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'I i I ,i" I , " " " " " Ii, ".' d \, "", I I " " .. , . --------------------~~~--~*-~-~ e -----,-----"'---,----,--,--,.--"--.---.~-' , ~ . : IN THE COURT OF COMMON PLEAS : (I OF CUMBERLAND COUNTY 8 (I * I '* I : STATE OF ""\'. " PENNA. : 8 (I (I MiCHAIlL. W. CllIlW. (I ~." N () ,tI009qqq q~,i'y~~q" 19 96 ~ ., ,illllltif f Il' (I VcrslIs * il ! IlLiZABIlTHA.CHIlW. .. .. :".1 ~ Il' Pflffllllillllt . . . 8 ~ 8 DECREE IN : (I . . DIVORCE . . ~ It AND NOW, ...,....., .tkfl'?":.., .'~.f,'.. 199.7..... It Is ordered and ~ l! d d h MICllAFI W CllFW I ff ~ ~ ecree t at .......".. ..','. ...... '" ..".. .. .. ... .. .. .. ....." p alntl , . A and "" , . . . . . . . , , . , ,1\~4;:~1i~,\,1) ,I} I . \;I,Il:;~, . . . . , . . , . . . . , . . . . . . . , '. defendant. (I ~ ~ . are divorced from the bonds of matrimony, 8 . ~ (I The court retains lurlsdlctlon of the following claims which have : , ~ (I been raised of record In this action for which a final order has not yet ~ ~ been entered; ~ , I ~ (I TI,': . ~~~II,I~ . ,'~I!(! , ~(!,!d 1 ~ ~(,J1!". ~) f. ~h~, ~l ~ t:'::!'~~, ~lf'.r.l.t,",l, P.l.".b.O,l,u,t.l,o,lI, A~~':C,II!<;I~ ~ .~~c I ~ ! ~1~~~~I~~r'~tcd I~~~~'lll:,."" . , , . , . ~:' ., ,.".., ,......"., .,.., I .,.'..........,.,., : ~ ~ 1,< / ~ : n y_:), . ~ /i'tL $ ',..:( , ":1. ../ -.( I ~ . Aile.', ,~{(..'t.:',tC( r, /u.iYh~, /~...~{t';..",'Y J, I':. J ' ~~,/ ~'_/ v ~ . , 'l,(.~{)I.t{ /" ,.'2'd' )b 10, I~,' t _ ____ _ __-.'.'. _'~ .'. ~~. ,*, ,*, '.' ,*:.,~:,~:*.~~Ol:,n:.r,:"w.:~ . . Ct\div\dis\mda,che ~ITAL DIBBOLtrrION AGRBRMBNT TIIIS AGRBBMEN'l', made this ~ r day of I ~.,.f , 199', by and between MICHAEL W, CHEW, of Dauphin County, Pennsylvania, hereinatter referred to as "HUSBAND", and ELIZABETH A. CHEW of CUmberland County, Pennsylvania, hereinafter referred to as "WIFE". WITNBSSETH: WHBRBAS, the parties hereto are Husband and Wife, having been married January 19, 1973; and WHBRBAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart trom one another, and are desirous of settling fully and finally the respective financial and property rights and obligation as between each other, including, without limitation by specifica- tion: The settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of real and personal property; and in general, the settling of all matters between them relating to any and all claims and possible claims by one against the other or against their respective estates. NOW, THERBFORB, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be " . kept, the parties heretofore, intending to be legally bQund and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as tollows: 1, SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem tit, free from any control, rp.straint or interference whatsoever by the other, Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions shall not be taken to be an admission on the part of either lIusband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interfer- ence, 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 in all respects as if he or she were single and unmarried, 3, AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: T his Agreement shall not be considered to affect or bar the 'right of Husband or Wife to a limited or absolute divorce on lawful grounds . . as such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and not shall be deemed to be a condonation on the part of either party hereto of any act or acts on the part ot the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 4, INCORPORATION IN DIVORCE DECREE: It is further agreed, covenanted and stipulated that this Agreement, or the essential parts hereof, shall be incorporated in any decree hereinafter entered by any court of competent jurisdiction in any divorce proceedings that have been or may be instituted by the parties for the purpose of enforcing the contractual obligations of the part ies , This Agreement shall not be merged in any such decree but shall in all respects survive the same and be forever binding and conclusive upon the parties, 5, BFFECTIVH DATE: The effective date of this Agreement shall be the "date of execution" or "execution date," defined as the date upon which it is executed by the parties if they have each executed this Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 6. DISTRIBUTION DATE: The transfer of property, funds 3 . and/or docum~nts provided for herein, shall only take place on the "distribution" date which shall be defined as the date ot execution of this Agreement unless otherwise specified herein. However, the support and/or alimony payments, if any, provided for in this Agreement shall take effect as set forth in this Agreement, 7. MUTUAL RELEASE: HUSBAND or WIFE each do hereby mutually remise, release, quit, claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of any from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and where so ever situated, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities as such other or by way of dower or courtesy, or claims in the nature of dower or courtesy of widow's or widower's rights, family exemption of 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 a testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania (b) any State, Commonwealth or territory of the United States, or (c) any country or any rights which either party may have or at any 4 . time hereafter shall have for past, present or future support or maintenance, alimony, pendente lite, counsel fees, property of division, costs or expenses, whether arising as a result of the marital relations or otherwise, except, all rights and agreement