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HomeMy WebLinkAbout96-03490 I \ L Q) - :J (j . '" 7 l- V --- ? .- o ~ ~ F J o a- T <Y) ...9 cr I I I \" \ I , ,. 00 " ~, /11 ) . , ~..*..~~.~~*.~*.'-,*..~.:~..~"~.~.*.,~,.*,~.~,~.~,*..~,*.~. ~ """"."._"., . , @: ,I ~: ~i w' "'{ IN THE COURT OF COMMON ,:.:- .:.:. ';4 I~ I' IN I. I~ I~ I. PLEAS ~1 ~~ .1 .1 ~~ . , ~I OF CUMBERLAND COUNTY ')1.' STATE OF ;~~~t PENNA. ~ ~ , I ~I ~i ~I ~,' \ .1 ~~ . \ oJl ", , I ~I ~( 'I ~I '" '1 ~I 'i KATlIIlYN E. G I VI.EII, l'lnlntlff i'\ II. 9~-3/,9l) "WH.. , \'.-1",;\1:-; I.EIIOY E. GIVI.EII, Defendant DECREE IN DIVORCE AND NOW, ,,)~"':^'\.'2:'L. 19R, It Is ordered and decreed that ' . . KAl'URYN."~, GIVJ.t:R, , , . .. . . , , , . . . . '. plaintiff, and. . . , , . , . . . , , . .1',Ii.II,O,Y. ,t;..,GIVI.J~1\ . . , , , . . . , , , . " defendant, are divorced from the bonds 01 matrimony, ~ {J ~ ~I ~ oJ " w '.' ~ The court retains jurisdiction 01 the following claims which have been raised of record In this action lor which 0 final order has not yet been entered; ~)~v..Jl v. '.' ~ ~. .', ~ .the Ma~ LtaL ,Settlement .AI\~eem"nt .~I{ ,h(n:eh~ .enter.ed nl{ .,10 ,1Ir.der. ,of botwII"n ,tho 'pnl'Hoa, ,dntedlleeember .16, '1996, J .Collrt .nnd .the .toma ,thoreof :nro ,horoby. . , oJ " ., ~ Incorporated In the Ilecrel! Ln Illvorce. II y Th ,. \~r j.~/./ . , Aile.!:..''''; , [1/" '/-".,//. -y J ~_.."..,-,,,c.- (./<'- ~"'\"''''i''I'i''''"'!i'''17 . ''''.Ar 1 ~i 1< J::~/) 6:. /~ '1 // . , ;Y Prolhnnnlnry oJ ~ w ~' oJ " ~ ~ ~ ~ - -- - ->>:. ~ .o:~. :~ .:+;. .:+:. .:+:- .:+:. .:+:. -:.:- .:.;. ,;.:. .:.:' ':6> .:.:- .:.:- .:.:. .~.:' .:.;. .:.;. ~ >:' ~ ~ ~ .~ " ~ ~ ~ ~ ~ ~ ~ .' f, W '" ~ ~ I~ ~ " \~ I. I,~ I: I~ I~ I" ,~ I., I' I~ I",' I. '~ I~ ",' ~ '.' .,', , ~ '~ , . ',~ ',' * ~ :~ , ~ , ~ NOW, THEREFORE, in consideration of the premises and of the marriage, and in further consideration of the mutua 1 promises and undertakings hereinafter set forth, each in- tending to be legally bound hereby, the parties agree as follows: 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time ohoose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of th~ causes leading to their living apart. 2. INTERFERENCE. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried except as may be neoessary to carry out the provisions of this Agreement. 3. WIFE'S D~. Wife represents and warrants to Husband that as of the date of separation she has not in- curred, and in the future she will not contract or incur, any debts or liability for which Husband or hls estate might be responsible and shall indemnify and save harml.ess Husband from any and all claims or demands made against him by -2- ~ ~. ~ . , reason ot debts or obligations incurred by her. AllY and all loans and/or debts, and charge accounts, presently in wite's name alone shall bG Wite's soIa and separate responsibility for payment. Wife agrees to indemnify and save harmless Husband from any 10SB he may sustain, including attorney tees, as a result of any detault in payment by Wife. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the date of the separation he has not incurred, and in the future he wJ.ll not contract or incur, any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Any and all loans and/or debts, and charge accounts, presently in Husband's name alone shall be Husband's sole and separate responsibil- ity for payment. Husband agrees to indemnify and save harmless Wife from any 108s she may sustain, including attorney fees, as a result of any default in payment by Husband. 