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..Jacqueline [\1. Verne}
$300.00 per month, and it liuther appearing to the Court that such a distribution is
equitable, lawful and proper, we hereby order, decree and direct as follows:
1. Wife shall rece:ive $300.00 per month of Husband's monthly payment from the
Military.
2. In tho event that the Military is unable or unwilling to forward $300.00 from
Husband's retirement benefit, then the military shsll pay the greatest amount allowable to
Wife. Husband, pursuant to the Marital Property and Settlement Agreement, shall pay to
Wife, in accordance with the Marital Property and Settlement Agreement, whstever the
difference from the total ofS3oo.00 and whatever payment the Military does make. In all
instances, Wire shall receive from either the Military or from Husband the amount of
$300.00 per month.
3. This order is subject to modification should it become necessary to conform it to
the requirements of the military pay center and the terms of the Marital Property and
Settlement Agreement.
4. This court has jurisdiction over Member and Former Spouse by reason of their
domicile in this state.
.5. Former Spouse's interest shall terminate only upon the death of either party and
shall not terminate upon the remarriage of Wife.
6. Pursuant to 10 U.S.C. section 1408(d) a former spouse ofa retired military
member is authorized to obtain court awarded payments from a member's retired pay
directly from the member's service finance center.
7. In order to effect service on the service finance center so that direct psyments can
be sent to Former Spouse, certain information must be provided to the finance center. In
hereof; IIId each haa had tho opportunity to consult with his or her own competent legal counsel
independent of each other; 11I11.
WHF.RI-:AS, eal:h party warrlllts, IS part of the consideration of this Agreement, that each has
fW1y IIId co~lctely diKloacd alllnfonnation of a tinandal nature requested by the other, and that no
infonnatlon of sul:h nalure haa been subject to distortion or in any manner being misrepresented; and
WHEREAS, other thlll IS IIClt forth herein, Wife desires tinaOy and forever to relinquish all of
her rlabt of dower. rlabta II heir or surviving spouse or otherwise, actual, currently existing, or
Inchoate, In IIId to the realllld penonal properly of the Husband, now owned by him or which in the
lUture may be owned by him, IIId all rights to counsel fees, or expenses and other than as set forth
herein, Jluiband HlLow1ac wilhcs to relinquish aD his rights of curtesy, rights as heir or surviving spouse
or oLherwilo, actualllld currently existing or inchoate in IIId to the real and personal estate of the Wtfil,
currently owned by her or which she may own in the future;
NOW, TIIEREfORE. the parties hereto intending to be legally bound hereby do hereby
JJIItuaDy agrco IS follows:
I. Advice 01 Coullld. Husband and Wife acknowledge that they have been given the
opportunity to obtain the advice of counsel regarding the provisions of this Agreement and their legal
effilct in advlllCC of the date set forth abme to permit such independent reW:w. Eac:h party
acbowledscs that he or she has had the opportunity to receive independent legal advice from counsel
of his or her seleWon, IIId that each fW1y understands the filets and has been fu1Iy informed IS to his or
her legal rights IIId obHgation. and each psrty acbowledges and accepts that this Agreement is, and
under the clrcurnstlllceS, fiIir and equitable, after having the opportunity to receive such advice and
with such bowlcdse, IIId that exeattion of this Agreement is not the resuh of any improper or iIJega1
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agreement or agreements. In addition, each party hereto acknowledges that he or she has had the
opportunity to be fuI1y advised by his or her respective attorney of the impact of the Pennsylvania
Divorce Code, whereby the court has the right and duty to determine aD marila1 rights of the parties
includiug divorce, alimony, alimony pendente lite, equitable distribution of aD marital property or
property owned or possessed individually by the other, counsel fees and costs of litigation and, fuI1y
knowing the same and havmg the opportunity to be fully advised of his or her rights thereunder, each
party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set
forth herein are liUr, just and equitable to each of the parties, and waives his or her respective right to
have the Court of Common Pleas ofCwnberland County, or any other court of competent jurisdiction,
make any determination or order effecting the respective parties' rights to a divorce, alimony, aJimony
pendente lite, equitable distribution of aD marila1 property, counsel fees and costs of litigation.
2. Separation. Husband and Wife do hereby mutually agree and consent to live separate
and apart and do further agree that it shall be lawful for the Husband and Wife at aD times hereafter to
live separate and apart from each other, and to reside, from time to time, at such place or places as they
respectfully shaD deem fit, free from any control or restraint or interference, direct or indirect, by each
other.
3. No Molestation, Harassment or Interference. Neither party shaD molest, harass or
interfere with the other or compel or endeavor to compel the other to cohabit or dweD with 1:im or her
by any means whatsoever.
4. Mutual Property and Estate W liver. Except as otherwise expressly set forth herein.
in w1Iich event such express provision shaD take precedence over this paragraph, the parties hereto
intend that from and after the date of this Agreement, neither shaD have any spouse's rights in the
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property or cstIte of the other, and to that end both parties waive, relinquish, 4I1d forbear the rights of
dower or curtesy, rights to inherit, rights to claim or take the Husband or Wtfe's or liuniIy exemption or
allowance, to be VOlited with letters of administration or letters testamentary, or to take against any will
of the other, and each agrees with the other if either should die intestate, his or her share shaD descend
to vOlit in his or her heirs at law, personal representatives, and next of kin, excluding the other as
thoush he or she had died a widow or widower. And each further agrees that should the other die
tClilato, hla or her property shaD descend to and vest in those persons set fonh in the other's Last WiD
and T oswncnt as though the spouse so designated as beneficiary had predeceased the testator. The
parties further agree that they may and can hereafter, as though unmarried, without any joinder by him
or her, !IOu, oonvey, transfer or encumber any and aD real estate and personal property which either of
them now or hereafter own or possess and further agree that the recording of this Agreement shaD be
con<:1usive evidence to aD of his or her right to do so. Tbe said Husband and Wife do hereby
Irrevoc:ably grant, each to the other, should the exercise of this power hereby given be necessary, the
risbt and the power to appoint one or more times any person or persons whom the Husband or Wife
&haD decllP'atll to be the attomey-in-tiIct for the other, in their name and in their stead, to execute and
acknowlodge any deed or deeds, releases, quit claims, or satisfiu:tions, under seal or otherwise, to
enable either party hereto to sJienate his or her real or personal property, but without any power to
iqloso personal6ability for breach of warranty or otherwise. Each of the parties hereto further waives
any right of e1ection contained in Chapter 22 of the Pennsy1v8l1ia Probate Estates and F1duciaries Code.
and any right to seek or have an equitable distribution of married property ordered by the Court
pursuant to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither
shaD hereafter be under any legal obligations to supporlthe other, pay any expenses for maintenances.
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fimeral, burial. or otherwise for the other, and to that end each of the parties hereto does hereby waive
111)' right to receive support, alimony, alimony pendente lite, counsel fees. expenses. or any type of
financial .......anee whatsoeVer &om the other, ~ as otherwise expressly provided lOr herein.
,. DiMon 01 Penooal Property.
The parties agree that they have divided among themselves the majority of the penona.I
properly to their naUua1 salisfilction including automobiles, aD financial accounts, and household
furnishings. Husband agrees to turn over additional items such as Wife's Mother's decanters,
!lCI'Ipbooks, chiIdreo's toys, nintendo g>UDeS. Barbie items prior to the signing oflbis Agreement.
The parties further agree to review &miIy photographs and sbare the costs of repro<hl(;rinn 011
a '0"0 basis lOr ODe duplication of designated photos. This shaD be accomplished by the date of this
signing.
The parties acknowledge that they were the joint owners of two (2) timo.oh.res; name1y Mother
Nature's Acre and Thunderbird. The parties agree that Husband shan become the sole 0WDeI' of
Mother Nature's Acre and Wife shaD become the sole owner of Thunderbird. Each party agrees to
execute whatever documents are nec-ry to accomplish said transfers and pay the Olll.-di.!S
maintenanee fees 011 their respective tirneohare.
