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HomeMy WebLinkAbout96-01388 '\ j ~ " , i ! i , ! , f J J /' . , ~, ...31 , I "'j -~----~----~~--~--- *, . -. -.'." __.. _.n _ ' ._ . ..... , . . _ ,. . v__ ..' .! .1 .) *i :1 .: *1 *1 *! . * al '1 :1 :1 . \ al '1 *1 . . (I . (I . (I (I (I (I i (I , ~ (I (I . I f-.-,.-. ' :C. > ':M' .:c. '. ,;co .;co ':c. .:c. .>> .. 11 . ...... --.-. . ~ 1* I. i. I, ill !~ . * (I (I (I * . (I (I (I (I I, (I . (I (I I 1* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~. PENNA. GEORGE E. DARHOWER, I I I, Plaintiff i\;ll 96-13flfj CIVIL \'1"1',11, LINDA J. DARHOWER, Defendant DECREE IN DIVORCE AND NOW, . . .~~. , . ~, . , . , . , . . . , " 19 C} ~~ " it is ordered and GEORGE E. DARHOWER, III . . decreed that.. , . . ,. . ... . ,.. . ,. . .. , , . . . . . . . ,.. , ' .. . ,.. . . " , . . " plaintiff, and............. .LIN!l,~ ,J... ,DARH,oWER...,................. 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; ~ THE PARTIES MARITAL SETTLEMENT AGREEMENT DATED ~IARCH 21, 1996 .. . . . . . , . . .. . . . . . . . . , . . , . . . . . . . . . . . . . . . . . . . . . . .. . . . . . , . . .~ ,. . . . . , . . . . . . . . . . / IS INCORPORATED HEREIN AS A FINAL ORDEa.~F COURT. . . . . . . . . . . . . . . . . .. ..,... . . . . . . . . . , . . . . . . . ... ~. . . . . . . . l . . . . . . . , . . . . . . . D y Th\" 10/': / \J./. Uvf Alle.t. ,/ "e> I ,// /",# .J . ",-.4..t<./,(.{:..t Ie tJ"c;rP. .M!"......7\.,",7- './)/~,}" '--" ..":;;.,, C'1../ . ~~.J':' ;.'"d.. '^ .../'~.v. ""r7 , .' 7 Prothonotary * (I . (I (I w (I (I ~ '. . ~ ~ '. '~ .' J. ~ ~ ~ , .' :~ .......... ....... j! -:<<. .:.:. -:~. .~<<. ..... '~.' ..... ...~. .:<<. ';4'.' ...... ..... -:<<. spousal support and alimony Husband is represented by his own separate legal counsel and has been advised of his respective rights, privileges, duties and obligations relative to the parties' property rights and interests under the Divorce Code and regarding alimony and spousal support; and, WHEREAS, each party is fully fanliliar with the marital property and both parties now desire to settle and determine his and her property rights and claims under the Divorce Code, including all claims regarding equitable distribution of marital property, alimony, spousal support and related economic claims, NOW, TIlEREFORE, the parties hereto being legally bound hereby, do covenant and agree as follows: I. The parties agree to the entry of a Decree in Divorce pursuant to Section 330 I (C) of the Divorce Code, Both parties shall execute and file the requisite Consents and Waivers with the Court no later than June 28, 1996 so that this divorce action can be finalized pursuant to Section 330 1 (C). The Husband's attorney shall file the Praecipe to Transmit the record and obtain a Decree in Divorce without delay after the necessary Consents and Waivers have been filed. Should either party do anything to delay or deny the entry of such a Decree, or fail to do anything required to obtain the Divorce Decree in breach of this Agreement, the other party may. at his or her option. declare this Agreement null and void, ab initio, 2. This Agreement and all warranties and representations contained herein shall survive the Divorce Decree and shall continue to be enforceable in accordance with its terms. No Court may change the teons of this Agreement, and it shall be binding and inclusive upon the parties. An action may be brought at law, in equity or pursuant to the provisions of the Divorce Code to enforce this 2 I I " " Agreement by either Husband or Wife In the event of a reconciliation, allempted reconciliation or other cohabitation of roo parties hereto after the date of this Agreement, this Agreement shall remain :i 'I iJ 'I II I 1 I , in full force and effect in the absence of a