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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
DENISE L. JAMES
Ptnintiff
[\; o. 96-3075
Vt'l',HIS
SCOTT W. JAMES,
Defendant
DECREE IN
DIVORCE
AND NOW, . . . . . .. . . .1>AA~. . ,2.r.~ " 19 ,'?'. . " It Is ordered and
decreed that....,.....,. .DENISE.t. .JAMES......,.."........., plaintiff,
and. . . . . , . . . . . . . . . , . . . . . . . .S~9.TT. ~'" .JM'fJ!:.S. . . . . . . . . . . . . . . . . . . " 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 finol order has not yet
been entered; NONE
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. . . . . . . ,t.he. J.i.na.l. .Div.o.r,c.e. ,De.c.t:e.El. . . . . . . . , ,
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This ^sreement of December 13. 1996 is hereby incorporated in the
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DINISI L. JAMIS, I IN TH. COURT or CONNON PLIAS
Plaint::I.U : CtINIllRLAND COUNTY, PINNSYLVANIA
:
v. : NO. 96.3075 CIVIL
:
SCOTT ". JANIS, : CIVIL ACTION . IN DIVORCI
Defend.ant: I
SIPARATION AND PROPIR~Y S~IMINT AGRIIMINT
THIS AGaIDINT, made and concluded this P.-day of ~~.e~-
19 q" by and between SCOTT W. JAMIS, of Baltimore, Maryland,
hereinafter referred to as "HUSBAND"; and DINISI L. JANIS, of
Carlisle, Pennsylvania, hereinafter referred to as
"WIPI" .
WITNlSSETHI
WHIRIAS, Husband and Wife were lawfully married on April 3,
1983, in Cumberland County, Pennsylvania; and
WHIRIAS, three children were born unto the marriage! Ryan,
September 30, 1983; Brandon, September 5, 1986; and Kacey, ,July 22,
1988;
WHIRIAS, certain differences have arisen between the parties
as a result of which they now 1 i ve separate and apart from one
another, and are desirous, therefore, of entering into an Agreement
which will distribute their marital property in a manner which is
considered to be an equitable division of all joint property, and
will provide for the mutual responsibilities and rights growing out
of the marriage relationship; and
WHIREAS, a Complaint for Divorce has been filed in the Court
of common Pleas of Cumberland County, Pennsylvania, to the term and
Number 96-3075 Civil; and
~.. -. ~." . _. -.... .' . .,
WIII.IAB, the parties intend to execute Affidavits under
Section 3301(c) of the Divorce Code, and
WIII.IAS, there has been a complete disclosure of the earnings
,
and property of each party, and each understands his/her rights
under the Divorce Code of the Commonwealth of Pennsylvania; and
WKIRIAB, the Wife, after being properly advised by counsel,
Judith Calkin, and the Husband, who is represented by P. Richard
Wagner, have come to the agreement; and
WKIRIAS, it is the desire of the parties, after long and
careful consideration, to amicably adjust, compromise and settle
all property rights, except those hereinafter set out, and all
rights in, to or against each other' a property or estate, including
property heretofore or subsequently acquired by either party, and
to settle all disputes existing between them, including any and all
claims for Wife's and/or Husband's maintenance and/or her support,
alimony, counsel fees and costa.
NOW, THIRIPORI, in consideration of the promises, covenants
and agreements hereinafter contained, each of th~ parties hereto,
intending to be legally bound hereby, promises, covenants and
agrees as follows:
I. DIVORCI
The parties agree that the marriage is irretrievably broken,
and that they mutually consent to a divorce and agree to execute
all necessary affidavits requjred by the Court at the appropriate
times.
This Agreement shall remain in full force and effect
regardless of any change in the marital status of the parties. It
is warranted, covenanted, and represented by Husband and Wife, each
to the other, that this Agreement is lawful and enforceable.
Husband and Wife each knowingly and understandingly hereby waive
any and all possible claims that this Agreement is, for any reason,
illegal, or for any reason whatsoever of public policy,
unenforceable in whole or in part.