During the course of the parties' maniage, Husband was employed as a member of the UDited
Slates AnDed Forces and is, as a result., entitled to and presently receiving a military p-cWo
COlIII!Imcing June I, 1999, Wife shaD receive $300.00 each \IIODth until her death or Husband's death
and Wife will be responsible lOr the payment of any income taxes on her portion of such pension. The
parties will cooperate to ensure the entry of a Qualified Domestic Relations Order Ollfficiftot fur
purposes ora direct payment of Wife's $300.00 each month. In the event the military is \!lIAble 01'
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IDlwillinS 10 make said direct payments for whatever reason, including a QDRO is nOl in place by June
I, 1999, Husband agrees to Itrange for the direct deposit 0($300.00 or any difference that the miIiury
will DOl pay direct1y 10 Wife 011 a monthly basis, to a bank designated by Wilil. Said payments by
Husband 10 be made 011 the first day of each month unless that day fiIIIs 011 a Sunday, in which case the
direct deposit will be made on the next business day. The parties agree that they will cooperate to
arrange fur the withdrawal of that sum each month from Husband's r.hecking acco.mt.
Husband fiuther agrees to pay to Wife the lump sum of$~,OOO.OO 011 the fuDowing payment
sc1;eduIe: $2,000.00 contemporaneous with the signinS of this agreement but Dot later than May 14,
1999; S2,OOO.00 011 September 14, 1999; and SI,OOO.OO on December 31, 1999. Husband shaD also
pay 10 Wilil on December 31, 1999, the sum ofS200.oo fur persona1 propeny items that Husband
disposed ot: AD of said payments are to be hand delivered or mailed to Wife's attorney so that Wife
receives them 011 the d""'gI'ated daleS. Payment JbaII be made by money order.
Except as otherwise set forth above, neither party shall make any claim 10 any $Uch items of
marita1 property, or oftha separate personal properly of either party, which are DOW in the pos_m.-
and/or IDIcIer the cootrol of the other.
From and after the date of the signins of this Asreemem both parties shall have cou.,1de
hedom of disposition as to their separate property which is in their possession or COIItrol pursuant to
this Agreement and may mortgase, seD, grant, convey or otherwise encumber or dispose of audl
property, whether real or persona1. whether such property was acquired before, during or after
marriage, II1d neither Husband nor Wife need join in. consent to, or acknowledse any deed, IlIOI'tgap,
or other instrument of the other pertaining to such disposition ofproperty.
6. Debts. The parties agree that all marita1 debt has been satisfactorily divided. The puties
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..... to be reI'pOIIsible lOr my other individual debts \!rhich are presently in their iIIdMdua1l111D1lS and
to indamifY and bold IwmIess the other lOr the afuremelltiOlled debts.
7. future Deba. The parties further agree that neither wiD incur my more futuro debts lOr
wbiclI the other may be beld liable, and if either party incurs a debt lOr \!rhich the other will be liable,
that party i1curring sudI debt will indenmify and bold the other harmless from my and aU liabilily
thereof
8 . RuJ Pt uptol1. The parties acknowledge that a roreclosure proceeding bas been liIed
in whiclJ the real property will be surrendered.
9. Support, Alimony and Alimony rendente Lite. Both psrlies agree to waive any
md aD rights either may bllVe to spousal support. alimony and/or alimony pendente lite from this
time forward into tbe future.
10. Pluon. Except IS provided in paragrapb , berein, both parties agree to waive the
other's peaaion, c<<Uemeol or IRA accounts.
11. COIlII8f:I Fees and Court COlts. The parties agree to be responsible fur their
respective 1egaI fees md court colils incurred in the process of any divorce action or separation
a8JeOlllCllt.
12. Divorce. The parties acknowledge their intention and agreemeut to procelld in an
acdon In divon:e to obtain a final decree in divorce by mutual consent on the grounds that their
marriage is irretrievably broken, and to settle amicably md fully bereby aD claims raised by either party
in any divon:e action. The parties agree to OllCClIte any and aU documents necessary fur the entJy of a
final divorce decree.
13. Breach. In the event that either party breaches any provision of this Marital Property
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and S<;t.......... Aar-t, he or she sbaD be responsible fur I11Y I11d all colllS incurred 10 enfurce the
terms hereof; including, but nOl limited to, court costs I11d reasonable cOWlsel fi:es of the other party.
In the event ofbreacll, the other party shaD have the righl, at his or her eleclion, to sue fur damages fur
such bradl or to seek such other and additional remedies as may be available 10 him or her.
14. Enloreement The parties agree that this marital sett1ement agreement or any part or
parts hereof may be enfurced in any court of competent jurisdiction.
15. Applicable Law and Exeeution. The parties hereto agree that this marital sellIement
a8leement sbaD be construed under the laws of the Conunonwealth of Pemtsytvania I11d sbaD bind the
parties hereto and their respective heirs, executors and ...oigJI4 This doc:wnent sbaD be executed as
origina1l11d IDIltipIe copies.
16. The Entire Agreement. The parties acknowledge lIIId agree that this marital
....""'-t a~ contains the entire understanding of the parties I11d supersedes any prior
agreement between them. There are no other representations. warranties, promises, covCDlllta or
undarstandings between the parties other than those expressly set furth herein.
17. Int..~tion and Judplent for Divorce. In the event that either Husband or W.
at any time hereafter obtain a divorce in the action fur divorce presently pending between them, or
otherwise, this agreement I11d all of its provimons shaD be i9corporated into any such j",lr-t tOr
divorce, either directly or by reterenco. The Court, on entry of judgment fur divorce, sbaD retain tbe
right to enfurco the provisions and terms of this marita1 settlement agreement
18. Addidonallnstnunenta. Each of the parties shall on demand or within a rea........"'"
period thereafter, execute I11d deliver I11Y I11d aD other documents I11d do or cause to be done any
other act or thing that may be necessary or desirable to effectuate the provisions and pwpoces of this
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of the Divorce Code of 1980, as amended.
6. The Plaintiff has been advised of the availability of
counseling, and that the Plaintiff may have the right to request
that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff .equests Your Honorable Court to enter
a Decree in Divorce, divorcing the Plaintiff from the Defendant.
Respectfully submitted,
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William C~Vohs, Esquire
Attorney ID No. 65208
HANFT & VOHS
11 West Pomfret Street, Suite 2
Carlisle, PA 170~3
(717) 249-5373
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1~ Nonh Enola Drm:
I:nola. PA 17U15
( 717) 7 J 1.1 1U8
Ollice of the Divorce Master
9 North Hanover Street
Cumberland County
Carlisle. P A 170 IJ
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Subject: F inallzalJon of the Divorce 1:: .
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I. Pursuant to a petition for divorce and separation as Ii led in Cumberland CourllY
Circuit Court. dated March II. 1996. document case number 96-1549. :..!
March 30, 1999
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2. Please allow this statement to be my pretrial statement. I currently am unemployed
and disabled I can not alTord an attorney. Untortunately my disability pension is above
the income ceiling for a court appointed attorney.
1 (would like a hearing to tinalize the divorce.
PERSONAL PROPERTY
I. China that we jointly owned worth approximately purchased lor S21 00. Present
value S4OOO.
2. Hummel Figurines, approximately 50-60 of them, purchased lor approximately S I 00
each. Approximate value 57000.
1 Crystal whales four of them, as a set worth 51SOO.
4. Radio Shack Computer, purchased lor approximately 52700.
a. All personal property was equitably distributed at the time of separalion. (even
stored some of it tor her lor well over z. year. She picked it up. in it's entirety. with the
exception of approximately 700 ceramic molds. that were purchased at an auction for
$180. I received $60 dollars for the molds
b. She seems to want some pictures. which I am in possession of I am willing to
share the cost of reproduction. 50/50 with her. of as many pictures as she chooses. as long
as she pays tor it up front. I will show her the reccipl~ and provide a price to her. She
may do a lcw at a time or all at once.
c. The house was under n:posscsslon and I ""antcd to make surc that she ""as able
to obtalll ber and the chlldrcn' s POSS":SSlllns belilre sh..: was unabh: to.
Bollom Line: She was provided adequalC opportunity to d.....de thc martial assets at the
time of separation. Now shc wants to go shopping at my cxpense. What I have phYSical
possession of is mine, and what shc has phYSical pusscsslon of IS hers Ifthat's not the
cas.:. then I claim some of thc high costll..:ms she IS In possessIOn of as martial assets.