wrillen agreement signed by the parties expressly stating that this Agreement has been revoked or modified, ), The parties have agreed to divide their personal etlects, household furniture and furnishings, automobiles and all other articles of rangible personal property which have heretofore been used by them in common. Neither party will make a claim to any such items which have been designated as property of the other. Each party will execute any and all documents necessary to effectuate the transfer of ownership of any irems of personal property titled in both names. The party receiving sole ownership of such items shall pay all costs associated with the transfer and maintenance of the property in the future. 4. Wife has a pension with her employer (Cowles Media) presently valued at approximately $8,000.00 and Husband has a pension with his employer (Naval Ordinance Center) presently valued at approximately $25,000 00, Wife shall become the sole and separate owner of the pension through her employer, and Husband shall become the sole and separate owner of the pension through his employer, Each party hereby expressly waives any right to claim any pension/retirement rights of the other, vested or contingent, each party to retain full ownership of such rights as his or her sole and separate property. Aside from the foregoing, the parties have divided between them to their mutual satisfilction all intangible personal property consisting of cash, bank accounts, annuities, securities, insurance policies and other such types of property, The parties hereby agree that all such intangible property presently in the possession of or titled in the name of Husband shall be his sole 3 and separate property, and that in the possession or titled in the name of the Wife shall be her sole and separate property. 5. The parties are the owners of real estate situate at 9 Timber Road, Mechanicsburg, Pennsylvania, and the parties agree that there is presently approximately $41,000.00 in equity in the marital residence. Wife will refinance the marital residence in her name alone, and Husband shall deed all his ownership interest in the residence to Wife. Wife shall claim the interest paid in connection with the mortgage as a deduction for income tax purposes. 6. Husband shall be solely and individually responsible for the payment of the entire remaining balance on the PSL loan at Members First, with a balance of approximately $4,660.00 and his daughter Adrienne Darhower's college loan with a balance of approximately $6,600,00. 7. Husband shall pay Wife child support in the amount of$600.00 per month, $300,00 to be paid on or about the first day of each month and the additional $300.00 to be paid on or about the fifteenth day of each month, until Dylan Darhower's eighteenth birthday. Husband shalJ claim both Caitlin and Dylan as dependents for income tax purposes until Dylan is eighteen. 8. The parties shall have shared legal custody of Caitlin Oarhower and Dylan Darhower (hereinafter "children"). Wife shall have primary physical custody of the children, and Husband shall have partial physical custody of the children as follows: a. Each week on Tuesday and Thursday, and one of these visits shall be an overnight visit at Husband's residence; b. Every other weekend from Saturday until Sunday: c, On every day designated as a federal holiday; 4 d. On Christmas day lor one-half of the day; e, During the summer lor two weeks and for one additional week between September and May; and, f At such other times as the parties may from time to time agree. 9. Except as herein otherwise provided, each party represents that she and he have not heretofore incurred or contracted any debt or liability or obligation for ",nich the other may be held responsible or liable, Each party agrees to indemnifY and save and hold harmless the other from and against all such debts, liabilities or obligations of any kind which may have heretofore been incurred between them, except the obligations arising out of this Agreement. 