II. SBPARATION AND INTBRPBRBNCB
It shall be lawful for each party at all times hereafter to
live separate and apart from the other party at such place that he
or she may from time to time chose or deem fit. The foregoing
provision shall not be taken as an admission on the part of either
party of the lawfulness of the causes leading to their living
apart. Each party shall be free from the inteI'ference, authority
and contact by the other, as fully as if he or she were single and
unmarried, except as may be necessary to carry out the provisions
of this Agreement. Neither party shall molest the other nor
attempt to endeavor to molest the other, nor compel the other to
cohabit with the other, nor in any way harass or malign the other,
nor in any way interfere with the peaceful existence separate and
apart from the other.
III. DEBTS
Each party agrees to pay all debts incurred by him or her
individually since the date of separation. Each party shall
indemnify and hold harmless the other party from any and all claims
or demands made against him or her by reason of debts or
obligations incurred by him or her. The parties have incurred
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various debts during the course of the marriage, whJ,ch have beer.
divided between the parties. Husband expressly assumes the debt as
of the date of separation for his parents, Mr. and Mrs. Wesley
Jameo.
IV. LIGAL ADVICI
The provisions of this Agreemt!lnt and their legal effect have
been fully explained to the parties and each party acknowledges
that he and she have received or had the opportunity to receive
independent legal advice from counsel of his or her selection, and
that each has determined to complete this Agreement, and each fully
understands the facts and has been fully informed as to hls or her
legal rights and obligations.
V. RIAL PROPBRTY
Husband and Wife agree that the real estate has been sold and
that the proceeds thereof are currently in escrow. Husband and
Wife agree that from the bounds of the proceeds currently being
held,' Wife shall receive $37,000.00. The remainder of the amount
currently being held shall be the sole and exclusive property of
Husband. Husband agrees that he shall assume any and all capital
gains tax that may be incurred by the parties as a result of the
aforementioned sale of the marital home. Husband further agrees
that any and all interest that may be accumulated on the escrow
(which is being held in the form of a CD) shall be the oole and
separate property of Husband, and Husband will be responsible for
the payment of all taxes on said interest.
VI. 'IRSONAL PRO'IRTY
All items of personal property have been divided between the
parties and shall become the exclusive property of the party in
whose possession the items are on the date of this Agreement.
VII . IOtJITAIlLI DISTRIBUTION
The distribution of marital property and of marital debt shall
be regarded as equitable reimbursement alimony for enforcement
purposes and shall continue in effect until all obligations have
been met. Neither party ahall include any debts referred to above
in any bankruptcy petition or proceeding and in any event, shall
not be dischargeable in bankruptcy. The parties have attempted to
distribute their marital property in a manner which conforms to the
criteria set forth in Section 401 of the Pennsylvania Divorce Code
and the division of existing marital property is not intended by
the partiea to constitute in any way a sale or exchange of assets,
and the division of being effective without the introduction of
outside funds or other property not constituting outside property.
The division of property under this Agreement' shall be in full
satisfaction of all marital rights of the parties.
VIII. INCOME TAX
Husband and Wife agree that Husband shall be permitted to
claim one child for the 1996 tax year. Thereafter, the children
shall be declared as tax dependants by the person in who's custody
the children have resided.
I
IX. HIALTH INSURANCI
Husband agrees that he shall pay fifty percent (sot) of Wife's
bi-weekly medical costs to provide medical coverage for the three
children. Any eye/ dental, orthodontic or doctor bill that is not
covered by insurance shall be divided by the parties on an equal
basis.
X. ALIMONY
Husband and Wife agree that of the aforementioned $37,000.00
received by Wife, $4/700.00 shall be determined to be alimony paid
during the tax year of 1996. Wife agrees to claim forty-seven (47)
weeks of alimony at $100.00 for income purposes, and Husband agrees
to deduct forty-seven (47) weeks of alimony at $100.00 a week for
a tax deduction in 1996 taxes. The effect of this paragraph is to
provide that of the $37/000.00 received by Wife, as hereinbefore
provided, $4/700.00 shall be determined to be alimony.