REAL PROPERTY
I. 1986. Plymouth Voyager. Valued at S16,000
2. Timeshare Property. Thunderbird Resort. Paid in Full, approximately worth S7000.
Maintenance fees owed are approximately $1400.
3. Campground property. Mother Nature's Acres. Paid in Full. Maintenance lees owed
are $400. Additionally. I've paid the maintenance li:es since the separation to the amount
of$800.
She voluntarily had the van repossessed in Washington State. I want to be reimbursed for
the Voyager she lost. That was a martial asset. The 1986 Ford Ranger has always been
solely in my name only. She has no claim to it; it is not a martial asset. The 1986 Geo
Metro, is also solely in my name. I purchased it/rom my daughter f leather for $2000 plus
I was required to take over the payments. That was the amount my daughter had invested
in the car. This transaction took place on April 30, 1996. The separation had already
taken place. The Geo is not a martial asset. If the rules or laws don't apply to me. then
they shouldn't apply to her. Ifshe has a claim on either of my automobiles, then I want to
claim her 1998 Geo as an asset as well. I've maintained both automobiles, I've had sole
ownership of them. Both are in my name only,the Geo was never owned by her.
The campground and timeshare properties are jointly owned. She needs to decide which
thing she wants to do:
I. She can sign them both over to me. and I will he responsible lor the maintenance fees
that are owed.
2. She can sign one over to me and keep the other one. I'd rather have the timeshare.
I would then sign over the other one to her.
3. This choice would requm: her to act in less than 30 days. since they are both in
foreclosure. She can pay half of the maintenance fees owed on both, including the S800 I
paid since the s..:paration. Pay half of the cost for both of these propcnies to be assessed
in value, approximately 1U0 cacho Then they can be placed on the market to be sold. Half
of the value can be split between us.
She ha.~ dlu.ellllullo a4:1 >I11U1 it \~ould rnak,: bulh PlulJCllIes gUllIlu fUIl:du'UII.: all..! 1Jt:
lost. This is a generous otl'er for hcr 10 takc advantagc of, an oller whIch has becn by mc
to her from the start ofthc dl~orcc For somconc Inlcrestcd in money, she's not acting in
her own best interests.
The pruP'=rly at 315'1 Rimer Highway wuuld sllll bc a lIlallial asscl if,he lIadll'tlilcd fur
bunkruptcy and ruined my credit to the point where I could not gct it refinanccd At thc
lime, I was working and paYing the other bills, including child support. I want to be
reimbursed for thc half thc cquity of the house, which was set at $~OOO full equity ThiS
amount would be 51500.
~IONEY OWE~ fOR MEDICAL BltLS
AltadlO;:u is Ihc cow t 01 dcr n;quirillg 110;:1 to puy lIalf of alllll<:Ji..:al alld dClltal bills I'll
Heatl1er and Jeremy. I'm still waiting lor reimbursement.
Jc.'eul~ tlClIlhCl'
MwicHI DelltHI MwicHI DeIlIHI
1996 10.00 0 133 1.28 0
1997 0 0 576.0U 126.40
1998 0 52300 ]082.26 666.82
1111111 10.00 52300 3009.54 793.22
"Hlr 5.00 261.50 1504.77 396.61
TOTAl, OF HAtF: $1167,88
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LAW OHICE OF
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96-1549 CIVIL TERM
Husband Introduced an unsigned copy of the property settlement agreement
that he and his wife both acknowledge she signed on January 30, 1996, and which
she subsequently destroyed. Husband testified that when he presented the written
agreement to wife, he only read parts of it to her. The agreement contained parts
neither of them understood, Husband acknowledged that wife said that there were
terms in the agreement that she did not like including the amounts set forth for child
support and alimony, Husband testified that before wife signed the agreement: "I
told her we could amend It any way ahe wanted to." Husband acknowledged that
'I told her that she needed to sign the document ~o that we could move on with other
things,' even though he knew she did not want a divorce. Husband testified that he
did not have a copy of the agreement for wife when she signed it on January 30,
In SImeone v. SImeone, 525 Pa, 392 (1990), the Supreme Court of
Pennsylvania stated: 'Absent fraud, misrepresentation, or duress, spouses should be
bound by the terms of their agreements,' In the present case, there was no final
agreement that reflected a meeting of the minds of the parties, In a coercive setting,
husband induced wife to sign an agreement that he knew was not acceptable to her
by misrepresenting that she "could amend It any way ahe wanted to." When wife
timely sought to amend it, husband reneged and now seeks to hold her to all of the
terms In the original document. Such an "agreemenf' is not enforceable,
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*$IWIO\/IaR' CAlLlSU,MIIOU' (711)24).9190. FAX (711) 24].U11
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HAROLD BOOTH, JR.
PlaincilT
v.
CIVIL ACTION. LAW
IN DIVORCE
DEBBIE K. BOOTH,
Defendant
NO. 96-1549 Civil Term
PRAECIPE
TO THE PROTHONOTARY:
Please enter my appearance for che Defendant, Debbie K Booch, in (he above-captioned mailer.
Respectfully submilled:
l.~~!h.~.
tUcquOiine M. Verney, Esquire )'
Allorney 1.0. #
44 South Hanover Street
Carlisle, P A 17013
(717) 240.0145
TO THE PROTHONOTARY:
Please withdraw my appean1llce for the Defendant, Debbie K. Booth, in the above-captioned matter.
Respectfully submilled:
..c:;? t... 7)/ r
K thleen D. Keatin , Esq1'e
Attorney 1.0. # 66271
1'0 Box 1103
Carlisle, PA 17013-6103
(717) 240-0145
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6, On or about JHluary 16, 1')')6, n'}g'Jti.ati.ons began
betw",en Plaintiff and Q"f,,:nddnt f,..r th,,; purpose of crc'ati.ng an
acceptable Separation Agreement and Property Settlement in this
ma t t e r .
7, On or about Januclry 28, 1996, the p<lrt i8'1 came to an
agreement concerning the separation of mar.ital property.
Sub3equently, Defendant signed the Separation and Property
Settlement Aqreemenr. but has sine.} subsequent ly changed her mind
to the terms, A copy of this Agreement is ~ttached as Exhibit
"A. ft
8, It is established law in this Commonwealth that parties
may bind themselves contractually prior to th~ execution of a
written document through mutual manifestation of assent, even
where a later formal document is contemplated. Krause v. Great
Lake Holdinas. Inc., 387 Pa, Super. 56, 563 A.2d 1182 (1989),
appeal denied, 524 Pa. 629, 574 A,2d 70 (1989), Luber v. Luber,
418 Pa. Super. 542, 614 A,2d 771 (1992), appeal denied, 631 A.2d
1008.
9. On or about January 2:-3, 1996, Plaintiff and Defendant
reached an agreemAnt, in which Defendant waS to receive $5,000
cash in return for her interest in thA marital home, in addition
Defendant was to receive alimony in the sum of $250.00 dollars
per month and Oefendant was to pay to Plaintiff the sum of
1
:';,~PAPA r [n~j AW) Pf(l) t'io: R'["{ ,i[,:'!"l'L,:~Ir:NT N;pn:Mfl!J:
'rHLS AGRE2:ME~l'r, m,j.jt1 rtlis
,Lt Y () f
19')1-), by .ind b.:tw,:::"~'n Hlr~)L,:t R'-\l)th, ,Tr., ot Cl.lfTIt_H.~r.ldn,j County,
Penn:3'1lv.-jni,~1, p,lr:ty or the tLrst". pdrt, h~~relndftf~c refer:red to a:i
"Husband" and Debbie K, Booth of Cumberland County, Pennsylvanla,
P,lcty or tht-~ ~iol..:()nd pdrt.,. hE:r("~dt'ter refer.eed to dS lIWi.fe".
