HomeMy WebLinkAbout96-04864
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, msde this /6l:-'dey of ~(,J""'''l ' 1997, by and
between SCOTT G. SNYDER, hereinafter callad "Husbend", end JILL R. SNYDER,
herelnefter called "Wife".
WITNESSETH:
WHEREAS, Husband and Wife were legally married on September 28, 1990:
WHEREAS, two chlldrsn were born of this marriage, Mason G. Snyder, born
October 22, 1991, and Jacob A. Snyder, born Septamber 11, 1995;
WHEREAS, differences have arlsF,ln between Husband and Wife In consequence
of which they desire to live saparata and apart from each other; and
WHEREAS, Husband and Wife desire to settla and determine their rights end
obligations.
NOW THEREFORE, In consideration of the premises end covenants contained
herein, It Is agreed by and between the parties hereto that:
1, SEPARATION.
It shall be lawful for eech party at all times hereafter to live separate and apart
from each other et such plecs as he or she from time to time shall choose or deem fit.
The foregoing provision shall not be taken as an admission on the part of either party
of the lawfulness or unlawfulness of the causes laadlng to their living apart.
2, INTERFERENCES.
Each party shall be free from Interference, authority and control by the other,
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as fully as If ha or she were single and unmarried, axcept as may ba necessary to
carry out the provisions of this Agreement. Neither party shall molest or attempt to
endeavor to molest the other, or In any way harass or malign the other, nor In any
other way Interfere with the peaceful existence, separate and apart from the other.
Each of the parties hereto completely understand and agree that neither shall
do or say anything to the chlldron of the parties at any time which might In any way
Influence the children adversely against the other party.
3. DIVISION OF REAL PROPERTY.
Tha parties wera the owners of real estate titled as tenants by the entireties
located at 604 Eighth Street, New Cumberland, Cumbllrland County, Pennsylvania.
The pertlas have sold and sattled on said property and, after the paymant of all liens
and costs, have equelly divided tha net proceeds. The parties agree that, In the event
capital gain arises from the sale, they will share equally the gain.
4, QIYlSION OF PERSONAL PROPERTY.
The parties hereby have divided their major Items of personal property Including,
but not limited to, household goods and furnishings and parsonal effects as follows:
Wife shall become the sole owner and Husband shall waive eny claim to the
Items more speclflcelly set forth on Exhibit" A". Husband shall become the sole
owner and Wife shall waive any claim to the Items more specifically set forth on
Exhibit "B".
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Any Items of personel property not speclflcelly Identified on Exhibits "A" and
"B", shell be divided es the parties shell agree,
6. CUSTODY AND VISITATION,
The pertles shell share legal and physical custody of their minor children, Mason
G. Snyder, born October 22, 1991, and Jacob A. Snyder, born Septembar 11, 1996,
on an equal basis. The parties shall agree upon and datermlne the equally shared
custody schedule at the time that either party vacates the merltal residence.
6. CHILD SUPPORT.
Given the shared custody arrengement, tha parties egrae that thay will equally
share expenses relating to the children to Include, but not be limited to, clothing, day
care and medical expenses not covered by Insurance. This arrangement shall continue
so long as the parties equally share custody. In addition, the parties shall share
equally the cost of any Increase In the cost Wife pays for medical coverage for the
minor children over and above the amount Wife pays at the time of the entry of this
Agreement consistent with Paragreph 7 hereof.
7. MEDICAL INSURANCE,
Wife agrees that she shall carry the minor children on medical coverage es
provided by her employer,
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Wife shell retain 8S her 8010 and separato property. her IRA with 106, Eeeh party
walvas any claim they may have to the other'~ IRA.
11. MARITAL DEBTS.
Husband shall retain os his sole end separate obligation the following debts:
1. Sears. Account No. 114 84111 46442 7 with on approximate
balance of $400.00;
2. J,C. Penney. Account No. 072 722 791 01 with en epproxlmate
belance of $350.00; and
3. First Card Visa . AccO\lI1t No. 4250 462 635 664 with an
approximate balance of $400.00.