5. ~TABLE DISTRIBUTION. Husband and Wife acknowl- edge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separato property are tair, equitable and satisfactory to -3- . them based on the length of their marriage and other rele- vant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to division ot property in lieu of and in full and final settlement and satisfaotion of all claims and demands that they may now have or hereafter have against the other for the equitable distribution of their property by any court of competent jurisdiction pursuant to section 3502 of The Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distri- bution of marital property, but nothing herein contained shall constitute a waiver by either par.ty of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 6. DIVISION OF PERSONAL PROPERTY AND VEHICLES. The parties have divided between them, to their mutua 1 satisfac- tion, the personal effects, bank accounts, household furni- ture and furnishings, and all other articles of personal property which have heretofore been used by them in common. It is specifically understood that Wife shall receive the dining room suite. The parties expressly agree that Wife shall be entitled to exclusive ownership of the 1987 Ford Tempo currently in -4- It; jl \:I "rf ~ ". # . her possession, and that Husband shall relinquish any and all interest he may have in such vehicle. Husband shall transfer title to said vehicle to Wife after January 1, 1997 and prior to Janusry 8, 1997. Until said transfer is oompleted, Wife sheIl retain exclusive possession and use of the vehicle and Husband shall maintain the required insur- ance coverage of the vehicle at his expense. Fol.lowing the transfer, Wife agrees to be solely responsible for payment of any and all encumbrances and expenses (inclUding the aforesaid insurance) affecting such vehicle. Wife shall indemnify and save harmlass Husband from any 10ss he may sustain, including attorney fees, as a result of any default in payment of the aforesaid obligations by Wife. Husband shall be entitled to exolusive ownership of the vehicle currently in his possession, and Wife shall relinquish any and all interest she may have in such vehicle. Husband agrees to be solely responsible for payment of any and all encumbrances and expenses regarding such vehicle. Husband shall indemnify and save harmless Wife from any 10ss she may sustain, including attorney fees, as s result of any default in pa~nent of the aforesaid obligations by Husband. The parties further agree to execute any vehicle ti- tles, Power of Attorney or other documents necessary to give this Paragraph full force and effect, upon request. -5- ~ ~~ ~( . , . 7. REAL ~STATE. (a) The parties aoknowledge that the marital residenoe titled in Husband's name situate at 4800 Delbrook Road, Meohaniosburq, Cumberland county, Pennsylvania has been listed for sale with a mutually agreed upon real estate broker and has been sold. At settlement, after deducting all normal settlement charges pertaining to the sa Ie of said real estate, Husband shall receive the net proceeds of sale, subject to the conditions below. As oonsideration for Wife's interest in the equitable division of. assets, sh~ shall receive from Husband the sum of Seven Thousand Five Hundred and 00/100 ($7,500.00) Dol- lars, payable as followSI (1) $4,000.00 on or before November 15, 19961 and (2) $3,500.00 no later than December 15, 1996, or within seven (7) days of completion of Husband's 401(k) loan processing, whichever occurs first. In any event, this money shall be paid to Wife regardless of whether Husband is successful in obtaining a loan against his 401(k) plan. Pending sale and settlement, it is specifically under- stood and agreed that Husband assumes sole responsibility for payment of the mortgage and all other real estate-relat- ed and household expenses, including but not limited to taxes, insurance and utilities. Further, to the extent -6- , there is any capital gains tax liability on the sale of the marital residence, Husband shall be solely respcnsible tor same. (b) Wife hereby irrevocably releases any and all rights, title and interest she may have in certain real estate being purchased by Husband, located at 4601 Londonderry Road, Harrisburg, Pennsylvania, and shall exe- cute any spousal waivers and/or all other documents neces- aary to facilitate Husband's purchase of said property. 