WLTm:ss,:TfI:
~IHE:REAS, husband and wife were! married on August 17,
1974, in San Anton io, Texas; and
WHF:pr'~AS, hU:Jband dnd wife are residentcl of th.~
Commonwealth of Pennsylvania and have been so for at least the
Pa~t six (6) months; and
WHEREAS, ce.tain diver~e, unhappy differences have
arisen betwe!en the parties hereto which have made them desirous
of living separate and apart from one another; and
WHEREAS, husband and wife desire to settle and
determine certain of their marital rights and obligations, and
make an equitable distribution of their marital property; and
WHERF:AS, it is the intp.ntion clnd purpose of this
Agreement to set forth the respective rights and duties of the
parties while they continue to live apart from each other and to
settle ali financial and property rights between them; and
WHEREAS, the parties hereto have mutually entered into
agreement for the division of their jointly owned assets, the
1
provi;3iom~ for thie li"bllltie3 the'l 0''/''', .,nd fH,)vi~;l"n" for the
r...solution of their mut,..-d ditt,"rencP3, ,ltter both rl,IV'J had fuli
dnd amble <.,ppurtuni1'Y to ,consuLi' wlth th,C)ir re3pective dttorneY3,
and the partlus now wish to have thdt d~L"'en~nt reduced to
wrLtir.Cj,
NOW, TH~R~rOkE, the partie9 hereto in consideration of
the mutually made and to be kept promlses set forth herein and
for other good dnct vdluable considerdtion, intending 1:0 be
legally bound and to legally bind heirs, successors, assigns, and
persondl repr.esentative.s, do hereby covendnt, promise dnd agree
as fo l lows:
ARTICLE r
SEPARA1' r.5lli
1.l
It shall be lawful for husband and wife at all times
hereafter to Live separate and apart trom each other and to'
reside trom time to time at such place or places as they shall
deem fit free from any control, restrain, or intederence, direct
or indirect, by each other. Neither party shall molest the other
or compel or endJavor to compel the other to cohabit or dwell
with him or her by any legal or other proceedings.
:2
p~]Li.cy, un~nforce,ibL~~ Lfl 'Nh\)t~~ r_.)(' in f).Jct". Husbdnd dnd wi.fe do
each hereby w~rrant, covenant and aqrea that, in any possible
event he dn she drfcJ rlnd t;!.ver: Shdl.l be estopped fcom dssertinq dny
illegality or unenforceability dS tu all or any part of this
Agreement.
2.2
It is Furthe,r speclfically understood and aqnHld that
the provision oE this Agreement relating to the equitable
distribution oE property of the parties are accepted by each
party as a final settlement of tor all purposes whatsoever.
Should either of the parties obtain a decree, judgment or order
of separation or divorce in any other state, county, or
jurisdiction, each of the parties to this Agreement hereby
consents and agrees that this Agreement and all its covenants
shall not be effected in any way by any such separation or
divorce; and that nothing in any such decree, judgment, order or
further modificati'Jrl or r,~vision thereof shall alter, amend or
vary any term of this Agreement, whether or not either or both of
the parties should remarry, it being understood by and between
the parties that this Agreement shall survive and shall not be
merged into any decree, judgment or order oE divorce or
separation,
2.3
It is specifically agreed that a copy of this Agreement
4
may be incorpordted by reference into any divorce judqment or
decree if or whenever sought by any of the partIes hereto. Such
incorporation, however, shall not be regardad a merger, it being
the intent of the pdrt les to p'~rrnit. Agreem'~nt to surviv.] any such
agreements.
ART ICLE I [ I
E:QU[TABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property
in a manner which conforms to the criteria set forth in Section
3502 of the Pennsylvania Domestic Relations Code, and taking into
account the following considerations: the length of the
marriage; the prior marriages of the parties; the age, health,
station, amount and sources of income, vocational skills,
employability, estate, liabilities, and need for each of the
parties; the contribution of one party to the education, training
or increased earning power of the other party; the opportunity of
each party for future acquisition of capital assets and income;
the sources of income of both parties, including, but not limited
to medical, retirement, insurance or other benefits; the
contribution of dissipation of each party in the acquisition,
preservation, depreciation, or appreciation of marital property,
including the contribution of a party as a homemaker; the value
of the property set apart to each party; the standard of living
5
. ,
of the partles established durlnq their marriage.
3.2
The division oE existing maritaL property is not intended by
the parties to constitute in ~ny way a sale or exchange of assets
and the division is being effected without the introduction of
outside funds or ocher property not constituting marital
property. The division of property under this Agreement shall be
in full satisfaction of all rights of equitable distribution of
tho;) parties.
3. J
The parties shall retain sole and exclusive right, title and
possession of all personal property currently in their
possession. Except as provide for herein, Husband shall make no
claim whatsoever for any personal property in wife's possession.
Additionally, except as provided for herein, Wife shall make no
claim whatsoever for any personal property in Husband's
possession, Should it be necessary for either party to execute
any documents to convey title to any such personal property in
the other party's possession, they shall do so within thirty (30)
days of the execution of this Agreement or within thirty (30)
days of the request from the opposing party.
3.4
Except as pr~vided herein, Wife waives any right or interest
she may have in Husband's employment benefits, including any
6
pension bo'!nefits, re~irem,'n~ pLan, sto,~k option purchase plan,
profit sharing plan or related matters, ~xcept as provided
herein, Husband waives any right or interest he may have in
Wife's empLoyment benefits, including dny pension benefits,
retirement plan, stock option purchase plan, profit sharing plan
or related matters,
J,5
Husband and Wife agree to waive and relinquish any and all
right that he or she may now have or hereafter acquire in any
real or tangible personal property subsequently acquired by the
other party. Husband and Wife specifically agree to waive and
relinquish any right in such property that may arise as a result
of the marriage relationship.
J.6
The parties are the owners of a certain parcel of real
property with improvements located thereon known as 3159 Ritner
Highway, Newville, Cumberland County, Pennsylvania (hereinafter
kbnown as the "Property"). Wife agrees to transfer all of her
right, title, and interest, in the Property to Husband. Husband
agrees, upon WiLe's transfer above, to pay to Wife the sum of
Five Thousand ($5,000,00) Dollars,
J,7
The parties are the joint owners of two (2) tirneS'lares.
7
Wife shall be entitled to the sole use dnd ownership of the
Thund8rbird timeshare, Husband shall bu entitled to the sole use
and ownership of the Nother Nature's Acre timeshare.
AHTICLF. l'j
IU:LEASE 0.' SUPPORT FOR HUSBAND AND WIFE
4. 1
The parties herein acknowledge that by this Agreement they
have respectively secured and maintained a substantIal and
adequate fund with which to provide themselves sufficient
resources to provide for their comfort, maintenance, and support
in the st,) t ion 0 f 1 ite in wh ich they a re accustomed. Husband and
Wife do hereby waive, release and give up any rights they may
respectively have against the other for alimony, support, or
maintenance.
4.2
Husband and Wife specifically waive, release and give up any
rights for alimony that they may be entitled to pursuant to
Chapter 31 of the Pennsylvania Domestic Relations Code, except
for the extent provided for herein.
4 , 3
Husband agrees to pay to Wife as alimony, the sum of of Two
Hundred Fifty ($250,00) ~)llars per month for four (4) years,
Wife agrees to flay to Husband as child support, the sum of Four
Hundred ($400,00) Dollars per month until the parties' youngest
8
child ~edches eighteen yea~s of age and has graduated from high
school. Should the parties' minor children reside primarily with
Wife, Husband agrees to pay to Wife Two Hundred ($200.00l Dollars
as child support for Each child who has not yet graduated from
high school, and Wite agrees that she will nnt receive alimony
from Husband until all of the parties' minor children have
graduated from high school,
At Wife's election, Wife can pay Husband One Hllndreu fifty
($150.00) Dollars (representing the difference between the
alimony and the child support) per month, without suffering any
tax consequences,
Upon the graduation of high school of the parties' youngest
child, Husband agrees to pay to Wife as allmony, the sum of Four
Hundred Fifty ($450,00) Dollars, until such time as Wife
remarries, dies, cohabits with another man, or until such time as
Wife can support herself without the assistance of Husband.
ARTICLE V
DEBTS OF THE PARTIES
5.1
Each party represents to the other that except as otherwise
specifically set forth herein, there are no major outstanding
obligations of the parties, that since the separation neither
party has contracted for any debts for which the other will be
responsible and each party indemnifies and holds harmless the
9
other for all obligations separately incurred or assumed under
this Aqreement.