10. Both parties covenant, warrant, represent and agree that each will now and at all times hereafter save and keep each other indemnified against all debts, charges, or liabilities incurred by the other execution of this Agreement, except as may be otherwise specifically provide:! for by the terms of this Agreement and neither of them shall hereafter incur any liability whatsoever for which the Estate of the other may be liable. Each party further agrees to indemnifY and save and hold harmless the other from any and all liabilities he or she may incur upon the obligations of or assumed by the other, which indemnification as to all provisions of this Agreement shall include the right to recover out of pocket expenses and reasonable attorney's fees actually incurred. II. Both parties agree that the hereinabove set forth Agreement constitutes an equitable distribution of their marital property and equitable resolution of all other economic claims pursuant to the provisions of the Divorce Code and each party irrevocably waives, releases, and remises any claim to ownership of or interest in any property designated as the property of the other by virtue of 5 "q 'n >- Cl f; (..... I' c":., , r , ~ UJ ( " I- I_ i U' r;" l L.;, -',. , I '" i i1:" ~ .', ,- I \ ., , () en \,.J .. . ...~ J -.- r , ,. . ;. t~: U.l: () " 1': , I Cc' e. , ~i:!; ".. I 4: '.L. f, -. , . ~. '; U f.....". >.~ W' (' i c ( l Co< re Ul 0< ow ,..:I '" . Z>- OE< XZO< XP.... OOZ UUO< > l&or::l,..:l OZ>- O<~ E<,..:IZ OoIOoIZ PWi>l 8!i1'" P i>lU 0:: E< Z H " \) ~ 1 ~ 1 - ~ 'i. .4J ';.) ) , j .' ;'j \1'- j .. I ,) ) Ie) " i~ '", .' r- 1(." ,~ I" I' ,.J' I I ..... H '8 J ,~'"" ' j") '" '"' '......<.~ ...... + + + + + H + + 3: H + W + < .... . + U + ,..:I a: + a: + , " (oJ + 0 + Z "" 0; a: 3: + > + 0 5 t ::: ow", 0 + H + HW :.'" 0:: .... + r::l + E<U ~ ~ :s 0.... 001 e:: + + ua: ~ ~ 0< '" '" 0::.... + Z + <0 .. 00Ie:: r::l'tl + H + > ~ Ii s: ~ u 0<... > c:: + + ,..:IH ! ~ '" ill z: r::l", .... + E< + HI:) ~ ~ ,., + Z + > ~ .~ CII + H + HZ z: :l W'" < I:) + 0< + U.... "-I ~ ~ I:) + ,..:I + Q2 ~ ~ OW :z + '" + "" t') H + X + '" b 001 ..l + 0 + '" 0 + U + '" OW + + ... t') + + + + + + . . '""'"~~""II II II ;I l! II " j; d '1 ~ i i I q il il .........} VERIFICATION ( , I I I i ! I verilY thai the 5IaIemenls made in this Complaint ere true and correct. I W"dersIand thai fuJse sIaIlmlro herein 8I1l made subject to the penaJtits of 18 Pa C S, ~ 4'Xl4, ~ to ~ fiIIsification to &lIhaities. ~c}~Lo GE E. DARHOWER, ill D81e: 3 - 13- 9t. A<,\ "<r!'J ~..-: ":J , C': '. I III ~ .;': &!{ i II... 0 C: ) Lo..;: . , fr!~' .. " oj , F '- . I, e!) C; '- . J GEORGE E. DARHOWER,III., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 96-1388 CIVIL TERM Ii i: II i! II ,. II " V. LINDA J. DARHOWER, Defendant CIVIL ACTION-LAW IN DIVOR:E DIPINDART'S AFrIDAVIT or CONSINT, ACCIPTARCI or SIRVICI ARD WAIVlR OP NOTICI OP INTINTIO. TO RlQUIST INTRY OP DIVORCI DICRlI UWDSR SICTIO. 3301(C) or Tal DIVORCS CODS 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 14, 1996. 2. The defendant accepts service of the complaint by certified mail-restricted delivery on March 23, 1996. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. S. 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 ! I I /' 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. I I il II Date: (4\ ':'2) \ C) (oJ /1 ../1 //.~,J /.".. /,1 ,/ _,/ ./ /~~;...~/~ ;.-<' L4(/'l((.ff~_ / / t,inda J. Darhower I, "ol ,... >. c) " (. ~ ''- tu ~ . , C .)~ , GO\ ". '- . , 9,. _-"J E2: :") -., , a:~. ~J I"J ,. -J "'- ,. '.,-' 0 c-. ( ( t . I