and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE to give each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, peraonal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreemc.nts and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. a. ADVICE OF COUNSEL: The provisions of this Agreement and its legal effect have been fully explained to the lIusband by his attorney, L. Rex Bickley, Esquire. Wife has been advised that she should seek legal counsel, The parties acknowledge that they fully understand the facts and have been fully informed as to their legal 5 rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that is being entered into freely and voluntarily, atter having received such advice and with such knowledge and 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. The parties further acknowledge that they have each made to the other a full accounting of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purpose of this Agreement, Each party agrees that he or she shall not at any future time raise as a' defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement with the exception of disclosure that may have been fraudulently withheld, 9. PERSONAL RIGHTS: Wife and Husband, at all times hereafter, may and shall live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any buoiness, occupation, profession or employment which to him or her may seem advisable. Wife and husband shal.l not molest, harass, disturb or malign each other or 6 the respective families of each other or compel or attempt to compel the other to cohabit or dwell, by any means or n any manner whatsoever, with him or her, 10. WARRANTY AS TO EXISTING OBLIGATIONS: Each party repre- sents that they have not heretofore incurred or contracted for any debt or liability or obligatJ,on 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 indemnity and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been ." incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 11, WARRANTY AS TeL-FUTURE OBLIGATIONS: Husband and Wife covenant, warrant, represent and agree that with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatso~ver for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 12, PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furn- iture and furnishings, and all other articles of personal property 7 which have heretotore been used by them in conunon, and neither party shall made any claim to any such items which are now in the possession or under the control of the other, Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect of this paragraph upon receipt, By these presents, each ot the parties hereby specifi-cally waives, releases, renounces and forever abandons whatever claim he or she may have with reepect to any of the above items which have become the sole and separate property of the other from the date of execution hereof. The itema of perso~al property 1 isted in Schedule A shall become the property of the Husband and the Wife hereby agrees to convey said property immediately. 13. AFTER-ACOUIRIlD PROPIlR'ry: Each of the parties shall hereafter own and enj oy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same liS fully and affectively, in all respects and for all purposes as though he or she were unmarried. 14. REAL ESTATE: The parties are j oint owners of real estate located at 405 South Enola Drive, Ilnola, Cumberland County, pennsyl vania. The Husband hereby agrees to convey any all interest in the marital home to the Wife. 8 This real estate is encUmbered with a mortgage held by National City Mortgage in the remaining principal amount of $65,791.68, Wife hereby agrees to assume all responsibilities for the payment of this mortgage and further agrees to hold husband harmless with respect to this obligation. 15. ~LD SUPPORT: The Husband hereby agrees to pay support for his child, namely, Jennifer Chew, in accordance with Domestic Relations Laws and Guidelines of the Commonwealth of Pennsylvania. Any change or modification with the support shall be in accordance with the support and divorce laws of the Commonwealth of Pennsylvania. 16. RETIREMENT ACCOUNTS AND PENSION PLANS: The Wife is presently the owner of a pension with the Commonwealth of Pennsylvania, Department of Transportation. The Husband hereby agrees to waive any right he may have to the marital portion of that pension. 17. AUTOMOBILES: The parties are the owners of the following vehicles: 1987 Ford Ranger truck and 1986 Chevy Cavalier The Husband hereby agrees to transfer his interest in the 1986 Chevy Cavalier to the Wife which shall become solely her property. The Wife hereby agrees to transfer her interest in the 1987 Ford Ranger truck to the Husband which shall be come solely his property. Both parties agree to execute any documents necessary to effectuate this transfer. 9 18. APPLICABILITY OF TAX LA.~ TO PROPBRTY TRANSFBRS I The wife shall be responsible for any capital gain obligations with respect to the sale of the marital residence and responsible tor any other taxes on the real estate. 