In the event either party contracted for or incurred any
debts since the date of separation, the party who incurred said
debt shall be responsible for the payment thereof reqardless of
the name in which the accounl may have been charged, Husband and
Wife acknowledge ~nd agree that they have no outstanding debts or
obligations of the Husband and Wife incurred prior to the signing
of this Agreement.
5.2
Each party relinquishes any rlght, title and interest he or
she may have to any and all motor vehicles currently in the
possession of the other party. Each party shall execute the
necessary documents to have said vehicles properly registered in
the other party's name with the Pennsylvania Department of
Transportation.
ARTICLE: VI
MISCELLANEOUS PROVISIONS
6.1
The provisions of this Agreement and their legal effect have
been fully explained to the parties by their respective counsel
or the parties have waived their right to have legal advice
regarding the meanLn') and implication of this Agreement. The
parties acknowledge dnd accept that this Agreement is, in the
10
circumstances, fair and €,'quitable, that it is being enter,ed into
freely dnd voluntarily, after having received such advice and
with such knowledge that execution of this Agreement is not the
result of any duress or undue influence and that it is not the
result of any collusion or improper or illegal agreement or
agreements,
6,2
Husband and Wife do hereby mutually remise, release,
quitclaim, and forever discharge the other and the estate of the
other, for all times to come and tor all purposes whatsoever, of
and from any and all legal right, title and interest, or claims
in or against the property of the other or against the estate of
the other, of whatever nature and wheresoever situate, which he
or she now has or at any time hereafter. may have against such
other, the estate of such othe~, or any part thereof, whether
arising out of any former acts, contracts, engagements, or
liabilities of such other as by way of dower or curtesy, or
claims in the nature of dower or curtesy or widow's or widower's
rights, family exemption, or similar allowance, or under the
intestate laws, or the right to take against the spouse's will;
or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to
participate in d deceased spouse's estate, whether arising under
the laws of (3) Pennsylvania, (b) a,1Y state, commonwealth, or
11
territory of the United States, or (c) any other country, or any
rights which either party may have or at any time hereafter have
for past, present, or futu~e support or maintenance, alimony,
alimony pendente lite, source fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except
and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any thereof. It is the intention of Husband
and Wife to give to each other by execution of this Agreement a
full, complete, and general release with respect to any and all
property of any kind or nature, real or personal, not 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 for the breach of any thereof.
6.3
Each party represents that they have not heretofore incurred
or contracted for any debt or liability or obligation for which
the estate of the other party may be responsible or liable,
except as may be provided for in thIs Agreement. Each party
agrees to Lndemnify and hold the other party harmless from and
agaInst any and all such debts, liabilities or obligations of
each of them, includLng those for necessities, except for the
12
obligations arhinq out. of this Agreement. f1usb,1nd dnd Wife each
warrant, covendnt, rerre~ent and agree that edch wiil, now and at
all times hereafter, save harmless and keep the other indemnified
from all debts, charges, and liabilities incurred by the other
after the execution ddte 0f this Agrecnl~rlt, except as is
otherwise specifically provided herein.
6,4
No w~lver or modification of any of the terms of this
Agreement shall be valid unless in writing and signed by both
parties and no waiver of any b.e~ch hereof or default hereunder
shall be deemed a waiver of any subsequent default of the same or
similar nature,
6,5
This Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania which are in effect as
of the date of execution of this Agreement.
6.6
This Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
6, ./
this Agreement constitutes the entire understanding of the
parties and supersede3 any and all prior agreements and
neqotiations between them. There are no r'epresFOntations or
1.1
warranties othAr thdn those expressiy set forth herein,
6,8
If any term, condition, clause, se~tion, or provision of
this Agreement shall be determined or declared to be void or
invalid ln law or otherwise, then only that term, condition,
clause, or provi~ion shdll be stricken from this Agreement, and
in all other re9pects, th~s Agreement shall be valid and continue
in full force, effect, and operation. Likewise, the failure of
any party to meet his or her obligation under anyone or more of
the articles and sections herein shall in no way void or alter
the remaining obligations of the parties,
6.9
It 13 specifically understood and agreed that thi3 Agreement
constitutes an equitable distribution of property, both real and
personal, which was legally and benAficially acquired by Husband
and Wife, or either of them, during the marriage as contemplated
by the Domestic Relations Code of the Commonwealth of
Pennsylvania.
6.10
The parties warrant and represent that they have made full
disciosure of ali assets prior to the execution of. this
Agre~ment,
14
,.... "..,a
~,-;,~",..--".;
LAW OfFICE Of
JACQUBUNB M. VERNEy
ATTORNEY AND COUNSELOR AT LAW
March 9, 1998
E, aobert Elicker. II
Office of Divorce Master
9 North Hanover Strut
Carlisle, P A 17013
Re: Bnoth v. Boolh
No, 96-1549
IN DIVORCE
Dear Mr, Elicker:
Enclosed please find my Pro-Trial Statement filed on behalf of Debbie K. Booth.
Defendant in the above referenced case,
Very trUly yours.
(~:.-..}t; 0.,-- <(f
f.cqu~line M, Verney, Esquire
JMV/mos
Enclosure
C(:: Michael A. Scherer. Esquire
Debbie K. Booth
4-4 SOUTH HANOVER STREET. CARLISLE. PA 17013 (717) 243-9100 FAX 243-3518
f.".. ()ffi"'.'
S,.ph.".!. Fi..h.,,'"
of ,'outI.J~1
()'HRIEN, /lARK.. SCHERER
17 "'.., Sou,h S,re.'
('",./1,1.. 1'.III....ylwnill 1701 J
ROMrf L, Q'B,I.n
DQYIJ ,~. Baric
,\Itch.../.... Sch....'
1717) 249-6873
Jo:'lr 1717) 249-j7jj
March 10. 1998
Robert Elicker, III
Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
RE: ~arold Booth. Jr v. Debbie K. Booth
No. 96-1549 Civil Term
Dear Mr. Elicker:
Harold Booth, Jr. will not be retaining me in this mailer. I have forwarded your letter
dated February 9, 198 to him and he has made arrangements to pick up his file from me.
Please contact me if you have any questions or concems.
Very truly yours,
O'BRIEN, BARIC & SCHERER
fY/iJAuJ a. ~Jw'tJ;'1 /qv
Michael A. Scherer
MASljc
cc: Jacqueline M. Verney, Esq.
Harold Booth, Jr.
File
......dlrllett.nibootb,ltr
Office 0' Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
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HAROLD BOOTH, JR,
3159 RITNER HIGHWAY
NEWVILLE, PA 1~2<1.l~.N"
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Wife suffered a mental breakdown and was hospitalized for 3 days, Wife has been
unable to return to her previous field of employment since the breakdown. She presently
works at Ross Distribution, grossing $13.000.00. Husband is retired from the military
receiving $1100.00 per month.
II. PRES[NT INFORMATION
I. ASSETS AND LIABILITIES:
See anached Inventory and Appraisement. Exhibit "A",
2, EXPERTS:
At this time no e:qlert witnesses are contemplated, Ifnecessary, Wife can produce
medical experts concerning her mental breakdown. Wife reserves the right to
supplement the list of expert witnesses as appropriate,
3. WITNESSES:
Wife expects to call Wife and Husband as witnesses. Wife reserves the right to
supplement her list of witnesses if necessary.
4, EXHIBITS:
Wife anticipates offering, ifnecessary, the health report of Lorraine McDonald,
MS,N., C,R.N.P., anached hereto as Exhi!lit "a". Wife reserves the right to
supplement this list if necessary,
l INCOME INFORMATION:
Wife is employed by Ross Distribution, earning $1083.00 monthly gross income,
She also works part time as a delivery person for a local Pizza shop. She nets
appro,umately $1000.00 per month from both jobs, See Income/E.'<)lense Statement,
Exhibit "C". Husband is retired from the military receiving $1100.00 per month.
Wife also believes he works to supplement his income and receives military benefits
to attend school.
6, EXPENSE INFORMATION:
Please see IncomelE"Pense Statement, Exhibit "e".
7. COUNSEL FEES:
Wife has made numerous attempts to reasonably settle this matter and believes
Husband should pay her counsel fees since he has not made any attempt to resolve the
dispute including the distribution of personal items belonging to Wife.