XI. ALIMONY PBNDBNTB LITB. COUNSEL PEBS AND BXPBNSBS
Husband and Wife acknowledge and agree that the provisions of
this Agreement providing for the equitable distribution of marital
property of the parties is fair, adequate and satisfactory to them.
Both parties shall accept the provisions set forth in this
Agreement in lieu of and in full and final settlement of all claims
and demands that either may now or hereafter have against the other
for alimony pendente lite, counsel fees or expenses or any other
provision for their support and maintenance, before, during and
after th~ commencement of any other proceeding for divorce or
annulment between the parties. Each party shall be responsible for
his or her own counsel fees, and each agrees to indemnify, defend
and save the other harmless from any action commenced against tne
other for alimony pendente lite, counsel fees and/or expenses,
XII. PINAL DISTRIBUTION or THB ASSBTS
Any interest to be transferred pursuant to this Agreement
shall be conveyed and transferred to thfl respective parties
immediately upon the execution of this Agreement, with an effective
date as of the date of separation.
XIII. RBCONCILIATION
Pending a reconciliation between the parties, this Agreement
,
shall continue to remain in full force and effect absent of
writing, signed by the parties stating that this Agreement is null
and void.
XIV. BXBCUTION or DOCUMBNTS
Husband and Wife covenant and agree that they will execute any
and al.l instruments necessary and desirable for the proper
effectuation of this Agreement.
xv . BRBACH
In the event of a breach of any of the terms of' this
Agreement, the non-breaching parties shall be paid, as part of any
award or judgment against the breaching party, all costs, including
actual counsel fees paid to his or her attorney.
XVI . RILBASBS
A. Except as provided for in this Agreement, Husband and
Wife each hereby for~ver releases, remises, discharges and
quitclaims the other and the estate of the other, for all time to
come and for all purposes whatsoever, from any action or any nature
whatsoever in law or J.n equity and from any and all rights, titles,
interest, or claims in or against the other or in or to the real,
personal or mixed property of the other and all rights of curtesy
or dower or for equitable distribution. Husband and Wife release,
discharge and forever remise all right, tit le and interest and
claims to take against the other's will and/or under the intestate
laws, or a fami ly exemption or similar allowance or all other
rights of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of Pennsylvania or any other
state or commonwealth or territory of the United States or any
other country.
B. It is specifically further understood and agreed by and
betweell the parties hereto that Wife and Husband accept the
proviaiona made and set ~orth in this Agreement in lieu of and in
full satisfaction of any and all of Wife's rights against Husband
or Husband's rights against Wife for any past, present and future
claims on account of support and maintenance.
XII. INCORPORATION IN PINAL DIVORCI
This Agreement will be incorporated for purposes of
enforcement only, but shall not merge in the final Divorce Decree
between the parties. The Court on entry of the judgment for
divorce shall retain the right to enforce the provisions and the
terms of the Agreement. This Agreement shall remain in full force
and effect regardless of any change in the marital status of the
parties.
XIII. CHOICI or ~6M
This Agreement shall be interpreted under the laws of the
Commonwealth of Pennsylvania.
XIX. ~
A modification or waiver of any of the provisions of this
Agreement shall be effective only if made in writing and executed
with the same formality as this Agreement. The failure by the
party to insist upon strict performance of the provisions of this
Agreement shall not be construed as a waiver of any subsequent
default of the same or similar nature.
XX. DESCRIPTIVE HBADINGS
The descriptive headings used herein are for convenience only.
They shall have no effect whatsoever in determining the rights or
obligations of the parties.
XXI. PEPARABILITY
In case any provision of this Agreement should be held to be
contrary to, or invalid, the laws of any countries, state or other
jurisdiction, such illegality or invalidity shall not in nay way
effect the other provisions hereof, all of which shall continue,
nevertheless, in full force and effect, and each paragraph herein
shall be deemed to be a separate and' undisputed covenant and
agreement.
