by reason of debts or obligations
incurred by him,
14. WAIVERS OF CLAIMS AGAINST ESTATES.
Except as herein otherwise provided, each party may dispose of his or her
property in any way, and each party hereby waives and relinquishes any and all rights
he or she may now have or hereafter acquire, under the present or future laws of any
jurisdiction, to share in the property or the estate of the other as a result of the marital
relationship, including without limitation, dower, curtsy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and
right to act as administrator or executor of the other's estate, and each will, to the
request of the other, execute, acknowledge, and deliver any and all instruments which
may be necessary or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights and claims.
6
15. REPRESENTATION.
It is recognized by the parties hereto that Rodney L. Bennett Is represented by
John J. Connelly, Jr" Esquire and Debra Bennett Is represented by Thomas D. Gould,
Esquire. It Is fully understood and agreed that the parties have the right to have
advice of counsel prior to the signing of this Agreement. By the signing of this
Agreement, each party understands the legal Impact of this Agreement and waives
his or her right to have this Agreement reviewed by an attorney of his or her choosing,
and further acknowledges that the Agreement is fair and reasonable and each party
intends to be legally bound by the terms hereof.
16. VOLUNTARY EXECUTION.
The provisions of this Agreement are fully understood by both parties and each
party acknowledges 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 undue influence.
17. ENTIRE AGREEMENT.
This Agreement contains the entire understanding of the parties and there are
no representations, warranties, covenants or undertakings other than those expressly
set forth herein.
18. PRIOR AGREEMENT.
It Is understood and agreed that any and all property settlement agreements
which mayor have been executed prior to the date and time of this Agreement are
null and void and of no effect,
7
19. MODIFICATION AND WAIVER.
Any modification or waiver of any provision of this Agreement shall be effective
only if made in writing and executed with the same formality as 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.
20. GOVERNING LAW.
This Agreement shall be governed by and shall be construed in accordance with
the laws of the Commonwealth of Pennsylvania.
21. INDEPENDENT SEPARATE COV~NANTS.
It is specifically understood and agreed by and between the parties hereto that
each paragraph hereof shall be deemed to be a separate and independent covenant
and agreement,
22. VOID CLAUSES.
If any term, condition, clause, or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this Agreement and in all other
respects this Agreement shall be valid and continue in full force, effect and operation.
23. ENTRY AS PART OF DECREE.
It is the intention of the parties that this Agreement shall survive any action for
divorce which may be instituted or prosecuted by either party and no order, judgement
8
or decree of divorce, temporary, final or permanent. shall affect or modify the financial
terms of this Agreement. This Agreement shall be made a part of any such Judgment
or decree of final divorce,
24. DOMESTIC RELATIONS CODE OF THE COMMONWEALTH OF
PENNSVL VANIA.
Except as specifically provided In this Agreement, each party waives any claim
they may have against the other under the Domestic Relations Code of the
Commonwealth of Pennsylvania Including. but not limited to, alimony. alimony
pendente lite. counsel foes, costs and equitable distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound
hereby, have hereunto sot their hands and seals the day and year first above written.
WITNESS:
''''(?
. - . \ ~,
'.' ' . !'\.
, \, ,\". ( ,)\ ' ! .\
"~~~~cci~nell~:J;, E~~~r~
( "I , \ .
l{o/,t'V ~ &1~//eIf--.
Rodf1ey L. Ben~tt
rh~}J(, ) D ~Ld
Thomas D. Gould, Esquire
,I / 0) /1 _
/.. ( (f-f,/i J.[/L'lU~~>L-/
. ~
Debra Bennett
9
r;: M
r: -,
we:: ("ol '.
O.
._(
L. ' L.-
1._-,
Cl: . (n
L\
r::' ' .
,-
u. , - )
'-' '", u