8, ITEMS IN DISPUTE:
All marital property not already divided,
9. PROPOSED RESOLlITION:
Wife requests a division of 60/40 of all marital property, an alimony award and aU
other military benefits to which Wife is entitled. Wife further proposes Husband pay
for her counsel fees and e"Penses. Fair rental value of marital residence should also
be assessed against Husband since he rented the mari.tal residence to others and
received income therefrom.
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ROD1'llEY K. HOUGH, M.D., F.A,A....P,
WILLIS W, WILLARD, M.D., F,A.A.F.P.
DENISEj. HOUGH, M.S,N., C,R.N.P.
LORRAINE W. McDONALD, M.S.N" C.R.N.P.
49 Brookwood Avenue. Carlisle, PA 17013-9126. 717243-8000. FAX 717243-3599
May 31, 1996
Re: Debbie Booth
To Whom It May Concern:
This letter is to explain the mental status of Mrs, Debbie Booth through the early part
of 1996, I first saw Mrs. Booth on January 3, 1996 complaining of anorexia, fatigue,
headache and extremely tearful, following the walk-out of her husband of 21 years two
days prior, She reported at that time that her husband was just saying that he needed
some time to himself, however she subsequently found out that he had been involved
in multiple extramarital relationships over the last several months. At that time the
patient was having flight of ideas and difficulty concentrating, but denying any suicidal
or homicidal ideation, I found her to be extremely depressed at that time, and
recommended that she begin antidepressant therapy, At that point in time she refused,
stating that she might be able to handle it on her own, however I saw her back less
than two weeks later and she was started on antidepresslilnt therapy for increasing
symptoms, The instigator for her continued demise was her husband moving all of his
belongings out of the family home and into a home with another female partner, At that
point in time she was suffering Insomnia, agitation, decreased appetite, and poor
concentration to an increasing degree, From January 3 to January 17, 1996 she had
lost over 13 pounds,
A depression screening evaluation done at that time showed a depression index of 80
which indicates severe to extreme depression, and we again approached tho idea of
hospitalization with Mrs, Booth.
Secondary to difficulties with Mrs. Booth's HMO insurance, they were unable to begin
any type of counseling, and on February 14, 1996 she returned to the office with
continuing symptoms of depression, Throughout this six week period from my initial visit
with her, her husband was in and out of the home and in and out of a sexual
relationship with her, possibly exposing her to sexually transmitted diseases including
Hepatitis B and AIDS. She had lost an additional 13 pounds in that two week period of
time, and had stopped taking Zoloft because she felt as though it was not beneficial to
her, I again recommended that she begin hospitalization followed by outpatient
treatment,:ho',Vever secondary to the responsibilities involved with taking care of her
children';.' slie was unable to make arrangements at that time.
- t; "
t )t
Household Child Household Child
Week Week Month Month
EXPENSES
Hcm~
Mor:c;ac;e.Rent ........................................ $ $ $ 4.2., .'0 $
Maintenance ........................................... $ S S S
UllIiljes (telephone. heating .'"
elecl/lc, elc.) ......,................................. S S S ~() S
Em;lIcyment (transportation.
luncnes) ...............................,......,..,...., $ $ $ S
faAes
Real Estate ..,......,........,....,....,...........,...., S $ $ S
Personal Properly........,......,........,.,........ S $ S S
Income ......,..........,..,.........,...,.................. S $ $ S
Insurance
Homeowners ..,.........."............................ $ S S S
Automobile ..........,.....,....,....,......,............ S $ S ~~ S
life/Accident/Health .............................. S $ S $
Olller ......,..................,.........,..,................. S S S S
Automobile (payments, fuel, "
repairs) .......,......".................,............... S S s /YO s
Medical
Doc lor, Dentist, Orthodontist.......,........ S $ S $
Hospital,................,................................. S S $ S
Special (glasses. braces, etc,) ............... S S S S
Education
Privale, ParoChial SChoOl..,....,............... $ S S S
COllec;e..........,..........,.............,......,.......... S S S S
Personal
Clothing ........,....,..."......,......................... S S S $
Food ................,..................,....,................ S $ $ ;lo-<J S
Other (household supplies,
barber, etc.l....................,.......,..,.......... $ S $ S
Credil payments and loans .....,....,..,..,.., $ $ $ S
Miscellaneous
Household help/child care ..........,.......... $ S $ $
Entertainment (Inc. papers, 5-"
books. vacation, pay TV, etc.)............ S $ $ S
GiltS/Charitable contributions .............. $ $ $ S
legal Fees ......,...............,..,...................., $ $ $ ~o S
Other child support/alimony
payments ....,......,....,............................ S S $ S
Other (specify) ..A(!~).!..f!.'./.;.L..,................ S $ $ IJ-{J $
Total Expenses ............,................................ S S s ...l.L~ s
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LAW flHIl:f. Of
Jacqueline 1\1. Verney
HAROLD BOOTH JR"
Defendant
.
.
I~ THE (,Ol'RT m' COM:\ION PLUS OF
C'UMBERl.AND ('OUNTY, PENNSn,V ANIA
CIVil, ACTION - 1.:\ W ~ \D , ,
\D 'jl
V. . IN DIVORCE :- -.,
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DEBBrE K. BOOTH, NO, 96-1~9 "',' '-" ,;\J
~ ,. :'! ~ i~
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PETITION "'OR RE1.:\'fED C:1.:\IM -<
AND NOW, comes the defendant, Harold Booth Jr., respectfully represents that:
ALIMONY PENDENTE LITE
I, Filed for divorce on or about March II, 1996.
2. Dcfendantlacks sullicient property 10 provide reasonable means and is unable 10
support himselflhrough appropriate employment.
3. Defendant requires reasonable support to adequately support himself in accordance
with the standard of living established during the marriage.
4. Detendant requests the Court to enter an award of reasonabllltemporary alimony and
additional sums as they may become necessary from time to time hereafter until final
hearing and pennanently thereafter,
RflI
Date: AP~;L ~ J"}'>?
Harold Booth r,
24 North Enola rive
Enola, PA 1702~
(717) 732-1208
heteOt; md ead! has hid the opportuDhy to con..llt with his or her 0WlI ~ IepI ~ll'te1
~ ofead! odIer; and,
WHEREAS, ead1 party MI1'IIIlI, III part of the coosideratioo of this AgJectIlal1, that ead! ....
IWIy IIId ~1dCIY diacIoIIed aD infimDItioa of I fin-..Q.' IIIture ~ by the odIer, and that 110
i1furmation of IIIdI natunl has been suIJ,jea to distor1ioa or in lIlY lIIIIIIIer being mi...,... sm:to<f; IIId
WHEREAS, odIer thin III see fOrth hereiiI. Wife desires finaDy md finmlr to reIinquiIb aD of
her risbt of dower, riabts III heir or llUIViving spouse or odIawiBe, ICtUII, cummly ~& or
~ in IIId to the real md penonal property of tile HusbInd, now owned by him or wbid1 ia tbc
future 11II)' be OMled by him, IIId aD riabts to c:olllltel -. or CllpCIIICI and odJer thaa II see fOrth
hereia, I'l...,d Iikewlae wishes to reIinquiIb aD hi. rigbts of curtesy, risbts II heir or llUlVivia8 IpOUIC
or otherwiso, adualllld cummly pillfirlg or iacbotto ia IIId to tho real and penonal ClUte oftbc Wdil,
cummIy 0\Wed by her or which ibe 11II)' 0Ml in the future;
NOW, TIIEREFORE, the parties hereto inteIIdiag to be IegIDy bound hereby do haeby
-.ny agree IlIlD11ows:
1. Advice ~ CoaDICl. HlI......d IIId Wife ac:lmowledge that they have been sMa the
opportuaity to obtaia the lIdW:e of COIll'1Jel regardins the provisioas ofd1is ~ and their IepI
effix:l ia IlMDce of the dIte see fOrth Ibow to permit IIIdI iodepaulem review. Each party
ac:JmoMedsea that he or &be has hid the opportuDity to receive iNl~ClIt IegaIlIdW:e from ~...ee1
ofhia or her n'1~.1IId that ead!1WIy undentaads the /icQ IIId has been fully infurmed III to his 01'
her IepI ripts mil ~. and ead1 party ac:Imowledgcs and ac:cepts that this Asr...........1 is, IIId
IIIId<< the cira............ liir and equitable, a1ler having the opportuDity to receive sud1l1dW:e mil
with IIIdI JmoMedse, IIId that Cf"ecIM of this Ass eemeut is not the result of III}' ~roper or iIJega1
2
.__ 01' ........-lC. ID ~. eada party hereto acImowIedpa that be or. has had the
opportuD&y to be fully adviaed by his or her .apective IttOI'UY of the iqlact of the PamayIvInia
0i\I0rc:e Code,..h...dly the COIIIt has tbc risbt IIId duly to determine aD marb1 fiabta of the parties
b:bIiDa divon:e, alimony, alimony p""'.c-. !ita, equitable distribution of II marU1 JlI"lINRY or
1"'09IRY owned or po I 1 j mdMdual1y by the other, 001"'.... feel IIId COllI of ~ ad. IWIy
bowiIa the IIIDI and havias the opportuaity to be IWIy advlaed ofhia or her risbta~, eada
party hereto ItiIl de8ires to exeado this Aea _'_1. ac:ImcJwIedslDs that the termI .... ..-ditlnat. see
lbrth bereIn are tiir, jilt mil equiIabIe to eada of the parties, md waives his 01' her .eepective ript to
hive the CGIIIt ofC-...." Pleas of ('.....I'Crlaad CouDty, 01' lIlY other COIIIt of C'~- )ala.ll...wa.