Wife shall retain as her 5010 and separato obligation the following debts:
1, Texaco. Account No. 138305652828001 with an approximate
balance of $100.00:
2. Boscoy's. Account No. 0039'17290 with an approximate balance
of $300.00: and
3. PNC Mastercard. Account No. 54470500 0107 9768 with an
approximate balance of $1/000,00.
Each party shall Indemnify and hold the other harmless on the debts for which
thay have ass\Jmad sole responsibility. All t\lrther da~ts incurred by the parties shall
" ba thalr Individual responsibility.
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, 2, BANK ACOOUNT.S..
The parties have divided to their mutual satisfaction, ell bank accounts held by
them during their marriage. Any accounts previously divided, shnll ramaln the sole
end seperate property of the perty In possession of the said eccount.
13, BREACH.
If either party breaches eny provision of this Agreement, the other perty shall
have the right, et his or her election, to sue for damages for BlICh breach. The party
breaching this contract shall be responsible for the payment of legal fees and costs
Incurred by the other In enforcing his or her rights under this Agreement, or seeking
such other remedy or relief as may be available to him or her.
14. FULL DISCL05UFU;.
Husband and Wife each reprosont and warrant to the other that he or she has
made a full and complete disclosure to the other of nil nssots of any nature
whatsoever In which sllch party of every type whatsoever and all other facts relating
to the subject matter of this Agreement.
16. AQ.QITI 0 NAI"J~tmtM.E.I~.L
Each of the pmtles shall on domand execute and deliver to the other any deeds,
bills of sele, assignment, consents to change of bepeflclary on Insurance policies, tax
returns and other docilments and do or callsed to be done any other oct or thing that
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he or sho may now have or hereafter aoqulre, under the present or future laws of any
Jurlsdlotlon, to share In the property or tho ostato of tho othor as 0 rosult of tho morltal
relatlonshlp,lncllldlng wlthoutllmlllltlon, dowor, ourtsy, statutory allowanco, widow's
allowanco, right to tako In Intostacy, right to tako against tho Will of tho othor, and
right to oct os mJmlnlstrutor or oxoclItor of tho othor's 05tOtO, and oach will, to tho
roquost of the othor, oxecuto, acknowledge, and dollvor any Elnd all Instruments which
may bo nllcossary or advlsablo to carry Into offoct this mutual walvor and
rollnqulshment of all sllch Intorosts, rights and claims.
19. BfPRESENTATION.
It Is rocognlzed by the partllls hereto that Scott G. Snyder Is represanted by
John J. Connolly, Jr., Esquire and Jill R. Snydor Is represllnted by Bruce F, Bratton,
Esquire. It Is fully understood and agreod that by the signing of this Agroomont, each
party lmdorstflnds tho logallrnpact of this AgreolTlnnt Emd further acknowledges that
tho Agreemont Is fair and roasonable and each party Intends to be legally bO\lnd by
tho terms hereof.
20. Y,O.11LNTARY EX~CUTlON.
The provisions of this Agreomont are fully understood by both parties and oach
party acknowlodges that this Agreement I~ fair alld equitable, that It Is being entered
Into volllntarlly ond that It Is not the rosult of allY duress or llndue InfllJencEl.
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each paragraph hereof shall be deemed to be a seperote and Independent COVenant
and agreement.
26. ~OID CLAUSES.
If ony term. condition, clause, or provision of this Agrccment sholl be
determined or declared to be void or Invnlld In law or othorwlso, thon only thot torm,
condition, clause or provision sholl bo stricken from this Agreomont and In all other
resPQcts this Agreemont shall be valid and continue In full force, effoct and operation.
27, gJUBY~Qf_.P.il/BEJ;.
It Is tho Intention of the parties that tills Agreoment shall sllrvlve any action for
divorce which may bo InstltlJlod or prOSCclltod by elth(Jr party and no order, Judgement
or decree of divorce, tempormy, final or permanont, shall affect or modify the flnanclol
terms of this Agreement. Tills A{Jrooment shall be modo a part of any such Judgment
or decree of final divorce.