XXII. ENTIRB AGREEMBNT
This Agreement contains the entire / complete and exclusive
understanding of the parties. There are no r.epresentations,
warranties, promises, covenants or undertakings other than those
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DENISB I,. JAMES,
Plnintiff
IN 'rllF. COUR'!' OF' COMMON PI,EAS
CUMnF:/ll,AND COllN1'Y, PP.NNsvrNANIA
vs.
SCO'I"l' W. .IAMl':S,
lIofendnnt
CIVlI, AC'l'ION-IN DIVO/lCE "
NO. (/~ 3 (I 7~- fl ('\Ill( _
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE nF:F:N
against tho claims sot
taka prompt action.
You are warned that if you fnil to do so, the case may
proceed without you and a decree of divorce or annulment. may be
enternd against you by the Court.. A judgmnnt may Illso be
en.ton1<1 against you for any other claim or 1'01 inf l"equested in
those papors by the Plaintiff. You may 1<'>Re money or property
or other rights Important to YOII, l,ncludil\g custody or
visitation of your children.
When tho ground for the dlvorco is indignitieR or
irr<~trievable bnilakdown of tho marriage, you may request
mllrl'lage cOllnBeli,ng. A IJ.st. of mllrriage counBelors is
avallable In the Court AdmlniRtrntor's Offlcf,l, Cumborland County
Courthouse, CarliRlo, PA.
Sll~itJ IN COUR'I'. I f you wish to defend
forth In the fa llowlng pages, you must
PROPE/l'I'Y,
ANNULMEN'I'
'I'HP.M.
IF' YOU DO NO'I' F'lI,E A CLAIM FOil Al.IMONY, DIVISION OF'
I,AWn;R'S f'EES OH EXPF;NSES BEFORE A DIVORCE OR
IS GHAN'I'ED, YOU MAY I,OSE 'I'IIE HIGIl'I' '!'O CI,AIM ANY OF'
IF YOU DO
1'EI,f;PHONE
GE'!, I,EGA!,
YOU SHOUI,D
NOT HAVE
'I'HE Of'F'ICE
HlU,P.
'!'AKE 'l'HIS PAPEH 1'0 YOUR LAWYER A1' ONCE.
A I,AWYP.H OR CANNO'!' AF'f'OHD ONE, GO TO OR
SWI' F'OR'!'H BELOW '1'0 f' I Nfl OUT WIIERE YOU CAN
Court Administrator
4th f'ioor
Cumberland County CourthouRe
Cariisle, PA 17013
(717) 24()-6200
O~NISE L. JAMES,
Plaintiff
IN 'I'IIP. COlJR'1' OF' COMMON PLEAS
CUMOP.Rl.AND COlJN'I'Y, PENNSYLVANIA
NO. '1' 30'1 ~~ eWd'~
VII.
SC:O'I"1' W. JAM~S,
Dofondant
CIVIl. AC'I'ION"I,AW
III VOHCF: AC'1' ION
NO F'AUlil' D I VOIlCE COMPI..A I N'r
3301101
ANO NOW com~s the above-nallled PlaintIff, DENISE L. JAMES,
by JudIth A. Calkin, P.squiro and she soaks to obtain B Decree in
l>ivorce from tho above named Defendant upon the groundll hereinafter
more fully set forth!
'1. Plaintiff Is IlBNISB I.. ,JAMBS, who re/lides at 133
Garland Drive, Carlisle, Cumberland County, Pennsylvania.
2. Defendant Is SCO'I"I' \~. .'AMP.S, who re/lldes at 82 OIde
F'orgo I~ne, Baltimore, Maryland.
3. PlaIntiff has been a bona fldo re/lldent in the
Commonwoalth for at least six nmnth/l Immediately previous to the
filing for this Complaint.
4. 'rhe Plaint.!ff and Defendant WHre married on April 3,
19E1J in Cumborland County, Pennsylvania,
'L 'rhAre hilS bean no prior ar.t I on for divorce or
annulment bntwaen the parties.
6. 'I'he Defendant. Is not a member of the Armed Serv\.ces.