8. PENSIONS AND EMPLOYMENT BENEFI'rs. Husband and Wife are the owners of certain pension plans and/or retire- ment plans and/or employee stock or savings plans, which they have accumulated during the course of their past and present employment. It is hereby specifically agreed that Husband and Wife each shall forever relinquish to the other his or her right, title and interest in said pension plans and/or retirement plans and/or employee stock or savings plans, as well as all other employment benefits, of the other. The parties agree to execute any and all documenta- tion necessary to effectuate the terms herein contained. Specifically included are Husband's 401(k) plan and defined pension benefit through his UGI employment. -7- J6.~\.:J ~J- ''Iv' j.; 9. CUSTODY. Custody of. the parties minor ohild, JOShUA H. Givler, shall be governed by the Order which was issued by Judge Edgar B. Bayley on August 14, 1996, entered to No. 96-3101, Court of Common ~leas of Cumberland County, Pennsylvania, or as such Order may hereafter be modified. 10. CHILD BUPPOR'r. Husband shall pay child support pursuant to the Order which has been entered in the Domestic Relations Order at Cumberland County, Pennsylvania, on July 10, 1996, pursuant to No. 631 B 93 (DR 25,498), or as that Order may be modifi.ed hereafter. In addition to any provisions which may be contained herein regarding custody and visitation, Husband and Wife shall have the following rights with respect to the child: reasonable telephone calling privileges I access to report cards and other relevant information concerning the progress of the child in schooll approval of exttaordinary medical and/or dental treatment except in the case of an emergency and provided that such approval shall not be unreasonably withheld I approval of summer camp and schools provided that such approval shall not be unreasonably withheld. 11. DEPENDENCY EXEMPTIONS FOR INCOME TAX. For purpos- es of federal and state income taxes, wife shall claim herself and Joshua M. Givler, for as lon9 as sha has primary -8- ~~ \- . physioal oustody of said ohild. The parties agree to file separate returns for 1997 and subsequent tax years. For tax year 1996, the parties shall file a joint federal tax re- turn, and shall equally divide any refund resulting there- from. Husband shall ensure that at a minimum, Wife shall be entitled to the same rofund Wife would have received had she filed separately. 12. ALIMONY. Both parties agree to make no claim for alimony or alJ.mony pendente lite now or at any future timo, or in connection with the pending divorce aotion between the parties, except that Husband shall continue to pay alimony pendente lite pursuant to the Order of Court which was issued on October 17, 1996 by Judge J. Wesley Oler, Jr., entered to No. 96-3490, Court of Common Pleas of Cumberland County. Pursuant to said Order, alimony pendente lite shal1 terminate upon receipt of the December 1996 payment by Wife. 13. COUNSEL FEE~. Husband and Wife agree to be solely responsible for payment of his or her respective attorney fees in connection with this Agreement and the pending di- Vorce action between the parties. 