19. BFFBCT OF DIVORCB DECRBB: The parties agree that except as otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 20, BRBACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her~ election to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement, 21, WAIVER OF PAYMBNT OF LBGAL FEES: Wif~ shall be responsible for payment of her legal fees. Husband shall be responsible for payment of his legal fees. 22, ALIMONY AND ALIMONY PBNDENTB LITE: Husband and Wife do hereby waive, release and give up any other rights they may respectfully have against the ocher for any alimony, support or maintenance, It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any additional support from the other 10 party, except as provided herein, 23, MUTUAL CONSENT DIVORCEt The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and they both consent to the entry of a decree in divorce pursuant to ~3301(c) of the Pennsyl- vania Divorce Code, Act 26 of 1980, aa may be amended (herein referred to as the Code), Accordingly, both parties agree to execute such consents, affidavits, or other documents and to direct their respective attorneys to file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said ~3301(C) of the Code, Upon request, to the extent permitted by the law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such di vorce, 24, AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 25, ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time at the request of the other, execute, acknowledge and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 11 :.16, VOID CLAUSES I If any term, condition, clause or provision lit this Agreement shall be determined or declared to be void or inval id in law or otherwise, then only that term, condition or clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, eftect and operation, 27. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and Agreed by and between the parties hereto that each paragraph hereot shall be deemed to be a separate and independent Agreement, 28, MODIFICATION AND WAIVER: A modification or waiver of any ot the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement, The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent defaults of the same or similar nature, 29. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no affect whatsoever in determining the rights or obligations of the parties. 30. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 12 31. MUTUAL COOPERATION: Each party shall, at allY time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and ettect to the provisions of this Agreement, 32. APPLICABLE LAW: under in accordance with This Agreement shall be construed the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 33. OTHER DOCUMENTATION: Wife and Husband covenant and agree that they will forthwith (and within at least ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary effectuation of this Agreement. 34. NO WAIVER OF DEFAULT: full force and effect unless or desirable for the proper This Agreement shall remain ill and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performanr.e of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provisi'c,n hereof be construed as a wai.ver of any subsequent default or breach of the same or similar nature, nor 13 shall it be construed am a waiver of strict pertormsnce of any other obligations herein, 35, ENFORCEMENT OF AGREEMENT: It either party breaches any provision ot this Agreement, the other party shall have the right, at his or her selection, to sue for damages for such breach or to require specific performance. The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her, 36, SEVERABILI'l'Y: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure 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, void or alter the remaining obligations of the parties, 37, HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement, nor shall they affect its meaning, construction or effect, 14 i'r. " ~, a) ~~ "'l ~j:". iIJ !~S' (')~J ,..,~ ( "/'1 Po.'l' "'" ... r;_I~ 9', :)~-~ , . ) N :-';'1/ [:.)". ("j ..1.... I' t-.,. , U' ,1,,./) Ci.,!.I.' .., ~I; ,,' ,,) ~1.. ..t ft' ~ r-' ..oS C' <J , " y ;'1 'li , i' , , , , 'i , 'i'" 'I I , ',1 '1/ ;' I , 1/ ;,1 , , " " , p , , I " " 'J , i\ Ii , 'I, t". Ii , , , " " '., ,LI i, '; \, '; I , ,I , '1 ' " , MICHABL W. CHBW, Plaintiff vs. IN THB COURT OF COMMON PLBAS Oll' CUMBBRLAND COUNTY, PBNNSYLVANIA NO. Ill.. 'fObfl (!.,~':I Tj.-. BLIZABBTH A. CHBW, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Michael W. Chew, 'through his attorney, L. Rex Bickley, Esquire, who hereby files the following Complaint in Divorce: 1. The Plaintiff, Michael W. Chew, is an adult individual who presently resides at 818 S. Humer Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant, Eli2abeth A. Chew, is an adult individual whose residence is 405 S. Bnola Drive, Enola, Cumberland County, Pennsylvania 17025. 3. The pprties were married on January 12, 1973, in Harrisburg, Dauphin County, Pennsylvania. 4. There have been no prior actions of divorce or annulment between the parties. 5. The Plaint if f has been advised of the availability of counselling and the right to request that the Court require the parties to participate in counselling. 6. The Defendant is not a member of the Armed Services of the United"States or any of its allies. ~ ~ eo ~ ~I.i ..... -. ).. :> \) "I ~ ~ . <) " " $ '. 1 III , , ; ~ .' ! I " " '" ""~, "'. .:r .... (r:. .:J ... I~' , ~.~ ) & : li,.~ J' :'.: . ,)';' 1- ~I' t:,)... )~t ~f..: 'l,.j l." In "'J - )" If ~ ' l:;..l ,,' r.;J f~' 0;..1 .:IIE " ~ VI lfj ., '" u ,. I, ,"I , , " ,. , , "'I "", '.11 " , , '.'j , " " fi ;,1'/;1', , i, ,I " . I I ': ',.j , , I.", I' I, " " .' , 'I. '" " " , " , '. .. ," " ," " ',,1' , , " I, , , ,In, , !' 'y " 'I '" , >, , ,I )Ir' , , I ii " , , , " ~ 0:) ~ , ~ ("', t~ 60 ~~4. i, , :,r..: ~':J~ij I' " ( I , h "'" -; ,. I" I;..!;;,! ", N :'(<l) -u. N ({~~ " 15:'" f..!'l " , , . ~. :;;J , .. oCI: .9. " a " ~ \; I' ,/ , , , " , , ., , , " , , " , " 1;1 " I , ., " , , I.," , , , ,,' .. ), , 'I ~ en' E; ~ '" .. r!\ ~~ Cl:l .' .( 0'. ?5. (.)~t ~?' I]~ \, ('.1 :/,to " oN .l~ f' ,"J'" _ ii:l\ ' c.n ,',i :;.; , I.. ~ '~, , , ~ 1-' c:r " " " ,', .' 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