IIIIb lIlY .,...___ootinn 01' ord<< #OC'''. the .~ parties' rigbts to a divon:e, alimony, alimony
p-d-t..&te, equitable diIbiludoa of aD marUl p.operty, COI"'.... .. JDd COllI of~
2. s.p.ndoa. }Ia.oMnd IIId Wdil do hcrdly ........ny tsree mil e-- to 1M IIIlpIII&e
lIDllapat IIDll do liutIIer agree that it sbaIl be Iawtbl tbr the }Ia."'-ad IIId Wdillt aD times bInafter to
1M separate aad IpGt from eada other, and to N8ide, lI:om time to time, II suda place or placelll they
~ .R.ny sIIall deem fit, he from lIlY coattOI or reetraiat or iIIerferaIce, dind 01' indirec:t, by eada
odIer.
J. No MoIeItatiGa, o.r-mt 01' 1Dterf'ereace. NeidIer party sbaIlll"l'~. haraII 01'
inta1in with the odIer 01' .......,a or endeavor to ~ the odIer to c:obabil or dwell with him 01' ..
by III}' DIDlI ~er.
4. Mutual Pt...-li IDd 1:1II,., WUver. ExA:c:pt IS otherwiae ""PI mly see fOrth hereia,
ia whid1 event aICh lllIpreM prnvisim shaD take pretedeoce over this pll'l8flPb, the parties hcnto
intcIId thII &om mil aIer the dIte vf this Ast-'Wlt. neither shaD hive lIlY IIpOUIIC's ripts ia the
3
I'.vpetty or.... of the odIer, md to that Gad both partieI waive, nrInquish, IIId lOabear the ripts of
doMIr or curtcay, ripts to inherW, riabU to daim or take the HrubIDd or Wdil's or fami1y ~ or
aIIowInI:e, to be WIled with Ieucn of ........i... .Iltiud or Idters '--my, or to tab against lIlY wiD
oflbe other, ad each I'" wah the odIer if either thould die ......... hie or her lIIwe IIIIaI1 d-w
to velIl in hie 01' her heirs II law, perDIIl",c -nivea, IIId IIlllI& of kia, -.....flna Ibe other II
thou&b he or IIbe had died 1 widow or widower. And each IIuther qrees that sIIould the other die
t.~ his or her property sbaI1 d~ to IIId WII i1 those persoas see Ibrth ia the odWs lilt WiD
IIId T..~ II thouah the IpOUIC so d-ip...,d II benefIc:iary had ~-t the -"-. Tho
parties fbrther qree ... they 11II)' md 4:ID herealIer, III t.bousb 1auaa..aW, without lIlY joinder by him
01' _, leD, CODVCy, trIIIIIiIlr 01' -...""'- lIlY ad aD Jeal .... md penonal ,.operty whid1 eidIer of
them aow 01' bInafter o\w or pclll III IIId Ibnber qree ... tbc -diua of dIia Aat~ sbaIl be
CClII.....lye evldmc:e to aD of hie or her ript to do!lO. The Slid tfa.......d IIId Wdil do hereby
~ snnt. each to the odIer, IhouId the excrciIe of dIia power hereby sMa be nee 't, the
Jiaba mil the power to appo;.4 oae or more timesIII}' penoa or penllIII wbom the }fa........ 01' Wdil
IiIaII d....... to be the attorDe)'-iD-&ct tOr the other, in their name mil i1 their .... to a~~ IIId
ac:ImowIedp lIlY deed or deeds. c' -. quit claims, or atiolVtinn" IIIId<< sed or odI.erwlae, to
lIIIble __ party hereto to .&..not., his or her real or penoaa1 p.IlpCIty, but without lIlY power to
t.."otIC perDIIllIabi&y tbr breadl ofwurmty or otherwiso. EICh oftbe parties herao fbrther Mivea
lIlY ript of ~ l'.nIItlIIinM in Chapter 22 of the PIlImsylvmla ProbIIe 11...", IIId FIdudariea Code,
md lIlY riabt to seek or have an equitable di&lributiou of mmied property ordered by the Court
punuanl to ~ 3302 of the Divorte Code. Each oCtile parties Junto fiD1her qrees that neidac:r
IiIaII berafter be UDder lIlY legal OOIiptinols to 5IIppOIt the odIer, pay lIlY ~ tbr .........."""""
4
m-.I, burial, or othawitJe lbr the odIer, and to that end eac:h of the parties her$) does hercily waive
lIlY riab& to receive support, aIimoay, alimony pendt:nte !ita, COUDSeI -. expenses. or lIlY type of
"""';"1 .-...-....... ~ fium the odIer, ~ II odIerwise ~. :s&ly provided fur hfnio.
". DiviIloa~""'" ......-1.7.
The parties agree thII they hive divided IDIlIDg rh....-Jvea the IIIIjority of the pcnml
property to their IDdUIl satisfactloo in(-.,~ automobiles, aD financial 1ClOO'~ md houadJold
fill'lli"'~ }Ia.oI>mJ.d qreea to tum over .dmm...1 items ardJ II Wdil'. ModIer's ~
ICI'Ipboob, ddIdren's toys, nint-to ~ Babie items prior to the ......1 oftbis Av--
The parties fiuther agree to review &mily photognpha and sIwe the costs of rcprodalrll- OIl
1 "01-'0 buis tbr OIIC dup~ ofd........'lCI photos. This sbaII be .(X~1Ished by the Ute of this
olpiolg
The parties ac:Imowledge that they were the joint owners of two (2) nn.....hn-es; namdy Mother
NIlure'. Aae and 11nmdabird. The parties agree that }Ia.""-'IIl sbaII become the sole CM1lCI' of
Mother NIlure's Aae IIId Wdil sid become the &Ole oWller of1bunderbird. Each party apes to
~ ~ dlVl.-. ue DOC -"/ to .~Iish said tIIDI&n IIId pay the ...-....,
........-- files OIl their rapedive tinwaah.""
Durina the COlUIIC oftbe parties' marriage, }Ia'ob-d was eu.,1oyed III 1 n..... of the United
StItea AImed Fon:es and is, III 1 resJIl, -"tlo<f to and prellClltly receiving 1 military p""'.....