14. FINANCIAL DISCLOSURE. The parties have disclosed to each other and they are aware of the extent of each -9- ~ k other's income, assets, liabilities, holdings and estates. Husband and Wife confirm that by executing this Agreement each forever waives any future right to set aside said Agreement, or to defend against its Qnforcement or any portion thereof based upon the absence of such a disclosure by the oth~r party, or based upon any claim that it is inequitable, unconscionable or does not make a reasonable provision for one or the other of them. 15. BREACH. If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, inclUding legal fees and expenses, or seek such remedies or relief as may be available to him or her respectively. 16. ADDITIONAL INSTRUMENTS. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal effect have been fully explained to the parties by Max J. Smith, Jr., Esquire, attorney for Husband, arId David C. Schanbacher, Esquire, attorney for -10- * ~ Wife, and each party acknowledgas that the Agreement is fair and equitable, that full disclosure has been made by each respective party to the other, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Wife and Husband acknowledge that they have been furnished with all information relating to the financial affairs of the other, which has been requested by them respectively. 18. NO-FAULT DIVORCE. Both parties agree to execute an Affidavit of Consent and Waiver of counseling to faoili- tate entry ot a divorce decree pursuant to section 3301(C) of the Divorce Code at the expiration of ninety (90) days from the date of divorce complaint filing in the divorce proceeding instituted by Wife docketed to No. 96-3490, Court of Common Pleas of Cumberland County, Pennsylvania. 19. WAIVER OF CLAIMS AGAINS'l' ES'rATE. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relin- quishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any juriSdic- tion, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, curtesy, statutory allowance, widow's -11- tjJ ~~0 ~ allowanae, right to take property against the Will of the other, and the right to act as administrator or executor of the other's estate, and each wil1, at the request of the other, execute, 80knowledge and deliver any and all instru- ments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights and claims. 20. INCORPORATION OF AGREEMENT FOR ENFORCEMENT. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legBl representatives and assigns. This Agreement shall survive a decree of divorce between the parties in any jurisdiction and any other order which may be entared in accordance with this Agreement. In the event that a Decree of Divorce is entered in the Court of Common Pleas at Cumberland county, Pennsylvania or in the event that a Decree in Divorce is entered in any other jurisdiction, the parties agree to incorporate this Agree- ment in the Divorce Decree for purposes of enforcement. It is the specific intent of the parties to be bound by the provisions hereof in lieu of any other claim or order of support, maintenance, alimony, equitable diatribution, counsel feas, costs, maintenance of insurance, equitable relief or property settlement or with regard to any other claim tor relief which might be brought by either party -12- ~ ~ " against the other, or with regard to any other provision hereof. In the event that any final order of oourt is entered in any jurisdiotion with respeot to the parties hereto whioh is oontrary to the provisions hereof, then the rights and responsibilities of each of the parties hereto shall be relieved or adjusted to the extent necessary to oonfor.m to this Agreement. 21. ENTIRE AGREE~HI. This Agreement contains the entire understanding of the parties, and there are no repre- sentations, warranties, covenants or undertakings other than those expressly set forth herein. 22. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effec- tive only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement, shall not be construed as a waiver or any subsequent default of the same or similar nature. 23. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administra- tors, successors and assigns. -13- v~ J \:J ~\J' ~' 24. SEVERABILITY. If any term, condition, olause or provision of this Agreement shall be d~termined or deolared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be strioken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and opera- tion. Likewise, the failurEl of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the r.emaining obligations of the parties. 25. AFTER-ACOUIRED PERSONAL PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any olaim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 26. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. -14- 'AQ,'~ vr ,\0 '0' \;' .' ~. '- j'I U~ i ., , ~ till c.,; ~ ) f" I. , H.':; ~jl ..:J III (.1' " .... , , [!r . (Id ., ,:,J.. I II. r- I , ; c.;' <.J .. -:-. -,.. -J.. Q: .... 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" In ~ U ,j' t~ ) ~ ~ . < e I:l ~ .... ~ .... 0 ~ f-< o-l fI; en ~ .... ~ ~ ~ ..; ,~ '" l> ~~8~~ t. o-l en .~ ~ ~~ '" ~ .. u J ~ 8 :;, g 0 '" .. iJ Q.:i ~~~ 0 '" '" " __ en e .... <t ~ I:l!;l ~~ .." I- ~ '; t: ,.1 . ... M ." ~ :.. . .... , " ::iiJ < < <.;t-lil :3 ",'" '" 0 ~ '" ,To" ,c_ I '" ~ '" . '" ~~ I;l ~ <.; .,'" I ~ e;!'" "' '" ~~ ... .. "" - 0 8 , '" ~ I.: " I': ;;. I' C .... ~"' i:il ~ ~ .. 0 " f-o ~ t:) ~ ",en , 1:": ~ :: .. f !!l ~ 0'" .... . '" ~~ ~<~t~~ 8 !J '" . '" . - Cl l> . Z ~ I ..; ~ '" ~ Oo-l = .~ joo ~ '" r:!;l ~ o-l ~ < .... ~ ....~ ~ :> "' l;io z ,,.. b:! '" :oj .... U o-l "'u M.\Htt.. Wt~ua.t. A"'U Pt.Hkll\."l. AIIUM".~' .\1 '"'''' 126 t;"... kl'\l. ~IMtt I. !-l1l1"ft.....III.U.. ...""", 111~1 ......1111.... 171n ~.12.7.lMM t"u' 17111 5J2-6S~1 .. ~ "-7/,.1 . ,/-1 ,) ),) 'u , . . KATIIRYN E. mVI.ER. I'elilioner IN TIlE COURT OF COMMON PLEAS OF CUMBEIU.AND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW <)6-3490 CIVIL TERM LEROY E. GIVLER. Respondenl Alimony I'cndcnll.llo:/ Counsel fees! Expenses l'ETlTlON 1101~ ALIMONY I'ENI)ENT un:, COUNSEL I1EES ANI) EXl'ENSES TO TilE IIONORAlH.E. TilE JlJ()(i!'S OF TilE SAID COURT: The I'clilion of Kulhryn E. Givler by hcr attorncy. Duvid C. Schanbucher. Esquire. rcprcscnls as Illllows: I. A Compluint in Divorce was IiIcd on Junc 21. 19<J6. and wus duly served UP'lIl dclcndanl. 2. By reason of Ihc conduct of Ihc rcspondenl. petitioncr will bc pUllO considcrable expense in prcparution of her cuse in thc cmploymenl of counsel and the puymentof cosls. 3. I'elitioncr is without adcquute funds to support herself und lomcctthe costs and expenses of this litigalion and is U1lUble to maintain hcrself during thc pcndency of this action. 4. Respondenl has fuiled and rcfused to support petitioner adequately since the purties' separution. 5. Respondelll is al prescnl employcd and carns approximately thirty-live thousand ($35.000.00) dollurs net income per ycar. " WIIEREFORE. I'ctilioner respcetfully prays that your Ilonorablc Court order respondenlto puy petitioner alimony pcndenllile und to pay her counsel tccs and expenses. MARK. WEIGl.E AND PERKINS BY: ()-v-....! ( I./,....}...J..- David C. Schanbacher, Esquire Atlllrney for Petitioner 126 East King Su'cet Shippensburg.I'A 17257 (717) 532-7388 MAlfk. WJIlHl ANO I't.lH(IN~. AI JoIINI-"" '" I /l.W 1,1" I A',I 1(lr~f, '~ltH 11 'iltll'l'l r~~.IH"U.. I'A I 1)','11'" i'i: ". :-. f; C'; t- .' ~/ 'Ii ' I l:~ . . t-il ;.:.,! ',( (I)' . 'r1 ,') '... ()I'. ' It) 1-1jl C" ' . 'I,i" (..' ' I 11,1) I , C ,Il..,. I.'. '" u <n ,j -- .... ~ " !'l r....< r.... 0.... ~ ~ ",!:i .... " ~ ~~ l i.'il> ~ ... c: ~ I ""s;l ... ~ ~~8::.\~ "'''' ... 0 z~ ,~ u u Q~~'Cl u c: .... '" 0'" c: '" " ... ~ I- '~R". ~": ,~ " u '" < ~ \,; ..: ~ '" c: ,~ \l.: "" . r:: I ~~ ..... " "" 0 G I:! tIl <.; "E ~~ "'''' ... f-o I ::i~ '" . " " . , I: II< ~ r:: S "'''' u '" c:: ~ ~ ;;, Q I '" c: '" ;;; I f-08 "" .... S " ... ~~.:~~ ., ~ ... u " u ,.. 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