28. Q1Y_QB.ill:-8Cllil.N,
The parties 5h<1I1, at the explrotlon of nlnGty (90) clays from tho service of tho
Complaint In Divorce, execute all documents necessary to fln<illzo tile divorce action
Indoxed to number 96 . 4864 Civil, 111 tho Court of Common Ploas, Cumberland
County, Pennsylvania, as well as Affidavits of Consent and WalvGrs of Counsollng end
Welvers of Notice of Intention to Requost Entry of II Divorce Decrc>o.
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v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-41164
IN DIVORCE
JILL R, SNYDER,
Plaintiff
SCOTT G. SNYDER,
Defendant
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY I
Transmit the record, together with the following information, to
the Court for entry of a Divorce Decree I
1, Ground for divorce I Irretrievable breakdown under
Section 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint I By Acceptance of
Service executed by John J. Connelly, Jr., Esquire on
September 13, 1996 on behalf of the Defendant.
3. (a) Date of execution of the Affidavit of Consent required by
Section 3301 (c) of the Divorce Code I By Plaintiff on
January 16, 1997 and by Defp-ndant on January 13, 1997,
(b) Date of Execution of the plaintiff's Affidavit required
by Section 3301(d) of the nivorce Code: Not applicable.
(c) pate and manner of service of Notice of Intention to file
Praecipe to Transmit Record, a copy of which is attached,
if. the Decree is to be entered under Section 3301(c) of
the Divorce Code I Not applicable _C Waiver of Notice of
Intent executed by Plaintiff on January 16, 1997 and by
Defendant on January 13, 1997 and filed herewith.
4, Related claims pending I None raised by pleadings.
6, Date and manner of service of Notice of Intention to file
Praecipe to Transmit Record, a copy of which is attached, if
the Decree is to be entered under Section 3301(d) (i) of the
Divorce Code I Not applicable,
Respectfully subm~tted,
/
MARTS~ N. ( _
By ~uce F. Bratton, Esquire
Attorney I.D. No. 23949
2515 North Front Street
P. 0, Box 12106
Harrisburg, PA 17108-2106
(71 7) 236-4241
Attorneys for Plaintiff
Date I ~.I ~,u44'~ 11
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JILL R. SNYDER,
Plaintiff
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
NO, 1~' q frc 4- (t~~l
IN DIVORCE
SCOTT G. SNYDER,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against
the claims set fort.h in the following pages, you must take prompt
action, You are warned that if you fail to do so, the case may
proceed against you and a Decree of Divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children,
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
One Courthouse Square, Carlisle, Pennsylvania,
Ir YOU DO NOT rILB A CLAIM rOR ALIMONY, DIVISION or PROPBRTY,
LAWYBR'S rBBS OR BXPENSES BErORE A DIVORCE OR ANNULMBNT IS GRANTBD,
YOU MAY LOBB THB RIGHT TO CLAIM ANY or THBM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. Ir YOU DO
NOT HAVE A LAWYER OR CANNOT AFPORD ONE, GO TO OR TELEPHONE THE
OPPICB SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
'l'elephone: (71'7) 240-6200
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
Uated ha sido demandado en la Corte. si desea defenderse de
las quejas expuestas en las p6ginas siguientes, debe tomar acci6n
con prontitud. Se le avisa que si no se defiende, el caso puede
JILL R. SNYDER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
NO,
IN DIVORCE
SCOTT G. SNYDER,
Defendant
COMPLAINT UNDER SECTIONS 3301(c) AND-ldl
OF TilE DIVORCE CODE
Count I
1. Plaintiff is Jill R, Snyder, who currently resides at
504 Eighth Street, New Cumberlalld, Cumberland County, Pennsylvania.
2. Defendant is Scott G. Snyder, who currently resides at
504 Eighth Street, New Cumberland, Cumberland County, Pennsylvania.
3, Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six months immediately previous to
the filing of this Complaint,
4. Plaintiff and Defendant were married on or about
September 28, 1990 in Lewisberry, York County, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties,
6, Plaintiff has been advised of the availability of
marriage counseling and that she may have the right to request that
the Court require the parties to participate in counseling.
7, Plaintiff avers as the grounds upon which this action is
basedl
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