('..(,o'.'-~I June 1, 1999, Wdil sbaIl recciw SJOO.OO each IlIIIIIth IIIItiI her death or lJI.ohand's death
IIId Wife wiD be re&pODSible fur the payment of any inc:ome taxes OIl her portion of IIIdI p""'1linn. The
parties wiD coopalIle to ensue the entJy of 1 Q".~ ~ p.....u.... Order .afIV.l-t fur
JIIIIPOII'S of 1 direct payment of Wdil's SJOO.OO each month. In the eveot the military is uaahIe 01'
5
uawiIIina to IIIIb said dind pIYlDfIIlS fur whItcver rea&OII, "I'''~II QORO II DOl ill place by Me
I, 1999, }fa.....lld agrees to arrmge lbr the dind depoIit ofSJOO.oo or lIlY ,liffil..,dClll thII the aUwy
wiB DOt PlY directly to Wdil 011 . mnntIJly basis, to I bank ~"'ild by Wdil. Said ptymIIIII by
III."'-d to be made 011 the fine day of eadllDIlIIth unIesa thII day liDs 0111 Suadty, ia whidll:llll the
dIrec:t depOIiI wiB be made on the next busia_ day. The partica agree thII they wiD ........... to
amaae fur the wkbdnwI1 of that SIIID each IDIlIIth lI:om }fa."'-d'. dteckina ........mt
Hwiband fbrth<< qreea to PlY to Wdil the ~ IIIID of~,OOO.oo 011 the 1ilIlowia& pIyIIIG
~.J..: $2,000.00 CCJlIt~.,,,,,1I1M1S with the ...... of this Igreanr:nt but DOt !at<< than M.y 14,
1999; $2,000.00 011 Septcmler 14, 1999; and SI,OOO.oo 011 [\,(....iler 31, 1999. }fa......... lIbaIl also
PlY to Wdil 011 Dec-.her 3 I, 1999. the un of $200.00 fur penonall"vyII1y itsm thII III'''''''''
disposed of AD of IIid ptymIIIII &nl to be hand delivered or IIIIiIed to Wdil'. sttomey 80 that WIfis
receives them on the d I 'v riM dItea. PIIymenl sbaIl be made by IDIllICY order.
Except II otberwiIIe see fiIrth above, neither party sbaIl make lIlY daim to lIlY sudI itomI of
marUlp.clpeIty, or of the scpan&eperaooalproperty ofeitberparty, whidlare now ia the po '-
lIIdIor UDder the coatrol of the odIer.
From and a1ler the dIIe of the oi..... of this Asr-'- both parties sbaIl have ~ldo
fieedom of ~ II to their lICparlte 91~ whidl is ia their po . - or coatrol pumIIIIt to
this Aaa"'~''''IC mil 11II)' mortpge, sell, grant, c:onvey or otherwise eD"',.w-. or di".- of sudI
JIIupolIty. Mctber real or penooaI, whether sudI property was .cquired befure, during or after
IJIIITiaae, and neither .'"......d nor Wdil need join in, eomatt to, or ac:knowIedse lIlY deed, IIIOItpp,
or odIer iastrumcut of the other patsinins to sud1 dispositioa of property.
6. DebD. The parties agree that aD marital debt has been ati....'1orily divided. The particI
6
.... to be Nlp""oihIo lOr lIlY other iDdMdual debu MidI are ~ ia dacir iDcIivDIII _ mil
to ......ay IIId IIoId Iwn I II die other lOr the d,,~.-otlnntd debta.
7. ........ 0IbCa T1Io paItica fbrthIr qree thIt neither \WI incur lIlY 11IOI'O future debu filr
Midi the otber IIIIY be hold .UbIe, IDd if lIitber party inaln I debt tbr wbidl tbc other wiD be IabIe,
tUt party iacurriIa uh debt wiD in.t-il}t IIId hold tho other harmIeI8 from lIlY IDd aD IIabiIi&y
dMnof
8. Real "...-tt. Tho partiea acImowIedp thIt. findoan pl'O("'e'l.... has beea llIed
ia wbid1 the reel9'~ wiD be UJ8Idaed.
9. Support, Alimoay IDd Alimoay Peadeute Ute. Both parties 111" to waive any
and aD riabta eidJer 11II)' me to lpOuaaJ IUJIport, aIimoDy lIId10r .Iimony peadeate IiIe fiom t.hia
time tbrward into the fbture.
10. ....... Except II provided ia paragrlph ~ henia, both parties qree to waiw tho
odMI-'l p""'...... ....ulloo4 01' IRA --
11. Cowud r_ aad COIIIrt COllI. The parties qree to be ,."....oihle _ their
.~ IepI .. IDd COllIt COllI iocuned ia the procou of lIlY divorce Idina or acpandmI
~.~.t
12. DiYora. Tho partin acImowIedp their inteDtioa IDd ..,..JeIIC to pl'CXlClld ia III
Idina ia divorce to oIJtain I 8nal der:ree iI divon:e by DIIdual .......,- 011 the pouads that their
.....n... . imtriIvably brokm, md to seuJe amiI:ably IIId IWIy hereby aD daimI railed by ciIber party
ia lilY divon:e action. The partlea Igree to Cf'ecIM lIlY IDd aD dnn_. lie( I '1 lOr the entry of I
8nal divorce d<<Iee.
13. Brae'" ID the event that fiir<< party breadrCllIIIY provision of thiI MarUI Pl~y
7
md Sd'.......~.1 ~. be 01' .. IbaD be ""PO"'oihIe fix lIlY IIId aD CIOIII iIamed to adDn:e the
t<<IIII benot; .......... but not Iimital to, cowt c:cIfltIlIId ~_.ble tWill"'" .. of die otber party.
ID tIIc evad of1lRadl, the other party sbaI have the fiabt, II his 01' _ .ri.QaJ. to __ d... III fix
IIIdIInIdl or to _ suda odIer IIId oMirinn.1 ,.......m- II may be available to him 01' _.
14. EaIortfo_t The pam. ape dill this mariaaI-'--t qretIIIIIIt or III}' part or
panalMnof may be ea1brced in lIlY cowt of C("""'" jurllIIflmnaa
J ,. ....,......... Law IDd l:ueutioa. The plltiea hento ape that this marita1-1aonwtt
........._4 IbaD be COIIIUued UDder the J.ws of the CUU........-Ith ofPmuylvania md 8ball hiDd the
pam. hento md their ~ hein, ~ttors and '....... TIIis d.v>.a_ IlIalI be euc:uted II
oripal mil aultiple copiea.
16. no bdrt .....t. The parties ac:Imowledp and ape that this JDIIUI
_L.-- . aan--t (10.".:". the entire 1IIIdenaIIdins of the padiea and supenedea my prior
~t ben\.. dMm. Then are DO odIer.~ f If..v-, "'...~ ~...~ COYeDII1U or
uadenIaadiDp bctv.11Il1lle p3ItleI other thm thole ""I'.....Iy .. bth bereia.
17. '**.-IId081Dd "'........ _ Divorce. In the MIlt that either I'n""-f or Wl&
II lIlY time hereaIt<< obtain I dIvorc:e ia the actiml fOr dIvorc:e,. -.:y p""dinS bctweaI them, or
otherwi&e, this ......... .If md aD of ita pruvisioas IbaD be incorporated iato lIlY mcIl ,;'''r- &lr
divorte, either directly or by reliraIce. The Court, ou eatry ofj'<lr- filr divon:e, ...... the
rigbt to CIDim:e the provl&ioas ad termI of this marita1-Lon-t agr-n.....t
18. AdrItioIUII...,...... Eac:h of the parties sbaIl ou "--d or withia 11eI-.hIe
period thereafter, aecute and ddiver lIlY and aD other doannenta and do or C'aI18C to be dODe III}'
otber ad or thins that may be nCl:elllllly 01' desirable to el!ectulle the pnMliooa and pwpoeeI of this
8
In tbe Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
HAROLD BOOTH ) Ou.;kOI Numt>or 96-1549 CIVIL
Plaimiff )
V~. ) PACSES Ca.-.: Numhor 505100907 /028,475
DBBBI! K. BOOTH )
Oorond4m ) Olhor Slalo 10 Numhor
ORDER
AND NOW, to wit on this 15TH DAY OP NOVEMBER, 2000
IT IS HEREBY
ORDERED that the 0 Complaint for Suppon or 0 Petition to Modify or (i) Other
ALIMONY PBNDIlNTIl LITE
filed on MARCH 29, 2000
in the above captioned
matter is dismissed without prejudice due to:
PARTIBS HAVING SBTTLED THIS MATTER
o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
BY THE COURT:
JUDGE
1JIlO: RJ Sha:Uay
xc: defen:lant
plaIntiff
Jac'l'lellne Verney, EsqIllre
II-ff'J-I'(
Sorvico Type M
Form OE-506
Wnrkor 10 21005