7. ThA marriage i/l Irrotrlnvahly broken.
8. Plnlntlff has be<1n advised of the availability of
marriage counseling and that. she may have the right to request the
r.ourt. to n><]ulre thn partleR to partlclp,H.n I.n /lur.h counselIng.
Being so advised, Plaintiff doos not requeBt that the Court require
the partieB to participate in counBoling prior to a Divorce Decree
being handled down by the Court.
Wherefore, the Plaintiff prays your Honorable Court to
enter a Decree in lHvorce from the bonds of. matrimony.
COUN'r I I
,
(Equitable Distribution)
10. Plaintiff and Defendant have acquired real and
personal property during their marriage.
11. Plaintiff and Defendant have been unable to agree
as to an equitable division of said property as of the date
of the filing of this Complaint.
WHEREFORE, Plaintiff requests that the Court enter a
Decree equitably distributing marital property.
COUN'r I I I
REOUEST FOR ALIMONY
12. Count I, II [, III of the Complaint are incorporated
herein by reference thereto~
13. Plaintiff is unable to support herself through
appropriate employment.
14. Defendant is able to provide support to Plaintiff.
WHEREFORE, Plaintiff respectfully requests the Court
to enter an alimony award on her behalf.
COUNT IV
REQUEST FOR ALIMONY PENDENTE LITE AND
COUNSEL FEES. COSTS AND EXPENSES
15. Count.s I, II, II I & I V
of the Complaint are
1
incorporated herein by reference thereto.
16. Plaintiff has employed Judith A. Calkin, Esquire to
represent her in this matrimonial caso.
17. Plalntiff is unable to pay her counsel fees, costs
and expenses and Plaintiff is more than able to pay them.
18. Plalntiff ill unable to sustain herself during the
COurse of this litigation.
WHEREFORE, Plaintiff respectfully requests the Court to
enter an award of Alimony Pendente Lite, interim and final counsel
fees, costs and
expenses.
jl,
Relpectfully lubmittedl
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J6dlth A. calk(~, Esquire
~ttorney for Plaintiff
2201 Nor.th Second Street
Harrisburg, PA 17110
(717) 238-2312
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rn the COllff of Cllm.mon Plna of
ClImIMrJand C~lInIY, Pennsyh'lnia
l'lllintiH
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VI.
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Defendllnt
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llP.NISF. I" .IAMBS,
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IN TilE COUll1' OF' COMMON PLEAS
ClIMBER1.ANO COUN'rY, PENNSYLVANIA
NO. 96-3075 CTVIl.
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SCO'I"!' W. .'AMP.S,
Do r rmda n t
CIVil. AC'l'lON 'IN DIVORCH
ACCEPTANCE or SERVICE
r, P. IHch.'lt:d ~lagner, At.torr:!':}' ["I!- tho n.."rnnd'lnt, 1n I'll",
ahovo-captioned CBSO,
do herehy Bccept aorv iro 0 f thri
.lJO 1 (<1) Divorce Compol int: and horeby acknowledge
receipt of a
true, correct ond complete copy.
I understand that false statements herein are
m"dp
HuhJect
to t.ho penalties of lB Pa.C.S. Sod.ion 4904,
,'nJlltt.nq t.o un/lwnrn fnlst.ficBtion to nuthort.tiea.
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DENISE L. JAMES,
Plaintiff
IN THE COURT OF COMMON PLBAS
CUMBERLAND COUNTY, PBNNSYLVANIA
NO. 96-3075
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SCOTT W. JAMES,
Defendant
CIVIL ACTION-IN DIVORCE
WAIVIIR or NOTICI OJ' INTIDITION
TO RIQU.ST IDITRY or A DIVORCI DICRII
UNOIR 3301(01 or THI DIVORCI CODI
.\
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I dOll' t
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 a~e
true and correct.
I understand that false statements herein ar
made subject to the penalties of 18 Pa.C.S. 84904 relating to
unsworn falsification to authorities.
Date:
Ivl'4/16
(L~ t.Sr-'_J
DENISE L. JAM